CHECKLIST FOR RESTRICTED TRADING STRATEGY

SCOPE AND APPLICABILITY

This Checklist applies universally to all accounts maintained with Capital Street, without exception. Specifically, the restrictions and prohibited strategies set out herein apply in full to each of the following account types, setups, and conditions (collectively referred to as “Special Condition Accounts”), whether applied individually or in any combination:

(a) All Promotional Accounts — accounts to which any bonus, deposit match, leverage promotion, cashback, rebate, funded trading program, or any other publicly or privately offered promotion or incentive has been applied, whether in full or in part, including but not limited to the 150% Bonus, 200% Bonus, 650% Bonus, 900% Bonus, 1:10000 Leverage Promotion, Live Funded Trading programs, and any other promotion offered by the Company from time to time;

(b) Combined Promotion Accounts — accounts on which two or more promotions, offers, or incentive structures are active simultaneously or sequentially, regardless of whether such combination was formally offered or applied through exception;

(c) Swap-Free / Islamic Accounts — accounts granted a swap-free or Islamic account status, or any other arrangement that removes, waives, or modifies the overnight financing charges otherwise applicable to standard accounts;

(d) Bridge / Copy Trading Accounts — accounts operating as part of a copy trading arrangement, signal provider/receiver setup, bridge connection, or any other structure in which trades are mirrored, replicated, or automatically copied from one account to another, whether using the Company’s own copy trading infrastructure or any third-party tool, software, or platform;

(e) Managed Accounts — accounts operating under a management arrangement, including but not limited to MAMM (Multi-Account Money Manager), PAMM (Percentage Allocation Money Manager), LAMM (Lot Allocation Money Manager), MAM (Multi-Account Manager), and any other managed account structure or power of attorney arrangement under which trading decisions are made by a third party on behalf of the account holder;

(f) API Trading Accounts — accounts on which automated or semi-automated order placement is facilitated through an API (Application Programming Interface) connection, direct market access tool, or any third-party software or system that interfaces with the Company’s trading infrastructure to place, modify, or close orders;

(g) Custom / Specially Configured Accounts — accounts that have been granted any individually negotiated or customised trading condition, including but not limited to modified leverage tiers, reduced spreads, commission adjustments, extended trading hours, customised margin requirements, or any other condition that differs from the Company’s standard publicly available account parameters;

(h) Any Other Special Condition Account — any account type, setup, or configuration not listed above that has been granted, applied, or approved by the Company with conditions that differ in any material way from a standard, unmodified retail trading account.

For the avoidance of doubt, the fact that a Special Condition Account is managed by a third party (including an IB, money manager, or copy trading provider) does not transfer or dilute the account holder’s personal responsibility for compliance with this Checklist. The account holder remains solely and fully liable for all trading activity conducted in their account.

GENERAL PROHIBITION

If the Company suspects or has reason to believe that a Client has abused the Terms and Conditions of this Checklist, any Bonus Program, any promotional offer, or any Special Condition Account, or has used any of the prohibited trading strategies listed herein — whether within their own account(s), using other trading accounts held with the Company, externally through accounts held with other brokers, or through any combination of the foregoing — the Company reserves the right, at its absolute discretion and without obtaining the Client’s consent, to take immediate remedial action. The specific consequences that apply depend on the nature of the account and the conditions in place at the time of the violation, as set out below:

(i) Where a Bonus is in use on the account: The Bonus shall be removed from the account with immediate effect; all profits generated while the Bonus was active shall be debited from the account; and any losses incurred shall be deducted from the client’s own deposited funds.

(ii) Where any other promotion, incentive, or special trading condition is in use (including but not limited to swap-free status, custom leverage, reduced spreads, copy trading or bridge arrangements, managed account structures, API access, or any other specially granted condition) but no Bonus is involved: The relevant special trading condition(s) shall be revoked with immediate effect; the account shall be suspended pending review; and all profits earned in connection with, or during the period of, the prohibited trading activity shall be debited from the account. Any losses shall be recovered from the client’s deposited funds.

(iii) Where no promotion or special condition is in place (standard account): All profits generated from the prohibited trading activity shall be debited from the account; any losses shall be recovered from the client’s deposited funds; and the account may be suspended or permanently terminated at the Company’s discretion.

Under the terms of any promotion, Special Condition Account, or custom account setup, trading strategies including, but not limited to, the following are strictly prohibited:

PROHIBITED TRADING STRATEGIES

1. Scalping (Short Duration) — Trades closed under 320 seconds (this is an average indicative time; trades above this threshold may still be classified as scalp trades based on other factors such as spikes in trading volume, low trading profit/loss, trading concentrated around news releases, or any pattern of opening and closing positions within a short period). There exists no justifiable rationale for opening and closing trades with a price movement smaller than the average 5 or 15 minute market move if trading within that time frame. Anything closed below the average market move (adjusted for the applicable spread) qualifies as a scalp trade. Any collection and succession of trades being opened and closed in rapid succession — especially in blocks of multiple lots — are indicative of rebate churning behaviour. Reference: https://www.investopedia.com/terms/forex/f/forex-scalping-and-scalper-system-strategy.asp

2. CFD/Future/Derivatives/Forex Scalping (Small Price Movement) — A trading style in which a trader buys or sells an instrument and holds it for a very short period in an attempt to profit from small price movements. Scalping typically involves a large number of trades exploiting minor intraday price moves, often amplified by high leverage and large position sizes. Scalpers typically seek to use promotional or special-condition accounts to gain trading advantages. The associated risks — including leverage, spreads, fees, and slippage — are wholly the client’s responsibility.

3. Hedging (All Forms) — Hedging of any kind is strictly prohibited across all accounts, including all Special Condition Accounts, without exception. Prohibited hedging includes:

    (a) Direct Hedging: Placing opposing buy and sell positions on the same instrument within the same account simultaneously or at any overlapping point in time;

    (b) Cross-Pair / Correlated Hedging: Taking positions in two or more instruments that are correlated — positively or negatively — with the purpose or practical effect of neutralising or offsetting exposure (including but not limited to pairs such as EUR/USD & USD/CHF, EUR/USD & GBP/USD, or any other instruments whose price movements are substantially linked);

    (c) Inter-Account Hedging: Placing opposing or offsetting positions across two or more accounts held under the same name, household, IP address, device, payment method, location, or accounts controlled by related or associated individuals or entities;

    (d) Group / Coordinated Hedging: Any formal or informal arrangement between two or more clients to place offsetting trades across their respective accounts;

    (e)Any other strategy or pattern of trading that Capital Street, in its sole and absolute discretion, determines to constitute hedging behaviour or to have the intent or effect of hedging (by eliminating all forms of risk, including but not limited to economic or market risk, in the trades or combination of trades initiated), regardless of the instruments or methods used.

Reference: https://www.investopedia.com/trading/hedging-beginners-guide/

4. High Frequency Trading — Any automated or semi-automated trading strategy that relies on extremely high speed order execution, very short holding periods, or a very large number of trades placed within short time windows to generate profit. Reference: https://www.investopedia.com/terms/h/high-frequency-trading.asp

5. Expert Advisors (EAs) — The use of automated trading bots, robots, scripts, or Expert Advisors on any promotional, swap-free, managed, copy trading, API, or otherwise specially configured account is strictly prohibited unless expressly approved in writing by the Company. Reference: https://finance-pedia.com/glossary/expert-advisor/

6. Algorithmic Trading — Any rule-based, programmatic, or automated trading system that generates and executes orders without direct human input on a trade-by-trade basis, unless explicitly authorised by the Company in writing for the specific account and account type in question. Reference: https://www.investopedia.com/terms/a/algorithmictrading.asp

7. All Forms of Trading Arbitrage — Any strategy that seeks to exploit price discrepancies between markets, instruments, platforms, or time periods, including but not limited to the forms listed in items 8, 9, and 10 below. Reference: https://www.investopedia.com/terms/a/arbitrage.asp

8. Latency Arbitrage — Exploiting delays between the Company’s price feed and external market prices, or between the Company’s platform and other platforms, to place trades that are effectively risk-free at the moment of execution. Reference: https://www.investopedia.com/articles/trading/04/111004.asp

9. News/Event Arbitrage — Placing trades immediately before, during, or after scheduled or unscheduled market-moving events (including but not limited to economic data releases, central bank announcements, geopolitical events, election results) with the intent of exploiting price dislocations or feed delays at the time of the event. Reference: https://www.investopedia.com/terms/n/news-trader.asp

10. Swap/Rollover Arbitrage — Exploiting the swap-free or Islamic account status, or any other modification to overnight financing charges, in combination with positions in markets where rollover or carry differentials exist, to generate risk-free or near-risk-free returns from financing differences rather than legitimate market exposure. Reference: https://www.investopedia.com/articles/investing/050515/arbitrage-strategies-changing-interest-rates.asp

11. Trading Volume Spikes in Thin/Volatile Markets — A sudden and significant increase in trading volume during or around volatile, illiquid, or thin market conditions (including partial market holidays, low-liquidity periods, or major news events) that is inconsistent with the client’s prior trading pattern and appears designed to satisfy volume requirements of a promotion, generate rebates, or exploit temporary market conditions.

12. Any Systematic Strategy Deriving Sole Advantage from Special Account Conditions — Any trading strategy that derives its primary or sole commercial advantage from the special terms of a bonus, promotion, swap-free setup, managed account structure, copy trading arrangement, API connection, custom leverage, or any other specially granted condition, including but not limited to: trading with intent to scalp during thin or illiquid markets; high-leverage trading during news releases or political events; wash sales; misuse of swap-free or Islamic account conditions; and any strategy specifically structured to magnify profits by exploiting the promotional or special parameters of the account rather than genuine market movements.

13. All Corporate Actions — Including but not limited to stock splits, reverse splits, dividends, index rebalances or adjustments, and any other structural event that causes a mathematical or technical adjustment to the price of the traded instrument, where a position has been opened specifically to exploit the predictable price effect of that corporate action.

14. Deep Drawdown Accumulation / Martingale-Style Position Stacking — Accounts exhibiting deep drawdowns with a continued accumulation of losing positions being added in a martingale-style pattern, with no attempt to close loss-making positions regardless of the size of losses, particularly where balances continue to rise (through rebates or bonus credits) while the account’s realizable equity value falls.

15. Late-Stage Unlimited Position Opening Near Bonus Expiry — Accounts approaching the expiry of a promotion or near threshold levels opening unlimited positions at multiple price levels, selectively closing positions that increase the account balance while allowing losing positions to remain open, resulting in a rising nominal balance but declining or stagnant realizable account value.

16. Simultaneous Opposing Positions Across Managed / Coordinated Accounts — The simultaneous opening of buy and sell positions in the same or correlated instruments across two or more accounts that are being managed by the same individual, entity, or related party, including accounts operating under MAMM, PAMM, LAMM, copy trading, or any other managed or coordinated account structure.

CONSEQUENCES OF VIOLATION

If the Company has reason to believe that a user is in violation of the terms of any promotion, Special Condition Account, or the restrictions set out in this Checklist, the Company shall inform the user in writing of the said violation. The remedies available to the Company, and which it may exercise at its sole and absolute discretion, are differentiated based on the account type and conditions in place at the time of the violation, as follows:

WHERE A BONUS IS IN USE ON THE ACCOUNT:

a) Cancellation of the Bonus and removal of all profits generated in the account while the Bonus was active, with immediate effect.

b) Removal of the Bonus funds and all profits generated using the Bonus; deduction of any losses from the client’s own deposited funds; closure of the account; and return of the user’s remaining net funds (after settlement of all losses and liabilities) via the original method of deposit.

c) Where the account balance at the time of determination is below the original starting balance, losses shall be deducted from the user’s deposited funds and any remaining balance remitted to the client via the same method as the original deposit.

WHERE A PROMOTION OR SPECIAL TRADING CONDITION OTHER THAN A BONUS IS IN USE (including but not limited to swap-free accounts, custom leverage, reduced spreads, copy trading or bridge arrangements, managed account structures such as MAMM/PAMM/LAMM, API access, or any other specially granted condition):

d) Immediate revocation of the relevant special trading condition(s) — including withdrawal of any custom leverage, swap-free status, reduced spreads, managed account access, copy trading connectivity, API access, or any other specially granted parameter — with no obligation on the Company to reinstate such conditions at any time.

e) Immediate suspension of the account pending full investigation and final determination by the Company’s Compliance Department.

f) This should be debiting of all profits earned since custom configuration or set up was applied/used. In some cases all profits in the account may be debited if the scale of violation is significant and deemed to be a systemic risk to the stability of the platform, liquidity provider arrangements and/or the general stability of the overall platform and its associated ecosystem.

g) Recovery of any losses arising from the prohibited trading activity from the client’s own deposited funds, by way of deduction or set-off against any balance standing to the client’s credit in any account held with the Company.

IN ALL CASES (applicable regardless of account type or conditions in place):

h) Permanent termination of any or all accounts held by the client with the Company.

i) Withholding, freezing, or offsetting of any funds in any account associated with the client against losses, costs, or other liabilities identified in connection with the prohibited activity.

j) Any other corrective, remedial, or punitive action deemed appropriate by the Company in its sole and absolute discretion.

PLEASE NOTE

The Company’s decision in all matters related to misuse or violation of the terms of any promotion, bonus, Special Condition Account, or custom account setup is final and binding. All promotions and special account configurations offered by the Company are at the sole discretion of the Company, and no binding obligation is placed upon the Company to negotiate any aspect, benefit, or condition of any promotion or special account setup with users, including but not limited to its start/end dates, amounts, terms and conditions, availability to individual users or accounts, or any other component or sub-condition.

The restrictions set out in this Checklist apply equally and in full to all Special Condition Accounts as defined in the Scope section above. The classification of an account as a managed account, copy trading account, API account, or any other special type does not exempt it from any restriction contained herein. The account holder is at all times personally and fully responsible for ensuring that all trading activity conducted in their account — whether by themselves, by a money manager, by a copy trading signal, or by any automated system — complies with this Checklist and all applicable terms and conditions of the Company.

APPLICATION UNDER GENERAL TERMS AND CONDITIONS

The restrictions, prohibitions, and consequences set out in this Checklist are not limited in their application to promotional accounts or accounts operating under special conditions. They form part of, and are incorporated into, the Company’s General Terms and Conditions of business and apply in full to all accounts maintained with Capital Street, without exception.

Where the Company has reason to believe — in its sole and absolute discretion — that any client is misusing any trading conditions granted to them, or is employing any abusive, restricted, or prohibited trading style or strategy as described in this Checklist, whether or not such conditions are linked to a promotion, bonus, or special account setup, the Company shall be entitled to apply all remedies set out herein under the general terms of the client agreement. This includes accounts operating under standard trading conditions where no promotion or special setup is in place.

Consequences Under General Terms — Trade Cancellation, Profit Removal and Loss Recovery

Where the Company determines that a client has engaged in any abusive, prohibited, or restricted trading strategy — whether detected at the time trades are placed or identified retrospectively — the following consequences apply automatically and unconditionally under the general terms and conditions of the client agreement, without the client’s consent and without prior notice:

(a) Cancellation of Trades in Violation: Any trade — whether currently open or already closed — determined to have been placed in contravention of the restrictions in this Checklist or the Company’s Terms and Conditions shall be cancelled, voided, and reversed with immediate effect and treated as if never opened or executed. This remedy may be applied retrospectively across the full period of identified prohibited activity, regardless of whether the trades were profitable or loss-making at the time of cancellation.

(b) Removal of All Profits: All profits — whether realised or unrealised — generated directly or indirectly from prohibited, abusive, or restricted trading activity shall be debited from the client’s account with immediate effect. This includes profits on individual trades, profits accumulated across any account where the prohibited strategy was used, and any ancillary gains that would not have arisen but for the prohibited activity. Where such profits have already been withdrawn, the Company reserves the right to recover them by any lawful means, including by deduction from any other account held by the client with the Company.

(c) Recovery of Losses from Client’s Deposited Funds: Any losses arising from prohibited or abusive trading activity shall be recovered directly from the client’s own deposited funds by deduction, offset, or set-off against any positive balance in any account held by the client with the Company. All such losses are solely and entirely the client’s financial liability. The Company’s right to recover such losses is unconditional and not subject to dispute. Where the net effect of the prohibited activity results in a balance below the client’s net deposit, the resulting deficit remains the client’s sole obligation, recoverable by any lawful means available to the Company.

The above consequences apply in addition to, and not in substitution of, any other remedy available to the Company under the general Terms and Conditions, including account suspension, permanent termination, and withdrawal of any special trading conditions, bonuses, or promotional benefits.

The Company’s determination as to whether a trading strategy constitutes a prohibited, abusive, or restricted practice — and its determination of the appropriate remedial action — is made in its sole and absolute discretion and is final, conclusive, and binding on the client. The client expressly waives any right to contest, appeal, or seek reversal of any determination or action taken under this section. No liability shall attach to the Company for any financial loss sustained by the client as a result of any action taken in good faith under these provisions.

By maintaining an account with Capital Street and/or executing the Client Agreement, the client unconditionally acknowledges and agrees that: (i) all prohibited profits are not rightfully the client’s property and the client has no entitlement to retain them; (ii) all losses from prohibited trading are solely the client’s financial liability, recoverable from their deposited funds; (iii) these consequences apply regardless of whether trading was conducted personally by the client or by any third party on their behalf, including any money manager, copy trading signal, Expert Advisor, API system, or any other automated or semi-automated tool; and (iv) the application of these consequences under the general terms is independent of and in addition to any promotional or special-condition-specific remedies that may also apply.