AAA Risk Disclosure Statement

This TRIPLE A EXPERTS INVESTMENT SERVICES S.A. (‘AAA’) Risk Disclosure Statement is an integral term of the Customer Agreement.

THE MAJORITY OF GLOBAL FOREIGN EXCHANGE CURRENCY DEALERS AND BANKS INCLUDING AAA, ARE COMPENSATED ON THE DIFFERENCE BETWEEN THE BID/ASK SPREAD IN THE CURRENCY PRICE OFFERED TO PARTICIPATING TRADERS AND/OR HAVE THE ABILITY TO ACCUMULATE POSITIONS ON A PROPIETARY BASIS AND ASSUME THE RISK OF THE NET OPEN POSITIONS THEY CARRY.

Each capitalized term not defined in this Risk Disclosure Statement shall have the meaning given to it in the AAA Glossary of Terms obtained from the AAA website: www.aaafx.com Trading in margined Foreign Exchange and/or Precious Metals involves a high degree of risk including the risk of loss of the Customer’s entire Risk Capital deposited with AAA. Losses, in some cases, have the potential to extend beyond the Customer’s Account Value.

This brief statement does not disclose all of the risks and other significant aspects of spot Foreign Currency, Precious Metals Commodities and options trading. In the light of the risks, you should undertake such transactions only if you (“Customer” or “you”) understand the nature of the trading in which you are about to engage and the extent of your exposure to risk. Trading in spot OTC Foreign Exchange is not suitable for many members of the public. You should carefully consider whether such trading is appropriate for you in the light of your experience, objectives, financial resources and other relevant circumstances. In consideration of AAA agreeing to enter into Foreign Exchange Contracts with its Customer(s) for this Account, AAA requires all the undersigned Customer(s) to analyze their financial objectives, financial status, investment constraints and tax situation to determine whether spot OTC Foreign Exchange trading is suitable for them. In addition, we require our Customers to read and acknowledge the AAA Risk Disclosure Statement that outlines without limitation some of the risks associated with trading margined spot OTC Foreign Exchange through AAA. By signing this document, the Customer acknowledges, understands and agrees to the following: There is no guarantee of profit from trading with AAA. By signing the AAA Risk Disclosure Statement, the Customer acknowledges tthat neither AAA nor any of its representativesguarantees to the Customer that they will profit from trading or investing in OTC margined spot Foreign Exchange. Customer further confirms that the Customer could sustain the total loss of their entire Risk Capital deposited in their Account and are financially able to withstand any losses incurred. OTC margined spot Foreign Exchange trading involves a high amount of risk and is highly speculative. By signing the Risk Disclosure Statement, the Customer ( agrees that they are in full understanding and are willing to assume the legal, economic, and other risks associated with trading in margined OTC spot Foreign Exchange, and are willing and able to assume the loss of their entire Risk Capital, defined as those funds, that if lost, would not change your lifestyle or your family’s lifestyle. As such, Customer further agrees that margined spot OTC Foreign Exchange trading may not be suitable for retirement funds. AAA encourages Customers to closely manage outstanding open positions and to use prudent money management precautions such as, but not limited to, Stop Loss Orders.

Excessive leverage available with OTC margined spot Foreign Exchange can lead to quick losses. By signing the Risk Disclosure Statement, the Customer agrees that using a high degree of leverage, defined as the use of a small amount of capital to control a larger amount in an Open Position, can result in large losses due to a price change(s) of open Foreign Currency positions with AAA. AAA provides leverage on most Currency Pairs for most customers of 100:1. For example, with 100:1 leverage, the Customer has the potential to control a $500,000 position with $5,000 in an Account. AAA encourages each of its Customers to use only that portion of leverage that such Customer is most comfortable with and to use money management precautions such as, but not limited to, Stop Loss Orders for the purpose of managing risk. AAA reserves, at its sole discretion, the right to reduce or increase the amount of leverage given on any Currency Pair at any time and without notice.

OTC margined spot Foreign Exchange trading experiences periods of substantial liquidity risk. By signing the AAA Risk Disclosure Statement, each Customer acknowledges that liquidity risk, resulting from decreased liquidity of a currency pair, is usually due to unanticipated changes in economic and/or political conditions. Each Customer also acknowledges that Liquidity Risk can affect the general market in that all participants experience the same lack of buyers and/or sellers. Each Customer also understands that liquidity risk can be AAA specific due to changes in liquidity available to AAA from AAA’s inter-bank liquidity providers or specific to retail Foreign Exchange market makers due to a perception that the risks of the market segment have increased. When liquidity decreases, Customers can expect, at the minimum, to have wider bid to ask spreads as the supply of available bid/ask prices, outstrips the demand. Decreases in liquidity can also result in “Fast Market” conditions where the price of a currency pair moves sharply higher or lower or in a volatile up/down pattern without trading in an ordinary step-like fashion. In some instances there may exist the possibility that a trading bid and/or ask price for a Foreign Exchange pair or pairs is not available (a situation where there is no liquidity). Although there may be instances when the aggregate OTC spot Foreign Exchange market enters a “Fast Market” situation or periods where liquidity is in short or no supply, it is important to note that, AAA’s prices, bid/ask spreads and liquidity will reflect the prevailing inter-bank market liquidity for AAA. AAA will liquidate Customer positions that are not adequately margined. Because of the leverage available with OTC margined spot Foreign Exchange trading and the potential forextreme volatility, AAA reserves the sole discretionary right to liquidate a Customer’s Account should the Margin in the Account not be sufficient to cover the potential risk of loss. Required margin levels are indicated on AAA’s trading platforms. Should a Customer’s Account value go below the Liquidation Level, AAA reserves the right to automatically Liquidate the customer’s position and the Customer will be responsible and liable for all resulting losses as a result of such liquidation. AAA reserves the right to change the Liquidation Level at its sole discretion. Prices from AAA are independent of prices of other institutions and businesses.

By signing the AAA Risk Disclosure Statement, each Customer acknowledges that the prices reported by AAA for buying and selling currency pairs are independent and can differ from the prices displayed elsewhere or from those of other liquidity providers in the Interbank Market. Differences can result from, but are not limited to, changes in liquidity from Interbank market makers to AAA, an unbalanced position or exposure in currency pairs at AAA, or differing expectations of price movements in currency pairs by AAA. AAA expects that in most cases the prices provided to its Customers will be in line with the general Inter-bank Market but AAA does not represent, warrant or covenant, explicitly or implicitly, that this will always be the case. Rollover rates for open positions of currency pairs are determined by AAA and are independent of prices found elsewhere in the Interbank Market. By signing the AAA Risk Disclosure Statement, each Customer acknowledges that all existing spot open positions that remain open over the end of business day (defined as 5:00 p.m. New York / 12:00 a.m. Greece), are automatically rolled over to the next available Spot Settlement Date at a net debit or credit to a Customer’s Account as determined by spot interest rates determined solely by AAA. In general, if a Customer is long (has bought) on a currency that has a higher spot interest rate than the currency on which such Customer is short (has sold); such Customer can expect a net credit added to the Customer’s Account Value at the end of day. If a Customer is short (has sold) a currency that has a higher spot interest rate than the currency on which such Customer is long (has bought), such Customer can expect a net debit subtracted from the Customer Account Value at the end of the day. Rollover debits and credits are also influenced by the number of days that the position must be to be rolled. For positions that must be rolled from a Spot Settlement Date of Friday to Monday, the debit or credit will reflect the rollover from Friday to Monday, or three (3) business days. For rollovers from Monday to Tuesday, Tuesday to Wednesday, Wednesday to Thursday and Thursday to Friday, the rollover debit or credit is for only one (1) business day. If there is a holiday and AAA is closed, the rollover would include the holiday. For example, if Tuesday is a holiday, rollovers from Monday will be two (2) business days (i.e. from Monday to Wednesday). Since rollover debits and credits are determined by the respective short-term spot interest rates of the respective currencies that make up a currency pair, a large spread between one currency’s rate in relation to another can cause a large debit or credit rollover amount. This spread can result, but is not limited to a country’s tightening of credit conditions in order to dissuade speculators from shorting a currency versus another. For example, the Bank of England in the early 1990’s raised short-term interest rates to over 20% in an attempt to dissuade currency speculators from selling Pound Sterling against other currencies when the Pound Sterling came under pressure by speculators. In this situation, those who were short GBP and long US Dollars were forced to rollover their spot positions at a large debit from one spot settlement date to the next. By doing so the Bank of England was attempting to dissuade currency speculators from selling GBP over spot and rolling over the position from one day to the next. The action was intended to force those who were short GBP, to cover their positions before the end of the day forcing an underlying bid into the currency. Year-end and quarter-end periods can also cause unusual spikes in short-term interest rates that may cause temporary spikes in rollover debits and credits. Each Customer acknowledges that there exists a rollover risk to currency positions. AAA will display the rollover debits or credits for the respective currency pairs on its web site (www.aaafx.com and automatically periodically update Customer Reports to reflect the cash flow. AAA reserves the right to change the credits or debits at its sole discretion if the original amounts are in wrong due to an error or omission. Sweep rates for currency balances other than USD are determined by AAA and may be independent of prices found elsewhere in the Interbank Market. Profits that are calculated in a Foreign Currency are “swept” into dollars when the open positions are closed and the Profit and Loss realized. For example, if a Customer buys one (1) lot of USD/JPY at 115.00 and sells the same one (1) lot at 116.00, the realized profit on the transaction would be:

Sale Proceeds in Yen = 11,600,000 Yen
Less: Purchase Proceeds in Yen = 11,500,000 Yen
---------------------
Realize Profit of the Trade = 100,000 Yen

Since the Realized Profit is in Yen, the amount must be swept into US dollars by selling Yen and Buying USD. If the exchange rate for the USD/JPY exchange rate is 116.05, the 100,000 Yen are converted and swept into USD at 116.05 creating a USD realized profit of $861.70 (100,000 / 116.05 = $861.70). When dealing in currencies where the secondary currency is USD (i.e. EUR/USD and GBP/USD), the realized profit or loss is already stated in USD. As a result, the profit or loss does not have to be swept. There is no guarantee that AAA will be able to execute Stop Loss Orders, Limit Orders or OCO orders at the price the Customer designates. Customer acknowledges and agrees that there may be market, liquidity or other conditions that will prevent AAA from executing a Customer’s specific Stop Loss Orders, Limit Orders or OCO Orders at the Customer designated price. In some cases the orders will be executed at prices that are less favorable to the price entered and desired by the Customer. The Customer acknowledges and agrees that the Customer is still responsible and liable for deals executed at levels different from their orders and that AAA is not liable for failure to do so. There is a technology risk inherent in trading online or via a software application and the Customer accepts that risk. AAA has invested resources developing, testing, configuring, and integrating the AAA Internet Trading Platform, and other relevant software and hardware. However, the Customer acknowledges and agrees that AAA does not guarantee that the Customer will be able to successfully execute, deal, monitor their positions, or perform other essential trading tasks while using the public Internet and other technology from AAA or from third party vendors known or not known on which AAA may rely. AAA cannot control, without limitation, the routing, Internet connectivity, reliability of customer or AAA equipment, network connections or any other technology hardware malfunction caused by AAA hardware, hardware and connectivity that makes up the public Internet, or hardware at the Customer’s location. AAA does not guarantee, although reasonable efforts have been made, that the AAA Internet Trading Platform and Associated Back Office and Broker Software Interfaces or any other code or application including but not limited to the interface with AAA liquidity provider(s) or the interface with the escrow account institution or other technology application that would come under the heading software, are free of programming bugs that can cause trading, position keeping or any other required functionality of the AAA Internet Trading Platform and other relevant software applications associated with AAA including but limited to clearing, market making and escrow account software from becoming inoperable or without errors. The Customer necessarily assumes a failure of communication risk. Although AAA will have qualified representatives available by telephone during business hours to accept and execute Customer Market Orders, there exists the risk that the Customer will not be able to contact or make contact with the AAA representative due to, but not limited to, communication malfunction, an overabundance of telephone orders, or any other malfunction or negligence.

The Customer acknowledges and agrees that Customer will hold harmless AAA for any loss or missed trading opportunity resulting from any communication problems the Customer may encounter. AAA does not take responsibility for third party account managers and Customer agrees to hold harmless AAA, its employees, agents, officers, directors and shareholders from any losses sustained by Customer as a result of actions undertaken by such third party account managers. Should a Customer grant a third party account manager discretionary trading authority, the Customer grants such authority for the Customer’s Account at its sole and full risk. AAA reserves the right to correct any deals executed on misquoting errors. In the case when a quoting error occurs that results in a Customer deal executed at an off-market price, AAA reserves the sole discretionary right to make the necessary corrections and adjustments to the Customer’s Account whether it be in the favor of the Customer or not in the Customer’s favor. Any change will be reported to the Customer via an electronic method such as but not limited to e-mail. All market recommendations made by AAA or any representative of AAA are for informational purposes only. Any decision by the Customer to buy or sell a Foreign Currency Pair is an independent decision by the Customer. Market recommendations made by AAA or a representative of AAA do not constitute an offer to sell or buy any Foreign Currency pair from AAA or from any other source that may provide dealing prices to the Customer. AAA and its employees are not investment or trading advisor(s) and have no fiduciary duty to the Customer and are therefore not liable for any losses on trades and for any losses incurred by the Customer as a result of information or any recommendations made by AAA or any representative of AAA. Customer is at risk if AAA should go out of business. There is no guarantee that AAA as a business will be profitable. Consequently, there exists a credit risk that AAA may be subject to losses, which could, in turn, jeopardize the capital that the Customers have in their Accounts. AAA may decide to exit the OTC margined Foreign Exchange business. As a result, the Customer agrees and acknowledges that AAA may liquidate all Customer positions, and return margined funds to the Customer at the sole discretion of AAA, at any time and for any reason. AAA’s Customers shall not hold AAA liable for any loss as a result of liquidation of the Customer’s position either on an actual basis or as a result of missed profit opportunities. Customers are responsible for any reporting errors. In case of Reporting and Confirmation errors or omissions, and/or errors in details of transactions including but not limited to the price at which deals were executed, the currency pair traded, the market direction (i.e., “buy” or “sell”) of order, the type of order and/or any errors in fees, charges or credits to the Customer’s Account, including but not limited to charges for executing a transaction, wiring funds, rolling over position, and/or sweeping Foreign Currency balances into the home currency, the Customer shall notify AAA immediately upon discovery for review. In addition, the Customer is responsible for submitting details of any errors in writing to AAA and sending the complete details to:

TRIPLE A EXPERTS S.A
14 Akti Kondyli
185 45 Piraeus
Greece (Europe)

Notice shall be deemed received only if actually delivered or mailed by registered mail, return receipt requested or by private courier with a receipt. Deals executed over the telephone have inherent risks. AAA will accept Market Orders for deals done over the telephone and, at AAA’s discretion other types of orders may be accepted. Telephone deals are considered executed when the AAA representative says, “done” and relays the complete deal details. Any given price by an AAA representative over the telephone prior to execution is deemed to be an indicative price. AAA reserves the right to change the indicative price given over the phone if the actual dealing price is different due to market conditions, misquote or volatility. AAA is not responsible for Customer telephone orders if the Customer cannot be heard or understood by the AAA representative due to, without limitation, accent, speech defect, faulty connection, or excessive background noise at the Customer’s location or at AAA. To better ensure execution, AAA requires that Customers communicate in English or Greek when giving orders. AAA cannot guarantee that telephone orders given in a foreign language will be executed. For best results and fast execution, the following procedure will be used. The Customer will first be asked by the AAA representative the following Account Information: The Customer’s AAA User Name, Account Number and/or other identifying features. Only after the AAA representative confirms the Customer’s identity, the Customer should relay the following order information: the execution direction to Buy or Sell, the number of lots, and the desired currency pair. The AAA representative will repeat the order information for the Customer to confirm. For example the AAA Representative may say the following, “Buy 2 lots of EUR vs. USD at the Market. Confirmed?” By saying, “Yes” the order will be executed at the Market and the details-immediately given to the Customer after execution. The AAA representative will enter the deal into the Customer’s Account. The details and effects of the deal will be reflected in the customer’s online reports. AAA does not warrant that deals done over the telephone will be done at prices that mirror the prices displayed electronically at that time over the AAA Internet Trading Platform. Although currently not planned, AAA reserves the right to charge a commission for deals done over the telephone. Should AAA charge a commission for telephone deals, it will be reported on the AAA Website and be reflected as a line item debit in the Customer’s AAA Account Reports. All deals and charges done via the phone are final. AAA reserves the right to tape all telephone calls without providing an electronic indicator tone (“beep”) or otherwise advising the Customer that the call is being recorded.AAA is not responsible or liable if the tapes of the telephone calls are erased or never recorded because of error, omission or for any other reason. AAA is also not liable should user name and Account information be obtained knowingly or unknowingly by a third party and as a result, deals done in the name of the Customer without his or her knowledge or authorization. Customers are responsible for protecting the confidentiality of their user ID and other identifying account information. Transactions in other jurisdictions include an inherent risk.

Transactions on markets in other jurisdictions, including markets formally linked to a domestic market, may expose you to additional risk. Such markets may be subject to regulation, which may offer different or diminished investor protection. Before you trade you should enquire about any rules relevant to your particular transactions. Your local regulatory authority will be unable to compel the enforcement of the rules of regulatory authorities or markets in other jurisdictions where your transactions have been effected. You should ask the firm with which you deal for details about the types of redress available in both your home jurisdiction and other relevant jurisdictions before you start to trade. Off-exchange transactions. In some jurisdictions, and only then in restricted circumstances, firms are permitted to effect off-exchange transactions and the firm with which you deal may be acting as your counterparty to the transaction. AAA functions as a direct counterparty to Customers in currency transactions. AAA neither offers the right to offset, nor guarantees a market in which to offset. Therefore, it may be difficult or impossible to liquidate a position, to assess its value, to determine a fair price or to assess the exposure to risk. For these reasons, these transactions may involve increased risks. Off-exchange transactions may be less regulated or subject to a separate regulatory regime. Before you undertake such transactions, you should familiarize yourself with the applicable rules and attendant risks. AAA has limited liability. The Customer agrees and acknowledges that AAA shall not be liable to the Customer for any claims, losses, damages, costs or expenses, including attorneys’ fees caused directly or indirectly by any events, actions or omissions, without limitation, claims, losses, damages, costs and expenses, including attorney’s fees, resulting from civil unrest, war, insurrection, international intervention, governmental action including, without limits, exchange controls, forfeitures, devaluations and nationalizations, natural disasters, acts of God, market conditions, communication problems or any delay, disruption, failure of any transmission or communication system or computer hardware or software application whether supplied and belonging to AAA or from a third party vendor that the Customer and AAA rely on to conduct execution and reporting services. Trading Rules and Regulations AAA’s Trading Rules and Regulations combined with the AAA Risk Disclosure Statement, Additional Risk Disclosure Statement and all other account documents, annexes and amendments thereto will outline procedures and policies regarding trading and setting up an account with AAA and form an integral part of the Customer Agreement. All Customers are required to read, understand and adhere to these rules and regulations. AAA reserves the right to change any rules or regulations at its sole discretion and at any time and any such changes automatically become part of the terms and conditions of the Trading Rules and Regulations with which all Customers must comply. Customers may or may not receive notice of such changes but such changes will be posted on AAA’s website. By opening an account with AAA, the Customer agrees to adhere to AAA’s Trading Rules and Regulations as amended from time to time.

Trading Hours

Deposit and Account Information

Trade Disputes
In the event of a trade dispute, it is the responsibility of the customer to contact an AAA representative in a timely manner via e-mail (support@aaafx.com) or the telephone at (+30) 2130176380 The Customer should specify the deal ID or deal number, the specific dispute with the trade and any other information relating to the deal in question. Upon knowledge of the details of the dispute, an AAA representative will analyze the deal and price logs and respond directly to the client. Because of the nature of the FX market, AAA cannot settle disputes that are not brought to the attention of AAA representatives in a timely manner. For example, should a Customer knowingly delay reporting a trade dispute in an attempt to benefit from a “free option” as a result of the problem, the client would be considered responsible for the transaction. In addition, disputes submitted after additional deals have been done in the Account, may subject the Customer to waiving his right to partial or full restitution.

System manipulation
It is expressly prohibited to directly or indirectly use any device, software or other artifice to manipulate or attempt to manipulate the functioning of any electronic system, data feed, software, connection speed or other interface, device or software of any type or kind made available to you by AAA in connection with trading on any trading platform made available by AAA. Such prohibition extends to, but is not limited to, efforts to buy at the bid, sell at the offer, or otherwise trade on off market prices by taking any action, directly or indirectly, that interferes with, jeopardizes, compromises, slows down, accelerates, impedes or interrupts the normal operation of any AAA operational and/or dealing activity, system, platform or pricing function. Should AAA determine, in its sole judgment, that a prohibited activity has taken place, AAA reserves the right to close the account, report the activity and withhold gains created as a result of the prohibited activity.