Information on Investment Intermediary Financial House Ever Inc. and Its Services, Intended for Clients and Potential Clients

I. Introduction

1. This Information on Investment Intermediary Financial House Ever Inc. and Its Services, Intended for Clients and Potential Clients (hereinafter referred to as the “Information) has been developed on the basis and in accordance with the provisions of Article 47, in conjunction with 46 of Commission Delegated Regulation (EU) 2017/565 of 25 April 2016 supplementing Directive 2014/65 / EU of the European Parliament and of the Council as regards organisational requirements and operating conditions for investment firms and defined terms for the purposes of that Directive (Delegated Regulation 2017/565) and Article 71, Paragraph 2 of the Markets in Financial Instruments Act (MFIA), and in accordance with the requirements of Directive 2014/65/EU of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments and amending Directive 2002/92 / EC and of Directive 2011/61 / EU (MiFID II) and in particular with Article 24(4).

2. The information has been prepared in accordance with the nature, scale and complexity of the business activities of Financial House Ever Inc.

3. The information is applicable to contracts between Financial House Ever Inc. and its clients that regulate trading in contracts for differences (CFDs) on an over-the-counter market (OTC market).

4. Financial House Ever Inc. does not offer its clients trading in financial instruments other than CFDs on a market other than the OTC market.

II. INFORMATION ON THE INVESTMENT INTERMEDIARY

1. Investment intermediary Financial House Ever Inc. is a company registered under the Commerce Act of the Republic of Bulgaria having its seat and registered office at 1303 Aleksandar Stamboliyski Blvd., City of Sofia.

2. Contact data of Financial House Ever Inc. are:

-> Address: 1303 Aleksandar Stamboliyski Blvd., City of Sofia.

-> Contact phones: + 359 24003339

-> Official email address:  [email protected]

-> Email address of Internal Control Department:  [email protected]

-> (amended with decision of the Board of directors from 09.10.2020) Company websites:  www.ever.bg; www.fxmeridian.com.

3. The languages in which the client can maintain contact with Financial House Ever Inc. and receive documents and other information from it are Bulgarian and English. The methods of maintaining contact that will be used between Financial House Ever Inc. and the client are:

a) through visits to the office of Financial House Ever Inc.;

b) by exchanging documents with an electronic signature;

c) by phone;

d) by email;

e) through the electronic trading platform offered by Financial House Ever Inc.

4. The manners of sending and receiving orders are:

a) personally or through a proxy at the office of Financial House Ever Inc.;

b) through the electronic trading platform offered by Financial House Ever Inc.

5. Financial House Ever Inc. holds the following licenses and permissions:

5.1. License to operate as an investment intermediary

-> No. 225 – II / 18.12.1996 issued by the State Commission for Securities and Stock Exchanges

-> No. 668 – II / 13.12.2000 issued by the State Commission for Securities

-> РГ-03-0008 / 26.05.2009 issued by the Financial Supervision Commission (FSC).

Financial House Ever Inc. has the right to operate under the conditions of freedom to provide services in all Member States of the European Union.

The supervision of the activity of Financial House Ever Inc. as an investment intermediary is exercised by the Bulgarian Financial Supervision Commission, with address: 16 Budapest, Sofia;  www.fsc.bg,

5.2. Authorization (license) No. 015 / 16.02.2000 to carry out transactions in foreign funds under the Law on Banks (Credit Institutions Act) issued by the Bulgarian National Bank (BNB). The BNB’s address is 1 Knyaz Battenberg I Square.

6. Financial House Ever Inc. does not operate through tied agents, neither in Bulgaria nor in another EU Member State.

7. The nature, frequency and periodicity of the reports on the results of the service to be provided by Financial House Ever Inc. to the client in accordance with Article 25 (6) of MiFID II are as follows:

a) Financial House Ever Inc. provides confirmations for the entered into transactions and reports on the investment services and activities of its clients, as the terms and conditions for these notices for the various financial instruments are specified in the specific contract with the client, and are consistent with the rules of the market where these financial instruments are traded.

b) Where a client uses an electronic trading platform, Financial House Ever Inc. shall send confirmation for any transaction entered into by order of a retail client. This shall be done at the earliest opportunity, but no later than the first business day following the conclusion of the transaction. The confirmation is part of the daily report.

c) Financial House Ever Inc. prepares and submits a daily report on transactions entered into by the client through the electronic trading platform or the email address given by the client if the respective platform does not allow it to submit reports. If no transaction is entered into during the respective business day and there is no open position in the client’s account, Financial House Ever Inc. does not prepare a daily report.

d) Financial House Ever Inc. sends, once a quarter, to each client for whom it holds financial instruments or funds, a durable reference to those financial instruments or funds, unless such reference is provided in another periodic report. The periodic reference of the client’s assets is not provided when Financial House Ever Inc. provides its clients with access to an online system that meets the criteria for durable medium, if up-to-date reports on the client’s financial instruments or funds are easily accessible by the client and the investment intermediary has evidence that the client has accessed that report at least once during the respective quarter.

8. Financial House Ever Inc., as an investment intermediary that holds financial instruments and funds of clients, takes measures to protect the clients’ rights of ownership on these assets. These measures are as follows:

a) Financial House Ever Inc. has separated its financial instruments and funds from those of its clients.

b) Financial House Ever Inc. keep records and accounts of financial instruments and funds of its clients who:

-> enable it any time to distinguish assets held for one client from assets held for any other client, and from its own assets;

-> accurately reflect the financial instruments and funds held for clients;

-> can be used for documentary traceability (audit trail).

c) For all financial instruments and funds, Financial House Ever Inc. keeps analytical accounts of its clients. Financial House Ever Inc. takes the necessary steps to ensure that all clients’ financial instruments can be clearly distinguished at any time from the investment intermediary’s financial instruments, through accounts with different names in the investment intermediary’s accounting records or through equivalent measures ensuring the same level of protection.

d) Financial House Ever Inc. does not use and cannot use financial instruments (CFDs) of its clients on its own account, at the expense of its other clients, or at the expense of any other person.

e) Financial House Ever Inc. does not use and cannot use funds on its own account client funds, except with the explicit consent of the client.

f) Financial House Ever Inc. shall not be liable to its creditors with the financial instruments and funds of its clients. Enforcement on the funds and financial instruments of clients for the purposes of covering obligations of Financial House Ever Inc. shall not be allowed.

g) Financial House Ever Inc. implement the necessary organization to minimize the risk of losing or reducing the client’s financial instruments and funds, or limiting or losing their rights in relation to those assets as a result of misuse of the assets, fraud, poor management, improper record keeping or negligence.

h) Financial House Ever Inc. appoints an employee responsible for compliance of the investment intermediary’s obligations related to the protection of the clients’ financial instruments and funds.

i) The financial instruments offered for trading by Financial House Ever Inc. are CFDs, which by their nature are not transferable securities and are not held in a depository institution but in an analytical account with the investment intermediary. In view of this, Financial House Ever Inc. does not deposit client financial instruments with a depository institution under Article 94(1) of the MFIA, and keeps them with them in analytical accounts of its clients.

j) Financial House Ever Inc. does not keep the funds of its clients. Financial House Ever Inc. deposits the client’s funds in an entity named below into an account or accounts separately from all accounts used to hold funds of the investment intermediary. Financial House Ever Inc. may deposit its clients’ funds with:

-> a central bank;

-> a credit institution licensed to operate under the Credit Institutions Act, in accordance with the requirements of Directive 2013/36/EU of the European Parliament and of the Council of 26 June 2013 on access to the activity of credit institutions and the prudential supervision of credit institutions and investment firms, amending Directive 2002/87/EC and repealing Directives 2006/48/EC and 2006/49/EC, respectively;

-> a credit institution licensed in a third country;

-> qualified money market fund.

Financial House Ever Inc. does not deposit its clients’ funds in a qualified money market fund.

Financial House Ever Inc. does not deposit clients’ funds with a credit institution or qualified money market fund, which are in the same group as the investment intermediary.

(amended with decision of the Board of directors from 09.10.2020) Financial House Ever Inc. deposits its clients’ funds with the commercial banks (credit institutions) listed on its website www.ever.bg and/or www.fxmeridian.com. Financial House Ever Inc. informs the client or potential client by the durable medium declared by it or through its website when accounts containing that client’s funds are subject to or will be subject to the law of a jurisdiction other than that of a Member State, and it points out that the rights of the client or potential client associated with this funds may differ accordingly.

Financial House Ever Inc. informs the client or potential client by the durable medium declared by it or through its website about the cases when that client’s funds can be held by a third party on behalf of the investment intermediary, and about the responsibility of the investment intermediary under the applicable national law for any acts or omissions of the third party, as well as the consequences for the client of the eventual insolvency of the third party.

l) Financial House Ever Inc. reconciles its accounts and records with those of the commercial banks where the assets of the intermediary and its clients are held, and the reconciliation is made on a daily basis.

m) (amended with decision of the Board of directors from 09.10.2020) Detailed information on this matter can be found in Information on the Protection of Financial Instruments and Funds of the Clients of Financial House Ever Inc. Trading in Contracts for Differences on an Over-the-Counter Market, which is accessible to the clients in the offices of Financial House Ever Inc. and on its website (www.ever.bg and/or www.fxmeridian.com).

n) Financial House Ever Inc. informs the client that the Investor Compensation Fund has been established in the Republic of Bulgaria, which is a legal entity with its seat and registered office at 31 Tsar Shishman Street, City of Sofia;  www.sfund-bg.com.

The Fund provides compensation to clients of investment intermediaries, such as FINANCIAL HOUSE EVER, including its branches in the host countries, under the terms and conditions of the Public Offering of Securities Act (POSA).

The Fund pays compensation to clients for claims arising from the inability of the investment intermediary to repay clients’ funds, financial instruments or to satisfy other claims of clients in compliance with the procedures, restrictions and procedures provided for in Bulgarian law.

Certain assets that are not financial instruments may not be protected by the Fund in accordance with applicable law.

The Fund pays compensation to the clients of the investment intermediary in cases where:

-> by a decision of the respective district court the insolvency proceedings were initiated for the investment intermediary, including when the insolvency proceedings were terminated on the grounds of Article 632 of the Commerce Act;

-> the license, respectively the authorization, to act as an investment intermediary was revoked by a decision of the Financial Supervision Commission because the investment intermediary was in a permanently deteriorated financial state and was unable to fulfill its obligations.

Within 7 days of receipt of the decision referred to in above, the Fund shall publish in at least two central dailies and on its website (www.sfund-bg.com) notification of the decision made under the preceding paragraphs and for the period within which the clients of the investment intermediary may file a request for payment of compensation from the Fund, as well as the bank through which the compensation will be paid.

Compensation shall be paid for the claims arising from the inability of the investment intermediary to return the client’s assets in accordance with the legal and contractual conditions. Client’s assets are considered to be funds, financial instruments and other assets of the clients of an investment intermediary, which it holds, administers or manages for their account in connection with the investment services provided by it under Article 6, Paragraph 2 and 3 of the MFIA, including interest, dividends and similar payments.

The Fund pays compensation to each client of an investment intermediary in the amount of 90 per cent of the value of the claim, but not more than the following amounts:

-> until 31 December 2006 – BGN 12,000;

-> 1 January – 31 December 2007 – BGN 24,000;

-> 1 January 2008 to 31 December 2009 – BGN 30,000;

-> from 1 January 2010 – BGN 40,000

The structure and activities of the Investor Compensation Fund is regulated in the Rules adopted by Decision No. 40-П of 10.08.2005 of the Financial Supervision Commission, promulgated, SG No. 69 of 20.06.2005.

Upon request of a client, Financial House Ever Inc. will provide them with detailed information on the terms and procedure for compensation of investors under the POSA.

9. Financial House Ever Inc. applies a policy regarding the conflict of interest of Financial House Ever Inc., which is as follows:

a) When performing services and activities under Article 6, Paragraphs 2 and 3 of the MFIA, the company takes all necessary actions to identify potential conflicts of interest between:

1. the investment intermediary, including the persons who are members of the board of directors or manage its activities, the persons and all other persons who may conclude transactions, individually or jointly with another person, on behalf of the company, all other persons who work under the contract for it, and persons linked by control to it on the one hand and, on the other hand, its clients;

2. its individual clients.

b) Under this policy, a conflict of interest is a situation that arises in connection with the provision of investment and/or ancillary services by the investment intermediary and may impair the interest of a client. The policy contains circumstances that present a conflict of interest or which may lead to a conflict of interest, creating a risk of damaging the interests of a client or clients of the investment intermediary, including such circumstances which are or should be known to the investment intermediary and which may give rise to a conflict of interest as a result of the structure of the group of which the investment firm is a part and the activities of the other members of the group and the procedures and measures for the treatment of such conflicts.

c) Circumstances that the Company accepts under this conflict of interest policy or which may give rise to such conflicts are:

1. All cases as a result of which the provision of investment and/or ancillary services or otherwise by the company, a person working under contract for it, or a person directly or indirectly linked by control to it, fall into one of the following categories:

1.1. is able to make financial profit or avoid financial loss at the expense of the client;

1.2. has an interest in the result of the service provided to the client or the transaction performed for the account of the client, which is different from the client’s interest in that result;

1.3. there is a financial or other incentive to favour the interest of a client or group of clients over the interests of another;

1.4. performs the same activities as the client;

1.5. receives or will receive from a person other than the client benefits in connection with a service provided to the client in the form of funds, goods or services in violation of the Financial Markets Act and its implementing acts, and applicable regulations with direct effect, or other than the standard fee or commission for that service.

2. The cases in which a person who works under a contract for the investment intermediary and is engaged in the conduct of activities that may give rise to a conflict of interest, or because of its activity as an investment intermediary they have access to inside information within the meaning of the Measures Against Market Abuse with Financial Instruments Act or other confidential information about clients or transactions with or for clients.

3. A case in which the II, taking into account the professional qualities and market reputation of the persons under Article 93, Paragraph 1, items 2-4 of the MFIA and the regulatory requirements and market practices related to holding of funds found that the rights of the client could be violated.

4. Under this policy, transactions and / or services with conflicting potential are:

4.1. when the II aggregate  a client order with a transaction on its own account and the order so aggregated is partially executed;

4.2. orders for the purchase or sale of financial instruments (shares) of issuers with which it is acquired, respectively, lose the respective shareholding therein, referred to in Article 145, Paragraph 1 of the POSA by the client;

4.3. providing services by FH EVER Inc. as a registered agent when transactions in dematerialized financial instruments are entered into directly between the parties and the latter are clients of the II and its employees;

4.4. a conflict of interest may arise or has arisen between two intermediary‘s clients.

d) in the circumstances referred to in subitem b), it shall follow the following measures and procedures for the treatment of conflicts of interest:

1. strict confidentiality is maintained with regard to transactions with conflicting potential, in order to avoid actual occurrence of conflicts and risk of carrying out transactions based on inside information;

2. the general terms and conditions applicable to the contracts with the clients before the conclusion of the contract are explained to each client;

3. the measures and requirements under the Markets in Financial Instruments Act and its implementing acts, as well as the applicable regulations with direct effect  shall be strictly complied with;

4. the policy adopted by II for execution of orders given by clients shall be strictly complied with, including client orders are not executed unless the latter has given their explicit prior consent to the policy followed by the II;

5. persons working under a contract for the II and carrying out activities involving a conflict of interest shall act with a degree of independence of execution appropriate to the size and activities of the II, as well as the significance of the risk of damage to the client’s interest, with due respect for the following measures to the extent necessary to ensure the necessary degree of independence:

5.1. keeping complete confidentiality and preventing the exchange of information between them and other employees of the II, when the exchange of that information may harm the interests of one or more clients;

5.2. control shall be exerted over persons whose principal functions include the provision of services on behalf of and/or for the account of clients or the provision of services to clients where a conflict of interests may arise between clients, or which may otherwise represent conflicting interests between which a conflict arises, including over the interest of the II;

5.3. lack of direct correlation between the remuneration of the persons carrying out mainly one activity and the remuneration of the persons carrying out mainly other activity for the II, or the income generated by the latter if a conflict of interest may arise in connection with such activities;

5.4. employees, including the members of the Board of Directors, are prohibited to exert an inappropriate influence on the way in which other person working under a contract for the II provides services and activities under Article 6, Paragraphs 2 and 3 of the MFIA;

5.5 employees, including the members of the Board of Directors, are prohibited to simultaneously or consistently participate (one person) in the performance of separate investment or ancillary services or activities, where such participation may impair the proper management of conflicts of interest, and if it is impossible to exert control over this;

e) The II shall additionally apply the following measures in the treatment of conflicts of interest:

1. it ensures equal and fair treatment of the clients acting in the interest of the client under the best conditions for them. The II avoids situations where the interest of its client would conflict with its obligation to other of its clients;

2. the rules for the conclusion of personal transactions are strictly applied, and every person working under a contract for the II, when concluding the contract, receives the same on a durable medium and declares that they are familiar with the rules;

3. giving priority to the client’s interest over its own interest, including when a client’s order is aggregated with a transaction on own account and order so aggregated is partially executed, the II distributes the transactions for the account of the client with priority and in the client’s interest, except in the exclusions explicitly specified in the Markets in Financial Instruments Act and its implementing acts, as well as the applicable regulations with direct effect;

4. a person within the internal control department shall be notified of such transactions, who should assist in resolving the conflict, if such has arisen;

5. The rules for separating one’s portfolio of financial instruments from those of investors shall be strictly followed.

6. The II shall keep and update information about the types of investment or ancillary services or investment activities performed by or on behalf of the investment intermediary, in which a conflict of interest arises or may arise in the course of providing the service or activity, which leads to significant damage to the interest of a client or clients of the investment intermediary.

f) If, despite the application of the rules for internal organization of the II, there is still a risk for interests of the client, then the II cannot carry out activities for the account of a client if they do not inform it of the general nature and/or sources of the potential conflict of interests. In the cases under the preceding sentence, prior to carrying out an activity for the account of a client in respect of which there is a conflict of interest, the II shall provide the client on a durable medium with information on the conflict of interest, which is sufficient in accordance with the client’s characteristics to take informed decision on the investment or ancillary service in connection with which a conflict of interest arises.

10. (amended with decision of the Board of directors from 09.10.2020) Financial House Ever Inc. provides its clients with the opportunity to trade in contracts for differences (CFDs) on an over-the-counter market (OTC market) against payment of the full value of the financial instrument or against a margin provided through a trading account against a margin provided through the electronic trading platform www.fxmeridian.com

Financial House Ever Inc. does not offer its clients trading in financial instruments other than CFDs in a market other than the OTC market.

Financial House Ever Inc. offers its clients the following types of CFDs:

-> CFDs on securities and exchange-traded funds;

-> CFDs on indices;

-> CFDs on futures;

-> CFDs on currency pairs and precious metals;

-> CFDs on options traded.

The main features of CFDs offered by Financial House Ever Inc. are:

-> the creator and distributor of CFDs offered for trading by Financial House Ever Inc. is the investment intermediary itself;

-> The CFD offered for trading by Financial House Ever Inc. is not a transferable security and is not held in a depositary institution but in an analytical account with the investment intermediary;

-> neither party acquires the CFD itself nor the underlying asset on which it is based;

-> neither party is obliged to buy, sell, deliver or receive the respective CFD’s underlying asset;

-> the rights and obligations of each of the parties to the CFD are solely to exercise or receive payments under the submitted order, as the results of the execution of the orders are reflected in its positions in assets and/or funds accordingly;

-> transactions in CFDs are not subject to centralized clearing.

(amended with decision of the Board of directors from 09.10.2020)Detailed information about the financial instruments offered for trading by the investment intermediary can be found in Information on Financial Instruments That are Subject of the Investment Services Provided by Financial House Ever Inc. and Associated Risks, which is available to clients in the offices of Financial House Ever Inc. as well as on its website www.ever.bg and/or www.fxmeridian.com.

(amended with decision of the Board of directors from 09.10.2020) Information about each financial instrument offered by Financial House Ever Inc. is available and can be freely accessed on the intermediary’s web site (www.ever.bg  and/or www.fxmeridian.com).

11. Financial House Ever Inc. warns that trading in financial instruments, including CFDs, poses significant risks and is not suitable for each investor. Trading in financial markets is not suitable for investors seeking a stable income, as the income from such activity is volatile and uncertain.

The financial instruments offered by Financial House Ever Inc. – CFDs – are complex financial instruments and, accordingly, their risk component is composite and complex, therefore the risk of loss of the funds invested by the client is significant.

In trading in financial instruments, including CFDs, there is no guarantee that the initially invested amount will not be lost and there is almost never a guarantee that the expected return will be realized. The losses may exceed the amounts of deposited funds, but they will be fully consistent with the client’s performance and their investment behavior.

Clients should take into account that the profitability of CFD trading is also influenced by the fees and commissions that the investment intermediary charges as specified in the Tariff of Interest Rates, Fees and Commissions of Financial House Ever Inc. and from other expenses related to that type of derivative instruments.

(amended with decision of the Board of directors from 09.10.2020) Information on fees, commissions and other potential costs of CFD trading is available in the current Tariff and is also published and freely available on the web site of Financial House Ever Inc. (www.ever.bg and/or www.fxmeridian.com).

Clients should also bear in mind that financial markets are highly volatile, i.e. they are characterized by price volatility and quotations of financial instruments. The prices and quotations of CFDs are directly dependent on the price of the respective underlying asset, which is influenced by many and various factors, including: changes in the supply and demand ratio; world trade; tax, monetary, regulatory and foreign policy of the parties; important economic and political news; changes in interest rates of central banks; transactions of central banks and major players; currency depreciation; actual presentation of business entities in their respective segment; market players’ anticipations and expectations, as well as many other factors.

The types of CFDs offered by Financial House Ever Inc. do not contain a mechanism for protection against market dynamics, which means that the client may lose all or part of their investment.

The execution venues may impose price restrictions on the financial instruments traded on them, assets that are underlying for the CFDs offered by Financial House Ever Inc., as well as suspend trading in individual instruments. Financial House Ever Inc. warns its clients that in specific cases the client may assume financial and other additional obligations as a result of transactions in financial instruments, including contingent liabilities in addition to the costs of acquiring CFD.

It should be taken into account that trading against a guarantee amount (margin), while allowing profit to be made on the whole open position, is a high risk form of investment and can also lead to significant losses or complete loss of invested client funds.

Financial House Ever Inc. warns that using leverage can multiply both clients’ profits and losses, and relatively small market movements can have a large effect on client positions. As a result, the deposited funds constituting a guarantee on open positions can be completely exhausted.

The client should take into account that regardless of the specific financial instrument, trading against a guarantee amount provided is higher risk than trading against paying the full value of the financial instrument.

(amended with decision of the Board of directors from 09.10.2020) Detailed information about the financial instruments offered for trading by the investment intermediary can be found in Information on Financial Instruments That are Subject of the Investment Services Provided by Financial House Ever Inc. and Associated Risks, which is available to clients in the offices of Financial House Ever Inc. as well as on its website (www.ever.bg and/or www.fxmeridian.com).

12. In the process of opening a trading account, Financial House Ever Inc. assesses whether the service requested by the client is suitable for them. The assessment is made on the basis of the information provided by the client regarding their knowledge and experience in trading on financial markets.

Notwithstanding the evaluation of Financial House Ever Inc., the client should make for themselves a careful assessment of whether the services offered by Financial House Ever Inc. are suitable for them and whether to use them or not.

In the event that the assessment of Financial House Ever Inc. shows that the requested service is not suitable for the client, the investment intermediary shall inform the client and warn them about the risks thereof.

The decision to use this service, although it is considered unsuitable for them, is up to the client and they explicitly state it to the intermediary.

(amended with decision of the Board of directors from 09.10.2020) Financial House Ever Inc. warns that if, despite the intermediary’s warning, the client determines that they will use a service that is deemed unsuitable for the client, the client, prior to conducting actual trading that would result in financial losses for them,  should obtain  some experience in this type of trading through a demo account, and familiarize themselves  with the specifics of trading against a guarantee amount (margin trading) in general, including through the training materials available on the website of Financial House Ever Inc. (www.ever.bg and/or www.fxmeridian.com).

13. With regard to the trading of the above-mentioned CFDs, which is carried out on an OTC market, Financial House Ever Inc. is the only execution venue of the orders and acts as a principal on each transaction (rather than an agent or broker). In practice, the client’s orders are executed through the electronic platform for trading in financial instruments offered by the investment intermediary, at the prices quoted by the investment intermediary, and on each transaction with the client Financial House Ever Inc. is a counterparty. All orders of clients for trading in CFDs are executed against the own liquidity of Financial House Ever Inc. Financial House Ever Inc. does not transfer (route, direct, send) the client’s orders to another execution venue.

Financial House Ever Inc. does not execute orders from clients outside the specified execution venue.

Financial House Ever Inc. does not execute a client order or a transaction for its own account grouped (aggregated) with an order of another client when it comes to orders for trading CFDs on a OTC market, since in this case, Financial House Ever Inc. is the only place for execution of the orders and is a counterparty to each transaction.

Financial House Ever Inc. warns its clients in advance that their CFD trading orders will be executed outside the trading venue (regulated market, multilateral trading system and organized trading system). Financial House Ever Inc. warns that any specific instructions from the client may prevent the investment intermediary from taking the measures provided for and applied to the Policy for Execution Clients’ Orders applicable to the agreements for trading in CFDs of Financial House Ever Inc. to obtain the best possible results in the execution of those orders with respect to the elements covered by these instructions.

Financial House Ever Inc. does not apply different charges depending on the place of execution of the client’s orders, as it acts as the only place for execution of those orders.

Financial House Ever Inc. acts as the sole venue for executing the orders of its clients, and therefore does not receive payments or incentives from third parties (which are themselves venues for execution) in connection with the execution of those orders. Financial House Ever Inc. does not receive any consideration, discount or non-monetary benefit for transferring a client’s order to a specific trading venue, a place for executing orders, respectively.

Financial House Ever Inc. only charges its clients the fees specified in its Tariff of Interest Rates, Fees and Commissions, and these fees do not vary depending on the client or the execution venue.

Financial House Ever Inc. acts as a counterparty to all transactions with clients, therefore it does not charge receivables from two or more participants in a transaction in accordance with Article 24, Paragraph 9 of MiFID II, it does not receive non-monetary benefits as an intermediary, and the value of all monetary benefits it receives as an intermediary is specified in the Tariff of Interest Rates, Fees and Commissions of Financial House Ever Inc.

When performing investment services and activities for clients, Financial House Ever Inc. acts honestly, fairly and professionally in providing investment and ancillary services in accordance with the best interests of its clients.

Financial House Ever Inc. promptly, honestly and accurately executes the received client orders, including in the order of their receipt. Financial House Ever Inc. adheres to the following conditions when executing client orders:

-> It ensures that orders executed on behalf of clients are promptly and correctly registered and distributed;

-> It executes comparable in other respects orders of clients consistently and immediately, unless this is impracticable due to the characteristics of the order or prevailing market conditions or if the interests of the client require otherwise;

-> It informs the retail client of any significant difficulty related to the proper execution of the orders as soon as they become aware of the difficulty.

Financial House Ever Inc. does not misuse the information related to pending client orders and takes all reasonable steps to prevent the misuse of such information by any of its respective persons.

When executing a client’s order, Financial House Ever Inc. takes all sufficient steps to obtain the best possible result for the client, taking into account the price; the costs; the speed of execution of the order; the likelihood of execution and settlement (if, in view of the type and nature of the transaction, it is carried out); size; the nature and all other circumstances relating to the execution of the order.

In executing an order submitted by a retail client, the best possible result is determined by the total value of the transaction, including the price of the financial instrument and the costs associated with the execution, which include all costs directly related to the execution of the order, including execution venue fees, clearing and settlement fees (if any) and other fees and charges paid to third parties involved in executing the order, if any.

Upon specific instructions from the client, Financial House Ever Inc. executes the order by following these instructions. All special instructions of the client derogate from the rules for achieving the best result set out in the Policy for Execution Clients’ Orders applicable to agreements for trading in CFDs of Financial House Ever Inc.

When executing clients’ orders, Financial House Ever Inc. takes into account the following criteria in determining the relative importance of the factors mentioned above:

-> client’s characteristics, including categorization of the client as retail or professional;

-> characteristics of the client’s order;

-> characteristics of the financial instruments that are the subject of that order.

(amended with decision of the Board of directors from 09.10.2020) Information on the execution of client orders is available in the Policy for Execution Clients’ Orders applicable to agreements for trading in CFDs of Financial House Ever Inc., which is available and can be freely accessed on the website of Financial House Ever Inc. (www.ever.bg and/or www.fxmeridian.com).

III. FINAL PART

14. (amended with decision of the Board of directors from 09.10.2020) The latest up-to-date revision of this Information is available to clients in the offices of Financial House Ever Inc., as well as on its website (www.ever.bg and/or www.fxmeridian.com). Financial House Ever Inc. informs its clients through its web site about significant changes in the Information or about the adoption of a new one.

15. This document was approved by the Board of Directors of Financial House Ever Inc. at a meeting held on 5 June 2018 and is effective from the same date. This document is amended with a decision of the Board of directors from 09.10.2020.

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