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Invest-Terms_EN

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0% found this document useful (0 votes)
7 views

Invest-Terms_EN

Uploaded by

tom4.magera
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
You are on page 1/ 50

Trading 212 UK Ltd.

Aldermary House
10-15 Queen Street, London, EC4N 1TX

Invest Terms
Please note that definitions and interpretations are listed in Clause 36 at the end of these
Invest Terms.

Preamble.
Please read these Invest Terms carefully before opening an Account with us. By opening an
Account with us, you agree to be legally bound by these Invest Terms.

You can accept the Invest Terms on our Website by ticking the declaration that you have
read, understood and agreed to the Invest Terms. Should you refuse to accept them, you will
not be able to open an Account with us. The Invest Terms shall come into effect on the date
you accept it through our Website and/or through our mobile application.

References to clauses herein shall be limited to clauses of this Agreement unless explicitly
stated otherwise.

Headings, capitalised letters and highlighted or bolded words and phrases are included for
convenience only and shall not affect the interpretation of this Agreement.

Any words and phrases following the terms including, include, in particular or any similar
expression shall be construed as illustrative and shall not limit the sense of the words
preceding those terms.

1. Introduction.
1.1. Any reference in these Invest Terms (the “Agreement”) to ‘we’, ‘us’, ‘our’, ‘ours’ and
‘ourselves’ as appropriate shall mean Trading 212 UK Ltd. (‘Trading 212’ or ‘the Company’).

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Similarly, any reference to ‘the Client’, ‘you’, ‘your’, ‘yours’ and ‘yourself’ as appropriate shall
mean you as a customer of our services under this Agreement.

1.2. We are authorised and regulated by the Financial Conduct Authority of the United
Kingdom (the “FCA”). Our FCA register number is 609146 and this can be seen on the FCA
register available at https://register.fca.org.uk/, or by contacting the FCA at telephone
number 0800 111 6768.

1.3. The FCA's registered address is 12 Endeavour Square, London, E20 1JN. References to the
FCA shall include any successor, governing, or regulatory body that may replace, supersede
or take over any of the functions of the FCA.

1.4. Our registered office is Trading 212 UK Limited, Aldermary House, 10-15 Queen Street,
London, EC4N 1TX and we are registered in England and Wales with company number
08590005. We trade using the name “Trading 212”.

2. Scope of the Agreement.


The Agreement between you and us includes this Agreement, Order Execution Policy,
Disclosure Notice, Privacy Policy, Cookies Policy, all schedules, ancillary documents referred
to therein, any amendments thereto and any additional terms and conditions issued by us
from time to time (together referred to as the “Agreement”).

3. Client Acceptance and Categorisation.


3.1. We are required under Applicable Law to perform KYC Procedures in order to identify and
verify our customers. We have undertaken a risk-based approach to this process, which
may require obtaining, including but not limited to, documentary proof of your name, date of
birth and address. You agree that we may use additional online electronic verification tools
that may request, among other things, further details, documents, and photo & video
evidence from yourself. If you cannot satisfactorily prove your identity, you may not be able
to open an Account with us or may have to close your existing Account.

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3.2. We may also ask you to provide additional personal information to ensure that you meet
the tax requirements of other jurisdictions that you may choose to invest in. Failure to do so
may mean that you suffer a greater amount of withholding tax on income, as referred to in
more detail in Clause 24.2.

3.3. We may assess the appropriateness of certain complex products for you by reference to
your knowledge, experience and understanding of the risks involved. You will only be able to
place an Order in such complex products if you successfully complete the relevant
assessment. If, on the basis of the assessment, we conclude that dealing with those complex
products is not appropriate for you, we will notify you of this and we shall not proceed with
executing the Order(s).

3.4. We will not accept you as a Client, and we shall not commence providing our Share
Dealing Services to you until:

a. We have successfully completed the KYC Process; and


b. We have established that you have passed the Appropriateness Test, where
applicable.

Only after we have completed our client acceptance process and you have received a
confirmation from us, shall we be able to offer you our Share Dealing Services. Prior to that
moment, you shall be considered by us as a Prospect Client, and you may have access to
certain parts of the Trading Platform for evaluation purposes. During such times, you shall be
bound by the terms of this Agreement.

3.5. In compliance with applicable regulations, we shall categorise our clients into three
main categories: “eligible counterparties”, “professional clients” and “retail clients”.

3.6. Unless expressly notified to the contrary in writing, we shall treat you as a Retail Client as
required by the FCA Rules. Accordingly, you have the right to receive information from us
with respect to the Share Dealing Services.

3.7. You may request a different categorisation, which may result in the loss of certain
regulatory protections. We are not obliged to accept any such request, as this will depend
on your experience and knowledge, and we will need to obtain further information and

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documentation from you. Where such a request is approved by us, we will provide you with a
written confirmation and notice of the protections lost.

4. Share Dealing Services.


4.1. We shall provide our Share Dealing Services on an "execution-only” basis, meaning all
investment decisions are taken solely by you, and therefore you and you alone determine
your Investment strategy and choices, are responsible for all Orders, and are responsible for
regularly monitoring your Investments. We shall never advise you on your Investments, your
transactions, or your share trading decisions. We will not offer you any advice or
recommendations regarding our Share Dealing Services, and no information provided by us
should be interpreted as such.

4.2. You should obtain your own professional advice as to whether the intended Investments
are appropriate for you. We may provide you with factual information in relation to our
products, their potential risks, or about the financial markets in general, which is not based
on an assessment of your individual circumstances.

4.3. Using our Share Dealing Service entails a high level of investment risk. Orders you place
for Transactions are at your own risk and expense.

4.4. By using the Share Dealing Services, including our Website and Trading Platform, you
acknowledge and agree that:

a. it is prohibited to use, store, reproduce, display, modify, sell, publish and distribute
content and information related to the Share Dealing Services without our prior
written permission; and
b. You shall not use the Share Dealing Services for any unlawful or unauthorised
purpose.

4.5. We are not responsible for the provision of any tax or legal advice in relation to the Share
Dealing Services. You are solely responsible for any and all tax obligations applying to you as
a taxpayer, including reporting and paying all applicable taxes, duties or other fiscal
liabilities in relation to the Share Dealing Services. This is without prejudice to the best-effort
obligations of Trading 212 under Clauses 12.9. and 24.2.

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4.6. We will act on your behalf to execute various Order types pursuant to our Order
Execution Policy.

4.7. Your Stocks ISA and Cash ISA and any ISA Services shall be governed by the ISA Terms
available on our Website, in addition to the present Invest Terms. Please note that there are
specific rules in relation to your Stocks ISA and Cash ISA contained therein.

4.8. Joint accounts are not allowed and you acknowledge that you are not allowed to have
more than one Invest or ISA Account in your name. If you are in breach of this rule, we may
terminate all of your agreements with us. In case you have multiple accounts with us, open
in different currencies (e.g .ISA account in GBP and Invest account in EUR), we reserve the
right to impose a currency conversion charge for every inter-account currency conversion,
in accordance with our Terms and Fees.

4.9. You expressly agree that we will hold one individual client balance with respect to your
Invest and Stocks ISA Accounts in terms of both your money and assets, and Cash ISA in
terms of money. We have the right to combine and consolidate your money and assets we
hold for you in any of your Invest, Stocks ISA and Cash ISA ISA accounts. We have the right to
set-off any amounts payable by us to you (including but not limited to your cash, unrealised
profits and any credit balance, even if your Account(s) were closed) and the amounts that
are payable by you to us (including but not limited to unrealised losses, costs, charges
expenses with respect to any of our services, even if your Account(s) were closed).

4.10. Our Multi-Currency Account functionality allows you to hold cash in multiple currencies.
During the opening of your Account, you select a Primary Currency. The currencies available
to be set as Primary Currency will be visible on the Website and differ based on your country
of residency. The Primary Currency is used for calculating and displaying your Account
balance and Statements. Once confirmed, your Account’s Primary Currency cannot be
changed. You can hold cash balances across multiple Non-Primary Currencies, as specified
on our Website. We can add new currencies with immediate effect and no prior notice. In
case we terminate the support for a currency, we will give you at least thirty (30) days’ prior
notice. When converting between currencies, the applicable FX fee will be applied, as per our
Terms and fees page on our Website. The applicable FX exchange rate will be the live
interbank exchange rate.

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4.11. To ensure we act within the scope of our regulatory permissions, please note that we are
not a currency trading platform and you should not use the Multi-Currency Account
functionality for this purpose without actively engaging in trading activities through your
Account or Stocks ISA Account with us. For Accounts that are not actively trading, we reserve
the right, at our sole discretion, to restrict your use of Multi-Currency Accounts.

4.12. Our 24/5 Trading feature allows you to buy and sell certain Investments outside of
Regular Trading Hours. You can enable or disable the feature on our Website each time
before you place an Order. With 24/5 Trading you will have access to three additional
trading sessions:
a. Extended Hours Trading consisting of two sessions:
i. Pre-market Trading, and
ii. After Hours Trading, and
b. Overnight Trading.

Not all Investments are available for 24/5 Trading - you can see which Investments are
available by checking the Website. By enabling 24/5 Trading you will be able to trade
around-the-clock with no interruptions. However, different timeframes may apply, for
example during stock market holidays or US bank holidays, in which case we will do our best
to notify you in advance. Trading outside Regular Trading Hours comes with additional risks,
such as lower liquidity, higher price volatility and wider spreads. Your Order may be delayed,
partially executed, or not at all. Please check our Website and our Disclosure Notice for more
information and an overview of the associated risks.

5. Your Rights and Obligations.


5.1. You acknowledge that you are not permitted to open and/or operate an Account with us
on a third party’s behalf, regardless of your legal relations. You are expressly prohibited from
making use of our Share Dealing Services for Algorithmic Trading purposes or for providing
any commercial services, such as agent, brokerage and/or asset management services,
regardless of the fact that such services may be legally authorised. We reserve the right to
unilaterally close any such account that we become aware of, and we shall not be liable for
any losses, damages, costs, or expenses arising from our actions under this clause.

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5.2. You shall provide us with such information as we require to comply with all FCA Rules
and all applicable anti-money laundering rules and regulations. You warrant that any
information provided to us by you is complete, accurate and not misleading in any respect.
We reserve the right to reject applications from high-risk jurisdictions in accordance with our
ongoing legal and regulatory responsibilities.

5.3. You warrant on a continuous basis that by entering into this Agreement and any
Transactions under it, you will not violate any applicable laws and/or regulations.

5.4. You consent to be provided with key information documents (“KIDs”) for those Products
falling under the Packaged Retail and Insurance-based Investment Products Regulation
(“PRIIPs”) by means of our Website.

5.5. You accept full responsibility for monitoring your Account. You agree to notify us
immediately if you become aware of:
a. the loss, theft or unauthorised use of your username or password or account number;
b. the failure by you to receive a message or partial message from us indicating that an
Order was received, rejected and/or executed; or
c. any inaccurate information in your account(s) balances, statements, contract notes,
records or assets or money held or transaction history.

5.6. You must ensure that your password remains confidential at all times, and you must
take all responsible steps to:
a. stop any other person using your password;
b. not disclose your password to any other person, including any of our employees
(whether over the telephone or otherwise);
c. not use your account number in full or in part as your password;
d. ensure you are not overheard when contacting us by telephone; and
e. not leave your mobile phone or other devices unattended whilst you are logged on to
the Trading platform.

5.7. If you do not comply with the obligations in this Clause 5., this may affect the way we can
provide our Share Dealing Services to you, and we may:
a. refuse to open an Account for you or accept your assets;
b. refuse to deal for you;

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c. refuse to make payments or transfer Investments from your Account;


d. close your Account; and/or
e. take any other responsible step necessary to comply with regulatory requirements.

6. Our Rights and Obligations.


6.1. We are required to assess and define a target market for the investment products
manufactured for, distributed or sold to you. In our role as a product manufacturer and/or
distributor (seller), we will assess investments periodically, and we will share information on
investments so that we can take any appropriate steps to improve outcomes for you as our
client.

6.2. We may take any action that we, in our reasonable discretion, consider desirable to
ensure compliance with applicable laws and regulations. We shall not be liable for losses,
damages or delays arising from our compliance with any statutory or regulatory
requirements.

6.3. Before we accept your Instruction to Deal in relation to Investments and Shares listed in
the US, we will ask you to sign a W-8BEN form.

6.4. We shall not accept an Instruction to Deal when:


a. the relevant market is closed for trading;
b. if you do not have enough money in your Account to execute the Transaction; or
c. if there are events described as “Force Majeure” pursuant to Clause 30. of the
Agreement.

6.5. We shall provide a Statement and a Confirmation of your Transactions, as well as an


account balance and a record of all Transactions for your Account via the Trading Platform.
In the absence of Manifest Error, the Statement and Confirmation shall be binding on you.
You shall check the electronic Statements received from us and notify us promptly of any
discrepancy.

6.6. We shall open an Account in your name in the selected available currency. You shall be
able to use your Account to trade once you have deposited at least the amount specified in

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the Terms and Fees Table into your Account and the Account has been confirmed as
verified.

6.7. We shall have the right to introduce new Investments and Market Hours, trading at the
Trading Platform and to suspend and/ or remove from the Trading Platform any Investment
and Market Hours at our sole discretion.

6.8. We reserve the right to immediately place a Sell-only Limitation in the following cases:
a. Where we have a suspicion of unlawful activity;
b. Where we have suspicions of restricted or abusive trading activity;
c. In the event we exercise our rights under Clause 33.7.;
d. To comply with any regulatory obligations, including where you have not provided
legally required information in a timely manner;
e. In case you have not logged in to your Account or Stocks ISA Account for a period of
twelve (12) consecutive months, we reserve the right to request a verification of your
personal details as provided in Clause 3. In such case, we may impose a Sell-only
Limitation until satisfied that your KYC details are up-to-date; or
f. We have reasonable grounds to believe that allowing you to continue trading will be
detrimental to us, You as a client, other clients of us and/or financial markets.

In the above situations, We will notify you upon placement of a Sell-only Limitation.

6.9. We reserve the right to place a Sell-only Limitation with fourteen (14) calendar days
prior notice in the following cases which may include but are not limited to:
a. When we have issued you with a notice informing you of our intention to end our
business relationship with you / close your account;
b. Where You have not provided your express consent whenever we have requested
such, including but not limited to in the event that we need to obtain express consent
in order to introduce new features or services on the Trading Platform or amend
existing ones.

6.10. If a company goes bankrupt or is delisted from the respective stock exchange, we may
attempt to obtain prices for the instrument on the over-the-counter (OTC) market. If this is
not possible, you shall be informed that your positions in shares of this company shall be

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closed, and you agree to the closing prices. You agree to waive any right to possible future
compensation regarding delisted instruments.

7. Exclusion of liability.
7.1. We shall not be liable for any losses, damages, costs or expenses incurred or suffered by
you under this Agreement unless arising directly from our negligence, breach of contract,
bad faith, wilful default or fraud. In no circumstances shall we be liable for consequential loss
or special damage.

7.2. Nothing in this Agreement will limit our liability in respect of death or personal injury
caused by our negligence. You and we agree that this provision will survive any termination
of this Agreement.

7.3. The Company will not be held liable for any loss, cost or charge incurred resulting
directly or indirectly from the exercise of our right to place restrictions on your Account or
take any other action as provided in this Agreement.

7.4. You hereby agree and acknowledge that in the event of downtime of the Trading
Platform, You shall waive any claims against Trading 212 of missed profits and/or claims that
You would have executed an Order on a specific price during the downtime. You
acknowledge that sometimes there may be technical issues or faults with the Trading
Platform.

7.5. You acknowledge that at our sole discretion, we can reverse or cancel any incorrect
entry in the Account, including but not limited to voting rights, Corporate Actions, pending
Orders, executed transactions, deposits, withdrawals and similar bookings, which has
resulted in direct or indirect malfunction, error or mistake.

8. Settlement.
8.1. All Deals transacted between us will be carried out in accordance with the standard
settlement practices and/or market rules of the relevant exchanges.

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8.2. Transactions in European Shares are currently settled on a T+2 basis. Most worldwide
shares settle on either a T+2 or a T+3 basis.

8.3. The settlement date cannot be changed once you offer to enter into a Transaction.

8.4. We may settle transactions on a Delivery Versus Payment basis, and in entering into this
Agreement, you agree that we may at our discretion use the Delivery Versus Payment
exemption as permitted by the FCA CASS Rules. The Delivery Versus Payment exemption
essentially allows us to disapply the FCA CASS Rules relating to your money or assets for a
short period of time when settling your transaction within a Commercial Settlement System,
subject always to Applicable Law.

8.5. Investments held for you in custody will be used to settle your sale Transactions.
Otherwise, in respect of all sale Transactions, you:
a. confirm that, at the time of placing an order to sell, you own the relevant investments;
and
b. will immediately arrange for delivery to us of any certificates and transfer forms,
pertaining to such Investments, at the latest by the contracted settlement date,
otherwise, payment to you may be delayed.

9. Deposits and Withdrawals.


9.1. You have the right to deposit and withdraw money to your Account via the methods
specified on our Website. We reserve the right to restrict the available methods at any point
in time. Please note that depending on the method, there might be specific conditions for
the deposit to take place. You are obligated to log in to our Website via your username and
password before issuing a Payment Instruction. Please note that for any deposits and/or
withdrawals, you are obliged to use only a bank account, card or another type of account
belonging to you.

9.2. You should transfer money to Your Account only after agreeing to the terms of this
Agreement and receiving a username and password to access the Trading Platform. You
can only make deposits/withdrawals to/from accounts in your own name.
Deposits/withdrawals from/to third parties are not permitted and will not be processed. By

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agreeing to make a deposit, you confirm you are depositing your own funds for your own
trading with Trading 212.

9.3. Submitting a withdrawal request can be done by logging in to your Account on the
Website or by initiating a Trading 212 Card Withdrawal with your Trading 212 Card, as per
Clause 10. Please note that regular withdrawals may take up to three (3) Business Days to
process, while Trading 212 Card Withdrawals are usually executed instantly. You shall have
the right to withdraw money from your Account up to the amount of Available Cash. All
verified Trading 212 Card Withdrawals will be directed to your own E-Money Account, for
further processing, as per Clause 10. No payments to third parties from your Account shall be
allowed.

9.4. You acknowledge that by default, the withdrawal of any portion of the Available Cash will
be executed via the same method and to the same source as the one we originally received
the funds from. There are certain situations where an exception might be made for a
withdrawal to be executed to a payment method different from the one used for a deposit,
but those are subject to prior approval by us. You will be required to provide us with all
evidence requested by us that the new payment method is in your name. Notwithstanding
the above, Trading 212 Card Withdrawals will always be executed via the Trading 212 Card
and reflected on your Available Cash balance.

9.5. You might not be able to withdraw the proceeds of the sale of shares from your Account
unless and until the sale has settled on the settlement date (usually at T+2).
Notwithstanding the latter, we may, at our absolute discretion in limited circumstances, after
receipt of a request from you, allow withdrawal of limited amounts. Proceeds of sale of
shares held in your Account can be used before settlement date for the purpose of buying
more shares.

9.6. You consent that whenever you confirm a withdrawal, Trading 212 may use a specific
payment intermediary or bank to process your withdrawal as per your Payment Instruction.
The payment intermediary or bank may hold the withdrawal amount while the payment
transaction is being processed, which means that the withdrawal amount will no longer be
considered Client Money.

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9.7. We may request additional information and/or documentation to verify the legitimacy of
any Payment Instruction request. We may delay or refuse to process a Payment Instruction
where we have reasonable grounds relating but not limited to:
a. the authenticity of the instruction provided;
b. the suspected unauthorised or fraudulent use of your Account;
c. the validity of the nominated bank account supplied; or
d. legal or regulatory requirements.

You hereby agree that under such circumstances, there may be a delay in the processing of
your Payment Instruction.

9.8. You hereby undertake to inform Us every time a card used by You to make deposits to
your Account has been blocked, deactivated or otherwise suspended. Save for cases where
a card has expired, we shall not be liable if we should satisfy Your withdrawal request by way
of paying money back to a card that has been blocked, deactivated or otherwise
suspended without Your prior notification thereof.

9.9. If you decide to withdraw funds that were initially deposited with a payment card, by
submitting a chargeback with your issuing bank or otherwise, then you expressly agree that
we shall have the right to set-off the respective amounts from your Available Cash in
relation to any funds that are successfully reversed during the chargeback process.

10. Trading 212 Card Withdrawals.


10.1. You may be able to apply for a Trading 212 Card on our Website. The Trading 212 Card is
issued and managed by Paynetics UK Limited (“Paynetics”) (company No: 12481335, with
seat and registered address at: 1st Floor 18 Devonshire Row, London, England, EC2M 4RH, FCA
ref. No: 942777), a third-party provider (separate from Trading 212) authorised and regulated
by the FCA to provide e-money and payment services. Prior to being issued with and
activating the Trading 212 Card, you need to become a client of Paynetics and agree to
Paynetics’ Cardholder Agreement. Paynetics’ Cardholder Agreement details the applicable
terms and conditions for opening an E-Money Account, issuance and use of the Trading 212
Card. Trading 212 acts as a distributor for Paynetics and provides customer services in
relation to the Trading 212 Card. You will be able to manage the Trading 212 Card via the
Website. By accepting Paynetics’ Cardholder Agreement you request that Paynetics open an

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E-Money Account and issues a Card in your name. Please see the applicable limits and fees
specified in the Terms and Fees page on our Website.

10.2 Where you decide to become a client of Paynetics and accept Paynetics’ Cardholder
Agreement, you agree that we share all personal information required by Paynetics and/or
other relevant third parties in accordance with our Privacy Policy.

10.3. You will be able to submit a Payment Instruction for Trading 212 Card Withdrawals by
using the Trading 212 Card online, in shops, at physical or virtual Point-of-Sale terminals
(POS) and at Automated teller machines (ATMs). The Payment Instructions for Trading 212
Card Withdrawals will be processed as Payment Instructions under Clause 9. You are
therefore instructing us to facilitate these Trading 212 Card Withdrawals as Payment
Instructions from the Available Cash in your Account. Whenever you use your Trading 212
Card – whether it is for online purchases, in shops or ATM withdrawals - you are issuing a
Payment Instruction to Trading 212 for a Trading 212 Card Withdrawal. This Payment
Instruction authorises Trading 212 to deduct the specified amount from the Available Cash in
your Account and transfer it on your behalf to your E-Money Account held with Paynetics.
You are responsible for ensuring that you have sufficient Available Cash to cover the
requested Trading 212 Card Withdrawal, otherwise the Trading 212 Card Withdrawal may fail.
If, for any reason, your E-Money Account ends up with a negative balance, you instruct us to
reimburse the required amount from your Available Cash upon Paynetics’ request, where we
will notify you after the Trading 212 Card Withdrawal.

10.4. It is only possible to use your Trading 212 Card to withdraw Available Cash from your
Account or, where applicable, to receive chargebacks. Note it is not possible to use the
Trading 212 Card or your E-Money Account to receive any other payments from you or any
third party. In case a payment is mistakenly paid into your E-Money Account, Paynetics may
reverse the relevant transaction as detailed in the Paynetics’ Cardholder Agreement.

10.5. When using our Multi-Currency Account feature, we will prioritise Trading 212 Card
Withdrawals in the same currency to avoid any foreign exchange. If there are insufficient
Available Cash in the currency of your Trading 212 Card Withdrawal, the transaction will be
processed in your Primary Currency or, as a secondary option, in the currency with the
highest Available Cash balance. We will apply an FX fee when we convert between
currencies to facilitate the Trading 212 Card Withdrawal, as per our Terms and fees available

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on our Website. Please note that combining Cash balances in different currencies for a
single Trading 212 Card Withdrawal is not possible. If we cannot verify the Trading 212 Card
Withdrawal due to insufficient Available Cash in your Account or Primary Currency (or the
highest balance in another currency), the withdrawal request will not be processed.

10.6 Any cashback or other promotional proceeds paid by us or Paynetics in relation to the
Trading 212 Card will be credited to your Account with us.

10.7. It may be possible for you to instruct a Trading 212 Card Withdrawal above the Available
Cash in your Account where you use your Trading 212 Card for offline transactions and/or
automatic settlement transactions. This could result in a negative balance on your Account.
You agree to immediately deposit sufficient Available Cash to cover the negative balance.

11. Communications.
11.1. You shall place Orders via the Trading Platform after logging in with your username and
password.

11.2. If you need to contact us for any reason in relation to this Agreement, please do so:

a. by post to Trading 212 UK Ltd., Aldermary House, 10-15 Queen Street, London, EC4N 1TX;
or
b. by the Chat button on the website www.trading212.com and on the Trading Platform;
or
c. by email at: [email protected]

11.3. We may contact you and give you any notices in connection with this Agreement by
post, telephone, or by electronic means using the latest address, telephone number or
electronic mail address which you have provided. You hereby consent to us providing you
with information through a durable medium other than paper and to us providing
information that is not addressed to you personally by means of the Company’s website.

11.4. You agree that we may record all communications between you and us and use such
recordings, or transcripts of such recordings, as well as any e-mails, recorded chat
messages or other communications you send to us through our Platform or otherwise, for

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training purposes, for the purposes of investigating any complaint you may make, or for any
other legal or regulatory purposes including as evidence in any dispute or anticipated
dispute between you and us. Upon your request and in accordance with our Privacy Policy,
we will provide a copy of such records to you within a reasonable period.

11.5. If you no longer want to receive email, in-app or push notifications from Us, you can
easily unsubscribe by following these steps:

a. When you receive a notification from Us in your email, please click on the
“Unsubscribe from this type of notifications” link at the bottom of the email page and
we will immediately unsubscribe you from receiving the respective category of
notifications; or

b. Log in to your Account via our Website or the Trading 212 mobile application, go to
“Settings”, then “Notifications” and simply tick the notifications you would like to
receive. (If you are no longer willing to receive any notifications, just untick them all).

Notwithstanding the above, please note that we might be obliged to notify you about certain
events (i.e. amendments to this Agreement) and therefore, you cannot unsubscribe from
receiving mandatory communications.

12. Placing an Order to Deal.


12.1. We will treat each Order you place for the Share Dealing Services as an offer to purchase
services subject to this Agreement. We may, in our reasonable discretion, refuse to accept
any Order or instruction from you, or we may accept your Order subject to certain conditions
or we may, acting reasonably, refuse to proceed with an Order that we have accepted
(including but not limited to situations where we are unable to execute your Order due to
restrictions with our executing brokers or other third parties, trading venues or due to
unusual market conditions). If we do this, we will make all reasonable efforts to facilitate
sales and notify you in writing unless we are prevented from doing so by law.

12.2. Orders may be executed after acceptance by us. In some situations, we may provide a
partial fill of an Order as an alternative to an outright rejection. If an Order can only be

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executed partially due to various reasons or applicable limits, you authorise us to make all
reasonable efforts to execute that part of the Transaction.

12.3. Orders executed during 24/5 Trading will be processed by Trading 212’s Systematic
Internaliser, as defined in our Order Execution Policy. All order types available during Regular
Trading Hours will be available during 24/5 Trading. Market conditions however may differ
significantly in comparison to Regular Trading Hours and you should consider the risks
related to trading outside of Regular Trading Hours. Please refer to our Order Execution Policy
and Disclosure Notice for more details.

12.4. By placing an Order for the purchase of Investments, you agree that you will have
sufficient funds in your Account on the date when you are required to make the payment to
settle the trade. When you place an Order, we shall exercise our best efforts to calculate the
maximum amount of Available Cash that you can spend on this Order and add a
reasonable percentage above the current market price to cover market price changes
(“Total Order Blocked Funds”). The Total Order Blocked Funds will be blocked and will not
form part of Available Cash. Upon execution of the relevant Order any residual funds of the
Total Order Blocked Funds will be returned to the Available Cash. We shall not accept an
Order if there are not sufficient funds at the point of placing and it is your sole responsibility
to make sure that you have sufficient Available Cash in your Account to cover the Total
Order Blocked Funds.

12.5. You acknowledge and accept that there may be a delay in the execution of an Order
because all Orders are executed strictly by reference to time of receipt. In particular, an
Order received when the relevant exchange is closed or not on a Business Day will not be
executed until after it next re-opens. We will present that Order for execution when the
exchange next reopens or, if a large number of Orders have been received while the market
is closed, as soon as reasonably practicable after the exchange next re-opens.

12.6. You acknowledge and accept that:

a. we do not guarantee a fixed price for execution, except to Limit Orders (as defined in
our Order Execution Policy);

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b. for each Transaction, you shall receive a quote from the Trading Platform. The quote
shall only be valid until replaced by a new one, which shall happen automatically on
the Trading Platform;
c. All quotes displayed on our Trading Platform are only indicative; and
d. Due to price movement, the actual execution price may differ.

12.7. You can place an Order as long as the value of the Order does not exceed 95% of the
Available Cash in your account. Regardless of this, you can still end up with a negative
balance on your Account in cases of sudden market volatility, where the price would
drastically change between the time of giving the order and its execution. This is commonly
referred to as ‘Order slippage’. Should such a change occur, and your obligation to settle
exceeds your Available Cash, you will remain liable to settle the Deal in full. If a Deal results in
a negative balance on your Account, you instruct us to attempt to sell the part of your
Position that results in a negative balance to prevent a negative balance on your Account -
we will do this on a best-effort basis.

12.8. You are not permitted to Short Sell. This means that you cannot give us an Instruction to
sell an Investment that you do not own at the time of the sale and that is not held on your
Account, whether settled or unsettled at the time of sale.

12.9. When you place a buy Order, the funds to be invested will be used by Trading 212 to
cover both the price of the Financial Instrument/s and any applicable transaction tax and/or
stamp duty, governmental or administrative levy and fee or other liabilities. Similarly, when
you place a sell Order, any applicable transaction tax and/or stamp duty, governmental or
administrative levy and fee or other liabilities will be subtracted from the receipts booked in
your Account. Transaction tax is the collective term referring to all taxes and levies charged
in transactions in Financial Instruments in all applicable jurisdictions. Certain jurisdictions
may oblige you to pay a certain amount (usually, a fixed percentage) of transaction tax or
stamp duty. The existence and amount of tax depend on the specific type of Financial
Instrument and the applicable national legislation. Trading 212 will on a best-effort basis
withhold those transaction taxes from you and the relevant funds will cease to be protected
under Client Money Rules, as they will be due to the respective authorities and not to you.
Specific cost details will be provided to the Client within the order review window.

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12.10. You accept that some small and micro-cap shares trade on highly illiquid markets or
by way of an auction or other non-standard bidding process, which may cause delays in
executing Orders in such Financial Instruments. In these circumstances, you agree that
Trading 212 will process your Order as soon as is reasonably possible. Trading 212 will not be
liable for any financial losses, perceived or actual, that you may suffer as a result of these
delays.

12.11. Trading 212 may temporarily or permanently, at any time and at its sole reasonable
discretion, place restrictions and other limits on the minimum and/or maximum size of any
Order or Position in any Investment. Such limits will be imposed as a result of considerations
including but not limited to market conditions and/or an assessment of Trading 212’s risk
and/or compliance departments. In such an event, we will exercise our best efforts to inform
you as timely as possible by email or through our Trading Platform. Nevertheless, it is your
responsibility to monitor your Account and be informed about the current size limits
imposed on Orders that you may want to execute.

12.12. Multi-Currency Accounts allow you to select the currency of your Order before placing
it, which can be either the Instrument Currency or your Primary Currency. You will not be able
to place an Order in more than one currency. You are responsible for ensuring you hold
sufficient Available Cash in the currency you selected for your Order. In case you do not hold
sufficient Available Cash in the currency of your Order, your Order may not be executed or
may be executed partially.

13. Fractional investing.


13.1. Trading 212’s Fractional Shares programme allows you to purchase securities in
monetary amounts rather than share quantities. The benefits of fractional shares are that it
provides extensive diversification for relatively small investments, but you should be aware
of the unique features, risks and limitations prior to participation in Trading 212’s Fractional
Shares Programme. This is noted in our Disclosure Notice and Order Execution Policy.

13.2. If you hold fractional entitlements (such as dividends, options and voting rights), you will
have the sole beneficial interest to the entitlement. Any dividend payable to you will be on a
pro-rata basis to reflect your fractional entitlement (we will hold these on your behalf in line
with the FCA Rules see Clause 16 below). We will exercise our best efforts to provide you with

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the possibility to exercise any voting rights on a pro-rata basis, in line with conditions of
Clause 24. We do not restrict in any way any rights you would otherwise have over the
securities and funds in your Trading 212 account, including any fractional shareholdings.

13.3. You acknowledge and agree that fractional shares are not transferable. If you close
your Account or transfer your Account to another firm, the fractional shares held in your
Account shall be liquidated. Similarly, Fractional shares cannot be put into certificate form
and mailed. Liquidations of fractional shares may result in additional charges.

14. Client money.


14.1. Any money, regardless of its currency, held on your behalf by us that qualifies as client
money for the purposes of the FCA Client Money Rules will be protected in accordance with
those rules and held in a segregated bank account, Term Deposit or held with a Qualifying
Money Market Fund (QMMF) alongside the money of our other clients. If your money is held in
a QMMF, the client assets custody rules provided in Clause 16 will apply.

14.2. When you hold Cash in your Account or Stocks ISA Account with us, we may hold your
money in one or more of the following:
a. Interest-bearing Regular Bank Deposits with UK/EU-regulated financial institutions;
b. Interest-bearing Term Deposits with a term of up to 95 days with UK/EU-regulated
financial institutions; and/or
c. QMMFs (only if you provide express consent as per Clause 15 below).

14.3. When we hold money in Term Deposits, subject to the Applicable Law, those Term
Deposits may only permit a withdrawal on the provision of notice or at the end of the term,
which may be up to 95 days. This will not affect your ability to withdraw your money or
otherwise use it for making Investments. However, if Trading 212 or the UK/EU-regulated
financial institution fails, there might be a delay in accessing your money for withdrawal. For
a more detailed overview of the applicable risks, please refer to our Disclosure Notice
available on our Website.

14.4. All due skill, care and diligence will be exercised in the selection, appointment and
periodic review of any third-party UK/EU-regulated financial institution or QMMF with whom

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your money is placed. We will not be responsible for any acts, omissions or defaults of the
third-party bank or QMMF.

14.5. Where permitted by CASS Rules and in the event that there has been no movement on
your Account balance for a period of at least six (6) years and we are unable to contact you
despite having taken reasonable steps to do so, you agree that we may cease to treat your
money as client money and may pay it to a registered charity of our choice. Where we do
this, we will unconditionally undertake to pay you a sum equal to that paid to charity if you
later contact us to claim these amounts.

14.6. Where appropriate, you authorise us to allow another person such as an exchange,
clearing house or executing broker to hold or control your client money for the purposes of
your Transactions on your behalf through or with that other person.

14.7. In the event of our failure (for example, due to insolvency), any money held in a client
money account by third parties or deposited with a QMMF will be segregated from our other
assets and will not be available to our creditors. However, in the event of failure (for example,
due to the insolvency) of a third party, as your client money will be held with other
customers' money in a pooled client money account or QMMF in the event that the third
party holding the money defaults and there is a shortfall, you agree to share proportionately
in that shortfall with other creditors of the third party where your client money is deposited.

14.8. We may hold client money in a client bank account or QMMF located in a jurisdiction
outside of the UK. The legal and regulatory regime applying to any such third party will be
different from that of the UK, and in the event of the insolvency or any other equivalent
failure of that third party, your money may be treated differently from the treatment which
would apply if the money was held with a bank or QMMF in the UK.

14.9. Your money will cease to be Client Money when it is paid to you or to one of your duly
authorised representatives; or paid to a third party on your instructions, or paid to us when
money is due and payable to us.

14.10. We will take all the necessary steps to ensure that the clients’ funds are safeguarded.
Specifically, we will:

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a. maintain records and accounts enabling us at any time and without delay to
distinguish funds held for one client from funds held for any other client and from our
own funds;
b. maintain records and accounts in a way that ensures their accuracy and, in
particular, their correspondence to the funds held for our clients and that they may be
used as an audit trail;
c. introduce adequate organisational arrangements to minimise the risk of the loss or
diminution of client funds, or of rights in connection with those funds, as a result of
misuse of funds, fraud, poor administration, inadequate record-keeping or
negligence;
d. introduce arrangements to ensure that clients’ funds are safeguarded in the case of
insolvency;
e. appoint a single officer of sufficient skill and authority with specific responsibility for
the safeguarding of client funds.

14.11. When making use of our Multi-Currency Account functionality, your funds may be held
in different client bank accounts or QMMFs. Nevertheless, at all times, they shall constitute
Client Money and shall be subject to the applicable FCA CASS Rules, unless they are QMMFs -
in such an event, they shall constitute Client Assets.

14.12. Given the nature of the Share Dealing Services, your Account will ordinarily not have a
negative balance. Nevertheless, it is possible for your Account balance in your Primary
Currency and/or Non-Primary Currency to be negative in certain limited situations. This
includes situations such as Order slippage (as described in Clause 12.7), fees and charges
imposed by the issuers of Financial instruments (as described in Clause 18.5) or when using
a Trading 212 Card for offline transactions (as described in Clause 10.7). When making use of
our Multi-Currency Account, you agree that we have the right to convert funds you hold in
your Primary Currency and/or Non-Primary Currency to cover a negative balance in any
other currency. You also agree to immediately deposit sufficient Available Cash to cover any
negative balances on your Account balance.

15. Interest Sharing Programme.


15.1. If you provide us with your express consent to participate in our Interest Sharing
Programme, in addition to Regular Bank Deposits and Term Deposits, we may hold your

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Cash in a QMMF. We will retain any received interest, and we will separately pay you part of it
in the currencies and at the rates specified in the Terms and Fees page on our Website.
Please note that these currencies and rates may be subject to change, as per Clause 15.4
below. In case you make use of our Multi-Currency Account and hold Cash in more than one
interest-paying currency, you will be able to earn interest on each of those balances. Not all
currencies offered in the Multi-Currency Account are interest-paying - you can see which
currencies are interest-paying in the Terms and Fees page on our Website.

15.2. At any time, you can change your mind and either opt in or out of the Interest Sharing
Programme via our Website. If you choose not to participate in the Interest Sharing
Programme, we will not hold your Cash in QMMFs and therefore, no interest will be paid to
you as per clause 15.1. We may still hold your Cash in Term Deposits and/or Regular Bank
Deposits with UK/EU-regulated financial institutions, and we will retain any received interest.

15.3. The interest rate we receive can be subject to immediate change by the regulated
UK/EU financial institutions and/or QMMF managers, for instance, due to changes in the
applicable base rate by the Bank of England or the European Central Bank. If we lower the
interest rate you receive, we will give you at least one(1) day’s notice. If we increase the
interest rate to your advantage, we will apply the changes immediately and not send a
notice.

15.4. If you opt-in to the Interest Sharing Programme and meet the criteria for receiving
interest on your Cash according to this Clause 15, no further action is required on your part
to receive the interest. It will be credited to your Account or Stocks ISA Account automatically
at the end of each Business Day and reflected on your periodic Statement. Please note that
any interest paid into your Stocks ISA Account will not impact your maximum subscription
limit.

15.5. You will be eligible to receive interest as of the next day after you opt in to the Interest
Sharing Programme, and you will not receive any interest for the day you opt out of it. We will
only pay you the interest if that amount is greater than or equal to one (1) penny (or cent,
depending on the currency). If it is less than that, we will retain it and roll it forward until one
(1) penny is accumulated and then pay it out to you. Until such time, any amount less than
one (1) penny will not be held as client money under Clause 14.

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15.6. Depending on your tax residency and the type of your Account, a tax may be
applicable. You are solely responsible for any tax liabilities and if in doubt, you should
contact the relevant tax authorities with any queries.

16. Client assets.


16.1. You instruct us to hold any Investment (including your money held in QMMFs, if
applicable) bought on your behalf until we receive further instructions from you to sell or
transfer it into your own name or to another nominee, subject to the conditions specified in
Clause 17. We will hold Investment on your behalf in accordance with Chapter 6 of the FCA’s
Client Assets Rules.

16.2. We may, subject to the FCA’s Client Assets Rules, appoint any other third party to hold
your Investments, including documents of title or certificates evidencing title to such
Investments. We will exercise reasonable skill and care in the selection, appointment and
periodic review of such third parties, but we are not liable for their acts, omissions, insolvency
or dissolution. Any discrepancy in terms of client assets and any resulting shortfall will be
dealt with in accordance with the FCA Client Assets Rules.

16.3. A third party holding your Investments may have a security interest, lien or right of
set-off over your Investments, which are not settled as per Clause 8. This may be required by
applicable laws to such a third party in the jurisdiction where your Investments are held or
may be imposed by the third party as security for the fees it charges for holding your
investments. In the unlikely event that a third party exercises its rights over such unsettled
Investments, Trading 212 will be liable to you for all and any such Investments.

16.4. You hereby authorise us to hold your Investments in safe custody as your custodian (or
appoint a Sub-custodian to do so), to transfer securities from your account to meet sales
effected for your account, to accept offers, or undertake other matters in relation to your
Investments covered by this Agreement.

16.5. Detailed records of all your Investments and assets held by us will be kept at all times to
show that your Investments are held on your behalf, for your benefit and do not belong to us
or any Sub-custodian.

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16.6. Investments purchased by us on your behalf or transferred to us will be registered in the


name of a Nominee Company or our name or a Sub-custodian. We will be responsible and
liable for our nominee to the same extent as for our own acts, including losses arising from
fraud, wilful default or negligence.

16.7. Whenever your Investments are registered in the name of a Nominee company
nominated by us, that Nominee will hold them in trust for you. This means that you are the
beneficial owner of the Investments. Any Investments held by a Nominee will be held in an
omnibus account.

16.8. Your Investments will be registered in the same name as those of other clients (pooled
together with other clients’ Investments in an omnibus co-mingled custody account, like
with like). This means that Investments may not be immediately identifiable by way of
separate certificates. If our third-party nominee or we were to become insolvent, there may
be delays in identifying individual assets and possibly an increased risk of loss if there
should be a shortfall because additional time may be needed to identify the assets held for
specific clients. In addition, in the event of an unreconciled shortfall caused by the default of
a Custodian or Sub-custodian, you may share proportionately in that shortfall.

16.9. You authorise us and any Sub-custodian to hold or transfer Investments (or
entitlements to them) to a securities depositary, clearing or settlement system. Investments
that cannot be settled through a central securities depository system may be held overseas
by a third-party (includingSub-custodian, registrar, bank, executing broker, or settlement
agent) under the conditions of Clause 16.10 below and the applicable FCA CASS Rules.

16.10. You agree to the following: because of the nature of applicable laws or market
practices in certain overseas jurisdictions, it may not be possible to register your
Investments in your name, the name of the nominee or other relevant third party and, where
we have determined that it is in your best interests, or it is not feasible to do otherwise, your
Investments may be registered or recorded in our name or in the name of the person who is
a Sub-custodian insofar as permitted per the applicable FCA Rules.

16.11. We may be required to give your details (including your email address) and details of
your shareholding to Companies House or registrars.

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16.12. In the event that we have not received instructions from you in relation to any of the
Investment held in your account (e.g. to purchase, sell or move the assets) for a period of at
least twelve (12) years (notwithstanding any receipts of dividends or interest or similar items
and irrespective of any movement of your account balance) and we are unable to trace you
despite having taken reasonable steps to do so, you agree that we may cease to treat your
assets as client assets.

17. Investment Transfers.


17.1. You may be able to transfer Investments to your Account or Stocks ISA Account from
another investment provider. You will be able to request a transfer of Investments via the
Website. We will only accept Investments that are tradeable on our Trading Platform. The
account with the other investment provider needs to be in your name.

17.2. You may be able to transfer Investments out of your Account or Stocks ISA Account to
another investment provider. You will be able to request a transfer of Investments via the
Website. We will only transfer Investments that are accepted by the other investment
provider. The account with the other investment provider needs to be in your name.

17.3. We will not charge you any fees for transfers to or from your Account or Stocks ISA
Account. The other investment provider may impose fees or limits to such transfers.

17.4. Investment Transfers to or from your Account will be only in the form of Investments. You
will not be able to transfer cash in or out using Investment Transfers. Transfers to or from
your Stocks/Cash ISA Account may involve cash - please refer to the ISA Terms for more
details.

17.5. Investment Transfers do not follow the standard settlement practices described in
Clause 9. We will do our best efforts to ensure that Investment Transfers are processed
within the usual limit of up to 30 calendar days. Please note that depending on the
cooperation of the other investment provider, this process may take significantly longer.
Once you have requested an Investment Transfer and we have initiated it, you will not be
able to cancel it unless the Investment Transfer cannot be processed. Where you request an
Investment Transfer to your Account or Stocks ISA Account, we will consider the relevant
Investments your Client Assets as of the date we receive them from the other investment

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provider. Similarly, where you request an Investment Transfer from your Account or Stocks
ISA Account to another investment provider, we will stop considering the relevant
Investments your Client Assets as of the date we send them to that investment provider.

17.6. It may not be possible for you to transfer certain Investments out of your Account or
Stocks ISA Account. These include:

a. Investments that are not accepted by the other investment providers;


b. Investments that have been suspended from trading;
c. Investments that have not yet settled, as per Clause 8.;
d. Fractional shares, as per Clause 13.3.;
e. Investments that are not transferable due to other regulatory or technical reasons.

Where Investment Transfers of certain Investments are not possible, you may or may not be
able to liquidate the Investments to cash and transfer the cash from or to the other
investment provider. Please note that this may result in additional charges imposed by third
parties or taxes.

17.7. You will be able to receive up-to-date information on all Investment Transfers at all
times via the Website.

17.8. When requesting an Investment Transfer, you are solely responsible for providing
accurate information and data to us, including, where applicable, information on the price
at which you acquired the Investments. Failure to do so may result in the delivery of
inaccurate information by us on your profit or loss with respect to Investments that were
transferred via an Investment Transfer. You remain solely responsible for any and all tax
obligations relating to Investment Transfers, including where you have provided inaccurate
information or data to us.

17.9. Where you request an Investment Transfer from your Account, we will restrict you from
placing Orders in the relevant Investments that are subject to the Investment Transfer.
Please refer to the ISA Terms for the further restrictions in place with respect to any
Investment Transfers of Stocks ISA accounts.

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17.10. We reserve the right to refuse to facilitate an Investment Transfer to or from an


investment provider outside the UK/EEA.

18. Fees.
18.1. If applicable, you shall pay the charges and/or commissions details of which are set out
in the Terms and fees and may be amended from time to time by written notice from us to
you. For Multi-Currency Accounts, any applicable fees due when executing orders will be
deducted from the currency of the relevant Order.

18.2. Charges due to us shall be due immediately upon our demand which may be oral or in
writing unless otherwise agreed and shall be paid by you as stated on Confirmations and
periodic Statements, and such charges may be set off against any payment due from us to
you. You agree and understand that any other obligation and liability towards us is subject
to unilateral set-off from your side going back to the beginning of our contractual
relationship.

18.3. You acknowledge that Zero (0) commission will be subject to any applicable tax,
governmental or administrative levy, and fee or other liabilities, charges, costs and expenses
payable in connection with the transactions effected on your behalf.

18.4. You agree that Trading 212 will not be liable for any additional fees you may be charged
by any bank or other third-party financial services provider, which you use for the transfer of
funds to and from us.

18.5. Some Financial Instruments (including but not limited to American Depositary Receipts,
ADRs) may be subject to fees and charges imposed by their issuer. These will be charged to
your Account. As a result, your Account may end up with a negative balance if there is
insufficient Available Cash to cover these fees and charges. You agree to immediately
deposit sufficient Available Cash to cover the negative balance.

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19. Risk warnings.


19.1. There are risks involved with the use of the Share Dealing Services, including investment
risk caused by the fact that the value of your investments will change over time. For a more
detailed overview of the applicable risks, please refer to our Disclosure Notice available on
our Website.

19.2. Our Disclosure Notice is intended as a general description of risks associated with our
specific products and services and may not identify all possible risks. You should always
satisfy yourself that the Share Dealing Services or Transactions are suitable and appropriate
for you in light of your specific circumstances.

20. Market Abuse.


20.1. You shall not act in any way other than in the normal course of business or seek to
manipulate the relevant financial market and/ or the Company’s trading platform, including
but not limited by entering into a transaction which may qualify as:

a. Market abuse (such as insider trading or abusive use of confidential information) or


any similar practices which may qualify as market abuse; Insider trading is a criminal
offence for which you can be prosecuted, fined and imprisoned;
b. Scalping;
c. Acting in concert with a third party or similar abusive or manipulating way of using
the Trading Platform;
d. Platform abuse, price manipulation, time manipulation or similar practices; and
e. Exploiting errors in prices.

20.2. The confirmations set out in Clause 20.1. are made by you on the date of this
Agreement and are deemed to be repeated on each day this Agreement is in full force and
effect. In case of any breach, we shall have the right to cancel or void any Order or trade
made in violation of Clause 20.1. (regardless of whether the Position is still open or closed), to
close your Account and to terminate the Agreement. In such a case, we shall not be held
liable for any damages incurred by you.

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21. Conflict of Interest.


There may be limited circumstances in which a conflict exists between your interests and
those of us or our other clients. To mitigate and control these conflicts, we have drawn up a
Conflicts of Interest policy, part of our Disclosure Notice, available on our Website.

22. Order Execution.


22.1. In accordance with the Applicable Law, we have implemented an Order Execution Policy
that sets out the steps that we will take in order to obtain the best possible result
(best-execution) on behalf of our clients. The Order Execution Policy applies when we
execute Orders from Clients to trade in any of the Investments offered by us. As stated in
Clause 2 above, the Order Execution Policy is an integral part of this Agreement, and it can
be found on our Website.

22.2. Under certain conditions, as stated in Clause 9 of the Order Execution Policy, we may
aggregate your Orders with those of other clients. In certain cases, such aggregation may
mean that you obtain a less favourable price.

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23. Trading Platform.


23.1. You shall instruct us to deal for you electronically via our Trading Platform.

23.2. We will endeavour to execute all eligible Instructions to Deal as soon as reasonably
practicable.

23.3. Where a delay occurs because we are unable to interact with the relevant market for
any reason, we will attempt to execute your Instruction to Deal as soon as reasonably
practicable.

23.4. We may be required to cancel a Transaction if requested by a relevant stock exchange


or may be required to cancel an Instruction to Deal if requested or recommended by an
exchange, and you agree to use all reasonable endeavours to assist us in this regard.

23.5. You acknowledge that all proprietary rights in the Trading Platform are owned by us or
by any applicable third-party licensors or service providers selected by us and are
protected under copyright, trademark and other intellectual property laws and any other
applicable laws.

24. Voting Rights, Interest, Dividends, and


Corporate Actions.
24.1. It may be possible for you to participate in a Corporate Action (including but not limited
to dividends, voting rights, stock split, merger, spin-off, exercise of any conversion or
subscription rights or other types of Corporate Actions attached to Investments we hold on
your behalf). We will exercise our best efforts to inform you of such Corporate Actions, but we
cannot guarantee the timely delivery or correctness of any information provided by us with
regards to such Corporate Actions. We are not obliged to, but we may arrange for your
participation in such Corporate Actions. We do not accept any liability for any actual or
potential loss you may suffer if we are unable to facilitate your participation in any
Corporate Action.

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24.2. We will be responsible for claiming and receiving dividends, interest payments and
other income payments accruing to your Investments we hold on your behalf. Trading 212
will book any proceeds from your Investments in your Account balance. In the case of
Multi-Currency Account, such proceeds will be credited to your Primary Currency. Dividend
payments will remain exempt from foreign exchange fees and any exchange will be done at
the live currency exchange interbank rate. However, often a withholding tax would apply to
such proceeds and we will exercise our best efforts to collect the applicable withholding tax,
whereupon the relevant funds will cease to be protected under Client Money Rules, as they
will be due to the respective authorities and not to you. The existence and percentage of
withholding tax depends on various factors and circumstances, such as your tax residency,
the national legislation of the issuer and any applicable tax treaty. In some cases, you may
be able to reclaim all or part of any withheld taxes and may be required to provide
additional information to the relevant tax authority. Please note that you are solely
responsible for tax filing and reporting. If required by law and upon demand, Trading 212 will
provide information relating to you to the relevant tax authorities.

24.3. You shall be solely responsible for providing us with your instructions in respect of
Clauses 24.1. and 24.2. above, but if we are unable to obtain your instructions, we may,
without incurring any liability, use our judgement and act as we think fit in your best interest.

24.4. As a result of Corporate Actions, you may be allocated fractional shares. Trading 212 will
aim to provide them as fractional shares, however, if that is not possible for any reason,
Trading 212 will pay a cash equivalent of your fractional shares to your trading Account.

24.5. In the case of Corporate Actions, you understand and accept that the terms and
delivery date of the Corporate Action can be subject to immediate change without notice
due to changes made by the issuer or any other entity involved in the Corporate Action. You
accept that any Corporate Action can be amended, withdrawn or cancelled at any time.
You acknowledge and accept that these changes are beyond the control of Trading 212,
which will not be liable for any financial losses, perceived or actual, that you may suffer as a
result of these delays.

24.6. In the event of a stock split, you acknowledge and accept that Trading 212 may be
unable to apply the split to fractional investments. In these circumstances, you accept that
Trading 212 may offer to pay you a cash equivalent of your holding at the time of the stock

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split as an alternative, which may result in you no longer holding shares in the affected
securities. You accept that Trading 212 is under no obligation to obtain your consent prior to
taking this action.

24.7. In the event of a merger, spin-off, or special stock dividend, we will exercise our best
efforts to provide you with the new stock. However, this may not be possible in certain
situations, for instance, due to the omnibus structure of the custody account or technical
reasons. You consent that in such situations, the relevant corporate action will be paid in
cash to your Account. If, after your Account has been deactivated, you become entitled to a
stock dividend or other corporate action, you expressly instruct us to convert that
entitlement to cash (for example by selling a stock dividend) at the first available
opportunity and to return the full proceeds to any of the methods that you used for deposits.
In the event that none of the methods is active, we will exercise our best efforts to notify you
and obtain information on an alternative method to return the relevant proceeds.

24.8. When making use of Overnight Trading and dealing with stocks affected by a
Corporate Action (such as a stock split, merger, acquisition, new listing, or delisting), the
value and quantity of the respective Investments might be affected. In such cases, these
stocks may be restricted for trading by the respective exchange until a complete Regular
Trading Hours session has taken place following the processing of the Corporate Action.

24.9. In the event that there is a client money entitlement that cannot be allocated to you in
whole pennies or cents, meaning there is a residual amount of less than one (1) penny or
cent (as applicable, depending on the currency of your Account) that needs to be allocated
to you, you expressly agree that we may write this amount off and pay it away to a
registered charity.

25. Dividend Reinvestment.


25.1. We may allow for dividends on stocks in your Account to be reinvested, and it may be
done automatically as long as you instruct us to do so, by making use of Trading 212’s
Investment Pies technical tool. In the case of Multi-Currency Account, dividend reinvestment
will be processed in your Primary Currency. For more information, please refer to our Pies
and Autoinvest Terms, which in case of contradiction, shall prevail over this Clause 25.1.
Dividends on stocks will only be reinvested in the same stock where the dividend originated

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from. Instructions to reinvest dividends will not be carried out if your Account has been
suspended or restricted by us in accordance with this Agreement.

25.2. You will receive the maximum whole number of shares or fractions of a unit that can be
bought on your behalf. If your entire stock is sold before the dividend payment date, no
reinvestment will take place, and the whole of your dividend will be paid in cash to your
Account.

25.3. Dividend reinvestment will take place as soon as reasonably practicable following
payment of the dividend to your Account. We reserve the right to delay or postpone
investments where there is insufficient liquidity in the market and in certain circumstances
(e.g. if the relevant eligible investment is not available, in extreme market conditions, for
operational reasons or due to a system failure or malfunction). We will not be responsible for
any loss which you may incur as a result of such market movements.

25.4. The number or value of stocks you will receive for each dividend that is reinvested will
depend on:
a. the amount of your cash dividend, which is based on the number of existing stocks of
that type you hold at the relevant dividend record date multiplied by the dividend
payment amount;
b. the market price at which the new stocks are bought; and
c. the dealing costs and stamp duty reserve tax for the purchase of the new stocks.

26. Share lending.


26.1. We offer a Share Lending Programme, where you allow us to borrow shares that you
hold in your Account in accordance with the terms of this Clause 26 and in compliance with
the FCA Rules. To participate, you can provide your express consent during the opening of
your Trading 212 Account opening process or at a later point. Before opting in, please review
our Disclosure Notice, which provides details about the associated risks.

26.2. You can withdraw your consent from our Share Lending Programme at any time
without any charge. This will not affect your Account with us, and you will continue to be a
Client of Trading 212. Your withdrawal will normally be processed within two days, in line with
standard settlement practices.

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26.3. When your shares are lent, Trading 212 receives interest on a daily basis. We share 50%
of that interest with you based on the proportion of your shares that have been borrowed.
We will pay this amount into your Account on a daily basis and hold it as Client Money. If the
amount is less than one (1) penny or cent, as applicable, we will use a rounding method
called “half up” and pay you the rounded-up amount. Please note that, in the case of
Multi-Currency Trading, interest from lent shares will be credited to your Primary Currency
balance.

26.4. Where we borrow your shares, you continue to be the beneficial owner of the shares,
and you continue to have the market exposure inherent to beneficial ownership of the
shares. You will also retain the legal right to receive the lent shares back from us but they will
not be held according to FCA’s Client Assets Rules. Instead, we will hold collateral for you,
equal to at least 102% of the value of shares lent. The collateral will be in the form of US
Treasury Bonds and will be held in line with FCA’s Client Asset Rules in a segregated account
with a reputable third party. We will monitor the collateral on a daily basis, to ensure that its
value is equal to or more than 102% value of the shares lent.

26.5. Participating in the Share Lending Programme will not restrict you from selling your
shares at any time. You will not experience any delays in executing trades due to share
lending.

26.6. We do not guarantee that your shares will be borrowed. We may borrow all, some or
none of the shares in your Account, depending on the market demand for the shares you
hold in your Account. It is not possible for you to choose which shares will be lent. You can
see whether we have borrowed your shares on the Trading Platform, which will also include
information on the number of lent shares, their value, the value of the collateral and interest
you receive. This information will also be visible in your Statements.

26.7. When we borrow your shares, we act as your counterparty and are obliged to redeliver
those shares to you. We may on-lend the shares we borrowed from you to a reputable third
party (the “Borrower”) through a back-to-back lending arrangement. The Borrower will have
an obligation to redeliver the shares to us.

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26.8. While your shares are lent, you will no longer have legal ownership of them until they
are redelivered. Therefore, you will no longer be able to exercise some of the attached
shareholder rights, including any voting rights, on the lent shares.

26.9. Shares lent to the Borrower are generally recalled from the Borrower before the
ex-dividend date to capture the dividend. Where the recall does not happen, we receive a
payment from the Borrower, and you will be entitled to a payment from us in the form of a
manufactured payment in lieu of a dividend, equivalent to the dividend you would otherwise
have received. Please note that this payment may have different tax implications, and you
are responsible for any associated tax obligations.

27. Confidentiality.
Both parties shall hold in confidence all personal, business, financial and other confidential
information which is obtained about the other party as a result of providing the Services to
you and shall use all reasonable endeavours to prevent any disclosure of such information,
subject to this Clause. We may disclose information about you in the following
circumstances:
a. to any authority having the legal right to your information (including any law
enforcement or tax authority);
b. where we are required to disclose information pursuant to any court order or a similar
process;
c. where we are otherwise required or permitted by law to make disclosure; or
d. where necessary in order to provide you with the Services.

28. Personal Data Protection.


28.1. We will collect and hold personal information of you in our administration for the
purpose of providing you services under this Agreement. Your information will be processed
as specified in the Privacy Policy and Cookies Policy, available on our Website, in line with the
Applicable Law.

28.2. We are required to identify and verify the identity of our clients and, in certain
circumstances, those of other persons such as directors or beneficial owners, in accordance

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with the Money Laundering Regulations 2017, and to keep that information updated. You shall
agree that we may make checks using online electronic verification systems or other
databases as we may decide. These may request, among other things, further details,
documents, photo and video evidence from yourself. If you cannot satisfactorily prove your
identity, you will not be able to open an Account with us or may have to close your existing
Account. We may also report to official agencies any information which may come to our
attention that gives rise to money laundering or terrorist financing concerns. We may be
prohibited from notifying you of any report we may have to make or from either confirming
or denying that a report has been made. If we submit a report to the National Crime Agency
or analogous authority, we may be prohibited from continuing the provision of Share Dealing
Services to you while the authorities undertake their own investigations; and we may be
ordered to stop providing Share Dealing Services altogether. In those circumstances, we
shall not be able to accept responsibility for any resulting loss or inconvenience.

29. Event of Default.


29.1. Each of the following constitutes an ‘Event of Default’:
a. you default in any payment or other obligation you may have to us;
b. any bankruptcy, winding-up, administration or similar petition be filed by or against
you;
c. notice be given of a general meeting of your creditors or any similar event;
d. you die or become of unsound mind;
e. any event beyond our control occurs in the country in which you are normally
resident, which, at our sole discretion, makes it desirable for the protection of
Trading 212 UK Ltd. to treat the same as an Event of Default;
f. any termination or suspension or loss of any relevant regulatory authorisation;
g. any representation or warranty made under this Agreement proves or becomes false
or misleading in any material respect;
h. we consider it necessary or desirable for our own protection or to prevent what we
consider is or might be a violation of any Applicable Law or good standard of market
practice or any action is taken or event occurs which we consider might have a
material adverse effect on your ability to perform your obligations under this
Agreement; and
i. any event of default (howsoever described) occurs under any other agreement
between us.

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29.2. At any time following the occurrence of an Event of Default, we may, by written notice to
you, terminate this Agreement immediately.

30. Force Majeure.


30.1. Whilst we endeavour to comply with our obligations in a timely manner, we shall incur
no liability whatsoever for any partial or full default of our obligations by reason of any cause
or event beyond our reasonable control, including but not limited to any communications,
systems or computer failure, market default, suspension, failure or closure, or the imposition
or change (including a change of interpretation) of any law or governmental or regulatory
requirement and we shall not be held liable for any loss you may incur as a result. In addition
to and notwithstanding any of the above, the Force Majeure definition shall include, but shall
not be limited to any superior force, any event that encompasses acts of god (such as
earthquakes or tsunamis, etc.), certain acts of man of a disruptive and unforeseeable
nature, industrial action, epidemics, pandemics, actions by government agencies, or work
stoppages, any material change in economic conditions or any other event, that is beyond
the reasonable control and was and whose effects could not be avoided by reasonable
measure.

30.2. Force Majeure shall include any of the following: the suspension or failure of any
Financial Instrument, whether underlying or not, the suspension or closure of any markets,
exchanges, the nationalisation and/or government sequestration, the failure of any of our
suppliers, and if applicable our executing broker, agent or principal, dealer or any
Sub-custodian, clearing house or regulatory or self-regulatory organisation, for any reason,
to perform its obligations. Whereas in any such event, we will try to take reasonable steps to
mitigate the effect of the said event in order to continue our operations and to continue to
provide you with services and where we may therefore alter some of the (trading) terms and
conditions as per this agreement.

31. Complaints and Disputes.


31.1. Please inform us about any complaint as soon as practicable. Our internal complaint
handling policy is available on our Website, as required by the FCA Rules.

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31.2. If you are unhappy with the service that you receive from us or if we have been unable
to resolve the complaint to your satisfaction, you may be entitled to refer the matter to the
Financial Ombudsman Service (which provides consumers with a free, independent service
for resolving disputes with investment firms) via the website:
www.financial-ombudsman.org.uk, telephone: 0300 123 9 123 or 0800 023 4567, email:
[email protected] or in writing: The Financial Ombudsman
Service, Exchange Tower, Harbour Exchange Square, Isle of Dogs, London E14 9SR.

31.3. In the event that we are unable to meet our obligations to you, you shall have the right
to seek compensation from the Financial Services Compensation Scheme (the "FSCS") in
respect of the Services. This depends on the type of business and the circumstances of the
claim. As of the date of this Agreement, compensation is limited to 100% of the first £85,000.
Further information about compensation arrangements is available from the Financial
Services Compensation Scheme via the website: www.fscs.org.uk, telephone: 0800 678 1100
or 020 7741 4100 or in writing: Financial Services Compensation Scheme, 10th Floor, Beaufort
House, 15 St Botolph Street, London EC3A 7QU.

32. Amendment.
32.1. We may from time to time change the terms of this Agreement for the following
reasons:
a. to make them more favourable to you or to correct mistakes or oversights; or
b. to cover the improvement of the services, the introduction of a new service or the
replacement of a service with a new one; or
c. to provide for the introduction of new financial systems, change in technology and
products; or
d. to comply with the requirements under the Applicable Law and regulation.

32.2. If we make a change in accordance with the above clause, we shall always give you at
least thirty (30) days’ written notice before we make the change, except as required by
Applicable Law or regulation.

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33. Termination.
33.1. We may terminate this Agreement if you fail to observe or perform any provision of this
Agreement in the event of an Event of Default or as stipulated under Clause 33.8. Where we
serve notice to terminate this Agreement, we will provide you with at least thirty (30) days'
notice. We are not obliged to provide any grounds for such termination.

33.2. Unless otherwise required by Applicable Law, either party may terminate this
Agreement by giving written notice of termination to the other. Termination will be effective
as of the date set out in that notice.

33.3. Upon termination of this Agreement, all amounts payable by you to us will become
immediately due and payable. Termination will not affect any outstanding Transaction or
any legal rights or obligations which may already have arisen.

33.4. Termination will be without prejudice to the completion of transactions already


initiated, which will be settled in the normal way notwithstanding the termination.

33.5. Where you opt to terminate this Agreement, no penalty will be imposed, and no charge
will be made for associated costs.

33.6. We may terminate all or any part of this Agreement immediately on written notice if:
a. you commit a breach of any of your obligations under this Agreement;
b. there are events as described in Clause 30., "Force Majeure";
c. we suspect that you may be engaged in fraud, money laundering, funding terrorism
and/or any relevant criminal conduct;
d. you have failed to complete or adequately satisfy our source of wealth and/or KYC
documentation requirements.

33.7. We reserve the right to unilaterally terminate the Agreement at our sole discretion and
without prior notice in the event that your Account balance is 0 (zero) and that your account
has been inactive (no Transactions were made) for a period of six (6) consecutive months
(180 days).

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33.8. As a client of Trading 212, you agree that you will not behave in an inappropriate
manner towards Trading 212 or any of their employees. Inappropriate behaviour can include
but is not limited to - swearing, abusive language, racism, discrimination, harassment,
defamation, abuse of Trading 212 Chat/email system, misuse of social media channels and
spam. Trading 212 reserves the right to terminate your Agreement in these circumstances.

33.9. Immediately in the event of Us receiving official proof of the death of the Client, we shall
close any open Positions of the Client irrespective of their current result and hold any Client’s
assets in custody until we are presented with official evidence of the legal successors of the
deceased Client and concrete instructions by an authorised person on how to proceed
thereafter.

33.10. You and us may terminate the Agreement with immediate effect by mutual consent.

33.11. In the event that any proceeds of any sorts are booked to the Account after its
termination, we will exercise our best efforts to return those to you via the methods used for
deposits prior to termination. In the event that none of the methods is active, we will exercise
our best efforts to notify you and obtain information on an alternative method to return the
relevant proceeds.

34. General Provisions.


34.1. English shall be the language for communication between you and us for the duration
of this Agreement unless otherwise agreed. This Agreement can be translated into different
languages. If there are any inconsistencies between different language versions, the English
language version shall prevail.

34.2. By signing this Agreement, you shall be obliged to notify us promptly of any changes to
the information you have provided to us.

34.3. This Agreement shall supersede all prior written agreements entered into by you and us
in relation to the provision of the Share Dealing Services. This shall not affect any rights or
obligations that you or we may have under any previous terms relating to these services.

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34.4. If any court or competent authority finds that any provision of this Agreement (or part
of any provision) is invalid, illegal or unenforceable, that provision or part of the provision
shall, to the extent required, be deemed to be deleted, and the validity and enforceability of
the other provisions of this Agreement shall not be affected.

34.5. If any invalid, unenforceable or illegal provision of this Agreement would be valid,
enforceable and legal if some part of it were deleted, the parties shall negotiate in good
faith to amend such provisions so that, as amended, they are legal, valid and enforceable,
and, to the greatest extent possible, meet the parties’ original commercial intention.

34.6. Neither of us shall assign, transfer, charge, mortgage, subcontract or deal in any other
manner with all or any of our rights or obligations under this Agreement. You acknowledge
that we may from time to time outsource and/or partially outsource certain services offered
through this Agreement, to the extent as permissible by law, to any of our Trading 212’s
Group companies. To this end, we shall make sure that those Group companies are
sufficiently equipped and competent in carrying out and assuming responsibility for the
outsourced services.

34.7. In no event shall any delay, failure or omission (in whole or in part) in enforcing,
exercising or pursuing any right, power, privilege, claim or remedy conferred by or arising
under this Agreement or by law be deemed to be or construed as a waiver of that or any
other right, power, privilege, claim or remedy in respect of the circumstances in question, or
operate so as to bar the enforcement of that, or any other right, power, privilege, claim or
remedy, in any other instance at any time or times subsequently.

34.8. Nothing in this Agreement (or any of the arrangements contemplated herein) shall be
deemed to create a partnership between you and us.

34.9. A person who is not a party to this Agreement shall not have any rights under or in
connection with it.

34.10. Trading 212 has elected not to offer accounts to US persons as defined by the Foreign
Account Tax Compliance Act (FATCA). You confirm that by creating this account, you are not
a US Person. In doing so, you agree that if Trading 212 subsequently becomes aware you

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meet the definition of a US person, we may require you to close your account immediately,
and Trading 212 will not be liable for any losses that you may incur as a result.

34.11. Our Website may be accessed worldwide. However, the information on it is not directed
at residents of the United States and Canada and is not intended for distribution to, or use
by, any person in any country or jurisdiction where such distribution or use would be
contrary to local law or regulation. When visiting our Website, it is your responsibility to
ascertain the terms of and comply with any applicable local law or regulation to which you
are subject.

34.12. You agree that your use of data made available to you in relation to your use of the
Share Dealing Services, in real-time or delayed, through the Trading 212 platform, which may
include market prices, volumes and any other data related to Investments and transactions
executed on the Trading 212 platform (collectively “Market Data”), is subject to
confidentiality. You will only use the Market Data for your own personal use and benefit and
not for the management of assets of a third party in any capacity. You will not use the
Market Data for any unauthorised or illegal purpose, or in a professional capacity, meaning
that you shall not use the Market Data in the capacity of a:
a. member of any exchange;
b. registered or qualified professional trader or investment adviser with any stock,
commodities or futures exchange or contract market, or with any financial regulatory
authority;
c. employee of an organisation for the performance of professional investment
activities.

34.13. You receive the Market Data on "as is" and "as available" basis. We do not in any way
guarantee the correctness, accuracy, completeness or timeliness thereof. At all times when
Market Data seems incorrect or implausible, you shall not act upon such information. We do
not assume any liability nor may be held liable to you for any damages arising in connection
with the receipt or use of Market Data that is provided to you.

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35. Governing Law.


The law of England and Wales governs this Agreement, and both you and us hereby submit
to the non-exclusive jurisdiction of the courts of England and Wales in relation to any dispute
under or in respect of this Agreement.

36. Definition and Interpretations.


The following words and phrases shall have the following meanings:

Account means your personal account held within the Share Dealing Services;

After Hours Trading means the trading session after market close on the relevant trading
venue, typically between 16:00 and 20:00 US Eastern Time;

Agreement has the meaning set out in Clause 2.;

Algorithmic Trading means any kind of trading in Instruments where a computer algorithm
automatically determines individual parameters of Orders, such as whether to initiate the
Order, the timing of execution, price or quantity of the Order, or how to manage the Order
after its submission, with limited to no human intervention;

Applicable Law means:


a. the rules and guidance of the FCA or any other rules of a relevant regulatory authority,
b. the rules of a relevant market or clearinghouse, and
c. other applicable laws, rules and regulations as in force from time to time as
applicable to this Agreement;

Appropriateness Test as defined in Clause 3.3. of this Agreement, means our assessment
whether you have the necessary knowledge and experience to understand the risks involved
in relation to certain complex investment products offered via our Share Dealing Services;

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Available Cash means any cash on your Account not invested in Investments or blocked for
Pending Orders and which is not due to Trading 212 UK Ltd. or any third party for fees or
otherwise for the provision of services under this Agreement;

Business Day means any day other than a Saturday, Sunday and a public holiday in the UK;

Cash means any cash on your Account not invested in Investments;

Cash ISA Account means your cash individual savings account with us that allows you to
earn interest on cash in a tax-efficient way, as defined under the Individual Savings Account
Regulations 1998;

Client means any Prospect Client who has been accepted by us after successfully passing
the KYC Process and Appropriateness Test, where required, and we have provided him/her
full access to the Trading Platform and our Share Dealing Services;

Client Asset Rules means the provisions of the FCA Rules that relate to assets received by
MiFID investment firms from clients;

Client Money Rules means the provisions of the FCA Rules that relate to money received by
MiFID investment firms from clients;

Confirmation means a written record, giving the details of a deal, including all charges
applicable to that deal and the total amount payable by or to you in settlement of that deal;

Conflicts of Interest part of the Disclosure Notice outlines potential conflicts of interest with
clients and describes our organisational and administrative controls to manage such
conflicts of interests such that we can be reasonably confident that risks of damage to
clients as a result of any conflict will be prevented;

Corporate Action is a decision or event initiated by a publicly traded company that affects
the securities (such as stocks or bonds) issued by the company. Corporate Actions can
include events such as stock splits, dividends, mergers and acquisitions, and bankruptcies;

Deal means the purchase of, sale of, or subscription for specified investments by you;

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Disclosure Notice means the notice provided by us to you in compliance with FCA Rules
regarding the risks associated with Buying and Selling investments under this Agreement;

E-Money Account means your account opened by Paynetics UK in which e-money are
stored and to which your Trading 212 Card is linked to E-Money Account will be denominated
in GBP and (if available) in other currencies such as EUR and USD, as visible on our Website;

Eligible Counterparty shall mean eligible counterparty as defined in the FCA Rules;

Extended Hours Trading means the servic provided by Trading 212, which enables Clients to
buy and sell Investments on a compatible trading venue in a Pre-Market Trading and/or
After Hours Trading session;

FCA Rules means the rules and guidance issued by the FCA from time to time;

Financial Instrument means any contract that gives rise to a financial asset of one entity
and a financial liability or equity instrument of another entity. This includes a wide range of
financial products, such as stocks, bonds, derivatives, and structured products;

Fractional Shares Programme means the service provided by Trading 212 UK Limited as
described in Clause 13., which allows clients to hold fractional units in shares;

Group companies mean any company under common control as Trading 212 UK Ltd.;

Instruction to Deal means an instruction by you for us to Buy or Sell any investment on your
behalf including, for the avoidance of doubt, an Order;

Instrument Currency means the currency in which an Instrument is being traded in;

Investment means any Share, bond, Fraction of share or other debt instrument, gilt,
investment trust, unit trust or other security or investment in respect of which we offer to deal
in Transactions;

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Investment Transfers means transfers in or out of your Account or Stocks ISA Account, as
described in Clause 17

ISA Services means any services we provide to your Stocks ISA and Cash ISA account(s);

KYC Process means know your customer due diligence process as defined under Clause 3.3.
of this Agreement;

Manifest Error means an obvious error in the quotes of the Financial Instruments which
substantially deviates from the prevailing market price and which has occurred as a result
of a system or technical error;

Market Hours means the time span of trading on the financial markets as indicated on our
Website. During those market hours, the Client shall have the right to place orders for
execution for those Financial Instruments whose exchanges are open for trading;

MiFID means the Markets in Financial Instruments (MiFID II) Directive 2014/65/EU, as
implemented and retained in the national laws of the UK and amended from time to time;

Multi-Currency Account means the Trading 212 functionality allowing you to hold cash
balances in multiple currencies, as described in Clause 4.10;

Nominee company means a non-trading nominee company controlled by us or any other


nominee (including third parties appointed by us) from time to time;

Non-Primary Currency means any currency other than the Primary Currency;

Order Execution Policy means Trading 212’s Order Execution Policy, available on our Website
and stipulating the means by which we will meet our best execution obligations when
executing Orders for our clients;

Order means any order supported by us or the relevant stock exchange that we make
available to you;

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Overnight Trading means the trading session outside of Regular Trading Hours and
Extended Hours Trading, typically starting from 20:00 US Eastern Time and ending at 04:00 US
Eastern Time;

Payment Instruction means any instruction on Your Account for a deposit and/or
withdrawal (including a Trading 212 Card Withdrawal);

Pending Order as defined in our Order Execution Policy, is an Order to be executed at a later
time and at the price that the Client specifies;

Position means the number of shares of an Investment that a Client holds;

Pre-Market Trading means the trading session before market open on the relevant trading
venue, typically between 04:00 and 09:30 US Eastern Time;

Primary Currency means the default currency that you have selected during the account
opening process or at a later stage. It is used as the currency for calculating and displaying
your Account’s balance, positions, periodic reports and Statements;

Professional Client shall mean professional client as defined in the FCA Rules;

Prospect Client means anyone who has agreed to the terms and conditions of this
Agreement and for evaluation purposes has been granted access to certain parts of the
Trading Platform. A Prospect Client is not yet accepted by us and he/she does not have
access to our Share Dealing Services;

Qualifying Money Market Fund (QMMF) means a money market fund that aims to achieve
a return on investments and have a low-risk profile by investing in mostly low-risk financial
instruments such as government bonds. A QMMF is subject to higher regulatory scrutiny and
must meet higher quality standards than other money market funds;

Regular Bank Deposit means any interest-bearing deposit with a regulated financial
institution, other than Term Deposits;

Regular Trading Hours means the trading session on the relevant trading venue;

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Retail Client shall mean retail client as defined in the FCA Rules;

Scalping means a speculative type of trading where the opening and closing of a position is
executed within a very short timeframe (e.g. five minutes or less);

Sell-only Limitation (close-only limitation) is a limitation, where Your ability to open new
positions or place new buy Orders is restricted or disabled;

Share Lending means the process whereby those holding shares lend them to other parties
and maintain a right to reacquire the shares, as described in Clause 26.;

Share Dealing Services means execution-only share and fractional share dealing services,
as outlined in Clause 4. of this Agreement;

Statement means a written confirmation of any Transaction, any Orders that you set and/or
edit, and any Commission and other applicable Charges and Taxes that we apply;

Stocks ISA Account means your stocks and shares individual savings account with us that
allows you to make Investments in a tax-efficient way, as defined under the Individual
Savings Account Regulations 1998;

Sub-custodian means a bank or financial institution providing custody services in respect


of a particular market or jurisdiction, on behalf of Trading 212 UK Limited;

Term Deposit is a type of deposit for savings or investment purposes. Term deposits have a
fixed interest rate and a predetermined term, which is usually up to 95 days;

Terms & Fees means the table entitled “Terms & Fees” available at our Website;

Trading Platform means the electronic trading platform on our Website;

Trading 212 Card means the co-branded debit card linked to your E-Money Account, which
is issued by Paynetics UK Ltd. and distributed by Trading 212;

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Invest Terms

Trading 212 Card Withdrawal means a withdrawal from your Available Cash, initiated via
the Trading 212 Card and processed by Paynetics, as specified in Clause 10.3. above;

Transaction means the partial or full fill of your Instruction to Deal;

Website means our website at www.trading212.com and/or any mobile applications


provided by Trading 212;

24/5 Trading is a feature that allows Clients to trade outside Regular Trading Hours,
combining the Extended Hours Trading and Overnight Trading sessions.

These Invest Terms were last updated and published on 04.09.2024. A copy of the most
up-to-date version of these Terms is available on our Website.

The Invest Terms relevant before 04.09.2024 can be found here.

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