Introduction

This General Risk Disclosure Policy (hereinafter: the Policy) is provided to any Company’s Client and any Prospective Client (hereinafter: the Client) who is willing to enter into an agreement with the Company for opening a trading account with the Company, under the provisions of the Law as amended from time to time.

The Client must carefully read this Policy which is easily accessible on the Company’s website, www.adveniotrader.com, before deciding to open a trading account with the Company and before commencing any trading activity with the Company.

It is noted that this Policy found on the Company’s website cannot and does not disclose or explain all the risks and other significant aspects involved in dealing with Virtual Assets offered by the Company including, but not limited to, cryptocurrencies and derivatives with cryptocurrencies as underlying instruments (hereinafter: Virtual Asset(s)).

The Policy was designed to explain in general terms the nature of the risks involved when dealing in Virtual Assets on a fair and non-misleading basis, according to the Law. The Client should be aware of all the risks associated with Virtual Asset trading. If the Client has any doubts, he or she should seek advice and consultation from an independent financial advisor.  The Company does not provide such advice. If the Client does not understand the risks involved in trading in Virtual Assets, he or she should not trade at all.

Definition

“Crypto” A cryptocurrency is a digital or virtual currency secured by cryptography, which makes it nearly impossible to counterfeit or double-spend. Cryptocurrencies exist on decentralized networks that utilize blockchain technology—a distributed ledger secured by a network of computers.

Risk Warnings

The Client should not engage in any investment in Virtual Assets, directly or indirectly, unless he or she knows and understands the risks involved for each one of the Virtual Assets offered by the Company. Prior to applying for and opening an account with the Company the Client should consider carefully whether investing in specific Virtual Assets is suitable for him or her in the light of his or her personal circumstances and financial resources.

If the Client does not understand the risks involved, he or she should seek advice and consultation from an independent financial advisor. If the Client still does not understand the risks involved in the investment and trading with Virtual assets, he or she should not trade at all.

General Risks and Acknowledgements

The Client is warned of the following risks (the list is not exhaustive):

1. The Company does not and cannot guarantee that money deposited in the Client’s trading account for trading will not be lost as a result of his or her transactions.
2. The Client acknowledges that, regardless of any information which may be offered by the Company, the value of any investment in Virtual Assets may fluctuate downwards or upwards and it is even probable that the investment may become of no value.
3. The Client acknowledges that he or she runs a great risk of incurring losses and damages as a result of the purchase and/or sale of any Virtual Assets and accepts that he or she is willing to undertake this risk.
4. Information of the previous performance of Virtual Assets does not guarantee its current and/or future performance. The use of historical data does not constitute a binding or safe forecast as to the corresponding future performance of the Virtual Assets to which the said information refers.
5. Large losses may occur in a short period of time and may be equal to the total of funds deposited with the Company.
6. Some Virtual Assets may not become immediately liquid as a result of reduced demand, for example, and the Client may not be in a position to sell them or easily obtain information on the value of these Virtual assets or the extent of the associated risks.
7. When a Virtual Asset is traded in a currency other than the currency of the Client’s country of residence, any changes in the exchange rates may have a negative effect on its value, price and performance.
8. A Virtual Asset on foreign markets may entail risks different and/or greater to the usual risks of the markets in the Client’s country of residence. The prospect of profit or loss from transactions on foreign markets is also affected by exchange rate fluctuations.
9. A Virtual Asset may be a non-delivery spot transaction giving an opportunity to make profit on changes in currency rates, commodity, stock market indices or share prices, which is called the underlying instrument.
10. The value of the Virtual Asset may be directly affected by the price of the security or any other underlying asset which is the object of the acquisition.
11. The Client must not purchase a Virtual Asset unless he is willing to undertake the risks of losing entirely all the money which he or she has invested, and any additional commissions and other expenses incurred.
12. Under certain market conditions (for example but not limited to the following situations: force majeure event, technical failure, communications network failure, poor or no liquidity, market news or announcements etc.) it may be difficult or impossible to execute an order.
13. If the Client enters a market or limit order based on current price he or she sees on the screen, it may not be possible to execute the order at that price, because market conditions might unexpectedly quickly change between the time he or she submits the order, and the time the order reaches the place of execution.
14. Placing Stop Loss Orders serves to limit Client losses but does not guarantee execution price. Thus, under certain market conditions the execution of a Stop Loss Order may be worse than its stipulated price and the realized losses can be larger than expected.
15. Should the Equity of the Client be insufficient to hold current positions open, the Client may be called upon to deposit additional funds at short notice or reduce exposure. Failure to do so within the time specified may result in liquidation of positions at a loss and he will be liable for any resulting deficit.
16. Trading on-line, no matter how convenient or efficient, does not necessarily reduce risks associated with Virtual Asset trading.
17. There is a risk that the Client’s trades in Virtual Assets may be or become subject to tax and/or any other duty because of changes in legislation and/or his or her personal circumstances. The Company does not warrant that no tax and/or any other stamp duty will be payable. The Client acknowledges that he or she is solely responsible for any taxes and/or any other duty which may accrue in respect of his or her trades.
18. Before the Client begins trading, he or she should obtain details of all fees and other charges for which the Client will be liable. If any charges are not expressed in money terms (but for example as a dealing spread), the Client should ask for an explanation, including appropriate examples, to establish what such charges are likely to mean in specific money terms.
19. The Company will not provide the Client with investment advice relating to investments or possible transactions in investments or make investment recommendations of any kind.
20. There may be situations, movements and/or conditions occurring at the weekend, at the beginning of the week or intra-day after the release of significant macroeconomic figures, economic or political news that make markets to open with price levels that substantially differ from previous prices. In this case, there exists a significant risk that orders issued to protect open positions and open new positions may be executed at prices significantly different from those designated
21. Due to the complexity and the high risk involved in Virtual Asset trading the Clients are faced with high risk of losing all of their invested capital.
22. Trading with Virtual Assets is not appropriate for all Clients; Clients should possess the necessary knowledge and expertise in this specific product and must be aware and understand the specific characteristics and risks involved with Virtual Asset trading.

Third Party Risks

The Company may pass money received from the Client to a third party (i.e., a bank or a trading venue) to hold or control, to execute a Transaction through or with that person, or to satisfy the Client’s obligation to provide collateral (i.e. initial margin requirement) in respect of a Transaction. The Company has no responsibility for any acts or omissions of any third party to which it will pass money received from the Client.

The third party to which the Company will pass money may hold it in an omnibus account and it may not be possible to separate it from the Client’s money, or the third party’s money. In the event of insolvency or any other analogous proceedings in relation to that third party, the Company may only have an unsecured claim against the third party on behalf of the Client, and the Client will be exposed to the risk that the money received by the Company from the third party is insufficient to satisfy the claims of the Client with claims in respect of the relevant account. The Company does not accept any liability or responsibility for any resulting losses.

A Company or Bank or Broker through which the Company may deal with could have interests contrary to the Client’s interests.

The insolvency of the Company or of a Bank or Broker used by the Company to execute its transactions may lead to the Client’s positions being closed out against his or her wishes.

Trading Platform Risks

Clients, who undertake trading transactions on an electronic trading platform (hereinafter: the Platform), will be exposed to risks associated with the system including the failure of hardware and software (Internet/Servers). The result of any system failure may be that an order is either not executed according to the instructions provided for it or is not executed at all. The Company does not accept any liability in the case of such a failure. The use of wireless connections or dial-up connections, or any other form of unstable connection at the client’s end, may result in poor or interrupted connectivity or lack of signal strength causing delays in the transmission of data between the Client and Company, when using the Platform. Such delays or disturbances may result in the Client sending to the Company out of date ‘Market Orders’. In these circumstances, the price will be updated and the order executed at the best available ‘market price’.

The Client acknowledges that when an Order is closed or being executed, it may not be cancelled or modified.

The Client may lose all amounts he or she has deposited with the Company as a margin. The placing of certain orders available on the Platform (i.e. “stop-loss” or “limit” orders) that are intended to limit losses to certain amounts may not always be effective because market conditions or technological limitations may make it impossible to execute such orders. It should be noted that for all orders (including guaranteed stop loss orders) the Client may sustain the loss (which Client’s order is intended to limit) in a short period of time.

Technical Risks

The Client and not the Company shall be responsible for the risks of financial losses caused by failure, malfunction, interruption, disconnection or malicious actions of information, communication, electricity, electronic or other systems.

The Company has no responsibility if authorised third persons have access to information, including electronic addresses, electronic communication and personal data, access data when the above are transmitted between the Company or any other party, using the internet or other network communication facilities, telephone, or any other electronic means.

The Client acknowledges that the unencrypted information transmitted by e-mail is not protected from any unauthorised access.

The Client acknowledges that the internet may be subject to events which may affect his access to the Company’s website and/or the Platform, including but not limited to interruptions or transmission blackouts, software and hardware failure, internet disconnection, public electricity network failures or hacker attacks. The Company is not responsible for any damages or losses resulting from such events which are beyond its control or for any other losses, costs, liabilities, or expenses (including, without limitation, loss of profit) which may result from the Client’s inability to access the Company’s Website and/or the Platform or delay or failure in sending orders or Transactions.

The Client is warned that when trading in the Platform he or she assumes risk of financial loss which may be a consequence of amongst other things:

1. Failure of Client’s devices, software and poor connection quality.
2. The Company’s, third party’s or Client’s hardware or software failure, malfunction or misuse.
3. Improper work of Client’s equipment.
4. Wrong setting of Client’s software.
5. Delayed updates of Client’s software.
6. The Client not safeguarding, or sharing with others or third parties, his or her access credentials (including, but not limited to, password and/or PIN).

In connection with the use of computer equipment and data and voice communication networks, the Client bears the following risks amongst other risks in which cases the Company has no liability of any resulting loss:

1. Power cut of the equipment on the side of the Client or the provider, or communication operator (including voice communication) that serves the Client.
2. Physical damage (or destruction) of the communication channels used to link the Client and provider (communication operator), provider, and the trading or information server of the Client.
3. Outage (unacceptably low quality) of communication via the channels used by the Client, or the channels used by the provider, or communication operator (including voice communication) that are used by the Client.
4. Settings of the Client software that are wrong or inconsistent with requirements.
5. When carrying out transactions via the telephone (land or cell phone lines) voice communication, the Client runs the risk of problematic dialing, when trying to reach an employee of the Company due to communication quality issues and communication channel loads.
6. The use of communication channels, hardware and software, generate the risk of non- reception of a message (including text messages) by the Client from the Company.

Risks Particularly Associated with Transactions in Virtual Assets:

Leverage

Investing in some Virtual assets entails the use of “gearing” or “leverage”. In considering whether to engage in this form of investment, the Client should be aware that the high degree of “gearing” or “leverage” is a particular feature of Derivative Virtual assets.

This stems from the margining system applicable to such trades, which generally involves a comparatively modest deposit or margin in terms of the overall contract value, so that a relatively small movement in the underlying market can have a disproportionately dramatic effect on the Client’s trade. If the underlying market movement is in the Client’s favour, the Client may achieve a good profit, but an equally small adverse market movement can quickly result in the loss of the Clients’ entire deposit and may also expose the Client to a large additional loss. The Client must be familiar with all aspects of trading with Virtual Assets, and not purchase Virtual Assets unless he or she is willing to undertake the risks of losing entirely all the money which he or she has invested and also any additional commissions and/or other expenses incurred.

Transactions may not be undertaken on a recognised or designated investment exchange and, accordingly, they may expose the Client to greater risks than exchange transactions. The Client may only be able to close an open position of any given financial instrument during the opening hours of the Execution Venue. The Client may also have to close any position with the same counterparty with which it was originally entered into.

The Client fully acknowledges and accepts that, regardless of any information which may be offered by the Company, the value of the Virtual Assets may fluctuate downwards or upwards and it is not unlikely that the investment may become of no value. This is due to the high degree price fluctuations, but also due to high degree of “gearing” or “leverage” feature of Virtual Asset derivatives. This stems from the margining system applicable to such trades, which generally involves a comparatively modest deposit or margin in terms of the overall financial instrument position value, so that a relatively small movement in the underlying market can have a disproportionately dramatic effect on Client’s trades.

Volatility of price and limitation on the available market

Virtual Assets and the relevant markets can be highly volatile. The prices of cryptocurrencies and the underlying assets of cryptocurrency derivatives may be volatile and unpredictable and may fluctuate rapidly and over wide ranges and may reflect unforeseeable events or changes in conditions, none of which can be controlled by the Company or the Client. Those movements will affect the Virtual Asset prices, whether or not the Client can open or close a position and the price at which the Client wished to do so. So, under certain market conditions, it may be impossible to execute any type of Order at the declared price. Therefore, even ‘stop-loss orders’, whereby the Client’s trade will be executed only when the Virtual Asset the Client wants to buy or sell reaches a particular price (the stop price), cannot guarantee the limit of loss. ‘Stop-loss orders’ are not guaranteed to be filled at the price Client states. Once the ‘stop-loss orders’ has been triggered, it turns into a market order, which is filled at the best possible price. This fill (execution) price may be very different than the price specified by the ‘stop-loss order’.

The prices of Virtual Assets may be influenced by, amongst other things, changing supply and demand relationships, governmental, agricultural, commercial and trade programs and policies, national and international political and economic events and the prevailing psychological characteristics of the relevant marketplace.

Some of the Virtual Assets may not become immediately liquid as a result of reduced demand for the underlying instrument and Client may not be able to obtain the information on the value of these or the extent of the associated risks.

Trading in Virtual Assets is speculative and involves a high degree of risk. In particular if it is conducted using a margin (which covers only a small percentage of the value of the underlying asset being traded), as such, even small price changes in the Virtual Assets can result in significant losses. The Client should be aware that by trading with Virtual Assets on margin, the Client may lose the margin held at the Company that serves for the purposes of collateral for opening and maintaining Client’s trading positions.

Transactions in the Virtual Assets provided by the Company are not undertaken on an organized exchange, rather they are undertaken through the Platform that may be operated by a third party and, accordingly, such transactions may expose Client to greater risks than regulated exchange transactions. In that case the terms and conditions and trading rules are established solely by the third party. The Client may be obliged to close an open position of any given Virtual Asset during the opening hours of the Platform.

Total Loss might exceed the Initial Amount

The Client acknowledges and understands that risk of loss arising from trading in Virtual Assets can be substantial and the Client might lose more than the Initial Amount and any additional amounts, including the Margin Requirement. While Virtual Asset trading on margin typically only requires depositing a small percentage of the total trade volume (the Margin Requirement), profits and losses can quickly exceed the Margin Requirement, requiring the Margin Requirement to be adjusted at much higher than the initial amount.

Margin requirements

The Client should be aware of the implications of transactions with Virtual Assets on margin and Virtual Asset derivatives, and in particular the specific margin requirements which are applied thereto. The Client is required to deposit funds in his or her trading account in order to open a position and the funds should reflect the specific margin required. The Client shall be informed (i.e. seek information) about specific Margin requirement for each individual account before he or she begins trading; such information is available to the Client upon completion of the necessary information required by the Company to approve him as a Client of the Company.

Margin requirements will depend on the underlying Virtual Asset, with level of leverage chosen and the value of position to be established.

The Company will not notify the Client of any ‘Margin Call’ to sustain a loss-making position.

Review

The Company reserves the right to review and/or amend its Policy, at its sole discretion, whenever it deems necessary, without prior notice to the Client.

This Policy cannot and does not disclose or explain all the risks and other significant aspects involved in dealing in all Virtual assets and investment services. This Policy was designed to explain in general terms the nature of the risks involved when dealing in Virtual Assets on a fair and non-misleading basis.

Client Declaration

The Client hereby acknowledges, confirms and accept that by entering into an Agreement with the Company and every time he decides to place an Order in a Virtual Asset, that he or she runs a high risk of incurring losses and damages as a result and declares that he is willing to proceed with this kind of trading and undertakes such risks.

WARNING: It is emphasized that dealings in Virtual Assets are not appropriate for all Clients. The Client should not engage in any dealings in Virtual Asset, directly or indirectly, unless he or she knows and understands the features and risks involved in them and that he or she may lose entirely all his money and may also be imposed extra charges.