Risk Disclosure

Valid as of 17 December 2025

The purpose of this risk disclosure (the “Risk Disclosure”) is to provide you with insight on certain indicative (but not exhaustive) risks in trading financial instruments, such as (but not limited to) contracts for difference and/or foreign exchange.

By reviewing this Risk Disclosure, you are under no obligation to trade with Bullfy Ltd (the “Company” or “Bullfy”), however, the Risk Disclosure is based on those proposing to trade with Bullfy. It is acknowledged and therefore should be noted, that this Risk Disclosure does not contain all of the risks associated in trading financial instruments, and only acts as a guide to assist you in acknowledging the possible, indicative risks involved.

You should ensure that your decision is made on an informed basis. If you do not understand the Risk Disclosure (regardless of whether in whole or in part), please seek independent advice, as from the moment you will have opened an account with Bullfy, you will have signified that you understand all of the risks involved in trading financial instruments.

Below are certain key disclosures that you must take into account:

  1. Trading is not suitable for everyone.
  2. The degree of leverage associated with trading derivative products (such as contracts for difference), means that the degree of risk compared to other financial instruments is higher. Leverage (also known as margin trading) may work against you, resulting in the complete loss of your funds.
  3. You are solely responsible for monitoring your positions.
  4. Prior trading, you should carefully consider your investment objectives, your level of financial experience and your risk appetite.
  5. Bullfy shall never provide you with any type of advice.
  6. Past performance of any financial instruments does not guarantee any future results.
  7. You must bear in mind any commission and tax liabilities you will have from trading with us.
  8. Bullfy accepts no liability for any tax you may be required to pay on any profits made during the time you hold an account with Bullfy.
  9. There is always a relationship between high reward and high risk. Any type of market or trade speculation that can yield unusually high returns, is subjected to high risk. Only surplus funds should be placed at risk and anyone who does not have such funds should not trade in financial instruments. Different instruments involve different levels of exposure to risk.

In deciding whether to trade in financial instruments, you must be aware of the following:

1. CFDs in General

Contracts for Difference (henceforth referred to as “CFDs”) are complex financial products which generally only close when a client chooses to close an existing open position, and therefore generally have no set maturity date. CFDs can be likened to futures, which can be entered into in relation to certain indices, precious metals, oil, commodities, cryptocurrencies, or other financial instruments. However, unlike other futures, these contracts can only be settled in cash. Investing in a CFD carries risks similar to investing in a future and you should be aware of these. Transactions in CFDs may also have a contingent liability and you should be aware of the implications of this as set out in paragraphs below. When trading CFDs, you shall not have right to the underlying instrument or the rights which are attached.

2. Trading foreign exchange, indices, precious metals, oil and commodities

Trading foreign exchange and CFDs on cryptocurrencies and/or indices and/or precious metals and/or oil and/or commodities, carries similar risks as trading in a future and you should be aware of these. Such margined transactions may also have a contingent liability and you should be aware of the implications of this as set out below.

In addition to standard industry disclosures contained in this Risk Disclosure, you should be aware that margined trading in foreign exchange and/or CFDs on indices and/or precious metals and/or oil and/or commodities, are some of the riskiest forms of trading available in the financial markets and may not be suitable for all traders. Given the possibility of the complete loss of your funds, speculation in the precious metals, indices, oil, commodities or foreign exchange markets should only be conducted with funds that if lost, will not significantly affect your financial well-being.

3. Foreign markets

Foreign markets involve different risks from the client’s native markets. In some cases, risks will be greater. The potential for profit or loss from transactions on foreign markets or in foreign currency will be affected by fluctuations in foreign exchange rates. Such enhanced risks include the risks of political or economic policy changes in foreign media, which may substantially and permanently alter the conditions, terms, marketability or price of a foreign currency.

4. Risk reducing orders or strategies

The placing of certain orders (e.g. “stop loss” or “stop limit” orders) that are intended to limit losses to certain amounts may not always work because market conditions or technological limitations may make it impossible to execute such orders. Should a client trade using such orders or strategy they do so accepting this risk.

5. Contingent liability transactions

Foreign exchange and CFDs are margined transactions requiring you to make a series of payments against the contract value, instead of paying the entire contract value immediately. You may sustain a total loss of the margin you deposit with Bullfy to establish or maintain a position. Bullfy revalues your open positions continuously during each business day, and any profit or loss is immediately reflected in your account and a loss may result in you being called upon to pay substantial additional margin on short notice to maintain your open positions.

The Company may also change its rates of initial margin and/or notional trading requirements at any time with or without notice to you, which may also result in a change to the margin you are required to maintain. If you do not maintain sufficient margin on your account at all times and/or provide such additional funds within the time required, your open positions may be closed at a loss and you may be liable for any resulting deficit.

6. Leverage

The gearing and leverage that is obtainable with CFDs and foreign exchange trading, means that you only need to place a small deposit to commence trading with the Company, although this small deposit may result in large losses. Highly leveraged transactions are subject to significant changes in value as a result of relatively small changes in the value or level of an underlying or related market factor.

7. ‘Over- the-Counter’ Transactions

When trading CFDs and/or foreign exchange, you speculate on the anticipated price change for a particular underlying. Trading in the above financial instruments, does not occur on a regulated market. You will enter directly into a contract with Bullfy in respect of the financial instrument or other underlying you wish to trade under a CFD and/or foreign exchange. All open positions with Bullfy must be closed with Bullfy and cannot be closed with any other party. Trading in ‘Over- the-Counter’ financial transactions may expose you to greater risks than trading on a regulated market because there is no market on which to close out your open positions and prices and other conditions are set by us. ‘Over- the-Counter’ transactions may increase the liquidity risk and introduce other significant risk factors. It may be impossible, for example, to assess the value of a position resulting from an off-market transaction or to determine the risk exposure. Also, bid prices and offer prices need not be quoted by the Company and, even where they are, the Company may find it difficult to establish a fair price particularly when the relevant exchange or market for the underlying is closed or suspended.

8. Prices

The prices/quotes posted on the Company’s trading platforms (each, a “Platform”) may not necessarily reflect the broader market. Bullfy will select closing prices to be used in determining margin requirements and in periodically marking to market the positions in your account and closing out such positions. Although Bullfy expects that these prices will be reasonably related to those available on what is known as the interbank market or any appropriate exchange or other financial market (the “Reference Market”), prices Bullfy uses may vary from those available to banks and other participants in the Reference Market. Consequently, Bullfy may exercise considerable discretion in setting margin requirements and collecting margin funds. As the products are in part related to the underlying, you should ensure that you are aware of the risks involved in the underlying including currency fluctuation, volatility and gapping (a sudden price shift which can be caused by many factors including, but not limited to, economic events, epidemics, market announcements and periods where trading in the underlying does not take place). A non-guaranteed stop will not protect you against this risk as it is not immediate and only triggers an order to close the position at the nearest available price.

9. Weekend Risk

Various situations, developments or events may arise over a weekend when the markets generally close for trading, that may cause the markets to open at a significantly different price from where they closed on Friday afternoon. You will not be able to use the Platform to place or change orders over the weekend and at other times when the markets are generally closed. There is a substantial risk that stop-loss orders left to protect open positions held over the weekend will be executed at levels significantly worse than their specified price. When doing this a client accepts this risk and that they will be liable for any resulting deficit.

10. Electronic trading

Trading in ‘Over-The-Counter’ transactions through the Platform, may differ from trading on other electronic trading systems as well as from trading in a conventional or open market. You will be exposed to risks associated with the electronic trading system including the failure of hardware and software and system down time, with respect to the Platform, your systems and the communications infrastructure (for example, the internet) connecting the Platform with you.

11. Intraday Trading

Intraday trading can lead you to make numerous transactions, as a result of which you may commit several mistakes due to human error leading to the entire loss of your capital, along incurring significant transaction costs due to frequent trading.

12. Trading Suspensions

Under certain conditions, it may be difficult or impossible to liquidate a position. This can occur, for example, at times of rapid price movement where the price for an underlying rises or falls during one trading session, to such an extent that trading in the underlying is restricted or suspended. Where this occurs, you accept any associated risk and that you will be liable for any resulting deficit. You are also being made aware that under certain circumstances, Bullfy may be required to close positions due to regulatory or exchange instructions, and as such, Bullfy is not, and shall not, at any time, be, responsible for any losses that may occur.

13. Commissions

Before you begin to trade, you should obtain details of all commissions and other charges for which you will be charged from Bullfy. Also, you should make yourself aware of potential costs or liabilities that could ensue, including but not limited to, swaps and/or corporate actions, such as, but not limited to, rights issues and/or dividends and/or stock splits etc.

14. Insolvency

Any client insolvency or default may lead to positions being liquidated and/or closed out without your consent. Additionally, you will transfer full ownership and title to a portion of all the money you will deposit with Bullfy. This will represent an amount necessary to secure your present and/or future, actual and/or contingent liabilities to Bullfy, including margin requirements.

Bullfy will determine the amount of money required to secure your obligations to Bullfy in its sole discretion on a daily basis (based on your daily open positions and trading, taking market conditions into account), which amount may be greater than your margin requirements. You will have no claim over this amount of money, and you and Bullfy agree that Bullfy shall deal with this amount of money as it wishes. Such amount of money may therefore be irrecoverable in the event of an insolvency or default of Bullfy.

15. Communication

Bullfy accepts no responsibility for any losses that may arise as a result of delayed review or unreceived communications sent by Bullfy to its clients. You further accept that any losses arising as a result of unauthorized access of a third party to the Platform, is not the responsibility of Bullfy, except in the case of gross negligence on behalf of Bullfy or its staff. You alone are responsible for keeping all login details safe and Bullfy strongly recommends that user details are not written down or saved. Also, you are informed of, and accept that, the main method of communication will be in an electronic format, for example via email and information posted on the Bullfy website(s).

16. Advice

Bullfy does not, and shall not, at any time, provide any investment and/or any other type of advice pertaining to your trading decisions. Whilst we may make general assessments of the markets, such assessments are not individual investment advice and do not take into consideration your individual circumstances. Any decision to trade is made by you alone.

All general information we provide via online and/or offline mediums, are for general information and are the personal market outlooks of the moderator or author. It is not intended to be, and should not be, considered, to be advice to sell, buy or hold a trading instrument under any circumstances. Bullfy’s analysts and/or authors may trade and/or hold and/or be invested in trading products such as stocks and/or foreign exchange and/or CFDs and/or commodities and/or futures and/or other financial instruments.

17. Corporate Actions: Share CFDs

The treatment that you receive during a corporate action may be less favorable than if you owned the underlying instrument, because changes we make, may need to be made reactionary and in place prior to that required by the corporate action. Therefore, the time you have to make decisions could be considerably less; the options available may be more restrictive/less advantageous, and may be such that there is no option for you to close your position(s). Given that corporate events can often be announced at extremely short notice, you may have no opportunity or choice to close positions out, in order to avoid such consequences, and such actions may require you to provide more funds to cover margin at a very short notice.

18. Going Short on CFDs Shares

Going short on CFDs shares, has additional risks that do not apply to the long position. This includes, but is not limited to, the risk that you will be obliged to take the other side of a purchase opportunity, for instance, a rights issue resulting in you going further short at what could be unfavorable prices or paying a sum to buy back the rights the choice of which may be decided by Bullfy without your input, on terms decided by Bullfy or input being required at shorter notice than would be on the underlying share; you may experience forces buy-back due to corporate actions, stock borrowing conditions or regulatory requirements/changes, and you may experience variable borrowing charges whilst the position is open.

19. Position Monitoring

As otherwise stated above, it is your sole responsibility to monitor, at all times, the positions that you have opened, and you must always be in a position to do so.

20. Dividend Adjustments on CFD Positions

(A) Dividend adjustments on cash index CFDs

When any underlying stock that is part of a cash index CFD goes ex-dividend, the cash index CFD will be price-adjusted to reflect this dividend. The weighted proportion of the applicable dividend within the cash index CFD will be credited to yours account for long positions. and debited for short ones.

(B) Dividend adjustments on share index CFDs

When a stock that is an underlying asset of a share CFD goes ex-dividend, the share CFD will be price-adjusted to reflect this dividend. The value of the applicable stock dividend will be credited to your account for long positions and debited for short ones.

(C) Withholding Taxes on Dividend Adjustments

Dividend payments will be credited to your account with any applicable standard withholding taxes deducted. Bullfy does not currently support or offer preferential withholding tax rates that may be available due to residency or legal status.

21. Hedged Positions

Hedging positions might not fully stabilise your margin level, and therefore, a stop-out on your account might occur even when such hedged positions are in place. It may happen due to the following circumstances:

  1. Profits/losses on short positions are calculated with the ask price while profits/losses on long positions are calculated with the bid price. In abnormal trading conditions, the spread may widen, leading to losses on your account being higher than the margin held and therefore your positions being liquidated.
  2. Profits/losses on positions are calculated in the base currency of the traded instrument and then recalculated to the account currency with the use of the platform exchange rates. If hedged positions are opened in different time/ prices, then profits/losses on the account may be subject to account currency price fluctuations resulting in losses being greater than the margin held and therefore your positions being liquidated.

The Risk Disclosure shall be in addition to, and shall be read in conjunction with, Bullfy’s terms and conditions, as well as Bullfy’s other terms and conditions and policies made available on the Company’s website. Also, the Risk Disclosure may be amended from time to time. If Bullfy elects to provide you with written notice prior such amendment being made, the amended Risk Disclosure shall become effective on the date specified in such notice. If Bullfy does not elect to provide you with prior written notice, the amended Risk Disclosure shall become binding on the date that is published on the Platform and/or the Company’s website (whichever event occurs first).