Common use of Dealing Clause in Contracts

Dealing. 8.1 We may execute your dealing instructions upon or in accordance with the rules of any market or exchange and through any clearing house selected by us. We may enter into transactions for or with you which are not on or in accordance with the rules of any exchange for example, off-exchange transactions in foreign currencies, or in other non-readily realisable investments. 8.2 Assets and profits arising on closing a position, settlement or liquidation will be credited to your Account and losses will be debited from your Account. Any debit balance arising as a result of any close-out, settlement or liquidation will be payable by you forthwith whether or not demanded by us. 8.3 We shall be entitled to carry out all transactions in accordance with the rules, regulations, customs or practices of the relevant market, exchange and / or clearing house and all applicable laws whether imposed on you or us. We may take all such steps as may be required or permitted by such laws, rules, regulations, customs and / or market practice. We will be entitled to take or not take any reasonable action we consider fit in order to ensure compliance with the same and all such actions so taken will be binding upon you. 8.4 You agree that any transactions we effect for you will be subject to the rules, regulations, customs and practices of each relevant market, exchange, or clearing house on, through or with which we deal. 8.5 In executing transactions for or with you, we will always deal with you as principal whilst bearing in mind the best execution obligations of the MFSA and how they apply to each different client classification. 8.6 We may, at our discretion, aggregate your orders with our own orders or those of other clients of ours or our associates. We will allocate the proceeds of such orders among the participating accounts in a manner which we believe to be fair and equitable. If the combined order is not executed at the same price, we may average the prices paid or received and debit or credit your Account with the average net price. Details of average price will be furnished on request. Such allocation must take place within five business days of execution. In aggregating your orders in this way, we must reasonably believe this will be to your advantage, for instance to obtain better execution or reduced foreign exchange or other dealing costs by being part of a larger transaction. However, on occasion, aggregation and allocation may result in you obtaining a less favourable price. 8.7 Where we are unable or consider it undesirable or inappropriate to execute your order at once or in a single transaction (split fills and/or market orders) we may execute it over such period as we deem appropriate, and we may report to you an average price for a series of transactions so executed instead of the actual price of each transaction. 8.8 We may undertake a program trade or trades comprising a single transaction or series of transactions on your behalf. In doing so we will always act as principal. 8.9 We reserve the right to refuse any trades placed by you that we judge to be clearly outside the prevailing market price such that they may be deemed non-market price transactions, whether due to manifest human error or stale, incorrect or broken price feeds. Where we have opened or closed a trade before becoming aware of the price disparity, we may at our absolute discretion either treat that trade as void or accept that trade at the prevailing market price.

Dealing. 8.1 7.1 We may execute your dealing instructions upon or in accordance with the rules of any market or exchange and through any clearing house selected by us. We may enter into transactions for or with you which are not on or in accordance with the rules of any exchange for example, off-exchange transactions in foreign currencies, or in other non-readily realisable investments. 8.2 7.2 Assets and profits arising on closing a position, settlement or liquidation will be credited to your Account and losses will be debited from your Account. Any Subject to the FCA Rules on Negative Balance Protection, any debit balance arising as a result of any close-out, settlement or liquidation will be payable by you forthwith whether or not demanded by us. 8.3 7.3 We shall be entitled to carry out all transactions in accordance with the rules, regulations, customs or practices of the relevant market, exchange and / or clearing house and all applicable laws whether VARIANSE is a trading name of VDX Limited. VDX Limited is authorised and regulated by the Financial Conduct Authority (FCA) in the United Kingdom with FRN 802012. Address: Park house, ▇▇▇ ▇▇▇▇ ▇▇▇▇▇▇, ▇▇▇▇▇▇▇, ▇▇▇▇▇▇, ▇▇▇ ▇▇▇, Email: ▇▇▇▇▇▇▇@▇▇▇▇▇▇▇▇.▇▇▇. Tel: +▇▇ (▇) ▇▇▇ ▇▇▇ ▇▇▇▇. imposed on you or us. We may take all such steps as may be required or permitted by such laws, rules, regulations, customs and / or market practice. We will be entitled to take or not take any reasonable action we consider fit in order to ensure compliance with the same and all such actions so taken will be binding upon you. 8.4 7.4 You agree that any transactions we effect for you will be subject to the rules, regulations, customs and practices of each relevant market, exchange, or clearing house on, through or with which we deal. 8.5 7.5 In order to give effect to your dealing instructions, we may at our discretion instruct an intermediate broker selected by us (which may be an Associate of ours). We undertake to use reasonable care and skill in the appointment and supervision of any intermediate broker and to make available to you and take, at your cost and expense, such action on your behalf as you may reasonably request in relation to any rights we have against such intermediate broker. Subject to this we accept no liability for any default of any intermediate broker, nor do we accept any liability in relation to the default of any market, exchange or clearing house. 7.6 In executing transactions for or with you we will normally deal with you as principal. We will take all sufficient steps to obtain the best possible results in accordance with the best execution obligation under FCA Rules. We will execute your orders in accordance with our Order Execution Policy. A summary of our Order Execution Policy can be found at the following link: ▇▇▇▇://▇▇▇▇▇▇▇▇.▇▇▇. By signing and returning this Agreement, accepting this Agreement online by checking the applicable box or giving an instruction to us you consent to the contents of our Order Execution Policy. We may execute your orders in financial instruments admitted to trading on a Regulated Market, Multilateral Trading Facility or Organised Trading Facility (“Trading Venue”), outside a Trading Venue where we believe it is necessary to achieve best execution for you, In particular by agreeing to the terms of this agreement or by placing a trade with us, you will be providing your consent to your order being executed outside of a regulated market or Multilateral Trading Facility (MTF). 7.7 Where relevant, when executing your orders, we have implemented procedures and arrangements as required by FCA Rules that provide for the prompt, fair and expeditious execution of client orders. These procedures or arrangements shall allow for the execution of otherwise comparable client orders in accordance with the time of their receipt. We will execute otherwise comparable orders sequentially and promptly unless we consider that the characteristics of an order or prevailing market conditions make this impracticable or that yours or another client’s interests require otherwise. If you are a Retail Client, we will notify you about any material difficulty relevant to the prompt execution of your orders upon becoming aware of such difficulties. Where we accept instructions or orders from you, we will always deal with use reasonable efforts to carry them out. However, we cannot guarantee that we can give effect to such instructions and orders or that they will be carried out immediately as this will depend on prevailing market conditions. When we give you an indicative price we cannot guarantee that this will be the price at which your order will be executed as principal whilst bearing in mind the best execution obligations of the MFSA market prices can fluctuate suddenly and how they apply to each different client classificationunpredictably. 8.6 7.8 We may, may at our discretion, discretion aggregate your orders with our own orders or those of other clients of ours or our associatesAssociates. We will allocate the proceeds of such orders among the participating accounts in a manner which we believe to be fair and equitable. If the combined order is not executed at the same price, we may average the prices paid or received and debit or credit your Account with the average net price. Details of average price will be furnished on request. Such allocation must take place within five business days of execution. In aggregating your orders in this way, we must reasonably believe this that you will be to obtain a no less favourable price than if your advantageorder had been executed separately , for instance to obtain better execution or reduced foreign exchange or other dealing costs by being part of a larger transaction. However, on occasion, aggregation and allocation may result in you obtaining a less favourable price. VARIANSE | Client Agreement Page 7 of 29 VARIANSE is a trading name of VDX Limited. VDX Limited is authorised and regulated by the Financial Conduct Authority (FCA) in the United Kingdom with FRN 802012. Address: Park house, ▇▇▇ ▇▇▇▇ ▇▇▇▇▇▇, ▇▇▇▇▇▇▇, ▇▇▇▇▇▇, ▇▇▇ ▇▇▇, Email: ▇▇▇▇▇▇▇@▇▇▇▇▇▇▇▇.▇▇▇. Tel: +▇▇ (▇) ▇▇▇ ▇▇▇ ▇▇▇▇. 8.7 7.9 Where we are unable or consider it undesirable or inappropriate to execute your order at once or in a single transaction (split fills and/or market orders) we may execute it over such period as we deem appropriate, appropriate and we may report to you an average price for a series of transactions so executed instead of the actual price of each transaction. 8.8 We may undertake a program trade or trades comprising a single transaction or series of transactions on your behalf. In doing so we will always act as principal. 8.9 7.10 We reserve the right to refuse any trades placed by you that we judge to be clearly outside the prevailing market price such that they may be deemed non-market price transactions, whether due to manifest human error or stale, incorrect or broken price feeds. Where we have opened or closed a trade before becoming aware of the price disparity, we may at our absolute discretion either treat that trade as void or accept that trade at the prevailing market price. 7.11 As a client of ours you hereby accept that the prices quoted by other companies may not be relied upon by you in respect of your Account with us and that we reserve the right to decline any quote or refuse to be bound to any contract, including those arising from any manipulation of the quoting mechanism or our Services generally, notwithstanding our undertaking to provide a clear and fair service to you at all times. 7.12 In relation our dealing services, you represent and warrant that you: 7.12.1 are acting in accordance with the Act, the FCA Rules, the Market Abuse Regulation (596/2014/EU) and all applicable laws and regulations, 7.12.2 are not acting in any way which is intended to or may be considered to be market abuse, and 7.12.3 are not acting with the intention of contravening any other provision of the Act or any other applicable law or regulation. 7.12.4 will use the services offered by us pursuant to this Agreement in good faith and, to this end, you will not use any electronic device, software, algorithm, any trading strategy or any arbitrage practices (such as but not limited to latency abuse, price manipulation or time manipulation) that aims to manipulate or take unfair advantage of the way in which we construct, provide or convey our bid or offer prices. In addition, you agree that using any device, software, algorithm, strategy or practice in your dealings with us whereby you are not subject to any downside market risk will be evidence that you are taking unfair advantage of us. 7.13 In the event that (a) you open or close any Transaction or place an Order in breach of the representations and warranties given in Terms 7.12.1, 7.12.2, 7.12.3 or 7.12.4, or (b) we have reasonable grounds for suspecting that you have done so, we may, at our absolute discretion and without being under any obligation to inform you of our reason for doing so, close that Transaction and any other Transactions that you may have open at the time, if applicable, and also, at our absolute discretion: (a) enforce the Transaction or Transactions against you if it is a Transaction or Transactions under which you have incurred a loss; (b) treat all your Transactions that meet the circumstances set out in this Term as void if they are Transactions under which you have secured a profit, unless and until you produce evidence that satisfies us that you have not, in fact, committed the breach of warranty and/or misrepresentation the suspicion of which was the ground for us taking action under this Term. For the avoidance of doubt, if you do not produce such evidence within the period of three months from the date on which action is taken by us under this Term, all such Transactions will be finally null and void as between you and us; or (c) cancel any Order on your account with us 7.14 In the event of a system failure of the Trading Platform, or where the Trading Platform is unavailable for any other reason, trades may be placed over the telephone or via email (within our usual trading hours, details of which are set out on the Website). To place a trade over the telephone or via email, you must supply your Account number, name and provide certain security information if asked. When you place trades over the telephone, we cannot be expected to recognise your voice. Voice orders placed by VARIANSE is a trading name of VDX Limited. VDX Limited is authorised and regulated by the Financial Conduct Authority (FCA) in the United Kingdom with FRN 802012. Address: Park house, ▇▇▇ ▇▇▇▇ ▇▇▇▇▇▇, ▇▇▇▇▇▇▇, ▇▇▇▇▇▇, ▇▇▇ ▇▇▇, Email: ▇▇▇▇▇▇▇@▇▇▇▇▇▇▇▇.▇▇▇. Tel: +▇▇ (▇) ▇▇▇ ▇▇▇ ▇▇▇▇. contacting one of our dealers are defined as orders placed via telephone or sent manually via email and will only be considered live when acknowledged by us. 7.15 If you are unsure whether a trade or Order has been accepted because communication via the Trading Platform has broken down or has been interrupted, you must notify us immediately by telephone or email to confirm the status of that trade or Order. You cannot place a trade, Order or any other instruction by leaving a message on an answer phone or voicemail facility.

Dealing. 8.1 7.1 We may execute your dealing instructions upon or in accordance with the rules of any market or exchange and through any No. 8443644 and is authorised and regulated by the Financial Conduct Authority. Registered No. 600837 ▇▇▇ ▇▇▇▇▇▇▇▇▇, ▇▇▇▇▇▇, ▇▇▇▇ ▇▇▇, ▇▇▇▇▇▇ ▇▇▇▇▇▇▇ ▇▇▇.▇▇▇▇▇▇▇▇▇▇▇▇▇▇▇▇▇▇▇.▇▇▇ / 0044 (0)207 967 1729 clearing house selected by us. We may enter into transactions for or with you which are not on or in accordance with the rules of any exchange for example, off-exchange transactions in foreign currencies, or in other non-readily realisable investments. 8.2 7.2 Assets and profits arising on closing a position, settlement or liquidation will be credited to your Account and losses will be debited from your Account. Any debit balance arising as a result of any close-out, settlement or liquidation will be payable by you forthwith whether or not demanded by us. 8.3 7.3 We shall be entitled to carry out all transactions in accordance with the rules, regulations, customs or practices of the relevant market, exchange and / or clearing house and all applicable laws whether imposed on you or us. We may take all such steps as may be required or permitted by such laws, rules, regulations, customs and / or market practice. We will be entitled to take or not take any reasonable action we consider fit in order to ensure compliance with the same and all such actions so taken will be binding upon you. 8.4 7.4 You agree that any transactions we effect for you will be subject to the rules, regulations, customs and practices of each relevant market, exchange, or clearing house on, through or with which we deal. 8.5 7.5 In order to give effect to your dealing instructions, we may at our discretion instruct an intermediate broker selected by us (which may be an Associate of ours). We accept full liability for any default by an intermediate broker which is our Associate, and undertake to use reasonable care and skill in the appointment and supervision of any intermediate broker and to make available to you and take, at your cost and expense, such action on your behalf as you may reasonably request in relation to any rights we have against such intermediate broker. Subject to this we accept no liability for any default of any intermediate broker nor do we accept any liability in relation to the default of any market, exchange or clearing house. 7.6 In executing transactions for or with you, you we will always deal with you as principal whilst bearing in mind principal. While we will take reasonable steps to obtain the best price available you agree and acknowledge that save as required by the FCA Rules we are under no obligation to provide you with best execution obligations of in accordance with the MFSA FCA Rules and how they apply to each different client classificationyou hereby waive any such requirements. 8.6 7.7 We may, may at our discretion, discretion aggregate your orders with our own orders or those of other clients of ours or our associatesAssociates. We will allocate the proceeds of such orders among the participating accounts in a manner which we believe to be fair and equitable. If the combined order is not executed at the same price, price we may average the prices paid or received and debit or credit your Account with the average net price. Details of average price will be furnished on request. Such allocation must take place within five business days of execution. In aggregating your orders in this way, way we must reasonably believe this will be to your advantage, for instance to obtain better execution or reduced foreign exchange or other dealing costs by being part of a larger transaction. However, on occasion, aggregation and allocation may result in you obtaining a less favourable price. 8.7 7.8 Where we are unable or consider it undesirable or inappropriate to execute your order at once or in a single transaction (split fills and/or market orders) we may execute it over such period as we deem appropriate, appropriate and we may report to you an average price for a series of transactions so executed instead of the actual price of each transaction. 8.8 7.9 We may undertake a program trade or trades comprising a single transaction or series of transactions on your behalf. In doing so we will always act as principal. 8.9 7.10 We reserve the right to refuse any trades placed by you that we judge to be clearly outside the prevailing market price such that they may be deemed non-market price transactions, whether due to manifest human error or stale, incorrect or broken price feeds. Where we have opened or closed a trade before becoming aware of the price disparity, we may at our absolute discretion either treat that trade as void or accept that trade at the prevailing market price. 7.11 We are a market maker and may quote prices at which we are prepared to deal with our clients and such prices may or may not replicate the prices quoted and traded by other companies and / or their customers. As a client of ours you hereby accept that the prices quoted by other companies may not be relied upon by you in respect of your account with us and that we reserve the right to decline any quote or refuse to be bound to any contract, including those arising from any manipulation of the quoting mechanism or our services generally, notwithstanding our undertaking to provide a clear and fair service to you at all times. No. 8443644 and is authorised and regulated by the Financial Conduct Authority. Registered No. 600837 ▇▇▇ ▇▇▇▇▇▇▇▇▇, ▇▇▇▇▇▇, ▇▇▇▇ ▇▇▇, ▇▇▇▇▇▇ ▇▇▇▇▇▇▇ ▇▇▇.▇▇▇▇▇▇▇▇▇▇▇▇▇▇▇▇▇▇▇.▇▇▇ / ▇▇▇▇ (▇)▇▇▇ ▇▇▇ ▇▇▇▇

Dealing. 8.1 7.1. We may execute your dealing instructions upon or in accordance with the rules of any market or exchange and through any clearing house selected by us. We may enter into transactions for or with you which are not on or in accordance with the rules of any exchange for example, off-exchange transactions in foreign currencies, or in other non-readily realisable investments. 8.2 7.2. Assets and profits arising on closing a position, settlement or liquidation will be credited to your Account and losses will be debited from your Account. Any debit balance arising as a result of any close-out, settlement or liquidation will be payable by you forthwith whether or not demanded by us. 8.3 7.3. We shall be entitled to carry out all transactions in accordance with the rules, regulations, customs or practices of the relevant market, exchange and / or clearing house and all applicable laws whether imposed on you or us. We may take all such steps as may be required or permitted by such laws, rules, regulations, customs and / or market practice. We will be entitled to take or not take any reasonable action we consider fit in order to ensure compliance with the same and all such actions so taken will be binding upon you. 8.4 7.4. You agree that any transactions we effect for you will be subject to the rules, regulations, customs and practices of each relevant market, exchange, or clearing house on, through or with which we deal. 8.5 7.5. In executing transactions for or with you, we will always deal with you as principal whilst bearing in mind the best execution obligations of the MFSA FCA and how they apply to each different client classification. 8.6 7.6. We may, at our discretion, aggregate your orders with our own orders or those of other clients of ours or our associatesAssociates. We will allocate the proceeds of such orders among the participating accounts in a manner which we believe to be fair and equitable. If the combined order is not executed at the same price, we may average the prices paid or received and debit or credit your Account with the average net price. Details of average price will be furnished on request. Such allocation must take place within five business days of execution. In aggregating your orders in this way, we must reasonably believe this will be to your advantage, for instance to obtain better execution or reduced foreign exchange or other dealing costs by being part of a larger transaction. However, on occasion, aggregation and allocation may result in you obtaining a less favourable price. 8.7 7.7. Where we are unable or consider it undesirable or inappropriate to execute your order at once or in a single transaction (split fills and/or market orders) we may execute it over such period as we deem appropriate, and we may report to you an average price for a series of transactions so executed instead of the actual price of each transaction. 8.8 7.8. We may undertake a program trade or trades comprising a single transaction or series of transactions on your behalf. In doing so we will always act as principal. 8.9 7.9. We reserve the right to refuse any trades placed by you that we judge to be clearly outside the prevailing market price such that they may be deemed non-market price transactions, whether due to manifest human error or stale, incorrect or broken price feeds. Where we have opened or closed a trade before becoming aware of the price disparity, we may at our absolute discretion either treat that trade as void or accept that trade at the prevailing market price. 7.10. We are an STP only broker and quote the prices provided to us by our counterparties and these prices are at which we are prepared to deal with our clients and such prices may or may not replicate the prices quoted and traded by other companies and / or their customers. As a client of ours you hereby accept that the prices quoted by other companies may not be relied upon by you in respect of your account with us and that we reserve the right to decline any quote or refuse to be bound to any contract, including those arising from any manipulation of the quoting mechanism or our services generally, notwithstanding our undertaking to provide a clear and fair service to you at all times.

Dealing. 8.1 7.1 We may execute your dealing instructions upon or in accordance with the rules of any market or exchange and through any clearing house selected by us. We may enter into transactions for or with you which are not on or in accordance with the rules of any exchange for example, off-exchange transactions in foreign currencies, or in other non-readily realisable investments. 8.2 7.2 Assets and profits arising on closing a position, settlement or liquidation will be credited to your Account and losses will be debited from your Account. Any Subject to the FCA Rules on Negative Balance Protection, any debit balance arising as a result of any close-out, settlement or liquidation will be payable by you forthwith whether or not demanded by us. 8.3 7.3 We shall be entitled to carry out all transactions in accordance with the rules, regulations, customs or practices of the relevant market, exchange and / or clearing house and all applicable laws whether imposed on you or us. We may take all such steps as may be required or permitted by such laws, rules, regulations, customs and / or market practice. We will be entitled to take or not take any reasonable action VARIANSE is a trading name of VDX Limited. VDX Limited is authorised and regulated by the Financial Conduct Authority (FCA) in the United Kingdom with FRN 802012. Address: ▇ ▇▇▇▇▇▇▇ ▇▇▇▇▇▇, ▇▇▇▇, ▇▇▇▇▇▇, ▇▇▇▇ ▇▇▇, Email: ▇▇▇▇▇▇▇@▇▇▇▇▇▇▇▇.▇▇▇. Tel: +▇▇ (▇) ▇▇▇ ▇▇▇ ▇▇▇▇. we consider fit in order to ensure compliance with the same and all such actions so taken will be binding upon you. 8.4 7.4 You agree that any transactions we effect for you will be subject to the rules, regulations, customs and practices of each relevant market, exchange, or clearing house on, through or with which we deal. 8.5 7.5 In order to give effect to your dealing instructions, we may at our discretion instruct an intermediate broker selected by us (which may be an Associate of ours). We undertake to use reasonable care and skill in the appointment and supervision of any intermediate broker and to make available to you and take, at your cost and expense, such action on your behalf as you may reasonably request in relation to any rights we have against such intermediate broker. Subject to this we accept no liability for any default of any intermediate broker, nor do we accept any liability in relation to the default of any market, exchange or clearing house. 7.6 In executing transactions for or with you we will normally deal with you as principal. We will take all sufficient steps to obtain the best possible results in accordance with the best execution obligation under FCA Rules. We will execute your orders in accordance with our Order Execution Policy. A summary of our Order Execution Policy can be found at the following link: ▇▇▇▇://▇▇▇▇▇▇▇▇.▇▇▇. By signing and returning this Agreement, accepting this Agreement online by checking the applicable box or giving an instruction to us you consent to the contents of our Order Execution Policy. We may execute your orders in financial instruments admitted to trading on a Regulated Market, Multilateral Trading Facility or Organised Trading Facility (“Trading Venue”), outside a Trading Venue where we believe it is necessary to achieve best execution for you, In particular by agreeing to the terms of this agreement or by placing a trade with us, you will be providing your consent to your order being executed outside of a regulated market or Multilateral Trading Facility (MTF). 7.7 Where relevant, when executing your orders, we have implemented procedures and arrangements as required by FCA Rules that provide for the prompt, fair and expeditious execution of client orders. These procedures or arrangements shall allow for the execution of otherwise comparable client orders in accordance with the time of their receipt. We will execute otherwise comparable orders sequentially and promptly unless we consider that the characteristics of an order or prevailing market conditions make this impracticable or that yours or another client’s interests require otherwise. If you are a Retail Client, we will notify you about any material difficulty relevant to the prompt execution of your orders upon becoming aware of such difficulties. Where we accept instructions or orders from you, we will always deal with use reasonable efforts to carry them out. However, we cannot guarantee that we can give effect to such instructions and orders or that they will be carried out immediately as this will depend on prevailing market conditions. When we give you an indicative price we cannot guarantee that this will be the price at which your order will be executed as principal whilst bearing in mind the best execution obligations of the MFSA market prices can fluctuate suddenly and how they apply to each different client classificationunpredictably. 8.6 7.8 We may, may at our discretion, discretion aggregate your orders with our own orders or those of other clients of ours or our associatesAssociates. We will allocate the proceeds of such orders among the participating accounts in a manner which we believe to be fair and equitable. If the combined order is not executed at the same price, we may average the prices paid or received and debit or credit your Account with the average net price. Details of average price will be furnished on request. Such allocation must take place within five business days of execution. In aggregating your orders in this way, we must reasonably believe this that you will be to obtain a no less favourable price than if your advantageorder had been executed separately , for instance to obtain better execution or reduced foreign exchange or other dealing costs by being part of a larger transaction. However, on occasion, aggregation and allocation may result in you obtaining a less favourable price. 8.7 7.9 Where we are unable or consider it undesirable or inappropriate to execute your order at once or in a single transaction (split fills and/or market orders) we may execute it over such period as we deem appropriate, appropriate and we may report to you an average price for a series of transactions so executed instead of the actual price of each transaction. VARIANSE is a trading name of VDX Limited. VDX Limited is authorised and regulated by the Financial Conduct Authority (FCA) in the United Kingdom with FRN 802012. Address: ▇ ▇▇▇▇▇▇▇ ▇▇▇▇▇▇, ▇▇▇▇, ▇▇▇▇▇▇, ▇▇▇▇ ▇▇▇, Email: ▇▇▇▇▇▇▇@▇▇▇▇▇▇▇▇.▇▇▇. Tel: +▇▇ (▇) ▇▇▇ ▇▇▇ ▇▇▇▇. 8.8 We may undertake a program trade or trades comprising a single transaction or series of transactions on your behalf. In doing so we will always act as principal. 8.9 7.10 We reserve the right to refuse any trades placed by you that we judge to be clearly outside the prevailing market price such that they may be deemed non-market price transactions, whether due to manifest human error or stale, incorrect or broken price feeds. Where we have opened or closed a trade before becoming aware of the price disparity, we may at our absolute discretion either treat that trade as void or accept that trade at the prevailing market price. 7.11 As a client of ours you hereby accept that the prices quoted by other companies may not be relied upon by you in respect of your Account with us and that we reserve the right to decline any quote or refuse to be bound to any contract, including those arising from any manipulation of the quoting mechanism or our Services generally, notwithstanding our undertaking to provide a clear and fair service to you at all times. 7.12 In relation our dealing services, you represent and warrant that you: 7.12.1 are acting in accordance with the Act, the FCA Rules, the Market Abuse Regulation (596/2014/EU) and all applicable laws and regulations, 7.12.2 are not acting in any way which is intended to or may be considered to be market abuse, and 7.12.3 are not acting with the intention of contravening any other provision of the Act or any other applicable law or regulation. 7.12.4 will use the services offered by us pursuant to this Agreement in good faith and, to this end, you will not use any electronic device, software, algorithm, any trading strategy or any arbitrage practices (such as but not limited to latency abuse, price manipulation or time manipulation) that aims to manipulate or take unfair advantage of the way in which we construct, provide or convey our bid or offer prices. In addition, you agree that using any device, software, algorithm, strategy or practice in your dealings with us whereby you are not subject to any downside market risk will be evidence that you are taking unfair advantage of us. 7.13 In the event that (a) you open or close any Transaction or place an Order in breach of the representations and warranties given in Terms 7.12.1, 7.12.2, 7.12.3 or 7.12.4, or (b) we have reasonable grounds for suspecting that you have done so, we may, at our absolute discretion and without being under any obligation to inform you of our reason for doing so, close that Transaction and any other Transactions that you may have open at the time, if applicable, and also, at our absolute discretion: (a) enforce the Transaction or Transactions against you if it is a Transaction or Transactions under which you have incurred a loss; (b) treat all your Transactions that meet the circumstances set out in this Term as void if they are Transactions under which you have secured a profit, unless and until you produce evidence that satisfies us that you have not, in fact, committed the breach of warranty and/or misrepresentation the suspicion of which was the ground for us taking action under this Term. For the avoidance of doubt, if you do not produce such evidence within the period of three months from the date on which action is taken by us under this Term, all such Transactions will be finally null and void as between you and us; or (c) cancel any Order on your account with us 7.14 In the event of a system failure of the Trading Platform, or where the Trading Platform is unavailable for any other reason, trades may be placed over the telephone or via email (within our usual trading hours, details of which are set out on the Website). To place a trade over the telephone or via email, you must supply your Account number, name and provide certain security information if asked. When you place trades over the telephone, we cannot be expected to recognise your voice. Voice orders placed by contacting one of our dealers are defined as orders placed via telephone or sent manually via email and will only be considered live when acknowledged by us. VARIANSE is a trading name of VDX Limited. VDX Limited is authorised and regulated by the Financial Conduct Authority (FCA) in the United Kingdom with FRN 802012. Address: ▇ ▇▇▇▇▇▇▇ ▇▇▇▇▇▇, ▇▇▇▇, ▇▇▇▇▇▇, ▇▇▇▇ ▇▇▇, Email: ▇▇▇▇▇▇▇@▇▇▇▇▇▇▇▇.▇▇▇. Tel: +▇▇ (▇) ▇▇▇ ▇▇▇ ▇▇▇▇. 7.15 If you are unsure whether a trade or Order has been accepted because communication via the Trading Platform has broken down or has been interrupted, you must notify us immediately by telephone or email to confirm the status of that trade or Order. You cannot place a trade, Order or any other instruction by leaving a message on an answer phone or voicemail facility.

Dealing. 8.1 6.1. We may execute your dealing instructions upon or in accordance with the rules of any market or exchange and through any clearing house selected by us. We may enter into transactions for or with you which are not on or in accordance with the rules of any exchange for example, off-exchange transactions in foreign currencies, or in other non-readily realisable investments. 8.2 6.2. Assets and profits arising on closing a position, settlement or liquidation will be credited to your Account and losses will be debited from your Account. Any debit balance arising as a result of any close-out, settlement or liquidation will be payable by you forthwith whether or not demanded by us. 8.3 6.3. We shall be entitled to carry out all transactions in accordance with the rules, regulations, customs or practices of the relevant market, exchange and / or clearing house and all applicable laws whether imposed on you or us. We may take all such steps as may be required or permitted by such laws, rules, regulations, customs and / or market practice. We will be entitled to take or not take any reasonable action we consider fit in order to ensure compliance with the same and all such actions so taken will be binding upon you. 8.4 6.4. You agree that any transactions we effect for you will be subject to the rules, regulations, customs and practices of each relevant market, exchange, or clearing house on, through or with which we deal. 8.5 6.5. In order to give effect to your dealing instructions, we may at our discretion instruct an intermediate broker selected by us (which may be an Associate of ours). We accept full liability for any default by an intermediate broker which is our Associate, and undertake to use reasonable care and skill in the appointment and supervision of any intermediate broker and to make available to you and take, at your cost and expense, such action on your behalf as you may reasonably request in relation to any rights we have against such intermediate broker. Subject to this we accept no liability for any default of any intermediate broker nor do we accept any liability in relation to the default of any market, exchange or clearing house. 6.6. In executing transactions for or with you, you we will always deal with you as principal whilst bearing in mind principal. While we will take reasonable steps to obtain the best price available you agree and acknowledge that save as required by the FCA Rules we are under no obligation to provide you with best execution obligations of in accordance with the MFSA FCA Rules and how they apply to each different client classificationyou hereby waive any such requirements. 8.6 6.7. We may, may at our discretion, discretion aggregate your orders with our own orders or those of other clients of ours or our associatesAssociates. We will allocate the proceeds of such orders among the participating accounts in a manner which we believe to be fair and equitable. If the combined order is not executed at the same price, we may average the prices paid or received and debit or credit your Account with the average net price. Details of average price will be furnished on request. Such allocation must take place within five business days of execution. In aggregating your orders in this way, we must reasonably believe this will be to your advantage, for instance to obtain better execution or reduced foreign exchange or other dealing costs by being part of a larger transaction. However, on occasion, aggregation and allocation may result in you obtaining a less favourable price. Doo Clearing Limited is registered in England and Wales with registration number 10684079 and is authorised and regulated by the Financial Conduct Authority with license number 833414 ▇▇▇▇▇▇▇@▇▇▇▇▇▇▇▇▇▇▇.▇▇.▇▇ | ▇▇▇▇▇▇▇ ▇▇▇▇▇, ▇▇ ▇▇▇▇▇▇▇ ▇▇▇▇, ▇▇▇▇▇▇ ▇▇▇▇ ▇▇▇, ▇▇ | +▇▇ ▇▇ ▇▇▇▇ ▇▇▇▇ 8.7 6.8. Where we are unable or consider it undesirable or inappropriate to execute your order at once or in a single transaction (split fills and/or market orders) transaction, we may execute it over such period as we deem appropriate, appropriate and we may report to you an average price for a series of transactions so executed instead of the actual price of each transaction. 8.8 6.9. We may undertake a program trade or trades comprising a single transaction or series of transactions on your behalf. In doing so we will always act as principal. 8.9 6.10. We reserve the right to refuse any trades placed by you that we judge to be clearly outside the prevailing market price such that they may be deemed non-market price transactions, whether due to manifest human error or stale, incorrect or broken price feeds. Where we have opened or closed a trade before becoming aware of the price disparity, we may at our absolute discretion either treat that trade as void or accept that trade at the prevailing market price. 6.11. We are not a market maker and may show prices at which our liquidity providers are prepared to deal with our clients and such prices may or may not replicate the prices quoted and traded by other companies and / or their customers. As a client of ours you hereby accept that the prices quoted by other companies may not be relied upon by you in respect of your account with us and that we reserve the right to decline any quote or refuse to be bound to any contract, including those arising from any manipulation of the quoting mechanism or our services generally, notwithstanding our undertaking to provide a clear and fair service to you at all times.

Dealing. 8.1 A copy of our Order Execution Policy can be found in the Policies section of our website, together with a list of the top five brokers used to execute our orders. We absorb all broker execution and research costs. Agreement to these Terms and Conditions constitutes your consent to that policy which may be amended from time to time. In effecting any transaction for you hereunder we shall at all times comply with our Order Execution Policy and in particular, we will act in your best interests and comply with any applicable obligations regarding best execution under FCA Rules. You should note that where you give us specific instructions in relation to the execution of orders, this may prevent us from following our Order Execution Policy in relation to such orders in respect of the elements of execution covered by the instructions. We may execute aggregate transactions for your dealing instructions upon portfolio(s) with those of other customers and of our employees and of associates and their employees and will allocate such transactions on a fair and reasonable basis in accordance with the requirements of the FCA Rules. You acknowledge that each individual aggregated transaction may operate to your advantage, but also to your disadvantage, although not materially so. You may instruct us not to make public any Client Limit Orders in respect of shares admitted to trading on a regulated market or traded on a multilateral trading facility which are not immediately executed under prevailing market conditions. We may (subject to our Order Execution Policy) deal on such markets or exchanges and with such counterparties as we see fit. All transactions will be effected in accordance with the rules of any market or exchange and through any clearing house selected by us. We may enter into transactions for or with you which are not on or in accordance with the rules of any exchange for example, off-exchange transactions in foreign currencies, or in other non-readily realisable investments. 8.2 Assets and profits arising on closing a position, settlement or liquidation will be credited to your Account and losses will be debited from your Account. Any debit balance arising as a result of any close-out, settlement or liquidation will be payable by you forthwith whether or not demanded by us. 8.3 We shall be entitled to carry out all transactions in accordance with the rules, regulations, customs or practices regulations of the relevant marketmarket or exchange, exchange and / or clearing house and all applicable laws whether imposed on you or us. We we may take all such steps as may be required or permitted by such laws, rules, regulations, customs rules and / or regulations and/or by appropriate market practice. We will be entitled to take may coordinate settlement of transactions (whether or not take any combined with other transactions) for your portfolio(s) with counterparties on whatever terms are usual for the market or transaction concerned. We may do this notwithstanding that if a counterparty defaults, compensation arrangements (if any) may not be as favourable as those in other markets or for other sizes of transaction. We are authorised for the purposes of such transactions to give such warranties or undertakings on your behalf and surrender such liens or other rights as may be necessary or usual practice. We act in good faith and with reasonable action we consider fit skill and care in order to ensure compliance with our choice and use of counterparties. In the same and all such actions so taken will be binding upon you. 8.4 You agree event, however, that any transactions we effect for you will be subject counterparty fails to deliver documents or pay amounts due on the rulesdue date or within a reasonable time, regulations, customs and practices of each relevant market, exchange, or clearing house on, through or with which we deal. 8.5 In executing transactions for or with on receiving a request from you, we will always deal with shall pursue on your behalf appropriate legal remedies to recover the documents or amount due or compensation in their place. All reasonable costs and expenses properly incurred by us in this connection shall be paid by you. In the event that you as principal whilst bearing in mind instruct us to reverse a transaction, we shall do so at the best execution obligations of the MFSA and how they apply to each different client classification. 8.6 We may, at our discretion, aggregate your orders with our own orders or those of other clients of ours or our associates. We will allocate the proceeds of such orders among the participating accounts in a manner which we believe to be fair and equitable. If the combined order is not executed available price at the same price, we may average the prices paid or received and debit or credit your Account with the average net price. Details of average price will be furnished on request. Such allocation must take place within five business days of execution. In aggregating your orders in this way, we must reasonably believe this will be to your advantage, for instance to obtain better execution or reduced foreign exchange or other dealing costs by being part of a larger transactiontime. However, on occasion, aggregation and allocation may we shall not be responsible for any loss or expense to your portfolio(s) as a result in you obtaining of your instructions to reverse a less favourable price. 8.7 Where we are unable or consider it undesirable or inappropriate to execute your order at once or in a single transaction (split fills and/or market orders) we may execute it over such period as we deem appropriate, and we may report to you an average price for a series of transactions so executed instead of the actual price of each transaction. 8.8 We may undertake a program trade or trades comprising a single transaction or series of transactions on your behalf. In doing so we will always act as principal. 8.9 We reserve the right to refuse any trades placed by you that we judge to be clearly outside the prevailing market price such that they may be deemed non-market price transactions, whether due to manifest human error or stale, incorrect or broken price feeds. Where we have opened or closed a trade before becoming aware of the price disparity, we may at our absolute discretion either treat that trade as void or accept that trade at the prevailing market price.