Mudraone is the trading platform operated by WebTrade Management Ltd (the “Company”), which is authorized, licensed, and regulated by the Union of Comoros Offshore Finance Authority (“Comoros”) as an International Brokerage and Clearing House under License Number BFX2024178. Hereinafter, the “Company” provides financial services, as defined in this agreement, to you, the client (also referred to as the “customer,” “client,” or “you”), through its online trading platforms.

This Agreement is established between the Company and the Client (whether a legal entity or a natural person) who has completed the account opening process and has been accepted as a Client.

The Company reserves the right to update or modify this Agreement at any time and will notify you of any changes via email or through its website. By continuing to use the Company’s services, you agree to be bound by the updated Terms. The Company is not obligated to notify you of every amendment, and it is your responsibility to periodically review these Terms. Continued use of the Company’s services after any updates are posted signifies your acceptance of the changes. Any modifications will not apply to past transactions unless explicitly stated otherwise. If you do not agree with any updates, you may terminate the Agreement in accordance with the Termination clause.

COMMUNICATION WITH US

You may contact us using the details provided in the “Contact Us” section of our website.

All communications shall be in English, and you will receive documents and information in English. However, where possible, we may provide translations for your convenience. By agreeing to these Terms and Conditions, you acknowledge and accept the following:

The Company may use any ideas, concepts, know-how, or information contained in your communications for purposes including, but not limited to, product development and marketing. The Company also monitors communications to ensure service quality, compliance with this Agreement, website security, and other relevant reasons. You agree that such monitoring does not grant you any claim or right against the Company regarding how your communications are monitored.

MEMBERSHIP ELIGIBILITY

Our services are available only to individuals or legal entities that are legally able to enter into a binding contract under the laws of their country of residence.

Our services are strictly prohibited for individuals under 18 years of age (or the legal age in their jurisdiction). The Company disclaims any liability for unauthorized use of its services by minors.

Additionally, our services are not available in jurisdictions where their use is illegal. The Company reserves the right to refuse or revoke access to its services at its sole discretion.

Access to our website does not guarantee that our services, or any activities conducted through it, comply with the laws, regulations, or directives of your country of residence. It is your responsibility to ensure compliance with applicable laws before using our services.

 

DEFINITIONS AND INTERPRETATION

• Account – The personal trading account maintained by the Client with the Company, identified by a unique account number.
• Account Opening Application – The application form or questionnaire completed by the Client to apply for the Company’s services and a Client Account. This form is used by the Company to collect information for client identification, due diligence, categorization, and assessment of suitability in accordance with applicable laws and regulations.
• Access Codes / Login Information – The username and password provided by the Company to the Client for accessing the Company’s website.
• Agreement / Policy – These Terms and Conditions governing the services offered by the Company.
• Applicable Regulations – The regulations set forth by the Union of Comoros Financial Sector Conduct Authority and any other relevant laws.
• Balance – The total sum held in the Client’s Account at any given time.
• Business Day – Any day that is not a Saturday, Sunday, or public holiday in the Union of Comoros, or any additional holidays as announced by the Company on its website.
• Company’s Website – The official website of the Company: Mudraone.com .
• Execution – The process of executing client orders on the Company’s trading platform, where the Company acts as an agent for the Client’s transactions.
• Financial Markets – International markets where the exchange rates of financial instruments are determined through multi-party trade.
• Financial Instruments – Any financial instruments offered by the Company.
• Liquidity Provider – A third-party entity that underwrites or provides financing for transactions and facilitates market-making for specific assets.
• MTF (Multilateral Trading Facility) – A trading system that allows multiple parties to trade financial instruments.
• Operating (Trading) Time of the Company – The period during a business week when the Company’s trading terminal is available for trading operations. The Company reserves the right to modify these hours with prior notification to the Client.
• Order – A request or instruction from the Client to the Company to open or close a trading position in the Client’s Account.
• Services – The investment and ancillary services provided by the Company, as outlined in Section 5 of this Agreement.
• Traditional CFD Trading System – A more complex trading system that allows Clients to set stop-loss and take-profit levels.
• Transaction – Any action performed within the Client’s trading account, including deposits, withdrawals, open trades, closed trades, and any other financial instrument transactions.

In this Agreement, singular terms also include their plural forms, and vice versa. References to individuals also include legal entities, and vice versa. Gender-specific terms apply to all genders. References to “Paragraphs,” “Sections,” and “Appendices” pertain to their respective sections within this Agreement. Headings are used for reference purposes only and do not affect interpretation. Any mention of laws or regulations includes all amendments, replacements, extensions, or re-enactments of those laws or regulations.

 PROVISION OF SERVICES

The Company is authorized to provide the following investment services under its CIF authorization, governed by this Agreement:

• Reception and transmission of orders related to the financial instruments offered by the Company.
• Execution of orders on behalf of Clients.

Additionally, the Company provides the following ancillary services:

• Safekeeping and administration of financial instruments, including custodianship and related services.

The Company operates on an execution-only basis and does not offer advice regarding the merits of transactions or their tax implications. The Client assumes full responsibility for investment decisions, strategies, and any resulting financial consequences, including tax liabilities. The Company is not responsible for any Client decisions or reliance on the Company for investment advice.

The Company’s services allow Clients to enter into leveraged Contracts for Difference (CFDs), which provide exposure to price movements of various underlying assets, such as securities, commodities, indices, and other financial instruments, without requiring ownership of the underlying assets. CFDs are over-the-counter (OTC) derivative instruments that are not traded on any exchange and do not grant ownership rights in the underlying assets.

Each CFD is denominated in a specific Base Currency, and its profit or loss is determined by price changes in the underlying asset against the Base Currency, from the opening to the closing of the CFD.

Placing Orders

To enter a leveraged CFD transaction, the Client must place an Order through the trading platform, specifying:

• Position type – Buy (long) or Sell (short)
• Transaction size
• Leverage rate
• Rate (price)

By submitting an Order, the Client confirms they have reviewed the terms and acknowledge that Orders cannot be canceled once submitted. Upon receiving an Order, the Company provides an electronic acknowledgment, but the Order is only binding once executed and confirmed on the trading platform.

The Company provides rate quotes on a best-efforts basis. In the event of a Market Disruption Event or an Event Outside Our Control, the Company may be unable to provide a quote or execute transactions during the designated Market Hours.

Order Placement via Telephone

Orders may be placed by telephone under the following conditions:

1. Oral instructions constitute a valid Order at the quoted rate.
2. Orders placed by telephone will be executed at the current rate only.
3. Orders must be placed directly with an authorized representative of the Company. Orders left on answering machines or voicemail will not be accepted.
4. Orders are valid only upon confirmation by an authorized Company representative. Once executed, the Client’s Account will be updated accordingly.

Orders can be placed electronically on the trading platform at any time or by telephone during designated Trading Hours. Transactions will only be executed when both the Company’s Trading Hours and the relevant Market Hours overlap. Market Hours are published on the Company’s website and are subject to change.

By placing an Order, the Client acknowledges that they:

• Understand the risks associated with CFD trading, as outlined in the Company’s Risk Disclosure Policy.
• Do not gain ownership or rights to the underlying asset.
• Accept that rates are determined by the Company, which includes a margin between buy and sell rates, constituting the Company’s profit.

Order Execution and Rejection

Once an Order is placed, the Company may perform checks, including risk assessments and compliance with Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations. If the Order meets all requirements, it will be executed. Until execution, an Order remains pending and is not binding.

The Company may refuse or cancel an Order under the following circumstances:

1. Legal or regulatory requirements mandate cancellation.
2. The Order violates the Agreement or applicable laws.
3. The Order could harm the Company’s operations, reputation, or legal standing.

Additionally, the Company may take other actions as permitted by these Terms or applicable regulations.

The Liquidity Provider is the sole Execution Venue for processing Client Orders. The Company acts solely as an agent for the Client, with transactions executed through the Liquidity Provider.

ROLLOVER

We may permit an open Transaction to be rolled over in accordance with your instructions. If we agree to roll over an open Transaction, the original open Transaction will be closed and settled at the Rate applicable at the time of closure. A new Order will then be placed to establish a new open Transaction in the relevant Market. The specific times at which we close and roll over Transactions are stated in the Market Information section on our Website.

OVERNIGHT FINANCING (SWAP FEE)

When trading CFDs, your open Transactions are subject to Overnight Financing at the end of each trading day. This financing may result in either a credit or debit to your account, calculated based on the applicable interest rates for the currencies involved in the underlying instrument, plus a mark-up. The mark-up for currency pairs is detailed on the Market Information page of our Website. For exotic currency pairs, the mark-up may be higher and may vary between buy (long) and sell (short) positions.

If the calculated Overnight Financing (Swap Fee) Percentage is positive, a corresponding amount will be credited to your Account balance. If the percentage is negative, the amount will be debited. You can find the applicable Overnight Financing percentages, amounts, and their corresponding timeframes in the Order form under Tools within the Market Information tab.

To calculate the Overnight Financing charge or credit to your Account, multiply the Overnight Financing percentage by the size of your Order. The Overnight Financing process runs at specified times, which are detailed in the Order form under “Overnight Financing (GMT).” The calculated value and percentage apply for a single day. For CFDs traded five (5) days a week, the credit or debit applied on the last trading day of the week will be three times the usual rate to account for the weekend period.

MARGIN AMOUNT

Before placing an Order that creates an open Transaction, you must ensure that your Account balance is sufficient to meet the required Margin Amount. If your Account balance is below the required Margin Amount, we may (and where legally required, will) reject your Transaction.

The Margin Amount must be maintained throughout the duration of the open Transaction and may fluctuate until the Transaction is closed. The applicable Margin Amount varies depending on the Underlying Asset and your Account categorization. Details regarding the required Margin Amounts are available on our Website.

Non-standard Margin Amounts may apply in certain situations, including but not limited to:

• Transactions in Markets derived from options or options-related instruments.
• Holding positions in multiple Markets within the same Underlying Asset.
• Transactions exceeding the maximum permitted quantity.

The methodology for calculating non-standard Margin Amounts is outlined on our Website. We reserve the right to modify the calculation method at any time. Notification of changes to the Margin Amount may be provided through various channels, including mail, telephone, fax, email, text message, or a notice on our Website.

If your Total Margin falls to or below the Closing Margin Requirement, this will be classified as a Termination Event under Section [X]. In such cases, we may (and where required by law, will) close some or all of your open Transactions immediately, with or without notice. Additionally, we may decline to execute new Transactions until your Total Margin exceeds the Closing Margin Requirement. It is your responsibility to monitor your Account and ensure your Total Margin remains above the Closing Margin Requirement. If we close your open Transactions, they will be settled at the prevailing Rate at the time of closure.

While we may attempt to notify you before taking such action, we are not obligated to do so. Details regarding the Closing Margin Requirement applicable to your Account are available on our Website and are subject to change as necessary to comply with applicable laws and regulations. In certain circumstances (e.g., suspended markets), we may be unable to close out open Transactions immediately, and we do not guarantee that your losses will be limited to the funds available in your Account. In such instances, we will monitor the situation and take appropriate actions as needed.

ACCOUNT OPENING INFORMATION AND REQUIREMENTS

Upon registering an account with WebTrade Management Ltd, your trading platform will be set to the System by default. However, you have the option to switch to the Traditional CFD Trading System at your discretion.

The account registration process on the WebTrade Management Ltd platform is straightforward. To create a new trading account, follow these steps:

1. Visit the platform’s homepage and click on the “Sign Up” button.
2. Complete the registration form by providing all required information accurately.
3. Once all necessary details are submitted, your account will be created.

As part of the account opening procedure, the Company will request specific identifying information and documentation to verify your identity. This verification process adheres to strict compliance measures designed to prevent international money laundering activities and ensure the security of all customers’ trading activities. This process is also governed by the Company’s Privacy Policy.

If you are registering as a legal entity, you confirm that you have the authority to bind the entity to this Agreement. The Company will handle your information with care and in accordance with its Privacy Policy and any disclosures provided during the registration process.

By registering with the Company, you consent to the use of your provided information for the management of your trading account, transaction execution, and regulatory compliance. All interactions with the Company will be recorded for legal and compliance purposes. These records may be used in the event of disputes between you and the Company or if requested by regulatory authorities.

 

 

KNOW YOUR CUSTOMER – KYC

Know Your Customer (KYC) policies have become increasingly important worldwide, particularly among financial institutions, to prevent identity theft, money laundering, fraud, and terrorist financing.

To combat fraudulent activities, the Company may request sensitive personal information during the account verification process. We maintain a strict zero-tolerance policy on fraud, and any fraudulent activity will result in immediate account closure and the forfeiture of all associated funds. Upon confirmation of fraudulent activity, the original deposit amount will be refunded after adjusting for any losses or profits, and the account will be permanently closed.

The Company prioritizes the security of your personal and financial data by implementing robust fraud controls and security measures. To ensure the security of electronic transactions, we require certain information, including your preferred deposit method.

To access our Services and initiate Transactions, you must register an Account on our Website and complete the KYC process. This includes providing personal details such as your name, identification number, birthdate, email address, postal address, and telephone number (“Registration Details”). Your Log-In credentials will grant you access to your Account, Registration Details, and transaction history once your account is verified and approved.

As part of the verification process, we may require documents such as:

• A recent utility bill in your name and address (e.g., water, electricity, gas, or telephone) as proof of address.
• A valid government-issued identity document, which must be valid for at least six months from the submission date.

The Company reserves the right to reject any documents at its discretion. In addition to document submission, identity verification may involve a video or audio call. We may also request additional KYC information at any time during our business relationship, and your access to Services may be restricted until the required documentation is provided to our satisfaction.

Alongside the KYC process, we have implemented an Anti-Money Laundering (AML) policy to prevent criminals from using our platform for illicit activities. Money laundering involves disguising the origins of illicit funds to make them appear legitimate. Our AML policy outlines procedures designed to identify and mitigate financial crime risks, including money laundering and terrorist financing. The policy is available on our Website.

To conduct identity verification and background checks in line with KYC and AML requirements, the Company may engage third-party service providers. By using our Services, you consent to the transfer of your information for legitimate business purposes, including compliance with regulatory obligations. We will retain relevant KYC/AML information as required by law.

The Company reserves the right to take necessary actions based on the results of our KYC/AML checks. If you fail to pass these reviews, your access to our Services may be restricted or denied, and we may report any relevant findings to the appropriate authorities. The Company has sole discretion in determining the outcome of KYC/AML reviews and is under no obligation to disclose specific findings.

You confirm that all Registration Details provided are accurate and complete, and you agree to update them promptly if they change. If you have any questions, please contact our customer support team.

WHEN DO I NEED TO PROVIDE THESE DOCUMENTS?

To avoid delays in processing your transactions, we require all necessary documents before executing any transactions on your behalf.

How can I submit these documents?

You may scan or take a high-quality digital photo of your documents and send them via email to [email protected]  or upload them through your WebTrade Management Ltd trading platform. Additionally, our third-party verification software may prompt you to upload any outstanding verification documents.

HOW DO I KNOW MY DOCUMENTS ARE SAFE WITH YOU?

The Company places the highest priority on document security and treats all received documents with strict confidentiality. All files are fully encrypted at every stage of the verification process. For further details, please refer to our Privacy Policy.

ADVICE AND COMMENTARY

The Company does not provide investment advice, nor does it offer recommendations regarding specific orders. Clients are responsible for managing their accounts, placing orders, and making investment decisions based on their own judgment.

We do not offer legal, tax, financial, or other advisory services related to Transactions. Clients are encouraged to seek independent advice before entering into any Transactions.

Occasionally, the Company may provide general market information, news, or commentary through newsletters, its Website, or other channels. However:

• The Company assumes no responsibility for the accuracy, completeness, or reliability of such information.
• We do not guarantee the correctness or relevance of this information for any particular investment decision.
• Such content is for informational purposes only and does not constitute investment advice or a financial promotion.

The Company does not conduct investment research. Any materials containing market analysis are classified as marketing communications and should not be interpreted as advice, recommendations, or research. Clients must independently evaluate all transactions and should not rely on Company communications as investment advice. If uncertain, clients should seek independent professional guidance before proceeding with any transactions.

CLIENT GUARANTEES

• You confirm and guarantee that any funds provided to the Company for trading purposes are solely your own and are free from any liens, charges, pledges, or other encumbrances. Additionally, these funds are not derived, directly or indirectly, from any illegal activity or criminal enterprise.
• You act on your own behalf and not as a representative or trustee for any third party, unless you have presented valid documentation and/or power of attorney, satisfactory to the Company, authorizing you to act in such a capacity.
• If the Company has sufficient reason to believe that any received funds originate from unlawful activities or belong to a third party, it reserves the right to return these funds to the sender, whether that be you or a beneficial owner of a legal entity.
• The Company may reverse any transactions in your Trading Account and has the right to terminate this agreement if such circumstances arise.
• The Company reserves the right to take legal action against you to recover damages caused by any such event and may seek full indemnification.
• You declare that you are at least 18 years old (if a natural person) or have full legal capacity (if a legal entity) to enter into this agreement.
• You acknowledge that all trading activities must be conducted exclusively through the Trading Platforms provided by the Company, and that Financial Instruments are not transferable to any other platform.
• You guarantee the authenticity and validity of all documents submitted to the Company.
• You acknowledge that the Company does not provide legal advice regarding the use of its Services and makes no representations regarding their legality in your jurisdiction.
• You are solely responsible for maintaining the confidentiality of your Log-In credentials, Account details, and Registration Information.
• You are responsible for the security of your Account and data on your personal devices and internet access points.
• If your Log-In credentials are compromised due to malware or hacking, the Company assumes no liability. You must report any suspected security breaches to the Company immediately.
• Any unauthorized access to your Account may expose your confidential information and funds to third parties. If you suspect any unauthorized access, you must notify the Company immediately.
• You warrant that your use of the Website and Services complies with all applicable laws and regulations. Any engagement in fraudulent activities, money laundering, illegal gambling, terrorism financing, or malicious hacking is strictly prohibited.
• You agree not to conceal or alter your IP location and to always provide accurate and truthful location details.

 PROHIBITED ACTIONS

By accessing the Platform, you agree not to engage in any abusive or manipulative trading practices, including but not limited to:

• Manipulating the Company’s quoted prices.
• Exploiting server latency, lag trading, or price manipulation.
• Interfering with the Company’s execution policy or Trading Platform(s).
• Trading based on privileged or insider information.
• Placing orders based on system errors or malfunctions.
• Engaging in coordinated transactions to exploit system errors or update delays.
• Arbitrage trading, including Swap Arbitrage, Latency Arbitrage, and Bonus Arbitrage.
• Using scalping techniques or engaging in short-term trading patterns deemed unusual by the Company.
• Allowing unauthorized third parties to trade on your account.

If any of these activities are detected in your trading account, the Company reserves the right to:

• Cancel your trading orders.
• Reclaim any trading profits obtained through abusive methods.
• Immediately terminate your account as per the Company’s Terms and Conditions.

 RESTRICTED JURISDICTIONS

You are prohibited from accessing or using the Services if you are located in, incorporated in, or a citizen or resident of:

• Cambodia, Canada, Cuba, Ghana, Iran, Israel, Mongolia, Nigeria, North Korea, Panama, Pakistan, Philippines, Syria, Yemen, the United States, or any jurisdiction where our services are unauthorized or in conflict with applicable laws.
• Any jurisdiction embargoed by the United States of America.
• Any jurisdiction where your access to the Services would be illegal under local laws or would subject the Company to additional regulatory requirements.

The Company may take measures to restrict access from these jurisdictions. If it is determined that you are accessing the Services from a restricted location or have misrepresented your residency, the Company reserves the right to close your account immediately and liquidate any open positions.

COMPANY LIABILITY AND INDEMNITY

The Company and its related entities conduct transactions in good faith and with due diligence but shall not be held liable for any omission, fraud, or deliberate misconduct by any person, firm, or company from whom it receives instructions for executing orders or carrying out transactions on your behalf. This includes cases of negligence, fraud, or deliberate omissions on the part of the Company.

The Company is not responsible for any lost opportunities that may result in financial losses or changes in the value of your financial instruments.

If the Company incurs any claims, losses, damages, liabilities, or expenses arising from the provision of its services, you are fully responsible for covering such costs and must indemnify the Company accordingly. The Company is also not liable for damages resulting from negligence, omissions, or fraud by the bank holding its accounts.

Furthermore, the Company shall not be liable for the loss of financial instruments or funds held by third parties, such as banks, or for any actions taken based on inaccurate information before receiving updates from you. While the Company ensures that institutions handling your funds are reputable, it is not liable for losses caused by their financial deterioration, liquidation, or other failures.

Without limiting any other terms in this Agreement, the Company is not responsible for:

• System errors (from the Company or service providers)
• Delays
• Viruses
• Unauthorized use
• Actions taken by a market, clearinghouse, or regulatory body

For technical risks, please refer to the Risk Disclosure statement.

The Company is not liable for any partial or non-performance of obligations due to factors beyond its control, including communication failures, industrial actions, terrorism, natural disasters, regulatory changes, or failures by third-party brokers, custodians, markets, or regulatory entities.

You acknowledge responsibility for monitoring CFD expiration dates listed on the Company’s official website.

Neither the Company nor its directors, officers, employees, or agents are liable for any losses, damages, costs, or expenses arising from negligence, contract breaches, or misrepresentations. The Company shall not be held accountable for indirect, special, or consequential damages, including loss of profits, goodwill, or business opportunities.

You must cover any debit balances on your accounts and indemnify the Company for losses, liabilities, costs, or expenses, including legal fees, resulting from transactions, regulatory compliance, or any misrepresentations by you.

You agree to defend, indemnify, and hold harmless the Company and its representatives from any claims, liabilities, or damages arising from:

1. Your breach of the Terms.
2. Your use of the Website or Services, including unauthorized use.
3. Any violation of applicable laws or third-party rights.

You acknowledge that you have entered this Agreement based solely on its terms and not on any external representations. The Company bears no liability for any representations not explicitly stated in this Agreement.

WITHDRAWAL AND DEPOSIT POLICY

How to Withdraw Funds To avoid delays, ensure your documentation is correct, up to date, and verified before submitting a withdrawal request. A new payment method must be verified before the first withdrawal, but once verified, future withdrawals using the same method do not require additional verification.

For credit card withdrawals, front and back copies of each used card must be submitted. If a card expires, updated copies of the new card must also be provided.

Verification Stages

1. Proof of ID – Submit a government-issued identification document (passport, driver’s license, etc.).
2. Proof of Residence – Provide a recent utility bill or bank statement (dated within the last six months) confirming residency in an accepted country.
3. Appropriateness Assessment – Ensure that all questionnaire responses are accurate and up to date.
4. Payment Method Verification – If using a credit card, submit an image showing the last four digits, name, and expiration date. For wire transfers, submit a bank receipt of the transfer.
5. Withdrawal Request – Log into your account, navigate to the withdrawal section, enter the requested amount, and submit the request.

Withdrawals are processed within 3-7 working days.

AVAILABLE WITHDRAWAL METHODS

Withdrawals can be processed via credit card or wire transfer. For security reasons, any new payment method must be verified before use. Withdrawals will only be processed once all required documents are received. Initially, refunds are processed back to the original deposit source before an alternative payment method can be used.

CURRENCY FOR WITHDRAWALS

 Funds are transferred in the account’s registered currency to the provided bank account, which must be under the client’s name. If the receiving bank account operates in a different currency, any conversion fees applied by the banks will not be covered by the Company.

DELAYS OR SUSPENSIONS IN WITHDRAWALS

The Company reserves the right to delay withdrawals if illegal activity or trading system abuse is suspected. Due to legal constraints, the Company cannot disclose details of ongoing investigations or enforcement actions without proper authorization.

PROCESSING TIME FOR WITHDRAWALS

The Company aims to process withdrawal requests as quickly as possible, completing transactions within 3-5 business days from approval. To avoid delays, ensure that all verification documents are up to date. External factors such as credit card refund processing times or intermediary bank delays may extend processing time.

HOW CAN I MAKE A DEPOSIT?

The Company accepts deposits through bank accounts and other linked payment methods, such as credit cards, provided they are in the name of the customer with whom the Company has established a business relationship. Regardless of the currency used for the deposit, all funds allocated to your trading account will be converted to the base currency in which your account is registered.

DO YOU ACCEPT ANONYMOUS OR THIRD-PARTY DEPOSITS?

Third-party deposits are accepted only when a Third-Party Form has been completed and all relevant Know Your Customer (KYC) documentation has been provided for both the third party and the account holder.

HOW LONG DOES IT TAKE FOR A DEPOSIT TO BE PROCESSED?

Deposits are credited to the client’s trading account within one (1) business day from the time the funds are received in the Company’s bank account. If funds do not appear in our accounts, the Back Office department will assist the client in tracking the transaction with their bank.

WIRE TRANSFERS

 If the Company makes an error during the transfer of funds, the client will be reimbursed. However, if the client provides incorrect transfer instructions, the Company may not be able to correct the mistake, and the client may be responsible for any resulting loss. Additional charges from intermediary banks may apply to wire transfers, and these charges are not covered by the Company. The Company reserves the right to request documentation verifying the source of deposited funds and may reject deposits if it is not satisfied with their legitimacy. The Company also reserves the right to refuse a withdrawal request via a specific transfer method and may suggest an alternative. If the Company receives a chargeback from a credit card issuer or any other payment method, it may seek reimbursement by debiting the client’s trading account, deducting amounts from future payments, charging the client’s credit card, or using other legal means. Any bank charges incurred will be deducted from the client’s trading account.

ORDER EXECUTION POLICY

This Order Execution Policy (the “Policy”) is available upon request to both retail and professional clients and is published on our website. It provides clients with information to help them make informed decisions about using the Company’s services.

FINANCIAL INSTRUMENTS

The Company executes orders related to one or more financial instruments as defined in these Terms.

ORDER EXECUTION POLICY

The Company adheres to the following principles when executing client orders:

• Orders executed on behalf of clients are promptly and accurately recorded and allocated.
• Comparable client orders are carried out sequentially and promptly unless market conditions or client interests dictate otherwise.
• Clients are informed of any material difficulty in executing their orders as soon as possible.

The Dealing Risk Department oversees order execution and ensures compliance with this policy, striving to execute orders on terms most favorable to clients while considering their trading strategies and needs.

POLICY REVIEW

Senior Management reviews the Order Execution Policy annually or whenever a significant change affects the Company’s ability to provide the best execution of client orders through its trading platform. The Company reserves the right to amend the policy at any time and will inform clients and relevant regulatory authorities of any material changes.

EXECUTION FACTORS

When executing client orders, the Company considers the following factors to achieve the best possible results:

• Price
• Costs
• Order size
• Execution speed
• Market conditions
• Likelihood of execution and settlement
• Any other relevant considerations

BEST EXECUTION CRITERIA

 The importance of execution factors is determined based on:

• The client’s classification (retail or professional)
• The nature of the client’s order
• The characteristics of the financial instruments involved
• The execution venues available

While price and cost are generally the primary considerations, other factors may take precedence if they result in the best possible outcome for the client.

EXECUTION VENUES

Execution venues refer to the entities where orders are placed or transmitted for execution. Client orders are executed through a third-party liquidity provider. The Company safeguards client funds while facilitating trading through its platform by transmitting orders to market makers per individual or accumulated client requests.

PRICING EXECUTION FACTORS

The Company obtains financial instrument prices from third-party external providers, ensuring they reflect underlying market values. To provide clients with competitive pricing, the Company compares multiple data sources and reviews its pricing providers at least annually. Prices displayed on the trading platform are continuously updated, but under certain conditions, the Company may not be able to execute an order at the requested price and reserves the right to execute it at the next available price.

COSTS

 When opening a position in certain financial instruments, clients may be charged a commission or financing fee. Commissions may be a percentage of the total trade value or a fixed amount.

ORDER SIZE

All orders are placed in monetary value. A client can place an order as long as there are sufficient available funds in their trading account. If a client wishes to execute a large order, the price may, in some cases, be less favorable due to variations in pricing from the Company’s liquidity provider. The minimum order size may vary depending on the type of client account.

EXECUTION SPEED

Prices fluctuate over time, and the frequency of these changes depends on the financial instrument and market conditions. The technology used by the client to connect to the Company’s trading platform significantly impacts execution speed. Unstable internet connections, such as wireless or dial-up connections, may result in delays, order rejection, or minor price deviations from the market price displayed on the platform. The Company strives to provide high-speed execution within the limits of available technology and communication infrastructure.

NATURE OF ORDERS

The characteristics of an order depend on the selected financial instrument. The instrument’s value is primarily influenced by the volatility of the underlying asset and the client’s chosen risk management strategy.

MARKET CONDITIONS AND VARIATIONS

The Company’s quoted prices, sourced from independent price providers, are influenced by various factors, including those affecting the price of underlying instruments. The Company takes reasonable measures to ensure clients receive the best possible results under prevailing market conditions.

LIKELIHOOD OF EXECUTION

The Company is not an execution venue for CFD client orders. Instead, client orders are transmitted to third-party liquidity providers for execution. The execution of orders depends on the pricing and liquidity provided by these third parties. While the Company executes all client orders, it reserves the right to decline an order or offer an alternative price.

LIKELIHOOD OF SETTLEMENT

The Company ensures the settlement of all transactions upon execution or expiration of a specific transaction.

ORDER AGGREGATION AND ALLOCATION

The Company may aggregate client orders under the following conditions:

• Aggregation does not disadvantage any client involved.
• Clients are informed that aggregation may, in certain instances, be disadvantageous.
• A fair allocation policy is in place to distribute orders equitably based on volume, price, and partial executions.

ORDER MANAGEMENT

The Company ensures that client orders are handled fairly and to their best advantage. Orders are executed promptly and equitably, considering their nature and prevailing market conditions. The Company follows these principles:

• Orders are executed fairly and sequentially.
• Similar orders may be aggregated for the client’s benefit.
• Allocation or reallocation is conducted equitably to prevent client disadvantage.

PARTIAL EXECUTION

In cases of partial execution of an aggregated order, the Company may allocate the execution proportionally among clients. If the Company’s participation was necessary for execution, it will reasonably demonstrate that execution could not have been achieved without its involvement.

MONITORING

The Company regularly assesses transactions to ensure compliance with its execution policy and to confirm that clients receive the best possible execution results.

CONCLUSION

Clients receive appropriate information regarding the execution policy, and their consent is obtained before implementing the documented policy. Clients are also warned that specific instructions may prevent the Company from achieving the best possible execution results. The policy is periodically reviewed, and any material changes are communicated to clients.

EXECUTION REFUSAL AND CANCELLATION

The Company reserves the right to refuse order execution at any time, without prior notice or explanation, including in the following cases:

• Failure to provide required identification or documentation.
• Submission of false or fraudulent documents.
• Insufficient funds in the trading account.
• Lost or stolen payment method used for deposit.
• Risk of chargeback.
• Suspicion of market manipulation, insider trading, money laundering, or any activity affecting the integrity of the trading platform.
• Insufficient funds to cover the order and associated fees.
• Orders placed using insider information.

If the Company refuses to execute an order, this does not affect any obligations the client has toward the Company or any rights the Company has regarding the client’s assets. Clients agree not to submit orders that may lead the Company to act contrary to its policies.

CANCELLATION OF TRANSACTIONS

The Company reserves the right to cancel any transaction if there are sufficient reasons or evidence to believe that:

• The transaction resulted from fraud or illegal activities.
• Orders were placed based on incorrect pricing due to system errors or malfunctions, whether on the Company’s system or that of third-party service providers.
• The Company did not execute the transaction according to your instructions.
• The transaction violates the terms of this Agreement.

USE OF THIRD-PARTY SOFTWARE

 The use of robots or any automated trading software from third parties is strictly prohibited. The Company will cancel or reject any orders submitted using such software. Accounts found in violation of this policy will be terminated under Section 18, in favor of the Company.

SETTLEMENT OF TRANSACTIONS

 The Company will settle all transactions upon execution. A financial contract is considered complete once it has been customized, the premium or margin has been calculated, and payment has been verified. You are fully responsible for the settlement of all transactions conducted under your account with the Company.

 CLIENT FUNDS

Your trading funds will be held in a segregated bank account with a bank or financial institution specified by the Company. By accepting this Agreement, you authorize the Company to make deposits and withdrawals on your behalf, including transactions for settlement and amounts payable to the Company or other entities.

Any amount due to you will be paid directly into a bank account where you are the beneficial owner. Fund transfer requests are processed within the timeframe specified on the Company’s website. The crediting time depends on your bank provider. The Company reserves the right to offset any amounts in your account against obligations owed to the Company without prior authorization.

You may withdraw funds that are not used for margin coverage without closing your account. However, withdrawal requests may be declined if they do not meet the Agreement’s conditions, or processing may be delayed due to incomplete documentation. Any bank fees associated with fund withdrawals will be your responsibility. The Company is not liable for any incorrect payment details you provide.

Deposited funds will be credited to your trading account at the value date received, net of bank or intermediary fees. The Company must verify the sender’s identity before accepting deposits. If verification fails, the Company may refund the net deposit amount using the original payment method.

The Company reserves the right to reject specific withdrawal methods and suggest alternatives requiring a new request. If documentation is insufficient, the withdrawal may be reversed, and funds returned to your trading account. Withdrawals typically take 3 to 7 business days to process, with an additional 3 days for funds to reflect in your account. If a bank reverses a deposit for any reason, the Company may reverse the transaction, even if it results in a negative account balance. You waive any rights to interest earned on funds held in the Company’s bank accounts.

CHARGEBACKS, EXCESS PAYMENTS, SET-OFF, BINDING CALCULATIONS

You agree not to initiate chargebacks, payment reversals, or disputes. If you do, you must reimburse the Company for losses, including dispute costs. If you attempt a chargeback or reversal, the Company may terminate services, withhold payments, and take further action as needed.

If the Company mistakenly transfers excess funds to you, you must return the excess amount, or the Company may deduct it from any balance owed to you.

SET-OFF

The Company may offset any amounts owed to you against amounts you owe to the Company. All calculations performed by the Company regarding this Agreement or transactions are final and binding.

 COMPLAINTS PROCEDURE FOR CLIENTS

The Company has adopted this Complaints Procedure to ensure fair and timely resolution of issues.

• Submitting your complaint Complaints should be sent via email, as indicated on the Company’s website. The email must include your name, trading account number, and complaint details. Anonymous complaints will not be processed. Once submitted, the Compliance Department will handle the complaint.
• Acknowledging your complaint The Company will acknowledge receipt within five (5) days and provide a unique reference number for your complaint.
• Handling your complaint After acknowledgment, the Company will investigate the matter and attempt to resolve it promptly. You will receive an outcome within two (2) months. The Company will update you on the progress and may contact you for additional details. Your cooperation is required to expedite the resolution.

If further investigation is needed and resolution is not possible within two (2) months, a holding response will be sent explaining the delay and expected resolution timeframe. The final outcome will be provided within one (1) month of the holding response, depending on case complexity and your cooperation. If you fail to respond within three (3) months, the complaint will be considered closed.

• Final decision Once a resolution is reached, you will receive an explanation and details of any corrective actions taken, if applicable.

RISK FACTORS

We do not provide financial advice or consider your individual needs and goals. You should carefully assess whether leveraged trading with us is suitable for you. If you do not fully understand or cannot afford to assume all associated risks, you should not trade with us. Prior to engaging in any trading activities, please review our full Risk Disclosure Policy.

Price Fluctuations

The Client acknowledges and accepts that, regardless of any information provided by the Company, the value of investments may fluctuate both upwards and downwards. In some cases, investments may lose all value. The margining system applicable to such trades typically requires only a small deposit or margin relative to the total contract value. Consequently, minor market movements can significantly impact the Client’s trades and portfolio.

If market movements are favorable, the Client may achieve substantial gains. However, unfavorable movements may result in the loss of the entire capital invested with the Company. The Client should not enter into trading with the Company unless they are fully prepared to accept the risk of losing all invested funds.

Trading through the Company involves leverage, which amplifies both potential gains and losses. The high degree of leverage available in CFD trading can work against or in favor of the Client. Therefore, the Client must acknowledge and accept the risk of losses and damages resulting from trading in financial instruments.

It is crucial that the Client does not invest funds they cannot afford to lose, such as retirement savings, loans, mortgages, emergency funds, or funds required for essential expenses like education, homeownership, or medical needs.

The Company reserves the right to act in its best interests and/or in the best interest of the Client by adjusting account leverage without prior notice. The maximum leverage offered to retail clients varies based on the category of the underlying CFD:

• 30:1 for major currency pairs
• 20:1 for non-major currency pairs
• 20:1 for major indices and gold
• 10:1 for commodities (excluding gold)
• 10:1 for non-major equity indices

Reduced Demand for the Underlying Instrument

Some underlying instruments offered by the Company may not be immediately liquid due to reduced demand, which may impact the Client’s ability to obtain information about their value or associated risks.

Reliance on Past Performance

Past performance of the Company’s portfolio does not guarantee future results. Similarly, the performance of an underlying instrument cannot be predicted based solely on historical data. Therefore, past data should not be relied upon as an indicator of future performance.

 

 

TERMINATION POLICY

Client Termination

The Client may terminate their account or discontinue the use of the Company’s services at any time. Upon termination, the Client agrees that all amounts payable to the Company, including costs, charges, or additional expenses, become immediately due. The Company has up to seven (7) business days to fulfill its financial obligations to the Client.

The Client must close all open positions before terminating their account and refrain from opening new positions during the termination process. The Company may restrict or limit platform access for the Client during this period and has the right to reject new orders. Any remaining open positions will be closed at the prevailing market prices as part of the balance settlement process.

Clients with multiple currency accounts may request the consolidation of balances into a single base currency for settlement purposes. If the Company detects any suspicious or illegal activity during the termination process, the Client will be notified of an extended review period and must cooperate in resolving the matter. The Company reserves the right to withhold partial or full account balances if the Client is found accountable.

Company Termination

The Company may suspend or terminate a Client’s account if the Client is found in violation of Company policies, for internal reasons, or if illegal activities are suspected. In such cases, the Company will conduct an investigation and determine whether funds should be refunded or withheld.

Upon notification of termination, the Company may:

• Restrict or limit the Client’s access to the platform or website
• Close all open positions at prevailing market prices
• Withhold partial or full account balances
• Consolidate account balances into a single currency for settlement
• Require the Client to re-verify their account or provide additional documentation for enhanced due diligence

The Company will provide the Client with an estimated timeframe for the completion of the termination process, not exceeding thirty (30) days, though this may vary by case. Records of transactions and dealings will be maintained for at least five (5) years following termination, as required by law. Private information will be handled according to the Company’s Privacy Policy.

COSTS AND CHARGES

The Client agrees to pay all applicable charges, including fees imposed by clearing organizations and interest on outstanding amounts, as determined by the Company. A comprehensive list of fees, costs, and charges is available on the Company’s website.

If any value-added tax (VAT) or other tax obligations arise from transactions performed on behalf of the Client, the Client is fully responsible for paying these amounts to the Company upon request. The Company is authorized to debit the Client’s account to settle such obligations.

All payments to the Company must be made in the currency specified by the Company to designated bank accounts. Payments must be made without any deductions or withholdings.

The Company may share charges with partners, affiliates, intermediary service providers, and agents in connection with transactions carried out on the Client’s account. Information about fees and commissions paid to partners is available upon request.

Before executing any transactions, the Client should review all applicable charges, including spreads, commissions, and swaps, as detailed on the Company’s website. Clients are encouraged to seek clarification if needed.

Charges may be expressed in monetary terms or other units such as pips, whose value varies depending on the instrument.

Margin requirements dictate the collateral needed for a trading position and influence the level of leverage available. These requirements may vary based on factors such as the currency pair traded, account type, broker policies, and market conditions.

Due to fluctuations in third-party liquidity provider fees, spreads, swaps, and commissions are subject to continuous changes. Clients should monitor these costs in real time via the WebTrade Management Ltd platform before making investment decisions.

INACTIVITY POLICY

Trading Platform access is provided continuously, regardless of trading activity. If a Trading Account remains inactive for at least three (3) months, the Company reserves the right to charge a monthly inactivity fee:

• $10 per month after 3 months of inactivity
• $15 per month after 6 months of inactivity
• $30 per month after 12 months of inactivity

The Client agrees to pay these fees, which will be deducted from any available funds held by the Company on the Client’s behalf. The applicable fees are subject to periodic updates, as notified to the Client.

TAXES

You acknowledge that you are solely responsible for any applicable taxes related to your transactions on the Website and/or through the Services. This includes, but is not limited to, value-added tax payable in any jurisdiction. The Company does not provide tax advice regarding the Services or otherwise. It is your responsibility to report, pay, and remit any applicable taxes to the relevant tax authorities in your jurisdiction(s).

Unless otherwise agreed, all amounts payable under these Terms are stated exclusive of any taxes or mandatory payments. You must pay any such taxes directly to the appropriate government agencies in compliance with applicable laws. Additionally, you agree to fully indemnify the Company for any tax payments it may be required to make on your behalf. The Company reserves the right to debit your Account for any such payments made on your behalf.

 

 

INTELLECTUAL PROPERTY

All brand names, trademarks, service marks, and trade names associated with the Website, whether owned by the Company or its affiliates, licensors, or partners (collectively referred to as “Partners”), remain the exclusive property of their respective owners. The Company and/or its Partners also own all intellectual property rights (IPR) related to the content of the Website (“Content”). By using the Website and Services, you do not acquire any rights to these trademarks or the Content, except as permitted under these Terms.

For the purpose of these Terms, “Intellectual Property Rights” or “IPR” includes but is not limited to patents, copyrights (including rights in software), trademarks, trade names, service marks, database rights, design rights, trade secrets, know-how, and other proprietary rights, whether registered or unregistered, worldwide.

You agree not to:
a) Copy, redistribute, publish, reverse engineer, decompile, disassemble, modify, translate, or attempt to access the source code to create derivative works;
b) Sell, assign, sublicense, transfer, distribute, or lease the Software;
c) Make the Software available to any third party via a computer network or other means;
d) Use the Website or related software in violation of any applicable laws or regulations (collectively referred to as the “Prohibited Actions”).

You will be held liable for any damages, costs, or losses incurred by the Company due to your engagement in any Prohibited Actions. If you commit or become aware of any Prohibited Actions, you agree to promptly notify the Company and assist in any investigation.

You acknowledge that using the internet carries risks, including exposure to viruses and cyber threats. You are responsible for using reputable antivirus software to safeguard your devices. The Company is not liable for any damage or disruptions caused by malware, phishing, spoofing, or other cyberattacks. Always log in through the official Website and avoid unauthorized communications requesting your credentials.

DURATION OF THE AGREEMENT AND AMENDMENTS

This Agreement remains valid indefinitely unless terminated by either party.

AMENDMENTS TO THE AGREEMENT

The Company may amend this Agreement under the following circumstances:

• Unilateral Amendment Due to Legal Changes: If changes in applicable laws require amendments, the Company will notify you via email, written communication, or an announcement on its Website. Your consent is not required for such amendments.
• Other Amendments: If the Company makes amendments unrelated to legal changes, it will notify you via email or the Website. You may object to the amendments within five (5) days by sending a registered letter, provided that all pending transactions are completed. If no objections are raised within this period, the amendments will be deemed accepted.

NOTICES

Unless otherwise specified, any notices, instructions, authorizations, or other communications from you to the Company must be in writing and sent to the Company’s designated mailing address as indicated on its Website. Notices will only take effect when received by the Company, provided they do not violate any terms of this Agreement. The Company may designate alternative methods of communication at its discretion.

RECORDING OF TELEPHONE CALLS

You acknowledge that the Company may record telephone conversations between you and the Company without the use of a warning tone. This is done to ensure that the essential terms of transactions and any other relevant information are promptly and accurately documented. These recordings will be the sole property of the Company and will be considered valid evidence of any orders or instructions you provide.

GENERAL PROVISIONS

You confirm that no representations or assurances have been made by or on behalf of the Company that influenced your decision to enter into this Agreement.

If any provision of this Agreement is found to be illegal, void, or unenforceable under the laws or regulations of any jurisdiction, the validity and enforceability of the remaining provisions shall not be affected. Additionally, the legality and enforceability of the affected provision in any other jurisdiction shall remain intact.

You agree to take all necessary actions, including executing any required documents, to enable the Company to fulfill its obligations under this Agreement. Detailed information regarding the execution and conditions of investment transactions in financial instruments, as well as other relevant Company activities, is accessible to both individuals and legal entities on the Company’s website.

FORCE MAJEURE

The Company shall not be held liable for any delays, performance failures, or service interruptions caused by circumstances beyond its reasonable control. These may include, but are not limited to:

• Natural disasters (acts of God)
• Actions by civil or military authorities
• Terrorist activities
• Civil unrest or war
• Strikes or labor disputes
• Fires
• Failures in telecommunications, internet services, or network providers
• Equipment and/or software malfunctions
• Any other unforeseeable events beyond the Company’s control

Such events shall not impact the validity and enforceability of the remaining provisions of this Agreement.

APPLICABLE LAW AND JURISDICTION

This Agreement and all related transactions between you and the Company shall be governed by the laws of the Union of Comoros. Any disputes arising from this Agreement shall be subject to the jurisdiction of the Court of the Union of Comoros.

DIGITAL SIGNATURE

All communications between the Company and the Customer conducted via electronic means, including emails and interactions on the Website, shall be considered legally binding as if they were in written form. This includes any references to this Agreement or amendments made to it.