This Withdrawal Policy constitutes a legal requirement as detailed below:

DEPOSITS OF FUNDS POLICY

The client may deposit funds into the client account at any time during the course of this agreement. Deposits will be accepted by bank transfer, Swift, E-wallet, debit / credit card or any other method of electronic money transfer (where the originator is the client) acceptable by the Company from time to time. The Company shall credit the client account within two business day after the amount is cleared in the bank account of the Company with the relevant amount. The relevant amount will be net of any transfer fees or other charges incurred by the Company that are imposed by the institution (or intermediary involved in the process) that holds the funds.

The Company will not accept third party or anonymous payments of funds in the client account (without derogating from the paragraph below).

The client accepts that the funds shall be deposited in his/her trading account only if the Company is satisfied that the sender of the funds is the client or his/her authorized representative (unless legally consented inter alia, Trustee, POA or guardian). If the Company is not satisfied as to the above then the Company has the right to reject the Funds and return them to the remitter net of any transfer fees or other charges incurred by the Company, using the same transfer method as the one through which it originally received the funds.

Unless said otherwise, the interest derived from the bank account of clients’ funds shall not be paid to the clients and it can be used by the Company for its own account. The clients are informed accordingly as evidenced by their signature or other equivalent alternative mechanism.

WITHDRAWALS OF FUNDS POLICY

As soon as withdrawal instruction / Payment Order Instruction is received from the client through his/her trading account (for security purposes) nevertheless, clients can contact the company either by phone, fax, e-mail and/or in person to request a withdrawal.
The Company will ensure that the withdrawal request by the client includes all necessary information and the following checks must be performed:

  1. a) Confirm that the account number, name and banking details of the client agree with the details provided in the account opening application process.
    b) The clients is eligible to withdrawal according to company policy
    c) Withdraw the funds from the client’s account.
    d) Prepare the transfer request for the bank and forward to the Account’s departments.
    e) Send the payment instruction to the relevant Bank for payment.

Upon the company receiving an instruction from the Client to withdraw funds from the Client Account, the Client’s funds will be processed within 5-7 business days, if the following requirements are met (notwithstanding the provisions of this article the actual receipt of funds depends on the Client’s payment method):
a) the instruction is to make a bank transfer of funds to the account of the Client;
b) at the moment of payment, the Client’s Free Margin exceeds the amount specified in the withdrawal instruction including all payment charges;

In case the client requests his fund to be withdrawn from his account and to be transferred to a bank account that has not been notified to the Company in the past, then the Company will perform Know Your Customer procedures on the same client in order to ensure that the beneficiary of both bank accounts is the same person and then the Company can proceed with the transfer of funds.

The Company will effect withdrawals of client funds, upon an application for withdrawal made via the Company Online Trading System (if available at the time).

The client accepts that withdrawal of any part of the funds shall be concluded using the same transfer method and the same remitter as the one which the Company originally received the Funds from. Under such circumstances, the Company shall return the part of the funds requested less any transfer fees or other charges incurred by the Company.

The Company reserves the right to decline a withdrawal request of the client asking for a specific transfer method and the Company has the right to suggest an alternative.

Withdrawals will only be effected towards the client. The Company will not to effect withdrawals to any other third party or anonymous account.

The Company reserves the right to request additional information and/ or documentation to satisfy itself that the request is legitimate. In addition, the Company reserves the right to reject such a request if it deems that this may not be legitimate. The client accepts that under such circumstances there may be a delay in processing the request.

All payment and transfer charges will be borne by the client and the Company shall debit the client account for these charges.
The Company shall be responsible for responding to any client requests, regarding information on the status of their order, received by telephone at any time, within a reasonable period of time. The client using the Internet shall be able to get information on the status of their order within a reasonable period of time through specialized software. Information to clients regarding the status of their order must be provided to the client in no longer than one business day. When such telephone calls are received they must be recorded on the software of the Company including date and time the call by the customer was made.

Clients’ requests will be received electronically. In cases that the client has not access in the electronic means clients’ requests will be accepted by E-mail, provided that the signature of the client is verified and the transfer/withdrawal form is properly completed (with respect to check list aforementioned) .

Clients’ requests will be forwarded immediately to the Back Office Department for approval in terms of funds availability after they have discussed the request with the client and have confirmed it. Once the Costumer Support Department approves the request, they shall then forward it to the Finance and Accounting Department for processing.

For all transactions described above the employee shall record the transactions in the Company’s cash account ledger and shall file the documentation for each transaction recorded after a reference is made into the ledger.

  1. COMPLAINTS OR GRIEVANCES POLICY

1.1 Complaint or grievance handling
The Company shall establish, implement and maintain effective and transparent procedures for the reasonable and prompt handling of complaints or grievances received from retail or potential retail clients, and to keep a record of each complaint or grievance and the measures taken for the complaint’s resolution.

Clients’ complaints or grievances are initially handled by the Costumer SupportDepartment. However, the final settlement of non-trivial complaints or grievances needs to be approved by Compliance Officer and if necessary by Senior Management.

The procedure which shall be followed by the Company, when handling with clients’ complaints or grievances, is the following:
• A complaint or grievance is initially handled by a member of the Costumer Support Department. The employee receiving the complaint or grievance shall take the necessary actions so that the complaint or grievance is properly addressed.
• The complaint or grievance in the form that has been received immediately (within three working days), should be forwarded to the head of the department where the complaint is addressed.
• The member of the Costumer SupportDepartment shall inform the client that the complaint or grievance has been forwarded to the relevant department/personnel, providing all details so that the client is aware who is dealing with his/her complaint or grievance.
• The member of staff, in addition to the above, should make all best efforts to ensure that in the case of the complaint or grievance being of such nature that can be resolved immediately, to do so that the client will not have to pursue the filling of a formal complaint. The member of staff in such a case shall not:
i Commit him/herself in any way to the client
ii Address any issues in relation to best execution
iii Address any issues relating to legal issues
iv Commit the Company in taking any action prior to examining the issues in a formal manner

1.2 Procedure to be followed when a formal complaint or grievance is received:
a. When a written complaint or grievance is received, this shall be forwarded to the relevant department which is the most appropriate for dealing with the complaint.
b. The member of the Costumer SupportDepartment shall contact the client to inform him/her that the complaint or grievance has been received and it is under investigation.
c. Upon receiving a written complaint or grievance, the following details should be obtained and recorded:
• The identification particulars of any client having made a complaint or grievance.
• The service provided by the Company and related to the complaint or grievance.
• The employee responsible for the provision of those services.
• The department where the employee belongs.
• Date of receipt and registration of complaint or grievance.
• Content of the complaint or grievance.
• The capital and the value of the financial instruments which belong to the client.
• The magnitude of the damage claimed by the client.
• Reference of any correspondent exchanged between the Company and the client.

  1. The events leading to the complaint or grievance should be examined and assessed based on the information provided by the client.
    e. The facts as stated by the client have been examined and verified whether any additional information, need to be retrieved from the Company’s archive (electronic mail, recorded telephone calls, IT data, etc).
    f. All non-trivial complaints or grievances shall be brought to the attention of and their resolution should be approved by the Senior Management.
    g. Upon completion, of the investigation a report shall be prepared stating the facts and brought to management’s attention, which will decide on the formal response to the client and the action to be taken.
    In the case where a client complaint or grievance is valid, the management shall take such necessary action together with the Head of Department(s) to which the complaint or grievance is related in order to identify and verify:
    a. Reasons for failure of procedure followed.
    b. Weaknesses of the internal controls.
    c. Implementation of internal controls that would prevent any complaint or grievance in the future.

All suggested procedures shall be approved by Senior Management at the meeting following the completion of the investigation.

The above mentioned procedure shall be disclosed in summarised form to the complainant through the agreement which is signed for the provision of investment services.

1.3 Procedure to be followed when a formal complaint or grievance is received concerning client withdrawal of funds
The procedure prescribed in section 1.2 above is the client complaint procedure that will be performed as soon as a client requests withdrawal of his funds.
In relation to the procedure to be performed by the Company as soon as a withdrawal request is received from clients, please refer in the relevant section of the Company’s terms and conditions
1.4 Record-keeping of complaints or grievances received
The Company shall maintain all complaints or grievances for a minimum period of five years. The responsible department shall be the Back Office / Account Opening Department and the Compliance Officer has to ensure that the procedure is properly followed.