Client Appropriateness Policy

This Client Appropriateness Policy (the “Policy”) sets out the framework applied by Kohle Capital Markets Limited (the “Company”, “we”, “us”, or “our”) to assess whether the financial products and services offered through the KCM Trade platform (the “Services”) are appropriate for prospective and existing users.

This Policy is maintained in compliance with Rule 7 (Suitability of Transactions) of the Securities (Conduct of Business) Rules 2007 of the Republic of Mauritius and the licensing conditions applicable to the Company’s Investment Dealer (Full Service Dealer, SEC-2.1B) licence issued by the Financial Services Commission of Mauritius (FSC Mauritius).

1. Purpose

The purpose of this Policy is to:

Ensure that the Services are made available only to persons who have sufficient knowledge and experience to understand the nature and risks of the products offered
Establish a framework for assessing user appropriateness at the time of account registration and on an ongoing basis
Ensure that users who may not be appropriate for leveraged and derivative financial products are adequately warned before accessing the Services
Comply with applicable conduct of business obligations under the laws of the Republic of Mauritius

2. Scope

This Policy applies to:

All prospective users seeking to register for a live trading account with the Company
All existing users of the Services in respect of any material change to the products or risk profile of the Services they access
All products made available through the Services, including Contracts for Difference (CFDs), foreign exchange (forex) instruments, and other leveraged derivative products

This Policy does not apply to users accessing only demo (paper trading) accounts, as no real funds or leveraged positions are involved.

3. Regulatory Basis

3.1 Appropriateness Assessment (Execution-Only Services)

The Company provides trading services on an execution-only basis. It does not provide personal investment advice, portfolio management, or discretionary services.

For execution-only services involving complex or leveraged financial instruments (including CFDs and forex instruments), the Company is required under applicable FSC Rules to assess whether the client has the necessary knowledge and experience to understand the risks involved in the type of products and transactions envisaged, before allowing access to those products.

This assessment is referred to as an appropriateness test or appropriateness assessment.

3.2 Distinction from Suitability

Where the Company provides a personal recommendation (which it does not do in the ordinary course of its execution-only business), a full suitability assessment — incorporating the client’s financial situation and investment objectives as well as knowledge and experience — would be required. The appropriateness assessment described in this Policy is a lesser assessment applicable to execution-only services and does not constitute an assessment of the overall suitability of the Services for a given user’s personal financial circumstances.

4. Appropriateness Assessment — Information Collected

As part of the account registration process, the Company collects information from prospective users to assess appropriateness. This information includes, but is not limited to, the following categories:

4.1 Knowledge and Experience

Whether the user has traded, or has experience with, financial instruments of a similar nature (including CFDs, forex, derivatives, or equities)
The frequency and duration of any such prior trading activity
Whether the user has received formal education, training, or professional qualifications relevant to financial markets, trading, or investment management
The user’s level of familiarity with concepts such as leverage, margin, mark-to-market valuation, and contract roll

4.2 Financial Situation

The user’s approximate annual income or revenue
The user’s approximate investable assets or net worth (excluding primary residence)
The proportion of the user’s overall financial resources that the user intends to allocate to trading through the Services

4.3 Investment Objectives and Risk Tolerance

The user’s primary purpose in using the Services (e.g., speculation, hedging, supplemental income)
The user’s self-assessed risk tolerance
Whether the user can afford to sustain losses up to and including the total amount deposited, in view of their financial situation

5. Outcome of the Appropriateness Assessment

5.1 Appropriate

Where the Company’s assessment of the information provided indicates that the user has sufficient knowledge and experience to understand the risks of the products being offered, the user will be assessed as appropriate and permitted to access the full Services (subject to completion of identity verification and other onboarding requirements).

5.2 Not Appropriate — Risk Warning

Where the Company’s assessment indicates that the user may not have sufficient knowledge and experience to understand the risks, the Company will:

Provide the user with a clear and prominent risk warning notifying them that the Company considers the product or service not appropriate for them based on the information provided
Require the user to affirmatively acknowledge receipt of that warning before proceeding
Record the warning and the user’s acknowledgement

Where the Company issues a not-appropriate warning, the user may still proceed to access the Services at their own initiative, provided they acknowledge the warning. The Company’s obligation is to warn, not to prevent access in all cases. The Company will however refuse access or restrict access in cases of particularly high assessed risk or where required by applicable law or regulatory guidance.

5.3 Insufficient Information

Where a prospective user declines to provide sufficient information to complete the appropriateness assessment, or provides information that cannot be adequately assessed, the Company will:

Warn the user that the Company is unable to determine whether the products are appropriate for them
Require the user to acknowledge the warning before proceeding
This outcome shall be treated in the same manner as a not-appropriate determination for the purposes of risk warning and recordkeeping

6. Re-Assessment

The Company may require a user to complete a refreshed appropriateness assessment in the following circumstances:

Where the user seeks access to a new class of product that was not covered by the initial assessment
Where the Company has reason to believe that the user’s circumstances have materially changed
Where the Company’s policies or applicable regulatory requirements change in a manner that necessitates re-assessment
At periodic intervals as determined by the Company’s compliance function

7. Reliance on User-Provided Information

The Company relies on the accuracy and completeness of information provided by users in connection with the appropriateness assessment. Users are required to provide accurate and up-to-date information.

The Company is not required to verify the accuracy of information provided by users, except where it is apparent on the face of the information that it is inaccurate. Where a user provides information that is, or appears to be, inaccurate or misleading, the Company reserves the right to:

Decline to complete the appropriateness assessment
Treat the user as not appropriate
Restrict or suspend access to the Services

The Company will not be liable for any adverse outcome arising from a user’s provision of inaccurate information.

8. Execution-Only Limitation and No Advice

The Services are provided on an execution-only basis. The appropriateness assessment does not constitute, and must not be construed as:

A personal recommendation to trade any specific instrument
Investment advice or guidance tailored to the user’s personal circumstances
An endorsement of the user’s trading strategy or objectives
A guarantee that any instrument or strategy will be profitable

Users are solely responsible for their investment and trading decisions. The Company strongly encourages users to seek independent professional advice before committing funds to leveraged or derivative products, particularly where the user has limited prior trading experience.

9. Record Retention

The Company maintains records of:

The information collected from users as part of the appropriateness assessment
The outcome of the assessment (appropriate / not appropriate / insufficient information)
Any warnings issued and the user’s acknowledgement thereof

Records are retained for the minimum period required under applicable laws and regulatory obligations and in accordance with the Company’s data retention practices set out in its Privacy Policy.

10. Review and Amendment

This Policy is reviewed at least annually, or following any material change in the Company’s product suite, applicable regulatory requirements, or FSC guidance on appropriateness assessments.

This Policy should be read together with the following documents:

12. Contact Information

For enquiries relating to this Policy, please contact:

Kohle Capital Markets Limited
Email: CS@kcmtrade.com
Website: https://www.kcmtrade.com