Disclosure Notice

Trading BitBaxter Markets & PRIME CONSULTORIA E COMERCIO DE ALIMENTOS LTDA

CNPJ 37484255000187

QUADRA SHN, QUADRA 02, BLOCO F,ENTRADA 87, SALAS 1603 E 1604 1603 EDIF EXEC. OFFICE TOWER ANDAR 16 70702-906

ASA NORTE BRASILIA

Disclosure Notice

Table of Contents
Introduction
I. Risk Disclosure
1. Risk Warnings Related to CFDs 5
1.1. General Risks
1.2. Leverage
1.3. Margin Rates
1.4. Position Monitoring
1.5. Counterparty Risk
1.6. Counterparty Credit Risk on CFD Trades
1.7. CFDs do not give you any rights in the Underlying Asset
1.8. Negative Balance Protection
1.9. Our rights to adjust, modify and/or Close-Out CFD transactions in the event of a
corporate action affecting the Underlying Asset 10
2. Risk Warnings applying to trading CFDs on Virtual Currencies (i.e.Cryptocurrencies)
2.1. Risk of losing the money on the Trading Platform
2.2. Risk of having the Bitcoins and/or other Cryptocurrencies stored on the electronic
wallet, stolen
2.3. Risks associated to the sudden movements in the price fluctuations of the
cryptocurrencies
2.4. Risks associated to the potential high degree of anonymity of Bitcoin and/or other
Cryptocurrencies
3. Risk Warnings related to Shares (Equities)
3.1. General risk warnings
3.2. Dividend Payment Not Guaranteed
3.3. Dealing/Administrative Costs
3.4. Shares deposited as Collateral
3.5. Market Gapping
3.6. Non-readily Realisable Investments
3.7. Past Performance
3.8. Dealing in Securities which may be Subject to Stabilisation
3.9. Liquidity Risk in Shares
3.10. Information on Overseas Investments
3.11. Price Volatility
3.12. Penny Shares
3.13. Settlement
4. Risk Warnings Related to Fractional Shares
5. Risk Warnings Related to Share Lending
5.1. General Warnings
5.2. Counterparty Credit Risk
5.3. Price fluctuation
6. Risks Warnings related to ETNs and ETCs
6.1. Exchange Traded Notes
6.2. Exchange Traded Commodities
7. Risk Warnings applicable to both CFDs and Equities
7.1. Execution Only – You trade entirely at your own risk
7.2. Market Risk
7.3. Volatility Risk
7.4. Currency Risk
7.5. Interest Rate Fluctuation Risk
7.6. Regulatory and Taxation Changes Risk
7.7. Liquidity Risk
7.8. Risk of Disruption or Interruption of Access to BitBaxter’s Electronic Systems and
Services
7.9. Segregated Accounts
7.10. No Guarantees
7.11. Uninvested Money Risks
II. Conflicts of Interest
1. What is a conflict of interest?
2. Managing and monitoring conflicts
2.1. Policies and procedures
2.2. Supervision
2.3. Remuneration
2.4. Gifts & inducements
2.5. Outside business interests
2.6. Personal account dealing
2.7. Dealing & allocation
2.8. Policy of independence
2.9. Confidentiality
3. Record Keeping
4. Disclosure
5. Miscellaneous
III. Complaints Procedures
1. Introduction
2. What is a complaint?
3. How to make a complaint?
4. Investigation
5. Timeframes
6. External Dispute Resolution
7. Complaints Register
8. Our Right To Proceed With The Recovery Of Debts
9. Interim Relief – Injunctive Relief

Introduction

Trading BitBaxter Markets is the trading name of BitBaxter (“the Company”, “Trading BitBaxter Markets & PRIME CONSULTORIA E COMERCIO DE ALIMENTOS LTDA”, “the firm”,
“we”, “our” or “us”).
The Company is registered in Brasil (Register number CNPJ 37484255000187) and is authorized and
regulated by Brasil Securities and Exchange Commission
The Company is committed to:
a. providing a high standard of client service; and
b. maintaining our reputation for credibility and accountability.
We welcome feedback on our service at any time. If you are dissatisfied with our services,
please give us the opportunity to fix the problem. We will investigate, answer your questions
and work hard so you enjoy trading with us.
Should you feel dissatisfied with any aspect of our service, your first action should be to
contact our Customer Service Team at office@bitbaxter.com
The following disclosures provide you with information about the nature and risks of certain
investment types, how we identify, monitor, manage and where applicable disclose conflicts
of interest that may arise from time to time and how you can submit complaints and our
processes for dealing with such complaints.
All words and phrases highlighted and not defined in this Disclosure Notice, shall have the
same meaning as defined in our Invest Terms and CFD Terms (as applicable).

I. Risk Disclosure

This section provides you with information about the nature and risk of certain investment
types. It does not explain all the risks or how the risks relate to your personal circumstances.
If you have any doubt whether or not our products are appropriate for you, you should seek
professional advice before trading.
We provide the opportunity for investment and dealing in the following products:
a. Contracts for differences (“CFDs”) on financial assets including shares, bonds, indices,
exchange traded funds (“ETFs”), commodities, cryptocurrencies and currency pairs
(“Forex”); and
b. Transferable securities (“equities”), including shares, fractional shares, ETFs and
Undertakings for Collective Investments (“UCITS”).
Even though our offerings are suitable for both retail and professional clients, be aware that
by investing in or dealing in any of the above you are risking your capital and you may not
get back as much as you originally invested.
1. Risk Warnings Related to CFDs
1.1. General Risks
CFDs are financial instruments that are traded on margin, enabling investors and traders to
participate in the movement of shares and index prices without having ownership of the
underlying asset.
Trading in CFDs may not be suitable for all investors due to its high risk and complex nature.
You may lose all or most of your initial payment and may be required to make additional
payments. You shall be responsible for your own trading decisions. If you are in any doubt,
you should seek independent advice.
CFDs are highly risky due to the speculative and volatile markets in these products and the
leverage (margin) involved. Trading these products may result in the loss of the entire funds
you deposited in the account. We are required by law to notify retail clients about the
percentage of Retail Clients who have lost money trading CFDs with us during the last 12
months. This disclosure will be made available on our website: www.bitbaxter.com You
must carefully consider your financial circumstances and risk tolerance before trading CFDs.
CFD trading is an activity that carries a high risk to your capital. Don’t use money you can’t
afford to lose.
You should only consider trading in CFDs if:
a. you have extensive experience trading in volatile markets,
b. you fully understand how they operate, including all the risks and costs involved,
c. you are aware that the greater the leverage, the greater the risk,
d. you understand that your position can be closed whether or not you agree with our
decision to close your position,
e. you have high-risk tolerance and the capability to absorb losses if they occur,
f. you have sufficient time to manage your investment on an active basis.
If you do not have access to the internet and cannot access the Website, please notify the
customer service team. If requested, we shall provide you with a hard copy document that
contains a description of some of the risks involved in trading CFDs.
Trading in CFDs relies on the price movement (appreciation and depreciation) of underlying
instruments. You are therefore exposed to similar but magnified risks to holding the
underlying instruments. The value of the underlying instruments may go up and down. Due
to the use of leverage, CFD trading carries a higher degree of risk than ordinary share
dealing and may not be suitable for everyone.
The trading you conduct on our Trading Platform is not conducted on an exchange or a
market and is not cleared on a central clearinghouse. The CFD transactions are contracts
with us as your counter party.
1.2. Leverage
Our products offer various levels of leverage. Before trading, we shall ask you to make an
initial deposit. Each product we offer has a margin requirement. Based on this requirement
and your initial deposit, you shall be able to trade a contract value in excess of your funds.
For example, a margin requirement of 5% would enable you to trade contracts 20 times as
large as your deposit. Fluctuations in asset prices will therefore be magnified many times.
This can work for or against you as a small price movement against you may result in a
larger profit or loss respectively. Using leverage or margin means that you may lose the
entire funds you have actually deposited in your account if the price of the CFD moves
significantly against you.
1.3. Margin Rates
We reserve the right to adjust margin requirements for each of our products and have the
right to change or increase its Margin Requirements at any time: In order to protect the firm
and all of our clients, we may modify Margin Requirements for any or all clients for any open
or new positions at any time, in our sole discretion. If we increase our margin requirements, it
may prevent you from adding positions or hedging existing positions if you have insufficient
equity. If margin requirements increase on your existing CFDs, you will have to deposit
additional equity in advance or your positions may be liquidated. This may result in your
margin requirement increasing. You may therefore be required to deposit additional funds
to maintain existing positions.
Having said the above it is of crucial importance that clients always monitor their positions
with the Company. Clients should ensure that their trading accounts are sufficiently funded
to avoid any disturbances from possible margin calls and /or stop-outs in their trading
activity.
Initial Margin percentages by type of underlying for Retail Clients:
a. 3,33% of the notional value of the CFD when the underlying currency pair is composed
of any two of the following currencies: US Dollar, Euro, Japanese Yen, Pound Sterling,
Canadian Dollar or Swiss Franc;
b. 5% of the notional value of the CFD when the underlying index, currency pair or
commodity is:
i. any of the following equity indices: Financial Times Stock Exchange 100 (FTSE
100); Cotation Assistée en Continu 40 (CAC 40); Deutsche Bourse AG German
Stock Index 30 (DAX30); Dow Jones Industrial Average (DJIA); Standard & Poors
500 (S&P 500); NASDAQ Composite Index (NASDAQ), NASDAQ 100 Index
(NASDAQ 100); Nikkei Index (Nikkei 225); Standard & Poors / Australian Securities
Exchange 200 (ASX 200); EURO STOXX 50 Index (EURO STOXX 50);
ii. a currency pair composed of at least one currency that is not listed in point (a)
above; or
iii. gold;
c. 10% of the notional value of the CFD when the underlying commodity or equity index is
a commodity or any equity index other than those listed in point (b) above;
d. 50% of the notional value of the CFD when the underlying is a cryptocurrency; or
e. 20% of the notional value of the CFD when the underlying is:
i. a share; or
ii. not otherwise listed above.
The above-mentioned margin percentages are applicable to all clients.
1.4. Position Monitoring
It is your responsibility to monitor your account. We have the right to liquidate your positions
without notice in the event of a margin deficiency (stop-out).
You must monitor your account so that at all times the account contains sufficient equity to
meet our Margin Requirements. We do not have to notify you of any failure to meet Margin
Requirements prior to us exercising its rights under its Agreement with you, including but not
limited to its right to liquidate positions in your account(s).
Should the net value of the account (cash plus running profits minus running losses) fall
below 50% of the margin required, we may close some or all of your positions at the current
market price. This should not however be taken as a guarantee, and it is your responsibility
to ensure that sufficient funds are in your account at all times.
1.5. Counter party Risk
In relation to CFDs, we are counter party to all your trades. None of our CFD products are
listed on an exchange, nor can any rights, benefits or obligations be transferred to anyone
else. While we undertake our obligation to provide you with best execution and to act
reasonably and in accordance with our published terms and conditions, CFDs opened on
your account with us must be closed with us, based on our prices and conditions. CFDs are
contracts with us as your counter party, and are not traded on a regulated exchange and
are not cleared on a central clearinghouse. Thus, exchange and clearinghouse rules and
protections do not apply to trading CFDs with us.

1.6. Counter party Credit Risk on CFD Trades
Since we are the counter party to your CFD trades, you are exposed to the financial and
business risks, including credit risk, associated with dealing with us. That is, in the unlikely
event that we were to become insolvent, we may be unable to meet our obligations to you.
Please note that Trading BitBaxter Market clients’ funds are covered by the Investors
Compensation Fund and in the unlikely event of default, you may have recourse to this fund.
The maximum amount of compensation paid to a client, who will be deemed as eligible for
compensation is EUR 20.000 or 90% of the covered investor’s claim, whichever is lower. The
said coverage applies to the total amount of claims by a client against an ICF member,
irrespective of the number of accounts, the currency and the place of provision of the
service.

1.7. CFDs do not give you any rights in the Underlying Asset
A CFD secures a profit or a loss by reference to fluctuations in the price of the Underlying
Asset, rather than by taking delivery of any Underlying Asset. No CFD transaction shall confer
on you any right, voting right, title or interest in any Underlying Asset or entitle or oblige you
to acquire, receive, hold, vote, deliver, dispose of or participate directly in any corporate
action of any Underlying Asset.
1.8. Negative Balance Protection
Negative balance protection is available to all Trading 212 clients. The Negative Balance
Protection limits the maximum losses that a retail client could have. It is designed as a
backstop for when the margin close-out rule does not work effectively as a result of a very
sudden price movement. By introducing a Negative Balance Protection per account the
client can never lose more than the total sum invested for trading CFDs. There can be no
residual loss or obligation to provide additional funds beyond those in the client’s CFD
trading account.

1.9. Our rights to adjust, modify and/or Close-Out CFD

transactions in the event of a corporate action affecting the Underlying Asset
In the event of a Corporate Action affecting the Underlying Asset of a CFD (e.g. splits,
spin-offs, rights offerings, mergers and acquisitions, etc.):
a. We may at our sole discretion determine the appropriate adjustment or modification
or action to take, if any, and when, with respect to the CFD to preserve the economic
equivalent of the rights and obligations of the parties;
b. As an addition or alternative to the foregoing, we reserve the right at our sole
discretion to close out your open CFD position in the Underlying Asset prior to the
Corporate Action.
2. Risk Warnings applying to trading CFDs on Virtual
Currencies (i.e.Cryptocurrencies)
When trading bitcoin and other cryptocurrencies with Trading BitBaxter you will not own any
physical bitcoin and no wallets but speculate on the volatility of the price movements in
bitcoin and other cryptocurrencies via a CFD. Trading CFDs on bitcoin and other
cryptocurrencies can be subject to extreme volatility, much more than traditional currencies
and when trading bitcoin and other cryptocurrencies, it is possible to lose or gain substantial
amounts in short periods of time. Trading CFDs on cryptocurrencies can result in loss of your
entire deposits.
2.1. Risk of losing the money on the Trading Platform
Since there will be no cash delivery nor a number of Bitcoins and/or other Cryptocurrencies
actually involved in the transaction performed on the Company’s trading platforms, but only
trading the difference in the price fluctuation, such risk does not apply. The Bitcoins and/or
other Cryptocurrencies shall be traded like any other financial instrument on the Company’s
trading platforms.

2.2. Risk of having the Bitcoins and/or other Cryptocurrencies stored
on the electronic wallet, stolen
The Company does not offer the possibility of purchasing, transferring and/or exchanging
cryptocurrencies. The Company’s Clients are only permitted to trade cryptocurrencies via
CFDs without actually owning any cryptocurrencies. In this context, there is no need for an
electronic wallet for the storage of cryptocurrencies and thereby there is no risk of loss or
stolen cryptocurrencies.

2.3. Risks associated to the sudden movements in the price
fluctuations of the cryptocurrencies
Adequate risk warnings shall be disseminated to the interested clients and/or potential
clients regarding the lack of regulation over Bitcoin and/or other Cryptocurrencies, instability
and volatility of the price of such currencies as well as the factors that may determine
sudden movements in the price fluctuations of the cryptocurrencies, in order to alert and
protect investors, prior entering into transactions related to the prices value difference of the
Bitcoin and/or other Cryptocurrencies, against other traditional currencies.
Stricter margin call levels shall be implemented when dealing with such transactions as well
as limitations on the leverage allowed for opening such positions involving Bitcoins and/or
other Cryptocurrencies.
Moreover, the Company has in place a negative protection as well as the necessary settings
on the platform, which will not allow clients to lose more than their invested capital. Levels of
protection can be elevated in the case of Bitcoin and/or other Cryptocurrencies related
trading activities.
2.4. Risks associated to the potential high degree of anonymity of
Bitcoin and/or other Cryptocurrencies
Since the Company only permits trading in cryptocurrencies via CFDs, the risk of anonymity
behind cryptocurrency ownership is not applicable in this context.

3. Risk Warnings related to Shares (Equities)

3.1. General risk warnings
Shares represent a part ownership in a company. As such, the owner of a share participates
in the fortune of the company. If the company does well, the shares are likely to rise in price,
but if the company does poorly, the share price is likely to fall.Holders of ordinary shares are
the last to be paid in the event of a company becoming insolvent. However, ordinary
shareholders also have the potential for returns, in the form of dividends or share price
appreciation, provided the company does well and is perceived to be continuing to do well.
In extreme cases a company can become insolvent and you may lose all the value of your
investment.Share prices are based on supply and demand forces which in many cases
depend on perceptions of the companies’ future prospects by the market.If in general,
market sentiment is pessimistic about a company and their future prospects, the share
price will likely fall and therefore, if you sell at that point or if price does not recover, you get
back less than you put in.
The value of your investments and the level of any income from them can go down as well
as up. You may not get back the full amount you have invested. You should also remember
that past performance of shares is not an indication of how those Investments might
perform in the future.
Certain investments may not be readily realizable. You may have difficulty selling these
investments at a reasonable price, and in some circumstances, it may be difficult to sell
them at any price.
Foreign markets will involve different risks from EEA markets, and in some cases, the risks will
be greater. The potential for profit or loss from transactions on foreign markets or in
foreign-denominated contracts will also be affected by fluctuations in foreign exchange
rates.
3.2. Dividend Payment Not Guaranteed
Some shares pay a dividend, either semi-annually or quarterly. A dividend is an amount of
money, determined by the company’s Board of Directors, which is a distribution of the
company’s profits. Established, profitable companies tend to pay dividends and have a
good record of providing a steady stream of dividend payments. Periods of economic
difficulty may, however, interrupt such dividend payment for even the most established
shares. Younger, less established companies that are building a business tend to retain their
profits for re-investment. These are called “growth” companies as their business strategy is
to grow their business rapidly.
3.3. Dealing/Administrative Costs
Costs mmissions and Charges levied by ourselves or third parties will reduce potential profit
you can make or increase the level of loss. Before you begin to trade, you should understand
all commissions and other charges for which you will be liable.
3.4. Shares deposited as Collateral
If you deposit collateral as security with us, the way in which it will be treated will vary
according to the type of transaction and where it is traded. There could be significant
differences in the treatment of your collateral depending on where or how you are trading.
Deposited collateral may lose its identity as your property once dealings on your behalf are
undertaken and even if your dealings should ultimately prove profitable, you may not get
back the same assets which you deposited, and may have to accept payment in cash. You
should ascertain from us how your collateral will be dealt with.
3.5. Market Gapping
This is a sudden shift in the price of an instrument or its underlying from one level to another.
It can happen at any time, but occurs most frequently when the market closes at one level
but reopens at another. This can cause unexpected losses.
3.6. Non-readily Rea lisable Investments
We may arrange or enter into transactions in non-readily realizable investments. These are
investments in which the market is limited or could become so. You may have difficulty
selling such an investment at a reasonable price and, in some circumstances. It may be
difficult to sell it at any price. Do not invest in such investments unless you have carefully
thought about whether they are suitable for you.

3.7. Past Performance
You should be aware that the price of the financial instruments that you are dealing with
depends on fluctuations in the financial markets outside of our control and that past
performance is no indicator of future performance.

3.8. Dealing in Securities which may be Subject to Stabilization
We, and/or our representatives, may from time to time carry out transactions on your behalf
in securities subject to stabilization. Stabilization enables the market price of a security to be
maintained artificially during the period when a new issue of securities is sold to the public.
Stabilization may affect not only the price of the new issue but also the price of other
securities relating to it.
3.9. Liquidity Risk in Shares
Shares are available in companies of different sizes, industrial sectors, geographical
locations, and on different stock markets. Liquidity is an important risk factor when investing
in individual equities and is generally driven by the market capitalization (total value of
issued shares) of the company and current market conditions. Liquidity levels can change
rapidly and lack of liquidity often restricts trading in equities with smaller market
capitalization (known as mid cap and small cap).
3.10. Information on Overseas Investments
Information on overseas investments is not as readily available to the public and the
financial pages of the national press give little coverage of the subject. Different time zones
also mean that you will not always be able to get a real time price for overseas stocks
during your relevant trading day. When investing in overseas markets, currency fluctuations
need to be taken into account. A gain or loss made on the performance of a stock can easily
be offset by a movement in the currency exchange rate. Alternatively a gain or loss on a
stock could be compounded to make an even larger one.
3.11. Price Volatility
The price of individual shares can fluctuate considerably and can appreciate or decline
rapidly. Shares can also remain in decline over long time periods. Share prices rise and fall
according to the health of the company and general economic and market conditions.
Individual share price rises and falls can be significant. Stock market investments tend to be
more volatile than investments in most bonds.
3.12. Penny Shares
Shares purchased on the Alternative Investment Market (AIM) (especially those known as
‘penny shares’) carry a higher degree of risk of losing money than other shares. This is
because the requirements on companies that are listed on AIM are less stringent than those
for companies with a full market listing. There is also usually a wider spread between the
buying price and the selling price of these shares and if they have to be sold immediately,
you may get back less than you paid for them due to a lack of liquidity. The price of these
shares may change quickly and they may go down as well as up. It may also be difficult to
obtain reliable information about their value or the extent of the risks to which they are
exposed.
3.13. Settlement
In many market places (for example shares traded on the London Stock Exchange)
settlement takes place by the counter parties simultaneously matching shares traded with
cash being given. In other market places (for example those where CFDs are traded), you, on
making an initial investment, put up a sum of cash (the margin) which represents a
percentage of the value of the investment. If the price of the investment subsequently
fluctuates, you may be called upon to put up extra cash (a margin call).
4. Risk Warnings Related to Fractional Shares
Fractional shares cannot be traded on public exchanges and are liquid and unrecognized
outside our trading platform. You can only liquidate them when they are sold through us and
they cannot be transferred to another broker unless they are sold.
We will comply in all respects with “best execution” on all orders executed through
BitBaxter in line with its regulatory requirements. This means that execution will be based on a
price no worse than the prevailing bid/offer on the reference exchange as of the time of your
order for all full share and fractional share components of a transaction. Any Order greater
than one share that includes a fractional share component will be executed in a mixed
capacity. BitBaxter will act in either a principal or risk less principal capacity with respect to the
fractional share components of the transaction. If you enter an order solely for a fractional
share, BitBaxter will execute your trade over-the-counter, matching it internally based on a price
no worse than the prevailing bid/offer on the reference exchange as of the time of your
order. Orders entered outside of regular trading hours cannot be executed.
BitBaxter rounds all fractional holdings to eight decimal places. For all notional based orders, your
transaction will never exceed the order amount. Rounding may also affect your ability to be
credited for cash dividends, stock dividends and stock splits. For example, if you own
0.00000001 shares of stock that pays a one cent dividend per share, we will not credit your
cash balance a fraction of a cent. In carrying out rounding, we will use reasonable
endeavors to get as close as possible to your order, however, we shall not be liable for any
loss or damage suffered or incurred by you arising out of or in connection with such
rounding, save to the extent directly attributable to our negligence, fraud, wilful default,
breach of contract or breach of Rules.
On a best effort basis we will facilitate voting rights on a pro-rate basis, however, we cannot
guarantee this right. We do not restrict in any way any rights you would otherwise have over
the securities and funds in your BitBaxter account, including any fractional shareholdings.
There are potential conflicts of interest in connection with fractional transactions and you
have consented to this transaction by agreeing to the Invest Terms. You may revoke your
consent to such a transaction at any time by written notice to us.
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.

5. Risk Warnings Related to Share Lending

5.1. General Warnings
When you lend your shares to us, we will on-lend the shares by entering into a back-to-back
lending arrangement with a reputable third-party (Borrower). We will receive fees or
payment for lending shares to the Borrower. Such fees are due to us only.
When you lend your shares to us, we shall at all times act as your counter party and are
obliged to redeliver shares to you. You will not receive fees or payment for lending your
shares to us.
Shares that you lend to us and which we lend out to the Borrower are generally recalled from
the Borrower before the ex-dividend date in order to capture the dividend. Where the recall
does not take place, we will be entitled to a payment from the Borrower, and you will be
entitled to a payment from us, equivalent to the dividend you would otherwise have
received. Please note that the aforementioned payment may have different tax implications.
You remain responsible for any and all tax obligations that may arise in connection with the
aforementioned payment.
With respect to shares lent, voting rights will be held by the Borrower, although the Borrower
will be required to account for the benefit of Corporate Actions such as rights or bonus
issues. This means that You may not be able to exercise all voting rights related to any
shares lent. You will receive any other rights and distributions made on loaned shares.
5.2. Counter party Credit Risk
Since we are your counter party for all transactions, in the event that we become insolvent,
we may be unable to return the shares lent. In addition, due to the chain of borrowing, you
may be exposed to counter party credit risk whereby the borrower may become insolvent.
We mitigate this risk in the following way:
a. We require collateral from the Borrower and shall provide you with the same
collateral. The collateral value must be higher than the value of the shares lent,
specifically, at least 102% of the value of the shares lent. The collateral will be in the
form of US Treasury Bonds, and therefore its value is relatively stable. Importantly, the
collateral will be held in a segregated account for you, which means that you are
entitled to the collateral in the event of our insolvency.
b. We and not the Borrower, are always your counter party for the share lending
transaction and therefore, even if the Borrower becomes insolvent, we guarantee the
timely return of the shares to you with its own equity.
Therefore, with respect to losses for a client whose shares are lent arise only at the moment
when both the Borrower and we are no longer able to meet their obligations (i.e. both the
Borrower and BitBaxter are insolvent), and the value of the security has fallen or the value
of the shares has increased.
5.3. Price fluctuation
We do not know in advance which shares will be lent or when; sometimes just a part of the
portfolio is lent and sometimes none of it. The market dictates the demand for the shares;
there is no certainty whatsoever whether your shares will indeed be lent. You will be able to
see information about this on the Trading Platform, where you will see end-of-day
information on what percentage of your shares (per instrument) are lent.
Notwithstanding whether the shares are lent or not, you are always exposed to price risk on
the shares. The price of shares rises and falls, so this risk continues to exist.
Where your shares are lent, to help mitigate the risk of share price fluctuation, we require the
Borrower to monitor all collateral which it provides to us, and similarly we will monitor all
collateral which we provide to you, on a daily basis, to ensure that the value of the collateral
is always equal to or more than 102% of the value of the shares lent.

6. Risks Warnings related to ETNs and ETCs
Please bear in mind the above-outlined considerations concerning cryptocurrencies also
apply with respect to ETNs and ETCs with underlying cryptocurrencies. Trading in such
instruments entails high risk. You should only invest in financial products that are
suitable to your knowledge and experience.

6.1. Exchange Traded Notes
ETNs are types of debt securities designed to track the total return of an underlying market
index or another benchmark. They are often unsecured, meaning that they are not backed
up by collateral since they do not hold the underlying asset. ETNs are considered high risk for
lenders, as it is unsure whether the borrower will repay the full amount. ETNs can be held to
maturity or bought or sold at will. This type of debt instrument has a volatile price and unlike
bonds, it does not pay interest payments. Every ETN has a Key Investor Document (KID),
showing the costs, investment policy and risk of the product.
By investing in ETNs, you can lose the full amount invested, including the incurred transaction
costs. There is also a risk that the issuer becomes insolvent and is not able to pay out the
value of the ETN. The ETN may also not be profitable and unable to pay its transaction costs.
Another associated risk is the inability to sell the position in the market at any preferred point
in time.
6.2. Exchange Traded Commodities
An ETC is a debt instrument, which follows individual or multiple commodities and it can
offer investors the possibility to invest in commodities like gold, oil, metals, energy and
livestock. ETCs’ value may fluctuate based on price changes of the underlying commodity.
ETC issuers charge fees, which are included in the product and disclosed in the KID.
Additional broker fees may also apply. An ETC follows the price of a commodity or
commodity index and it does not represent ownership. As such, ETC investors may lose the
full invested amount including the incurred transaction costs.

7. Risk Warnings applicable to both CFDs and Equities

7.1. Execution Only – You trade entirely at your own risk
Our service is “execution only”, meaning we will only carry out your trading instructions. We
shall not offer you any advice or recommendation regarding the suitability of any
investments with us, and nothing we send or tell you should be interpreted as such. We do
not provide investment, tax or trading advice. Our service is “execution only”, meaning we will
not advise you on any transaction, nor will we monitor your trading decisions to determine if
they are appropriate for you or to help you avoid losses. You should obtain your own
financial, legal, taxation and other professional advice as to whether CFDs or Shares are an
appropriate investment for you. We may provide you with factual information in relation to
our products, their potential risks, or about the financial markets in general; in doing so we
shall not have assessed your individual circumstances.
7.2. Market Risk
Trading with Shares and CFDs carries the risk of sudden market fluctuation. CFD trading in
particular relies on the price movement of underlying financial products. You are therefore
exposed to similar, but magnified risks to holding the underlying assets.
7.3. Volatility Risk
Markets for CFDs and Shares can be highly volatile. The prices of CFDs and their Underlying
Products (shares or indices) may fluctuate rapidly and over wide ranges. The prices of CFDs
will be influenced by, among other things, the market price of the underlying product of the
CFD, the earnings and performance of the company or companies whose shares comprise
the underlying product or a related index, the performance of the economy as a whole, the
changing supply and demand relationships for the underlying product or related
instruments and indices, governmental, commercial and trade programs and policies,
interest rates, national and international political and economic events and the prevailing
psychological characteristics of the relevant marketplace.
Furthermore, sharp, sudden and unexpected movements in the underlying product’s price,
may result in a substantial and magnified profit or loss to you. Markets may not move in a
smooth fashion, and price ‘gaps’ may occur with consecutive quotations far apart. There
may not always be an opportunity for you to place an order or for our platform to execute an
order at the price level which you have selected. One of the effects of this may be that stop
loss orders are executed at unfavorable prices, either higher or lower than you may have
anticipated, depending on the direction of your trade.
7.4. Currency Risk
Where you are trading a product denominated in a currency different from that in which you
hold your account, fluctuations in the exchange rate affect your profit and loss.
When you deal in a CFD or Shares that are denominated in a currency other than the base
currency or currency you have on deposit in your Account, all margins, profits, losses and
financing credits and debits in relation to that CFD are calculated using the currency in
which the CFD is denominated. Thus, your profits or losses will be further affected by
fluctuations in the exchange rates between the account currency and the currency in which
the CFD is denominated. We apply a margin “haircut” to reflect this risk, and so the Margin
Requirement on the CFD will effectively increase.
7.5. Interest Rate Fluctuation Risk
Interest rates fluctuate, which will affect the financing charges (or rebates) you will pay (or
may receive) on your long (or short) CFD positions. This will also affect your total profits or
losses.
7.6. Regulatory and Taxation Changes Risk
Changes in taxation and other laws, government, fiscal, monetary and regulatory policies
may have an adverse effect on the value of your CFDs or Shares, the tax you pay on your
CFDs or Shares, and the total return on the products.
7.7. Liquidity Risk
Under certain circumstances, it may not be possible to close a part of or a whole position at
the current price or at all. We are not obligated to provide quotes for any CFD at any time,
and we do not guarantee the continuous availability of quotations or trading for any CFD.
We may at our sole discretion cease quoting CFDs and/or cease entering new CFD or Shares
transactions at any time based on lack of market data, halts or suspensions or errors or
liquidity or volatility in the market for the Underlying product, or our own risk or profit
parameters, technical errors, communication problems, market or political or economic or
governmental events, Acts of God or Nature, or for other reasons.
7.8. Risk of Disruption or Interruption of Access to BitBaxter’s
Electronic Systems and Services
We rely on computer software, hardware and telecommunications infrastructure and
networking to provide its services to Clients, and without these systems we cannot provide
the services. These computer-based systems and services such as those used by us are
inherently vulnerable to disruption, delay or failure, which may cause you to lose access to
our trading platform or may mean we are unable to provide CFD or Shares quotations or
trading, or may negatively affect any or all aspects of our services. Under our CFD Terms you
accept our systems and services and our liability to you is limited.
7.9. Segregated Accounts
All our client funds are held in segregated bank accounts.
While we monitor the creditworthiness of our banks closely and select them on the
basis of robustness and solidity, using only major international banks, this does not mean
that they are risk-free. We can provide you with details of which banks we use, on request.
7.10. No Guarantees
The Company does not and cannot guarantee the initial capital of your portfolio or its value
at any time or any money invested in your dealings in CFDs or Shares trading.
You unreservedly acknowledge and accept that, regardless of any information which may
be offered by the Company, the value of any Investment may fluctuate downwards or
upwards and it is even probable that the investment may become of no value.
You further unreservedly acknowledge and accept that you may run a significant risk of
incurring losses and damages as a result of your dealings in CFDs or Shares trading and you
accept and declare that you are willing to undertake this risk.
You should not engage in CFD or Shares trading unless you understand the nature of such
trading, the nature of the particular transaction you are entering into and the true extent of
your exposure to the risk of loss. In order to engage successfully in CFDs or Shares Trading,
you should be experienced in dealing in derivatives and understand the geared or
leveraged nature of these products.
7.11. Uninvested Money Risks
When you hold Uninvested Money with BitBaxter, we may deposit your Uninvested Money with
banks on your behalf and you may be eligible to receive interest from BitBaxter on Uninvested
Money, as per the applicable Invest Terms. While your Uninvested Money will continue to
receive protections as client money (as per section 7.9 above), that can still expose you to
certain risks
7.11.1. Inflation: Inflation risk occurs when the rate of inflation exceeds the interest rate
earned, which can result in your money losing value over time. In case of inflation, the
interest you may be eligible to receive from T212 may not follow the pace of rising costs.
7.11.2. Credit risk: If the bank in which your Uninvested Money is deposited becomes
insolvent, you may lose (a part of) your money. To manage this risk, as per section 7.9 above
BitBaxter carefully selects banks and regularly monitors their creditworthiness. Additionally, you
may be eligible to recover (a part of) your money from a protection scheme.

II. Conflicts of Interest

We have put in place a range of procedures in order to identify, monitor, manage and where
applicable disclose conflicts of interest that may arise from time to time. The effectiveness
of all these controls is monitored on an ongoing basis and forms part of our Compliance
Monitoring Programs.
We place a great emphasis on maintaining a strong compliance culture. This culture is
continually reinforced with all staff, and the need always to act in clients’ best interest is the
cornerstone of our philosophy.

1. What is a conflict of interest?
Conflicts of Interest may arise in any area of our business in the course of providing any
investment and ancillary services, which may result in benefiting our interests. Conflicts of
Interest can arise between various parties, including:
a. BitBaxter and one or more of its clients;
b. A director or an employee and one or more of the firm’s clients;
c. A director or an employee and BitBaxter;
d. Two or more of the BitBaxter’s clients;
e. A third-party service provider and BitBaxter;
f. A third-party service provider and BitBaxter s client(s); and,
g. Two or more employees.
It is not desirable to enumerate a definitive list of circumstances in which conflicts could
arise; part of staff training in this area is to recognize and remediate or escalate potential
conflicts in the course of business. However, to help identify potential conflicts of interest, we
have considered a number of areas, including:
a. circumstances where we could make a financial gain, or avoid a financial loss, at the
expense of a client;
b. where financial or other incentives to fav our the interest of one client or group of
clients over the interests of another client or group of clients might arise;
c. where our employees conduct personal account dealing and their positions oppose
to clients’ positions, particularly in relation to less liquid stocks;
d. where we may or will receive an inducement from a third party in relation to a service
provided to the client or us, in the form of monies, goods or services, other than the
standard commission or fee for that service;
e. where we or a relevant person has an interest in the outcome of a service provided to
the client or of a transaction carried out on behalf of the client, which is distinct from
the client’s interest in that outcome;
f. where we have information about or have obtained information from one customer
that is of relevance to transactions for another customer (for example information
which shows one customer may be selling a specific stock and another buying; and
g. where our employees accept benefits or gifts that could be construed as conflicting
with our duties to the client.
Hereby, we have provided a summary of the most prevalent conflicts of interest that may
arise and what we are doing to identify and mitigate them.

2. Managing and monitoring conflicts
We have a number of mechanisms in place to manage potential and actual conflicts, which
are summarised below.
2.1. Policies and procedures
In order to identify, analyze and mitigate any possible conflicts of interest, we have
embedded policies and procedures throughout our business to ensure conflicts are
identified, considered and mitigated. We also run a robust Compliance Monitoring Plan,
which includes ongoing monitoring of Conflicts of Interest.
Our employees undergo regular training and receive guidance where conflict situations
arise. The management team are responsible for ensuring that their teams have robust
controls in place to identify and manage risks which arise. We conduct a Risk Framework
and have a register, where we record actual and potential conflicts of interest as well as
details of the controls which were put in place to mitigate potential issues.
2.2. Supervision
Where the interests of one team and its clients may conflict with the interests of another
team and its clients, the management structure has been separated. We have in place
measures designed to prevent or limit any person exercising inappropriate influence over
the way in which services or activities are carried out.
2.3. Remuneration
In order to mitigate any conflicts of interest related to remuneration dissatisfaction, we have
a remuneration policy which is updated annually. We have a remuneration policy which is
updated annually and any direct link between the remuneration of relevant persons
principally engaged in one activity and the remuneration of, or revenues generated by,
different relevant persons principally engaged in another activity, where a conflict of interest
may arise in relation to those activities has been removed. Our staff is remunerated by a
combination of:
a. Basic salary and related benefits;
b. Discretionary annual bonus.
These take into account individual, team and company performance. No employee will
directly benefit from any single trade a client may make.
2.4. Gifts & inducements
In order to dissuade the possibility of gift receiving or inducements from our employees, we
have procedures in place about the giving and receiving of gifts or hospitality. Employees
must neither solicit nor accept any inducements which may conflict with our obligations to
clients, nor offer inducements which could conflict with the recipient’s obligations to its own
clients.
2.5. Outside business interests
We manage any possible conflicts of interest arising from employees’ outside-of-work
activities that may arise by requiring all employees to disclose their outside business
interests and directorships. We undertake pr-employment screening exercises in order to
ensure that Staff is fit and proper and appropriately qualified.
2.6. Personal account dealing
In order to ensure our employees invest by complying with the relevant regulations and
without using any insider information, we have in place restrictions regarding employees’
own, personal-account, dealing. All dealing or investment accounts must be approved by
the management and copies of contract notes are automatically sent to the Compliance
Department.
2.7. Dealing & allocation
In order to ensure that deals cannot be allocated in fav our of one group of clients or staff, we
operate dealing and allocation procedures which cover dealing fairly and in due turn.

2.8. Policy of independence
Our staff procedures require employees to disregard any material interest or conflict of
interest when acting on clients’ behalf.

2.9. Confidentiality
Our strict client confidentiality policy ensures that all information relating to clients is
retained with the firm and treated as confidential information. Confidential information is
only disclosed to those entitled to receive it. Staff is prohibited from using any such
confidential information for their own interests.
3. Record Keeping
The Compliance Department will arrange for the recording of any ‘Conflict of Interest’ in an
appropriate and separate ‘Conflicts of Interest’ register, and will inform the Risk
Management, senior management and Board of Directors of the Company of the matter
and of any action taken.
The register shall also include an updated version of this Policy. The information contained
within the register facilitates the effective identification and management of any potential
‘Conflicts of Interest’.
The information contained within the register will be kept for a minimum of five (5) years,
with any changes made in it will also be kept for the same period of time.
4. Disclosure
Stage three in mitigating potential ‘Conflicts of Interest’ is to be transparent towards the
Clients with regard to the identified conflicts that might arise, or are about to arise when
conducting business. Possible measurements will be implemented in order to act in the best
interest of the Client.
Where a conflict arises and the Company becomes aware of it, it shall take all reasonable
steps to address that conflict and, if not possible, the Company shall disclose the conflict to
the client prior to undertaking investment business for that client or, if it does not believe that
disclosure is appropriate to manage the conflict, it may choose not to proceed with the
transaction or matter giving rise to the conflict.
The Company reserves the right to assess and periodically review, at least annually, and, if
necessary, amend this Policy and arrangements, at its sole discretion, whenever it deems fit
or appropriate, in order to address any deficiencies.
5. Miscellaneous
These conflicts of Interest’s arrangements are not part of our Invest and CFD Terms and do
not seek to impose any obligations on us which we would not otherwise have, but for the
Brasil Investment Services and Activities and Regulated Markets Law of 2007.
Markets in Financial Instruments Directive (recast) –
These conflicts of Interest arrangements ’ are not intended to, and do not, create third-party
rights or duties that would not already exist if they had not been made available.

III. Complaints Procedures

1. Introduction
Should you feel dissatisfied with any aspect of our service, your first action should be to
contact our Customer Service Team at office@bitbaxter.com
The complaints handling section sets out the method for the submission of complaints by
clients and our processes for dealing with such complaints.

2. What is a complaint?
We define a complaint as any oral or written expression of dissatisfaction, whether justified
or not, from, or on behalf of, a person about the provision of, or failure to provide, a financial
service or a redress determination, which:
a. alleges that the complainant has suffered (or may suffer) financial loss, material
distress or material inconvenience; and
b. relates to an activity of that respondent, or of any other respondent with whom that
respondent has some connection in marketing or providing financial services or
products, which comes under the jurisdiction of the Financial Ombudsman Service.”

3. How to make a complaint?
Any member of the Company staff can receive a customer complaint and has the
responsibility to do everything within their authority to resolve the issue at the first point of
contact. Where a member of staff feels they lack the experience, expertise or authority to
settle the matter immediately, they may refer the matter to their supervisor.
Complaints shall be submitted in writing through the normal Customer Support
communication channels, namely by sending an email to our Customer Service Team at
office@bitbaxter.com.
To help us respond as quickly as possible, a complaint sent by the client shall include:
a. the client’s name and surname;
b. the client’s username;
c. the date on which the issue arose;
d. the affected transaction numbers, if applicable; and
e. a clear and logical description of the issue.
Complaints shall not include offensive language directed to either the Company or any
Company employee.
Our Customer Support team may contact the complainant directly in order to obtain further
clarifications and/or information. The complainant’s cooperation is required for the handling
of the complaint in question.
While our Customer Support team will be able to resolve the majority of queries, you may
also refer the query as a complaint to our Compliance Department. We prefer to receive
complaints in writing, as there is less potential for misunderstanding.
In order to contact the Company’s Compliance Department, you should write to
legal@bitbaxter.com
setting out the details of your complaint as clearly as possible. The Compliance Department
operates independently and will carry out an impartial review of your case, contacting you
for more information if necessary. They will endeavor to determine what happened or
failed to happen, and assess whether we have acted properly and in accordance with our
rights and obligations. They may also determine whether any compensation is due.
4. Investigation
Upon receipt of your complaint our staff will acknowledge your complaint within five (5)
days from the receipt of your complaint and provide you the unique reference number of
your complaint. The unique reference number should be used in all your future contact with
the Company, the Financial Ombudsman regarding the specific complaint.
Whilst our internal procedures allow us up to eight weeks to deal with a complaint, every
effort will be made to resolve complaints as quickly as possible. In any case, we will inform
you of the progress of your complaint 28 days after receiving it.
5. Time frames
The Company will make every effort to review a Complaint carefully, investigate the
circumstances surrounding your complaint and will try to resolve it without undue delay. The
Company shall make every effort to investigate a complaint and provide the outcome of the
Company’s investigation within eight (8) weeks from the date the Complaint was submitted
to the Company.
During the investigation process the Company will keep the Complainant updated of the
handling process of the complaint.
The Company may contact the Complainant directly (including communication by email or
phone) in order to obtain, where needed, further clarifications and information relating to a
complaint. The Company will require full cooperation in order to expedite the investigation
and possible resolution of a complaint.
In the event that a complaint requires further investigation and the Company cannot resolve
it within eight (8) weeks, the Company will issue a holding response in writing or another
durable medium.
When a holding response is sent, it will indicate the causes of the delay and when the
Company’s investigation is likely to be completed. In any event, the Company shall provide
the Complainant with the outcome of the investigation no later than four (4) weeks from the
issuing of the holding response, depending on the complexity of the case and your
cooperation.
Please note that the Company shall consider a complaint as closed and cease the relevant
investigation in case the Complainant fails to respond to the Company within the period of
twelve (12) weeks from the date of the submission of the complaint.
When the Company has reached an outcome, the Company will inform the Complainant of
it together with an explanation of the Company’s position and any remedy measures the
Company intends to take (if applicable).
6. External Dispute Resolution
If the Complainant is not satisfied with the Company’s final decision the Complainant may
submit their complaint to the Financial Ombudsman in Brasil and seek
mediation for possible compensation. It is important that you contact the Financial
Ombudsman in Brasil within sixteen (16) weeks of receiving a final response
from the Company otherwise the Financial Ombudsman in Brasil may not
be able to deal with your complaint.

In the unlikely event that the Company was unable to provide you with a final response
within twelve (12) weeks time period specified above you may again contact the office of the
Financial Ombudsman in Brasil no later than sixteen (16) weeks after the
date when we ought to have provided you with our final decision.

7. Complaints Register
We store all complaints we receive on an internal archive, as quickly as possible, and in an
appropriate manner.
We are required to provide to Brasil Finance Gov. information regarding the complaints we receive via an
electronic form to the Commission on a monthly basis.
8. Our Right To Proceed With The Recovery Of Debts
The above Complaints Handling Procedure does not apply to money that you may owe to
us.
We may take immediate action to recover any debts payable to us in court.

9. Interim Relief – Injunctive Relief
Nothing set forth herein shall prevent either Party from applying to court for interim or
injunctive relief.
Each party acknowledges that a breach of the provisions of this Agreement may cause the
other Party irreparable injury and damage and, therefore, any such breach may be enjoined
through injunctive proceedings, in addition to any other rights and remedies that may be
available to either Party as per applicable law or in equity.

When investing, your capital is at risk. Investments can rise and fall and you may get back less than you invested.