Client Categorisation Policy
1. Introduction
This Client Categorisation Policy (the "Policy") sets out the framework adopted by LEVELS Ltd. (the "Company") for the classification and categorisation of clients.
The purpose of this Policy is to establish a consistent approach for assessing clients, understanding their experience and characteristics, and determining the level of service, information, protections, and treatment that may be applied by the Company.
This Policy forms part of the Company's overall compliance and client management framework and should be read together with the Client Agreement and other Company policies.
2. Purpose
The objectives of this Policy are to:
- establish clear client categories;
- facilitate effective client onboarding;
- support risk management and compliance procedures;
- ensure appropriate treatment of clients;
- maintain accurate client records;
- assist the Company in understanding the nature of its client relationships.
The Company reserves the right to determine the appropriate category for any client.
3. Client Categories
For the purposes of this Policy, the Company may classify clients into one of the following categories:
3.1 Retail Clients
A Retail Client is a client who does not meet the criteria established by the Company for Professional Clients or Eligible Counterparties.
Retail Clients generally include individual traders, investors, and businesses using the Company's services for their own account.
Retail Clients are generally considered to require the highest level of disclosures and client communications.
3.2 Professional Clients
A Professional Client is a client who possesses sufficient knowledge, experience, expertise, financial resources, or market understanding to assess and manage trading risks independently.
Professional Clients may include:
- regulated financial institutions;
- investment firms;
- fund managers;
- proprietary trading firms;
- family offices;
- institutional investors;
- corporate entities with relevant trading experience;
- individuals with significant trading experience or financial market expertise.
The Company may request evidence supporting Professional Client status.
3.3 Eligible Counterparties
An Eligible Counterparty is a professional market participant, institution, financial organisation, liquidity provider, broker, dealer, or other entity that transacts with the Company on a business-to-business basis.
The Company may determine whether a client qualifies as an Eligible Counterparty based upon the nature of the relationship and services provided.
4. Client Classification Process
The Company shall determine a client's category based upon information available during onboarding and throughout the business relationship.
The Company may consider factors including:
- trading experience;
- professional background;
- financial knowledge;
- business activities;
- regulatory status;
- assets and financial resources;
- transaction history;
- expected trading activity;
- information provided by the client;
- any other relevant information.
The Company may request supporting documentation where necessary.
5. Reclassification of Clients
The Company reserves the right to reclassify a client at any time where it reasonably considers such reclassification appropriate.
Reclassification may occur as a result of:
- updated client information;
- changes in circumstances;
- changes in business activities;
- changes in regulatory requirements;
- changes in risk profile;
- information obtained during the relationship.
The Company may notify the client of any material reclassification where appropriate.
6. Rights and Responsibilities of Clients
Clients are responsible for providing accurate, complete, and up-to-date information to the Company during onboarding and throughout the business relationship.
Clients shall promptly notify the Company of any material change relating to:
- trading experience;
- professional status;
- financial circumstances;
- regulatory status;
- ownership or control;
- business activities;
- contact information;
- any information relevant to their categorisation.
The Company shall be entitled to rely upon information provided by the client unless it becomes aware of circumstances suggesting that such information may be inaccurate, incomplete, or outdated.
7. Effect of Client Categorisation
Client categorisation is used by the Company for internal, compliance, operational, risk management, and client management purposes.
The categorisation assigned to a client may influence:
- onboarding procedures;
- due diligence requirements;
- information requests;
- risk assessments;
- account settings;
- available services;
- client communications;
- compliance monitoring.
The Company reserves the right to apply additional requirements, restrictions, protections, disclosures, or controls irrespective of a client's categorisation where it considers such measures necessary.
8. No Reliance on Client Category
A client's categorisation shall not be interpreted as:
- investment advice;
- a recommendation;
- a representation regarding suitability;
- a guarantee of trading knowledge or expertise;
- an assessment of the client's financial position.
Regardless of categorisation, clients remain solely responsible for their trading decisions and the management of their accounts.
9. Client Duty to Cooperate
Clients shall cooperate with any reasonable request made by the Company in relation to categorisation, verification, due diligence, compliance reviews, or reassessments.
The Company may request additional information or supporting documentation where necessary to determine or verify a client's category.
Failure to provide requested information may result in:
- delays in onboarding;
- restrictions on account activity;
- suspension of services;
- reclassification of the client;
- termination of the business relationship.
10. Company Discretion
The Company retains sole discretion regarding the categorisation and re-categorisation of clients.
Nothing in this Policy shall prevent the Company from:
- applying enhanced due diligence measures;
- imposing additional requirements;
- restricting services;
- declining applications;
- reclassifying clients;
- taking any action reasonably necessary to protect its legitimate business interests or comply with applicable obligations.
The Company's determination regarding client categorisation shall be final unless otherwise required by applicable law.
11. Record Keeping
The Company may maintain records relating to:
- client categorisation;
- supporting documentation;
- classification decisions;
- reassessments;
- client communications;
- compliance reviews.
Such records may be retained in electronic, digital, written, scanned, or any other form considered appropriate by the Company.
12. Amendments
The Company reserves the right to amend, supplement, 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.
13. Reservation of Rights
Nothing in this Policy shall limit any rights, powers, remedies, protections, or actions available to the Company under:
- the Client Agreement;
- the AML, CFT & KYC Policy;
- the Abuse & Market Manipulation Policy;
- the Best Interest & Order Execution Policy;
- the Risk Disclosure & Warning Notice;
- applicable laws.
The rights available to the Company are cumulative and may be exercised independently or together.
14. Effective Date
This Client Categorisation 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.
