PAMM Manager Agreement

1.1 This Agreement establishes terms for professional trading managers providing PAMM account management services through Pure Portal platform.

1.2 Managers are independent contractors responsible for managing investor capital according to approved trading strategies.

1.3 Managers must possess minimum 6 months trading experience and $10,000 minimum account balance. Full background verification required.

1.4 Managers responsible for all trading decisions, risk management, and performance reporting. Company provides infrastructure only.

1.5 Managers must comply with AML/KYC regulations, position limits, and leverage restrictions. Violations result in account suspension or termination.

1.6 Compensation based on management fees (1-5% AUM) and performance fees (20-30% of profits). High-water mark principle protects investors.

1.7 Manager accepts personal liability for trading losses and investment performance. Investors do not guarantee returns.

1.8 Termination available with 30 days notice by either party. Immediate termination for fraud or regulatory violations.

2.1 Qualification Requirements: Minimum 18 years age, 6 months active trading history, positive trading record, $10,000+ account balance, clean compliance record.

2.2 Background Verification: Full identity verification, source of funds check, regulatory history review, sanctions screening, criminal background check conducted.

2.3 Account Activation: Manager account created through platform, bank details verified, fee structure configured, marketing materials approved, account activated.

2.4 Manager Profile: Manager creates trading profile showing experience, strategy, track record. Profile visible to potential investors on platform.

2.5 Initial Minimum: Managers must maintain $10,000 minimum balance. Account closed if balance falls below minimum for 30 consecutive days.

2.6 Compliance Certification: Managers certify compliance with all laws, trading restrictions, and Company policies before activation.

2.7 Risk Acknowledgment: Managers acknowledge investment risk, market volatility, potential for losses, and personal liability for trading.

2.8 Ongoing Requirements: Managers must maintain compliance, provide accurate reporting, respond to audits, cooperate with investigations.

3.1 Trading Authority: Manager has exclusive authority to trade PAMM account. All trading decisions made by manager independently.

3.2 Best Execution: Manager must achieve best execution for all trades through appropriate liquidity providers and execution quality standards.

3.3 Position Limits: Maximum position size limited to $100,000 per trade or 5% of account equity, whichever is smaller.

3.4 Leverage Limits: Maximum 1:200 leverage on forex. Leverage on CFDs limited to asset class maximums. Margin requirements strictly enforced.

3.5 Stop Loss Requirements: Managers required to maintain appropriate stop loss levels for all positions. Accounts suspended if stop loss requirements violated.

3.6 Risk Management: Daily position monitoring, margin monitoring, volatility assessment, portfolio concentration review, liquidity management.

3.7 Prohibited Trading: Market manipulation, spoofing, insider trading, grinding, abusive order practices strictly prohibited and monitored.

3.8 Trading Records: Complete records maintained for all trades. Audit trail available for regulatory review. Records retained minimum 5 years.

4.1 Management Fee: Annual fee (1-5%) calculated on average monthly assets under management. Deducted monthly from account equity.

4.2 Performance Fee: Fee on profits only (20-30%) applied monthly. High-water mark principle applies - fees only on new profit peaks.

4.3 Fee Example: $100,000 account with 2% mgmt fee + 20% performance fee earning $5,000 profit = $200 mgmt + $1,000 performance fee.

4.4 Payment Terms: Fees deducted automatically monthly. Deductions visible on daily statements. Fee calculations transparent and auditable.

4.5 Fee Transparency: All fees disclosed upfront. Investors review and approve fee structure before investment. No hidden fees permitted.

4.6 Fee Changes: Managers may adjust fees with 30 days notice. Existing investments grandfathered 60 days. New investments subject to new fees.

4.7 Performance Tracking: Monthly performance reports provided. Annual audit available on request. Fee calculations independently verified.

4.8 Tax Responsibility: Managers responsible for all tax obligations on earned fees. Company provides annual fee statements for tax reporting.

5.1 Investor Communication: Managers must respond to investor inquiries within 24 hours. Monthly webinars or updates recommended.

5.2 Performance Reporting: Daily P&L reports, monthly detailed performance reports with trade analysis, quarterly performance review letters.

5.3 Trade Transparency: All trades disclosed to investors. Trade-by-trade detail available. Rationale for trades may be summarized.

5.4 Account Transparency: Daily statement showing equity, margin, P&L, positions, fees. Monthly consolidated reports with analysis.

5.5 Communication Channels: Secure messaging through platform, email updates, performance dashboard access, regular investor communications.

5.6 Withdrawal Processing: Investor withdrawals processed within 10 business days. Manager must close positions to meet withdrawal requests.

5.7 Professional Conduct: Managers must maintain professional standards in all investor communications. Misrepresentation prohibited.

5.8 Confidentiality: Trading strategies may be confidential but performance results disclosed to investors. Client lists confidential.

6.1 Regulatory Compliance: Managers operate under Vanuatu FSC regulations. Full compliance with AML, KYC, sanctions screening required.

6.2 AML/KYC: Managers verify investor identity, source of funds, trading purpose. Ongoing transaction monitoring conducted.

6.3 Sanctions Screening: Managers prohibited from accepting investors from sanctioned jurisdictions. Screening conducted on account opening.

6.4 Trading Restrictions: Managers must comply with position limits, leverage limits, stop loss requirements. Violations result in suspension.

6.5 Account Monitoring: Company monitors manager accounts daily for compliance. Automated systems detect violations in real-time.

6.6 Audit Rights: Company may audit manager accounts for compliance. Managers must cooperate with audits and provide documentation.

6.7 Regulatory Reporting: Managers may be required to report to financial authorities. Managers authorize regulatory reporting by accepting Agreement.

6.8 Compliance Violations: Violations result in warning, fee reduction, trading restrictions, account suspension, or termination depending on severity.

7.1 Segregated Funds: All investor funds held in segregated accounts separate from Company operating funds. Client funds not used for Company operations.

7.2 Risk Monitoring: Daily monitoring of account risk metrics. Accounts suspended if drawdown exceeds 30%. Managers notified immediately.

7.3 Margin Maintenance: Strict margin monitoring. Forced liquidation if maintenance margin not met. Manager liable for liquidation losses.

7.4 Position Concentration: Concentration limits prevent over-exposure to single trade. Maximum 20% of account in single position.

7.5 Drawdown Limits: Maximum 30% account drawdown before account restriction. Maximum 50% drawdown before account closure.

7.6 Volatility Alerts: Real-time alerts when volatility exceeds thresholds. Manager may reduce leverage or close positions.

7.7 Insurance and Reserves: Company maintains reserves to cover settlement discrepancies. Segregated funds protected under Vanuatu law.

7.8 Emergency Procedures: If system failure occurs, Company halts trading and protects positions. Manager notified immediately.

8.1 Termination for Convenience: Either party may terminate with 30 days written notice. Manager may close account with 30 days notice.

8.2 Immediate Termination: Company may terminate immediately for fraud, material misrepresentation, regulatory violations, or prohibited conduct.

8.3 Account Closure Process: Upon termination, all positions closed at market rates. Investor funds returned within 5 business days.

8.4 Final Accounting: Final performance report provided at closure. All fees calculated through closure date. Remaining equity returned to investors.

8.5 Post-Termination: Manager may not solicit investor clients for 12 months. Non-compete clause prevents competing broker referrals for 12 months.

8.6 Dispute Resolution: Disputes first addressed through negotiation with Company. Unresolved disputes proceed to mediation in Port Vila.

8.7 Arbitration: If mediation fails, disputes submitted to arbitration under Vanuatu Arbitration Act. Single arbitrator for disputes under $50,000.

8.8 Governing Law: Agreement governed by Vanuatu law. Disputes resolved in Vanuatu courts or arbitration. Prevailing party may recover attorney fees.