1.1 This Financial Services Guide (“FSG”) is dated 11 September 2020 and has been prepared by (“we”, “our”, “us”) in compliance with our obligations as the holder of an Vanuatu Financial Services Commission (VFSC License No 40436) (“VFSC”).

1.2This FSG has been designed to help you decide whether to use any of the products and services that we offer. The FSG is an important document and a regulatory requirement under the Corporations Act 2001 (Cth) (“Corporations Act”). It contains information about who we are, remuneration, any associations or relationships we may have with financial product issuers, details of any potential conflicts of interest, our internal and external dispute resolution procedures and how you can access them, information on how we handle your personal information, and how we can be contacted.

When providing our services to you, we are also required to issue you with other documents. We will give you a Product Disclosure Statement if we offer to issue our financial products to you. Before you open an account with , we will provide you with a Product Disclosure Statement which contains important information regarding:

• the terms and conditions for the products and services we offer;

• the features of our products and services;

• any significant risks associated with our products; and

• details of fees and charges for our products and services.

You should read the PDS carefully prior to acquiring any financial products from us.

You will also receive our Client Agreement, which is a governing contract between us and you. These terms will dictate the rights and conditions of each party and contains important information about transacting with us.

Prior to trading you will be required to fill out an online or paper Account Application. We will also provide you with transaction confirmations over the trading platform.

1.3This FSG contains general information only. If you have further questions regarding this FSG please contact us.

2.1 holds an Vanuatu Financial Services Commission (VFSC License No 40436).

We are the providing entity of the services contained herein and you may contact us as follows.

Address: Room 11, 2/F., Bougainville Building, Bougainville Street, Port Vila, Vanuatu.

Email:

Website:

is licensed by VFSC to (amongst other authorisations) provide dealing and execution services in Margin FX products and to give financial product advice. It is authorised to deal by issuing and making a market in its own foreign exchange contracts and contracts for difference.

We do not provide personal financial advice. Any representation whether verbal or written made during the course of ’s relationship with you must not be construed as personal advice that has taken into consideration your financial situation, objectives and needs.

When you trade in the OTC derivative products we act as principal and we are the issuer of the products. This means we are the counterparty to every trade and have no obligation to act in your best interests.

We will receive instructions from you via an on-line trading platform or via phone. If you give us instructions via phone, you must confirm that such instructions have been effected by us by checking your account on our trading platform.

We will only provide you with general advice, which does not take account your objectives, financial situation or needs. Therefore, you are required to ensure that you obtain prior advice regarding the suitability of our products and services for your personal financial needs, objectives and circumstances, from a licensed and independent professional advisor.

While believes the general advice and information we provide is accurate and reliable, neither nor its directors, officers, employees, contractors or associates assume any responsibility for the accuracy and completeness or currency of that advice and information.

We are entitled to any fees generated as a result of our provision of OTC derivative products to you. Our PDS provides detailed information about specific costs, transaction fees and charges associated with each of our financial products, as well as with different types of trading accounts that we offer. Further written details can be given to you on request. The common fees and charges associated with the financial products offered by us may include any or all of the following:

(1) We may charge spreads (the difference between the bid and the ask price) on your trades in favour of . Details of spreads can be found on our website. For Margin FX Contracts the spreads will be charged in the quote currency of the instrument being traded, which can then be converted into the base currency of the Trading Account in order to determine your cost of trading.

(2) Spreads vary according to the market concerned and are subject to variation, especially in volatile market conditions, and we may change our spreads at any time. The applicable spreads are provided in our website and our Platform. Because dealing spreads depend upon activity in an underlying market the spread when you close a order may be different to the spread when you opened it.

Margin is not a cost, however Margin is the amount of capital required by as collateral in your Trading Account for you to open a Transaction. The way that we calculate Margin varies based on the Instrument being traded and the details of the underlying asset. Margin requirements will be displayed on our Platform and we recommend that you check the details of your Contract to understand the amount of Margin required.

Any open Transaction held by you at the end of the trading day on which the relevant Instrument is traded or over the weekend when the relevant underlying market is closed, shall automatically be rolled over to the next business day to avoid an automatic close and physical settlement of the Transaction. You acknowledge that, when rolling such Transactions to the next business day, an Overnight Funding charge will be either added to or subtracted from the balance of your Trading Account. The Overnight Funding charge is a constant percentage of the position value and is based on a number of factors including amongst others, whether the Transaction is a Buy or a Sell, interest rates, Instrument differentials, daily price fluctuations and other economic and market related factors. The Overnight Funding for each Instrument is displayed on the Platform. In deciding whether to open a Transaction for a specific Instrument, you acknowledge that you are aware of the Overnight Funding charge.

No interest is paid or received if you open and close a position in the same trading day.

Fees may be payable by you by virtue of the fact that incurs expenses maintaining your account for trading, regardless of your actual usage.

If there are no open positions or trades on your account, it will be considered inactive from the next calendar day (‘Inactive Day’) following the last trade. For a period of at least 180 days after the Inactive Day, you will be liable to pay a fee (‘Inactivity Fee’) in return for the provision of administrative and information services and the continued availability of your Trading Account. You should be aware that a payment activity (i.e. deposit or withdrawal) and a pending order is not deemed as a transaction.

You shall pay Inactivity Fees as agreed with you from time to time or we may deduct such Fees from any funds held by us on your behalf.

The Inactivity Fee will be equal to the lesser of the remaining balance in your account or USD $10, levied monthly in arrears and in the Base Currency of your Trading Account. For the avoidance of doubt, where the Inactivity Fee occurs during a partial month, that entire month is counted in the calculation of the Inactivity Fee.

Upon assessment of the Inactivity Fee your Trading Account may be closed.

Please visit our website for further details and applicable costs.

Any payment by to third parties and/or its employees must comply with financial services regulation in Vanuatu and the Future of Financial Advice (‘FOFA’) reforms. In particular any fee paid by us to a third party who:

• Is an VFSC licensee, or its representative; and
• Provides financial product service to retail clients (“Authorised Third Party”); or
• Is an employee

Whether as your agent or otherwise and that relates in any way to your trading with us, must not be what is termed ‘conflicted remuneration’.

Employees of are not renumerated on a commission basis. No related body corporate of nor any director of or its related bodies corporate service receive any commission or other benefits attributable to the OTC derivatives products offered by us. Our staff are renumerated for the provision of services to our clients at the discretion of senior management having regard to standards of service to clients and feedback from them, their contribution to the firm in general and reaching a range of personal performance targets. Our employees receive salaries, performance bonuses based on achievement of predetermined business objectives such as client service, client satisfaction, risk management and leadership/team contribution.

We have no associations or relationships with any issuer of any financial products that might reasonably be expected to be capable of influencing us in providing any of our authorised services.

In compliance with s912B of the Corporations Act and VFSC RG 126, we maintain professional indemnity insurance in connection with the financial products and services we provide, including any claims in relation to the conduct of our former representatives/employees.

Your privacy is important to us and we are committed to compliance with the Privacy Act and the Vanuatu Privacy Principles. We may disclose your personal information to external parties who act on our behalf in the operation of our business or in connection with the transactions to be undertaken. Such external parties are required and committed to protecting your privacy and where they are offshore we take reasonable steps to ensure that to the maximum extent reasonably possible any information sent has the same level of privacy protection as we provide here in Vanuatu. will not otherwise disclose your personal information without your consent, except as authorised or required by privacy laws. Please refer to our privacy policy on our website, and contact us if you have any concerns.