Abuse & Market Manipulation Policy

1. Introduction

This Abuse & Market Manipulation Policy (the "Policy") sets out the standards, principles, prohibited conduct, investigative procedures, and corrective measures adopted by LEVELS Ltd., an International Business Company incorporated under the laws of Saint Lucia under registration number 2024-00069, with its registered office situated at Ground Floor, The Sotheby Building, Rodney Village, Rodney Bay, Gros Islet, Saint Lucia (the "Company").

This Policy forms an integral part of the Company's Client Agreement and applies to all clients, authorised representatives, beneficial owners, account controllers, traders, introducers, agents, and any other persons who directly or indirectly access or use the Company's services.

2. Purpose of This Policy

The purpose of this Policy is to:

1. a) promote fair, orderly, and legitimate trading activity;
2. b) protect the integrity of the Company's trading environment, systems, infrastructure, pricing mechanisms, execution arrangements, and risk management framework;
3. c) establish clear standards regarding unacceptable trading conduct;
4. d) protect the Company and its clients from abusive, manipulative, deceptive, fraudulent, or otherwise improper trading practices;
5. e) provide a framework for identifying, investigating, reviewing, and addressing suspicious trading activity;
6. f) ensure that trading activity is conducted in a manner consistent with fair dealing, sound market practices, and the Company's legitimate commercial interests.

3. Application of This Policy

This Policy applies to:

• all trading accounts maintained with the Company;
• all transactions executed through the Company's platforms;
• all financial instruments offered by the Company;
• all account holders and beneficial owners;
• any person acting directly or indirectly on behalf of a client;
• any related accounts, linked accounts, connected accounts, or accounts operating under common control.

The Company may apply this Policy to individual accounts or to groups of accounts assessed collectively where circumstances reasonably indicate a material connection between them.

4. General Principles

Clients are expected to act honestly, fairly, and in good faith when using the Company's services.

The Company does not prohibit legitimate trading strategies, including profitable trading strategies, merely because they are successful or generate substantial profits.

However, the Company reserves the right to investigate and take action where trading activity appears designed to:

• exploit errors, weaknesses, delays, vulnerabilities, or inefficiencies;
• circumvent the Company's risk controls or trading conditions;
• obtain an unfair advantage over the Company, its systems, liquidity arrangements, service providers, or other clients;
• interfere with the proper operation of the Company's trading environment;
• misrepresent the true nature, scale, ownership, control, or purpose of trading activity.

The Company shall assess trading activity based upon its overall substance, economic reality, and practical effect rather than solely upon its technical form.

5. Relationship with Other Documents

This Policy shall be read together with:

• the Client Agreement;
• the Best Interest and Order Execution Policy;
• the Risk Disclosure and Warning Notice;
• the AML & CFT Policy;
• the Client Categorisation Policy;
• the Website Terms of Use;
• any other policies, notices, trading conditions, or procedures issued by the Company from time to time.

In the event of inconsistency between this Policy and the Client Agreement, the Client Agreement shall prevail unless expressly stated otherwise.

6. Interpretation

Nothing in this Policy shall be interpreted as limiting the Company's rights under:

• the Client Agreement;
• applicable laws;
• regulatory obligations;
• general principles of contract, fraud prevention, risk management, or market integrity.

The examples provided throughout this Policy are illustrative only and shall not be interpreted as limiting the scope of conduct that may be considered abusive, manipulative, deceptive, improper, suspicious, or otherwise inconsistent with the purpose of this Policy.

7. Definitions

For the purposes of this Policy, unless the context otherwise requires, the following terms shall have the meanings set out below.

7.1 Abusive Trading

"Abusive Trading" means any trading activity, conduct, strategy, arrangement, scheme, pattern, or practice which, in the Company's reasonable opinion, seeks to obtain an unfair, artificial, unintended, improper, or disproportionate advantage from the Company's services, systems, pricing mechanisms, execution arrangements, promotions, infrastructure, operational processes, or risk management framework.

Abusive Trading may exist whether undertaken through a single account or multiple accounts and regardless of whether such activity generates profits or losses.

7.2 Market Manipulation

"Market Manipulation" means any activity intended to create, or having the effect of creating, a false, misleading, artificial, distorted, deceptive, or improper impression regarding market activity, pricing, liquidity, demand, supply, execution conditions, or trading behavior.

Market Manipulation may include conduct directed toward the broader market, the Company's trading environment, or the Company's internal execution and pricing mechanisms.

7.3 Related Accounts

"Related Accounts" means two or more accounts which, in the Company's reasonable opinion, are connected directly or indirectly through common ownership, beneficial ownership, management, control, funding sources, devices, internet connections, trading strategies, software, introducers, communication channels, household members, business relationships, or any other factor indicating a material connection.

Related Accounts may exist regardless of whether such accounts are registered under different names, entities, jurisdictions, or identities.

7.4 Common Control

"Common Control" means the ability of a person, group, entity, or arrangement to directly or indirectly influence, direct, manage, coordinate, control, or materially affect the trading activity, decisions, execution, funding, operation, or management of one or more accounts.

Common Control may exist irrespective of legal ownership or formal account registration.

7.5 Coordinated Trading

"Coordinated Trading" means trading activity conducted through multiple accounts in a manner indicating common planning, common decision-making, common execution, shared strategy, automated replication, synchronized activity, signal distribution, centralized management, or other forms of coordinated operation.

The existence of Coordinated Trading shall be assessed based upon the totality of circumstances and not solely on any individual indicator.

7.6 Single Economic Unit

"Single Economic Unit" means two or more accounts, persons, entities, or arrangements which, when assessed objectively, operate substantially as one trading operation, one trading strategy, one source of decision-making, one source of funding, or one economic interest.

The Company may assess accounts collectively where it reasonably concludes that their activity represents a Single Economic Unit.

7.7 Artificial Fragmentation

"Artificial Fragmentation" means the division, distribution, allocation, splitting, replication, or spreading of trading activity, positions, exposure, capital, risk, profits, losses, or transactions across multiple accounts for the purpose or effect of concealing, reducing, circumventing, avoiding, or impairing the operation of risk controls, trading limits, surveillance measures, commercial terms, compliance procedures, or monitoring processes.

7.8 Execution Model Exploitation

"Execution Model Exploitation" means any conduct intended to obtain an advantage from the Company's execution model, pricing model, risk management structure, operational assumptions, technology infrastructure, liquidity arrangements, or trading conditions in a manner inconsistent with their intended commercial purpose.

This may include conduct which relies upon execution conditions that would not reasonably be available under normal market conditions, institutional trading conditions, or the true economic scale of the trading activity.

7.9 Latency Arbitrage

"Latency Arbitrage" means any strategy that seeks to profit from delays, timing differences, transmission delays, pricing delays, stale prices, execution delays, quote discrepancies, data-feed differences, or other timing-related inefficiencies between the Company's systems and external market conditions.

7.10 Price Arbitrage

"Price Arbitrage" means any activity seeking to exploit discrepancies, inconsistencies, delays, inaccuracies, or temporary differences between prices available through the Company's systems and prices available from other sources, venues, providers, exchanges, platforms, or markets.

7.11 Scalping

"Scalping" means a trading strategy involving the frequent opening and closing of positions over relatively short holding periods with the objective of capturing small price movements.

7.12 High-Frequency Trading (HFT)

"High-Frequency Trading" ("HFT") means trading activity characterised by the rapid generation, submission, modification or execution of a significant number of orders, whether manually or through automated systems, algorithms, Expert Advisors or similar technologies.

7.13 System Exploitation

"System Exploitation" means any attempt to exploit technical weaknesses, software behavior, operational vulnerabilities, communication failures, infrastructure limitations, platform functionality, configuration settings, pricing mechanisms, execution processes, or any other aspect of the Company's systems in a manner inconsistent with their intended use.

7.14 Bonus Abuse

"Bonus Abuse" means any conduct intended to improperly obtain, maximize, manipulate, exploit, circumvent, or benefit from promotions, incentives, rebates, bonuses, rewards, referral arrangements, loyalty programs, or similar schemes in a manner inconsistent with their intended purpose.

7.15 Suspicious Activity

"Suspicious Activity" means any conduct, pattern, transaction, arrangement, account activity, or circumstance that reasonably warrants further review, investigation, clarification, verification, monitoring, or assessment by the Company.

Suspicious Activity may exist regardless of whether a breach of this Policy is ultimately established.

7.16 Prohibited Conduct

"Prohibited Conduct" means any activity that violates:

• this Policy;
• the Client Agreement;
• Company Policies;
• applicable laws;
• accepted principles of fair dealing;
• legitimate commercial standards applicable to the Company's business.

8. General Standard of Conduct

All Clients are expected to conduct their trading activity honestly, transparently, fairly, and in good faith.

The Company recognizes that legitimate trading strategies may vary significantly between Clients and that profitable trading alone does not constitute evidence of abusive conduct.

Accordingly, the Company shall not regard trading activity as abusive solely because:

• it is profitable;
• it is highly profitable;
• it is systematic;
• it is automated;
• it involves large trading volumes;
• it utilizes advanced technology;
• it is commercially successful.

However, where such activity is combined with circumstances indicating unfair advantage, manipulation, circumvention of controls, concealment, system exploitation, or conduct inconsistent with the purpose of the Company's services, the Company may investigate and take action under this Policy.

9. Prohibited Conduct

The Company prohibits any conduct that compromises, interferes with, manipulates, circumvents, exploits, abuses, or otherwise adversely affects the integrity of its trading environment, execution arrangements, systems, risk management framework, commercial conditions, or legitimate business interests.

The categories described below are not exhaustive and are intended to provide guidance regarding conduct that may be considered unacceptable under this Policy.

10. Market Manipulation and Deceptive Conduct

Clients shall not engage in any conduct that creates, or is reasonably capable of creating, a false, misleading, deceptive, artificial, or distorted impression regarding market activity, pricing, liquidity, trading interest, execution quality, or trading conditions.

Examples may include:

• fictitious trading activity;
• manipulative order placement;
• deceptive transaction patterns;
• coordinated activity designed to influence pricing;
• conduct intended to create misleading trading signals;
• transactions lacking legitimate economic purpose;
• activity intended to distort risk measurements, account performance, or market perception.

The Company may consider the overall effect of the conduct rather than solely the Client's stated intention.

11. Related Account Abuse and Common Control

Clients shall not use multiple accounts, entities, nominees, third parties, family members, associates, or related persons to conceal, misrepresent, or circumvent the true ownership, control, purpose, scale, or nature of trading activity.

Without limitation, the Company may consider the following factors when assessing whether accounts are related:

• common beneficial ownership;
• common funding sources;
• common withdrawal destinations;
• common devices;
• common internet connections;
• common trading strategies;
• common software or automation;
• common decision makers;
• common communication channels;
• common business interests;
• common household relationships;
• coordinated or synchronized trading activity.

Where the Company reasonably concludes that accounts operate under Common Control or as a Single Economic Unit, the Company may assess such accounts collectively for risk management, compliance, surveillance, commercial, and investigative purposes.

12. Coordinated Trading and Artificial Fragmentation

The Company recognizes that certain legitimate arrangements may involve multiple accounts participating in similar trading activity.

However, the Company may consider trading activity abusive where multiple accounts are used in a manner that:

• conceals aggregate exposure;
• conceals actual risk;
• conceals beneficial ownership;
• circumvents trading restrictions;
• circumvents account limitations;
• circumvents commercial terms;
• circumvents surveillance procedures;
• impairs the Company's ability to assess the true economic nature of the activity.

The Company may aggregate related accounts when assessing:

• trading volume;
• market exposure;
• concentration risk;
• profitability;
• risk-adjusted performance;
• execution behavior;
• overall commercial impact.

13. Execution Model Exploitation

Clients shall not engage in conduct designed to exploit, manipulate, circumvent, or improperly benefit from:

• execution arrangements;
• pricing methodologies;
• risk management systems;
• liquidity arrangements;
• operational processes;
• trading infrastructure;
• commercial assumptions upon which trading conditions are offered.

The Company may review activity where trading patterns indicate reliance upon execution conditions that may not reasonably reflect:

• prevailing market conditions;
• available liquidity;
• order size;
• aggregate exposure;
• execution risk;
• the true economic scale of the activity.

The Company may consider whether the overall activity is consistent with the intended commercial purpose of the trading conditions offered to the Client.

14. Latency Arbitrage and Price Arbitrage

Clients shall not engage in strategies that seek to exploit:

• stale prices;
• delayed prices;
• delayed execution;
• transmission latency;
• communication delays;
• data-feed discrepancies;
• quote delays;
• system synchronization issues;
• pricing anomalies.

The Company may investigate activity where trading results appear materially dependent upon such circumstances.

The existence of profitable trading alone shall not be sufficient to establish Latency Arbitrage or Price Arbitrage.

The Company shall consider all relevant facts and circumstances when conducting its assessment.

15. Abusive Scalping and High-Frequency Trading

The Company recognises that Scalping and High-Frequency Trading are widely used trading techniques and, in themselves, do not necessarily constitute improper conduct.

However, the Company may consider such trading abusive where, having regard to the overall trading pattern, it reasonably concludes that the activity is primarily intended to exploit technical, pricing, execution, operational or risk management weaknesses rather than genuine market movements.

Clients shall not engage in:

• exploitation of stale quotes;
• latency arbitrage;
• quote delays;
• coordinated multi-account execution;
• automated replication;
• execution model exploitation;
• systematic exploitation of pricing anomalies;
• generation of excessive order traffic intended to interfere with systems;
• repeated trading designed to obtain risk-free or near risk-free outcomes through technical deficiencies.

16. System Exploitation

Clients shall not exploit or attempt to exploit:

• software errors;
• platform malfunctions;
• technical weaknesses;
• configuration issues;
• communication failures;
• infrastructure limitations;
• operational vulnerabilities;
• programming errors;
• system defects.

The Company may take action regardless of whether such circumstances were intentionally caused by the Client.

17. Misrepresentation and Concealment

Clients shall not:

• provide false information;
• provide misleading information;
• omit material information;
• conceal beneficial ownership;
• conceal Common Control;
• conceal Related Accounts;
• conceal funding arrangements;
• conceal trading arrangements;
• conceal material facts relevant to the Company's assessment of risk.

A failure to disclose material information may itself constitute a breach of this Policy.

18. Circumvention of Company Controls

Clients shall not engage in conduct intended to bypass, avoid, undermine, interfere with, or impair:

• trading limits;
• leverage limits;
• margin requirements;
• risk controls;
• surveillance systems;
• compliance procedures;
• onboarding requirements;
• commercial arrangements;
• promotional terms;
• investigation procedures.

The Company may consider both the form and substance of the conduct when determining whether circumvention has occurred.

19. Bonus, Rebate and Promotional Abuse

Where promotional programs, rebates, incentives, bonuses, contests, loyalty programs, referral programs, or similar arrangements are offered, Clients shall not engage in conduct intended to improperly obtain benefits contrary to the purpose of such programs.

Examples may include:

• coordinated participation;
• artificial volume generation; self-dealing;
• wash trading;
• account splitting;
• account duplication;
• concealment of related accounts;
• manipulation of qualification criteria.

20. Other Improper Conduct

The Company reserves the right to determine that conduct is abusive, improper, manipulative, deceptive, or inconsistent with this Policy where, after considering all relevant circumstances, the conduct:

• undermines the integrity of the Company's services;
• creates an unfair advantage;
• exposes the Company to unreasonable risk;
• circumvents the intended operation of the Company's systems;
• conflicts with the principles and objectives of this Policy.

The absence of a specific example within this Policy shall not prevent the Company from taking action where the conduct is otherwise inconsistent with its legitimate business interests or the principles of fair dealing.

21. Detection, Monitoring and Surveillance

The Company maintains monitoring, surveillance, risk management, compliance, and review procedures designed to identify trading activity that may be inconsistent with this Policy, the Client Agreement, applicable laws, or the Company's legitimate business interests.

The Company reserves the right to review, analyse, monitor, and assess any account, transaction, order, position, trading pattern, communication, funding activity, withdrawal activity, or related information at any time.

Such monitoring may be conducted on a real-time, periodic, automated, manual, risk-based, event-driven, or ad-hoc basis.

21.1 Factors Considered During Monitoring

The Company may consider, among other things:

• trading frequency;
• trade duration;
• execution timing;
• account profitability;
• account relationships;
• order size;
• aggregate exposure;
• concentration risk;
• execution patterns;
• common funding sources;
• common withdrawal destinations;
• trading correlations;
• synchronization of activity;
• pricing behavior;
• latency indicators;
• unusual account activity;
• abnormal transaction patterns;
• any other factor reasonably considered relevant.

No single factor shall necessarily determine whether conduct is abusive.

The Company shall assess the overall facts and circumstances available at the time of review.

21.2 Aggregation of Accounts

For monitoring, compliance, risk management, and investigative purposes, the Company may aggregate and analyse accounts that it reasonably believes may be connected through Common Control, Related Accounts, Coordinated Trading, or a Single Economic Unit.

Such aggregation may be performed regardless of differences in account names, legal ownership, jurisdictions, or registration details.

22. Investigations and Reviews

The Company reserves the right to conduct investigations, reviews, audits, examinations, assessments, or enquiries whenever it reasonably considers such action necessary.

An investigation may be initiated where:

• suspicious activity is identified;
• abnormal trading patterns are detected;
• unusual profitability is observed;
• information received by the Company requires verification;
• complaints or reports are received;
• compliance concerns arise;
• operational concerns arise;
• risk management concerns arise;
• the Company reasonably suspects a breach of this Policy or any Company Policy.

22.1 Scope of Investigation

The Company may review:

• account activity;
• trading records;
• transaction history;
• order history;
• execution records;
• communications;
• login records;
• IP information;
• device information;
• payment records;
• funding records;
• withdrawal records;
• KYC documentation;
• beneficial ownership information;
• relationships between accounts;
• any other information reasonably considered relevant.

22.2 Appointment of Internal and External Specialists

The Company may appoint, consult with, or rely upon:

• compliance officers;
• forensic auditors;
• external auditors;
• trading experts;
• technology specialists;
• legal advisers;
• risk consultants;
• investigators;
• regulatory consultants;
• independent experts.

The Company may rely upon such findings, reports, analyses, opinions, and recommendations when making decisions under this Policy.

23. Requests for Information

During an investigation or review, the Company may request information, documentation, explanations, confirmations, declarations, or supporting evidence from the Client.

Such requests may include:

• proof of identity;
• proof of address;
• source of funds information;
• source of wealth information;
• beneficial ownership information;
• explanations regarding trading activity;
• explanations regarding account relationships;
• device ownership information;
• communication records;
• banking records;
• corporate documents;
• or any other information reasonably required.

23.1 Obligation to Cooperate

Clients shall cooperate fully and promptly with any investigation conducted by the Company.

Failure to provide requested information within the timeframe reasonably specified by the Company may result in:

• continuation of restrictions;
• suspension of withdrawals;
• suspension of trading activity;
• adverse inferences being drawn from the available evidence;
• decisions being made based on the information available to the Company at the time.

24. Account Restrictions During Investigation

Where the Company reasonably considers that an investigation is necessary, it may implement temporary restrictions or protective measures pending completion of the review.

Such measures are precautionary in nature and do not constitute a final determination regarding the conduct under investigation.

24.1 Temporary Restrictions

The Company may:

• restrict trading activity;
• limit account functionality;
• reject orders;
• delay processing requests;
• suspend withdrawals;
• place funds under review;
• restrict transfers;
• require enhanced verification;
• suspend access to certain services.

The Company may implement one or more measures simultaneously where reasonably necessary.

24.2 Review of Profits and Withdrawals

The Company may, at any time, review any transaction, profit, balance, credit, rebate, bonus, withdrawal request, or account activity.

Where the Company reasonably suspects that any profit, gain, credit, balance, or other benefit may have arisen from prohibited conduct, abusive trading, market manipulation, fraud, technical exploitation, pricing anomalies, system misuse, breach of this Policy, breach of the Client Agreement, or any activity requiring further review, the Company may:

• place such amounts under review;
• suspend or delay withdrawals;
• restrict account activity;
• freeze disputed funds;
• maintain reserves;
• implement protective measures;

pending completion of the investigation.

24.3 Duration of Restrictions

Any restriction, suspension, review, or protective measure may remain in place for such period as the Company reasonably considers necessary to complete its assessment and reach a determination.

25. Protective Measures

Where circumstances warrant, the Company may take any action reasonably necessary to:

• protect market integrity;
• protect the Company's systems;
• protect the Company's clients;
• protect liquidity arrangements;
• protect risk management processes;
• preserve evidence;
• prevent ongoing harm;
• safeguard the Company's legitimate business interests.

Such measures may be taken before, during, or after an investigation.

26. Findings and Determinations

Following completion of an investigation, the Company shall assess all relevant facts, evidence, information, explanations, and circumstances available to it.

The Company may conclude that:

1. a) no breach has occurred;
2. b) additional information is required;
3. c) suspicious activity remains unresolved;
4. d) a breach of this Policy has occurred;
5. e) a breach of the Client Agreement has occurred;
6. f) corrective action is appropriate.

The Company's conclusions shall be based upon the balance of information reasonably available at the time of the determination.

26.1 Standard of Assessment

The Company shall assess conduct based on:

• substance over form;
• economic reality;
• overall trading behavior;
• cumulative evidence;
• practical effect of the conduct;
• consistency with the objectives of this Policy.

The Company shall not be required to establish criminal liability, regulatory liability, or fraud beyond reasonable doubt in order to take action under this Policy.

27. Corrective Actions

Where the Company reasonably determines that conduct has occurred which is inconsistent with this Policy, the Client Agreement, Company Policies, applicable laws, or the principles of fair dealing, the Company may implement one or more corrective actions.

Corrective actions shall be proportionate to the circumstances and may be applied individually or collectively.

27.1 Available Corrective Actions

The Company may:

• issue warnings;
• require additional disclosures;
• require additional verification;
• impose trading restrictions;
• impose account limitations;
• reject future transactions;
• suspend account functionality;
• terminate promotional participation;
• terminate rebate arrangements;
• suspend withdrawals;
• close positions;
• close accounts;
• terminate the business relationship;
• take any other action reasonably necessary to protect the Company and its legitimate business interests.

27.2 Financial Adjustments

Where the Company reasonably determines that profits, gains, credits, rebates, bonuses, commissions, incentives, or other benefits have arisen directly or indirectly from conduct prohibited by this Policy, the Company may:

• reverse such amounts;
• cancel such amounts;
• adjust account balances;
• remove improperly obtained benefits;
• restore account balances to the position that would reasonably have existed in the absence of the relevant conduct;
• offset such amounts against any sums owed by the Client to the Company.

27.3 Void Transactions

The Company may declare transactions wholly or partially void where it reasonably determines that such transactions were materially affected by:

• Abusive Trading;
• Market Manipulation;
• System Exploitation;
• Execution Model Exploitation;
• Latency Arbitrage;
• Price Arbitrage;
• misrepresentation;
• concealment of material information;
• breach of this Policy;
• breach of the Client Agreement.

The Company may take such action regardless of whether the affected transactions have been closed, settled, credited, withdrawn, or otherwise processed.

27.4 No Entitlement to Improper Benefits

Clients shall not acquire any entitlement to profits, gains, credits, benefits, rebates, bonuses, incentives, or other advantages derived from conduct determined by the Company to be inconsistent with this Policy.

The Company's objective shall be to restore the economic position that would reasonably have existed had the relevant conduct not occurred.

28. Account Aggregation and Economic Reality

The Company reserves the right to assess trading activity based upon its economic reality, practical effect, and overall substance rather than solely upon the legal structure, account registration details, or technical form of the activity.

28.1 Aggregation of Related Activity

Where the Company reasonably concludes that accounts, persons, entities, arrangements, or trading activity are materially connected, it may aggregate such activity for purposes including:

• risk assessment;
• compliance review;
• surveillance;
• investigation;
• exposure calculations;
• profitability assessment;
• determination of trading behavior;
• application of this Policy.

28.2 Economic Substance

In determining whether conduct is abusive, manipulative, deceptive, or otherwise improper, the Company may consider:

• the overall trading objective;
• the economic purpose of the activity;
• the practical effect of the conduct;
• the aggregate exposure created;
• the cumulative impact on the Company's trading environment;
• the relationship between connected accounts;
• the commercial reality of the activity.

The Company shall not be bound solely by the legal form, technical structure, or outward appearance of any arrangement.

29. Records and Evidence

The Company may maintain records relating to:

• transactions;
• orders;
• communications;
• investigations;
• reviews;
• compliance assessments;
• risk assessments;
• client interactions;
• technical data;
• account activity.

Such records may be maintained in electronic, digital, written, recorded, or any other form.

29.1 Reliance on Company Records

Unless demonstrated otherwise by credible evidence, the Company's records shall constitute prima facie evidence of the matters recorded therein.

The Company may rely upon:

• internal reports;
• trading records;
• system records;
• audit reports;
• compliance reviews;
• forensic analyses;
• expert opinions;
• technical assessments;
• third-party records.

30. No Waiver

Failure by the Company to exercise any right, power, remedy, discretion, or authority under this Policy shall not constitute a waiver of that right.

Any delay in exercising any right shall not prevent the Company from exercising that right at a later date.

The Company's approval, acceptance, processing, execution, settlement, or previous non-objection to any activity shall not prevent the Company from subsequently reviewing, investigating, or taking action in relation to such activity.

31. Survival of Rights

The Company's rights under this Policy shall survive:

• account closure;
• termination of the Client Agreement;
• withdrawal of funds;
• completion of transactions;
• cessation of trading activity;
• termination of the business relationship.

The Company may continue investigations and take corrective action after any of the above events where reasonably necessary.

32. Amendments

The Company reserves the right to amend, supplement, modify, replace, or update this Policy from time to time.

Any amendment may become effective upon publication on the Company's Website, Client Portal, Platform, or upon notification to Clients.

Continued use of the Company's services following such publication or notification shall constitute acceptance of the revised Policy.

33. Reservation of Rights

Nothing in this Policy shall limit or prejudice any rights, remedies, powers, protections, or actions available to the Company under:

• the Client Agreement;
• other Company Policies;
• applicable laws;
• regulatory obligations;
• general legal principles;
• contractual rights;
• equitable remedies.

The rights contained in this Policy are cumulative and may be exercised independently or together.

34. Effective Date

This Policy shall become effective on the date determined and published by the Company and shall remain in force until amended, replaced, or withdrawn by the Company.