Client

Agreement
 General Terms and Conditions

1. Introduction
1.1 This Agreement is concluded by and between Headway (hereinafter called the “Company”) on the one part and
the Client, as a legal entity or an individual, who has completed the Account Opening Application Form (hereinafter
called the “Client”) on the other part.

1.2 This Agreement specifies the terms and conditions for the provision of services by the Company. The Company
provides to the Client the following services: transactions in financial markets, transactions with financial instruments,
which are either represented or not represented in the organized market.

1.3 This Agreement also sets forth the order of payments between the Parties, in connection with the aforementioned
in 1.2.

1.4 Accepting this Agreement the Client guarantees the following:

a) In case the Client is a private person or a legal entity, each person or entity is capable and no one except the
Client has any rights of demand or obligation in respect to the transactions performed in the Client’s trading
account;
b) In case of any change or modification of personal data or expiration of personal ID document(s), the Client is
obliged within three (3) business days to inform the Company of such changes or expiration. The changed
documents must be sent by email containing the Client’s first and last name, account number(s), phone, as
well as Client’s valid passport or ID and recent proof of residential address. The notification must be signed,
scanned and sent to care@hw.site from the email the Client submitted during his/her account registration.
The changed documents can also be uploaded in the Personal Area. The Company has the right to request
other verification documents in order to verify the Client and comply with applicable KYC regulations. Any
delay or failure to comply with this clause shall amount to breach of this Agreement by the Client and can
lead to the closure of the Client’s account(s);
c) In case the Client is a private person he submits the registration form personally. If a legal entity, the form is
submitted by the person in charge;
d) Each Client can register once in the company (one Personal Area with completed identity verification). This
applies in all following cases:
- if the Client registered on the Company website as a trader or as a Partner;
- if the Client is a private person with a registered profile;
- if the Client is a director of a legal entity with a registered profile.
In cases when the Client needs to complete an identity verification for a new Personal Area, the Company
cancels the verification of the previous Personal Area.

1.5 All the transactions on the Client’s trading account are performed in compliance with this Agreement.

1.6 Client’s Representations.

1
1.6.1 The Client represents and warrants that he/she is free to enter into this Agreement, to perform each of the
terms and covenants contained herein and that he/she is not restricted or prohibited, contractually or otherwise, from
entering into or performing under this Agreement and that his/her execution of and performance under this
Agreement is not a violation or breach of any other agreement between the Company and any other person or entity.

1.6.2 The Client understands and expressly agrees that the Company shall exercise its right to monitor activity of the
Client and verify consistency of Client’s behavior and trading activities on the Company’s platform.

1.6.3 The Client further represents that he/she has complete understanding and is agreeing with all terms and
conditions of this Agreement.

1.7 The leading language of the present Agreement is English. A translation of any Company document into a
language other than English is intended solely as a convenience to the Company's Clients. The function of the
translation is merely informative. In case of inconsistency between the English version and the translation of the
present Agreement into another language, the English version shall be of prior importance. The Client must provide
the relevant documentation or information to substantiate the chargeback cycle or compliance case in the English
language or with an accompanying translation in English. The Client accepts and understands that the official
language of the Company is English.

1.8 In the Agreement, words importing the singular shall import the plural and vice versa, words importing the
masculine shall import the feminine and vice versa and words denoting persons include corporations, partnerships,
other unincorporated bodies and all other legal entities and vice versa.

1.9 The Agreement overrides any other agreements, arrangements, express or implied statements
made by the Company or any Introducer(s).

2. Company’s services
2.1. Company's services include MetaTrader 4, MetaTrader 5 and technical analysis means and any Third Parties'
services offered along with the Company's services.

2.2 Company’s services refers to any interactive services or software provided by the Company, which allow the
Client to: perform transactions on financial markets through the Company by means of MetaTrader 4 and MetaTrader
5 including electronic data transmission between the Client's PC or any similar device, connected to the Internet and
the Company's authorized network.

2.3 Accepting this Agreement the Client confirms he/she has read the communication rules and agrees that he/she is
only able to perform orders by means of the MetaTrader 4 and MetaTrader 5.

2.4 The Client confirms that the Company may modify, add, rename or leave unmodified the Company’s services
offered in compliance with this Agreement without prior notification. The Client also confirms that the Agreement is
applied to the services which may be modified, added or renamed in future in addition to the services provided by the
Company at present.

2
2.5 The Company is not liable to (unless set forth in this Agreement):

a) Track any Client’s trading operation status and inform the Client about it;
b) Close any Client’s open position;
c) Attempt to execute any Client’s order by different quotes than the quotes offered in Metatrader 4 and
MetaTrader 5 trading platforms.

2.6 Company’s services do not include providing recommendations or information capable of engaging the Client to
perform any transactions. In exceptional cases the Company reserves a right to provide information,
recommendations or advice to the Client, however, in these cases the Company will not be responsible for any
consequences of such recommendations and advice. Despite the Company reserves a right to close or decline any
Client’s position, all the trading operations performed by the Client as a result of imprecise information and/or mistake
still remain in force and are mandatory for both the Client and the Company.

2.7 The Company reserves a right to decline the Client and offer him/her to withdraw the deposit in case his/her
activity or interaction with the Company is deemed inappropriate and/or incorrect.

2.8 No actual supply of the currency or base asset of energies and indices is made within a trading operation. All the
profits and losses are deposited or deducted from the Client’s trading account balance immediately after the position
closure.

3. Payments and Financial operations

3.1 Funds deposit to the Client trading account.

3.1.1 Clients can deposit funds to his/her account by means of the methods and payment systems available in the
Personal Area.

3.1.2 If it is impossible to execute a deposit automatically, the request will be carried out by the financial department
within two (2) working days after it is created.

3.1.3 The Company has the right to establish the minimum amount of funds. The minimum amounts are indicated in
the deposit form.

3.2 Withdrawal of funds from the Client’s trading account.

3.2.1 Withdrawals must be made using the same payment system, same account, and same currency that were
used to deposit funds. If a trading account uses multiple payment systems or multiple wallets within the same
payment system, funds must be withdrawn in proportion to the amounts deposited. In exceptional cases this rule may
be waived, pending account verification and under strict advice of our payment specialists.

3.2.2 If the Client uses digital or virtual currency within financial operations, the Client undertakes to use only one
specific wallet per each digital currency while withdrawing the funds.

3.2.3 Withdrawals of profits and partner commissions must be made to a personal bank account\ e- wallet only. The
Company reserves the right to request a proof ( Screenshot ) that the e-wallet belongs to the client.

3
3.2.4 If the internal transfer was used to spread the funds between the Client's accounts, the Company reserves the
right to require the Client to split the withdrawals according to the transferred amounts in order to comply with
Anti-Money Laundering policy and regulations.

3.2.5 The withdrawal request will be carried out by the financial department within two (2) working days after it is
created.

3.2.6 In exceptional cases (such as force majeure circumstances, termination of payment system operation, etc) the
Company is entitled to decline a Client’s funds withdrawal in this payment system. Depending on circumstances such
cases are considered case by case.

3.2.7 If an account has been deposited via a debit or a credit card at least one time, a withdrawal from the account
should be executed back to this card during the year since the last deposit made via the card and a card copy is
required to process a withdrawal. The copy must contain the first six (6) digits and the last four (4) digits of the card
number, cardholder’s name, expiry date and cardholder’s signature.

3.2.8 In case of discrepant transactions, the Company may cancel any financial operations that are not found in the
payment system’s records or were canceled or chargeback. In this case, the Company also reserves a right to cancel
any trading operations made with the unconfirmed funds as well as call back any related payments for these
operations, such as Partner Commission, promo and bonus lots, etc.

3.2.9 Company does not accept direct payments or payments to third parties.

3.2.10 Headway is not liable for delays in processing withdrawals if such delays are caused by the payment system.

3.3 Financial security.

3.3.1 In case of indication or suspicion of any form of Client's fraudulent activity or violation of conditions of Customer
Agreement, the Company in its sole discretion will be entitled to suspend all transactions of deposits or withdrawals.

3.3.2 The Company may at any moment ask the Client to submit a copy of a passport or other equivalent document,
certified by a notary (at Company’s discretion).

3.3.3 The Company is entitled to prohibit the deposit or withdrawal of funds to the Third Parties.

3.4 In case if it becomes known of the Client's death or Client's incapability the Company has the right to terminate
the Agreement and to block the Client's trading account. The right to withdraw the remaining balance from the
Client's trading account will be available only for Client's heirs according to the applicable law and with documents
issued by the competent authorities. Client's heirs cannot get access and use the Client's trading account.

4. Orders and requests

4.1 The complete official information regarding the current trading conditions is located at www.hw.site .The
Company reserves a right to change the trading conditions with a prior notification.

4
4.2 Clients orders and requests.

4.2.1 During trading operations the following execution methods are applied:Market execution for all trading
instruments

4.2.2 Any Client’s order given by means of MetaTrader 4 or MetaTrader 5 trading terminal generally goes through
the following steps:

- The Client submits an electronic order;

- The client terminal sends the order or request to the server;
- Provided there is a stable connectivity between the client terminal and the server, the order is
received by the server and verified;
- In case the order is valid, it is put into the queue. In this case “Please wait... Order is being
processed by the server” message is displayed in the “Order” window of the client terminal;
- The server returns the order processing results to the client terminal;
- Provided there is a stable connectivity between the client terminal and the server, the terminal
receives the order or request processing results.

4.2.3 Client’s request is declined in the following cases:

- During market opening when the order is sent before the first quote is received by the trading
platform;
- In irregular market conditions;
- In case the Client doesn’t have sufficient margin. In this case “No quote” or “Not enough money”
message is displayed by the trading platform;
- In case the Client uses an Expert Advisor performing over 30 requests per minute the Company
reserves a right to ban such EAs;
- For instruments with fixed commission for order opening with no spread, the Company reserves the
right to change to “Close only” mode and decline new requests for order opening with the comment
“Trade is disabled” in case spread on the basic contract exceeds the size of commission amount.

4.2.4 The Client can cancel a sent order only while it is in queue with “Order is accepted” status. In this case the
Client should press the “Cancel order” button. Due to the specifics of MetaTrader 4 or MetaTrader 5 platform order
cancellation in this case cannot be guaranteed.

4.2.5 In case the order has reached the dealer and has “Order is in process” status, such order cannot be canceled.

4.2.6 The time of the order processing depends on the connection between the client terminal and the Company’s
server, as well as on the current market conditions. During regular market hours the order processing time usually is
1 to 5 seconds. In irregular market conditions, the processing time can last longer.

4.2.7 In case the current quote of the financial instrument changes at the moment when the Company is processing
the Client’s request, the Company reserves the right to use the new price (Bid/Ask). In such a case, the Client’s
request will be processed at the new price.

4.2.8 The general means of sending orders and requests is the trading terminal.

5
4.2.9 As an exception, the use of the same IP address by different Clients can be a basis to consider all the orders
on all the accounts, performed from this IP address, as those performed by the same Client.

4.2.10 Orders opened or closed by off-market quotes can be canceled in case they were opened or closed by an
off-market quote.

4.2.11 The Client is not allowed to use the arbitrage strategies on connected markets, e.g. currency futures and spot
currencies. In case if Company notices this usage in either transparent and clear or hidden way, the Company
reserves a right to cancel such orders.

4.2.12 Client’s orders will be canceled by the Company in case they are inconsistent with this Agreement.

4.3 Trading operations.

4.3.1 A buy order (long positions) is opened by Ask price. A sell order (Short positions) is opened by Bid price. A buy
order is closed by Bid price. A sell order is closed by Ask price.

4.3.2 In case of the position rollover, swap addition or deduction to open orders is carried out from 23:59:00 to
00:10:00, trading platform time. So the swap will be added or deducted to all orders which were open during the
period from 23:59:00 to 00:00:00, trading platform time.

4.3.3 In regular market conditions a Dealer keeps the spread within the range stated in the contract specifications.

4.3.4 If the Client is trading those energies and indices contracts that have a limited period of trading, e.g. expiration
date, all orders executed on one contract will be closed by the last quote.

4.3.5 Spread can be increased for:

a) The all Company Clients without prior notification in the event the conditions come, different from the regular
ones;
b) The all Clients with obligatory prior update of contracts specification changes at the Company website;
c) The all Clients without prior notification if the force majeure circumstances occur;
d) Any of requests exceeding regular market volume for the tool stated in the contract specification;
e) The time before, during and after economic, political and other news releases, during the Gap, during the
Market opening time, on Monday, as well as at the time of low market liquidity and when a market situation is
conditional on the high spreads;
f) The instruments with the fixed spread or fixed commission, the Company reserves the right to increase the
spread in case the spread on the basic contract exceeds the size of fixed spread.

4.4 Order opening.

4.4.1 The obligatory parameters needed for the submitting an order are:

a) Tool name;
b) Trade volume;
c) Order type.

4.4.2 In case of opening an order with the help of the means of the client terminal without using an Expert Advisor,
the Client needs to press the “Buy” or “Sell” button at the moment, when Company’s quotes satisfy and fit the Client.

6
4.4.3 In case of opening an order by the means of the client terminal with the Expert Advisor help, an order should be
generated to perform trade at a current quote.

4.4.4 Order processing for opening:

a) As soon as the Client’s order to open the position comes to the server, an automatic check of the trading
account for free margin for the opening is carried out. If the necessary margin is present, the order is
opened. If the margin is not sufficient, the order is not opened, and the notice about funds absence is created
on the server;
b) In the event of the “Market execution” trading tool type method, a quote for opening an order may differ from
the requested one;
c) The order opening note appears on the log-file of the server, and declares that the Client’s request has been
processed, thus, the order has been opened. Each order that is opened on the trading platform receives a
ticker;
d) The order for position opening submitted for processing before the first quote appears on the trading platform
at market opening, will be declined. In this case the client terminal window will show the “No quote/trading is
forbidden” message. In case if the Dealer processes by mistake a Client request to open an order at the
price of the previous day's closing, the Company is liable to cancel such an order. In such a case the
Company contacts the Client and informs about it.

4.5 Order closing

4.5.1 In the event of closing order by the means of the client terminal without using an Expert Advisor, the Client
needs to press the “Close” button, when the Company’s quotes satisfy and fit the Client.

4.5.2 In order to close the order by the means of the client terminal using an Expert Advisor, the order should be
generated to be closed at a current quote.

4.5.3 The “Stop Loss” and/or “Take Profit” orders may be used for the orders closing.

4.5.4 Order processing for closing:

a) If in the list of open orders on a trading account there are two or more locked positions, then while generating
a request or an order to close any of those, an option “Close by” appears in the dropdown “Type” list. After
choosing it, one or several open positions of the reverse direction appear. After marking the needed position
from the list, a button “Close#...by#...” is activated. By pressing it the Client closes locked positions of equal
volumes or partly closes two locked positions of different volumes. In such a case a smaller position and a
symmetric part of a bigger one close, and a new position in the direction of a bigger one between the two
stays open, thus receiving a new ticker;
b) If in the list of open orders on a trading account there are two or more locked positions, then while generating
a request or an order to close any of those, an option “Multiple Close by” appears in the dropdown “Type” list.
After choosing it, a list of all positions for the given tool appears and a button “Multiple Close By for…” is
activated. By pressing this button the Client closes all locked positions for the tool. In such a case a new
position(s) stays open in the direction of a bigger total volume, which receives a new ticker;
c) Important to note: functions “Close By” and “Multiple Close By” do not operate for the tools with floating stock
spread;
d) When the note about closing a position appears in the log-file, this means that the Client’s order to close a
position has been processed;
e) If an order to close a position has been submitted for processing before a first quote appears at the trading
platform at market opening, such an order shall be declined by the Dealer. In the client terminal window the

7
 “No price” message will appear. The Company is entitled to cancel trade when the Dealer processed the
Client’s order to close a position at a quote of a previous day closing by mistake. In such a case the
Company contacts the Client and informs about it.
f) If a “Market execution” type is used for a trading tool, the quote for closing an order may differ from the
requested one.
g) If you hold a buy position you will receive the dividend as a positive adjustment to your account. If you hold a
sell position there will be a negative adjustment according to the issuing body. Note that when you enter into
a Product you are not trading in and do not own or have any rights to the Underlying Instrument.

4.6 Mandatory position closure.

4.6.1 If Margin level is lower than 30% on the Client account, margin call occurs. The Company is entitled but not
liable to close Client’s positions. Decision to close positions is made only by the server.

4.6.2 The Company is entitled to mandatory closing of Client open positions without prior notification of the latter one,
if a Margin level is less than or equal to zero of the necessary margin for maintaining open positions.

4.6.3 The current account balance is controlled by the server, which in the event of execution of p. 4.6.2 of the
present Agreement generates an order to stop out. Stop out is executed at a current market quote on a first-come
basis with Client orders. Mandatory position closure is noted in the log-file of the server with a notice “stop out.”

4.6.4 If the Client has several open positions, the first position closed is the one with the biggest floating loss.

4.6.5 When after a mandatory position closure the Client account has a negative balance, compensation is added to
the account, which sets the account to zero. However in special cases, e.g. when the Company considers Client’s
actions as intentional, the Company reserves the right to claim a debt payment from the Client.

4.6.6 In case the Company has reasons to believe that a Client operates two or more accounts under different
registration data, meaning the Client opened opposite orders on the same trading instrument that are left open over
the weekend or during the period between trading sessions, Company reserves the right to deduct the losses
exceeding the balance of one account from the funds of another account belonging to a Client.

4.7 Leverage change.

4.7.1 It is impossible to change the leverage if the account is in the trade mode, e.g. when the orders are opened.
This is done for the security reasons and risk minimizations of the Client’s trading operations.

4.7.2 The Company has a right to change leverage on the Client account any time without prior notification, based on
the leverage limit depending on the sum of equity according to the terms and conditions below. The Company has a
right to open positions and to reopen positions as well, with prior notification.

equity 0 - 1000$ -> 1:Unlimited

equity 1001 - 5000$ -> 1:2000
equity 5001 - 20000$ -> 1:1000
equity 20001 - 30000$ -> 1:800
equity 30001 and more -> 1:600

8
4.7.3 In order to minimize Client's risks at the time of market opening on Monday, in case a Client kept open orders
during the weekend, the Company reserves the right to make the leverage lower, and change margin requirements
several-fold.

4.7.4 The leverage for some trading metals, indices and energies at any trading account is set like the following:

up to 1:100 for Stocks

up to 1:500 for Cryptocurrencies.
up to 1:100 Palladium and Platinum;
up to 1:100 Indices, Energies;

5. Margin requirements

5.1 The Client must deposit and maintain the Initial Margin and/or Hedged Margin in the amount
established by the Company at the time the position is opened.

5.2 The client responsible for the full understanding of the Margin and how it’s calculated.

5.3 The Company has the right to change Margin requirements with prior notice to the Client. In this
situation the Company has the right to apply new Margin requirements to the new positions and to the
positions which are already open.

5.4 Lower Margin requirements for a specific Financial Instrument apply to all positions opened for this
Financial Instrument.

5.5 The Company reserves the right to increase the size of Margin requirements, before the close of the
market before weekends and holidays. Information about the time frames during which increased Margin
requirements are in effect is published in the Client's Personal Area and/or on the Company’s Website.
5.6 Increasing the amount of hedging in Market Maker accounts (and for the Underlying Assets that are
subject to Hedged Margin) will result in a reduction of Margin requirements for new hedging orders.

5.7 Reducing the amount of hedging in Market Maker accounts (and for the Underlying Assets that are
subject to Hedged Margin) is treated as opening a new position and will result in a proportional (based on
the amount) change in Margin requirements on previously opened positions for the corresponding financial
instrument.

5.8 The Margin requirements applicable to the different CFDs can be found in the Contract Specifications
section on the Website at If at any time the Equity falls below a certain percentage of the Necessary
Margin, specified in the Contract Specifications section on the Website, the Company has the right to
close any, or all of the Client’s Open Positions without the Client’s consent or any prior Written Notice to
him. In order to determine if the Client has breached this paragraph, any sums referred to therein which
are not denominated in the Currency of the Client Account shall be treated as if they were denominated in
the Currency of the Client Account by converting them into the Currency of the Client Account, at
reasonable exchange rates as the Company will select, having regards to the prevailing market rates.

9
5.9 If a Margin Call notification is sent to the Client Terminal, the Client will not be able to open any new
positions, except where permitted by the Company, hedging position(s) to reduce margin. If the Client fails
to meet the Margin Call, his Open Positions are closed starting from the most unprofitable.

5.10 The Client has the responsibility to notify the Company as soon as he believes that he will be unable
to meet a Margin Call payment when due.

5.11 Margin must be paid in monetary funds in the Currency of the Client Account.

5.12 The Client undertakes neither to create, nor to have outstanding any security interest whatsoever
over, nor to agree to assign or transfer, any of the Margin transferred to the Company.

6. Order Description

6.1. Order types in the Headway trading platforms.

6.1.1. The following order types to open a position (pending orders) may be located in the Headway
trading platform:
a) “Buy Stop” – expects to open a position to buy at a higher quote than the current one at the moment of
an order placement;
b) “Sell Stop” – expects to open a position to sell at a lower quote than the current one at the moment of
an order placement;
c) “Buy Limit” – expects to open a position to buy at a lower quote than the current one at the moment of
order placement;
d) “Sell Limit” – expects to open a position to sell at a higher quote then the current one at the moment of
an order placement. The following orders may be used to close a position:
e) “Stop Loss” – expects to close a previously opened position at a quote less profitable for the Client, than
the current quote at the moment of an order placement;
f) “Take Profit” – expects to close a previously opened position at a quote more profitable for the Client
than the current quote at the moment of an order placement;

6.2. Time of placement and validity period of orders

6.2.1. Placement, modification and removal of orders by the Client shall be performed only during the
period when trading according with the following tool is allowed. Trading hours for each tool are stated in
the tool specifications.

6.2.2. Should irregular market situations occur, the trading with a certain tool may be stopped mandatorily,
till the causes of the closing are removed.

6.2.3. All pending orders as well as orders “Stop Loss” and “Take Profit” for financial tools have the GTC
Status (“Good Till Canceled”) and are accepted for the indefinite periods. The Client is entitled to set the
date and expiration date order validity him/herself, filling the date and time in the fields “Expiry”.

10
6.3. Order placement regulations.

6.3.1. At the moment when the Client submits an order to place the pending orders the following
parameters are to be determined:
a) Name of the tool;
b) Volume;
c) Order type (Buy Stop, Buy Limit, Sell Stop, Sell Limit);
d) Order level.

6.3.2. Additionally to the parameters determined in the Client order, optional parameters may be stated in
the Order, such as the following:
a) Stop Loss level of a pending order. 0.0000 value means that Stop Loss is not placed (or deleted if it had
been submitted earlier).
b) Take Profit level of a pending order. 0.0000 value means that Take Profit is not placed (or deleted if it
had been submitted earlier).
c) Date and time of a pending order validity.

6.3.3. The trading server may decline an order in the following cases:
a) If the value of one or several required parameters is missing or wrong;
b) In such a case if a pending order is placed by means of the client terminal without using an expert
advisor, an error message will appear: “Invalid S/L or T/P”.

6.3.4. When the Client submits an order to place “Stop Loss” and “Take Profit” for open positions the
following parameters are to be determined:

a) Ticker of the open position for which the orders are placed;
b) “Stop Loss” order level. 0.0000 value means that “Stop Loss” is not placed (or deleted if it has been
placed earlier).
c) “Take Profit” order level. 0.0000 value means that “Take Profit” is not placed (or deleted if it has been
placed earlier).

6.3.5. Orders of all types shall not be placed closer than a stated number of points to the current market
quote. The minimum distance in points from the level of a placed order to the current quote (pending order
level) for each tool is stated in tool specifications at the Company website.

6.3.5.1. If the order is executed in irregular market conditions, Stop levels may be increased.

6.3.6. Requests for order closure or modification, in case the current quote is closer to the S/L or T/P
levels of this order than to the “Stop levels” value, will be declined with the commentary as follows:
“Modification disabled. The order is too close to the market” or “No quote”.

6.3.7. Requests to set, modify or delete a pending order, in case the current quote is closer to the S/L or
T/P price of this order than to the “Stop levels” value, will be declined with the commentary as follows:
“Invalid S/L or T/P” or “No quote”.

11
6.3.8. When a note about an order placement appears in the server log-file, it means that the Client order
has been processed and the order is placed.

6.3.9. Every pending order receives a ticker.

6.3.10. If an order for placement is received for processing before a first quote appears in the trading
platform, it will be declined by a trading server. The window “No price/Trading is forbidden” will appear in
the client terminal.

6.4. Orders modification and deletion

6.4.1. When the Client submits an order to modify parameters of pending orders (level of a pending order,
Stop Loss and Take Profit for this pending order) the following parameters are to be defined:

a) Ticker;
b) Order level;
c) Stop Loss order level. 0.0000 value means that Stop Loss is not placed (or deleted if it has been placed
earlier);
A trading server is entitled to cancel an order if a wrong value of one or several parameters has been
given. In such a case a button “Modify” is not activated.

6.4.2. When the Client submits an order to modify Stop Loss and Take Profit orders for the open position,
the following parameters are to be defined:
a) Ticker for an open position;
b) Stop Loss order level. 0.0000 value means that Stop Loss is not placed (or deleted if it has been placed
earlier);
c) Take Profit order level. 0.0000 value means that Take Profit is not placed (or deleted if it has been
placed earlier);

6.4.3. When the Client submits an order to delete a pending order, he/she shall state the ticker of a
deleting order.

6.4.4. When a note about modifying or deleting an order appears in the server log-file, the Client order to
modify or delete an order is considered processed, and an order is considered to be modified or deleted.

6.4.5. A trading server may decline a modification or deletion order if it has been submitted for processing
before a first quote in the trading platform at market opening appears. If a Dealer by mistake processes a
Client order, order modification or deletion may be cancelled. The Client will receive a notification about it
via internal email of a trading terminal.

6.4.6. If three months have passed after a Client has submitted a pending order, and the account has an
insufficient margin level to open the order, the Company has the right to delete the pending order from the
account without prior notice.

12
6.5. Order execution

6.5.1. An order is executed in the following cases:

a) Orders Sell Stop – at the moment, when Bid price in the quote flow is equal or smaller than an order
level;
b) Buy Stop order – at the moment, when Ask price in the quote flow is equal or bigger than an order level;
c) Sell Limit order – at the moment, when Bid price in the quote flow is equal or bigger than an order level;
d) Buy Limit order – at the moment, when Ask price in the quote flow is equal or smaller than an order
level;
e) Take Profit order – for an open buying position, when Bid price in the quote flow is equal or bigger than
an order level;
f) Stop Loss order – for an open buying position, when Bid price in the quote flow is equal or smaller than
an order level;
g) Take Profit order – for an open selling position, when Ask price in the quote flow is equal or smaller than
an order level;
h) Stop Loss order – for an open selling position, when Ask price in the quote flow is equal or bigger than
an order level.

6.5.2. In the cases of price gaps order execution is determined by the following rules:
a) If the "Take Profit" level of a pending order is in the price gap during order opening, once the order is
opened Take Profit settings will be annulled. In such a case a note is added to the comments: (tp
canceled/gap);
b) “Take Profit” order with a level in the price gap is executed at the stated in the order quote; c) “Stop
Loss” order with a level in the price gap is executed at the first quote after a price gap. In such a case a
note is added to the comments (sl gap/ slip);
d) “Buy Stop” and “Sell Stop” pending orders are executed at the first quote after the price gap. In such a
case a note is added to the comments (started gap/ slip);
e) “Buy Limit” and “Sell Limit” pending orders are executed at the stated in them quotes. In such cases a
note is added to the comments (started/gap);
f) in case a price gap is over 300 pips and profit is recorded on it, the Company reserves the right to limit
profit for such an order by 300 pips. In certain cases with small price gaps orders may be executed in the
standard mode as stated in the quotes.
g) Buy and Sell orders are generally executed at the initial quotes after the price gap. In case an order is
executed at a price valid before the price gap, the Company reserves the right to reconsider the order data
and execute it at the initial quotes after the price gap.
h) Buy and Sell orders can be closed at the initial quotes after the price gap.

6.5.3. a) In regular market conditions the order is executed by the Company at the price specified in the
order.

b) If the order is executed in irregular market conditions, the order execution price may differ from the one
specified in the order, either in favor of the Client or not. In this case, the order will be accompanied by the
"slip" comment.

13
6.5.4. In case any two of the following conditions are met simultaneously on the Client's account:
a) Margin level does not exceed the consequent of the leverage ratio currently set on the account;
b) 60% or more of total position volume is placed at one trading tool and in the same direction (sell or buy);
c) This part of the total position has been formed within 24 hours period before the market closes;

The Company is entitled to set “Take Profit” for orders, included in the total position at the Ask price level
of market closing for the tool minus one point (for sell orders) or at the bid price level of the market closing
for the tool plus one point (for buy orders).

7. ​Commissions, swap and other costs

7.1 The Client shall pay to the Company commissions and other costs in the amounts stated in the Trading
Instruments specifications. The Company publishes the size of all the current commissions and other costs at their
website.

7.2 The Company is entitled to change the size of commissions and other costs without prior notification of the Client.
All changes are published on the Company website in the section “Company news” and/or in the trading instruments.

7.3 Swap-free accounts are provided to the Clients on the following terms:

a) Swap-free accounts are available for clients from Muslim countries only, or, in case if needed, may be
optional for other Clients, from other countries;
b) For long-term strategies, when the deal is open more than two (2) days, the Company charges a fixed fee for
the total number of days during which the order was opened. The required fee is fixed and determined as the
value of 1 point of the transaction in US dollars, multiplied by the size of the currency pair swap point of the
deal. This fee is not an interest and depends on whether the deal is open to buy or sell;
c) The company reserves a right to refuse to provide a Client with swap-free services as well as debit the fee
from his or her trading account at any time;
d) Swap-free option is not available for trading on Stocks, "Forex Exotic", Indices, Energies and
Cryptocurrencies;
e) The company has the right to deduct swap-free in the following cases:
- the usage of a swap-free account for performing arbitrage orders;
- the usage of the Carry trade-related strategies;
- a purposeful usage of a swap-free option to make additional profits.

7.4 For opening Stock positions the commission is charged. The commission size for all Stock instruments is 0.35%.

8. Communication between the Client and the Company

8.1 The Company uses the following communication means to contact the Client in any case needed:

a) Internal emails of the trading platform at their sole discretion (from the Company to the Client);
b) Corporate chat that is realized through the Personal Area;

14
 c) Telephone number;
d) Post;
e) Announcements in the related sections of the Company website (e.g. Company news, for example).

To contact the Client the Company has to use the Client references, stated while opening the account or changed,
according to the present Agreement’s regulations.

8.2 The priority means of communication is email.

8.3 Correspondence, such as documentation(s), announcement(s), notification(s), report(s), and others are
considered to be accepted by the Client:

a) An hour after sending it via email;

b) Immediately after sending it via internal email of the trading platform;
c) Immediately after finishing a conversation by the telephone;
d) After seven (7) days since sending it via post;
e) An hour (1) after placing it at the Company website’s sections.

8.4 In order to provide the confidentiality of all trading operations made by the Client, the accesses to the Personal
Area and trading terminals are secured via passwords. The Client shall be responsible for keeping his/her logins or
passwords safe and secure.

8.5 To provide the security for all Clients trading operations, telephone conversations with the Company are recorded
on magnetic or electronic media. Such records are confidential proprietary to the Company and serve as evidence of
orders submitted by the Client.

9. Procedure of consideration and settlement of disputes

and claims
9.1 Procedures of consideration and settlement of disputes and claims for orders.

9.1.1 If a dispute situation occurs, the Client is entitled to make a claim against the Company. Claims are accepted
within two (2) working days since the moment the grounds for a claim appeared.

9.1.2 The Company considers a Client claim in the time period of ten (10) working days. The Client shall hold
negotiations and give answers to all Company requests with the good faith.

9.1.3 The claim from the Client should contain the information 9.1.7, and be sent via email to care@hw.site

9.1.4 All of the Clients’ claims shall be submitted otherwise shall not be considered.

9.1.5 The Claim consideration from the Client is suspended till the Client gives answers to all Company requests.

9.1.6 The Client’s claim shall be rejected and the Client’s accounts may be closed if the following cases occur:

a) Client fails to answer any and/or all requests of the Company within five (5) days from the day they were
received;

15
 b) The Company discovers that the Client was using multiple devices while accessing the Company’s platform
and/or accessing the platform from multiple IPs which would be inconsistent with ordinary Client behavior
and/or would raise suspicion that the Client’s accounts were compromised and/or used by unauthorized
Third Parties;
c) The Company has reasonable grounds to believe that the Client willingly provided access to his accounts to
the Third Parties;

9.1.7 The Client’s claim shall contain the following:

a) Full name;
b) Account number;
c) Date and time when a dispute situation occurred;
d) Ticker of the arguable order;
e) Claim description.

9.1.8 The Company may reject the claim provided by the Client if they do not comply with the p. 9.1.7.

9.2 Procedure of consideration of claims against service quality.

9.2.1 If the Client has a claim against the service quality, he/she may inform the Customer Care department
care@hw.site, and the customer care department will forward the complaint to specialists.

9.2.2 The time period for considering a claim against service quality is ten (10) working days. According to the results
of the examination a letter notifying about the results of examination shall be sent to the Client contacts in the
Personal Area which were stated while opening the account. If the documents or other ID issues are changed, the
Client should notify the Company about that via the email.

9.2.3 The Client’s claim shall contain the following:

a) Full name;
b) Account number;
c) Date and time when a dispute situation occurred;
d) Name of a service support department who the Client was talking to;
e) Communication method (telephone number, Life Chat via the Personal Area, corporate chat at the company
website, other communication methods, mentioned in p. 8.1);
f) Situation description and the essence of a claim.

9.3 Source of information to prove validity of claim.

9.3.1 Server log-file is the main source of information while considering dispute situations. Information on the server
log-file has absolute priority over other arguments while considering a dispute situation, including information at the
client terminal log-file.

9.3.2 If the server log-file does not contain the corresponding note proving Client intentions, it can be a basis to hold
a claim invalid.

9.4 Compensation payment.

9.4.1 If the Client's claim is proven, settlement is executed only in the form of compensation payment added to the
Client trading account.

16
9.4.2 The compensation shall not compensate for the profit not received by the Client in the event that the Client had
an intention to perform some action but has not performed it for some reason.

9.4.3 The Company shall not compensate for non-pecuniary damage to the Client.

9.4.4 The Company adds a compensation payment to the Client trading account within one (1) working day from the
moment of making a positive decision on the dispute situation.

9.5 Cases of rejection to consider a claim.

9.5.1 The dispute situations not stated in the present Agreement are considered by the Company according to the
universal best practice as not acceptable.

9.5.2 The claim situations against not processed orders submitted during server scheduled maintenance are not
accepted. Provided notification about such maintenance has been sent to the Client via internal email of the trading
platform or via any other means according to the p. 8.1 of the present Agreement. Non-receipt of such a notification
is not a ground for making a claim.

9.5.3 The claim against time period of order execution are not accepted regardless of time a Dealer needed to
execute an order, and regardless of time when a notice about an order execution appeared in the server log-file.

9.6 In case if the order of the Client be open, closed or changed due to the off-market quote, the Company reserves
the right to return the order status before spike.

10. Risks

10.1 The Client confirms that he/she is notified about risks related to performing trading operations at the world
financial markets, including the risks from the following points below.

10.2 Leverage risk.

10.2.1 The Margin level is recommended to be at the 100% and higher, as well as always submit Stop Loss orders to
eliminate possible losses.

10.2.2 While performing the trade on the conditions of “Margin trading,” a relatively small change of rate may strongly
influence the Client trading account balance due to the leverage effect. In the event of a market movement against
the Client position, he/she can bear loss in the amount of the initial deposit and any other additional funds deposited
to support open orders. The Client is fully liable for consideration of all risks, use of financial tools and a choice of the
relevant trading strategy.

10.2.3 The Client should acknowledge that he runs a risk of incurring partial losses or all his/her initial capital as a
result of the purchase and/or sale of any financial instrument. The Client accepts that he is willing to undertake this
risk and agrees that he/she will not be able to refund lost funds.

10.3 Risk of financial tool volatility.

17
10.3.1 A wide range of tools has great change of rates during the day that implies high probability of receiving profits
as well as bearing losses for trading due to the volatility of the rate.

10.4 Technical risks.

10.4.1 The Client accepts risks of financial losses due to a failure of information, communication, electrical and other
systems from the Client side.

10.4.2 During trading by means of the client terminal the Client accepts the risks of financial losses, which might
occur due to:

a) The failure in the hardware, software, and bad quality of connection from the Client side;
b) The malfunctioning of the Client equipment;
c) The wrong settings of the client terminal;
d) The not a timely update of the client terminal version;
e) The lack of the Client knowledge about the instructions, described in the support installed in the Terminal.

10.4.Risk of irregular market conditions.

10.4.1 The Client accepts that in the market conditions different from regular, the time of processing Client orders
may increase, the spread may be widened, and also the execution quote may differ from quotes in the flow.

10.5. Risk of technical peculiarities of the trading platform.

10.5.1 The Client accepts that in the queue of orders on the server there can be only one order. An attempt to submit
any new order will be rejected and in the order window a notice will appear “Order is locked”.

10.5.2 The current rates for the underlying assets are those calculated by the Company on the basis of the quotes
received by the Company. All issues regarding the market prices determination lie within the sole cognizance of the
Company.

10.5.3 The Client unconditionally accepts the quotes provided by the Company to its Clients as exclusively correct;
no claims about the quotes provided by the Company being different from the quotes of other sources can be
accepted for consideration.

10.5.4 The Company reserves the right to reconsider the provided quotes for any time period if, according to the
Company, such quotes fall within the definition of an “Off-market quote”, and/or “Irregular market conditions”, and/or
an “Obvious error” defined in the present Agreement and/or in the “Terms and definitions” section, and revise the
financial results of the trading operations executed at such quotes.

10.5.5 The Client accepts that closing a window of submitting or modifying or removing an order as well as the
window of opening/closing an order does not cancel the order which has already been submitted to the Dealer for
processing.

10.5.6 The Client accepts the risk of performing unplanned trading operations in the event of submitting an order a
second time before receiving information about the results of a previous order processing by the Dealer.

10.5.7 The Client accepts that in the event of submitting a pending order or Stop Loss and/or Take Profit orders for
the level, equal to the current quote in the quote flow, an order will be executed only in the event when a new tick
towards an order actuation will occur.

18
10.5.8 The Client agrees that trading operations using additional functions of the Client Trading Terminal such as
Trailing Stop and/or Expert Advisor and/or any other automated processes are executed completely under the
Client’s responsibility, as they depend directly on his trading terminal and the Company bears no responsibility
whatsoever.

10.5.9 The Client agrees that trading operations using additional functions of the Client Trading Terminal such as
Trailing Stop and/or Expert Advisor and/or any other automated processes are executed completely under the
Client’s responsibility, as they depend directly on his trading terminal and the Company bears no responsibility
whatsoever.

10.6 Risk of communication failure.

10.6.1 The Client acknowledges and is warned that unencrypted information sent via e-mail is not protected from
unauthorized access.

10.6.2 The Client agrees that the Company has the right to delete messages received by the Client through an
internal mail of the client terminal within three (3) calendar days since the moment of the message sending.

10.6.3 The Client is fully liable for keeping confidential information received from the Company and accepts risks of
any financial losses caused by unauthorized access of third parties to the trading account.

10.7 Risk of transaction processing delay.

10.7.1 The Client accepts all the risks of financial losses due to any transaction processing delays on the side of the
payment systems.

10.7.2 In case of such transaction processing delay, the Client is fully liable for consideration of all risks related to
insufficient balance on the trading account and has the option of processing the payment via an alternative payment
system.

10.8 Risk of force majeure circumstances.

10.8.1 The Client accepts the risks of financial losses caused by force majeure circumstances, including the ones
from the p.10.

11. Force majeure circumstances

11.1 None of the Parties shall be liable for its partial or complete failure to meet its commitments in case it is caused
by force majeure events like: civil unrest, war, insurrection, international intervention, governmental action including,
without any limitation, exchange controls, forfeitures, nationalizations, devaluations, natural disasters, acts of God,
and other inevitable events, not depending on the will of any of the Parties.

11.2 The Party which due to force majeure events cannot meet its obligations or commitments, shall inform the
counterparty about it in written form during five (5) days after the aforementioned events have occured.

19
11.3 The facts mentioned in this notification must be confirmed by a proper authority or an organization of the Party’s
country of residence. Failure to notify the other Party on the time shall not be considered a basis to release the Party
from the responsibility.

11.4 In case of the impossibility to meet the Party’s obligations and commitments that last over six (6) months, the
signed Agreement shall be canceled.

12. Changes to Agreement

12.1 The Client is notified that this Agreement may be modified when the specific situation or circumstance will need
that.

12.2 The Client will also have to accept the changes in the updated Agreement.

13. Acceptance
12.1 With opening an account in the Company the Client agrees or confirms or accepts the present Agreement in its
entirety.

20