APPLICATION PACK INSIGHT CAPITAL STRATEGIES LIMITED

Transcription

1 APPLICATION PACK INSIGHT CAPITAL STRATEGIES LIMITED

2 In order to open an account with Insight you must read and complete as appropriate the following documents which are included in this Application Pack: 1. CUSTOMER AGREEMENT 2. NOTICE OF OPT UP 3. RISK WARNING Please read these documents carefully and complete ALL SECTIONS in full using BLOCK CAPITALS. In addition, you will require to open a trading account with one of our selected broking partners and complete the appropriate Authorisation of Agent form, which allows Insight to manage the account on your behalf. We will be delighted to assist you in opening an account as required. Lastly, Insight clients must complete our Client Suitability Assessment which can be found at

3 CUSTOMER AGREEMENT INSIGHT CAPITAL STRATEGIES LIMITED

4 CLIENT AGREEMENT (Elective Professional Client) Introduction This client agreement ( the Agreement ) is the agreement between you, the Client, and Insight Capital Strategies Ltd ( INSIGHT ), which represents H2O Markets Limited, the Investment Manager. You should read it and ensure that you understand it. You should retain a copy for your records. We will provide hard copies of this agreement or any document related to it on request. A Glossary of terms used in the Agreement is included at the end. You will be asked to confirm your acceptance of this agreement when completing the Insight Client Application Form. Risk Warning The Managed Account Service uses leveraged products and strategies. These can increase the profits accruing to your Account in respect of winning trades but may equally increase the losses accruing to your Account in respect of losing trades. There are also costs inherent in leveraged trading which include financing charges and which may also increase losses and costs on your Account. INSIGHT will exercise due skill, care and diligence in the execution of its duties to minimise the risk of losses but such losses could extend to, or even in some cases exceed, a sum equal to the whole of your deposit. INSIGHT may apply stop losses to positions on the Account at levels calculated to minimise a situation where losses exceed your deposit. The effectiveness of such stop losses cannot be guaranteed. The Insight Client Application Form contains a set of questions designed to ensure that you understand the product you are buying and that this product is suitable for you. You must read the risk warning notice below and ensure that you have understood it before you enter into this Agreement. By signing the Insight Client Application Form you warrant to INSIGHT that you have read and understood the risk warning notice. Clients should be aware of the following Risk Warnings: Past performance is no guarantee of future performance and you may not get back the amount you invest. The value of investments and the income from them may go down as well as up and are not guaranteed. CFDs and Spread Bets are highly leveraged products and carry a high level of risk to your capital. Due to the leverage offered it is possible for you to incur losses in excess of your initial margin. These products are not suitable for all investors so please make sure that you understand the risks involved. You should not trade with capital you cannot afford to lose. The level and bases of, and reliefs from, taxation may change in the future. Rates of exchange may cause the value of investments to go up or down. Scope The Managed Account Service is only available in conjunction with your Contract for Difference (CFD) or spread betting account ( the Account ) with one of our broking partners and accordingly this Agreement will only take effect when you have signed an account opening agreement with that partner ( the Account Agreement ). By completing this application form you permit us to open a dedicated INSIGHT account on your behalf with our selected broking partner. It should be noted however that the broking firms have a number of criteria which must be met by any applicant before an account can be opened and reserve the right to reject any applicant with whom they are not entirely satisfied. In addition to the broking firms normal account opening documentation, you will be required to execute an agency agreement empowering INSIGHT, and only INSIGHT, to issue instructions on the Account. It is a requirement that you sign this document; without it, INSIGHT will be unable to arrange for the management of the Account. About INSIGHT We are Insight Capital Strategies Limited, a company registered in Scotland (company number SC464384) and an Appointed Representative of H2O Markets Limited, which is authorised and regulated by the Financial Conduct Authority (FRN ). You may contact INSIGHT by writing to INSIGHT at 29 Park Circus, Glasgow, G3 6AP; by telephoning INSIGHT on +44 (0) ; or by ing info@insightcapitalstrategies.com. Unless we agree otherwise with you in writing, all communications with INSIGHT must be in English. We are covered by the Financial Services Compensation Scheme. In the event that you have a claim against INSIGHT which INSIGHT is unable to pay in the event of our default, you may be able to claim compensation. The Financial Services Compensation Scheme covers you up to a maximum of 50,000 for any one claim. About You We accept you as a client based on the information you provide in the application form. No person shall have any rights under this Agreement unless their identity has been fully disclosed to INSIGHT in the application form. Neither shall INSIGHT have any fiduciary or other responsibility towards such a person. In accordance with the rules of our regulator, INSIGHT has categorised you as a Professional Client (Elective Professional Client) as defined in in COBS 3.5.3R of the FCA rulebook. In order to do so, INSIGHT has followed the procedure set down in that section of the FCA rulebook. You agree that we may contact you using any contact details that you have provided to INSIGHT at any reasonable time to discuss this service or any other service which we believe would be of interest to you. The Managed Account Service INSIGHT will arrange for the provision of a Discretionary Account Management service in respect of your Account. In doing so, we shall have absolute discretion on your behalf to arrange any transaction which the broker offers to undertake under the Account Agreement. You agree that you will neither place nor permit any person other than INSIGHT to place transactions on the Account. You understand and agree that many of the transactions offered by the broker relate to over-thecounter contracts, which will not be traded on any exchange or regulated market. Unless you notify INSIGHT otherwise in writing, we will proceed on the basis that the Account represents only a part of a well balanced portfolio and that you are prepared to accept a high level of risk in the pursuit of absolute gains on the Account.

5 Contracts for Difference and Spread betting carries a risk to your capital. You must read and ensure that you have understood the risk warning notice which forms part of this agreement. You agree to contact INSIGHT immediately if at any time you feel that you do not fully understand the risks involved in this service. Your investment objectives shall not be deemed breached as a result of changes in the value of the portfolio brought about solely through market movements. Client Money INSIGHT is not authorised by the FCA to hold or control client money. You must therefore ensure that any money is sent directly to the broker in accordance with the Account Agreement. Any withdrawal instructions should also be addressed to the broker. However, you should note that in accordance with this Agreement, a notice period of one week is required for any withdrawal. This will allow INSIGHT to unwind any open positions on your account on an orderly basis prior to your broker processing the withdrawal. Execution When INSIGHT undertakes transactions on your behalf, we will take reasonable steps to ensure the best possible outcome for you. We believe that the most important factors to you are: The status of the contract as a derivative. The overall costs involved in the contract. The ability to use profits on open contracts as collateral to cover losses or margin requirements on other open contracts. Fair treatment compared to other clients of INSIGHT. All orders will be aggregated. This means that our broking partners will agree a single price for the entirety of all client orders. In individual cases, this may work for you or against you. However, we believe that this is the only way of ensuring that all clients are fairly treated. We will review our order execution arrangements regularly, at least annually, to ensure that they are providing the best outcome for our clients. Conflicts of Interest We have designed our fee structure so that our profits will be maximised when yours are. We believe this substantially aligns your interests and ours. Nevertheless, there may be times in the course of our relationship when our interests and yours will not be aligned. To protect your interests, we have implemented a range of policies designed to manage any conflicts that may arise. A summary of these will be made available to you on request. Valuations The broker shall send you statements of the Account in accordance with the Account Agreement. These shall show all transactions entered into on the Account since the previous statement and the net value of the Account as at the statement date. You may also view the Account on-line at any time using the login details supplied to you. The Charges Our charges are straightforward:- We will charge a performance fee of 25% of any profits made above the high water mark on the Account for each year in which profits are made. The performance fee shall be calculated on new profits generated up to the relevant month end from the time of the Initial Deposit into the Account or from the previous relevant month end. The performance fee is only payable to the extent that the value of the account exceeds the high water mark, i.e. the highest valuation achieved at any previous relevant period end, after taking account of any deposits or withdrawals. You authorise the broker to pay all charges due directly to INSIGHT from the Account. We will send you an invoice when the charges are deducted. If you do not agree with the invoice, you should contact both the broker and INSIGHT as soon as possible. You will also be liable for any charges on the Account arising under the Account Agreement. Details of any 3rd party payments made by Insight to introducers are available on request. In keeping with standard practice in the industry, INSIGHT also receives a rebate on the spread and financing charge in relation to client trades. Details of these are available on request. Deposits, Withdrawals and Termination The Initial Deposit may be in 1,000 multiples subject to a minimum investment of 10,000. Further Deposits may be of any amount, subject to being a minimum of 1,000 and may be made into the Account at any time and will become eligible to be used to finance transactions as soon as value for the deposit is received into the Account. Notice of withdrawal from the Account or closure of the Account may be given by you at any time in which case all positions (or in the case of a partial withdrawal the necessary positions) will be closed down on the same day, or exceptionally if we in our absolute discretion believe it to be in your best interests, within 5 business days including the day that notice is given. Payment to you in respect of any withdrawal from the Account or closure of the Account will be made not later than one week after notice of the withdrawal or closure is received by INSIGHT. The performance fee is only payable to the extent that the value of the account exceeds the high water mark, i.e. the highest valuation achieved at any previous relevant quarterly period end. Withdrawals may be made of any amount, subject to the minimum value for an Account, 10,000, being maintained. In the event that you request a withdrawal which would reduce the value of the Account below this level, we may at our discretion, choose to close all positions on the Account and terminate this Agreement. Managed Spread Betting & CFD Service Variation, Assignment, Discontinuation You agree that INSIGHT may discontinue the service for any reason at any time. In the event that INSIGHT does this, we will write to you notifying you of the decision. The Account will then be closed on the same basis as if you had given INSIGHT notice of closing of the Account at the time that we gave notice of closing to you.

6 You agree that INSIGHT may vary any of the terms of this agreement at any time by written notice to you. We will give you at least 30 days notice of any such change. INSIGHT may assign any or all of its rights or obligations under this agreement to any other entity properly authorised and regulated by the FCA for the purpose. Exclusion of Liability You acknowledge that markets can fall or rise and that INSIGHT can offer no guarantee or warranty as to the performance of the Account. Any representation that INSIGHT may make or has made about the tax treatment of any product is based on our understanding of current tax law. However, the tax implications may vary depending on your circumstances and may be subject to change. You will be liable for any and all taxes arising from profits generated on the Account. INSIGHT will not be liable for any errors of fact or judgment or any action lawfully taken or omitted to be taken in providing the services under this Agreement except through its negligence, fraud or wilful default. We shall not be liable for any loss of opportunity whereby the value of the Account might have risen nor for any decline in the value of the same unless the loss is a direct result of our negligence, fraud or wilful default. Jurisdiction and Complaints You agree that this agreement shall be construed in accordance with the laws of Scotland. You agree that any dispute may only be resolved in the Scottish courts. In the event that you are dissatisfied with INSIGHT s service in any way, you should in the first instance contact our Compliance Officer, compliance@insightcapitalstrategies.co.uk detailing your concerns. We will seek to address any issues as quickly as reasonably possible. Personal Details, Representations and Warranties You represent and warrant that any and all information that you provide to INSIGHT about yourself is true and complete. You undertake to promptly advise INSIGHT of any changes to your personal details. You represent and warrant to INSIGHT that all cash or other assets transferred to the broker for credit to the Account are your sole and beneficial property and free and clear of any lien, charge or other encumbrance. Indemnities and Liability We accept no liability to you for any consequential loss or indirect loss, loss of profits or damage save in the case of fraud, wilful default or gross negligence on behalf of INSIGHT. A single or partial exercise of, or failure or delay in exercising, any right either under this Agreement or at law by INSIGHT shall not constitute a waiver by INSIGHT of, or impair or preclude any exercise or further exercise of that or any other right arising under this Agreement or at law. We shall have no liability to you for any consequential loss, indirect losses, loss of profits, loss of opportunity (including in relation to subsequent market movements) that you might suffer as a result of any defect or failure of the whole or any part of our telecommunications system, website, or internet trading website ( the Website ), including when all of our trading lines are busy. Should INSIGHT allow you access to the Website, this and any materials provided in connection with the Website are intended for your use only, are provided on a non-exclusive basis, and remain the property of INSIGHT and its internet providers at all times and you therefore have no rights to the ownership, copyright, or protected intellectual property rights of any software employed by the Website. Should you choose to access the Website, you agree to take steps to ensure that the hardware and software that you employ to access the Website does not introduce any form of computer virus, (including, but not limited to, software bombs and worms ) into the Website and you agree to indemnify INSIGHT for any loss that we may suffer as a consequence of such introduction. You acknowledge that the broker is not acting in the role of Investment Manager or Advisor and is only providing execution and statement services and a range of administrative and support services. In allowing you to access the Website INSIGHT makes no warranties (express or implied), representations or guarantees as to the fitness, suitability or merchantability of its content, documentation or any hardware or software provided by INSIGHT in connection with, or which forms part of, the Website. Neither INSIGHT nor its employees will be liable for any loss, cost, expense or damage whatsoever which may arise directly or indirectly as a result of any technical difficulties which you may experience in connection with the Website and which may lead to, but not be limited to, malfunctions, failures, delays, hardware damage or software erosion and could possibly lead to economic and/or data loss as a result of installing, attempting to access, accessing, using, maintaining, modifying or deactivating the Website or otherwise including arising out of the negligence of INSIGHT and/or if INSIGHT had been advised of the possibility of the same arising. Nor shall INSIGHT be liable for the introduction of any form of computer virus, (including, but not limited to, software bombs and worms ) into your computer hardware or software as a result of connection to the Website on the proviso that INSIGHT has taken reasonable steps to prevent any such introduction. INSIGHT does not effect insurance in respect of the liabilities limited and/or excluded under this Agreement. If you find this unacceptable, you should either refrain from dealing with INSIGHT or take steps to insure yourself in respect of those matters. You will indemnify INSIGHT and keep INSIGHT indemnified on demand in respect of all liabilities, costs, claims, demands and expenses of any nature whatsoever which INSIGHT suffers or incurs as a direct or indirect result of any failure by you to perform any of your obligations under this Agreement or under any bet and by signing this Agreement you acknowledge that you are not entitled to assign, transfer, charge, sub-contract or deal in any other manner with this Agreement nor any of its rights or liabilities hereunder (including any interest in balances, open positions or collateral), or purport to do any of the same.

7 By signing this Agreement you acknowledge that the taxable status of any bets that INSIGHT place on your behalf will be dependent on your personal circumstances and may be subject to variation, and therefore it is your responsibility to seek independent tax advice if you are in any doubt as to your liability to pay tax on bets placed on your behalf. You also agree that in the event that taxes become due and payable in relation to any bet placed on your behalf you will be responsible for the full payment of such taxes. In the event that INSIGHT is obliged, for whatever reason, to pay your personal liability with regard to such taxes you will fully indemnify INSIGHT against the same. & CFD Service In this Agreement, unless the context otherwise requires:- the clause headings shall not affect the interpretation and are for ease of reference only, use of the singular includes the plural and vice versa; the use of any gender includes the other genders; any phrase introduced by the terms "including", "include", "in particular", "for example" or the letters "e.g." or any similar expression shall be construed as illustrative and shall not limit the sense of the words that precede it. Each clause and part of a clause in this Agreement is separate and severable and enforceable accordingly and should any clause, either in whole or in part, of this Agreement be found to be invalid or unenforceable by any court or administrative body of competent jurisdiction, such invalidity or unenforceability shall not affect either the remaining part of the affected clause or the other clauses which shall retain their full force and effect. The rights contained within this Agreement that are in favour of INSIGHT are cumulative and are without prejudice to and are not exclusive of any rights or remedies provided by law. This Agreement and all business transacted between, with or for you shall be governed by, and shall be construed in accordance with, the laws of Scotland and the parties submit to the non-exclusive jurisdiction of the Scottish courts. Nothing within this Agreement shall restrict or exclude any liability or duty owed by INSIGHT to you under the rules of our regulator. In the event of conflict, the rules of our regulator shall prevail over this Agreement. GLOSSARY Account Account Agreement Agreement Deposit The Broker FCA Further Deposit InitIal Deposit INSIGHT Investment Manager Managed Account Service Our / our We / we Website The spread betting account which you have opened with the broker. The agreement that you have entered into with the broker in relation to the Account and which will be managed by the Investment Manager in accordance with this Agreement. This agreement. The aggregate sum that has been paid by you into the account less any withdrawals. Our Selected Broking Counterparty. Financial Conduct Authority Any sum paid by you into the account subsequent to the Initial Deposit. The first sum paid by you into the account as a result of which the account is opened. Insight Capital Strategies Limited H2O Markets Limited The service arranged by INSIGHT on behalf of the Investment Manager to manage the account in accordance with this Agreement. INSIGHT INSIGHT The internet trading website set up by the broker.

8 Please complete ALL SECTIONS in full using BLOCK CAPITALS. Title (Mr, Mrs, Miss, Other) Surname Forename(s) Date of Birth Residential Address Postcode Tel (day) Tel (Mobile) Initial Investment amount I confirm that I have read and agree to the terms of the Insight Client Agreement and Risk Warning. Signed by the Applicant: Date SUBSCRIPTION CHECKLIST Please ensure that the following information has been provided. Have you provided the necessary money laundering documentation? Have you completed and signed the Customer Agreement? Have you completed the Client Suitability Assessment? Have you signed the ICS Notice of Opt Up? Have you opened an account with one of our selecting broking partners? Have you completed and signed the relevant Appointment of Agent form? Contact Details For further information please contact: Paul Johnston Insight Capital Strategies Limited Telephone No:

9 NOTICE OF OPT UP INSIGHT CAPITAL STRATEGIES LIMITED

10 NOTICE OF OPT UP I/We hereby request to be classified as an Elective Professional Client and treated accordingly. I/We understand that in order to qualify as an Elective Professional Client under the provisions of the Markets in Financial Instruments Directive (2004/39/EC) (MiFID). I/We must satisfy at least 2 of the following 3 criteria: 1. I/We have carried out transactions, in significant size, on the relevant market at an average frequency of 10 per quarter over the previous 4 quarters; 2. The size of my/our financial investment portfolio, defined as including cash deposits and financial instruments, which exceeds 500,000; 3. I/We work or have worked in the financial sector for at least one year in a professional position, which requires knowledge of the transactions or services envisaged. I/We understand that Insight Capital Strategies is expected to carry out a quantitative assessment of my/our expertise, experience, and knowledge, in order to be reasonably assured that, in light of the nature of the transactions or services envisaged, I/we am/are capable of making my/our investment decisions and understanding the associated risks involved, and that Insight Capital Strategies is entitled to deny this request if it is not satisfied with its findings. CLIENT DECLARATION: I hereby declare that I/we satisfy that at least two of the three criteria listed above. I confirm that I wish to be treated as an Elective Professional Client. I have read and understood the written warning below from Insight Capital Strategies regarding the protections and compensation rights that I may lose and I am aware of the consequences of losing such protections. In particular, I will not benefit from the additional protections for retail clients, whereby firms must: Ensure that all information addressed to clients satisfies a number of conditions designed to ensure that that it is fair, clear and not misleading. Provide the appropriate information to clients about the firm and its services, about the safeguarding of financial instruments or funds held for clients and about costs and associated charges. Enter into a written client agreement setting out the essential rights and obligations of the firm. Obtain information about the clients experience and knowledge when assessing whether any transactions recommended to clients are suitable for them or whether certain other transactions are appropriate for clients to enter into. Comply with more extensive reporting obligations in respect of the execution or orders, portfolio management and contingent liability transactions. Inform clients about any material difficulty, which impacts the firm s ability to properly carry out orders. RISK WARNING The value of investments can go down as well as up and you may not necessarily get back the amount you invested. Specifically CFDs, Spread Betting and Foreign Exchange (Forex or FX), involve a high level of risk and you can lose more than your original investment and in some cases you may be liable for a greater amount than originally invested. You should be aware that due to the leverage involved losses can mount rapidly and substantially. Only speculate with money you can afford to lose. This is not suitable for everyone so please ensure you fully understand the risks involved and if required please seek independent financial advice. To view our full risk warning, please speak to your point of contact and request that one be either ed or posted to you in hard copy, alternatively you can view it on our website at risk_warning.pdf Please sign below to confirm your understanding of the above and to confirm that you wish to be treated as an Elective Professional Client. Name: Signature: Date: *For more detailed information please review:

11 RISK WARNING INSIGHT CAPITAL STRATEGIES LIMITED

12 RISK WARNING Before trading Contracts for Difference, Spread Bets or Foreign Exchange (ForEx or FX), please ensure you fully understand the risks involved. These products may not be suitable for all types of investor. Trading in Contracts for Difference / Spread Bets / FX carries a high degree of risk and is generally considered suitable only for the more experienced investor. Leveraged products carry a high degree of risk to your capital, and in some circumstances you may be liable for a greater sum than your initial capital invested. You should be aware that due to the leverage involved losses can mount rapidly and substantially. You should only speculate with money you can afford to lose. Past performance is not a guide to future performance. Please seek independent financial advice if you are unsure about your investment. These products are suitable only for people over the age of 18. Information and analysis produced by Insight Capital Strategies does not constitute a recommendation or offer to make a transaction in any derivatives or securities, and is intended to be general in nature. Insight Capital Strategies Limited is an appointed representative of H2O Markets Limited which is authorised and regulated by the Financial Conduct Authority (FRN ). It is imperative that the potential investor understands past performance of any investment is not necessarily a guide to future performance. The value of shares or income from them may go down as well as up. The value of shares may rise as well as fall due to the volatility of world markets, economic conditions/data and/or changes in the rate of exchange in the currency in which the investments are denominated. You may not necessarily get back the amount of capital you invested and as mentioned above you could be liable for an additional sum to balance your losses. If you are in any doubt about investment or the mechanics of such products, you should seek independent financial advice. Risk Disclosure Notice This notice is provided to you in compliance with the rules of the Financial Conduct Authority (FCA). If you are a retail client you are afforded greater protections than other customers, and you should ensure that your sales trader tells you what these are. This notice does not disclose all of the risks and other significant aspects of derivative products such as futures, options and contracts for differences. You should not deal in derivatives unless you understand the nature of the contract you are entering into and the level of your exposure to risk. You should also be satisfied that the contract is suitable for you in the light of your circumstances and financial position. Certain strategies, such as a "spread" position or a "straddle", can be of equivalent risk to a standard "long" or "short" position. Whilst derivative instruments can be utilised for the management of investment risk, some investments are unsuitable for many investors. Different instruments involve different levels of exposure to risk, and in deciding whether to trade in such instruments you should be aware of the following points. Futures 1. Transactions in futures involve the obligation to make, or to take delivery of the underlying asset of the contract at a future date, or in some cases to settle your position with cash. They carry a high degree of risk. The "gearing" or "leverage" often obtainable in futures trading means that a small deposit or down payment can lead to large losses as well as gains. It also means that a relatively small market movement can lead to a proportionately much larger movement in the value of your investment, and you should be aware that this can work against you as well as for you. Futures transactions may have to be margined, and you should be aware of the implications of this, which are set out in paragraph (6) below. Options 2. There are many different types of options with different characteristics subject to different conditions:

13 Buying options Buying options involves less risk than selling options because, if the price of the underlying asset moves against you, you can simply allow the option to lapse. The maximum loss is limited to the premium plus any commission or other transaction charges. However, if you buy a call option on a futures contract and you later exercise the option, you will acquire the future. This will expose you to the risks described under "futures" and "margined transactions". Writing options If you write an option, the risk involved is considerably greater than buying options. You may be liable for margin to maintain your position and a loss may be sustained well in excess of any premium received. By writing an option, you accept a legal obligation to purchase or sell the underlying asset if the option is exercised against you, however far the market price has moved away from the exercise price. If you already own the underlying asset which you have contracted to sell (known as "covered call options") the risk is reduced. If you do not own the underlying asset (known as "uncovered call options") the risk can be unlimited. Only experienced persons should contemplate writing uncovered options, and then only after securing full details of the applicable conditions and potential risk exposure. Contracts for differences 3. Futures and options contracts can also be referred to as contracts for differences. These can be options and futures on the FTSE-100 index or any other index or share, as well as currency and interest rate swaps. However, unlike other futures and options, these contracts can only be settled in cash. Investing in a contract for differences carries the same risk as investing in a future or an option and you should be aware of these as set out in paragraphs (1) and (2) respectively. Transactions in contracts for differences may also have a contingent liability and you should be aware of the implications of this as set out in paragraph (6) below. You should be aware that when trading CFDs, at no stage will you own the underlying asset. Foreign Exchange (FX) 4. Transactions in Foreign Exchange contracts carry a high degree of risk. The "gearing" or "leverage" used in Foreign Exchange trading means that a relatively small market movement can lead to a proportionately much larger movement in the value of your liability. You should be aware of the implications of this, in particular the margining requirements which, by accepting below, will be confirmation by you that this has been explained to you by the broker or a broker introducing your account to the broker. You should note that when trading FX, at no stage will you take any physical delivery of currency. Off-exchange transactions 5. It may not always be apparent whether or not a particular derivative is effected on exchange or is an off-exchange derivative transaction. While some off-exchange markets are highly liquid, transactions in off-exchange or "non transferable" derivatives may involve greater risk than investing in on-exchange derivatives because there is no exchange market on which to close out an open position. It may not be possible to liquidate an existing position, to assess the value of the position arising from an off-exchange transaction or to assess the exposure to risk. Bid and offer prices need not be quoted, and, even where they are, they will be established by dealers in these instruments and consequently it may be difficult to establish what is a fair price. The potential for profit or loss from transactions in foreign currency denominated contracts will be affected by fluctuations in foreign exchange rates. Foreign markets 6. Foreign markets will involve different risks from UK markets. In some cases the risks will be greater. The potential for profit or loss from transactions on foreign markets or in foreign denominated contracts will be affected by fluctuations in foreign exchange rates.

14 Contingent liability transactions 7. Contingent liability transactions which are margined require you to make a series of payments against the purchase price, instead of paying the whole purchase price immediately. If you trade in futures, contracts for differences or sell options you may sustain a total loss of the margin you deposit with your dealer to establish or maintain a position. If the market moves against you, you may be called upon to pay substantial additional margin at short notice to maintain the position. If you fail to do so within the time required, your position may be liquidated at a loss and you will be liable for any resulting deficit. Even if a transaction is not margined, it may still carry an obligation to make further payments in certain circumstances over and above any amount paid when you entered into the contract. Contingent liability transactions which are not traded on or under the rules of a recognised or designated investment exchange may expose you to substantially greater risks. Collateral 8. If you deposit collateral as security with your dealer, you should ascertain from your dealer how your collateral will be dealt with. Deposited collateral may lose its identity as your property once dealings on your behalf are undertaken. Even if your dealings should ultimately prove profitable, you may not get back the same assets which you deposited and may have to accept payment in cash. Costs 9. We will set out your dealing costs with you in writing prior to the account being opened. If you have any queries on costs please discuss this with your individual sales trader. We make costs as transparent as possible. CFDs, Shares and Foreign Exchange are traded at market prices and market liquidity, we operate Best Execution. The cost of these transactions will show up separately on your contract notes and statements. Costs are charged as a percentage, or basis points, of the total position size traded and are not relative to the deposit or margin used. Costs are charged where indicated on a per transaction basis. Minimum charges can be relevant for smaller trade sizes and there are also charges associated with overnight financing of positions - these will all be set out in writing prior to the account being opened. With respect to Foreign Exchange trading, costs may be included in the transaction price. If this is the case, we will stipulate the size of the bid/offer spread quoted depending on the products you wish to trade. There may be different costs associated with the live price feeds utilised in your trading platform. Please ask a member of Insight Capital Strategies team to explain the respective policies on price-feed fees relative to your account. Suspensions of trading 10. Under certain trading conditions it may be difficult or impossible to liquidate a position. This may occur, for example, at times of rapid price movement if the price rises or falls in one trading session to such an extent that trading is suspended or restricted. Placing a stop-loss order will not necessarily limit your losses to the intended amounts, because market conditions may make it impossible to execute such an order at the stipulated price. Clearing house protections 11. On many exchanges, the performance of a transaction by your broker (or the third party with whom he is dealing on your behalf) is "guaranteed" by the exchange or its clearing house. However, this guarantee is unlikely in most circumstances to cover you, the customer, and may not protect you if your broker or other party defaults on its obligations to you. On request, your broker must explain any protection provided to you under the clearing guarantee applicable to any on-exchange derivatives in which you are dealing. There is no clearing house for traditional options, nor normally for off-exchange instruments which are not traded under the rules of a recognized or designated investment exchange.

15 Insolvency 12. Your dealer's insolvency or default may lead to positions being liquidated or closed out without your consent. In certain circumstances, you may not get back the actual assets which you lodged as collateral and you may have to accept any available payment in cash. Insight Capital Strategies accepts no responsibility for insolvency of, or default by, other brokers involved with your transactions. Stop loss orders 13. Stop loss orders may be subject to slippage. This means that if the stop loss order cannot be executed at your chosen price in the market, or cannot be executed in the desired volume at the chosen price, the order will be filled at the best available price at that time. Unless you hold a limited risk account, stop losses are not guaranteed. Advisory Service Agreement 14. Although you may seek advice from Insight Capital Strategies and/or Insight Capital Strategies may offer advice to you in connection with an investment transaction, you have the final decision in relation to the execution of every investment transaction. Consequently, you should make every effort to ensure that you are fully satisfied that you understand the advice given to you in relation to every investment transaction as, unless you indicate otherwise, Insight Capital Strategies will be entitled to assume that you do. I/we accept that when Insight Capital Strategies provides advisory services it will be under the following conditions: (a) Occasionally Insight Capital Strategies may, at our discretion, provide advisory services, recommendations and information on our own initiative and at our discretion. However, Insight Capital Strategies shall not be obligated to continue to provide advice related to managing your investments. (b) Published recommendations and research reports may occasionally be provided to you by Insight Capital Strategies, as well as advertisements and other publications. When any document provided to you carries restrictions with regard to the individuals or category of individuals for whom such a document is intended or to whom it may be disseminated, you hereby concur that you shall not distribute such a document to any such individual or category of individuals. Insight Capital Strategies may have acted upon the document or information contained within it before distribution of the material. No representations are made by Insight Capital Strategies as to the time you receive information, recommendations or research reports and Insight Capital Strategies makes no guarantees that such information, recommendations or research reports will be received by you at the same time as our other clients. Screen information service(s) may utilise and/or contain information, recommendations and research reports published by Insight Capital Strategies. (c) When Insight Capital Strategies provides information regarding the financial markets, recommendations or advisory services, we give no warranty, guarantee or representation as to the completeness or accuracy of the information, recommendations or advisory services or to the tax consequences of transactions or investments. Unless Insight Capital Strategies specifically consents otherwise through written communication from you, you agree and acknowledge that (i) the advice offered by Insight Capital Strategies is purely incidental to your trading association with Insight Capital Strategies and offered exclusively to allow you to construct your own decisions regarding your trading and investments; (ii) the investments of Insight Capital Strategies directors, associates, management and employees or agents may vary from the advice, information and recommendations provided to you by Insight Capital Strategies and (iii) due to individual differences in the analysis of technical and/or fundamental factors by different personnel, the advice, information or recommendations provided to other clients may vary from advice, information or recommendations provided to you by Insight Capital Strategies. (d) Insight Capital Strategies will not, at any time, be required or be seen to be required to offer tax advice to clients. Insight Capital Strategies will not provide advice with regard to tax issues. Please note that past performance is not necessarily a guide to future performance.