Brokerage Terms and Conditions

MONOLITH MARKET

BROKERAGE TERMS AND CONDITIONS

operated by Monolith Private Wealth Limited

Licensed and regulated by the Financial Services Commission of Mauritius

Introduction and Important Notices

These Monolith Market Brokerage Terms and Conditions (the “Terms”) are a legally binding agreement between you (the “Client”, “you”, or “your”) and Monolith Private Wealth Limited (the “Company”, “MPW”, “we”, “us”, or “our”). The Terms govern your use of the Monolith Market platform and your receipt of brokerage and advisory services from the Company.

By opening an Account, depositing funds, placing an Order, or otherwise accessing or using the Monolith Market platform, you confirm that you have read, understood, and agreed to be bound by these Terms, together with the Incorporated Documents listed in Clause 1.3.

Read Before Trading: Trading in financial instruments involves significant risk and is not suitable for everyone. You may lose some or all of the money you invest. Before opening an Account or placing an Order, you should: (a) read these Terms and the Incorporated Documents carefully and in full; (b) consider whether the Services are appropriate for your financial situation, knowledge, experience, and investment objectives; and (c) seek independent professional advice if you are unsure. If you do not understand any part of these Terms, contact us before opening an Account.

Mauritian Law Applies: These Terms are governed by the laws of the Republic of Mauritius. MPW is licensed by, and subject to the supervision of, the Financial Services Commission of Mauritius. Your protections under Mauritian law are described in these Terms; protections that may be available under the laws of other jurisdictions (e.g., the European Union, the United States, the United Kingdom, the United Arab Emirates) do not apply to your relationship with MPW unless expressly stated in these Terms.

1. Definitions, Interpretation, and Incorporated Documents

1.1 Definitions

In these Terms, capitalised expressions have the meanings set out below. Defined terms used but not defined in this Clause have the meanings ascribed to them elsewhere in the Terms or, in their absence, the meaning given by the Securities Act 2005 of Mauritius.

1.2 Interpretation

In these Terms, unless the context otherwise requires: (a) references to clauses, sub-clauses and schedules are to clauses, sub-clauses and schedules of these Terms; (b) headings are for convenience only and shall not affect the interpretation of these Terms; (c) the words “include”, “including”, “in particular” and similar expressions are illustrative only and shall not limit the generality of the words preceding or following them; (d) references to any statute, statutory provision, regulation or rule include such statute, statutory provision, regulation or rule as amended, extended, re-enacted, replaced or consolidated from time to time; (e) references to time are to the time in the Republic of Mauritius, unless otherwise stated; (f) all amounts are stated in United States Dollars (“USD”), unless otherwise stated. Where MPW supports other Account currencies, the corresponding amount in the relevant Account currency, calculated at the applicable exchange rate determined by MPW, shall be the operative amount; and (g) words in the singular include the plural and vice versa.

1.3 Incorporated Documents

The following documents, as updated from time to time, are incorporated into these Terms by reference and form part of the agreement between you and MPW. Each is available on the Platform or will otherwise be made available to you before or at the time it becomes applicable to you.

Schedules. Schedules 1 to 5 form part of these Terms. If there is any conflict between the general provisions of these Terms and a Schedule, the Schedule prevails, unless the Schedule expressly states otherwise. Nothing in any Schedule limits MPW’s rights under Clauses 4, 5, 6, 8, 9, 11, 15, 22, 23, 25, 28, 29, 30, or under any other provision intended to protect MPW’s legal, regulatory, financial-crime, risk-management, enforcement, or operational position.

Other Incorporated Documents. If there is any conflict between these Terms and any other Incorporated Document, these Terms prevail, unless these Terms or that Incorporated Document expressly provide otherwise. Where the conflict involves a regulatory disclosure obligation, the Incorporated Document prevails to the extent necessary to comply with that obligation.

2. Client Eligibility and Categorisation

2.1 Eligibility to Open an Account

To be eligible to open an Account, you must:

• Be at least 18 years of age (or the age of majority in your jurisdiction of residence if greater);

• Have full legal capacity to enter these Terms and to receive the Services;

• Provide accurate and complete identification, address, source-of-funds, and other information required to satisfy MPW's KYC and AML/CFT obligations, as set out in the KYC Onboarding Requirements Notice;

• Not be a Sanctioned Person and not be ordinarily resident in, a citizen of, or established under the laws of a Sanctioned Person jurisdiction or any jurisdiction that MPW from time to time identifies as a Restricted Person jurisdiction;

• Not be a US Person, except where MPW expressly accepts US Persons subject to specific arrangements (typically this is not currently supported);

• Pass MPW's onboarding checks, including identity verification, address verification, source-of-funds verification, sanctions screening, PEP screening, and adverse-media screening.

2.2 Account Holders

Individual Accounts: opened by a natural person in their own name. The natural person is the contracting party and is responsible for the Account;

Joint Accounts: subject to MPW's discretion to offer joint Accounts. Joint Account holders are jointly and severally liable for the Account;

Corporate and Entity Accounts: opened by a legal entity. The signatories on the Account must be authorised by the entity to bind it to these Terms. MPW may require additional documentation (constitutional documents, board resolutions, register of beneficial owners) before opening an Entity Account;

Trust and Fiduciary Accounts: may be supported subject to additional documentation and risk assessment.

2.3 Client Categorisation

MPW categorises every Client as either a Retail Investor or a Sophisticated Investor under section 2 of the Securities Act 2005. The default categorisation is Retail Investor. The Client Categorisation Policy and the Sophisticated Investor Declaration explain the categories, the consequences of each, and the procedure for asserting Sophisticated status.

Your categorisation determines the level and form of certain protections that apply to you under these Terms and the Incorporated Documents, including the depth of risk disclosure, the form of suitability assessment, the leverage available to you, and the formality of certain communications. A request to be treated as a Sophisticated Investor is a Compliance Review Event under Clause 11.2 and may give rise to a Compliance Review Fee.

3. Services

3.1 Investment Dealer Services

In its capacity as an Investment Dealer licensed by the FSC under section 29 of the Securities Act 2005, MPW provides: (a) Receipt and transmission of Orders in financial instruments accessible through the Platform; (b) Execution of Orders on behalf of Clients, either by transmitting them to executing brokers, market makers, or trading venues; (c) Holding of Client Money in accordance with Clause 6; (d) Holding of, or arranging for the custody of, financial instruments acquired by you through the Services, in accordance with the arrangements described to you on the Platform and in the Incorporated Documents; (e) Settlement, clearing, and reporting in connection with executed Transactions; (f) Margin financing, leverage, and related services in accordance with the Leverage, Margin, and Negative Balance Protection Policy.

3.2 Investment Adviser Services

In its capacity as an Investment Adviser (Unrestricted) licensed under section 30 of the Securities Act 2005, MPW may provide: (a) personalised investment recommendations in respect of financial instruments accessible through the Platform, subject to the Suitability and Appropriateness Policy; (b) generic market commentary, educational content, and research. These materials are not personalised recommendations and do not, by themselves, create a suitability obligation in respect of any particular Client. The distinction between general information and personalised advice is explained in the Suitability and Appropriateness Policy; (c) the Copy Trading Service described in Clause 12, under which you may elect to copy automatically the Transactions of a selected Lead Trader. Copy Trading is provided under MPW’s Investment Adviser (Unrestricted) licence. Each copying relationship is treated as a personalised recommendation made to you based on the selected Lead Trader’s activity, while you retain ultimate discretion to start, modify, or stop copying; and (d) the PAMM (Percentage Allocation Management Module) Service described in Clause 13, under which you may, by accepting a PAMM Mandate, appoint MPW, acting through a designated PAMM Manager, to manage a PAMM Sub-Account on a discretionary basis. Transactions, results, and fees are allocated proportionally among Participants in accordance with the applicable Allocation Coefficients. PAMM is provided as a discretionary allocation management service under MPW’s Investment Adviser (Unrestricted) licence.

Investment Advice, in any of the forms described above, is provided only where you and MPW have expressly agreed to an advisory engagement. For Copy Trading, that agreement is made when you elect through the Platform to follow a specific Lead Trader or Copy Trading Strategy. For PAMM, it is made when you accept the relevant PAMM Mandate for a specific PAMM Account.

Unless and until you opt into an advisory Service in this way, the Platform operates on an execution-only basis, subject to any appropriateness assessment required for complex products under the Suitability and Appropriateness Policy. You may opt into Copy Trading or PAMM only where the relevant Service is available to you and you satisfy the additional requirements set out in Clauses 12 and 13.

3.3 No Other Services

MPW provides only those services that it is licensed to provide by the FSC and that it expressly offers under these Terms. MPW does not provide tax advice, legal advice, accounting advice, or any other professional advice outside the scope of its FSC licences. You are responsible for obtaining such advice from appropriately qualified professionals where you need it.

In particular, MPW does not operate as a currency exchange, money transmission service, remittance provider, or crypto-asset exchange, and the Deposit and Withdrawal facilities described in Clauses 7 and 8 must not be used for such purposes.

3.4 Services Subject to Eligibility and Availability

Not all Services are available to all Clients. Specific Services may be restricted by reference to your categorisation, jurisdiction of residence, CIP outcome, KYC status, Account type, regulatory status, product eligibility, or any other criterion that MPW reasonably applies.

MPW may, at any time and at its reasonable discretion, modify the range of Services it offers, add new Services, withdraw existing Services, restrict access to particular Services or financial instruments, or make any Service, product, instrument, Account feature, or Platform functionality available only on specific conditions. Where such changes are material and affect you, MPW will notify you in accordance with Clause 26.

MPW may decline to provide any specific Service to any Client where doing so is, in its reasonable assessment, inconsistent with Applicable Law, MPW’s risk appetite, its licence conditions, its internal policies, the requirements of any third-party service provider, or any legal, regulatory, operational, financial-crime, sanctions, execution, custody, liquidity, or risk-management consideration.

The Services are also subject to the Product Terms Schedule, Order Types and Execution Mechanics Schedule, Corporate Actions and Product Events Schedule, Custody and Client Assets Schedule, and Market Data and Platform Use Schedule, in each case to the extent relevant to the Service, product, instrument, Transaction, Account feature, or Platform functionality used by you.

4. Account Opening, KYC, and Ongoing Due Diligence

4.1 Account Opening

1. You apply to open an Account through the Platform, providing the information required by the KYC Onboarding Requirements Notice.

2. MPW conducts onboarding checks. These include identity verification, address verification, source-of-funds and source-of-wealth assessment, sanctions screening, PEP screening, adverse-media screening, and (where applicable) tax-status verification.

3. MPW may request additional information or documentation at any stage. You agree to provide such information promptly, accurately, and in the form MPW reasonably specifies.

4. MPW may, at its reasonable discretion, accept or decline your application. MPW is not required to provide reasons for declining.

5. On acceptance, MPW notifies you that your Account is open and ready for Deposits. The Effective Date of these Terms is the date of notification.

4.2 Accuracy and Updates

You confirm that all information you provide to MPW is true, accurate, complete, and not misleading when it is provided.

You must notify MPW promptly, and in any event within five (5) Business Days, of any material change to that information. This includes changes to your name, address, nationality, tax residence, source of funds or wealth, PEP status, sanctions status, bank account details, or any other information relevant to your KYC profile.

Failure to provide accurate or up-to-date information is a material breach of these Terms and may result in your Account being suspended or terminated. It may also result in reporting to the relevant authorities where required or permitted by Applicable Law and may give rise to a Compliance Review Fee under Clause 11.2.

4.3 Ongoing Due Diligence and Periodic Review

MPW will periodically review your KYC profile in accordance with its AML/CFT/CPF Policy, and the KYC Onboarding Requirements Notice. As part of these reviews, you may be asked to provide updated information, confirmations, or documents. You agree to provide them promptly and, in any event, within the timeframe specified.

Enhanced due diligence may be applied where appropriate. This may include cases where a Client is a politically exposed person, relates to a higher-risk jurisdiction, or otherwise presents an increased financial-crime, sanctions, fraud, or regulatory risk. In those circumstances, additional restrictions, monitoring, transaction-screening controls, lower review thresholds, or other risk-mitigation measures may also be applied.

If your circumstances change so that you are no longer eligible to open or maintain an Account, including if you become a Sanctioned Person or become resident, incorporated, established, or otherwise located in a Restricted Jurisdiction, your Account may be suspended, restricted, or closed in accordance with Clause 23.

Periodic reviews conducted on MPW’s ordinary review cycle do not attract a Compliance Review Fee unless a Compliance Review Event arises in the course of the review.

5. Orders, Execution, and Best Execution

5.1 Order Placement

You may place Orders only through the Platform or through any other channel that MPW specifies or accepts from time to time.

Each Order must identify the relevant financial instrument, whether the Order is to buy or sell, the size or quantity, and any applicable conditions. These may include a limit price, stop price, expiry, time in force, or any other execution parameter. The Platform may support different Order types from time to time, and the available Order types, their features, and their meanings will be described on the Platform, in the Platform help materials, or in any other materials made available to you.

Orders must be placed using your Account credentials and any authentication procedures required for your Account, including multi-factor authentication where applicable. You are responsible for keeping your credentials, devices, authentication methods, and access codes confidential and secure.

Any Order placed through the Platform, or through any other permitted channel, using your Account credentials and the applicable authentication procedures will be treated as having been validly placed by you or on your behalf, unless MPW has received prior notice that your credentials, device, or authentication method has been lost, stolen, compromised, or used without authority.

MPW may rely on and act upon any Order that appears to have been validly submitted through the Platform or any other permitted channel using your Account credentials and the applicable authentication procedures. It is not required to verify the identity or authority of the person placing the Order beyond those authentication procedures, unless required by Applicable Law or where there is reason to suspect unauthorised use, fraud, error, market abuse, or other improper activity.

Orders are also subject to the Order Types and Execution Mechanics Schedule and, where relevant, the Market Data and Platform Use Schedule. Those schedules explain, among other things, the operation of supported Order types, trigger rules, execution limitations, slippage, gapping, partial fills, automated order flows, and Platform pricing.

5.2 Order Acceptance and Rejection

MPW may, acting reasonably and without prior notice, reject, delay, suspend or decline to transmit or execute any Order where MPW determines that: (a) accepting, transmitting or executing the Order would or may be inconsistent with Applicable Law, including AML/CFT, CPF, sanctions, market-conduct, investor-protection, client-classification or other regulatory obligations; (b) there are insufficient funds, securities, collateral or available margin in your Account to satisfy the Order or any related fees, charges, margin requirements or settlement obligations; (c) MPW reasonably suspects fraud, error, mistake, unauthorised use, market abuse, market manipulation, insider dealing or any conduct prohibited under Clause 5.14 of Schedule 5, or other improper, unlawful or suspicious conduct; (d) market conditions, liquidity constraints, price volatility, trading halts, technical issues, system outages, exchange rules, trading venue requirements, liquidity provider restrictions, counterparty restrictions or other operational factors prevent or materially affect acceptance, transmission or execution of the Order; (e) the Order relates to a financial instrument, market, jurisdiction, trading strategy or transaction type that MPW has restricted, suspended or made unavailable for your Account or for Clients generally; (f) accepting, transmitting or executing the Order would or may breach any applicable leverage, margin, concentration, exposure or position-limit framework, including the Leverage, Margin and Negative Balance Protection Policy; (g) the Order is, in MPW’s reasonable assessment, inappropriate for you having regard to your Client Investment Profile, knowledge and experience, risk tolerance, financial situation, investment objectives, client classification, or the outcome of any suitability or appropriateness assessment conducted under the Suitability and Appropriateness Policy; (h) MPW is unable to complete any required account, KYC, AML/CFT, CPF, sanctions, source-of-funds, source-of-wealth, tax, client-classification, suitability, appropriateness, risk or other compliance checks; (i) MPW has reasonable grounds to believe that accepting, transmitting or executing the Order may expose MPW, any Client, any liquidity provider, trading venue, custodian, counterparty or other third party to legal, regulatory, operational, credit, settlement, reputational or financial risk; or (j) any other circumstance exists which MPW, acting reasonably and in good faith, considers justifies rejection, delay, suspension or non-execution of the Order.

Where MPW rejects or delays an Order, MPW will use reasonable efforts to notify you promptly through the Platform. MPW is not liable for any loss arising from rejection or delay made on a reasonable basis under this Clause 5.2.

5.3 Best Execution

Where MPW executes Orders on your behalf, MPW shall take all sufficient steps to obtain the best possible result for you in accordance with its Best Execution Policy and Applicable Law.

The Best Execution Policy describes the execution factors that MPW may consider, including price, costs, speed, likelihood of execution and settlement, size, nature of the Order, market conditions, available liquidity, and any other relevant consideration. It also describes the execution venues, liquidity providers, counterparties or other execution arrangements that MPW may use from time to time.

By placing an Order with MPW, you acknowledge and agree that your Orders may be handled and executed in accordance with the Best Execution Policy. You also consent, where applicable, to MPW executing Orders outside a regulated market, exchange or other trading venue, including by transmitting Orders to liquidity providers, market makers, counterparties or other execution venues used by MPW.

MPW may update its Best Execution Policy from time to time. The current version of the Best Execution Policy will be made available through the Platform, website or such other channel as MPW may specify.

Best execution does not guarantee execution, execution at a particular price, execution at the price displayed on the Platform, or execution without slippage or delay. Further information on execution mechanics, Platform prices, market data, order triggers, and execution limitations is set out in the Order Types and Execution Mechanics Schedule and the Market Data and Platform Use Schedule.

5.4 Order Aggregation and Allocation

MPW may aggregate your Order with Orders of other Clients, where permitted by Applicable Law and MPW’s policies, and where MPW reasonably considers that such aggregation is unlikely to operate to the overall disadvantage of any Client whose Order is aggregated.

You acknowledge that, although aggregation may operate to your advantage in some cases, it may in other cases result in a less favourable price, volume, execution outcome or allocation than if your Order had been executed separately.

Where Orders are aggregated and the aggregated Order is executed in whole or in part, MPW shall allocate the resulting Transactions fairly and consistently among the relevant Clients in accordance with its order allocation methodology, Applicable Law and any relevant internal policies. Such methodology may include allocation on a pro rata basis, time-priority basis, or any other fair and objective basis determined by MPW, having regard to the nature and circumstances of the relevant Orders.

MPW shall not give unfair preference to one Client over another when allocating aggregated Orders. Where an aggregated Order is only partially executed, MPW may allocate the executed portion among the relevant Clients on a fair and reasonable basis, which may result in your Order being only partially filled or not filled.

Where MPW reasonably considers that aggregation may operate to your disadvantage in a particular case, MPW shall not aggregate your Order unless you have given your express consent or unless aggregation is otherwise permitted under Applicable Law.

5.5 Errors, Mistakes, and Manifest Error

If MPW identifies that any Order, Transaction, price, quote, execution, confirmation, statement, Account balance or Account entry has resulted from a Manifest Error, MPW may, acting reasonably and in good faith, cancel, void, reverse, amend or correct the affected Order, Transaction, price, quote, execution, confirmation, statement, Account balance or Account entry.

For these purposes, a “Manifest Error” means an obvious or material error, whether caused by MPW, the Platform, a trading venue, liquidity provider, market data provider, counterparty, custodian, settlement system, third-party service provider or the Client, including: (a) an obvious mispricing or non-market price relative to prevailing market conditions; (b) an incorrect, stale, delayed or corrupted quote or market data feed; (c) a system, processing, calculation, transmission, display, booking, settlement or reconciliation error; (d) an Order placed with a manifest input error, including an obviously incorrect price, size, instrument, direction or other execution parameter; or (e) any other error which MPW reasonably determines to be obvious, material or inconsistent with fair and orderly market conditions.

Where MPW determines that a Manifest Error has occurred, MPW may take such corrective action as it considers reasonably necessary to place the relevant Account, Order, Transaction, cash balance, securities position, margin position or other Account entry in the position it would have been in had the Manifest Error not occurred.

MPW will notify you of any material correction made under this clause as soon as reasonably practicable. MPW shall not be liable for any loss of profit, loss of opportunity, indirect loss or consequential loss arising from the cancellation, reversal, amendment or correction of a Manifest Error, subject always to MPW’s fraud, wilful misconduct, gross negligence and any liability which cannot be excluded under Applicable Law.

5.6 Confirmations and Statements

MPW will provide confirmations of executed Transactions through the Platform, by in-app notification, email or any other communication method specified by MPW, promptly after execution or as otherwise required by Applicable Law.

MPW will provide Account statements showing your Account activity, Transactions, cash balances, securities positions, fees, charges, margin position, where applicable, and other relevant Account information, at such frequency and through such medium as MPW may determine in accordance with Applicable Law and FSC requirements.

You agree to review all confirmations, Account statements and Account information made available to you promptly. You must notify MPW in writing of any error, omission, discrepancy or unauthorised Transaction within ten (10) Business Days after the relevant confirmation, statement or Account information is made available to you.

If you do not notify MPW within that period, the relevant confirmation, statement or Account information shall be treated as accepted by you and, in the absence of manifest error, fraud, wilful misconduct or any matter which cannot be excluded under Applicable Law, shall be conclusive and binding on you.

6. Client Money and Segregation

6.1 Status of Client Money

Funds deposited by you shall be treated as Client Money from the moment they are received by MPW, whether received directly into a Client Money account or first received into a designated transit or collection account before being promptly transferred to a Client Money account.

Client Money is held by MPW on trust for you and for other Clients whose money is pooled or co-mingled in the relevant Client Money account, in accordance with this Clause 6, Applicable Law and FSC requirements.

Client Money is not the property of MPW and shall be segregated from MPW’s own money. It shall not be available to MPW’s general creditors in the event of an Insolvency Event affecting MPW. The arrangements described in this Clause 6 are intended to preserve the proprietary and beneficial interests of Clients in Client Money and to give effect to the applicable client money segregation requirements.

6.2 Holding of Client Money

MPW shall hold Client Money in one or more designated client money accounts maintained with one or more banks, custodians, payment institutions, electronic money institutions or other regulated account providers approved by MPW, subject always to Applicable Law and FSC requirements.

Each designated client money account shall be titled or designated in a manner that identifies it as an account holding Client Money and distinguishes it from MPW’s own corporate or operating accounts, for example: “Monolith Private Wealth Limited — Client Money Account”. Client Money shall be held separately from MPW’s own funds. MPW shall not co-mingle Client Money with its own corporate, operating or proprietary funds in any account.

MPW shall exercise reasonable skill, care and diligence in selecting, appointing and periodically reviewing any account provider with which Client Money is held, having regard to matters such as the provider’s regulatory status, financial soundness, reputation, operational reliability, jurisdiction, safeguarding arrangements, and ability to provide appropriate client money account arrangements.

Client Money may be held in pooled client money accounts together with Client Money belonging to other Clients. MPW shall record each Client’s individual entitlement to Client Money in its internal records and ledgers, including the Client Money Ledger, and shall reconcile such records and ledgers against the relevant account provider statements in accordance with Clause 6.4.

Where Client Money is denominated in a currency other than Mauritian Rupees, MPW shall, where reasonably available and practicable, hold such Client Money in a designated client money account denominated in that currency or in another appropriate account arrangement permitted by Applicable Law. If MPW is required or permitted to convert Client Money into another currency, such conversion shall be carried out in accordance with these Terms and any applicable exchange rate provisions.

6.3 No Use of Client Money for Proprietary Purposes

MPW shall not use Client Money to fund its own operations, to finance its own business activities, to extend credit on its own balance sheet, or for any purpose other than holding, transferring, applying or using such Client Money for the benefit of the relevant Client, including for the settlement of Transactions, payment of fees, charges or liabilities due from that Client, satisfaction of Withdrawals, or any other purpose permitted by these Terms and Applicable Law. MPW shall not lend Client Money to any third party or pledge, charge, hypothecate or otherwise grant security over Client Money for MPW’s own obligations.

Client Money may, where necessary, be transferred, applied or held with banks, custodians, payment institutions, liquidity providers, brokers, counterparties, settlement systems or other approved service providers for the purpose of executing, settling, margining, clearing or otherwise giving effect to Transactions or instructions relating to the relevant Client, subject always to Applicable Law and FSC requirements.

Clients are not entitled to receive interest on Client Money held in designated client money accounts, except where expressly stated in the Costs and Charges Schedule or otherwise agreed in writing by MPW. Any interest, return, rebate or similar amount received by MPW in respect of Client Money shall be treated and allocated in accordance with the Costs and Charges Schedule and any disclosures made to you.

6.4 Reconciliation — Internal Ledger to Bank Statements

MPW shall maintain a reconciliation framework designed to ensure that the Client Money Ledger remains accurate and that the aggregate balance held in designated client money accounts is at least equal to the aggregate amount of Client Money owed to all Clients.

Internal ledger. MPW shall maintain the Client Money Ledger as part of its internal books and records. Each Deposit, Withdrawal, Transaction settlement, fee, charge, adjustment and other Client Money movement shall be recorded in the Client Money Ledger in a timely manner.

Daily reconciliation. MPW shall reconcile the Client Money Ledger against the statements, records or confirmations provided by the relevant account providers at least once on each Business Day. MPW shall promptly identify, investigate and record any discrepancy identified through the reconciliation process.

Reconciliation breaks. Any reconciliation break, being a discrepancy between the Client Money Ledger and the relevant external account records, shall be investigated and resolved as soon as reasonably practicable and within the timeframe set out in MPW’s internal procedures. Material reconciliation breaks shall be escalated to the Compliance Officer and, where required, notified to the FSC or any other competent authority in accordance with Applicable Law and MPW’s regulatory obligations.

Top-up. Where a reconciliation shows that the aggregate balance held in designated client money accounts is less than the aggregate amount of Client Money owed to Clients, including as a result of a timing difference, processing issue or operational error, MPW shall promptly transfer sufficient funds from its own resources to the relevant designated client money account to restore the required aggregate balance, pending investigation and final resolution.

Removal of excess. Where a reconciliation shows that the aggregate balance held in designated client money accounts exceeds the aggregate amount of Client Money owed to Clients, including where MPW’s own funds have been inadvertently credited to or retained in a designated client money account, MPW may promptly remove the excess amount and transfer it to MPW’s own corporate account, provided that such removal does not cause a shortfall in Client Money.

Independent verification. MPW’s reconciliation framework, Client Money Ledger and related controls may be subject to review as part of MPW’s external audit and may be reviewed by the FSC or any other competent authority in accordance with Applicable Law.

Why this matters to you: The combination of segregation (Clause 6.2), the prohibition on proprietary use (Clause 6.3), and daily reconciliation (Clause 6.4) is designed so that your money remains identifiable as yours throughout your relationship with MPW. In the unlikely event of an Insolvency Event affecting MPW, your Client Money is intended to be returned to you rather than treated as part of MPW's general estate. The protection is, however, dependent on MPW's compliance with this Clause 6 and on the regulatory framework that applies at the time — MPW does not guarantee a particular outcome in an Insolvency Event and clients should consider this risk.

6.5 Treatment in Insolvency

In the event of an Insolvency Event affecting MPW, Client Money held in designated client money accounts is intended to be returned to the Clients beneficially entitled to it in accordance with Applicable Law in force at the relevant time. Any return of Client Money may be subject to applicable deductions, costs of distribution, reconciliation requirements, statutory priorities, insolvency procedures, and any amounts properly due from the relevant Client to MPW, including margin obligations, fees, charges, unsettled Transactions or other outstanding liabilities.

Where MPW holds or arranges the holding of your financial instruments through a custody arrangement, such financial instruments are not treated as Client Money. Their treatment in the event of an Insolvency Event affecting MPW, a custodian, sub-custodian, settlement system, broker, nominee or other relevant third party will depend on the applicable custody arrangements, the law of the place where the assets are held, the relevant account structure, and the contractual and legal rights applicable to those assets.

Further information on custody arrangements, including the use of custodians, sub-custodians, nominees or omnibus accounts, is set out in the Platform’s custody disclosures or such other custody disclosures as MPW may make available from time to time.

The treatment of financial instruments, custody arrangements, nominee or omnibus structures, fractional securities, voting rights, income, corporate actions, securities lending, rehypothecation, and custodian or sub-custodian risk is further described in the Custody and Client Assets Schedule.

6.6 Credit Institution Risk

Important risk disclosure: Although MPW holds Client Money in designated client money accounts with approved banks, custodians, payment institutions, electronic money institutions or other regulated account providers selected with reasonable skill, care and diligence, MPW does not guarantee the solvency or performance of any such account provider.

If an Insolvency Event affects any account provider with which Client Money is held, the return of your Client Money may be delayed, reduced or subject to the applicable insolvency, resolution, depositor protection, safeguarding or other legal regime applying to that account provider.

MPW shall use reasonable efforts to mitigate account-provider risk, including by conducting due diligence, periodically reviewing approved account providers, and, where appropriate and practicable, diversifying Client Money across more than one account provider. However, MPW cannot eliminate the risk of loss, delay or reduced recovery arising from the default, insolvency or failure of an account provider.

7. Deposits

7.1 Permitted Deposit Methods

MPW accepts Deposits through the Deposit methods made available on the Platform from time to time. The supported Deposit methods may vary depending on your jurisdiction, Account currency, Client classification, payment provider availability, regulatory requirements, internal risk controls and any other criteria determined by MPW.

Supported Deposit methods may include:

1. bank wire transfer, including SWIFT or local clearing systems;

2. direct local bank transfer, where supported in your jurisdiction;

3. debit card or, where supported, credit card payments processed through MPW’s approved payment service providers; and

4. any other Deposit method approved by MPW from time to time.

Before making a Deposit, you should check the Platform for the Deposit methods currently available to you, including any applicable fees, charges, minimum and maximum Deposit amounts, supported currencies, processing times, cut-off times and additional verification requirements.

MPW may add, suspend, restrict or remove any Deposit method at any time, including for legal, regulatory, operational, risk-management, payment-provider or security reasons.

7.2 Source of Funds

Deposits must be made from a Linked Account held in your name or, where MPW expressly permits, from an account or card held in the name of an approved Connected Person whose relationship to you and due diligence status have been accepted by MPW.

MPW does not accept Deposits from third parties, being any person or entity other than you or an approved Connected Person. If MPW receives funds from a third party, MPW may reject the Deposit, return the funds to the source account, deduct any costs reasonably incurred, request additional information or documentation, and restrict further activity on your Account pending completion of any required due diligence, AML/CFT, CPF, sanctions, source-of-funds or source-of-wealth checks.

MPW does not accept cash Deposits, anonymous or untraceable crypto-asset Deposits, Deposits made through privacy-enhancing or obfuscation mechanisms, or Deposits from any source that MPW cannot reasonably verify as legitimate under its AML/CFT/CPF framework.

You must, upon MPW’s request, provide evidence of the source of funds and, where required, source of wealth relating to any Deposit. Such evidence may include bank statements, payslips, employment confirmations, tax records, sale-of-asset records, inheritance documents, gift declarations, business accounts, audited financial statements, loan agreements, or any other information or documentation reasonably required by MPW.

7.3 Currency and Conversion

MPW supports Deposits in the currencies made available on the Platform from time to time. The supported Deposit currencies may vary depending on your jurisdiction, Account type, Account currency, Deposit method, payment provider availability, and any applicable legal, regulatory, operational or risk-management requirements.

Where you Deposit funds in a currency different from your Account’s base currency, MPW may convert the funds into the Account’s base currency or another supported currency, unless MPW permits the funds to be held in the original Deposit currency. Any such conversion shall be made at the applicable conversion rate available to MPW at or around the time of conversion, together with any spread, fee, charge or mark-up disclosed in the Costs and Charges Schedule or on the Platform.

You acknowledge that exchange rates may fluctuate between the time you initiate a Deposit and the time the funds are received, processed and converted by MPW. MPW is not responsible for any exchange-rate movement, bank charge, payment provider charge, correspondent charge or other third-party cost incurred in connection with the Deposit or currency conversion, except to the extent caused by MPW’s fraud, wilful misconduct or gross negligence.

Where MPW offers Multi-Currency Accounts, you may be permitted to hold balances in more than one supported currency. The Platform will display the currencies available for your Account and any applicable conversion options, fees, limits, cut-off times and processing arrangements.

7.4 Processing Timeline

Indicative processing timelines, subject to the Deposit method and to MPW's verification:

Processing times are indicative and not guaranteed. Delays may arise from correspondent banks, payment service providers, AML/CFT verification, additional due diligence, or technical issues. MPW will use reasonable efforts to credit Deposits promptly once received and verified, and to notify you of any material delay.

7.5 Failed or Returned Deposits

Deposits that fail, including where a card payment is declined, a bank transfer is returned by the receiving bank, or a payment provider rejects the transaction, will not be credited to your Account. Where a Deposit has been credited to your Account and is subsequently reversed, recalled, charged back, or otherwise cancelled by the sending bank, payment provider, card network, or any other relevant intermediary, MPW may reverse the corresponding credit in accordance with Clause 9 (Refunds and Chargebacks). You are responsible for any costs, charges, fees, losses, or expenses reasonably incurred by MPW in connection with any failed, returned, reversed, recalled, or charged-back Deposit, including bank fees, payment-network fees, payment-provider charges, foreign-exchange costs, and administrative costs. MPW may debit such amounts from your Account.

7.6 Minimum and Maximum Deposits

Minimum and maximum Deposit amounts are set out on the Platform and may vary depending on the Deposit method, Client categorisation, Account currency, jurisdiction, and any applicable regulatory, operational, or risk-management requirements. MPW may, at its reasonable discretion, accept a Deposit below the published minimum or apply a Deposit limit below the published maximum where required or appropriate having regard to AML/CFT considerations, sanctions screening, fraud-prevention measures, payment-provider requirements, or other relevant risk factors. Deposits above specified thresholds may be subject to enhanced due diligence, source-of-funds and source-of-wealth checks, and additional verification before they are accepted or credited to your Account.

8. Withdrawals

8.1 Right to Withdraw

You may request a Withdrawal of available funds from your Account at any time, subject to:

1. completion of KYC and your continuing satisfaction of MPW’s KYC and client due diligence requirements;

2. satisfaction of any open Transaction settlement obligations, margin requirements, negative balances, outstanding fees, charges, or other amounts due to MPW;

3. sanctions screening, fraud-prevention checks, and AML/CFT review of the proposed Withdrawal;

4. verification of the destination account or payment instrument in accordance with Clause 8.3; and

5. any restriction, suspension, delay, or refusal reasonably imposed by MPW in accordance with Clause 8.7.

8.2 Withdrawal Process

You must submit a Withdrawal request through the Platform, specifying the amount to be withdrawn, the Account currency, and the destination Linked Account.

Before the Withdrawal is processed, the destination Linked Account will be verified against the requirements of Clause 8.3, and the conditions set out in Clause 8.1 must be satisfied. The proposed Withdrawal will also be subject to the applicable AML/CFT, sanctions-screening, fraud-prevention, and payment-verification checks.

Subject to satisfactory completion of those checks, MPW will initiate the Withdrawal from the relevant client account through the applicable banking or payment channel. You will be notified once the Withdrawal has been initiated and, where available, payment reference details will be provided to assist you in tracking the payment.

8.3 Destination of Withdrawals

Withdrawals will be paid only to a Linked Account in your name. A Withdrawal to an account in the name of a third party is not permitted, unless MPW has expressly approved that third party as a Connected Person following completion of its due diligence.

Where Deposits into your Account have been received from a particular Linked Account, MPW will, by default, return Withdrawals to that same Linked Account. If that Linked Account has been closed or is otherwise unavailable, MPW may permit the Withdrawal to be paid to a replacement Linked Account in your name, provided that the replacement Linked Account has been verified by MPW. This “same-source” approach is applied as an AML/CFT control.

Where you have nominated more than one Linked Account, you may select the Linked Account to which a Withdrawal is to be paid, provided that each such Linked Account has been verified and approved by MPW before use.

Where you nominate a new Linked Account, MPW may require additional verification before approving it, including confirmation through a small test transfer, documentary evidence of account ownership, identity re-confirmation, or any other checks reasonably required for AML/CFT, sanctions-screening, fraud-prevention, or payment-security purposes.

8.4 Restrictions on Exchange-Like Use of Deposit and Withdrawal Facilities

The Platform is a brokerage service; it is not a currency exchange, money transmission service, remittance provider, or crypto-asset exchange. The Deposit and Withdrawal facilities are provided solely to fund and defund your Account in connection with your use of the Services.

You must not use, or attempt to use, the Deposit and Withdrawal facilities to convert between currencies, payment methods, or asset classes outside the ordinary course of trading activity on the Platform. For these purposes, "exchange-like activity" includes, without limitation, any pattern in which funds are deposited through one payment method, currency, or asset class and a Withdrawal is requested through a different payment method, currency, or asset class, with no or minimal genuine trading activity on the Account in the intervening period.

Where MPW identifies, or reasonably suspects, exchange-like activity on your Account, MPW may, acting reasonably and without prior notice where it considers this appropriate: (a) refuse, delay, or reverse the Withdrawal request; (b) require you to withdraw via the same payment method, currency, and Linked Account through which the corresponding Deposit was received, in accordance with Clause 8.3; (c) apply enhanced Withdrawal fees or charges in respect of Withdrawals that MPW determines form part of exchange-like activity, as set out in the Costs and Charges Schedule; (d) require enhanced due diligence, source-of-funds verification, or additional AML/CFT screening before processing the Withdrawal; (e) impose minimum trading activity or holding period requirements before permitting a Withdrawal in a payment method, currency, or asset class different from the Deposit; (f) suspend, restrict, or terminate your Account in accordance with Clause 23; and (g) file a suspicious transaction report or take any other action required or permitted under Clause 22 and Applicable Law.

The assessment of whether activity is exchange-like will be made by MPW in its reasonable discretion, considering the nature and frequency of Deposits and Withdrawals, the volume and character of trading activity, the time elapsed between Deposit and Withdrawal, and any other relevant indicator. MPW's determination is not required to meet the standard of proof applicable in legal proceedings.

This Clause 8.4 is without prejudice to any other right MPW may have under these Terms, the Incorporated Documents, or Applicable Law to refuse, delay, or restrict a Withdrawal.

8.5 Currency

Withdrawals will be made in the Account currency by default. Where you request a Withdrawal to a Linked Account denominated in a different currency, MPW may convert the Withdrawal amount into the relevant currency at the applicable conversion rate, applying any spread, fee, or charge disclosed in the Costs and Charges Schedule. The rate applied will be the rate available to MPW at the time the conversion is processed.

Withdrawals may also be subject to charges imposed by the receiving bank, payment service provider, correspondent bank, card network, or other intermediary involved in processing the Withdrawal. MPW does not control those third-party charges and is not responsible for any deduction, delay, rejection, or conversion applied by those third parties.

8.6 Processing Timeline

Indicative processing timelines:

Processing times are indicative and not guaranteed. Delays may arise from compliance review, enhanced due diligence, correspondent banks, or technical issues. MPW will use reasonable efforts to process Withdrawals promptly.

8.7 Holds, Restrictions, and Delays

MPW may hold, restrict, suspend, delay, or refuse to process a Withdrawal where, in its reasonable assessment:

a) required KYC, client due diligence, enhanced due diligence, or AML/CFT verification has not been completed or remains outstanding;

b) the Withdrawal would leave your Account with insufficient resources to meet open Transaction obligations, settlement obligations, margin requirements, negative balances, unpaid fees, charges, or other amounts due;

c) sanctions screening, adverse media screening, fraud screening, or other compliance checks identify a potential match or concern requiring further review;

d) the proposed destination Linked Account has not been verified to MPW’s satisfaction;

e) the Deposit funding the Withdrawal has not yet settled, remains subject to recall, reversal, chargeback, or return, or there is a reasonable risk that it may be reversed, recalled, charged back, or returned, subject to Clause 9;

f) there is a reasonable suspicion of fraud, account compromise, mistaken instruction, unauthorised activity, market abuse, conduct prohibited under Clause 5.14 of Schedule 5, misuse of the Platform, or other unlawful or improper activity, and further investigation is required;

g) the hold, restriction, freeze, block, delay, refusal, or other prevention of the movement of funds is required or permitted by Applicable Law, any competent authority, any court order, FIAMLA, AML/CFT legislation, sanctions law, or any applicable regulatory requirement; or

h) operational, banking, payment-provider, market, liquidity, system, or technical issues prevent or materially affect the processing of the Withdrawal.

Where a Withdrawal is held, restricted, suspended, delayed, or refused, reasonable efforts will be made to notify you of the reason, unless disclosure is prohibited by Applicable Law or by any competent authority, including where notification may constitute tipping off under FIAMLA or applicable AML/CFT legislation. The Withdrawal will be released or processed as promptly as reasonably practicable once the relevant matter has been resolved to MPW’s satisfaction.

8.8 Fees and Charges

Withdrawal fees, where applicable, are set out in the Costs and Charges Schedule and may be deducted from the Withdrawal amount or debited from your Account. Banks, payment service providers, correspondent banks, card networks, or other intermediaries involved in the receiving or payment chain may also apply their own fees, charges, deductions, or currency-conversion costs. MPW does not control those third-party charges and is not responsible for them.

Where a Withdrawal is rejected, returned, recalled, reversed, or otherwise not completed by the receiving bank, payment service provider, correspondent bank, card network, or any other relevant intermediary, MPW may pass on to you any costs, fees, charges, losses, or expenses reasonably incurred by MPW in connection with that rejection, return, recall, reversal, or non-completion. MPW may debit such amounts from your Account.

8.9 Minimum and Maximum Withdrawals

Minimum Withdrawal amounts are set out on the Platform and may vary by Withdrawal method, Account currency, Client categorisation, jurisdiction, or applicable operational, regulatory, or risk-management requirements. MPW may defer or decline to process a Withdrawal request below the applicable minimum amount until you submit a Withdrawal request for an amount equal to or greater than the applicable minimum, or until your Account balance is otherwise eligible for Withdrawal.

Withdrawals above specified thresholds may be subject to enhanced due diligence, additional verification, source-of-funds or source-of-wealth checks, and direct confirmation of the Withdrawal request through an out-of-band channel before they are processed.

9. Refunds and Chargebacks

9.1 Refunds — Scope

This Clause 9 addresses three distinct concepts that are sometimes confused:

Refunds of fees: where MPW has charged a fee in error, applied an incorrect amount, or otherwise agrees that a refund is due. Refunds of fees are dealt with in Clause 9.2.

Return of available funds: this is not a “refund” in the technical sense. A return of available funds means a Withdrawal of available funds standing to the credit of your Account and is dealt with under Clause 8.

Chargebacks of card payments: where a card-payment Deposit is reversed, recalled, charged back, or otherwise cancelled by the card issuer, card network, payment provider, or any other relevant intermediary, whether at your request, at the issuer’s initiative, or otherwise. Chargebacks are dealt with in Clauses 9.3 to 9.6.

9.2 Refunds of Fees

If you believe that any fee, commission, spread, charge, or other amount has been incorrectly applied to your Account, you should raise the matter promptly through the Platform support channel or in accordance with the Complaints Handling Procedure. The matter will be reviewed, and you may be asked to provide any information or evidence reasonably needed to investigate it.

If a refund is due, the relevant amount will be credited to your Account and the reason for the decision will be provided. If no refund is due, you will be given an explanation. You may escalate the matter in accordance with the Complaints Handling Procedure.

9.3 Chargebacks — General

Important: A Chargeback is a mechanism provided by card networks, including Visa, Mastercard, and other card schemes, that allows a cardholder to dispute a card transaction with the relevant card issuer. MPW treats any Chargeback relating to a Deposit made to MPW as a serious matter.

Brokerage services provided through the Platform are delivered electronically and once provided or made available, are generally not comparable to the consumer-protection scenarios for which the Chargeback mechanism is primarily designed, such as non-delivery of physical goods, fraudulent merchants, or unauthorised card use.

Accordingly, where MPW considers that a Chargeback has been raised improperly, inaccurately, or without valid basis, MPW reserves all rights to dispute the Chargeback, provide evidence to the relevant card issuer, payment provider, or card network, recover any related costs, and take any other action available to it under these Terms, Applicable Law, and the relevant card-network rules.

9.4 Effect of a Chargeback

When MPW receives notification of a Chargeback in respect of a Deposit credited to your Account, MPW may immediately reverse the corresponding credit on your Account, whether or not the Deposit amount has been used to fund Transactions or other activity in the meantime.

If the reversal causes your Account to have a negative balance, the negative amount will constitute a debt owed by you to MPW, due and payable on demand. You must satisfy that debt promptly. MPW may apply set-off against any cash balance, asset, credit, receivable, or other amount that MPW owes or holds for you, whether in the same Account or any other account held with MPW.

If, after the reversal, your Account remains in positive balance but the Chargeback amount exceeds the available positive balance, the shortfall will also constitute a debt owed by you to MPW, due and payable on demand.

MPW may suspend, restrict, or limit your Account, including Deposits, Withdrawals, Transactions, trading access, or other Platform functionality, pending resolution of the Chargeback dispute. MPW may continue to apply such restrictions where it has concerns regarding the integrity, security, funding status, or lawful use of the Account.

9.5 Disputing a Chargeback

MPW may defend or contest any Chargeback that it considers to have been improperly, inaccurately, or unjustifiably raised. In doing so, MPW may rely on the Order, Deposit, Account, onboarding, KYC, authentication, verification, communication, and Platform records that MPW maintains in the ordinary course of business.

MPW may request your reasonable cooperation in connection with any Chargeback investigation or dispute, including asking you to confirm to your card issuer, payment provider, or card network that the relevant Deposit was authorised and that the related Account activity was undertaken by you or with your authority. You agree to provide such reasonable cooperation promptly.

Where the Chargeback is upheld by the card issuer, payment provider, or card network, MPW remains entitled to recover from you the amount of the Chargeback, less any amount already recovered, netted off, or set off by MPW, together with any related costs, fees, charges, losses, or expenses reasonably incurred by MPW, in accordance with Clause 9.6.

9.6 Costs of Chargebacks

Where a Chargeback is raised in respect of a Deposit made to MPW, MPW reserves the right to debit or charge to your Account:

a) the amount of the Chargeback or payment reversal;

b) any fees, charges, penalties, or assessments imposed by the relevant card network, card issuer, payment service provider, acquiring bank, correspondent bank, or other payment intermediary; and

c) any costs, losses, or expenses reasonably incurred by MPW in investigating, defending, contesting, or responding to the Chargeback, including external advisory, legal, or recovery costs in non-routine cases.

These amounts are payable by you on demand. MPW may recover such amounts by applying set-off, deducting them from available Account balances, restricting or suspending the Account, or taking any other action available to MPW under these Terms, Applicable Law, or normal legal recovery channels.

Where MPW reasonably considers that a Chargeback has been raised in bad faith, fraudulently, dishonestly, without valid basis, or in breach of these Terms, MPW may suspend, restrict, or terminate your Account in accordance with Clause 23 and may report the matter to any relevant payment provider, card network, competent authority, regulator, law-enforcement agency, or fraud-prevention body.

9.7 Anti-Money Laundering Considerations

Where a pattern of Chargebacks, a single Chargeback in unusual circumstances, or a Chargeback combined with other risk indicators gives rise to an AML/CFT, fraud, sanctions, or financial-crime concern, MPW may take any action it considers necessary or appropriate under Applicable Law, including filing a suspicious transaction report with the FIU.

Where MPW has filed, is considering filing, or is otherwise involved in the assessment of a suspicious transaction report, MPW may be subject to tipping-off restrictions under FIAMLA or another Applicable Law. In such circumstances, MPW may be unable to disclose certain information to you, including the reason for any delay, restriction, refusal, suspension, investigation, or other action taken in relation to your Account.

MPW will not permit Chargebacks to be used as a means of extracting funds outside the normal Withdrawal framework, including where a client deposits funds by card, undertakes Transactions or other Account activity, and then initiates or procures a Chargeback in order to recover funds outside MPW’s Withdrawal, AML/CFT, sanctions-screening, and Linked Account controls. MPW may treat such conduct as a serious breach of these Terms, a misuse of the Platform, and a potential AML/CFT or financial-crime red flag.

10. Cancellation and Account Closure

10.1 Right to Close Your Account

You may request to close your Account at any time by giving notice through the Platform or support channel. Once MPW receives a closure request, your Account will enter in a wind-down process. Where you participate in any PAMM Account, closure takes effect only once the relevant Mandate has been terminated through full redemption in accordance with Clause 13.

The wind-down process may include:

a) cancelling any open or pending Orders, and stopping new Orders, Deposits, Copy Trading links, and PAMM subscriptions;

b) terminating Copy Trading links under Clause 12.9 and redeeming any Mandate under Clause 13.11;

c) closing, transferring, or otherwise dealing with any open positions;

d) settling any outstanding obligations owed to MPW, including unsettled Transactions, margin obligations, negative balances not covered by Negative Balance Protection, fees, charges, or other amounts due;

e) releasing any remaining Client Money to a verified Linked Account in accordance with Clauses 8.3 and 23.7; and

f) issuing a final Account statement or confirmation of closure.

If you have open positions when you request closure, you must close them before the Account can be closed. Alternatively, where available and subject to agreement, Applicable Law, market conditions, operational feasibility, and any relevant third-party requirements, a managed close-out or transfer of positions or non-cash assets to another provider may be arranged at your cost. If you have not closed your positions, or agreed a transfer, within fourteen (14) calendar days of your closure request, MPW may close them at prevailing market prices in accordance with the Best Execution Policy, without further notice, and you will bear the resulting market risk and costs.

Account closure may be delayed until all open positions and outstanding obligations have been dealt with to MPW’s satisfaction. MPW may also defer completing the closure, and releasing any Client Money, while any suspension, restriction, Compliance Review Event, or compliance review affecting your Account is open or pending, subject to Clause 8.7.

No Account Closure Fee is payable on a closure request under this Clause 10.1, except where Clause 23.6 treats the closure as a Client Misconduct Closure. A closure request does not affect MPW’s rights under Clauses 23.4.1 and 23.6.

Residual Client Money will be paid, or held, in accordance with Clause 23.7. Account records will be retained for the period required by Applicable Law, typically seven (7) years from termination, or for any longer period required for AML/CFT, sanctions, tax, regulatory, dispute-resolution, or other legal purposes.

10.2 No Specific Statutory Cooling-Off Right

Mauritian law does not impose a specific consumer-style “cooling-off” period for brokerage or investment services comparable to the cooling-off rights that may apply in some other jurisdictions or legal frameworks, such as the EU distance marketing regime for certain financial services.

Once you place an Order and that Order is executed, you become bound by the resulting Transaction. You bear the market risk and reward of that Transaction from the time of execution, including any profit, loss, price movement, cost, fee, or margin consequence arising from it. You should consider these consequences carefully before placing any Order.

10.3 Cancellation of Pending Orders

You may cancel a pending Order, being an Order that has not yet been executed, at any time through the Platform, subject to system availability, market conditions, and the rules or requirements of any relevant trading venue, liquidity provider, execution venue, or other third party.

Once an Order has been executed, whether in whole or in part, the executed portion cannot be cancelled, withdrawn, or reversed through cancellation. You may seek to close or offset the resulting position by entering into an offsetting Transaction, but you will bear all market risk, price movement, spread, commission, fees, charges, slippage, and other costs associated with doing so.

Certain Order types, including immediate-or-cancel, fill-or-kill, market, stop, or other conditional Orders, may be executed, partially executed, cancelled, rejected, or expired automatically in accordance with their terms, Platform functionality, market conditions, or the rules of the relevant trading venue, liquidity provider, execution venue, or other third party. Any executed portion remains valid and binding.

10.4 Modification or Cancellation of Subscriptions and Recurring Services

Where you have subscribed to a recurring Service, including a managed advisory engagement, subscription-based data feed, research service, software tool, or other recurring paid service, you may cancel that subscription by giving the notice specified in the relevant subscription terms. Where no notice period is specified, you may cancel the subscription by giving not less than fourteen (14) calendar days’ notice through the Platform or support channel.

Cancellation of a subscription Service does not, by itself, close your Account. Your Account will continue to operate unless and until you request Account closure in accordance with Clause 10.1.

Unless the relevant subscription terms provide otherwise, any pre-paid subscription fees may be refunded on a pro-rata basis for the unused portion of the subscription period, less any reasonable administrative costs, third-party costs, taxes, payment-processing costs, or other amounts reasonably incurred by MPW in connection with the subscription or its cancellation.

10.5 MPW's Right to Terminate or Close Your Account

MPW may suspend or restrict the Services, terminate these Terms, or close your Account, in whole or in part, in accordance with Clause 23 (Suspension, Termination, and Account Closure). In particular:

a) MPW may terminate on notice for any reason under Clause 23.3, in which case reasonable efforts will be made to support an orderly wind-down of your Account;

b) MPW may terminate with immediate effect under Clause 23.4, including on a Client Misconduct Closure under Clause 23.4.1, to which the Account Closure Fee under Clause 23.6 applies; and

c) the wind-down and effect of any termination by MPW are governed by Clause 23.7.

11. Fees, Costs, and Charges

11.1 General

The fees, costs, spreads, commissions, and other charges that apply to the Services are set out in the Costs and Charges Schedule.

Certain charges are not part of the ordinary cost of the Services and arise only when a specific event occurs. These are:

a) the Compliance Review Fee under Clause 11.2;

b) enhanced Withdrawal fees in respect of exchange-like activity under Clause 8.4;

c) Chargeback costs under Clause 9.6;

d) Inactivity Fees under Clause 20 and the Dormant Account Policy; and

e) the Account Closure Fee under Clause 23.6, which is payable only on a Client Misconduct Closure.

Each of these charges is payable only in the circumstances, and subject to the limits, set out in the provision that creates it.

MPW may update the Costs and Charges Schedule from time to time. Where a change is material, MPW will notify you in accordance with Clause 26. A change to any charge listed in the paragraph above applies only to events that occur after the change takes effect.

MPW will provide information on costs and charges before and after the provision of the relevant Service, where required, in accordance with the Costs and Charges Schedule, Applicable Law, and the FSC’s applicable expectations or requirements.

Some charges may be imposed by third parties involved in providing the Services, including banks, payment service providers, card networks, trading venues, execution venues, liquidity providers, custodians, market data providers, regulators, tax authorities, or other intermediaries. Where such charges arise, MPW may pass them on to you.

MPW may deduct any fees, costs, spreads, commissions, charges, or other amounts you owe to MPW from your Account. MPW may also set off those amounts against any cash balance, asset, credit, receivable, or other amount that MPW owes or holds for you, whether in the same Account, or in another account you hold with MPW. These rights continue after termination. They are subject to any limit on recovery stated in the provision that creates the relevant charge, including the Retail Investor limit in Clause 23.6, and do not apply to funds or assets that are frozen, blocked, or restricted as described in Clauses 11.2 and 23.6.

11.2 Compliance Review Fee

Nature of the fee. MPW carries out client-categorisation, due-diligence and transaction-monitoring procedures in the ordinary course of its business, in accordance with Applicable Law, including the Securities Act 2005, FIAMLA and the FSC Code of Business Conduct. These ordinary-course procedures are not separately charged. Where, however, MPW must reassess your categorisation, or any Transaction, Order, Deposit, Withdrawal or other Account activity, as a result of a Compliance Review Event, the reassessment requires compliance resources beyond the ordinary course, and a Compliance Review Fee will apply. The Compliance Review Fee is a charge for those additional services, set by reference to MPW’s reasonable estimate of the internal cost of providing them. It is not a penalty, and its application does not indicate that MPW has formed any view about you or your Account.

Compliance Review Events. A Compliance Review Event occurs where MPW, acting reasonably, determines that a reassessment of (i) your categorisation under the Client Categorisation Policy, or (ii) any Transaction, Order, Deposit, Withdrawal or other Account activity, is required as a result of any of the following:

a) a request by you to be treated as a Sophisticated Investor or otherwise to be re-categorised in a manner that reduces the protections applicable to you;

b) a change in your circumstances that you have not notified within the period required by Clause 4.2, or any information, declaration or document provided by you that is inaccurate, incomplete, inconsistent, outdated or misleading;

c) your failure to provide any information, confirmation or document requested under Clauses 4, 7.2 or 22 within the timeframe specified by MPW;

d) a Deposit received from a third party or from a source other than a verified Linked Account, contrary to Clause 7.2;

e) activity that MPW identifies, or reasonably suspects, as exchange-like activity under Clause 8.4;

f) a Deposit, Withdrawal, Transaction or pattern of Account activity that is inconsistent with your declared profile, source of funds, source of wealth or anticipated level of activity, or that otherwise requires enhanced review under MPW’s AML/CFT/CPF framework; or

g) any other circumstance attributable to your conduct, instructions or information which, in MPW’s reasonable assessment, requires such a reassessment.

Exclusions. No Compliance Review Fee is payable in respect of:

a) the onboarding checks described in Clause 4.1, or periodic reviews under Clause 4.3 carried out on MPW’s ordinary review cycle for your risk rating, unless a Compliance Review Event arises in the course of that review;

b) a request by you to be treated as a Retail Investor or otherwise to receive a higher level of protection;

c) a reassessment required by a change in Applicable Law, a regulatory direction of general application, or a change to MPW’s policies, risk methodology, systems or product offering;

d) a reassessment arising from an error by MPW or any of its service providers, or from a Manifest Error not caused by you;

e) a reassessment arising from Orders generated through Copy Trading or PAMM, to the extent it relates to the activity of a Lead Trader or PAMM Manager rather than to your own conduct, instructions or information; or

f) any matter for which MPW recovers its costs under Clause 9.6 (Costs of Chargebacks) or applies enhanced Withdrawal fees under Clause 8.4(c), for the same days and the same matter.

Accrual. The Compliance Review Fee accrues at the Daily Compliance Rate for each Business Day of the Compliance Review Period. The Compliance Review Period begins on the Business Day on which MPW opens the reassessment and ends on the Business Day on which MPW closes it, both inclusive. Where more than one Compliance Review Event is open on your Account at the same time, or several Compliance Review Events arise from the same or related facts, only one Daily Compliance Rate applies for each Business Day.

Notification. MPW will notify you when a Compliance Review Period begins, stating the Daily Compliance Rate and any information or documents required from you. MPW will notify you again when the Compliance Review Period ends, stating the total Compliance Review Fee. Responding promptly and completely to MPW’s requests will shorten the Compliance Review Period and reduce the fee. MPW is not required to give notice, or to explain the reason for a reassessment, where doing so would be prohibited by Applicable Law or by a competent authority, including where it could constitute tipping off under FIAMLA.

Payment. The Compliance Review Fee becomes due on the last Business Day of the Compliance Review Period or, if earlier, on the last Business Day of each calendar month during the Compliance Review Period. It may be debited from the available cash balance of your Account or set off in accordance with Clause 11.1. It will not be debited from a PAMM Sub-Account, or from any funds or assets that are frozen, blocked or restricted under Applicable Law, sanctions law, or a direction of a court or competent authority. Any amount that cannot be debited for that reason remains a debt owed by you and becomes payable when the restriction ceases.

Waiver, refund and rights preserved. MPW may, at its discretion, waive or reduce any Compliance Review Fee. A Compliance Review Fee charged in error will be refunded in accordance with Clause 9.2. Payment of a Compliance Review Fee does not oblige MPW: i) to complete a reassessment within any particular time; ii) to reach any particular outcome; or iii) to accept, transmit, execute or process any Order, Deposit or Withdrawal. It is without prejudice to MPW’s rights under Clauses 4, 5.2, 8.7, 22 and 23.

11.3 Interest on Negative Balances and Overdue Amounts

No credit. A negative balance on your Account, and any other amount you owe MPW, is a debt payable immediately or on demand. Interest under this Clause 11.3 compensates MPW for the cost of funding, and the credit risk of, that debt. It is not a charge for credit, and it does not entitle you to keep a negative balance or to delay payment.

Rate and accrual. Where your Account has a negative balance not covered by Negative Balance Protection, or any other amount you owe MPW is not paid when due, MPW may charge interest at the rate specified in the Costs and Charges Schedule. The Schedule may specify different rates, or no rate, for different Account types or client categories. Interest accrues daily from the date the negative balance arises or the amount falls due, until payment in full, both before and after termination and before and after any judgment.

Calculation and debit. Interest is simple interest, calculated on the outstanding principal amount only on the basis of a 365-day year, and is debited to your Account monthly in arrears on the first Business Day of the following month. Interest debited to your Account does not form part of the principal amount on which further interest is calculated.

Exclusions. No interest accrues:

a) on any amount, for any period during which MPW could not debit it only because funds or assets in your Account were frozen, blocked, or restricted as described in Clauses 11.2 and 23.6, or were held by MPW under Clause 8.7 or Clause 10.1 in an amount sufficient to discharge it;

b) on any amount waived under Clause 23.6 (Retail Investors); or

c) on any negative balance or amount arising from an error by MPW or its service providers.

Disclosure. Interest charged will be shown in your Account statements.

12. Copy Trading Service

12.1 Description and Regulatory Framing

Copy Trading is a Service that allows you to choose to have your Account automatically execute Transactions that replicate, on a proportional basis, the Transactions carried out in the account of a selected Lead Trader. In this arrangement, you act as the “Follower”. Your election to copy a Lead Trader is made through the Platform and operates according to the parameters you set, which you may change from time to time subject to the limits set out in this Clause 12.

This Service is provided under MPW’s Investment Adviser (Unrestricted) licence pursuant to section 30 of the Securities Act 2005. When you choose to copy a Lead Trader, that election is treated as a personalised investment recommendation made to you, with the Lead Trader’s trading activity serving as an input to that recommendation. You remain a Client of MPW at all times. You do not become a client of the Lead Trader, and the Lead Trader does not, merely by being available on the Platform, provide regulated investment advice or any other regulated service directly to you.

You retain ultimate control over your Account. You may start or stop copying a Lead Trader, change your copy parameters, override individual copied Orders where the Platform permits this, and close any underlying positions, in each case in accordance with this Clause 12.

Important regulatory framing: Copy Trading is structured so that MPW remains the regulated service provider responsible for the Service. The activity is provided under its Investment Adviser (Unrestricted) licence, and MPW remains responsible to you under Mauritian law and the applicable FSC rules. Lead Traders operate on the Platform under MPW’s authorisation and oversight. This includes selection criteria, review of the suitability of their published strategy, and ongoing monitoring of their activity. A Lead Trader is not, by virtue of being available on the Platform, licensed to provide investment advice to you directly, and does not have a direct contractual or regulatory relationship with you.

12.2 Lead Traders

A Lead Trader may be:

a) a representative of MPW whose strategy has been selected for availability on the Platform;

b) an external strategy provider that has been engaged, assessed, and made available under MPW’s licence; or

c) a Client who has been assessed, approved, and authorised on a documented basis to act as a Lead Trader on the Platform.

All Lead Traders are subject to due diligence before being made available to Followers. Depending on the nature of the Lead Trader and the relevant strategy, this review may cover identity, regulatory standing, trading history, risk-management discipline, conflicts of interest, and the suitability of the strategy for the intended population of potential Followers. The detailed onboarding and ongoing monitoring arrangements are set out in MPW’s internal procedures.

Each Lead Trader must comply with Clause 5.14 of Schedule 5. This obligation arises under these Terms, where the Lead Trader is a Client, or otherwise under its agreement with MPW. In particular, a Lead Trader must not:

i) trade ahead of, or against, Followers, whether through the Lead Trader’s Account, any Associated Account or any account held with another broker;

ii) generate Transactions primarily to earn fees, profit share or other remuneration rather than to pursue the published strategy;

iii) operate opposing or offsetting strategies, or selectively open, close or allocate positions, so as to present misleading performance;

iv) misrepresent the strategy, its risk profile or its performance, whether on the Platform or elsewhere; or

v) solicit or accept any payment, benefit or arrangement from or with a Follower outside the Platform without MPW’s prior written approval.

MPW may suspend, restrict, or remove a Lead Trader from the Platform at any time. This may happen, for example, where the Lead Trader materially deviates from the published strategy or risk parameters, breaches applicable standards or Clause 5.14 of Schedule 5, suffers a deterioration in performance such that continued availability is no longer considered to be in the interests of Followers, loses any required regulatory permission, or gives rise to a conflict of interest that cannot be satisfactorily managed.

Where removal results from conduct prohibited under Clause 5.14 of Schedule 5, it may take effect immediately and without prior notice. Clause 5.14.9 of Schedule 5 then applies, and any fees, profit share or other remuneration paid or payable to the Lead Trader in respect of the affected Transactions may be withheld or recovered.

Information about each Lead Trader will be made available on the Platform, including, where available and appropriate, details of the relevant strategy, historical performance, risk metrics, drawdowns, and fees. Past performance is not a reliable indicator of future performance.

12.3 Eligibility to be a Follower

To use Copy Trading, you must have an active and fully verified Account under these Terms.

You must also complete the Client Investment Profile, or CIP. The outcome of the CIP must indicate that Copy Trading is, in principle, suitable for your knowledge, experience, risk tolerance, financial situation, and investment objectives. Where Copy Trading is not considered suitable for you, access will be declined.

You must also meet any minimum capital, minimum allocation, or minimum copy-amount requirement published for the relevant Copy Trading Strategy.

Some Copy Trading Strategies may be available only to Sophisticated Investors because of their higher risk profile, complex or high-risk instruments, minimum allocation amount, or other relevant features. Any such eligibility requirements will be disclosed on the Platform.

Even where you meet the published eligibility criteria, you may not be permitted to copy a specific Lead Trader or Copy Trading Strategy where, in MPW’s reasonable judgement, that Copy Trading Strategy is not suitable for you.

12.4 General Acceptance of Copy Trading and Selection of Strategies

By accepting these Terms, you acknowledge and agree that Copy Trading may be made available to you as one of the Services offered through the Platform. Your use of Copy Trading is governed by these Terms, the Suitability and Appropriateness Policy, the Best Execution Policy, the Costs and Charges Schedule, the Risk Disclosure Statement, and any additional disclosures or conditions made available on the Platform.

Acceptance of these Terms does not, by itself, mean that you have elected to copy any Lead Trader or strategy, or that any capital has been allocated to Copy Trading. Each copying relationship must be selected and confirmed separately through the Platform.

You may select Lead Traders and strategies only from those made available to you based on your eligibility, Client Investment Profile, suitability assessment, and any applicable restrictions. Before you confirm a copying relationship, the Platform will display the key features of the relevant strategy, including the Lead Trader, the strategy description, principal risks, any strategy-specific risks, copy parameters, fees, performance information where available, and any other information considered material to your decision.

By confirming a specific copying relationship through the Platform, you acknowledge that you have reviewed the information provided, considered the risks, accepted the applicable fees and parameters, and chosen to follow that Lead Trader or strategy on that basis. The copying relationship will begin only once it has been accepted and activated through the Platform, subject to any applicable suitability, operational, regulatory, or risk-management checks.

Any later change to your selected Lead Trader, strategy, copy amount, copy ratio, risk parameters, excluded instruments, or other copy settings must also be made through the Platform and will take effect only in accordance with the Platform’s functionality and this Clause 12.

12.5 Copy Mechanics

Once you start copying a Lead Trader, the Platform will seek to replicate that Lead Trader’s Transactions in your Account on a proportional basis, taking into account the amount of copying capital you have allocated to the strategy and the parameters you have set, such as the copy ratio, maximum exposure per Transaction, and any excluded instruments.

Copied Transactions are executed in accordance with the Best Execution Policy. However, your Orders and the Lead Trader’s Orders may not be executed at the same price, at the same time, or on the same terms. Differences may arise because of market movement, latency, liquidity, order fragmentation, execution venue differences, slippage, or other factors. These differences are inherent in Copy Trading and may affect the performance of your Account compared with the Lead Trader’s account.

Not every Transaction made by a Lead Trader will necessarily be replicated in your Account. A Transaction may not be copied where, for example, your Account does not have sufficient available capital or margin, the relevant instrument is not available to you, the Transaction would breach a parameter you have set, or it would exceed a limit applicable to your Account, such as a leverage cap or position-concentration limit. Replication may also fail or be limited where the Lead Trader trades outside the hours during which your Account can transact, or where operational, technical, regulatory, or risk-management reasons apply. MPW will not be liable for non-replication in these circumstances.

You may not select individual Transactions to copy or ignore, except through the parameters made available on the Platform. You may, however, close any position that has been copied to your Account independently of the Lead Trader.

If you close a copied position before the Lead Trader closes the corresponding position, your Account will no longer track the Lead Trader’s position in respect of that instrument from that point onward.

12.6 Suitability and Appropriateness

Suitability for Copy Trading is assessed in accordance with the Suitability and Appropriateness Policy.

When you first elect to use Copy Trading, MPW will assess whether the Service is suitable for you in general and whether the selected strategy is suitable for you in particular, considering your Client Investment Profile.

Where you continue to copy a Lead Trader over time, the continued suitability of the strategy will be reviewed periodically, having regard to your CIP, the Lead Trader’s performance, and the risk profile of the strategy.

If your CIP changes and a strategy you are copying is no longer considered suitable, you will be notified. In that case, you may be required to stop copying the strategy, reduce or modify your exposure, or provide an explicit acknowledgement of the mismatch before being allowed to continue.

12.7 Fees, Profit Share, and Performance Fees

The fees that apply to Copy Trading are set out in the Costs and Charges Schedule. Depending on the strategy and the terms made available to you, these may include a performance fee, a profit share payable to the Lead Trader, execution costs such as spreads and commissions, platform fees, and any currency-conversion costs. Where a Lead Trader receives a profit share, MPW may retain a portion of that amount, provided this is disclosed to you.

Where a performance fee applies, it is typically calculated by reference to a High Water Mark. This means that the fee is charged only on profits above the previous highest value of your allocation to that strategy, so that you do not pay performance fees twice on the same profits.

Before you start copying a strategy, the applicable fees and the method of calculation will be disclosed to you. You will also be given information showing the potential cumulative effect of those fees under illustrative scenarios.

No fee, commission, rebate, profit share, or other remuneration connected with a Lead Trader will be received unless it is disclosed in the Costs and Charges Schedule or otherwise disclosed under the Conflicts of Interest framework.

12.8 Risks Specific to Copy Trading

In addition to the general risks described in Clause 15 and in the Risk Disclosure Statement, you acknowledge that Copy Trading involves specific risks.

Past performance is not a reliable indicator of future performance. A Lead Trader or strategy that has performed well in the past may perform poorly in the future, and previous returns should not be treated as evidence of future results.

A Lead Trader may deviate from the published strategy, take more risk than expected, suffer adverse market exposure, or make poor trading decisions. Any such conduct or outcome may affect your Account and may result in losses.

Some strategies may involve leverage, derivatives, complex instruments, short-selling, or other techniques that can magnify both gains and losses. These strategies may be volatile and may not be suitable for all Clients.

Your results may differ materially from those of the Lead Trader. Differences can arise because of latency, slippage, market movement, liquidity, order size, execution timing, account settings, available margin, or other operational factors affecting the execution of copied Transactions.

If a Lead Trader becomes unavailable, stops trading, is suspended, is removed from the Platform, or otherwise ceases to operate, your Account will stop receiving new copied Transactions from that Lead Trader. Any existing copied positions will remain in your Account until they are closed. You remain responsible for monitoring and managing those positions.

Following a single Lead Trader creates concentration risk, because your Account may be significantly affected by that Lead Trader’s decisions and performance. Following multiple Lead Traders may reduce concentration, but it does not eliminate the risk of loss.

The Lead Traders displayed on the Platform may also be affected by selection or survivor bias. They may not represent all traders who have previously used the system, and strategies that performed poorly, were suspended, or were removed may no longer be visible.

12.9 Termination of Copying

You may stop copying a Lead Trader at any time through the Platform. Stopping a copying relationship prevents future Transactions from being replicated in your Account, but it does not automatically close any copied positions that are already open.

When you stop copying, you may choose either to close all open copied positions immediately or to keep them open and manage them independently. If you choose to close them, the closing Transactions will be executed in accordance with the Best Execution Policy.

Your access to Copy Trading, or to a particular Lead Trader or strategy, may be suspended, restricted, or terminated where appropriate, including for the reasons described in Clauses 12.2 and 12.3 or in Clause 23 (Suspension, Termination, and Account Closure). Where your Account is closed under Clause 10.1 or Clause 23, all of your copying relationships end automatically, and any open copied positions will be dealt with as part of the wind-down under Clause 10.1 or Clause 23.7, as applicable.

If a Lead Trader’s strategy is terminated, whether by MPW or by the Lead Trader, your Account will stop receiving new copied Transactions from that strategy and you will be notified. Any existing copied positions will remain in your Account unless and until they are closed, and you remain responsible for monitoring and managing them.

Where a Lead Trader’s conduct falls within Clause 23.4.1, MPW may take action against the Lead Trader’s own Account under Clause 23, including a Client Misconduct Closure. A Follower will not be subject to a Client Misconduct Closure or the Account Closure Fee solely because of the Lead Trader’s conduct, unless MPW determines under Clause 5.14.9(c) of Schedule 5 that the Follower was involved. This does not affect MPW’s rights under Clause 5.14.9(b) of Schedule 5.

13. PAMM — Percentage Allocation Management Module

13.1 Description and Regulatory Framing

PAMM is a discretionary allocation management service under which capital contributed by multiple Participants is managed by a designated PAMM Manager through a pooled or virtually pooled trading account. Transactions carried out by the PAMM Manager are allocated among Participants in proportion to their respective Allocation Coefficients, meaning each Participant’s share of the aggregate capital allocated to the PAMM Account. Profits, losses, and applicable fees are allocated on the same basis.

The Service is provided under MPW’s Investment Adviser (Unrestricted) licence pursuant to section 30 of the Securities Act 2005. It is structured as a discretionary portfolio management service: the PAMM Manager exercises trading discretion over the capital allocated to the PAMM Account on behalf of all Participants, in accordance with the published PAMM strategy and the Mandate signed by each Participant.

Important regulatory framing: Under a PAMM arrangement, you, as Participant, do not make individual trading decisions in respect of the capital you allocate to the PAMM Sub-Account. Instead, you appoint MPW, acting through the designated PAMM Manager, to manage that capital on a discretionary basis.

This is materially different from execution-only brokerage, where you make your own trading decisions, and from Copy Trading, where you retain the discretion to start, modify, or stop copying a Lead Trader. Once you have allocated capital to a PAMM and signed the relevant Mandate, trading decisions are made by the PAMM Manager in accordance with that Mandate and the published PAMM strategy, until you redeem your interest, your participation ends, or the Mandate is terminated.

13.2 The Mandate

By accepting these Terms, you acknowledge and agree that PAMM may be made available as one of the Services offered by MPW, and that your use of any PAMM Service will be governed by these Terms, the applicable PAMM disclosures, and any additional terms displayed on the Platform.

Acceptance of these Terms does not, by itself, subscribe you to any specific PAMM Account or require you to allocate capital to any PAMM strategy. Each specific PAMM participation must be selected and confirmed separately through the Platform.

Before you subscribe to a specific PAMM Account, the Platform will make available the relevant information for that PAMM, including the identity of the PAMM Account, the designated PAMM Manager, the published strategy, permitted instruments, risk parameters, investment horizon, fees, subscription and redemption mechanics, reporting cadence, and applicable termination provisions.

When you confirm your participation in a specific PAMM Account through the Platform, you will be deemed to have accepted the applicable PAMM Mandate and the related disclosures for that PAMM. Your capital allocation, starting Allocation Coefficient, and participation in that PAMM will then be recorded on the Platform.

By confirming a specific PAMM participation, you acknowledge the discretionary nature of the Service, the risks associated with the relevant PAMM strategy, and the fact that trading decisions in respect of the allocated capital will be made by the PAMM Manager in accordance with the applicable Mandate and published strategy.

13.3 PAMM Managers

A PAMM Manager may be a representative or employee of MPW, an external strategy provider engaged and assessed by MPW, or a Client who has been assessed, approved, and authorised on a documented basis to act in that role. In each case, the PAMM Manager operates under MPW’s regulatory responsibility and oversight, and MPW remains the regulated service provider responsible to Participants.

Because the PAMM Manager exercises discretion over capital allocated by Participants, enhanced due diligence is carried out before a person is approved for that role. Depending on the nature of the manager and the proposed strategy, this review may cover identity, integrity, regulatory standing, trading capability, the robustness of the strategy, risk-management discipline, conflicts of interest, and operational capability. The detailed onboarding and monitoring requirements are set out in MPW’s internal procedures.

Each PAMM Manager must comply with the Mandate and with Clause 5.14 of Schedule 5. This obligation arises under these Terms, where the PAMM Manager is a Client, or otherwise under its agreement with MPW. In particular, a PAMM Manager must not:

i) trade ahead of, or against, the PAMM Account or its Participants, whether through the PAMM Manager’s Account, any Associated Account or any account held with another broker;

ii) allocate Transactions or results between the PAMM Account and any other account in a manner that favours the PAMM Manager, any Associated Account or any particular Participant;

iii) generate Transactions primarily to earn performance fees or other remuneration, or to crystallise a performance fee, rather than to pursue the published strategy;

iv) misrepresent the strategy, its risk profile or its performance, whether on the Platform or elsewhere; or

v) solicit or accept any payment, benefit or arrangement from or with a Participant outside the Platform without MPW’s prior written approval.

MPW may suspend, restrict, replace, or remove a PAMM Manager at any time where this is considered appropriate. This may happen, for example, where the manager materially deviates from the published strategy, breaches the Mandate or its risk parameters or Clause 5.14 of Schedule 5, fails to meet MPW’s standards, suffers a deterioration in performance such that continued management is no longer considered to be in the interests of Participants, gives rise to a conflict of interest that cannot be properly managed, loses any required regulatory permission, becomes unavailable, or where any other reason justifies such action.

Where removal results from conduct prohibited under Clause 5.14 of Schedule 5, it may take effect immediately and without prior notice. Clause 5.14.9 of Schedule 5 then applies, and any performance fee or other remuneration paid or payable to the PAMM Manager in respect of the affected Transactions may be withheld or recovered, with the High Water Mark adjusted accordingly.

Information about each PAMM Account and PAMM Manager will be made available on the Platform, including, where available and appropriate, the published strategy, historical performance, risk metrics, fees, current aggregate PAMM capital, and the number of Participants. Past performance is not a reliable indicator of future performance.

13.4 Eligibility for PAMM Participation

To participate in a PAMM Account, you must have an active and fully verified Account under these Terms.

You must also complete the Client Investment Profile, or CIP. The outcome of the CIP must indicate that discretionary allocation management is, in principle, suitable for your knowledge, experience, risk tolerance, financial situation, and investment objectives. Where PAMM is not considered suitable for you, access may be declined.

You must meet any minimum subscription or allocation requirements published for the relevant PAMM Account, including any minimum initial capital contribution.

Some PAMM Accounts may be available only to Sophisticated Investors because of their higher risk profile, use of complex strategies, minimum subscription amount, leverage, or other relevant features. Any such eligibility requirements will be disclosed on the Platform.

Even where you meet the published eligibility criteria, participation in a specific PAMM Account may still be declined where, in MPW’s reasonable judgement, that PAMM is not suitable or appropriate for you.

13.5 Subscription — Joining a PAMM Account

You may join a PAMM Account by reviewing the documentation made available on the Platform, considering the relevant strategy and risks, accepting the applicable Mandate, and allocating the agreed initial capital contribution from your main Account to your PAMM Sub-Account.

Your subscription will take effect at the next applicable valuation point for that PAMM Account, in accordance with its published dealing cadence. The dealing cadence may be daily, weekly, monthly, or otherwise specified on the Platform for the relevant PAMM Account.

Your initial Allocation Coefficient will be calculated by reference to your capital contribution as a proportion of the aggregate capital allocated to the PAMM Account at the effective subscription point.

Additional contributions may be permitted where allowed under the published rules of the relevant PAMM Account. Any additional contribution will be reflected through an adjustment to your Allocation Coefficient at the next applicable valuation point.

13.6 Allocation Methodology

Transactions carried out in the PAMM Account are allocated among Participants in proportion to their Allocation Coefficients at the relevant valuation point.

Profits and losses are allocated on the same basis, so each Participant bears exposure to the PAMM Account in line with their share of the aggregate capital allocated to it.

Management fees, performance fees, and any other applicable charges are deducted from each Participant’s PAMM Sub-Account in accordance with the fee structure set out in the Mandate.

Allocation calculations are performed on a continuous or periodic basis, as published for the relevant PAMM Account. Any question or dispute about a specific allocation should be raised through the Complaints Handling Procedure.

13.7 Fees, Performance Fees, and the High Water Mark

The fees that apply to the PAMM Service are set out in the Costs and Charges Schedule and in the relevant Mandate. Depending on the PAMM Account, these may include a management fee, a performance fee, execution costs such as spreads and commissions, platform fees, and any other charges disclosed before you subscribe.

A management fee, where applicable, is typically calculated as a percentage of the NAV of your PAMM Sub-Account, accrued daily and charged at the intervals published for the relevant PAMM Account.

A performance fee, where applicable, is calculated by reference to a High Water Mark. This means that the fee is charged only on net new profits above the previous highest NAV of your PAMM Sub-Account. If your PAMM Sub-Account is below its High Water Mark, no performance fee is charged until the drawdown has been recovered and new profits have been generated above that level.

Performance fees crystallise on the published calculation date, typically monthly or quarterly, and are deducted from your PAMM Sub-Account at that point. Following crystallisation, the High Water Mark is reset to the new peak NAV.

Performance fees are payable to MPW. Where the PAMM Manager is entitled to share in those fees, their agreed share is paid out of the performance fee received. This internal allocation does not increase the fee payable by you.

Worked examples showing how fees are calculated will be made available on the Platform before you subscribe to the relevant PAMM Account.

13.8 Reporting

Reports on the performance of your PAMM Sub-Account will be made available through the Platform at the cadence published for the relevant PAMM Account, typically monthly. You may also access reporting information on demand through the Platform, where this functionality is available.

Each report will include the key information relating to your PAMM Sub-Account for the relevant period, including the opening NAV, any capital contributions or redemptions, the gross trading result, fees deducted, closing NAV, performance metrics, and any relevant disclosures.

Reports will be provided through the Platform and may be downloaded where the Platform allows. Transaction-level information relating to the underlying PAMM Account may be provided in summarised form, such as daily summaries or strategy-level commentary, rather than on a trade-by-trade basis.

13.9 Withdrawal and Redemption

You may redeem all or part of your interest in a PAMM Sub-Account by submitting a redemption request through the Platform.

Redemptions take effect at the next applicable valuation point for the relevant PAMM Account, in accordance with its published dealing cadence and any applicable notice period. The notice period may be immediate, 24 hours, 7 days, one calendar month, or such other period as is specified on the Platform for that PAMM Account.

The redemption amount will be calculated by reference to your Allocation Coefficient at the effective redemption point, applied to the aggregate capital of the PAMM Account, less any applicable fees, charges, or redemption costs set out in the Mandate.

Once the redemption has been processed, the proceeds will be transferred from your PAMM Sub-Account to your main Account. From there, you may request a Withdrawal in accordance with Clause 8.

In exceptional circumstances, redemptions may be suspended, deferred, or processed over a longer period. This may happen, for example, during severe market disruption, where relevant assets or positions are illiquid, where the PAMM Manager is unavailable, where processing the redemption could prejudice remaining Participants, or where legal, regulatory, operational, or risk-management constraints apply. Where this occurs, Participants will be notified as soon as reasonably practicable, and redemption processing will resume once the relevant circumstances have been resolved.

Redemption in kind, meaning the transfer of underlying positions instead of cash, is not generally supported but may be permitted at MPW’s discretion in exceptional cases.

13.10 Risks Specific to PAMM

In addition to the general risks described in Clause 15 and in the Risk Disclosure Statement, you acknowledge that PAMM involves specific risks.

Discretionary risk: by accepting the Mandate, you give the PAMM Manager day-to-day discretion to make trading decisions for the relevant PAMM Account. Those decisions may result in losses, and you will not be able to intervene in individual trades.

Manager risk: the PAMM Manager may underperform, depart from the published strategy, make poor judgement calls, or become unavailable. The oversight framework described in Clause 13.3 is designed to reduce this risk, but it cannot eliminate it.

Strategy risk: the strategy may fail to perform as expected because of changing market conditions, model failure, market regime shifts, external events, or other factors outside the manager’s control.

Concentration risk: depending on the strategy, the PAMM Account may be concentrated in particular instruments, markets, sectors, currencies, asset classes, or trading techniques. This may increase exposure to specific risks.

Leverage and derivatives risk: where the strategy uses leverage, derivatives, or other complex instruments, both gains and losses may be magnified. In extreme circumstances, losses may exceed the capital allocated to the PAMM Account, with consequences for Participants, subject to any Negative Balance Protection that applies.

Liquidity risk: depending on the instruments traded and market conditions at the relevant time, redemptions may be delayed, reduced, suspended, or otherwise affected during periods of market stress or limited liquidity.

Allocation risk: although allocation calculations are supported by systems, reconciliations, and controls, errors may still occur. Any such error could affect the amount allocated to your PAMM Sub-Account.

Pooling risk: although your PAMM Sub-Account is recorded separately for administrative purposes, your economic exposure to the PAMM Account is proportional. Gains and losses are shared with other Participants on the applicable allocation basis, and the decisions, performance, or conduct of the PAMM Manager will affect all Participants in the relevant PAMM Account.

13.11 Termination of the Mandate

You may terminate your Mandate at any time by submitting a request for full redemption in accordance with Clause 13.9. Termination will take effect once the redemption has been completed.

Your Mandate may also be terminated, or a particular PAMM Account may be closed in its entirety, where this is appropriate for the reasons described in Clauses 13.3 and 13.4 or in Clause 23 (Suspension, Termination, and Account Closure). This may also occur where the PAMM Manager has been removed, becomes unavailable, or is otherwise unable to continue, and no suitable replacement is appointed within a reasonable period. Where MPW terminates these Terms or closes your Account under Clause 23.3 or 23.4, your Mandate terminates automatically and your interest will be redeemed in full.

On termination, the PAMM Manager will cease to manage trading activity in respect of your interest. Any open positions attributable to that interest will be closed, transferred, or run off in accordance with the wind-down approach published for the relevant PAMM Account, subject to market conditions, liquidity, operational feasibility, and any applicable legal or regulatory requirements.

Once the wind-down has been completed, the net proceeds will be credited to your main Account. From there, they will be available for Withdrawal in accordance with Clause 8. Where your Account is being closed, they will instead be dealt with in accordance with Clause 10.1 or Clause 23.7, as applicable, including the deduction of any amounts you owe MPW. No Account Closure Fee, Compliance Review Fee, or other amount owed by you individually will be debited from your PAMM Sub-Account or from the PAMM Account.

Where a PAMM Manager’s conduct falls within Clause 23.4.1, MPW may take action against the PAMM Manager’s own Account under Clause 23, including a Client Misconduct Closure. A Participant will not be subject to a Client Misconduct Closure or the Account Closure Fee solely because of the PAMM Manager’s conduct, unless MPW determines under Clause 5.14.9(c) of Schedule 5 that the Participant was involved. This does not affect MPW’s rights under Clause 5.14.9(b) of Schedule 5.

13.12 PAMM Closure and Manager Removal

A PAMM Account may be closed in its entirety where this is considered appropriate. This may happen, for example, if the PAMM Manager is removed and no suitable replacement is identified, if the PAMM Account falls below the minimum aggregate capital considered operationally viable, if closure is required for legal or regulatory reasons, or if there is any other reasonable basis for closing it.

On closure, the positions of the PAMM Account will be closed or run off in an orderly manner, taking into account the interests of Participants, market conditions, liquidity, and operational feasibility. Final NAVs and Allocation Coefficients will then be calculated, applicable fees and charges will be deducted, and the net proceeds will be credited to Participants’ main Accounts.

Where a PAMM Manager is removed but the PAMM Account is intended to continue under a replacement manager, Participants will be notified. They will be given an opportunity, on a best-efforts basis, to redeem before the replacement takes effect, while the normal redemption process will remain available. If the PAMM Account continues, it will do so under the replacement manager and the applicable strategy and Mandate terms made available to Participants.

14. Margin, Leverage, and Negative Balance Protection

14.1 Governing framework

Where you trade leveraged or margined products through the Platform, the Leverage, Margin, and Negative Balance Protection Policy (the “Leverage Policy”) applies in full and forms part of these Terms. The Leverage Policy sets out the applicable margin requirements, leverage limits by product category and Client categorisation, close-out trigger levels, margin call process, and the operation of Negative Balance Protection. By accepting these Terms, you agree to be bound by the Leverage Policy as the contractual basis governing all leveraged and margined activity on your Account. No separate margin agreement is required.

14.2 Margin requirements and MPW's right to adjust

Margin requirements, leverage limits, and margin call and stop-out thresholds may vary depending on the product, your client categorisation, market conditions, volatility, liquidity, and other risk-management considerations. MPW may, acting reasonably, change any of these parameters at any time. Where practicable, MPW will give you reasonable advance notice of a change through the Platform. Where urgent market conditions or risk-management considerations require immediate action — for example, during severe volatility, around major economic announcements, or ahead of market closures — MPW may apply changes to open positions without prior notice, with notice given as soon as reasonably practicable thereafter. You accept that the automated application of revised parameters in such circumstances does not give rise to a claim against MPW.

14.3 Margin calls and stop-out

MPW will notify you through the Platform (in-app alert, push notification, and email) when your Margin Level falls to or below the margin call threshold. A margin call is a warning; it does not itself close your positions. If your Margin Level falls to or below the stop-out threshold, MPW's systems will automatically begin closing your open positions — typically starting with the position carrying the largest unrealised loss — without further notice to you, until the Margin Level is restored or all positions are closed. MPW does not guarantee that a margin call notification will be received by you; connectivity issues, notification settings, or platform downtime may prevent delivery. The stop-out mechanism does not guarantee closure at the stop-out level: in fast-moving or gapping markets, positions may be closed at prices materially worse than the stop-out threshold, which may result in a negative balance.

14.4 Overnight financing

Leveraged positions held open beyond the end of the trading day may be subject to overnight financing charges (also referred to as swaps or rollover costs), which may be debits or credits depending on the instrument, position direction, and prevailing interest rates. Triple financing charges may apply on certain days to account for weekend or holiday periods. All applicable rates, calculation methods, and triple-charge days are set out in the Costs and Charges Schedule and within the platform's product specifications. Overnight financing can materially affect the profitability of positions held over time and you should review these costs before opening or holding leveraged positions overnight.

14.5 Negative Balance Protection

Negative Balance Protection, where it applies, limits your loss on the relevant Account to the funds available in that Account for the covered positions. This means that, for positions covered by Negative Balance Protection, MPW will reset your account balance to zero and absorb any negative amount resulting from market conditions; you will not be required to make any additional payment to cover losses beyond your deposited funds. Negative Balance Protection applies as standard to all Retail Investor accounts. It does not apply in all circumstances, including to Sophisticated Investor accounts that have opted for higher leverage without protection, to losses arising from Chargebacks or fraud-related reversals, to abusive or manipulative trading designed to engineer a negative balance, to any negative balance arising from opposing or offsetting positions held across your Account and any Associated Account (as defined in Clause 5.14.1 of Schedule 5) or any account held with another broker, or to other exclusions set out in the Leverage Policy. The Leverage Policy is authoritative on when protection applies and how it operates.

14.6 Your responsibility

You always remain responsible for monitoring your margin position, maintaining sufficient funds in your Account, and managing your open positions. Margin call notifications, the stop-out mechanism, and Negative Balance Protection are risk-management controls; they are not a substitute for your own active monitoring. You should not open or hold leveraged positions without understanding the margin requirements and the circumstances in which those positions may be automatically closed.

15. Risk Acknowledgement

You acknowledge and accept that investing in financial instruments involves risk, including the risk of losing some or all of your capital. Past performance is not a reliable indicator of future performance.

Leveraged and margined products involve a higher level of risk because gains and losses may be magnified. In some circumstances, losses may exceed your initial deposit, subject to any Negative Balance Protection that applies.

The value and performance of your investments may be affected by many factors, including currency movements, interest-rate changes, market volatility, liquidity conditions, counterparty risk, custodian risk, settlement risk, taxation changes, regulatory changes, and wider economic or political events.

MPW does not guarantee any investment outcome. It does not guarantee profit, protection from loss, achievement of your investment objectives, or that any particular Transaction will be suitable for your circumstances.

Where you use Copy Trading, you also bear the specific risks described in Clause 12.8, including Lead Trader performance risk, latency and execution-difference risk, leverage risk, and concentration risk.

Where you participate in a PAMM Account, you also bear the specific risks described in Clause 13.10, including discretionary management risk, strategy risk, pooled-allocation risk, leverage and derivatives risk, and liquidity or redemption risk.

Further information about the risks of the Services and of specific financial instruments is set out in the Risk Disclosure Statement and the Suitability and Appropriateness Policy.

You also acknowledge the product-specific, execution-specific, custody-specific, corporate-action, market-data, and platform risks described in the Product Terms Schedule, Order Types and Execution Mechanics Schedule, Corporate Actions and Product Events Schedule, Custody and Client Assets Schedule, and Market Data and Platform Use Schedule.

16. Communications

16.1 Language

Communications between you and MPW will be in English, unless another language is expressly agreed.

16.2 Communication channels

Communications will be sent principally through the Platform, including in-app messages and notifications, by email to the address registered on your Account, by SMS to the mobile number registered on your Account where SMS is used, or through your Account dashboard.

Material communications will be provided through durable channels, such as Platform notifications or email. You are responsible for keeping your contact details up to date. Communications sent to the contact details recorded on your Account will be treated as having been sent to you.

16.3 Recording of communications

Telephone calls, electronic messages, and other communications between you and MPW may be recorded and retained for compliance, supervision, dispute resolution, training, security, and AML/CFT purposes.

By using the Platform or any communication channel, you consent to such recording and retention, subject to the Privacy and Data Protection Policy.

17. Privacy and Data Protection

17.1 General

Personal data will be collected, used, shared, retained, and protected in accordance with the Privacy and Data Protection Policy and the Data Protection Act 2017 of Mauritius (the “DPA 2017”). By entering these Terms, you acknowledge that your personal data will be processed as described in the Privacy and Data Protection Policy, and you have the rights set out in that Policy in relation to your personal data.

17.2 Scope of processing

The Privacy and Data Protection Policy explains the main types of processing that may be relevant to your relationship with MPW. These include identity and KYC verification, provision of the Services, transaction processing, communications, risk and compliance monitoring, legal and regulatory reporting (including reporting to the FSC, FIU, MRA, and overseas tax authorities under FATCA and CRS), credit and fraud screening, cookies and analytics, and the use of third-party service providers such as payment providers, KYC providers, cloud providers, and other infrastructure providers.

17.3 Cross-border transfers

You acknowledge and agree that, while providing the Services, MPW may transfer your personal data to recipients located outside the Republic of Mauritius, including cloud-hosting providers, screening providers, custodians, clearing or settlement counterparties, payment providers, and tax authorities. In accordance with the DPA 2017, MPW will not transfer your personal data outside Mauritius unless at least one of the following conditions is met:

1. the Data Protection Commissioner has determined that the recipient country provides an adequate level of protection;

2. you have given your explicit consent to the transfer in accordance with paragraph 17.4, after being informed of the risks involved;

3. the transfer is necessary to open or operate your Account or to carry out a transaction you have requested;

4. the transfer is necessary for a contract concluded in your interest;

5. the transfer is necessary for compliance with a legal obligation to which MPW is subject, or for important reasons of public interest, including international tax-reporting obligations such as FATCA and CRS;

6. the transfer is necessary for the establishment, exercise, or defence of legal claims;

7. appropriate safeguards have been put in place by the recipient; or

8. the transfer has been specifically authorised by the Data Protection Commissioner.

17.4 Your explicit consent to cross-border transfers.

(a) Disclosure of risks. You understand that some recipients of your personal data are in countries that the Data Protection Commissioner has not determined to provide an adequate level of protection, and that those countries may not afford data-protection rights and remedies equivalent to those available under the DPA 2017. In such countries, your personal data may be subject to access by local authorities, and your ability to enforce your rights or obtain redress may be more limited.

(b) Consent. Having been informed of those risks, you expressly consent under paragraph 17.3(ii) to the transfer of your personal data outside Mauritius for the purposes described in these Terms and the Privacy and Data Protection Policy, including to recipients in countries that have not been assessed as providing an adequate level of protection.

(c) Other grounds preserved. This consent is only one of the grounds on which MPW may rely. Where a transfer is also necessary to open or operate your Account, to carry out a transaction you have requested, to comply with a legal obligation (including FATCA and CRS), or otherwise falls within paragraph 17.3, MPW may rely on that ground independently of your consent.

(d) Withdrawal. You may withdraw this consent at any time by contacting the Data Protection Officer. Withdrawal does not affect the lawfulness of transfers made before withdrawal, nor transfers that MPW may continue to make on another ground under paragraph 17.3. Because some cross-border transfers are essential to the provision of the Services, withdrawing your consent may prevent MPW from operating your Account or providing some or all of the Services, in which case the relationship may be brought to an end in accordance with Clause 10 (Cancellation and Account Closure).

18. Conflicts of Interest

Conflicts of interest are identified, prevented, managed, and, where appropriate, disclosed in accordance with the Conflicts of Interest Policy and the public-facing Conflicts of Interest Notice.

By entering into these Terms, you acknowledge that conflicts may arise in the course of your relationship with MPW. These may include conflicts connected with its dual licence as both an investment dealer and investment adviser, the selection of execution venues, relationships with third-party service providers, and the operation of Services such as Copy Trading and PAMM.

Where a conflict is material to a particular Transaction or Service, additional information may be provided to you so that you can understand the nature of the conflict and the steps taken to manage it.

19. Complaints

If you are dissatisfied with any aspect of the Services, or with the way MPW has acted, you may submit a complaint in accordance with the Complaints Handling Procedure.

Your complaint will be acknowledged, investigated, and responded to in accordance with that Procedure and the timelines set out in it.

If you remain dissatisfied after receiving the final response, you may refer the matter to the Ombudsperson for Financial Services in accordance with the Ombudsperson for Financial Services Act 2018, and, where appropriate, to the FSC. Further details on external escalation are set out in the Complaints Handling Procedure.

20. Dormancy

Your Account will be treated as inactive, and then as dormant, if there is no Qualifying Activity on it for the periods specified in the Dormant Account Policy. “Qualifying Activity” has the meaning given in the Dormant Account Policy and includes placing an Order, making a Deposit, or requesting a Withdrawal. Receiving statements, notifications, or marketing communications is not Qualifying Activity.

MPW may charge a periodic fee on inactive or dormant Accounts (an “Inactivity Fee”). The amounts, and the points at which they apply, are specified in the Costs and Charges Schedule and may differ by Account type. An Inactivity Fee:

a) is debited only from the available cash balance of your Account and will never create or increase a negative balance;

b) will not be recovered by selling securities or other non-cash assets without your instruction;

c) stops from the date of any Qualifying Activity and is never applied retrospectively; and

d) may be waived in whole or in part, including in cases of serious illness, bereavement, or a Force Majeure Event.

While your Account is dormant, MPW may restrict it under Clause 23.1. This includes requiring you to complete reactivation before any Order, Deposit, or Withdrawal is processed. You may reactivate your Account through the Platform at any time. Reactivation requires identity confirmation and any KYC, tax self-certification, and Client Investment Profile refresh required by the Dormant Account Policy.

A dormant Account may be closed under Clause 23.4.2(k) in accordance with the Dormant Account Policy. Closure on that ground is not a Client Misconduct Closure, and no Account Closure Fee applies. Where MPW cannot contact you, any residual balance will continue to be held as Client Money for you or your successors and paid out on a valid claim, subject to any unclaimed-property requirement of Applicable Law.

Dormancy does not extinguish your entitlement, or that of your successors, to the funds and assets in your Account. MPW will not appropriate them.

21. Tax

MPW does not provide tax advice. The tax consequences of using the Services will depend on your personal circumstances and on the laws of the jurisdiction or jurisdictions in which you are tax-resident or otherwise subject to tax.

You are responsible for your own tax affairs, including declaring and paying any taxes due on income, gains, transactions, or other amounts arising from your use of the Services.

Information about your Account may be reportable to the Mauritius Revenue Authority and, through it, to overseas tax authorities under FATCA, the Common Reporting Standard, or other tax-information exchange arrangements. Further details are set out in the FATCA and CRS Notice.

Taxes may also be withheld from your Account where this is required by Applicable Law.

22. AML/CFT/CPF Compliance

MPW is required to comply with the Mauritian AML/CFT/CPF framework, including the Financial Intelligence and Anti-Money Laundering Act 2002, or FIAMLA, and related regulations. It must also comply with applicable sanctions laws in Mauritius and in any other jurisdictions covered by its compliance programme.

As part of these obligations, KYC checks, ongoing monitoring, transaction screening, sanctions screening, and suspicious transaction reporting may be carried out where required by Applicable Law.

You agree to provide any information or documentation reasonably requested in support of these obligations, and to do so promptly.

Where AML/CFT, CPF, sanctions, or other regulatory considerations require it, action may be taken under these Terms, including the suspension, restriction, or termination of your Account.

If a suspicious transaction report is filed, the tipping-off restrictions under FIAMLA may prevent MPW from disclosing certain information to you, including details of the report or the reasons for any action taken or being considered.

23. Suspension, Termination, and Account Closure

23.1 MPW's Right to Suspend or Restrict

MPW may, acting reasonably, suspend, restrict, or otherwise limit your access to the Services, the Platform, or any part of your Account, including by restricting Deposits, Withdrawals, new Orders, specific instruments or Order types, leverage, Copy Trading, PAMM participation, or API or automated access. MPW may do so without prior notice where giving notice would be inadvisable, unlawful, impracticable, or inconsistent with the purpose of the measure.

This may happen where:

a) there is a reasonable suspicion of fraud, market abuse, conduct prohibited under Clause 5.14 of Schedule 5, account compromise, unauthorised activity, or other improper conduct;

b) KYC, AML/CFT, CPF, or related verification is incomplete, outdated, or requires further review;

c) you become, or MPW reasonably suspects that you are, a Sanctioned Person or Restricted Person, or you become resident, incorporated, established or located in a jurisdiction to which restrictions apply;

d) action is required by Applicable Law, by an order of a court or competent authority, or by a regulatory direction;

e) you have breached these Terms or any Incorporated Document;

f) your Account is affected by a Chargeback dispute, credit-risk concern, AML/CFT review, sanctions review, Compliance Review Event, or other compliance investigation;

g) any event described in Clause 23.4 has occurred or MPW reasonably believes it may occur; or

h) technical, operational, market, liquidity, security, or risk-management conditions reasonably require it.

A suspension or restriction may remain in place for as long as MPW reasonably considers necessary. It does not by itself terminate these Terms. Fees, charges, and financing costs continue to accrue during it in accordance with the Costs and Charges Schedule.

23.2 Termination by You

You may terminate these Terms by requesting closure of your Account in accordance with Clause 10.1. Where you participate in any PAMM Account, termination takes effect only once the relevant Mandate has been terminated through full redemption in accordance with Clause 13.

A closure request does not affect MPW’s rights under Clauses 23.4.1 and 23.6.

23.3 Termination by MPW on Notice

MPW may, at any time and for any reason, or for no stated reason, terminate these Terms, close your Account, or stop providing any Service to you, by giving you written notice of not less than thirty (30) calendar days if you are a Retail Investor, or fourteen (14) calendar days if you are a Sophisticated Investor. MPW may give a shorter period where Applicable Law, a competent authority, the withdrawal of a licence, permission, or product, or the requirements of a bank, custodian, liquidity provider, or other key service provider make this necessary. Where MPW terminates under this Clause 23.3, reasonable efforts will be made to support an orderly wind-down of your Account.

23.4 Termination by MPW with Immediate Effect

23.4.1 Client Misconduct Closure

MPW may terminate these Terms, close any or all of your Accounts, and stop any or all of the Services, with immediate effect or on such shorter notice as MPW decides, where MPW, acting reasonably, determines that:

a) you have engaged in conduct prohibited under Clause 5.14 of Schedule 5 or Clause 27, or in exchange-like activity under Clause 8.4;

b) you, or any person acting for you, have committed or attempted fraud, dishonesty, impersonation, identity misuse, or unauthorised use of a payment instrument;

c) any information, declaration, or document you have provided, at onboarding or later, is false, inaccurate, incomplete, or misleading in any material respect, including as to your identity, residence, tax status, source of funds, source of wealth, Client Investment Profile, categorisation, or eligibility under Clause 2.1;

d) you have failed to notify a change in your circumstances as required by Clause 4.2, where that change would have made you ineligible under Clause 2.1 or a Restricted Person;

e) you have failed to provide any information, confirmation, or document requested under Clauses 4, 7.2, or 22 within the timeframe MPW specifies;

f) MPW has reasonable grounds to suspect that your Account has been, or may be, used for money laundering, terrorist financing, proliferation financing, sanctions evasion, tax evasion, or any other financial crime, or that you have used or attempted to use the Services to get around AML/CFT/CPF or sanctions controls;

g) Deposits have been made from third parties or from sources other than a verified Linked Account contrary to Clause 7.2, or a Chargeback has been raised in bad faith, fraudulently, or without valid basis, or Chargebacks have been raised repeatedly in respect of your Account;

h) your Account has been used, accessed, or controlled by a person other than you or your authorised representative, or you hold or operate an Associated Account without MPW’s prior written consent, or engage in coordinated trading; or

i) any Associated Account has been terminated under this Clause 23.4.1.

Each such termination is a “Client Misconduct Closure”. MPW’s determination is not required to meet the standard of proof that applies in legal proceedings.

23.4.2 Other Grounds for Immediate Termination

MPW may also terminate these Terms, close any or all of your Accounts, and stop any or all of the Services with immediate effect, or on such shorter notice as MPW decides, where:

a) any circumstance described in Clause 23.1 continues, or is not remedied to MPW’s satisfaction within the period MPW specifies;

b) you commit a material breach of these Terms or any Incorporated Document, or repeated breaches which taken together are material;

c) you become a Sanctioned Person or Restricted Person, or otherwise cease to meet any eligibility condition in Clause 2.1;

d) any amount you owe MPW remains unpaid five (5) Business Days after MPW demands it;

e) an Insolvency Event occurs in relation to you, or, for an individual Account, you die or lose legal capacity;

f) you behave towards MPW, its staff, or its service providers in a way that is abusive, threatening, harassing, or otherwise unacceptable;

g) continuing the relationship would or may breach Applicable Law, any licence condition, or any direction of the FSC, a court, or another competent authority, or would expose MPW to material legal, regulatory, sanctions, or reputational risk;

h) a bank, payment service provider, custodian, liquidity provider, or execution venue refuses to support your Account or requires MPW to stop dealing with you;

i) a Force Majeure Event affecting your Account lasts for more than thirty (30) consecutive calendar days;

j) your Account has not been funded within ninety (90) calendar days of the Effective Date, or has held no balance and no open positions for six (6) consecutive months; or

k) closure is authorised under the Dormant Account Policy.

Where the facts behind a termination under this Clause 23.4.2 also fall within Clause 23.4.1, MPW may treat the termination as a Client Misconduct Closure.

In all cases under this Clause 23.4, MPW is not required to give reasons where doing so would be prohibited by Applicable Law, including where it could constitute tipping off under FIAMLA, or where it would undermine the purpose of the termination.

23.5 Partial Termination

MPW may exercise its rights under Clauses 23.3 and 23.4 in respect of all of the Services, or only in respect of a particular Account, sub-account, Service, Copy Trading Strategy, PAMM Account, instrument, product class, or functionality. In that case these Terms remain in force for the rest of the relationship.

23.6 Account Closure Fee

Nature of the fee. The Account Closure Fee is not a standard fee. It applies only to a Client Misconduct Closure. Closing an Account in those circumstances requires MPW to do work well beyond an ordinary closure, including:

• investigating and documenting the relevant conduct;

• compliance and MLRO review;

• enhanced reconciliation, and the reversal or adjustment of affected Transactions;

• dealing with banks, payment service providers, liquidity providers, and other counterparties;

• regulatory reporting where applicable; and

• enhanced record retention.

The Account Closure Fee is a charge for that work. It is set by reference to MPW’s reasonable estimate of the internal cost of providing it. It is not a penalty.

Amount. The Account Closure Fee is the fixed amount per Account closed specified in the Costs and Charges Schedule. Different amounts apply to Retail Investors and to Sophisticated Investors, and the Schedule may also set different amounts by Account type. The amount that applies is based on your categorisation on the date MPW gives notice of termination. Where MPW has re-categorised you as a Retail Investor because your Sophisticated Investor status was obtained through information falling within Clause 23.4.1(c), the Sophisticated Investor amount applies.

When the fee is not payable. The Account Closure Fee is not payable where:

a) you close your Account under Clause 10.1 or Clause 23.2, except as provided under Closure requests during a review below;

b) MPW terminates under Clause 23.3, or under Clause 23.4.2 where the termination is not treated as a Client Misconduct Closure; or

c) the termination results from an error by MPW or its service providers.

Closure requests during a review. The following closures are treated as a Client Misconduct Closure, and the Account Closure Fee is payable on them:

a) you request closure while a suspension, restriction, Compliance Review Event, or investigation relating to any matter in Clause 23.4.1 is open or pending, whether or not you have been told about it, and MPW later determines that the matter is established; or

b) you request closure within ninety (90) calendar days before MPW determines that any matter in Clause 23.4.1 occurred before or at the time of your request.

Third-party costs. In addition to the Account Closure Fee, MPW may pass on to you, at cost, any third-party charges reasonably incurred in connection with the Client Misconduct Closure. These include bank, payment-provider, liquidity-provider, transfer, and external legal or investigative charges.

Retail Investors. If you are a Retail Investor, the Account Closure Fee and related third-party costs will be deducted from the cash balance of your Account available at closure, including proceeds from closing positions, and will not create or increase a negative balance. Any part that cannot be recovered in this way will be waived.

Non-Retail Investors. If you are a Sophisticated Investor, any part of the Account Closure Fee or related costs that cannot be deducted from your Account becomes a debt owed by you to MPW, payable on demand. MPW may recover it by set-off under Clause 11.1 or through any other legal means.

Restricted funds. The Account Closure Fee will not be debited from funds or assets that are frozen, blocked, or restricted under Applicable Law, sanctions law, or a direction of a court or competent authority, or that are being held pending the assessment of a suspicious transaction report. Any amount that cannot be debited for that reason becomes payable once the restriction ends, and only to the extent Applicable Law permits.

Notification. The amount of the Account Closure Fee will be stated in the termination notice or in the final Account statement. MPW is not required to state the ground for the Client Misconduct Closure where doing so would be prohibited by Applicable Law.

Other rights preserved. The Account Closure Fee is in addition to, and does not limit:

• any Compliance Review Fee;

• Chargeback costs under Clause 9.6;

• the remedies in Clause 5.14.7 of Schedule 5;

• the indemnity in Clause 25.2; and

• any other right or remedy of MPW.

However, MPW will not recover the same cost twice.

Waiver. MPW may, at its discretion, waive or reduce the Account Closure Fee in any case.

23.7 Wind-Down and Effect of Termination

Where you terminate under Clause 23.2, the wind-down process in Clause 10.1 applies. Where MPW terminates under Clause 23.3 or 23.4:

a) pending Orders may be cancelled, and no new Orders, Deposits, Copy Trading links, or PAMM subscriptions will be accepted;

b) Copy Trading links will be terminated under Clause 12.9, and any Mandate will be terminated and redeemed under Clauses 13.11 and 13.12;

c) MPW may ask you to close your open positions by a deadline it specifies. If you do not, or where MPW terminates under Clause 23.4, MPW may close any or all of your open positions at prevailing market prices in accordance with the Best Execution Policy, without further notice, and you will bear the resulting market risk and costs;

d) non-cash assets will be transferred to another provider you nominate, where this is feasible and lawful and at your cost. If you do not nominate a provider within fourteen (14) calendar days of MPW’s request, MPW may sell those assets after giving you notice and treat the proceeds as Client Money; and

e) Deposits received after termination may be returned to their source.

On termination, all amounts you owe MPW become immediately due and payable. These include unsettled Transactions, margin obligations, negative balances not covered by Negative Balance Protection, accrued interests under Clause 11.3, fees (including any Account Closure Fee), costs, charges, Chargeback amounts, and indemnity amounts. MPW may deduct them from your Account or apply set-off under Clause 11.1.

Once those amounts have been settled and all required checks have been completed, any residual Client Money will be paid to a verified Linked Account in your name under Clause 8.3. Where the Linked Account is closed or rejects the payment, or where third-party transfer charges would be greater than the residual amount, MPW will hold the residual amount as Client Money until it receives valid instructions, and will treat it in accordance with the Dormant Account Policy.

Where KYC or verification is incomplete, MPW may, after internal review, return funds only to the account they were received from. Where Applicable Law, a sanctions requirement, or a competent authority requires or permits MPW to freeze, block, withhold, or not return funds or assets, MPW will hold them until it is permitted to release them, and will release them only to the person and the account that Applicable Law permits.

MPW will issue a final Account statement. Account records will be retained in accordance with Clause 10.1 and the Privacy and Data Protection Policy.

23.8 Accrued Rights, Survival, and No Liability

Termination does not affect any rights or obligations that arose before the termination date, including outstanding payment, settlement, interest, and margin obligations, fees, indemnities, and liabilities already incurred.

Any provision intended to continue after termination, or which by its nature should continue, will survive. This includes provisions on fees (including the Account Closure Fee), set-off, lien, confidentiality, record-keeping, data protection, limitation of liability, indemnity, governing law, and dispute resolution.

Subject to Clause 25.1, MPW is not liable for any loss arising from a suspension, restriction, termination, close-out, or sale carried out in accordance with this Clause 23.

Where MPW has terminated under Clause 23.4.1, MPW may decline any future application to open an Account from you or from any person MPW reasonably considers connected with you.

24. Force Majeure

24.1 Definition

A “Force Majeure Event” means any event or circumstance beyond MPW’s reasonable control that prevents, restricts, or delays the performance of its obligations under these Terms.

This may include, without limitation:

a) acts of God, natural disasters, pandemics, epidemics, or severe weather events;

b) war, armed conflict, civil disturbance, terrorism, or threats to public safety;

c) government action, regulatory action, sanctions, embargoes, currency restrictions, or other legal or regulatory constraints;

d) industrial action, strikes, lock-outs, or labour disputes;

e) failure, interruption, or disruption of public utilities, telecommunications, internet services, banking infrastructure, or payment systems;

f) failure, interruption, or disruption affecting a third-party service provider, including a cloud provider, custodian, payment processor, KYC provider, market data provider, trading venue, or other market infrastructure provider;

g) cyber-attacks, malware, ransomware, denial-of-service attacks, data breaches, or other malicious or unauthorised interference with systems;

h) suspension, closure, failure, or material disruption of any trading venue, clearing house, central counterparty, custodian, liquidity provider, payment provider, or banking partner; or

i) any other event or circumstance that is reasonably analogous to the above.

24.2 Effect

Where a Force Majeure Event prevents, restricts, or delays the performance of any obligation under these Terms, MPW will not be liable for the resulting non-performance or delay to the extent that it is caused by that Force Majeure Event.

Reasonable efforts will be used to mitigate the effects of the Force Majeure Event and to resume normal performance as soon as reasonably practicable.

If the Force Majeure Event continues for an unreasonable period, or materially prevents the continued operation of the Services, either party may terminate these Terms in accordance with Clause 23.

25. Liability and Indemnity

25.1 MPW's Liability

MPW will be liable to you only for direct loss that is finally determined to have arisen as a direct result of its material breach of these Terms, gross negligence, fraud, or wilful misconduct.

Subject to any liability that cannot lawfully be excluded or limited, MPW’s aggregate liability to you for any claim, or series of related claims, arising in connection with these Terms, the Platform, your Account, or the Services will not exceed the total fees and commissions actually paid by you to MPW in the twelve (12) months immediately preceding the event giving rise to the claim. For this purpose, third-party costs, taxes, duties, spreads, market charges, payment charges, pass-through costs, and any amounts paid or payable to third parties are excluded from the calculation of the liability cap.

MPW will not be liable for any market loss, trading loss, investment underperformance, loss of profit, loss of opportunity, loss of anticipated savings, loss of business, loss of goodwill, reputational loss, loss of data, indirect loss, consequential loss, special loss, punitive damages, or exemplary damages, whether arising in contract, tort, negligence, breach of statutory duty, or otherwise.

MPW will also not be liable for any loss arising from market movements, liquidity conditions, volatility, slippage, execution delay, trading venue disruption, custodian default, payment-provider failure, banking delays, third-party service-provider failure, system interruption, cyber incident, Force Majeure Event, inaccurate or incomplete information provided by you, failure to keep your Account secure, failure to monitor your positions, or any action taken in accordance with these Terms, Applicable Law, regulatory requirements, AML/CFT obligations, sanctions obligations, or risk-management requirements.

Nothing in these Terms excludes or limits any liability that cannot lawfully be excluded or limited under Applicable Law, including any mandatory protection that may apply under Mauritian law, consumer protection rules, or applicable FSC requirements.

25.2 Your Indemnity to MPW

You shall indemnify and hold harmless MPW, its directors, officers, employees, representatives, delegates, agents, affiliates, and service providers from and against any loss, liability, claim, demand, damage, cost, charge, expense, penalty, fine, assessment, or proceeding reasonably incurred or suffered in connection with:

a) your breach of these Terms or any Incorporated Document;

b) any information, representation, declaration, instruction, document, or confirmation provided by you that is inaccurate, incomplete, outdated, false, or misleading;

c) your fraud, negligence, wilful misconduct, breach of law, misuse of the Platform, unauthorised activity, or other wrongful conduct;

d) any Chargeback, payment reversal, recall, return, failed payment, or disputed Deposit connected with your Account;

e) any tax, regulatory, sanctions, AML/CFT, reporting, or legal liability arising from your status, circumstances, conduct, residence, nationality, tax classification, source of funds, source of wealth, or use of the Services;

f) any claim or action brought by a third party arising from your use of the Services, your Account, your Transactions, or any instruction given by you or on your behalf; and

g) any reasonable legal, professional, recovery, investigation, enforcement, or administrative costs incurred in connection with any of the above.

This indemnity will not apply to the extent that the relevant loss, liability, claim, cost, or expense is finally determined by a court or competent authority to have arisen directly from MPW’s fraud, wilful misconduct, or gross negligence.

26. Amendments and Notices

26.1 Amendments by MPW

MPW may update these Terms and any Incorporated Documents from time to time. Updates may be made for a number of reasons, including changes in Applicable Law or FSC requirements, changes to the Services, fees, or operational arrangements, changes involving third-party service providers, market or technology developments, and security, compliance, or risk-management considerations.

Where an amendment is material, you will be notified through the Platform, by email, or through another durable channel. A reasonable notice period will be given before the amendment takes effect, typically not less than thirty (30) calendar days, unless a shorter period is required or justified by Applicable Law, regulatory requirements, security concerns, or urgent operational reasons.

If you do not agree with a material amendment, you may close your Account in accordance with Clause 10.1 before the amendment takes effect. If you continue to use the Services after the effective date of the amendment, you will be treated as having accepted the amended Terms or Incorporated Document.

Non-material amendments, such as typographical corrections, clarifications, formatting changes, or updates to non-substantive references, may be made without prior notice. These amendments will be reflected in the version of the relevant document made available on the Platform.

For the avoidance of doubt, MPW may update, replace, supplement, or withdraw any Incorporated Document, including any schedule, in accordance with this Clause 26. Product, execution, custody, corporate-action, market-data, platform, technical, operational, or risk-management updates may take effect on shorter notice where this is reasonably required by Applicable Law, market conditions, third-party provider requirements, execution venue requirements, security considerations, or operational necessity.

26.2 Notices

Notices from MPW to you may be given through the communication channels described in Clause 16.2 and will take effect when sent.

Notices from you to MPW must be given through the Platform support channel, by email to clientcare@monolithmarket.com, or in writing to MPW’s registered office. A notice sent to MPW will take effect only when received during normal business hours.

Any notice or document relating to formal legal proceedings must be served at MPW’s registered office in Mauritius.

27. Intellectual Property and Platform Use

27.1 Ownership

All intellectual property rights in the Platform and its related materials belong to MPW or its licensors. These materials include all software, designs, content, branding, trademarks, databases, documentation, interfaces, tools, workflows and technical infrastructure. Nothing in these Terms transfers any of those rights to you.

27.2 Licence to use

MPW grants you a limited, revocable, non-exclusive, non-transferable and non-sublicensable right to access and use the Platform. You may use it only to receive the Services, and only in accordance with these Terms. No other right, title, interest or licence is granted to you, whether expressly or by implication.

27.3 Restrictions on use of the Platform

You must not, and must not permit any other person to:

a) copy, reproduce, modify, adapt, translate, or create derivative works from the Platform or any part of it;

b) reverse-engineer or decompile the Platform or any part of it, except to the extent permitted by Applicable Law;

c) remove, obscure or alter any proprietary, copyright or trademark notice;

d) scrape, harvest, or systematically extract or download data from the Platform, including market data, except as permitted under Schedule 5;

e) attempt to gain unauthorised access to the Platform, its systems or networks, or to any other person’s Account;

f) introduce any virus, malware or other malicious code, or interfere with or disrupt the operation, integrity or security of the Platform; or

g) use the Platform for any unlawful or improper purpose.

27.4 Trading conduct and automated access

Your trading activity on the Platform is subject to the conduct standards in Schedule 5 (Market Data and Platform Use Schedule). In particular:

a) you must not engage in market abuse, market manipulation, or any abusive or toxic trading practice described in Clause 5.14 of Schedule 5, including: i) latency arbitrage and price-feed exploitation; ii) abusive scalping and abusive news trading; iii) cross-account and cross-broker hedging; and iv) multiple-account abuse and coordinated trading; and

b) you must not use any API, bot, algorithm, expert advisor, bridge, copy tool or other automated means to access the Platform or place Orders, unless MPW has expressly approved this in advance. Any approved use is subject to Clause 5.13 of Schedule 5 and to any conditions MPW imposes.

27.5 Consequences of breach

If you breach this Clause 27, MPW may take any action available to it under these Terms, including:

a) the measures set out in Clause 5.14.7 of Schedule 5; and

b) the immediate suspension, restriction or termination of your Account and your access to the Services.

These rights are without prejudice to any other right or remedy available to MPW under these Terms or Applicable Law.

28. Assignment and Sub-Contracting

You may not assign, transfer, sub-license, charge, or otherwise dispose of any of your rights or obligations under these Terms without MPW’s prior written consent.

MPW may assign or transfer any of its rights or obligations under these Terms, in whole or in part, to a member of its group, to an FSC-licensed successor, or in connection with a sale, restructuring, merger, transfer, or reorganisation of its business or any relevant part of it. Where reasonably practicable, you will be given notice of the assignment or transfer.

Where the assignment or transfer is made to an FSC-licensed entity, or to another appropriately authorised entity providing equivalent services and materially equivalent protection, you agree that the assignment or transfer may take effect without requiring any further consent from you. Continued use of the Services after notice of the assignment or transfer will constitute acceptance of the new service provider.

MPW may also delegate, outsource, or sub-contract any part of the Services or its operational functions to third parties, including custodians, payment service providers, KYC providers, technology providers, cloud providers, market data providers, execution venues, liquidity providers, and other service providers. Unless otherwise stated in these Terms or required by Applicable Law, MPW remains responsible to you for the performance of the Services it provides, including where relevant functions are performed through delegates, outsourced providers, or sub-contractors.

29. Severability, Waiver, and Entire Agreement

If any provision of these Terms is found to be invalid, illegal, or unenforceable in any jurisdiction, the remaining provisions will continue in full force and effect. The affected provision will apply only to the extent that it is valid, legal, and enforceable, and will be interpreted, where possible, in a way that reflects its intended commercial effect.

Any failure or delay by MPW in enforcing any provision of these Terms will not be treated as a waiver of that provision, any related provision, or any right to enforce it later. A waiver will be effective only if given expressly and in writing.

These Terms, together with the Incorporated Documents, constitute the entire agreement between you and MPW in relation to the Services. They replace all prior agreements, statements, representations, understandings, and arrangements, whether written or oral, relating to the same subject matter, except in respect of any fraudulent representation.

30. Governing Law and Jurisdiction

These Terms, and any non-contractual obligation arising out of or in connection with them, are governed by and will be interpreted in accordance with the laws of the Republic of Mauritius.

The courts of the Republic of Mauritius will have exclusive jurisdiction to determine any dispute arising out of or in connection with these Terms, the Platform, your Account, or the Services. This is subject to any statutory right you may have, where applicable, to refer a matter to the Ombudsperson for Financial Services or to the FSC under Mauritian law.

Nothing in this Clause prevents MPW from bringing proceedings against you in any other jurisdiction where you reside, carry on business, hold assets, or where proceedings are necessary or appropriate to enforce its rights, recover amounts owed, protect its interests, or comply with Applicable Law.

31. Electronic Acceptance

These Terms are accepted when you confirm them electronically through the Platform onboarding workflow. Your electronic acceptance has the same legal effect as a written signature.

A record of your acceptance will be retained for evidentiary purposes. This may include the date and time of acceptance, IP address, authentication context, device or session information, and any other relevant acceptance data.

If you later choose to use Copy Trading or subscribe to a PAMM Account, your electronic confirmation of the relevant copying relationship or PAMM Mandate will constitute a separate and specific acceptance of the terms, disclosures, risks, fees, and parameters applicable to that Service. This includes Clause 12 in respect of Copy Trading and Clause 13 in respect of PAMM.

Your electronic acceptance of these Terms includes acceptance of the Incorporated Documents, including the Product Terms Schedule, Order Types and Execution Mechanics Schedule, Corporate Actions and Product Events Schedule, Custody and Client Assets Schedule, and Market Data and Platform Use Schedule, in each case as applicable to the Services, products, instruments, Transactions, Account features, or Platform functionality made available to you.

Where a particular Service, product, instrument, strategy, Account feature, or Platform functionality requires a separate acknowledgement, election, mandate, disclosure, risk warning, or consent, your electronic confirmation of that item through the Platform will constitute additional and specific acceptance of the terms, disclosures, risks, fees, parameters, and limitations applicable to that item.

Confirmation: By accepting these Terms electronically through the Platform, you confirm that you have read these Terms and the Incorporated Documents in full, and that you understand them or have had the opportunity to obtain professional advice before accepting them.

You also confirm that you understand the nature of the Services and the risks involved, including the risk of losing capital, and that no investment outcome, profit, return, or protection from loss is guaranteed.

You accept the Client categorisation applied to you, whether as a Retail Investor or Sophisticated Investor, and understand the consequences of that categorisation as described in the Client Categorisation Policy.

You further acknowledge that, if you use the Copy Trading Service under Clause 12, this involves MPW providing a personalised recommendation to you based on the activity of the Lead Trader you select. If you subscribe to a PAMM Account under Clause 13, you grant a discretionary management mandate under which trading decisions may be made on your behalf, through the designated PAMM Manager, without your further consent to individual Transactions.

By accepting these Terms, you also provide the consents and acknowledgements set out in them, including in relation to the processing of personal data, recording of communications, third-party sub-processing, electronic communications, and electronic acceptance.

You agree to provide accurate, complete, and up-to-date information, and to update that information whenever required.

End of Main Terms — Schedules Follow and Form Part of these Terms

MONOLITH MARKET

BROKERAGE TERMS AND CONDITIONS

SUPPLEMENTARY SCHEDULES

to be annexed to the Monolith Market Brokerage Terms and Conditions

These Schedules supplement and form part of the Monolith Market Brokerage Terms and Conditions. Capitalised terms used but not defined in these Schedules have the meanings given to them in the Terms. If there is any inconsistency between the Terms and the Schedules, the Schedules prevail in accordance with Clause 1.3.

These Schedules are drafted for use with the current Terms and should be reviewed together with the main Terms, the Incorporated Documents and the product offering actually made available on the Platform.

Schedule list

Schedule 1 – Product Terms Schedule

Schedule 2 – Order Types and Execution Mechanics Schedule

Schedule 3 – Corporate Actions and Product Events Schedule

Schedule 4 – Custody and Client Assets Schedule

Schedule 5 – Market Data and Platform Use Schedule

Schedule 1 – Product Terms Schedule

Product availability, product nature, ownership rights and product-specific risk allocation

1.1 Purpose and application

This Schedule applies to all financial instruments and product classes made available through the Platform from time to time. It should be read together with the main Terms, the Risk Disclosure Statement, the Costs and Charges Schedule, the Suitability and Appropriateness Policy, the Best Execution Policy, and any product-specific disclosure made available on the Platform.

1.2 Product availability

MPW may determine, at its reasonable discretion, which products, markets, asset classes, instruments, currencies, strategies, order types, leverage levels and account features are made available to a Client or category of Clients.

Availability may depend on Client categorisation, jurisdiction, KYC status, suitability or appropriateness outcome, Account currency, trading experience, product complexity, liquidity, market conditions, counterparty availability, custodian availability, settlement arrangements, regulatory restrictions and MPW's risk appetite.

A product being visible on the Platform does not mean that it is available to every Client or that it is suitable or appropriate for any Client.

1.3 Product information and disclosures

Before entering any Transaction, you should review the information made available for the relevant product, including the product description, pricing basis, key risks, costs, charges, margin requirements, trading hours, settlement cycle, tax treatment where disclosed, and any restrictions that apply.

Product information may be provided through the Platform, the Risk Disclosure Statement, the Costs and Charges Schedule, instrument pages, order tickets, product factsheets, disclosures, notices or other materials made available from time to time.

Product information may change. You are responsible for reviewing the latest information before placing an Order or allocating capital to Copy Trading or PAMM.

1.4 Cash securities and investment instruments

Where MPW makes cash securities or other investment instruments available, such as shares, bonds, exchange-traded funds or similar instruments, the Transaction may result in you acquiring an interest in the relevant instrument, subject to the custody, nominee, settlement, fractional interest and product-specific arrangements applicable to that instrument.

Unless the Platform or the relevant product disclosure states otherwise, legal title may be held by a custodian, sub-custodian, nominee or other account provider for the benefit of MPW's Clients, and your entitlement will be reflected in MPW's books and records in accordance with Schedule 4.

Rights attached to securities, including voting rights, dividends, distributions, rights issues, corporate actions and transfer rights, may be limited or exercised only through the relevant custodian or nominee structure. Schedule 3 and Schedule 4 apply to those matters.

1.5 Contracts for difference, rolling products and other derivatives

Where MPW makes contracts for differences, rolling spot products, margin FX, derivatives or similar products available, the Transaction gives you contractual exposure to price movements in the relevant reference asset or market. It does not give you legal or beneficial ownership of the underlying asset, nor any voting rights, delivery rights or ownership rights in that asset, unless the product documentation expressly states otherwise.

The economic result of a derivative Transaction may be affected by leverage, financing charges, spreads, conversion costs, margin requirements, slippage, corporate-action adjustments, dividend adjustments, liquidity, market volatility and the creditworthiness of the relevant counterparty or liquidity provider.

No physical delivery of the underlying asset will occur unless the relevant product is expressly described as physically settled and MPW confirms that physical settlement is supported by your Account.

1.6 Foreign exchange and precious metals

Where spot foreign exchange, rolling FX, precious metals or similar products are made available, they may be provided as cash-settled, rolling or derivative exposures rather than as physical delivery products. The applicable product disclosure will indicate the nature of the exposure.

FX and metals Transactions may be affected by spreads, rollovers, swap, overnight financing, liquidity, market gaps, banking holidays, settlement conventions, conversion costs, and restrictions imposed by liquidity providers or payment channels.

1.7 Bonds and fixed-income instruments

Where bonds or fixed-income instruments are made available, you accept issuer credit risk, interest-rate risk, liquidity risk, market risk, currency risk, settlement risk, and, where relevant, restructuring, default, bail-in or early redemption risk.

Prices for bonds and fixed-income instruments may be indicative, dealer-derived or based on third-party data rather than exchange-traded prices. Liquidity may be limited, and execution may depend on available counterparties and minimum dealing sizes.

1.8 Funds, ETFs and collective investment products

Where funds, ETFs or collective investment products are made available, you accept the risks associated with the underlying portfolio, the issuer, the fund manager, the depositary, the administrator, tracking error, liquidity, market disruption, suspension of dealings, valuation methodology and any product-specific fees.

MPW is not responsible for the performance, operation, valuation, suspension, liquidation or winding-up of any third-party fund, ETF or issuer, except to the extent required by Applicable Law or caused by MPW's fraud, wilful misconduct or gross negligence.

1.9 Options, futures and expiring products

Where options, futures or other expiring products are made available, the product may be subject to expiry, automatic close-out, exercise, assignment, cash settlement, physical settlement restrictions, margin changes, delivery restrictions, contract rollovers and exchange or counterparty rules.

MPW may close, cash-settle, lapse, roll, restrict or otherwise deal with an expiring product where necessary or appropriate, including where physical delivery is not supported, where you have insufficient margin or funds, or where action is required by a trading venue, broker, counterparty, clearing house, custodian or Applicable Law.

1.10 Crypto-assets and digital assets, where supported

Where crypto-assets, digital assets, tokenised assets or related products are made available, they may be provided as custody assets, derivative exposures, cash-settled products or other structures depending on the product description and regulatory permissions applicable at the relevant time.

Crypto-assets involve specific risks, including blockchain failure, fork, airdrop, protocol change, network congestion, cyber-attack, private-key compromise, wallet provider failure, smart-contract risk, regulatory restriction, extreme volatility, liquidity risk and the risk of permanent loss. MPW may decline to support, credit, distribute or participate in forks, airdrops, staking rewards or protocol events unless expressly stated on the Platform.

1.11 Fractional interests

Where fractional interests in securities or other instruments are supported, your entitlement may be limited to an economic interest recorded in MPW's books and records. Fractional interests may not carry voting rights, transfer rights, direct registration rights or the ability to receive the relevant instrument in physical or certificated form.

Dividends, distributions, corporate-action proceeds and fees relating to fractional interests may be rounded, aggregated, adjusted or credited in cash in accordance with MPW's systems and the relevant custodian or nominee arrangements.

1.12 Short selling and short exposure

Where short selling or short exposure is permitted, you accept the risk that losses may be unlimited or may exceed the funds initially allocated to the relevant Transaction, subject to any Negative Balance Protection that applies. You may also be exposed to borrowing costs, recall risk, buy-in risk, dividend-equivalent payments, corporate-action adjustments and forced close-out.

MPW may restrict, reject, close, reduce or recall short exposure where required by Applicable Law, market conditions, liquidity provider requirements, borrow availability, custodian requirements, risk-management considerations or any applicable market rule.

1.13 Product removal, reduce-only mode and forced closure

MPW may suspend, restrict, remove or cease to support any product, market, instrument, strategy or feature at any time where this is reasonably necessary or appropriate. This may include placing an instrument into reduce-only mode, prohibiting new opening Transactions, limiting position increases, amending margin requirements, cancelling pending Orders, or closing affected positions.

Such action may be taken because of legal or regulatory change, issuer action, market disruption, liquidity deterioration, counterparty withdrawal, custodian restriction, product expiry, pricing failure, sanctions, corporate action, technology limitation, risk-management concern or any other reason reasonably relevant to the orderly provision of the Services.

Where reasonably practicable, MPW will notify affected Clients before taking such action. Prior notice may not be given where immediate action is required or appropriate.

1.14 Product-specific costs and taxes

Different products may be subject to different spreads, commissions, custody fees, financing charges, rollover charges, borrowing costs, market charges, exchange fees, taxes, stamp duties, withholding taxes, transaction taxes, conversion costs and other charges. These are set out in the Costs and Charges Schedule, on the Platform, or in the relevant product disclosure.

You are responsible for understanding the costs and tax consequences of each product before trading. MPW does not provide tax advice.

1.15 No product recommendation unless expressly agreed

Making a product available on the Platform does not, by itself, constitute a recommendation, solicitation, invitation or advice to trade that product. A personalised recommendation is provided only where MPW has expressly agreed to provide Investment Advice in accordance with the Terms, including through Copy Trading or PAMM where applicable.

Schedule 2 – Order Types and Execution Mechanics Schedule

Order types, trigger rules, slippage, gapping, execution limitations and automated order flows

2.1 Purpose and application

This Schedule supplements Clause 5 of the Terms and applies to Orders placed through the Platform, through any other permitted channel, through Copy Trading, through PAMM, or automatically by the Platform in accordance with your instructions, parameters or Mandate.

2.2 General order principles

An Order is an instruction to seek execution. It is not a guarantee that a Transaction will be executed, executed in full, executed immediately, executed at the requested price, or executed at all.

Orders may be accepted, rejected, delayed, cancelled, amended, partially filled or executed at a different price in accordance with the Terms, the Best Execution Policy, this Schedule and the functionality of the Platform.

2.3 Order parameters

An Order may require you to specify the instrument, buy or sell direction, size, quantity, price level, order type, time in force, expiry, linked order, stop level, take-profit level, trailing distance, margin preference, or other execution parameter supported by the Platform.

You are responsible for checking that all Order parameters are correct before submitting the Order. MPW is entitled to rely on Orders submitted through the applicable authentication procedures.

2.4 Market orders

A market order is an Order to buy or sell as soon as reasonably practicable at the price available in the market or through the applicable execution arrangement at the time of execution.

A market order does not guarantee the price shown when the Order is submitted. The execution price may be less favourable because of market movement, liquidity, volatility, gaps, execution delay, order size, price aggregation, routing, or other execution factors.

2.5 Limit orders

A limit order is an Order to buy or sell at a specified price or better, subject to liquidity and execution availability. A buy limit order will generally seek execution at or below the specified price, and a sell limit order will generally seek execution at or above the specified price.

A limit order may not be executed if the specified price is reached only briefly, if insufficient liquidity is available, if the Order does not meet minimum size requirements, or if execution is otherwise restricted under the Terms.

2.6 Stop orders and stop-loss orders

A stop order is an Order that becomes eligible for execution when the relevant trigger price is reached or passed according to the Platform's pricing basis for that instrument.

Once triggered, a stop order may be executed as a market order or other order type supported by the Platform. It is not guaranteed to execute at the stop level. The execution price may be less favourable, particularly during volatile markets, illiquid markets, news events, market gaps, trading halts or market open conditions.

2.7 Stop-limit orders

A stop-limit order combines a stop trigger with a limit price. Once the stop trigger is reached, the Order becomes a limit order rather than a market order. This may reduce execution at a worse price than the limit price, but it may also result in no execution if the market moves beyond the limit price or liquidity is insufficient.

2.8 Take-profit orders

A take-profit order is an Order intended to close or reduce a position when a specified favourable price level is reached or passed. Execution is subject to liquidity, platform functionality, market conditions and the applicable execution arrangements.

A take-profit order may be executed at a price different from the target level where market movement, gaps, liquidity or execution mechanics require this.

2.9 Trailing stop orders

A trailing stop order is a stop order whose trigger level may move in line with favourable price movement according to the trailing distance or method selected on the Platform. It is designed to follow favourable market movement while preserving a stop trigger if the market reverses.

Trailing stop functionality may be affected by platform availability, pricing ticks, quote frequency, market gaps, volatility, instrument availability and technical limitations. A trailing stop is not guaranteed to limit losses to the selected trailing amount.

2.10 Linked, contingent and OCO orders

The Platform may support linked or contingent orders, including if-done, one-cancels-the-other, stop-loss and take-profit combinations or similar arrangements. These Orders operate according to the Platform functionality available at the relevant time.

Linked or contingent Orders may not operate as intended if there is a platform outage, market disruption, liquidity constraint, partial fill, rejected Order, margin shortfall, pricing error or other execution issue.

2.11 Time-in-force instructions

The Platform may support time-in-force instructions such as day orders, good-till-cancelled, good-till-date, immediate-or-cancel and fill-or-kill. The meaning and availability of each instruction may vary by product, market, execution venue or liquidity provider.

An Order may expire, cancel or remain pending according to its selected time-in-force instruction, the Platform functionality and any applicable market or venue rule.

2.12 Guaranteed stops

A stop order is not guaranteed unless it is expressly labelled on the Platform as a guaranteed stop and MPW confirms that guaranteed-stop functionality is available for the relevant product and Account.

Where guaranteed stops are offered, they may be subject to additional fees, minimum distance requirements, maximum size limits, instrument restrictions, trading-hour restrictions and other conditions disclosed on the Platform or in the Costs and Charges Schedule.

2.13 Trigger prices and pricing basis

Orders are triggered by reference to the price, quote or pricing basis used by the Platform for the relevant instrument. This may be the bid price, ask price, mid-price, last traded price, indicative price, broker quote, liquidity-provider quote, exchange price or another pricing basis disclosed on the Platform.

The price visible on third-party websites, news services, charting platforms or other data sources may differ from the price used by the Platform for triggering or executing Orders.

2.14 Slippage and gapping

Slippage means execution at a price different from the price requested, quoted, displayed or expected. It may be favourable or unfavourable. Gapping means a market movement from one price level to another without trading at intermediate prices or without sufficient liquidity at those levels.

You accept that slippage and gapping may occur, especially during fast markets, low liquidity, market open or close, news announcements, economic releases, trading halts, weekends, public holidays, market disruption or extraordinary events.

Stop-loss Orders, market Orders and other Orders may be executed at a less favourable price than expected where slippage or gapping occurs.

2.15 Partial fills

An Order may be filled in whole, in part, or not at all. Partial fills may occur where available liquidity is insufficient, where the Order is too large for immediate execution, where market conditions change, or where execution venues, liquidity providers or counterparties impose limits.

The unfilled portion of a partially filled Order may remain pending, be cancelled, expire or be treated in accordance with the Platform functionality and time-in-force instruction applicable to that Order.

2.16 Order modification and cancellation

You may request to modify or cancel a pending Order where the Platform permits this. A modification or cancellation request is not effective unless and until it has been received, processed and confirmed through the Platform or the relevant execution arrangement.

An Order may already have been executed before a modification or cancellation request is processed. Any executed portion remains valid and binding.

2.17 Orders outside trading hours

Orders submitted outside normal trading hours for the relevant instrument may be rejected, queued, held pending market open, executed when liquidity becomes available, or otherwise handled according to the Platform functionality and the relevant market rules.

Prices at market open may differ materially from prices available when the Order was submitted or last viewed.

2.18 Margin checks and automatic orders

Orders may be subject to pre-trade and post-trade checks, including margin, exposure, concentration, suitability, appropriateness, product-availability, sanctions, AML/CFT, risk-management and system checks.

Orders generated through Copy Trading, PAMM, margin close-out, stop-out processes, risk-reduction tools or other automated functionality may be submitted without further manual instruction from you, in accordance with the Terms, your copy parameters, the relevant Mandate or the applicable risk-management process.

2.19 No duty to monitor or intervene

Unless expressly agreed in writing or required by Applicable Law, MPW is not obliged to monitor your Orders, positions, copy parameters, PAMM exposure, margin level, stop levels, take-profit levels, trading strategy or Account performance, or to warn you before an Order is executed, expires, is rejected or is affected by market conditions.

This paragraph does not limit any monitoring, surveillance or review that MPW carries out for its own legal, regulatory, market-conduct, risk-management or compliance purposes, including under Clause 5.14 of Schedule 5. Such monitoring is carried out for MPW’s purposes only. It does not create any duty owed to you to monitor, warn or intervene, and MPW is not liable to you for any failure to detect or act on any matter through it.

Schedule 3 – Corporate Actions and Product Events Schedule

Dividends, adjustments, delistings, suspensions, expiry, rollovers and extraordinary events

3.1 Purpose and application

This Schedule applies where any instrument, underlying asset, index, issuer, fund, derivative, contract or product made available through the Platform is affected by a corporate action, market event, product event, adjustment event or extraordinary event.

3.2 Corporate actions and product events

Corporate actions and product events may include dividends, distributions, interest payments, coupon payments, stock splits, consolidations, bonus issues, rights issues, spin-offs, mergers, takeovers, schemes of arrangement, conversions, redemptions, issuer defaults, restructurings, delistings, suspensions, trading halts, insolvency events, fund liquidations, index changes, benchmark changes, contract expiries, rollovers, forks, airdrops and any analogous event.

3.3 Information and notices

MPW may provide information about corporate actions or product events through the Platform, email, in-app notification, Account statement, product page or other durable channel. Information may be received from issuers, exchanges, custodians, sub-custodians, market data providers, liquidity providers, administrators or other third parties.

MPW does not guarantee the accuracy, completeness or timeliness of third-party information. Where information is corrected, updated or reversed by a third party, corresponding adjustments may be made to your Account.

3.4 MPW's adjustment powers

Where a corporate action or product event occurs, MPW may take any action it considers fair, reasonable and operationally practicable, having regard to the nature of the product, the treatment applied by the relevant issuer, market, exchange, broker, custodian, counterparty, liquidity provider or calculation agent, and the interests of affected Clients.

This may include adjusting prices, quantities, contract terms, margin requirements, stop levels, take-profit levels, reference prices, cash balances, Account entries, Allocation Coefficients, NAVs, financing charges, copied positions, PAMM positions or any other relevant Account record.

It may also include closing, cash-settling, cancelling, suspending, converting, rolling, replacing, transferring, reducing or otherwise dealing with affected positions or Orders.

3.5 Dividends, coupons and distributions

Where you hold an instrument that gives rise to a dividend, coupon, interest payment or other distribution, your Account may be credited with the amount received or credited through the relevant custody or settlement chain, net of any applicable tax, withholding, fee, charge, currency conversion or third-party deduction.

Where you hold a derivative or short exposure, your Account may instead be credited or debited with a cash adjustment that reflects, or is intended to reflect, the economic effect of the dividend, coupon, interest payment or distribution on the relevant product.

Dividend and distribution adjustments may differ from the amount declared by the issuer because of withholding tax, currency conversion, custody fees, product structure, liquidity-provider methodology, counterparty treatment or Applicable Law.

3.6 Rights issues, elections and voluntary events

Where a corporate action requires an election, subscription instruction, tender instruction or other voluntary response, MPW may set an earlier internal deadline than the issuer, exchange, custodian or market deadline in order to process instructions through the custody or execution chain.

If you do not provide a valid instruction by the deadline specified, MPW may take the default action determined by the issuer, custodian, market or MPW's operational process. MPW is not obliged to make an election or advance funds on your behalf.

Some voluntary corporate actions may not be supported. In that case, MPW may credit cash proceeds, allow the entitlement to lapse, sell the entitlement where practicable, or take another action considered reasonable in the circumstances.

3.7 Splits, consolidations and reorganisations

Where an instrument is affected by a split, consolidation, reorganisation or similar event, positions and Account entries may be adjusted to reflect the economic effect of the event. Fractional entitlements may be rounded, aggregated, sold, cash-settled or otherwise dealt with according to the relevant custodian, market or Platform process.

3.8 Mergers, takeovers, delistings and suspensions

Where an issuer is affected by a merger, takeover, delisting, suspension, restructuring, insolvency or similar event, MPW may restrict trading, place the instrument into reduce-only mode, cancel pending Orders, close affected positions, transfer positions, cash-settle entitlements, or continue to show the position at a value determined by the available pricing or valuation process.

Liquidity may be limited or unavailable, and you may be unable to open, close, transfer or value the affected position during the relevant period.

3.9 Product expiry and rollover

Where a product has an expiry date, last trading date, rollover date or settlement date, you are responsible for monitoring that date and any related Platform notice.

MPW may close, cash-settle, roll, replace or otherwise deal with an expiring product before expiry where necessary or appropriate, including where physical delivery is not supported, where margin is insufficient, where the product is subject to liquidity or trading restrictions, or where action is required by a venue, broker, counterparty, clearing house, custodian or Applicable Law.

3.10 Index, benchmark and calculation changes

Where a product references an index, benchmark, basket, rate, formula or calculation agent, the product may be affected by rebalancing, methodology changes, benchmark cessation, benchmark replacement, data unavailability, calculation errors or changes made by the relevant administrator or calculation agent.

MPW may adjust, suspend, close, replace or otherwise deal with affected products in a manner it considers fair and reasonable, having regard to the treatment applied by the relevant third party and the nature of the product.

3.11 Extraordinary events

An extraordinary event may include market disruption, trading halt, exchange closure, liquidity failure, settlement failure, issuer default, nationalisation, expropriation, capital control, sanctions event, currency restriction, cyber incident, systems failure, force majeure event, legal change, regulatory action or any event that materially affects the pricing, trading, settlement, custody or availability of a product.

Where an extraordinary event occurs, MPW may take any action reasonably necessary or appropriate to protect Clients, preserve orderly trading, comply with Applicable Law, manage risk or give effect to the relevant third-party treatment.

3.12 Treatment of Copy Trading and PAMM

Corporate actions and product events may affect Copy Trading Strategies and PAMM Accounts. Adjustments may be applied to copied positions, Lead Trader positions, PAMM Account positions, Allocation Coefficients, NAVs, performance fee calculations, High Water Marks or other related records where necessary to reflect the relevant event.

Where a Lead Trader or PAMM Manager acts in response to a corporate action or product event, follower Accounts or PAMM Sub-Accounts may not receive identical results because of timing, liquidity, position size, fractional treatment, margin, product restrictions or operational limitations.

3.13 Errors, reversals and corrections

Corporate-action and product-event entries may be reversed, amended or corrected where MPW receives corrected information, where a custodian or other third-party reverses or adjusts an entitlement, where tax or withholding treatment changes, or where an operational, pricing or calculation error is identified.

If a correction results in an amount being owed by you to MPW, that amount may be debited from your Account or recovered in accordance with the Terms.

3.14 No guarantee of equivalent treatment

The treatment applied to your Account may differ from the treatment you would have received if you held the underlying instrument directly, held it through another broker, or participated directly with the issuer. Differences may arise because of nominee holding, omnibus custody, fractional interests, product structure, derivative exposure, tax treatment, custodian processes, operational constraints or Applicable Law.

Schedule 4 – Custody and Client Assets Schedule

Custody arrangements, nominee holding, omnibus accounts, fractional assets, securities lending and client asset risks

4.1 Purpose and application

This Schedule applies where MPW holds, arranges the holding of, administers or records financial instruments, securities, digital assets or other client assets for or on behalf of Clients. Client Money is dealt with separately under Clause 6 of the Terms.

4.2 Custody arrangements

Client assets may be held directly by MPW where permitted, or through one or more custodians, sub-custodians, brokers, nominees, settlement systems, depositaries, wallet providers, electronic money institutions, payment institutions or other approved service providers.

MPW will exercise reasonable skill, care and diligence in selecting and periodically reviewing custody providers, having regard to their regulatory status, financial soundness, operational capability, jurisdiction, safeguarding arrangements, technology standards, reputation and suitability for the relevant asset class.

4.3 Nominee and omnibus structures

Client assets may be held in the name of MPW, a nominee, a custodian, a sub-custodian or another account provider in an omnibus or pooled account, together with assets belonging to other Clients or other clients of the relevant provider.

Where assets are held in an omnibus or nominee structure, your individual entitlement will be recorded in MPW's books and records and, where applicable, in records maintained by the relevant custody provider. You may not be identified individually on the register of the issuer, central securities depositary, exchange, blockchain, custodian or sub-custodian.

4.4 Beneficial interest

Unless the relevant product disclosure states otherwise, you will have the economic or beneficial interest recorded for your Account, rather than direct legal title registered in your own name. Your rights are subject to the custody chain, settlement system, nominee arrangements, product structure and Applicable Law.

MPW's books and records will be used to determine your entitlement to client assets, subject to reconciliation, settlement, correction of errors and any rights of set-off, lien, deduction or adjustment permitted under the Terms.

4.5 Custody risks

You accept custody risk, including the risk that assets may be affected by the default, insolvency, operational failure, cyber incident, fraud, negligence, misconduct, record-keeping failure, legal restriction, settlement failure or regulatory action affecting any custodian, sub-custodian, nominee, broker, depositary, settlement system, wallet provider or other third party in the custody chain.

The treatment of client assets in an insolvency or resolution process may depend on the law of the jurisdiction in which the assets are held, the account structure, the quality of segregation, the custody provider's records, the type of asset and the rights of other clients or creditors.

4.6 Settlement risk

A Transaction may not settle on the expected date. Settlement may be delayed or fail because of market disruption, counterparty default, custodian failure, insufficient securities, payment failure, sanctions screening, regulatory restriction, operational error or other factors.

Until settlement is complete, your rights in the relevant asset or cash proceeds may be conditional or subject to reversal, correction or further action required by the settlement system, custodian, counterparty, broker or MPW.

4.7 Income, dividends and distributions

Income, dividends, coupons, interest, distributions or other amounts received in respect of client assets will be credited to your Account after receipt and reconciliation, net of any applicable tax, withholding, custody fee, conversion cost, third-party charge or other deduction.

Where amounts are received in a currency different from your Account currency, they may be converted at the applicable conversion rate and subject to any disclosed spread, fee or charge.

4.8 Voting rights and shareholder communications

Voting rights, shareholder communications, meetings, consents, class actions and other rights attached to client assets may be limited by the custody structure. MPW is not obliged to arrange voting, attendance, proxy submission, class-action participation or shareholder communication forwarding unless it expressly makes that functionality available for the relevant asset and Account.

Where voting or election functionality is made available, MPW may set internal deadlines, require specific instruction formats, decline unsupported elections, and act through the relevant custodian or nominee. Instructions received after the stated deadline may not be processed.

4.9 Transfers in and transfers out

MPW may, at its discretion, support transfers of assets into or out of your Account. Transfers may be subject to product eligibility, custodian acceptance, settlement system capability, regulatory checks, KYC, AML/CFT, sanctions screening, minimum size requirements, fees, taxes, third-party costs and operational limitations.

MPW may decline, delay or restrict a transfer where the asset is unsupported, the transfer route is unavailable, the receiving or delivering institution is not acceptable, due diligence is incomplete, or legal, regulatory, operational or risk-management concerns apply.

4.10 Fractional assets

Fractional assets may be recorded as book-entry economic entitlements rather than separately transferable legal interests. They may be incapable of transfer to another broker, direct registration, certificated delivery or voting.

If your Account is closed, a product is removed or a transfer is requested, fractional entitlements may be liquidated and credited in cash rather than transferred in kind.

4.11 Securities lending, pledging and rehypothecation

Unless you have given separate and express consent, or unless the relevant product terms clearly provide otherwise, MPW will not lend, pledge, charge, rehypothecate or otherwise use your fully paid client assets for MPW's own financing or proprietary purposes.

Where margin trading, securities financing, stock lending or collateral arrangements are offered, the relevant terms will specify the assets affected, the rights granted, the risks, the compensation or fees, the termination mechanics, and the circumstances in which assets may be used, transferred or returned.

4.12 Lien, set off and security rights

To the extent permitted by Applicable Law and the Terms, MPW may exercise rights of lien, retention, set-off, deduction or sale over assets or proceeds held for you where amounts are due from you, including fees, charges, margin obligations, negative balances, settlement obligations, Chargebacks, indemnity amounts or other liabilities.

4.13 Reconciliations and records

MPW will maintain records designed to identify each Client's entitlement to client assets and will reconcile those records against relevant custodian, sub-custodian, broker, settlement system or wallet-provider records at intervals determined in accordance with Applicable Law, internal procedures and the nature of the asset.

Any reconciliation discrepancy will be investigated and corrected as soon as reasonably practicable. Account entries may be adjusted where required to correct errors, reflect third-party corrections, give effect to corporate actions or align the records with the settled position.

4.14 Digital asset custody, where supported

Where digital assets are supported, they may be held through wallets, custodians, sub-custodians, omnibus addresses, segregated addresses, cold storage, hot wallets or other arrangements selected by MPW. You may not have access to private keys, wallet credentials, blockchain addresses or direct on-chain control unless expressly provided.

Digital asset custody involves additional risks, including private-key compromise, smart-contract failure, protocol failure, blockchain reorganisation, fork, airdrop, network congestion, wallet-provider insolvency, cyber-attack, irreversible transfer, regulatory restriction and loss of access. MPW may decline to support or credit unsupported tokens, forks, airdrops, staking rewards or other protocol events.

4.15 No deposit insurance or compensation scheme unless disclosed

Client assets and Client Money are not guaranteed by MPW, by any custodian or by any government or compensation scheme unless a specific guarantee or scheme is expressly disclosed as applicable. Segregation and custody arrangements are designed to protect client entitlements, but they do not eliminate custody, insolvency, market, settlement or operational risk.

Any disclosure regarding deposit insurance, investor compensation, statutory protection or equivalent arrangements should be read together with the regulatory disclosures made available on the Platform and should be confirmed by reference to Applicable Law.

Schedule 5 – Market Data and Platform Use Schedule

Platform prices, market data, system availability, mobile access, API use and security obligations

5.1 Purpose and application

This Schedule applies to your use of the Platform, including web, mobile, API, notification, reporting, charting, pricing, market data, analytics, educational content and other digital functionality made available from time to time.

5.2 Platform prices and quotes

Prices, quotes, charts, spreads, market data, order-book information, valuations, margin figures and other information displayed on the Platform may be derived from exchanges, liquidity providers, market makers, brokers, custodians, index providers, data vendors, internal systems, calculation agents or other sources.

Platform prices may differ from prices displayed by other brokers, exchanges, media sources, websites, data vendors or charting platforms. Unless otherwise stated, Orders are triggered and Transactions are valued by reference to the price or pricing basis used by the Platform for the relevant product.

5.3 Bid, ask, mid and spread

Products may be quoted with a bid price and an ask price. The bid price is generally the price at which you may sell, and the ask price is generally the price at which you may buy. The difference between the bid and ask price is the spread.

Charts, performance displays and indicative prices may show mid-price, last price, bid price, ask price or another pricing basis. You should check the order ticket and relevant product information before placing an Order.

5.4 Indicative, delayed and stale data

Market data may be real-time, delayed, indicative, derived, aggregated or subject to technical limitations. Prices may become stale or inaccurate because of latency, feed interruption, market disruption, systems failure, provider error, connectivity issues or extraordinary events.

MPW may reject, delay, re-price, correct, cancel, amend or reverse Orders, Transactions, valuations or Account entries affected by manifest error, stale price, corrupted feed, incorrect data or other pricing issue in accordance with the Terms.

5.5 No reliance on Platform information as advice

Market data, charts, tools, alerts, analytics, research, educational content, screeners, performance figures, risk indicators and other information made available through the Platform are provided for information purposes only, unless expressly identified as a personalised recommendation.

Such information does not constitute tax, legal, accounting or financial planning advice. You remain responsible for making your own trading and investment decisions, except where you have entered into a specific advisory, Copy Trading or PAMM arrangement in accordance with the Terms.

5.6 Third-party data and provider terms

Market data and other information may be supplied by third-party providers and may be subject to their terms, disclaimers, licence restrictions, exchange rules, usage limits and reporting requirements. You agree to comply with any third-party terms notified to you or made available through the Platform.

Third-party providers may require MPW to restrict access, collect information, impose usage limits, prohibit redistribution, terminate access or amend data functionality.

5.7 No redistribution or commercial use of market data

You must not copy, reproduce, redistribute, sell, licence, publish, transmit, scrape, harvest, benchmark, reverse-engineer, store for commercial use, or otherwise make market data or Platform information available to any third party without prior written consent from MPW and any relevant data provider.

Market data is made available for your personal use in connection with the Services only, unless expressly agreed otherwise.

5.8 Platform availability and maintenance

MPW will use reasonable efforts to make the Platform available, but does not guarantee uninterrupted, continuous, error-free or secure access. The Platform may be unavailable or degraded because of maintenance, updates, outages, cyber incidents, third-party provider failures, connectivity issues, market events, force majeure events, excessive demand, software defects or other operational reasons.

MPW may suspend, restrict or modify access to the Platform at any time where necessary or appropriate for maintenance, security, legal, regulatory, operational or risk-management reasons.

5.9 No guarantee of access during market events

During volatile markets, significant news events, market disruption, increased trading volumes or other exceptional conditions, the Platform may experience delays, reduced functionality, rejected Orders, delayed confirmations, pricing interruptions, login issues or other access limitations.

You remain responsible for monitoring your positions and Account. You should maintain alternative access arrangements where available and should not rely solely on one device, connection, channel or notification method.

5.10 Mobile application and device risk

Where you access the Platform through a mobile application or device, functionality may depend on device compatibility, operating system, app-store availability, network quality, mobile data service, device settings, battery life, security settings and third-party software.

You are responsible for keeping your device secure, installing updates, using appropriate security settings, and ensuring that notifications, permissions and connectivity are configured correctly. MPW is not responsible for losses arising from your device, operating system, network provider, app store or third-party software, except to the extent caused by MPW's fraud, wilful misconduct or gross negligence.

5.11 Notifications and alerts

The Platform may offer alerts, notifications, price alerts, margin alerts, risk warnings, execution confirmations or other messages. These tools are provided for convenience and may be delayed, unavailable, inaccurate or not delivered.

You should not rely on alerts or notifications as a substitute for active monitoring of your Account, Orders, positions, margin and Transactions.

5.12 Account security

You must keep your Account credentials, passwords, devices, authentication tools, access codes, API keys and security details confidential and secure. You must not share them with any other person, permit unauthorised access, or leave a logged-in session unattended.

You must notify MPW immediately if you suspect that your Account, credentials, device, authentication method or API key has been lost, stolen, compromised or used without authority.

Unless and until MPW has received notice and had a reasonable opportunity to act, Orders and instructions submitted using your credentials and authentication procedures may be treated as validly submitted by you or on your behalf.

5.13 API, automated access and bots

You must not use an API, bot, algorithm, scraper, automated trading system, copy tool, bridge, plug-in, external signal tool, latency tool or other automated access method unless MPW has expressly permitted that use and you comply with any conditions imposed.

MPW may impose rate limits, permission controls, product restrictions, monitoring, additional authentication, technical requirements or other conditions on API or automated access. It may suspend or terminate automated access where it creates legal, regulatory, operational, market-conduct, system, security or risk-management concerns.

5.14 Prohibited platform conduct and abusive trading practices

5.14.1 General prohibition

You must not use the Platform, any Account or the Services to engage in, attempt, facilitate or assist any conduct that is unlawful, abusive, manipulative or improper, or that is intended or likely to obtain an unfair advantage from the operation of the Platform, its pricing or its execution arrangements. This applies whether you act alone or with any other person, and whether the conduct is manual or automated.

In this Clause 5.14, an “Associated Account” means any other Account that MPW reasonably considers to be held, controlled, operated or beneficially owned by you, or operated in concert with you, whether in your name or in the name of any other person.

5.14.2 Market abuse

You must not engage in any conduct that constitutes or may constitute market abuse under the Securities Act 2005 or any other Applicable Law. This includes:

a) insider dealing, or trading on or disclosing inside or confidential information;

b) market manipulation, including creating a false or misleading impression of the supply of, demand for or price of any financial instrument;

c) spoofing, layering, or placing Orders with no intention of execution;

d) wash trading, matched trading or pre-arranged trading;

e) quote stuffing or any activity intended to overload, delay or disrupt the Platform, an execution venue or a liquidity provider; and

f) disseminating false or misleading information in connection with any financial instrument.

5.14.3 Abusive and toxic trading practices

You must not engage in any trading strategy or pattern of activity that exploits technical, pricing, latency or operational features of the Platform or its execution arrangements rather than genuine market movements. This includes:

a) latency arbitrage: trading on delays, lags or differences between Platform prices and prices on other sources, venues or providers;

b) price-feed exploitation: trading on stale, frozen, delayed, erroneous, off-market or corrupted prices, or on any Manifest Error;

c) abusive scalping: opening and closing positions within very short periods in a manner which, in MPW’s reasonable assessment, is designed to exploit pricing or execution latency rather than to take genuine market risk;

d) abusive news trading: placing, modifying or timing Orders immediately before, during or after the release of economic data, central bank announcements, corporate announcements or other market-moving events, in a manner designed to exploit pricing delays, gaps, widened spreads, temporary liquidity conditions or execution latency;

e) news straddling: placing opposing pending Orders around a scheduled event so as to profit from slippage, gapping or delayed execution irrespective of market direction;

f) cross-account and cross-broker hedging: holding opposing or offsetting positions across your Account, any Associated Account, or any account held with another broker, in order to exploit Negative Balance Protection, stop-out mechanics, swap or financing differentials, or differences in pricing or execution;

g) multiple-account abuse: opening or operating more than one Account, or using any Associated Account, to circumvent limits, restrictions, eligibility criteria or risk controls, or to replicate prohibited strategies;

h) coordinated trading: acting with any other person, whether or not a Client, to carry out any of the practices described in this Clause 5.14, including through shared devices, IP addresses, strategies, signals or funding sources;

i) rollover exploitation: opening and closing positions around the daily rollover, or holding offsetting positions, so as to capture swap, rollover or financing adjustments without taking genuine market exposure;

j) circumvention of product restrictions: using any method to access instruments, leverage levels, Order types or functionality that is not available to your Account or client classification; and

k) automated abuse: using any expert advisor, algorithm, bot, bridge, copy tool, signal tool or other automated means to carry out any of the above, whether or not the automated access has otherwise been permitted under Clause 5.13.

5.14.4 Venue and liquidity provider restrictions

MPW transmits Orders to external execution venues and liquidity providers, which may impose restrictions, rejections, re-quotes, cancellations, trade adjustments or other measures for activity they regard as abusive or toxic, including activity around news releases. Where an execution venue or liquidity provider applies such a measure to a Transaction executed for your Account, MPW may apply a corresponding measure to that Transaction and your Account.

MPW may also apply temporary restrictions around scheduled market events, including:

a) restricting the opening of new positions;

b) restricting the placing, modification or cancellation of pending Orders;

c) increasing margin requirements; and

d) widening minimum stop distances.

MPW will give notice of such restrictions through the Platform where reasonably practicable.

5.14.5 Legitimate trading

Nothing in this Clause 5.14 restricts trading based on genuine analysis or market views, including trading during periods of volatility or around market events, where the trading does not involve any practice described in Clauses 5.14.2 or 5.14.3. Short holding periods, high trading frequency or trading around news releases are not, by themselves, a breach of this Clause. MPW will assess your activity as a whole, having regard to its pattern, frequency, timing, profitability profile and execution characteristics.

5.14.6 Monitoring and assessment

MPW monitors trading activity to detect prohibited conduct. In doing so, MPW may rely on:

a) system logs, execution data, device and IP information, and session data;

b) information received from execution venues and liquidity providers; and

c) any other information available to it.

MPW will assess suspected prohibited conduct reasonably, in good faith and proportionately.

5.14.7 Remedies

Where MPW reasonably determines that you have engaged in, or are engaging in, any conduct prohibited by this Clause 5.14, MPW may take any one or more of the following actions, with or without prior notice:

a) reject, cancel or decline to transmit any Order;

b) cancel, void, reverse or amend any affected Transaction, or re-price it at the fair market price prevailing at the relevant time;

c) adjust the realised or unrealised profit and loss, swaps, financing charges or other entries on your Account attributable to the prohibited conduct;

d) withhold or reverse any profits attributable to the prohibited conduct, including profits already credited to your Account, and recover any such amounts already withdrawn as a debt owed by you to MPW;

e) close any or all open positions;

f) restrict your Account, including by reducing leverage, increasing margin requirements, applying minimum holding periods, widening spreads, limiting instruments or Order types, disabling automated or API access, or restricting withdrawals of the affected amounts pending review;

g) disapply Negative Balance Protection to any negative balance arising from the prohibited conduct, in accordance with the Leverage, Margin and Negative Balance Protection Policy;

h) apply any of the above measures to any Associated Account;

i) suspend or terminate your Account and the Services in accordance with the Terms; and

j) report the conduct to the Financial Services Commission or any other competent authority, and cooperate with any related inquiry or investigation, as required or permitted by Applicable Law.

5.14.8 Notice and representations

Where MPW takes action under Clause 5.14.7, it will inform you of the action taken as soon as reasonably practicable, unless prohibited by Applicable Law. You may submit representations or evidence within such reasonable period as MPW specifies. MPW will consider any representations made in good faith, and may maintain, vary or reverse its action accordingly.

5.14.9 Copy Trading and PAMM

a) Application. This Clause 5.14.9 applies where MPW takes action under Clause 5.14.7 in respect of conduct by a Lead Trader or PAMM Manager, including conduct carried out through a Copy Trading Strategy or a PAMM Account.

b) No retention of tainted profits. No Follower or Participant is entitled to retain profits that derive from conduct prohibited by this Clause 5.14, whether or not that Follower or Participant was involved in the conduct. MPW may cancel, reverse, re-price or adjust any Transaction copied into a Follower’s Account, or allocated to a Participant’s PAMM Sub-Account, that derives from a Transaction affected by action under Clause 5.14.7. MPW may do so on the same basis, and to the same extent, as it applies to the Lead Trader’s or PAMM Manager’s Transaction. Where MPW cancels or reverses a corresponding Transaction, it will treat the Transaction as not having been executed, and will reverse any resulting profit or loss together with the related costs and charges.

c) Involvement. MPW may treat a Follower or Participant as involved in the prohibited conduct and may apply any of the measures in Clause 5.14.7 to them, where MPW reasonably considers that they participated in, facilitated, coordinated or had knowledge of that conduct. In assessing this, MPW may take into account any relevant factor, including:

i) any connection with the Lead Trader or PAMM Manager, including through an Associated Account, shared devices, IP addresses, funding sources or communications;

ii) the timing of the Follower’s or Participant’s allocation, subscription, increase or withdrawal relative to the prohibited conduct;

iii) allocation sizes, copy ratios or risk settings that are disproportionate to the Follower’s or Participant’s usual activity or profile; and

iv) any manual intervention in, or replication of, the affected Transactions.

(d) Followers and Participants not involved. Where MPW is satisfied that a Follower or Participant was not involved in the prohibited conduct, it will not apply the measures in Clause 5.14.7(f) to (j) to them solely because of the conduct of the Lead Trader or PAMM Manager. This does not affect any action under paragraph (b).

e) Interim measures. Pending its review, MPW may:

(i) suspend copying of the affected Copy Trading Strategy, or new subscriptions to and redemptions from the affected PAMM Account; (ii) restrict the withdrawal of any amount attributable to the affected Transactions; and iii) apply any other measure reasonably necessary to preserve the position.

f) Fees and High Water Mark. If profits are cancelled, reversed or adjusted under this Clause 5.14.9, MPW will recalculate any performance fee, profit share or other remuneration charged on them. MPW will refund or credit any amount overcharged to Followers or Participants and will adjust the relevant High Water Mark accordingly. MPW may recover any such fee or remuneration from the Lead Trader or PAMM Manager.

g) Notice. MPW will notify affected Followers and Participants of any action taken under this Clause 5.14.9 as soon as reasonably practicable, unless Applicable Law prohibits this. Clause 5.14.8 applies to them.

5.14.10 No limitation

The rights in this Clause 5.14 are in addition to, and without prejudice to, any other right or remedy available to MPW under the Terms or Applicable Law, including Clause 5.5 (Errors, Mistakes, and Manifest Error). Any loss, cost or expense incurred by MPW as a result of your prohibited conduct may be recovered from you. This includes any amount refunded or credited to Followers or Participants under Clause 5.14.9(f).

5.15 System logs and electronic records

MPW may maintain logs and records relating to access, authentication, Orders, Transactions, communications, device information, IP addresses, session activity, API calls, Platform events and other relevant data. These records may be used for operational, compliance, security, dispute-resolution, audit, regulatory and evidentiary purposes.

Where there is a discrepancy between your own records and MPW's electronic records, MPW's records may be treated as authoritative unless there is clear evidence of error, fraud, wilful misconduct, gross negligence or any matter that cannot be excluded under Applicable Law.

5.16 Tools, calculators and simulated outputs

Calculators, margin tools, risk tools, performance projections, scenario analyses, back-tests, simulations, charts and similar tools are illustrative only. They may rely on assumptions, simplified models, delayed data, incomplete data or estimated inputs.

Actual trading results, margin requirements, costs, fees, taxes, execution prices, slippage, liquidity and market outcomes may differ materially from any output shown by such tools.

5.17 Demo accounts and simulated trading

Where MPW offers demo accounts, paper trading, trial access or simulation environments, those environments are provided for familiarisation and educational purposes only. Simulated prices, liquidity, execution, margin, slippage, latency, costs and performance may differ from live trading conditions.

A positive result in a demo or simulation environment is not a reliable indicator of future performance in a live Account. MPW may suspend, reset, restrict or terminate demo access at any time.

5.18 Third-party links and integrations

The Platform may contain links, integrations or connectivity with third-party websites, payment providers, identity-verification providers, market data providers, analytics providers, communication tools or other services. MPW is not responsible for third-party content, availability, performance, security or terms, except to the extent required by Applicable Law.