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Trading Operation

1. Term and Definitions

Balance shall mean the amountof money on the Client’strading account not including open positions; the state of a tradingaccount including all closed positionsand all non-trading operations.

Dividends (adjustment for dividends) shall mean a non-trading operation performed by theCompany in order to accrue/withdraw dividends with a long/short openedposition on CFD onStocks as of the day of shareholder register recording.

Available Market Price shall mean aquote, atwhich theCompany executes the Client’s order. Reliability of a quote is defined solelyby the Company based on the marketdata received from liquidity providers and counterparties.

Closing of Positionshall mean a tradingoperation of selling(buying) for the purpose of repayment of obligations under an earlier opened position and fixation of the financial result.

Quote shall mean indicative information onthe current rate ofthe instrument shown inthe form of Ask and Bid prices.

Leverage Level shall mean themaximum possible ratio between margin requirements for the opening / maintaining of anopen position and thevolume ofthe trading operation /position, which is defined by the settings of the Client’strading account.

Log-file shall mean a part of the Company’s servermeant to recordthe data transferred by the Client and the Company to each other in the course of trading and non-trading operations.

Lot shall mean standardized trading volume of trading operations with an instrument. Nominal volume of one lot shall be indicatedin the specification on the website and/or in the tradingplatform.

Margin Requirements (Margin)shall mean the amountof funds blockedon the Client’s trading account in order to maintain all their open positions. Margin Requirements for each instrument are specified on the Company’swebsite and are indicated on the Company’s server.

Initial Margin Requirements shall mean theamount offree funds on atrading account that is required foropening a position.

Unrealized (Floating, Current)Financial Resultshall mean the financial result onopen positions with the current cost of instruments,considering accumulated swaps.

Non-Market Quote shall mean a quote recognized by the Companyas wrong. The Companyis entitled to delete information on a non-market quote from the quote base. All trading operations performed at a non-market quote shall be annulled and the executedpending orders shall be cancelled.

Non-TradingOperations shallmean operations that are not related directly to the performance of trading operations:

Trading Operation Volume shall mean thevolume ofa trading operation expressed in lots.

BankingDay shall mean a time interval from 00:00:00 to23:59:59, server time UTC+2, time of ending of a bankingday on Friday, 22:59:59 exceptweekends and holidays.

Opening of Positionshall mean the result of approvalby the Company’s server of a trading order for the opening of position. After the position is opened, the following obligations shall commencefor the Client:

Pending Order shall mean an order for the performance of a tradingoperation upon meeting certain pricing terms in the quotes flow; it is implied, however, that such order shall beexecuted at an indefinitemoment in future according to the order execution procedure. Types ofpending orders:

Quotes Flow shall mean asequence ofmarket data in theform ofindicative quotes received from liquidity providers andmarket data providers with further retranslation to theClient’s trading platform.

Realized Financial Result shall mean the amount of funds in the currencyof the trading account subject to accrual to/withdrawal from the balance of the Client’s trading account as a resultof closing of the position.

Market Order shall mean anorder toperform atrading operation at theprices available at the moment of orderdelivery.

Company’s Website shall mean as relatedto these Regulations, a source of information on trading conditions, under which the Client’s trading orders are processed. The highest priorityof performance standards and trading conditions is defined by the specification of the Company’strading server.

Free Balance shall mean thefunds onthe Client’s trading account that maybe used by the Client as security for new tradingoperations.

Trading Operation shall mean aconversion operation with anon-deliverable financial instrument performed between the Client and Company, i.e., anoperation implying the buying or sellingof an instrument without the transfer of its ownership. Performance of a tradingoperation may lead to the opening of position, closingof position, partialclosing of position and closing by two and more opposite positionswith the mutual settlement of obligationsunder each of them.

Company’s Server shall mean ahardware andsoftware complex containing relevant trading conditions that ensure processing of the Client’sorders and requests,online provision of information on the adjustment of financial instrument prices to the Client (in the volume defined by the Company),accounting of mutual obligations betweenthe Client and theCompany, as well as the performance of other Agreementterms.

Equity shall mean a weightedestimation of the cost of funds on a tradingaccount representing the amountof funds on a tradingaccount including unrealized profit (losses).

Stop Out shall mean the processof compulsive closingof one or several positions on the Client’s tradingaccount due to insufficient marginsecurity to maintainopen positions.

Spread shall mean thedifference between the Askand Bidrates.

Swapshall mean the funds withdrawn from / accrued to thecurrent unrealized financial result for the rollover (prolongation) of an open position to the next day.

Ticket shall mean a unique identification number assigned toany operation in thetrading platform in orderto unify and define operations on the tradingaccount.

Trading Time shall mean aperiod oftime when trading with a financial instrument isallowed and the tradingserver processes the Client’s tradingrequests and orders.

Expert Advisorshall mean any automated trading system which is designedto automate trading operations in the TradingPlatform.

Trading Order (Trading Operation) – an order submitted by theClient tomake atransaction (trading transaction) with a particular financial instrument.

Trading Account shall mean anaccount forinternal record opened bythe Client with the Company, where the Company’sand the Client’s obligations arisingfrom trading and

non-trading operations performed under the Company’s regulating documents are recorded.

Trading Platform shall mean a specialized software and hardwarecomplex, by which theClient may agree with the Company via the Interneton material terms of the tradingoperations performed as part of the Agreement fulfillment and may protocol the agreed terms and the content of the approvedand cancelled orders.The Trading Platformensures identification of the parties (partyauthentication) that exchangemessages, as well asconfidentiality and integrityof such messages using built-incryptographic protection facilities.

Telephone Password shall mean a code word set by the Client throughthe Personal Page that is required for the unambiguous identification of the Client when performing trading operations via a telephone line.

Margin Level shall mean anindicator equal to theratio ofthe equity amount onthe trading account to margin requirements that characterizes sufficiency of funds on the trading account for maintaining openpositions.

Stop Out Level shall mean amargin level when thestop outprocedure isinitiated.

Hedging (Locking) shall mean apossibility tohave positions under oneinstrument that are opened in opposite directions.

Hedged Margin shall mean margin security required by theCompany forthe opening and maintenance of lockedpositions. Hedged Marginfor each instrument is indicated on theCompany’s trading server and is specified in the contractspecification on the Company’swebsite.

Ask Price shall mean thegreater price in thequote atwhich theClient maysend amarket request for a buy tradingoperation. Ask Priceis the price of activation of all the pendingorders implying performance of a buy trading operation.

Bid Price shall mean thelesser price in thequote atwhich theClient maysend amarket request fora sell trading operation. Bid Price is theprice ofactivation ofall thepending orders implying performance of a sell trading operation.

Market Execution shall mean thetechnology oforders execution, which implies the execution of the Client’s order atthe available price atthe moment of execution on thetrading server of the Company.

2. General provisions

2.1. These Regulations define the generalprocedure and termsof the Client’s orders and requests processing, under which PNM Investments Company (hereinafter referredto as ‘the Company’) provides the service for performing margin trading operations with non-deliverableover-the-counter instruments on trading and investment accounts.

2.2. Contracts fordifference (CFD) are margin leveraged products, which carry a high level of risk. Performing operations with CFD may not be suitablefor all Clients.The Clients should not perform trading and/or investment operations unless they understand the principles and nature of the operations, as well as the amount of their potential losses.The Clients should ensure, that performing tradingoperations with CFD instruments is suitable for themconsidering your circumstances, financial opportunities and resources, as well as investmentpurposes. If the Clients have any doubt,they should seek independent advice.The Clients perform all trading and/orinvestment operations at their own risk.

2.3. These Regulations define:

2.4. The terms of performing trading and/or investment operations are defined in these Regulations, Client Agreement, Risk Acknowledgement and Disclosure Statement and the other applieddocuments, including manual on trading platforms, as well as in the appropriatesection on the Company’s websites. All documents are regulated by the laws of the Saint Lucia. In case of any inconsistency between the documents the laws of the Saint Lucia shall prevail.

2.5. Trading conditions for a Client,such as instruments, which are available for trading,trading time, available request and order types, the size of commissions, including the terms ofthe rollover of an open position to the next day, are set up on the Company’s servers matching a trading accountand may be determined by the servicesused by the Client, individualagreements with the Client, restrictions on the part of the liquidity providers and the Company’s counterparties. Information regarding tradingconditions, defined on anappropriate account type, shall take precedence in case of conflict with other information published on the Company’swebsites. The Company takes all necessary measures to keep up-to-dateinformation on the Company’s websites and timely notification of the Client about allchanges in trading conditions.

3. General principles

Quotes / Prices

3.1. For alltrading instruments the Company shall issue quotes online following theprices

/ liquidity itgets from counterparties andliquidity suppliers. Any ofthe Client’s references to the quotesof other tradingand information systemsshall be unauthorized.

3.2. The Companymay choose not to issue quotes in case of the followingterms:

3.3. Spread is not fixed and dependson market conditions and flow data on prices /liquidity received from counterparties and liquidity suppliers.

3.4. All quotesthe Company communicates to the tradingplatform, Company’s websites and presents to partners areindicative.

3.5. In case a non-market quote enters the quotes flow, and in case of an unscheduled gap in the quotesflow caused by any hardwareor software failure,the Company may synchronizethe quotes base with the other sources.Such sources may be the following:

3.6. Information on spreads published on the Company’s websites is purely informative and is based on statistic and historical data.

3.7. While agreeing upon theimportant terms of aTrading operation, the Client and Company interact in the following way:

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3.8. Important terms of atrading operation are thefollowing:

3.9. In case of termination of services for trading operations with a certain instrument, the Company may unilaterally close the open positions on the Client’strading account at thelatest price available on the Company’s serverand delete all the pendingorders on its own.

3.10. The Company retains itsright tounilaterally change the terms of performing Trading Operations, restrict or expand the list of instruments.

3.11. To perform trading operations, the Client may usethe following types oforders:

3.12. The Client’s issue ofan order for atrading operation means their intention toperform a trading operation on the termsspecified herein, considering the specifics stipulated by these Regulations.

3.13. An order for a trading operationmay be issued by the Client within the businesshours of the Company,considering the specificsstipulated by these Regulations, in the following ways:

3.14. All the Client’s ordersand requests shallbe checked for correctness and compliancewith the trading terms before they are passed to processing / execution, includinga preliminary check for sufficiency of funds for a tradingoperation on the Client’s trading account.

3.15. Each requestand order of the Clientshall be processed on a first-served basis. Depending on the time required for the Client’s order or request processing, the procedure of completion of the Client’srequest or orderprocessing shall not be guaranteed. It means a

situation may occur,when completion of a Client’srequest processing is recorded in theserver log-file at a later time, than the time of completion of a request that followed.

3.16. The Client agrees that the processing/execution of themarket andpending orders shall takereasonable time.

3.17. Any Client’s request ororder shall be deemed processed only when arelevant record is made in the log-file on the Company’s server.

3.18. A tradingoperation is performed on the basisof the Client’s relevant ordersafter processing / execution of such ordersby the Company, considering the specifics stipulated by these Regulations.

3.19. A tradingoperation is performedonly upon the Company’s approvalof all of its importantterms defined hereby.

Leverage Level / Margin Requirements /Margin

3.20. During accountregistration the maximumpossible leverage is set up. It corresponds to account type. The Client uses it to perform tradingoperations.

3.21. The Companymay change the maximum leverageat its own discretion upon priornotice.

3.22. The minimummargin requirements to perform tradingoperations and to maintainopen positions on an instrument are defined by specification of the instrument corresponding to the accounttype and are indicated in an appropriate trading platform.

3.23. The minimummargin requirements to perform tradingoperations and to maintainopen positions on certain groupsof instruments do not dependon the maximum leverage set on the Client’s account.

3.24. Margin requirements needed to maintainopen positions are reserved on the Client’s account at the moment theposition is opened.

3.25. The Companyis entitled to change the size of margin requirements upon notifying the Client in advance.

3.26. The Companymay apply new margin requirements to positions, which have already been opened, as well as to newpositions.

3.27. The Client shall monitor the required margin level on their trading account on their own.

3.28. The Companymay fulfill the Client’s obligations towards the Companyon any open position or all open positions without giving a prior notice to the Client, if the level of ratio of equity to margin requirements needed to maintainopen positions goes below the Stop Out level. Stop Out leveldepends on tradingaccount type.

3.29. The Company shall notbe liable for Stop Out executed on theaccount that resulted from an untimelyreceipt of fundson the Client’s account.

Rollover

3.30. If there are open positions atthe endof atrading dayin theperiod from 23:55 to00:00 (trading platform time), theCompany shall unilaterally perform a rollover (swap) procedure. Positions are rolled over to the next day by way of withdrawal / accrual of an amount calculated according to swap calculation rulesof the trading platform and the Company’s server settings for a relevant accounttype from / to the current unrealized financial result on an open position.

Fees

3.31. The Client shall paya feefor performing trading operations according tothe size and / or rulesof their calculation set up on the Company’s server for a relevant accounttype.

Dividends

3.32. If there are open positions with CFDs on Stocks at the end of the trading day prior to thedate of registerrecording (ex-dividend date),the Company shall make adjustment for dividends on the date of register recording as soon as the first trading quote is receivedin the trading platform. Adjustment for dividends is made according to the termspublished on the Website in the relevant section.

The reasons for rejecting the Client’s trading requests

3.33. The Company is entitled to reject the Client’s request toopen orclose aposition, or refuse to execute a pending order if:

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