MARKETING COMPLIANCE PROCEDURES AND POLICIES MANUAL

AAA Trade Ltd., European Investment Firm & Liquidity Provider Address: Victory House,1 st Floor, 205, Archbishop Makarios Avenue, 3030, Limassol Phone: +357 25 030 060, Fax: +357 25 253 093 Email: office@aaatrade.com W: www.aaatrade.com MARKETING COMPLIANCE PROCEDURES AND POLICIES MANUAL V3 AAA Trade Ltd., is a Cyprus Investment Firm (CIF) supervised and regulated by the Cyprus Securities and Exchange Commission (CySEC) with CIF License number 244/14

Page 2 TABLE OF CONTENTS 1. SCOPE OF POLICY AND BASIC PRINCIPLES....4 1.1. Obligation for Compliance 1.2. Statutory Framework and Guidance..4 2. MARKETING RULES..5 2.1. General Rules.5 2.2. Risk Warnings.5 2.3. Contracts for Differences 6 2.4. Financial Success..6 2.5. Past Performance.8 2.5.1. Indication of Past Performance.8 2.5.2. Simulated Past Performance 8 2.6. Absolute Statements..9 2.7. Use of the Word Free...9 2.8. Restricted Audience..10 3. AFFILIATES AND INTRODUCING BROKERS.10 4. MARKETING MATERIAL APPROVAL PROCEDURE.11 4.1. Procedure.11 4.2. Common Reasons for Rejection 12 5. MONITORING..13 6. EDUCATION AND TRAINING OF EMPLOYEES 13 7. FAILURE TO COMPLY..13

Page 3 1. SCOPE OF POLICY AND BASIC PRINCIPLES AAA Trade Ltd ( Company ) is a European Investment Firm, authorized and regulated by the Cyprus Securities and Exchange Commission ("CySEC"). It is the Company s policy that all marketing, advertising and sales materials, promotions and communication ( Marketing Communication ) be truthful, accurate and approved by the Company s Compliance Department. The Company prohibits Marketing Communication which is inaccurate, misleading, deceptive, or otherwise not in compliance with the Company s procedures, policies, basic principles and relevant legislation and regulations. This Marketing Compliance Procedures and Policies Manual ( Manual ) was created and implemented with the goal of protecting the interests of the Company s Clients, and ensuring that the Company conducts its business in full compliance with all with the Company s procedures, policies, basic principles and relevant legislation and regulations. (The term Clients within the context of this Manual shall mean any person, whether natural, with whom the Company has entered into a business relationship, and shall also include prospective clients and any person to whom Marketing Materials are directed.) This Manual, and the policies and procedures contained herein, applies to all Employees of the Company as well as the Company s Affiliates and Introducing Brokers and any other person, whether natural or legal, who disseminates Marketing Materials on behalf of the Company. This Manual is revised and updated as necessary with the purpose of ensuring that the Company has in place at all times the most updated, compliant and effective procedures and policies. 1.1. Obligation for Compliance The Company recognizes, accepts, and has incorporated into its culture, the obligation as a licensed European Investment firm to comply fully with the all relevant legislation and regulation, including with respect to Marketing Materials. 1.2. Statutory Framework and Guidance The Company conducts its business in conformity with all relevant legislation, regulations and guidance offered by relevant bodies, particularly with respect to guidance offered by CySEC. Information addressed to Clients including marketing communication, or Marketing Materials, for Cyprus Investment Firms ( CIFs ) are under: a. The provisions of Section 36(1)(a) of the Investment Services and Activities and Regulated Markets Law of 2007, as in force ('the Law'); and b. of paragraph 6(2) 6(8) of the Directive DI144-2007-02 of 2012 for the Professional Competence of Investment Firms and the Natural Persons employed by them ( the Directive ).

Page 4 2. MARKETING RULES 2.1. General Rules In general, and at all times, all Marketing Material must be disseminated to Clients in a fair and transparent way which seeks to avoid misguiding Clients as follows: a. the name of the Company shall be included in any Marketing Material; b. when referring to the Company include the following statement (or similar statement specifically provided to you by the Company): AAA Trade Ltd. is authorised and regulated by the Cyprus Securities and Exchange Commission (License No. 244/14). c. shall be accurate, clear and presented in a way to be understood by the average member of the group to whom the Marketing Material is directed; d. shall indicate risks associated with benefits; e. shall not: i. emphasize any potential benefits without also giving a fair and prominent indication of associated risks; ii. disguise, diminish or obscure important items, statements or warnings; iii. give advice to the clients or offer opinions (unless disseminated by a person licensed and authorized to do so an approved by the Company); iv. mention bonuses as the Company does not offer bonuses; v. state that there are no fees as certain fees may apply; vi. encourage Clients to deposit beyond their economic profile; vii. place psychological pressure on the clients. The Company reserves the right to revise the required risk warning at any time, at its sole discretion. 2.2. Risk Warnings in General All statements must be balanced. When describing a potential benefit, the relevant risk must also be stated in a clear manner. In publications, a risk warning approved by the Company must be included in a prominent manner as follows: a. All financial promotions must include the risk warning: Trading is risky and your entire capital might be at risk. b. If the context of the promotion elaborates on CFDs/leverage the following risk warning must apply: CFDs are leveraged products and you might lose your entire capital. c. Risk warning should be prominent (for example, in bold print, prominently placed, and not in small print or hidden in any way). d. For a website in a language other than English, the risk warning must be translated accordingly.

Page 5 2.3. Contracts for Differences ( CFDs ) CFDs trading is a regulated activity and consequently promotional content must be fair, clear, not misleading, and must comply with all related requirements mentioned in this Manual. The risk warning shall be as follows: Risk Warning: Trading leveraged products such as CFDs involves substantial risk of loss and may not be suitable for all investors. Trading such products is risky and you may lose all of your invested capital. When advertising CFDs on Forex/Commodities/Indices/Stocks/Bonds always mention that those are traded through CFDs. This can be mentioned in the body of the material or alternatively include the sentence "CFDs Services" next to the Risk Disclaimer. Do not say "trade the stock market", "access to the stock market" and "stock broker" without mentioning that this is through CFDs, as this could be misleading. Examples: "Trade Facebook shares with AAA Trade" (include nearby or indicate an asterisk that the trading is through CFDs) "AAA Trade offers CFD trading in Shares, Forex, Indices and Commodities "Trade Shares, Forex, Indices, Commodities with AAA Trade" "Forex CFD trading with AAA Trade" "Forex trading with AAA Trade" (include nearby or indicate an asterisk that the trading is through CFDs) "Trade through CFDs: Forex, Commodities Indices, Stocks, Bonds" "Trade Forex, Commodities Indices, Stocks, Bonds*" Trade Facebook shares with AAA Trade without indicating anywhere that the trading is through CFDs 2.4. Financial Success Promising financial success, whether implied or explicit, is prohibited. Specifically, note the following non-exhaustive guidance: a. do not promise profits; b. Do not make unwarranted claims of success by other traders or yourself; c. do not promise that one can learn trading easily or profitably unless the word learn is connected

Page 6 with the demo mode or the platform usage; d. do not use the word "play" or game even when the advertisement/promotional material is related to demo mode/ practice mode, as the word play or game implies that our services even the demo service is a game, thereby undermining risks involved. Examples: "Easy learning platform" "Simple platform tools" "Easy to use platform" "Easy to navigate platform" "Intuitive platform" "User-friendly platform" "Easy profits with AAA Trade" "Easy and simple trading", "Trading the world's most popular financial instruments is easy" "Guaranteed profits by trading with AAA Trade platform" "Practice trading using AAA Trade's unlimited demo account" "Get to know trading using your AAA Trade free demo account" "Learn how to use the platform by trading in the AAA Trade demo mode" "Learn trading with AAATrade platform" "Learn how to become profitable trader using AAATrade CFDs service" "Trading is simple to learn with AAATrade" "You can learn to trade using a demo account on the AAATrade platform and start trading forex anywhere, anytime" "Start learning currency trading, and profit anywhere and anytime 24/5. "Trade Forex CFDs on the user friendly AAATrade trading platform using plenty of risk management tools" "Trading Forex can be simple, even for beginners"

Page 7 2.5. Past Performance 2.5.1. Indication of Past Performance Where the information contains an indication of past performance of a financial instrument, a financial index or an investment service, the following conditions shall be satisfied: a. Indication must not be the most prominent feature of the communication; b. The information must include: i. appropriate performance information which covers the immediately preceding five years; or ii. iii. iv. the whole period for which the financial instrument has been offered, the financial index has been established, or The investment service has been provided if less than five years, or Such longer period as the firm may decide, and in every case that performance information must be based on complete 12-month periods c. The reference period and the source of information must be clearly stated; d. The information must contain a prominent warning that the figures refer to the past and that past performance is not a reliable indicator of future results; e. Where the indication relies on figures denominated in a currency other than that of the Member State in which the retail client or potential retail client is resident, the currency must be clearly stated, together with a warning that the return may increase or decrease as a result of currency fluctuations; f. Where the indication is based on gross performance, the effect of commissions, fees or other charges must be disclosed. 2.5.2. Simulated Past Performance Where the information includes or refers to simulated past performance, it must relate to a financial instrument or a financial index, and the following conditions shall be satisfied: a. The simulated past performance must be based on the actual past performance of one or more financial instruments or financial indices which are the same as, or underlie, the financial instrument concerned; b. The information must contain a prominent warning that the figures refer to simulated past

performance and that past performance is not a reliable indicator of future performance. 2.6. Absolute Statements Page 8 An absolute statement is a statement which states something which is not relative or comparable, but which is absolute. The following words are examples of absolute adjectives best top first and may only be used Marketing Material if such claims may be supported by objective fact, i.e. the Company has won an award stating that it is the best investment firm in Cyprus. Unqualified, absolute statements and unwarranted claims are prohibited. Examples: One of the top investment firms One of the leading platforms A leading CFD provider A top CFD provider Number one CFD provider Best platform Best CFD Provider 2.7. Use of the Word Free The Company is aware and cautious on how to use the word free as this may encourage the Client to focus more on the word rather than on the entire meaning of the sentence. a. The word "free" may be used in relation to the demo mode, the software, the platform, the charts; b. The word "free" shall not be used in relation to trading or risk. Examples: "The demo mode is free of risk" Don't say: "Risk free trading"

Page 9 "Free download of the platform", "Free software to use for trading CFDs with AAA Trade" "Free live streaming charts and quotes in the AAA Trade platform" "All in one package for free trading with AAA Trade" 2.8. Restricted Audience Marketing shall not be directed to prohibited audiences, which include at minimum the following: a. persons who are under the age of 18 years; b. residents of Canada and United States of America, due to Domestic Regulations of Canada and USA; c. residents of any jurisdictions where such services are prohibited due to the domestic regulations of the jurisdictions; d. residents of countries considered high risk for money laundering and terrorist financing, including Afghanistan, Bosnia and Herzegovina, Democratic People s Republic of Korea, Iran, Iraq, Lao People's Democratic Republic, Syria, Uganda, and Vanuatu. This list is updated according with international standards. 3. AFFILIATES AND INTRODUCING BROKERS Affiliates and Introducing Brokers shall only promote the Company as follows: a. use of the Company s official marketing tools which are provided by the Company and which include the relevant warnings and risk disclosures; b. do not remove or alter risk warnings; c. where an Open Account or Sign Up or Register option or other invitation users to open an account with AAATrade, then a risk warning must be present close to such buttons; d. do not promote the Company by way of Marketing Materials that have not approved by the Company to promote the Company through search engines, social media networks, ad-networks, marketing-emails or any other manner. e. only promote the Company through websites or other sources which have expressly been approved by the Company in accordance with this Manual, Section 4, and Marketing Material Approval Procedure;

Page 10 f. In the event the Compliance Department does not approve the Marketing Material, it may not be used to promote the Company in any way. g. only promote the Company in association with materials or mediums which offer information on trading, financial markets or similar services; h. do not promote the Company in association with materials or mediums referencing in any way pornography, violence, offensive language, or political ideology or other potentially controversial topics; In the event the Affiliate or Introducing Broker wishes to use Marketing Material to promote the Company which have not been approved by the Compliance Department of the Company, the Affiliate or Introducing Broker shall submit the Marketing Material for Approval in accordance with this Manual, Section 4, and Marketing Material Approval Procedure. In the event the Compliance Department does not approve the Marketing Material, it may not be used to promote the Company in any way. The Company will block traffic it receives from unapproved sources and take appropriate action. 4. MARKETING MATERIAL APPROVAL PROCEDURE 4.1. Approval Procedure All Marketing Material are subject to the approval process of the Compliance Department of the Company in accordance with this section, which may be amended from time to time, or specifically revised in writing on a case by case basis, at the sole discretion of the Company. a. Marketing Material must be approved by the Compliance Department of the Company by email to compliance@aaatrade.com with a description of the proposed use of the Marketing Material. b. Name each file submitted for approval as follows: type of Marketing Material date of submission as in the examples below. Add unique numbering if necessary to differentiate between similar materials submitted on the same date. i. GoogleAdWords_02.16.2017 ii. Website Banners(1)_02.15.2017 iii. Website Banners(2)_02.15.2017 c. Marketing guidance or training materials shall be designated by versions: V1, V2, etc. with date of versions contained therein as follows or similar: d. Marketing materials shall be submitted and in an editable format, where possible, as an attachment to the email. e. Compliance will correspond by email with any comments.

Page 11 f. Compliance will approve Marketing Materials by providing a scan of the approved version with a stamp, date and signature of responsible person. If the type of the Marketing Material is not amenable to such a procedure, the Compliance Department of the Company will arrange a reasonable alternative for approval. g. The Compliance Department will review Marketing Material as quickly as possible. However, for maximum efficiency, prepare and submit Marketing Materials for a campaign at once so that approved Marketing Materials are on hand. h. Implement the Marketing Material only in the version approved by Compliance. i. The Compliance Department of the Company reserves the right to retroactively reject any previously approved Marketing Material in writing. Any such Marketing Material must be removed or revised in accordance with Company instructions. 4.2. Reasons for Rejection The Company rejects Marketing Material which does not comply with this Manual. The Company reserves the right to reject Marketing Material at any time, for any reason, at its sole discretion. Examples of reasons for rejection are listed below, though this list is non-exhaustive: a. untrue, inaccurate, misleading; b. does not contain the appropriate risk disclaimer regarding associated risks; c. risk disclaimer is improperly displayed (i.e. not prominent); d. fails to refer to the Company s Terms and Conditions apply where such omission may be misleading (i.e. the Marketing Material contains a term that must be qualified by the Terms and Conditions); e. includes an unfair comparison (i.e Forex and Binary Options); f. unclear regarding CFDs (i.e a statement to trade gold or otherwise that is without the appropriate disclaimer indicating that the trading referred to is trading through CFDs); g. does not fit with the Company s general design guidelines, branding and image. 5. MONITORING The Company is obligated to monitor the use and dissemination of Marketing Material. Therefore, all Marketing Material, in any medium, must be immediately made available to the Company upon the Company s demand. The Company reserves the right to demand revision or removal of any Marketing

Page 12 Material, at its sole discretion. 5.1. Telephone and other Audio or Sales Promotions The scope of this Manual includes telephone and other audio or sales promotions, which are subject to the procedures and policies contained herein. The Company shall monitor telephone and other audio or sales promotions in any manner it deems fit, including, but not limited to, listening to live or recorded audio or sales promotions, on a regular and on-going basis. 6. EDUCATION AND TRAINING OF STAFF The Company, Affiliates and Introducing Brokers shall ensure that all persons involved in marketing shall at all times be fully trained and competent for the performance of marketing in compliance with this Manual and all relevant legislation and regulations. 7. FAILURE TO COMPLY All employees of the Company, and its Affiliates and Introducing Brokers are required to comply with this Manual and all legislation and regulations. The Company reserves the right at its sole discretion to terminate any agreement, without prejudice, for any violation herein as it deems fit.