Copy Trading Risk Disclosure & Liability Statement

Copy Trading Risk Disclosure & Liability Statement

Vanuatu · Company legal entity: Topwealth Trading Limited · Final draft · 18 October 2026

1. Purpose, Status and Acknowledgement

1.1 This Copy Trading Risk Disclosure & Liability Statement (the “Statement”) is issued by Topwealth Trading Limited, operating as TopWealth Trading (the “Company”), for persons considering or using the Copy Trading Service. It should be read with the Copy Trading Terms & Conditions, Client Agreement, relevant risk disclosures and other applicable account documentation.

1.2 The Statement explains material risks and general responsibility principles. It does not replace individual assessment of financial circumstances and risk tolerance, and it does not constitute personalised investment, legal or tax advice.

1.3 By acknowledging this Statement, a Copy Trader confirms having had the opportunity to read and consider the risks described. Acknowledgement does not waive non-excludable rights or remedies.

2. General Market, Leverage and Margin Risks

2.1 Foreign exchange, contracts for difference and other leveraged markets can be volatile. Economic events, interest rates, geopolitics, market closures and changes in liquidity may trigger rapid adverse price movements.

2.2 Leverage magnifies gains and losses. Margin requirements may change and positions may be reduced or closed when the account does not maintain required margin. A Copy Trader may lose all capital committed to relevant trading activity.

2.3 Stop-loss orders, hedging and other controls do not eliminate market risk and cannot guarantee execution at a requested price, especially during gaps, volatile periods or illiquid conditions.

3. Copy Execution and Divergence Risks

3.1 A copied order may be executed later than the Signal Provider’s order, at a different price, in a different volume, partially or not at all. Differences can result from spreads, slippage, latency, market liquidity, trading hours, margin availability, instrument restrictions and execution conditions.

3.2 Consequently, Copy Trader positions, unrealised exposure, fees under separately disclosed account terms and realised results may differ significantly from those of a Signal Provider or another follower. No identical result is guaranteed.

3.3 Changes in a Signal Provider’s strategy, trading intensity or risk appetite may affect existing and future copied positions. A decision to stop copying may not immediately cancel outstanding orders or close existing positions; open exposure may remain.

4. Signal Provider and Strategy Risks

4.1 Signal Providers act independently and can make poor, inconsistent or unexpectedly aggressive trading decisions. Their experience, judgment, incentives or circumstances can change.

4.2 KYC verification, experience assessment, public listing or platform review does not guarantee a Signal Provider’s competence, integrity, authorisation, suitability or future performance; nor does it remove any mandatory Company responsibility for its own service.

4.3 A Signal Provider, promoter or third party could make misleading claims, misrepresent experience, or conceal material facts. Copy Traders should use official disclosures and available account information, exercise independent judgment and promptly report suspected misconduct.

5. Technology, Security and Service Disruption

5.1 The Service relies on software, trading platforms, market data, networks, servers, connectivity and third-party infrastructure. Outages, configuration errors, cyberattacks, stale signals or service interruptions can delay, alter, prevent or interrupt copying and attempts to stop trading.

5.2 Account compromise through phishing, malicious software, lost devices or password sharing may lead to unauthorised access. Participants should protect credentials and promptly notify the Company of suspected security incidents.

5.3 The Company does not promise uninterrupted or error-free availability. This disclosure does not remove its duties to use appropriate care, handle incidents or comply with legal obligations applicable to its conduct.

6. Performance Information and No Guarantee

6.1 Historical, simulated or back-tested results, win rates, rankings, drawdown figures, risk scores and similar statistics can be affected by limited observation periods, market regimes, available data and presentation methodology.

6.2 Past performance is not a reliable indicator or guarantee of future results. Neither approval of a Signal Provider nor display of a Strategy is a guarantee of profit, capital preservation or an appropriate level of risk for a particular Copy Trader.

6.3 An intervention, restriction or removal by the Company is a compliance or risk-control measure and should not be interpreted as certification that any other Strategy is safe.

7. Material Conflicts of Interest

7.1 The Company, Signal Providers and third-party promoters may have business, referral or other economic interests that differ from those of Copy Traders. Such interests can influence how strategies are advertised, selected, ranked or traded.

7.2 Signal Providers are required under the Copy Trading Terms & Conditions to disclose material conflicts to the Company and cooperate with reasonable management measures. Where required by Applicable Law, material conflicts must be disclosed to affected clients in a fair and timely manner.

7.3 Copy Traders should not infer that a popular, promoted or prominently displayed Strategy is necessarily the most suitable or least risky. This Statement does not set or describe any fee formula or remuneration model.

8. Responsibility and Third-Party Conduct

8.1 The Copy Trader voluntarily chooses whether to follow a Strategy and bears ordinary market and execution risks, subject to binding account terms and any legal rights arising from wrongdoing by another party.

8.2 A Signal Provider bears responsibility for its own statements, unlawful promotion, fraudulent or materially misleading records, misuse of information and contractual breaches to the extent established by law. Disagreements about a Strategy’s performance do not, by themselves, prove wrongdoing.

8.3 The Company remains responsible for its own conduct, contractual promises and non-excludable statutory or regulatory obligations. Labeling a Signal Provider independent does not by itself determine whether a regulated activity occurs or exclude liability imposed by law.

9. Limits of Liability and Indemnities

9.1 Subject to Applicable Law and the Client Agreement, the Company makes no promise that copying will produce particular profits, identical trades, uninterrupted connectivity or successful execution in all market conditions.

9.2 The Copy Trading Terms & Conditions contain a limited Signal Provider indemnity for documented, reasonably incurred losses directly caused by specified misconduct. It does not transfer responsibility for the Company’s own wrongdoing or statutory obligations which cannot be passed on.

9.3 Nothing in this Statement excludes or limits liability for fraud, legally non-excludable negligence or misconduct, mandatory client protections or other liabilities that Applicable Law does not allow the parties to disclaim. Any contractual limit is subject to those requirements.

10. Exceptional Events and Force Majeure

10.1 Natural disasters, armed conflict, severe market disruptions, exchange closures, telecoms outages, infrastructure failures, major cyber incidents and binding regulatory directions may materially interrupt or impair the Service.

10.2 In an exceptional event, intended trading instructions may be delayed, rejected or executed under changed market conditions. The Company may take measures authorised by applicable agreements and law to protect systems, clients and market integrity.

10.3 An exceptional event does not automatically excuse a party from duties or liabilities that cannot lawfully be excluded, and it does not guarantee the immediate removal of market exposure.

11. Complaints, Legal Rights and Confirmation

11.1 Copy Traders may report concerns or lodge complaints through the Company’s published channels, including info@topwealthtrading.com unless superseded by an expressly notified complaint channel. Legitimate complaints will be considered on their merits under applicable procedures and laws.

11.2 This Statement is interpreted under the laws of the Republic of Vanuatu, subject to any mandatory rights, complaint routes or rules applying in other relevant jurisdictions. Nothing prevents a person from communicating with a competent regulator or exercising lawful remedies.

11.3 By choosing to use the Service, a Copy Trader acknowledges that copying trades entails material financial and operational risks, that copied results may diverge from a Signal Provider’s results, and that no Strategy’s future performance is assured.