Refund and Cancellation Policy

Vertex Capital & Tech Limited — Trading as Vorum Capital

1. INTRODUCTION

1.1 Purpose and Scope

This Refund and Cancellation Policy ("Policy") governs the circumstances under which Vertex Capital & Tech Limited ("the Company"), trading as Vorum Capital, will process refunds, withdrawals, and account cancellations, and the conditions and timeframes applicable to each.

This Policy applies to all clients of the Company and to all deposit and withdrawal methods available on the Company's platform. It should be read in conjunction with the Terms and Conditions (Section 8 — Withdrawals), Client Agreement (Section 5 — Deposits and Withdrawals), and the Fraud Prevention Policy.

This Policy is also provided to the Company's payment processing partners as part of their merchant due diligence requirements.

1.2 Nature of the Company's Services

The Company provides online trading services in foreign exchange (FX) and Contracts for Difference (CFDs). These are financial products in which the client's outcome depends on market price movements. The key principle that distinguishes trading services from e-commerce is:

> Trading losses are not refundable. When a client places and loses a trade, the loss is the result of market price movements — a risk the client explicitly accepted by opening the position. Trading losses are not a product defect, a service failure, or an unauthorized charge.

This Policy is designed to be clear and fair: funds deposited but not traded are returned upon request; genuine trading outcomes are not.

2. REFUND POLICY

2.1 Refund of Untraded Funds

Eligibility: A client who has deposited funds that have not been used in any completed trading activity is entitled to a full refund of the unused balance, subject to the conditions in this Section.

Conditions for refund of untraded funds:

(a) The client has completed KYC verification (refunds cannot be processed to unverified accounts);

(b) There are no open positions that would be affected by the withdrawal;

(c) There are no compliance, AML, or fraud investigation holds on the account;

(d) The client has no outstanding obligations to the Company (unpaid fees, debit balance, etc.);

(e) The account is not subject to any applicable bonus conditions that restrict withdrawal.

Refund destination: Untraded funds are refunded to the same payment method used for the original deposit (same-source policy). See Section 5 for details.

Processing time:

• Amounts up to USD 5,000: 1–5 business days from approval;
• Amounts above USD 5,000: up to 21 business days from approval.

2.2 Funds Subject to Open Positions

Where a client holds open leveraged positions, a portion of the account balance is allocated as margin. The portion of the balance allocated as margin for open positions is not available for refund until those positions are closed. The client may:

(a) Close all open positions and then request a full refund of the remaining balance; or

(b) Request a partial refund of free margin (the balance above the required margin level) while keeping open positions active.

The Company will not forcibly close open positions to process a refund request unless the client explicitly instructs it to do so and the positions are in the client's name.

2.3 Trading Losses — Not Refundable

Trading losses are not refundable. This includes:

• Losses from trades that the client placed and then lost;
• Losses from margin calls or Stop Out events;
• Losses resulting from adverse market movements while the client held open positions;
• Overnight financing (swap) charges applied in accordance with the published swap rates;
• Inactivity fees applied in accordance with the published fee schedule;
• Spread costs built into the bid/ask price of each trade.

Exception — Company error: If a trading loss is demonstrably attributable to a material Company error (e.g., a proven pricing error, an incorrect trade execution at materially wrong price, or a platform malfunction that caused a position to be opened or closed contrary to the client's instruction), the client may file a complaint under the Complaints Handling Procedure. If the complaint is upheld, the Company will calculate and credit an appropriate adjustment.

2.4 Fee Refunds

The Company will process a refund of specific fees in the following circumstances:

Routine fees applied correctly in accordance with the published fee schedule are not refundable.

2.5 Deposit Errors

2.5.1 Error by Client

Where a client deposits more than they intended due to a keyboard error or similar mistake, the excess is treated as an untraded balance and subject to the withdrawal policy (Section 3). Processing times are the same as standard withdrawals.

2.5.2 Error by Company System

Where a deposit error is attributable to a malfunction of the Company's payment processing system (duplicate charge, incorrect amount processed), the Company will:

• Correct the error within 5 business days of the error being identified and verified;
• Refund any excess amount to the original payment method;
• Notify the client in writing of the correction made.

2.5.3 Double Charge

In the rare event that a client is charged twice for a single deposit intention (technical duplicate), the Company will refund the duplicate charge within 5 business days of the duplicate being identified.

3. WITHDRAWAL POLICY

3.1 Withdrawal Eligibility

Withdrawals are available to:

• Fully KYC-verified clients;
• Clients with no compliance holds on their account;
• Clients with a positive account balance after accounting for open position margin requirements;
• Clients who have not triggered a withdrawal restriction due to active bonus conditions.

3.2 Minimum Withdrawal Amount

The minimum withdrawal amount is USD 50 (or equivalent in the account base currency). Withdrawal requests below this threshold may be declined at the Company's discretion, except where the request represents the entire remaining balance on the account.

3.3 Withdrawal Processing Timeframes

The following timeframes apply from the date the withdrawal request is approved (i.e., after all verification and compliance checks are completed), not from the date of submission:

Important notes on timeframes:

• The above times relate to the Company's processing. Additional time may be required by the receiving bank or payment processor (typically 1–5 additional business days for bank transfers; near-instantaneous for PIX in Brazil);
• Timeframes may be extended where enhanced verification is required;
• Cryptocurrency withdrawals (where available) are subject to blockchain confirmation times in addition to the Company's processing time;
• The Company does not process withdrawals on weekends or public holidays in Saint Lucia;
• Large withdrawals (above USD 25,000) are subject to the 21 business day maximum to allow adequate time for enhanced compliance review, coordination with payment processors, and AML/CFT verification.

3.4 Withdrawal Methods

Withdrawals are processed to the same payment method used for the original deposit. The same-source policy exists to:

• Prevent money laundering (return of funds to their source);
• Protect clients against unauthorized withdrawal to third-party accounts;
• Comply with applicable AML/CFT requirements.

Where the original payment method is no longer available (card expired, account closed), the client must provide evidence and the Company will determine the most appropriate alternative, subject to enhanced verification.

3.5 Withdrawal to Different Account

Requests to withdraw to a different account from the one used for deposit are treated as high-risk and are subject to:

• Full re-KYC verification (including proof of ownership of the new destination account);
• Compliance Officer review and approval;
• Potential additional documentation to establish a legitimate reason for the change;
• Extended processing time of up to 21 business days.

The Company reserves the right to decline requests to withdraw to different accounts where the request cannot be satisfactorily explained or verified.

3.6 Withdrawal Restrictions

The Company may delay or refuse a withdrawal request in the following circumstances:

Clients are notified promptly of any withdrawal delay and the general reason (where disclosure is not legally prohibited).

4. CANCELLATION POLICY

4.1 Account Cancellation by the Client

A client may close their trading account at any time by submitting a written cancellation request to:

• Email: support@vorumcapital.com (subject: "Account Closure — [Account Number]")
• Client Portal: My Account → Settings → Close Account

Upon receipt of a valid cancellation request:

(a) Any open positions are closed at the prevailing market price, either automatically or upon the client's instruction (the Company will advise the client of any open positions before proceeding);

(b) The remaining account balance (after settlement of all open positions, fees, and outstanding obligations) is withdrawn to the client's registered payment method within the applicable withdrawal timeframe;

(c) The account is deactivated after the final withdrawal is processed;

(d) KYC and account records are retained in accordance with the record-keeping requirements of the AML/KYC Policy (minimum 5 years post-closure);

(e) There is no cancellation fee for closing an account;

(f) Clients who close their account may re-apply to open a new account in the future, subject to the Company's then-current eligibility and KYC requirements.

4.2 Account Closure by the Company

The Company reserves the right to close a client's account at its sole discretion in the following circumstances:

5. SAME-SOURCE POLICY — ANTI-MONEY LAUNDERING BASIS

The Company's same-source refund and withdrawal policy is not merely an administrative preference — it is a fundamental AML/CFT control. Returning funds to their source:

(a) Prevents the Company from being used as a mechanism to layer illicit funds (deposit stolen funds, then withdraw to a "clean" account);

(b) Ensures that the beneficial owner of the funds is the same person who deposited them;

(c) Provides a complete and traceable audit trail for all fund movements;

(d) Aligns with the FATF 40 Recommendations on financial institution AML obligations.

Requests to circumvent the same-source policy will be treated as potential red flags and reviewed under the AML/KYC Policy.

6. HOW TO REQUEST A REFUND OR WITHDRAWAL

6.1 Standard Withdrawal Request

Submit through the Client Portal:

vorumcapital.com → My Account → Withdraw

6.2 Written Request

For complex situations, written requests may be submitted to:

• Email: support@vorumcapital.com (Subject: "Withdrawal / Refund Request — [Account Number]")
• In Portuguese: suporte@vorumcapital.com (Assunto: "Pedido de Saque — [Número da Conta]")

6.3 Complaint Relating to Refund

If you believe a refund has been incorrectly refused or delayed, submit a formal complaint to:

compliance@vorumcapital.com (Subject: "COMPLAINT — Withdrawal Dispute — [Account Number]")

Complaints are handled in accordance with the Complaints Handling Procedure with a maximum response time of 30 business days.

7. CONTACT

Client Support: support@vorumcapital.com

In Portuguese: suporte@vorumcapital.com

Compliance / Disputes: compliance@vorumcapital.com

Website: vorumcapital.com