Copy Trading Terms & Conditions

Copy Trading Terms & Conditions

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

1. Introduction, Scope and Acceptance

1.1 These Copy Trading Terms & Conditions (the “Terms”) govern access to the copy trading service (the “Service”) made available under the TopWealth Trading brand by Topwealth Trading Limited, a company incorporated in Vanuatu (the “Company”). References to the Company’s regulatory status shall be read subject to its current registration, licence conditions and applicable authorisations.

1.2 These Terms apply to each Copy Trader and Signal Provider participating in the Service. A person accepts them by giving an electronic acknowledgement or by using the Service following proper notice. The Company may retain evidence of acceptance and the version accepted.

1.3 These Terms supplement the applicable Client Agreement, trading terms, privacy notice and duly disclosed product documentation. In the event of inconsistency, mandatory law prevails; these Terms govern conduct specific to copy trading, while applicable account terms govern the underlying trading relationship. Nothing in these Terms specifies operational formulas, remuneration rates or settlement methods.

2. Definitions and Interpretation

2.1 “Copy Trader” means a Company client who elects to follow a Strategy through the Service. “Signal Provider” (also referred to as “Money Manager”) means a person separately approved by the Company to make trading activity or signals available for copying. “Strategy” means the trading approach or signals attributable to a Signal Provider.

2.2 “Applicable Law” means all laws, regulatory requirements and legally binding directions relevant to the Service or a party’s activities. “Materials” includes profiles, strategy descriptions, statistics, advertisements, documents, data and other information submitted or published in connection with the Service.

2.3 An approval, display or ranking is not a regulatory licence, endorsement or promise of profitability. References to written approval include verifiable electronic approval issued by an authorised Company representative.

3. Service Character and Copy Trader Authority

3.1 The Service permits an eligible Copy Trader voluntarily to select a Strategy and authorise the Company to act on relevant signals without seeking a separate instruction for each copied transaction, subject to the applicable account agreement and any controls actually provided by the Service.

3.2 The Copy Trader remains responsible for selecting and monitoring Strategies and for decisions to begin, continue or stop copying. The Company does not guarantee the suitability, availability, profitability or identical execution of any Strategy, and does not provide personalised advice merely by displaying strategies or related information.

3.3 A request to stop copying may not automatically close existing positions, cancel outstanding orders or immediately remove market exposure. Existing positions and obligations remain governed by the applicable account agreement and trading conditions.

3.4 Neither selection of a Strategy nor the above authorisation gives a Signal Provider any power to access a Copy Trader’s account credentials, receive, hold, transfer or withdraw Copy Trader funds, or issue payment instructions for a Copy Trader. The actual regulatory character of the Service depends on the activities performed and Applicable Law, not solely on contractual labels.

4. Eligibility, Application and Approval

4.1 Every participant must satisfy applicable eligibility, identity verification, anti-money laundering, sanctions screening and other onboarding requirements. The Company may request documentation reasonably necessary for compliance or risk assessment.

4.2 Before any Strategy is made available for copying, the Signal Provider must apply and receive the Company’s approval, submit complete and authentic KYC documents and, where relevant, ownership, beneficial-owner, control, address, experience and regulatory-status information.

4.3 The Company may request evidence of trading experience, suitability and any authorisation legally required for the Signal Provider’s actual activities. The Signal Provider is responsible for determining and maintaining permissions required in the jurisdictions in which it operates or promotes the Strategy.

4.4 The Company may reject, defer or condition approval, and may reassess eligibility at any time on reasonable compliance, conduct, security or risk grounds. The Company’s review does not certify a person’s skills, honesty or regulatory standing and does not relieve the Company of its own mandatory verification obligations.

5. Continuing Verification and KYC Integrity

5.1 Each Signal Provider warrants that all KYC and related information supplied is genuine, accurate, complete, current and lawfully obtained. Forged documents, identity impersonation, concealed controlling persons, material omissions and fraudulent or misleading submissions are prohibited.

5.2 A Signal Provider must promptly correct inaccurate records and report material changes to identity, ownership, control, relevant permissions, sanctions, restrictions, regulatory investigations or enforcement action where relevant to eligibility or lawful operation. It must cooperate with lawful follow-up checks and reasonable requests for supporting evidence.

5.3 A materially false, forged or misleading KYC submission constitutes a serious breach. The Signal Provider is responsible, to the extent permitted by law, for substantiated losses and reasonably incurred expenses directly caused by its breach, subject to the responsibility and indemnity provisions in these Terms. The Company retains its own statutory due-diligence responsibilities.

6. Independent Status and Provider Duties

6.1 A Signal Provider acts as an independent third-party trader. Admission to the Service does not itself create employment, agency, partnership, fiduciary appointment by the Company, or authority to speak or contract for the Company. Any separate relationship must be evidenced by an express written agreement.

6.2 The Signal Provider must act honestly, fairly and in good faith, refrain from misleading participants, maintain appropriate account security, monitor its Strategy and deal promptly with relevant compliance or security concerns.

6.3 The Signal Provider must notify the Company immediately on becoming aware of compromised credentials, unauthorised activity, a material signal error or other incident potentially affecting followers, and must cooperate in containment and investigation. It must not knowingly continue to publish compromised or deceptive signals.

6.4 The Signal Provider shall promptly disclose to the Company material conflicts of interest reasonably capable of affecting its conduct or disclosures to Copy Traders, and shall cooperate with proportionate conflict management and lawful disclosure requirements.

7. Prohibited Conduct and Information Accuracy

7.1 Participants must not engage in fraud, market manipulation, collusion, wash trading, artificial transaction volume, unauthorised access, deliberate interference with servers or trading systems, circumvention of security controls, or any other conduct prohibited by Applicable Law or account terms.

7.2 A Signal Provider must not trade primarily to manufacture commissions, rebates or incentives without a bona fide trading purpose; fabricate account history or performance; misrepresent ownership or control of a Strategy; conceal material adverse information; or encourage Copy Traders to send funds or account credentials to unauthorised third parties.

7.3 Each Signal Provider warrants that Materials it supplies are accurate in all material respects, not presented in a materially misleading way, lawfully usable and supported by records where appropriate. The Company may verify, correct, label, restrict or remove inaccurate Materials and require documentary substantiation.

7.4 The Company may investigate suspected coordinated misconduct involving a Signal Provider, Copy Trader or promoter, considering available records and relevant circumstances. No conclusion or remedy under this clause displaces mandatory procedural rights or legal obligations.

8. Copy Trader Obligations

8.1 The Copy Trader must independently assess the nature of a Strategy, applicable market risks, personal financial circumstances and capacity to absorb losses; review available disclosures; and monitor the account and relevant Company communications.

8.2 The Copy Trader must provide accurate KYC and account information, safeguard credentials, promptly report suspected unauthorised activity, and comply with lawful instructions and trading restrictions. The Copy Trader must not permit a Signal Provider to operate the account using shared credentials.

8.3 Past performance, a platform rating, provider approval or positive publicity does not guarantee future results. The Copy Trader must not assume that copied positions will match a Signal Provider’s positions or that ceasing to copy automatically disposes of existing exposure.

9. Marketing, Promotions and Intellectual Property

9.1 A Signal Provider may lawfully promote its own Strategy through social media, websites, communities and other channels, provided statements are fair, clear, verifiable, not misleading, and compliant with Company promotion standards and Applicable Law.

9.2 A Signal Provider must not guarantee profit, capital preservation or a fixed return; falsify or selectively present results in a materially misleading way; impersonate Company personnel; claim an endorsement not actually given; or make regulatory claims unsupported by evidence.

9.3 Use of the Company’s name, logo, trade marks, branded templates or copyrighted materials requires prior written permission, which may be limited or withdrawn. A Signal Provider may identify the platform accurately in ordinary factual statements where lawful, without implying official sponsorship.

9.4 The Signal Provider is responsible, to the extent permitted by law and consistent with its actual control, for promotional Materials distributed by persons it authorises or instructs. On notice of inaccurate or non-compliant Materials, it must promptly correct or remove them and cooperate in mitigating harm.

9.5 Upon suspension or termination, all promotional claims suggesting current approval or ongoing availability must cease promptly. Any continuing use of the Company’s brand must end when permission expires or is withdrawn.

10. Confidentiality, Privacy and Records

10.1 Participants must keep non-public account, client, trading and security information confidential and use it only for authorised Service purposes. A Signal Provider must not improperly access, disclose, sell, export or exploit Copy Trader personal information.

10.2 Personal data is handled under the applicable Privacy Policy and Applicable Law. Confidentiality obligations do not prevent lawful disclosure to regulators, courts, professional advisers or competent authorities, or lawful exercise of complaint rights.

10.3 Participants must preserve reasonably available records relevant to a notified complaint, compliance enquiry or suspected misconduct, subject to lawful retention and privacy requirements, and cooperate with reasonable requests for relevant information.

11. Oversight, Enforcement and Service Exit

11.1 Where reasonably warranted by suspected misconduct, sanctions, security events, material risk, regulatory requirements or breach of these Terms, the Company may require corrections, restrict promotional Materials, suspend public listing, prohibit new followers, suspend signal availability, restrict relevant accounts or terminate access, as permitted by Applicable Law and account terms.

11.2 The Company may act without advance notice where reasonably necessary to protect clients, systems or comply with law. Where lawful and practicable, the Company will give an explanation and a reasonable opportunity to provide relevant information or challenge factual errors; this does not guarantee restoration.

11.3 Suspension or termination of a Signal Provider does not necessarily close Copy Traders’ existing positions or extinguish accrued rights, transactions, liabilities or pending complaints. The applicable account terms govern existing trading exposure and any lawful restrictions.

11.4 Participants may discontinue participation subject to applicable account agreements and outstanding obligations. The Company may retain and disclose relevant records as required by law or reasonably needed to resolve disputes.

12. Complaints, Cooperation and Dispute Handling

12.1 Complaints concerning the Company’s Service may be submitted using the complaint channels published by the Company, including info@topwealthtrading.com, unless a more specific notified complaint address applies. Complaints will be considered on their facts and in accordance with applicable complaint-handling obligations.

12.2 A Signal Provider must reasonably cooperate in investigation of complaints relating to its actions, records or promotions and must not obstruct clients’ lawful complaint or regulatory rights. A trading loss alone does not establish wrongdoing, and an allegation alone does not establish liability.

12.3 Disputes between a Signal Provider and a Copy Trader do not automatically exclude possible Company responsibility for its own conduct. Each party’s liability depends on the evidence, applicable agreements and Applicable Law.

13. Responsibility, Indemnity and Mandatory Rights

13.1 Copy Traders bear the ordinary market consequences of their voluntary trading decisions, subject to applicable account terms and any liability established against another party. Signal Providers are accountable for their own unlawful conduct, material misrepresentations and contractual breaches. The Company remains accountable for its own breaches and non-excludable duties.

13.2 To the extent lawful, a Signal Provider shall indemnify the Company for documented, reasonably incurred third-party claims, losses and professional expenses to the extent directly caused by that Signal Provider’s fraud, forged or materially misleading KYC, unlawful promotion, unauthorised disclosure or other material breach. The indemnity does not extend to loss caused by the Company’s own fraud, wrongful conduct or liability that cannot legally be passed on.

13.3 No term excludes, restricts or waives fraud liability, mandatory regulatory duties, non-excludable consumer rights or any other obligation that Applicable Law does not permit to be excluded. No general disclaimer guarantees that the Company is immune from claims about the Service.

14. Amendments, Governing Law and Survival

14.1 The Company may amend these Terms for legitimate commercial, regulatory or operational reasons, giving notice in the manner and timeframe required by Applicable Law and the applicable account agreements. Changes do not retrospectively extinguish accrued rights or claims.

14.2 These Terms are governed by the laws of the Republic of Vanuatu, subject to mandatory rules and rights applicable in other relevant jurisdictions. Any jurisdiction or dispute-resolution provision in a binding Client Agreement applies only insofar as valid and consistent with mandatory law.

14.3 Provisions concerning confidentiality, records, accrued rights, valid indemnities, complaints, governing law and other obligations by their nature intended to continue survive suspension or termination to the extent lawful. Invalid provisions are severable without invalidating the remaining terms, where possible.