OPEN TRADE HOLDING FEES POLICY

1. Purpose

This policy establishes a transparent framework for the assessment and administration of an Administrative & Commission Fee on trading positions held continuously beyond the prescribed fee-free period. It is intended to support liquidity provisioning, capital allocation, risk management and platform operations.

2. Scope

This policy applies to open trading positions on GFX Securities trading accounts to which the published MT5 extended-holding fee schedule applies. The relevant instruments, account types, exemptions (if any), and exact fee tiers must be verified against the approved MT5 schedule and applicable client agreements before implementation.

3. Effective Date and Transitional Application

The policy takes effect on 1 November 2026. The notice states that positions already open and positions opened on or after this date receive a 30-calendar-day fee-free holding period. For existing positions, the precise treatment of days accrued before 1 November 2026 must be documented and communicated before charging; the notice does not expressly settle whether their holding-day count restarts on the effective date.

4. Fee-Free Holding Period

No Administrative & Commission Fee under this policy is assessed for the first 30 calendar days of a position’s continuous holding period. Fees apply only when the position remains continuously open beyond 30 calendar days. This does not waive any other spreads, swaps, commissions or charges otherwise agreed with the client.

5. Fee Assessment and Calculation

For each eligible open position, the extended-holding fee is assessed daily for each chargeable day after the 30-day grace period, on a per-lot basis. Illustrative formula: daily fee = chargeable open lots × applicable daily per-lot rate. The actual rate, currency, tier, rounding method, calculation cut-off and treatment of fractional lots must follow the approved schedule disclosed in MT5. No numeric rate is established by this policy.

6. Operational Treatment

Operations and Finance shall establish a controlled process to identify qualifying positions, calculate charges from reliable trade and position records, reconcile postings and investigate exceptions. The treatment of partial closures, position increases, netting/hedging, non-trading days, and closure/reopening must be defined in a documented implementation specification before go-live. Charges should be traceable to the position, holding period, rate version and posting date.

7. Rate Schedule and Client Disclosure

The detailed fee tiers and per-lot rates shall be made accessible to clients through MT5, as stated in the client notice. The applicable schedule should be version-controlled, dated, and consistent with contractual disclosures. Client support shall explain how clients can view applicable rates and raise queries, without providing personalized trading recommendations.

8. Changes to Fees or Holding Terms

Rates and holding terms may be reviewed periodically in response to market conditions, liquidity-provider requirements and risk assessments. Any proposed change must be assessed for contractual, regulatory and fair-client-treatment requirements, approved through the applicable governance process, and communicated with any notice period required by governing terms or law. Changes must not be applied retrospectively without an appropriate legal and contractual basis.

9. Roles and Responsibilities

Management: oversee implementation and approve operational procedures within delegated authority. Operations: monitor-holding periods, position eligibility and fee exceptions. Finance: validate fee calculations, postings and reconciliations. Compliance/Legal: review disclosures, contractual basis, complaints and applicable regulatory requirements. Technology/MT5 administrator: maintain accurate configuration, access controls and audit logs. Client Support: communicate policy information and handle queries.

10. Client Communications and Complaints

Clients shall receive clear information on the effective date, 30-day fee-free period, applicable fee methodology, where to view rates, and support channels. The client notice dated 20 October 2026 identifies support@gfxsecurities.com as the contact. Disputes over calculations or eligibility shall be recorded, investigated, resolved and escalated under the company’s complaint-handling procedures.

11. Monitoring, Records and Controls

Maintain records of the approved policy and rate schedules, client notices, configuration changes, fee calculations, adjustments, reconciliations, approvals and complaints. Conduct periodic exception reviews and control testing. Retention periods shall follow applicable law, regulation and the company’s approved record-retention policy.

12. Regulatory and Contractual Compliance

This policy must be implemented only for products and activities that GFX Securities is authorized to offer, and subject to applicable regulatory rules and client contracts. It does not itself establish regulatory approval, authorize a new fee, or override productspecific disclosures. Compliance/Legal shall confirm the appropriate framework before deployment.

13. Review and Approval

This policy shall be reviewed at least annually and sooner if market, liquidity-provider, contractual, regulatory or operational changes warrant. Material amendments shall be submitted to the appropriate approving authority and reflected in client disclosures.