Client Categorization Policy

1. Introduction

ZenGuard Markets Ltd is required under the Markets in Financial Instruments Directive II (MiFID II) and the UK Financial Conduct Authority (FCA) Conduct of Business Sourcebook (COBS) to classify all clients into one of three categories: Retail Client, Professional Client, or Eligible Counterparty. This classification determines the level of regulatory protection and the nature of services you receive from us.

This Client Categorization Policy sets out how ZenGuard Markets Ltd categorizes clients, the criteria for each category, and the procedures for requesting re-categorization. It is essential that you read and understand this policy, as your categorization affects your rights and the protections available to you under applicable regulations.

2. Client Categories

Retail Clients receive the highest level of regulatory protection. ZenGuard Markets Ltd must provide retail clients with enhanced disclosure, suitability assessments, best execution obligations, and access to the Financial Ombudsman Service and Financial Services Compensation Scheme where applicable.

Professional Clients are presumed to possess the experience, knowledge, and expertise to make their own investment decisions and to assess the risks involved. They receive a lower level of regulatory protection than retail clients, including reduced disclosure requirements and limited access to certain redress mechanisms.

Eligible Counterparties are entities such as investment firms, credit institutions, insurance companies, pension funds, and other institutional investors. They receive the lowest level of regulatory protection and are typically not entitled to the same conduct of business rules that apply to retail and professional clients.

3. Default Categorization

Unless you meet the criteria for Professional Client or Eligible Counterparty status, you will be classified as a Retail Client by default. This default categorization ensures that all clients receive the maximum level of investor protection until and unless they expressly opt for a different classification and satisfy the relevant criteria.

ZenGuard Markets Ltd will assess your categorization at the point of account opening based on the information you provide and any documentation you submit. We may request additional information or documentation to verify your eligibility for Professional Client or Eligible Counterparty status. Your categorization will be confirmed in writing at the time your account is opened.

4. Retail Client Protections

As a Retail Client of ZenGuard Markets Ltd, you are entitled to comprehensive protections under MiFID II and FCA rules. These include the provision of a Key Information Document (KID) for each product we offer, a suitability or appropriateness assessment before we provide investment advice or execute orders on complex instruments, best execution obligations when we execute orders on your behalf, and clear disclosure of all costs, charges, and conflicts of interest.

Retail clients also have access to the Financial Ombudsman Service for the resolution of complaints and may be eligible for compensation under the Financial Services Compensation Scheme in the event of our insolvency. We are required to provide you with periodic statements, confirmations of transactions, and information about the performance of your investments.

5. Professional Client Criteria (Per Se)

Certain entities are automatically classified as Professional Clients under MiFID II. These per se professional clients include entities required to be authorized or regulated to operate in the financial markets (such as credit institutions, investment firms, insurance companies, and pension funds), large undertakings meeting two of the following criteria: balance sheet total exceeding EUR 20 million, net turnover exceeding EUR 40 million, or own funds exceeding EUR 2 million, national and regional governments, central banks, and international and supranational institutions.

If you fall within one of these categories, you will be classified as a Professional Client unless you request to be treated as a Retail Client. ZenGuard Markets Ltd will verify your status through appropriate documentation before applying this classification.

6. Professional Client Criteria (Elective)

Individuals and entities that do not qualify as per se professional clients may request to be treated as Professional Clients on an elective basis. To qualify, you must meet at least two of the following criteria: you have carried out transactions of a significant size on the relevant market at an average frequency of 10 per quarter over the previous four quarters, the size of your financial instrument portfolio exceeds EUR 500,000, you work or have worked for at least one year in the financial sector in a professional position that requires knowledge of the transactions or services envisaged.

ZenGuard Markets Ltd will assess your application against these criteria and may request supporting documentation. We will provide you with a clear warning of the protections you will lose and obtain your written acknowledgment before re-categorizing you as a Professional Client. The elective professional client classification applies only to the services or transactions for which you qualify.

7. Requesting Re-categorization

If you believe you qualify for a different client category, you may submit a written request to ZenGuard Markets Ltd. Your request should include your full name, account number, the category you are requesting, and supporting documentation demonstrating that you meet the relevant criteria. Requests for Professional Client status should be sent to compliance@zenguardmarkets.com.

We will acknowledge your request within five business days and will provide a written decision within a reasonable timeframe. If we approve your request, we will confirm the new categorization in writing and explain the implications. If we decline your request, we will provide reasons for our decision. You may request re-categorization at any time, and we will review your categorization periodically or upon material changes to your circumstances.

8. Consequences of Re-categorization

If you are re-categorized from Retail Client to Professional Client, you will lose certain regulatory protections. These include reduced disclosure requirements, no obligation on ZenGuard Markets Ltd to conduct a suitability assessment for non-advised services, limited best execution reporting, and potentially no access to the Financial Ombudsman Service for certain types of complaints. You will also receive less detailed information about the risks of products and the costs of our services.

Re-categorization to Eligible Counterparty status results in the loss of most conduct of business protections. We strongly recommend that you seek independent legal or financial advice before requesting re-categorization to a lower protection category. You may request to be re-categorized as a Retail Client at any time, and we will process such requests promptly.

9. Ongoing Obligations

ZenGuard Markets Ltd has ongoing obligations to ensure that client categorizations remain appropriate. We will review your categorization if we become aware of material changes to your circumstances that may affect your classification. We may also conduct periodic reviews of client categorizations as part of our compliance monitoring.

If we determine that your categorization is no longer appropriate, we will notify you in writing and may re-categorize you accordingly. We will give you reasonable notice of any such change and explain the implications. You will have the opportunity to provide additional information or to request a different categorization before any change takes effect.

10. Review and Updates

This Client Categorization Policy is reviewed at least annually by ZenGuard Markets Ltd to ensure it remains accurate and compliant with applicable regulations. We will update this policy when there are material changes to MiFID II, FCA rules, or our internal procedures.

Any material changes to this policy will be communicated to clients through our website and, where appropriate, by email. The updated policy will be effective from the date specified in the notice. We encourage you to review this policy periodically to ensure you understand your rights and our obligations.

11. Contact

If you have any questions about this Client Categorization Policy or wish to request re-categorization, please contact us:

ZenGuard Markets Ltd Compliance Department Email: compliance@zenguardmarkets.com Address: 1 Canada Square, Canary Wharf, London E14 5AB, United Kingdom

Our compliance team is available to assist you with any queries regarding your client categorization and the implications of each category.