GDFS TRADE CLIENT SERVICE AGREEMENT

01ABOUT GDFS

GDFS provides financial services in accordance with the authorisations applicable under its Australian Financial Services Licence.

The particular services and financial products available to you may depend on your account type, client classification, country or region of residence, regulatory requirements and the services made available by GDFS from time to time.

Nothing in this Agreement should be interpreted as providing a financial service or financial product that GDFS is not authorised to provide.

02ELIGIBILITY

To open and maintain an account with GDFS, you must:

• be legally capable of entering into this Agreement;
• satisfy all applicable identification and verification requirements;
• provide accurate, complete and current information;
• satisfy any eligibility, jurisdictional or client-classification requirements imposed by GDFS; and
• not be prohibited from receiving the relevant services under applicable law.

GDFS may accept or reject an application at its discretion, subject to applicable law.

Opening an application does not guarantee that an account will be approved.

03IDENTITY VERIFICATION AND KYC

GDFS may require information and documents necessary to verify your identity, address, source of funds, source of wealth, tax status, beneficial ownership and other information required for regulatory or compliance purposes.

We may use third-party verification providers to assist with these processes.

You agree to provide requested information promptly and to notify GDFS if any information previously provided becomes inaccurate or changes materially.

GDFS may restrict, suspend or refuse access to an account until required verification procedures have been completed.

04SERVICES

Subject to your eligibility and the services available to your account, GDFS may provide access to financial products and services authorised under its Australian Financial Services Licence.

Available products and services may vary from time to time.

Information displayed on the GDFS website or through a trading platform does not mean that every product or service is available to every Client.

Certain services may be provided through third-party financial institutions, execution venues, liquidity providers, custodians, technology providers, market-data providers or other service providers.

05TRADING PLATFORMS

GDFS may provide Clients with access to one or more trading platforms, including:

Finger Trader; and

MetaTrader 4 (MT4).

Additional platforms or digital services may be introduced from time to time.

The availability of a particular platform, financial product, market or functionality depends on the Client's account type, jurisdiction and the services made available by GDFS.

Finger Trader and MT4 are separate technology platforms and may have different functions, market coverage, execution arrangements, technical requirements and availability.

Access to one platform does not necessarily entitle a Client to access another platform.

GDFS may change, add, remove, suspend or replace a trading platform where reasonably necessary for operational, regulatory, security or commercial reasons.

06ELECTRONIC TRADING

You acknowledge that trading through an electronic platform involves technological risks.

These may include:

• internet interruption;
• hardware or software failure;
• communication delays;
• market-data delays;
• system maintenance;
• third-party infrastructure failure;
• cybersecurity incidents; and
• other circumstances outside the reasonable control of GDFS.

GDFS does not guarantee that any platform will operate continuously or without interruption.

Where reasonably possible, GDFS will take appropriate steps to maintain the availability and security of its services.

07ACCOUNT SECURITY

You are responsible for maintaining the confidentiality and security of your account credentials, passwords, authentication methods and devices.

You must not permit another person to access or operate your account unless specifically authorised by GDFS.

You must immediately notify GDFS if you believe:

• your account has been compromised;
• your credentials have been disclosed;
• an unauthorised transaction has occurred; or
• there has been any other security incident affecting your account.

GDFS may temporarily restrict an account where we reasonably believe this is necessary to protect the Client, GDFS or another person.

08ORDERS

Orders submitted through a trading platform are subject to applicable market rules, trading conditions, execution arrangements and product terms.

Submitting an order does not guarantee that the order will be executed.

An order may be:

• accepted;
• rejected;
• partially executed;
• cancelled;
• delayed; or
• otherwise handled in accordance with applicable market conditions and execution arrangements.

Factors affecting execution may include liquidity, market volatility, trading hours, price movements, technical conditions and the availability of relevant counterparties or execution venues.

09PRICES AND MARKET INFORMATION

Prices, quotations, charts, market data and other information displayed through GDFS services may be obtained from third-party sources.

Prices displayed on a platform may differ from prices available through another venue or data provider.

Unless otherwise expressly stated, market information is provided for informational purposes and should not be treated as a guarantee of execution at a particular price.

Market data may be delayed, interrupted, corrected or withdrawn.

10DEPOSITS AND WITHDRAWALS

Where funding services are available, Clients must use payment methods accepted by GDFS.

GDFS may require that deposits and withdrawals be made through an account or payment method held in the Client's own name.

Third-party payments may be rejected or subject to additional verification.

Processing times may vary depending on:

• the payment method;
• financial institutions involved;
• compliance reviews;
• currency;
• jurisdiction; and
• other operational circumstances.

GDFS may request additional information before processing a withdrawal where reasonably required for security, fraud prevention, anti-money laundering or other regulatory purposes.

11CLIENT MONEY

Where GDFS receives or holds Client money, such money will be handled in accordance with applicable Australian laws, regulatory requirements and the terms applicable to the relevant service.

The treatment of Client money may vary depending on the product, transaction and Client classification.

Clients should review the relevant disclosure documents before depositing funds or entering into transactions.

12FEES AND CHARGES

You agree to pay all applicable fees, commissions, spreads, financing charges, market-data charges, platform charges, transaction costs and other charges applicable to your account or transactions.

Applicable fees may be disclosed through:

• the GDFS website;
• the relevant trading platform;
• a fee schedule;
• product documentation;
• account documentation; or
• other disclosure provided to you.

GDFS may amend fees and charges from time to time in accordance with applicable law and any notice requirements.

13CURRENCY CONVERSION

Where a transaction, deposit, withdrawal, fee or settlement requires conversion between currencies, a currency conversion may be applied.

The applicable exchange rate may include conversion costs or adjustments.

Currency movements may affect the value of your account, investment or transaction.

14CLIENT RESPONSIBILITIES

You are responsible for:

• understanding the products and transactions you enter into;
• monitoring your account;
• maintaining sufficient funds where required;
• reviewing confirmations and account information;
• maintaining accurate contact details;
• protecting your account credentials; and
• complying with applicable laws and regulations.

You must not use GDFS services for unlawful, fraudulent, manipulative or abusive activity.

15FINANCIAL RISK

Financial products involve risk.

The value of an investment or position may rise or fall and you may lose some or all of the money committed to a transaction.

Certain products may involve additional risks, including leverage, liquidity risk, market volatility, counterparty risk, currency risk and technology risk.

Past performance is not a reliable indicator of future performance.

Before entering into a transaction, you should consider whether the relevant product is appropriate for your circumstances and review all applicable disclosure documents.

Where appropriate, you should obtain independent financial, legal and tax advice.

16GENERAL INFORMATION

Unless expressly stated otherwise, information made available through the GDFS website, Finger Trader, MT4, market commentary, educational materials or other communications is general information only.

It does not take into account your individual objectives, financial situation or needs.

Nothing displayed through a platform should be interpreted as a guarantee of investment performance or future results.

17THIRD-PARTY SERVICES

GDFS may use third-party providers in connection with its services.

These may include:

• technology providers;
• market-data providers;
• banks;
• payment providers;
• liquidity providers;
• execution venues;
• custodians;
• identity-verification providers;
• cloud infrastructure providers; and
• other financial or technology service providers.

The availability of services provided by third parties may be affected by circumstances outside the reasonable control of GDFS.

References to or integration with a third-party service do not necessarily constitute an endorsement of that provider or its products.

18FINGER TRADER

Finger Trader is a digital trading technology platform that may be made available to eligible GDFS Clients.

The availability of particular markets, products, order types, data or functionality through Finger Trader depends on the services enabled by GDFS and relevant third-party providers.

Finger Trader technology may be supplied or supported by third-party technology providers.

The availability of Finger Trader does not change the legal identity of the entity providing the relevant financial service to the Client.

19METATRADER 4

MetaTrader 4 ("MT4") is third-party trading software that may be made available to eligible GDFS Clients.

MT4 is a technology interface and does not itself provide financial services to the Client.

Trading through MT4 remains subject to this Agreement, applicable product terms and the execution arrangements established by GDFS.

MetaTrader and MetaTrader 4 are trademarks associated with their respective owner(s). GDFS does not claim ownership of the MetaTrader technology.

20SUSPENSION OF SERVICES

GDFS may restrict or suspend access to an account or service where reasonably necessary, including where:

• required by law or a regulator;
• identity verification is incomplete;
• fraud or unauthorised activity is suspected;
• there is a cybersecurity concern;
• the Client breaches this Agreement;
• there is insufficient information to satisfy compliance obligations;
• a third-party service becomes unavailable; or
• continued access could create material operational, financial, legal or regulatory risk.

Where appropriate and legally permitted, GDFS will provide notice of such restriction or suspension.

21TERMINATION

You may request closure of your account subject to settlement of outstanding transactions, fees, obligations and any required compliance procedures.

GDFS may terminate the Client relationship in accordance with applicable law and the terms of this Agreement.

Termination does not affect rights or obligations arising before the effective date of termination.

22SERVICE AVAILABILITY

GDFS aims to provide reliable access to its services but cannot guarantee uninterrupted availability.

Services may be temporarily unavailable due to:

• scheduled maintenance;
• emergency maintenance;
• market closures;
• technology failures;
• telecommunications failures;
• cybersecurity events;
• third-party outages;
• government action;
• natural disasters; or
• other circumstances beyond reasonable control.

23LIMITATION OF LIABILITY

Nothing in this Agreement excludes, restricts or modifies any right or remedy that cannot lawfully be excluded under applicable law.

Subject to those rights, GDFS will not be responsible for losses caused solely by circumstances outside its reasonable control, including failures of telecommunications networks, third-party infrastructure, market-data providers or external trading venues.

Nothing in this Agreement excludes liability where such exclusion would be prohibited by law.

24INDEMNITY

To the extent permitted by law, you are responsible for losses, costs or liabilities reasonably incurred by GDFS as a direct result of:

• your material breach of this Agreement;
• fraudulent or unlawful activity conducted through your account;
• information that you knowingly provide which is materially false or misleading; or
• your unauthorised use of GDFS services.
• This clause does not apply to the extent that the relevant loss was caused by the negligence, fraud, wilful misconduct or breach of law by GDFS.

25PRIVACY

GDFS collects, uses, stores and discloses personal information in accordance with applicable privacy laws and the GDFS Privacy Policy.

Information may be shared with service providers, financial institutions, regulators or other parties where necessary to:

• provide services;
• process transactions;
• verify identity;
• prevent fraud;
• meet legal obligations; or
• protect legitimate business and security interests.

Please refer to the GDFS Privacy Policy for further information.

26ELECTRONIC COMMUNICATIONS

You consent to receiving notices, statements, confirmations, disclosures and other communications electronically.

Electronic communications may be provided through:

• email;
• the GDFS website;
• Finger Trader;
• MT4;
• your Client portal; or
• another electronic communication method designated by GDFS.

You are responsible for maintaining current contact information.

27INTELLECTUAL PROPERTY

All intellectual property associated with the GDFS website, branding, software, documentation and content remains the property of GDFS or the relevant third-party owner.

Nothing in this Agreement transfers ownership of any intellectual property to the Client.

You receive only the limited right to use the relevant services for their intended purpose.

28PROHIBITED CONDUCT

You must not:

• use the services for unlawful purposes;
• attempt to gain unauthorised access to systems;
• interfere with platform operation;
• introduce malicious software;
• misuse market data;
• engage in fraudulent or manipulative activity;
• misrepresent your identity; or
• use another person's account without authorisation.

GDFS may investigate suspected prohibited conduct and take reasonable protective action.

29TAX

You are responsible for determining and satisfying your own tax obligations arising from your account, investments or transactions.

GDFS does not provide tax advice unless expressly authorised and agreed to do so.

Tax treatment varies between jurisdictions and individual circumstances.

You should obtain independent tax advice where appropriate.

30CONFLICTS OF INTEREST

GDFS maintains arrangements designed to identify and manage conflicts of interest in accordance with applicable regulatory requirements.

A conflict may arise between GDFS, a Client, another Client or a third-party service provider.

Where required, relevant conflicts will be managed or disclosed in accordance with applicable law and GDFS policies.

31COMPLAINTS

If you have a complaint regarding your account or a service provided by GDFS, please contact us using the contact information below.

GDFS will handle complaints in accordance with applicable Australian regulatory requirements and its internal dispute resolution procedures.

Where applicable, information regarding external dispute resolution options will be provided to eligible Clients.

32CHANGES TO THIS AGREEMENT

GDFS may amend this Agreement where reasonably necessary to reflect:

• changes in law or regulation;
• changes to financial products or services;
• technology changes;
• operational requirements; or
• changes to third-party arrangements.

Where required by law or where the change materially affects your rights, GDFS will provide appropriate notice.

Your continued use of the relevant services after an amendment takes effect constitutes acceptance of the amended Agreement, to the extent permitted by law.

33SEVERABILITY

If any provision of this Agreement is found to be invalid or unenforceable, the remaining provisions will continue in effect to the extent permitted by law.

34NO WAIVER

A failure or delay by GDFS to exercise a right under this Agreement does not constitute a waiver of that right.

35GOVERNING LAW

This Agreement is governed by the laws applicable in New South Wales, Australia.

Subject to any mandatory rights available to you under applicable law, the parties submit to the jurisdiction of the courts of New South Wales and the Commonwealth of Australia.

36OTHER DOCUMENTS

This Agreement should be read together with any documents applicable to your account or the relevant financial service, which may include:

• Financial Services Guide;
• Product Disclosure Statement;
• Target Market Determination;
• Risk Disclosure;
• Privacy Policy;
• Fee Schedule;
• Website Terms of Use;
• platform-specific terms; and
• other disclosures provided by GDFS.

Where there is an inconsistency, applicable law and any product-specific document that is legally required to prevail will take precedence.

37CONTACT US

GDFS Trade International Pty Ltd

ABN 82 607 000 779

Australian Financial Services Licence No. 480291

Customer Service: 400 120 3205

Email: [email protected]

Address: GEORGE HALIKIOTIS, 'Eakin McCaffery Cox', Level 28, 1 Market Street, Sydney NSW 2000, Australia

38ACCEPTANCE

By opening or maintaining a GDFS account or using a service made available by GDFS, you confirm that:

• you have read and understood this Agreement;
• the information you have provided is accurate and complete;
• you understand that financial products involve risk;
• you have reviewed the disclosure documents applicable to the services you use; and
• you agree to be bound by this Agreement.