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Legal Disclosures

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DISCLOSURES ON POTENTIAL CONFLICTS OF INTEREST

1. CFD and Liquidity Provider

CFD,i.e. Contract for Difference, is a financial instrument which is commonly traded “Over The Counter” (“OTC”), and as such, traded with the counterparty, a “Liquidity Provider”, and not through an exchange. The Liquidity Provider is a professional participant in the financial market, who continuously offers
purchase and sales prices for a financial instrument in order to buy and sell respectively in the event of interested clients.

SpotOption Exchange Ltd (“SOX”) acts as the Liquidity Provider in respect to [BROKER] Positions and responsible for the execution of the [BROKER] orders while acting as counterpart to its positions. The [BROKER] remains fully liable towards its Client, in any aspect except for the execution that is being done by its counterpart.

SOX acts as principal to the [BROKER] positions and its potential profits arise from the financial instrument spread but also from the difference between the [BROKER] winning and losing positions.

SOX may hedge all or partial of its trading flow with an external source such as other liquidity providers.

Remuneration of [BROKER] and conflict of interest

In accordance with section 29 of the Cypriot Investment Services and Activities and Regulated
Markets of 2007 (“the Law”) and in light of the above, we hereby wish to clarify as follows:

- [BROKER] remuneration is based on percentage of the trading volumes and the additional
discretionary commission paid by SOX based on the quality of the flow;
Due to the concern that a potential conflict of interest may arise, [BROKER] is taking all
appropriate measures to mitigate this concern, including, but not limited to a strict remuneration
policy that applies on all of the client facing personnel, intended to ensure they will act for the
benefit of the client and in full compliance with the Law, and various supervisory and monitoring
measures.

Last update: February 2018

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