CLIENT AGREEMENT

1. DEFINITIONS AND INTERPRETATION

In this Agreement, unless the context requires otherwise, the following terms have the meanings set out below, and words importing the singular include the plural and vice versa:

“Agreement” means this Client Agreement together with the Terms of Business, Risk Disclosure Notice, Privacy Policy, Fee Schedule, and any other policy or notice incorporated by reference or published on the Website from time to time.

“Anshin” / “we” / “us” means Anshin Trading (Pty) Ltd, an authorised Financial Services Provider in the Republic of South Africa.

“Client” / “you” means the natural or legal person who has registered an account via the Platform and accepted this Agreement.

“Liquidity Provider” / “LP” means the entity or entities designated by Anshin from time to time as the counterparty responsible for trade execution, pricing and the holding of Client funds, currently Finalto (as defined below).

“Finalto” means Finalto (Australia) Pty Ltd (ACN 158 641 064), regulated by the Australian Securities and Investments Commission under licence no. 424008, or such other Finalto group entity as may be designated, being the current Liquidity Provider.

“Routing Infrastructure” means the third-party order-routing / bridge technology used by Anshin to transmit Client orders from the Platform to the Liquidity Provider for execution.

“Platform” means the MT5 (MetaTrader 5) trading platform made available by Anshin to the Client, and the Website.

“Website” means anshinfx.com and any successor or related domain operated by Anshin.

“STP” means straight-through processing, being an order-execution model in which Client orders are transmitted electronically for execution without manual dealing intervention by Anshin.

2. REGULATORY STATUS AND ROLE OF ANSHIN

2.1 Anshin Trading (Pty) Ltd is an authorised Financial Services Provider (“FSP”) in the Republic of South Africa. (License Number 54135)

2.2 Anshin operates a straight-through processing (STP) order-routing model. Anshin holds the contractual relationship for, and operates, the MT5 trading platform through which the Client places orders. Anshin also holds the order-routing / bridge arrangement constituting the Routing Infrastructure, through which all Client orders placed on the Platform are transmitted automatically, without dealing intervention by Anshin, to the designated Liquidity Provider for execution.

2.3 Anshin does not: (a) act as principal counterparty to the Client’s trades; (b) act as market maker; (c) provide its own liquidity, quotes or pricing; (d) exercise dealing discretion over Client orders; or (e) guarantee execution, spreads, slippage or fill quality, all of which are determined by the Liquidity Provider.

2.4 Anshin does not collect, receive, hold, safeguard, or otherwise take custody of Client trading funds at any point. Clause 5 sets out how, and to whom, Client funds are transferred, and the resulting relationship between the Client and the Liquidity Provider.

2.5 By accepting this Agreement, the Client acknowledges and understands the distinction between: (a) the platform, onboarding and order-routing services that Anshin provides directly to the Client under this Agreement; and (b) the execution of trades and the holding of the Client’s funds, which are provided exclusively by the Liquidity Provider under its own terms, as further described in Clauses 5 and 6.

3. SERVICES PROVIDED BY ANSHIN

3.1 Anshin provides the Client with:

(a) access to, and use of, the MT5 trading Platform for the purpose of placing orders;

(b) client onboarding, identity verification (KYC) and account administration;

(d) customer support, and general administrative and marketing functions in connection with the Client’s use of the Platform; and

(e) such other services as may be described on the Website from time to time.

3.2 For the avoidance of doubt, the services described in Clause 3.1 do not include trade execution, pricing, quotation, margining, or the holding of Client funds, each of which is the sole responsibility of the Liquidity Provider.

4. ELIGIBILITY, ONBOARDING AND KYC

4.1 To register an account, the Client must be at least 18 years old, have full legal capacity to contract, and complete Anshin’s onboarding process, including identity, address and source-of-funds verification in accordance with applicable anti-money laundering laws and Anshin’s internal compliance policies.

4.2 Anshin reserves the right to decline, suspend, or terminate the registration of any applicant or Client, at its sole discretion, including where required for compliance with applicable anti-money laundering laws, sanctions screening, or other applicable law.

4.3 The Client warrants that all information provided during onboarding and on an ongoing basis is true, accurate and complete, and undertakes to notify Anshin promptly of any change to such information.

5. EXECUTION AND LIQUIDITY ARRANGEMENTS

5.1 The Client’s trades are executed by, and entered into as principal with, the Liquidity Provider designated by Anshin from time to time. The current designated Liquidity Provider is Finalto (Australia) Pty Ltd.

5.2 Order flow: orders placed by the Client on the Platform are transmitted through Anshin’s trading infrastructure and Routing Infrastructure to the Liquidity Provider for execution. The Client acknowledges that, notwithstanding that the order is placed on Anshin’s Platform, the resulting trade is executed by, and with, the Liquidity Provider, and that the Liquidity Provider’s own execution policy, dealing rules, and terms of business apply to that trade.

5.3 Where Anshin engages an additional or replacement Liquidity Provider, Anshin will, before any Client orders or funds are directed to that provider: (a) name that Liquidity Provider in an updated version of this Agreement or in a supplementary disclosure published on the Website; (b) provide reasonable prior notice to affected Clients; and (c) where more than one Liquidity Provider is used concurrently, specify which categories of Client, account or instrument are routed to which Liquidity Provider.

5.4 Anshin does not control or guarantee market prices, spreads, execution speed, slippage, liquidity availability, or margin close-out levels; these are determined exclusively by the Liquidity Provider in accordance with its own policies.

6. CLIENT FUNDS

6.1 Anshin does not operate client trust, segregated, or nominee accounts, and does not at any point receive, hold, or exercise control over Client trading funds.

6.2 All funds transferred by the Client for trading purposes are paid directly into a bank account held in the name of the Liquidity Provider.

6.3 The Client acknowledges that Anshin does not itself hold or safeguard the Client’s trading funds. Once transferred, those funds are held by the Liquidity Provider in accordance with the Liquidity Provider’s own client-money rules, custody terms, and risk disclosures, and Anshin does not control, and is not responsible for, how those funds are subsequently held, applied, or returned by the Liquidity Provider.

6.4 Anshin maintains internal records reconciling the Client’s individual trading balance, deposits, withdrawals and open positions against the Liquidity Provider’s main account, for the purposes of accurate reporting to the Client on the Platform.

6.5 The Client acknowledges that funds held by a Liquidity Provider are subject to that Liquidity Provider’s regulatory regime, which may differ from South African client-asset protections, and that the Client bears the counterparty, credit and cross-border risk of the Liquidity Provider holding its funds.

7. FEES AND CHARGES

7.1 Separately, the Liquidity Provider applies its own spreads, commissions, swap/rollover charges, conversion fees and other charges in respect of trade execution and the holding of funds, as set out in the Liquidity Provider’s own fee schedule and terms of business.

7.2 The Client is responsible for any bank charges, transfer fees, or other third-party costs incurred in funding or withdrawing from their trading account.

8. RISK DISCLOSURE

8.1 Contracts for Difference (CFDs), forex, and other leveraged financial instruments carry a high degree of risk and may not be suitable for all investors. The Client should not trade with funds they cannot afford to lose.

8.2 The Client may sustain losses exceeding deposited funds, depending on account structure, leverage, and market conditions.

8.3 Past performance is not indicative of future results, and no representation is made that any Client will or is likely to achieve profits or losses similar to those achieved in the past, or that any trading strategy will be successful.

8.4 The Client separately bears the risk that the Liquidity Provider holding its funds becomes insolvent, or is otherwise unable or unwilling to return those funds, as described in Clause 6.5. Anshin accepts no liability for any loss arising from an act, omission, insolvency, or default of the Liquidity Provider.

8.5 Technology risk: order routing, execution, and platform availability depend on third-party infrastructure (including the Routing Infrastructure and the Liquidity Provider’s systems), and may be subject to delay, interruption, or failure outside Anshin’s control.

8.6 This Clause 8 is a summary only. The Client must read the full Risk Disclosure Notice, published on the Website, before trading.

9. PLATFORM AND TECHNOLOGY

9.1 The MT5 platform contract, and the order-routing relationship constituting the Routing Infrastructure, are held by Anshin. Anshin is responsible for the availability and proper functioning of the Platform as an interface for placing orders, but is not responsible for pricing, execution, or settlement, which are the responsibility of the Liquidity Provider.

9.2 Anshin may suspend access to the Platform, in whole or in part, for maintenance, security, or regulatory reasons, and will endeavour to give reasonable notice where practicable.

9.3 The Client is responsible for maintaining the confidentiality of their login credentials and for all activity conducted through their account.

10. CONFLICTS OF INTEREST

10.1 Anshin maintains a conflicts-of-interest policy, available on request, designed to identify and manage conflicts that may arise in connection with its onboarding, platform and order-routing services.

11. CONFIDENTIALITY AND DATA PROTECTION

11.1 Anshin will retain the Client’s personal information and all account- and transaction-related records for a period of seven (7) years from the later of (i) the termination date of this Agreement, or (ii) the date of the Client’s last transaction. Where a longer retention period is required by applicable laws or regulatory requirements, or where retention is necessary for the establishment, exercise, or defence of legal claims, Anshin will retain such information for the applicable extended period. Upon expiry of the relevant retention period, the information will be securely deleted or irreversibly anonymised.

11.2 The Client consents to Anshin sharing information reasonably necessary with the Liquidity Provider, the provider(s) of the Routing Infrastructure, and other service providers for the purposes of onboarding, order routing, execution, and regulatory compliance.

12. TERMINATION

12.1 Either party may terminate this Agreement on [30] days’ written notice to the other.

12.2 Anshin may suspend or terminate the Client’s access to the Platform immediately, without notice, where required by law, by a regulator, or where Anshin reasonably suspects fraud, money laundering, breach of this Agreement, or other misuse of the Platform.

12.3 Termination of this Agreement does not affect any open positions or funds held by the Liquidity Provider, which remain subject to the Liquidity Provider’s own terms.

13. AMENDMENTS

13.1 Anshin may amend this Agreement from time to time by publishing the updated version on the Website and providing reasonable notice to the Client. Continued use of the Platform after the effective date of an amendment constitutes acceptance of the amended Agreement.

14. GOVERNING LAW AND DISPUTE RESOLUTION

14.1 This Agreement is governed by the laws of the Republic of South Africa.

14.2 This Agreement governs the Client’s relationship with Anshin only. Trade execution and the holding of Client funds are provided by the Liquidity Provider and remain subject to the Liquidity Provider’s applicable terms and conditions.