1. The terms form a legally binding agreement between you, the person who uses the Shyft App and us.
2. Pay special attention to the sections that are in bold , as they may exclude or limit our liability (responsibility) to you or involve some risk for you.
3. By ‘accepting’ the terms when you sign up for the Shyft App and by continuing to use the Shyft App, you agree to these terms and represent and warrant that you are at least 18 years of age and capable of entering into a legally binding agreement.
4. The terms take effect (start working) when you sign up for the Shyft App.
5. We may change the terms from time to time, and the latest version will apply to you each time you use the Shyft App.
6. You must know, understand and comply with the terms.
7. The terms apply together with the latest version of the Standard Bank General Terms and Conditions (general terms), including any definitions, privacy statement and disclaimers that are incorporated by reference into the general terms. If there is any conflict between the terms and the general terms, the terms will apply to the Shyft App.

The words below have the meanings set out next to them unless the context indicates a different meaning. Defined words and expressions are in italics in the terms.

We have included hyperlinks in these terms to other information that may apply to you. To view the information you will need to copy the entire web address (starting with "http://" or “https://” and ending with ".html" or ".co.za") and paste it in your browser. You must read any information that applies to you, because it forms part of these terms. If you cannot read any linked information, please contact us through Shyft support.

1. To be able to use the Shyft App you must be a permanent resident, a foreign national residing in South Africa or a non-resident. You also must also be 18 or older.
2. You must provide us with all information and documents required by FICA if we do not already have them.
3. To sign up you must provide your email address, identity number and any other information that we request. We will send you an email to confirm whether your registration has been successful. Once your registration has been confirmed and we have all the information and documents required by us and FICA, you can start using the Shyft App.
4. If you upload your FICA documents to the Shyft App using our digital onboarding process, it may take up to 48 hours for us to verify your information.
5. You will be required to confirm that you have read and understood and accept these Terms.
6. We may decline your application to register for the Shyft App and may also decline future applications by you, for any reason.
7. Standard data costs will be charged by your internet service provider every time you use the Shyft App.

1. When you top up your wallet, you must use the unique reference to allow us to allocate your payment correctly. It may take up to seven business days for the funds to reflect in your wallet.
2. We will not be responsible for any losses you may suffer if there is a delay in the funds reflecting in your wallet because of circumstances outside our control, for example if you enter the incorrect reference.
3. You can transfer funds out of your wallet and into an account held in your name (receiving bank account) by clicking on the withdraw button and entering the details of the receiving bank account. We are not responsible for any losses you may suffer if you provide us with incorrect, incomplete or invalid bank account details.
4. Transfers to receiving bank accounts can take up to seven business days to clear and be reflected in the receiving bank account. You must be the primary accountholder of the receiving bank account – funds must not be transferred out of your wallet into a bank account that is held by a third party.
5. We will not be responsible for any losses you may suffer if the bank where the receiving bank account is held rejects or delays any payment you make to such bank.
6. Buying and selling foreign currency
7. You can use the Shyft App to buy and sell foreign currency, being US Dollars, Pound Sterling, Australian Dollars or Euros, where the following codes are used:
   1. for residents, FinSurv Reporting Categories Code 511 04 (investment by a resident individual not related to the investment allowance – deposits with a foreign bank);
   2. for foreign nationals, BOP Category Code 417 (foreign national contract worker remittances, excluding compensation);
   3. for non-residents, BOP Category Code 510/02 (Investment by a non-resident individual – other).
8. The exchange rate applicable to buying or selling foreign currency is determined by us. You will not be charged any commission or fees when buying or selling foreign currency using the Shyft App except where you make a payment from your wallet to a beneficiary’s account.
9. Once you have provided all the requested information, the exchange rate will be displayed. The exchange rate will be updated from time to time and a new exchange rate will be displayed, which may or may not be the same as the previous exchange rate.
10. You can have one wallet for each type of foreign currency offered on the Shyft App. Each wallet can only be loaded with one type of foreign currency.
11. If you are exchanging foreign currency between wallets, for example buying Euros with US Dollars, your US Dollars wallet will be debited and your Euros wallet will be credited as soon as you accept the exchange rate.
12. If you want to cancel, change or stop an instruction relating to buying or selling foreign currency after you have sent it to us, you must contact us through Shyft support. Please note that we may not be able to cancel, change or stop the instruction and you will be liable for any fees or losses that we may incur while attempting to do so.
13. If you want to buy or sell foreign currency after hours or when the markets are closed, we will offer you an exchange rate which may be higher than the last available exchange rate.
14. When you accept the exchange rate and the terms and make the declaration applicable to your purchase of the foreign currency, the exchange rate will be booked and you will be liable for all amounts owed to us in this regard.
15. Please note that you will not earn interest on any currency in a wallet.

1. You can use the Shyft App to make international payments from a wallet.
2. You are not permitted to make an international payment without giving us the requested information and adhering to the regulations and any other applicable laws. However, we may require additional information from you at any stage of the international payment process, including after the international payment has been made, and you must provide such additional information to us as soon as possible after being requested to do so.
3. You are not permitted to make an international payment if you are not compliant with FICA.
4. Please note the following when using the Shyft App to make an international payment:
   1. Your daily payment limit will apply when you wish to make an international payment. This means that you will not be able to make an international payment if you have exceeded your daily payment limit.
   2. If you are a foreign national, you are not permitted to make an international payment with funds that you brought into South Africa or that are ring-fenced. Only funds that you have received or earned in South Africa can be used. You confirm, by accepting these terms and making international payments, that all funds transferred using the Shyft App have been received or earned in South Africa.
5. We will charge you a fee for making the international payment. Our fees and charges are displayed on the Shyft App.
6. You must ensure that you have enough funds in your wallet to make the international payment. The relevant wallet will be debited with the payment amount as well as the relevant fees.
7. Please note that you will not earn any interest on the amount debited from the wallet from the date on which it is debited to the date of payment to the beneficiary.
8. You accept that an international payment takes a minimum of two business days to be completed. This period may be extended, or the international payment may be delayed due to circumstances beyond our control or in terms of applicable laws or the laws in the jurisdiction of the beneficiary’s bank or any correspondent or intermediary bank. If this happens, we will contact you and you must provide the information required by the beneficiary’s bank, the intermediary bank or the correspondent bank as soon as possible.
9. Where an international payment is delayed, suspended, cancelled or not completed for any other reason, due to circumstances beyond our control, we will need a minimum of 14 days to investigate the reason for the delay or temporary suspension. We cannot guarantee a specific outcome or guarantee that information will be available during or after our investigation, as we depend on the intermediary or correspondent bank assisting us. If the delay, suspension or cancellation is imposed by the intermediary or correspondent bank because the beneficiary needs to provide information or complete compliance processes, the beneficiary must fulfil the requirements and comply with the instructions of the intermediary or correspondent bank for the international payment to be paid to the beneficiary.
10. If the international payment reflects in our system as “paid” or “completed” but has not been received by the beneficiary, you must contact the beneficiary directly and ask them to contact the correspondent or intermediary bank for resolution. We will make every reasonable effort to trace the international payment, where possible. However, we are reliant on the beneficiary and correspondent banks to update us. We will provide you with these updates when we receive them.
11. If the international payment is delayed by the beneficiary’s bank, a correspondent bank or intermediary bank, we cannot recall or reverse it.
12. If we are required to cancel an international payment because of any applicable laws or the laws in the jurisdiction of the beneficiary’s bank, a correspondent bank or an intermediary bank after your wallet has been debited,  you will not receive the full value of the international payment due to our fee charges.
13. You cannot cancel an international payment after you have instructed us to make the payment.
14. If you want to recall an international payment, you can contact us through Shyft support and we will do our best to contact the beneficiary’s bank to request that the international payment be recalled; however, we cannot guarantee that the international payment can or will be recalled. We rely on responses from the beneficiary’s bank network to process any recalls and payments could take 6 weeks or more to be returned to us. Please note that the decision about whether to accept or reject a request for the recall of the international payment is in the sole discretion of the beneficiary’s bank.
15. If the beneficiary’s bank agrees to recall the international payment and returns the payment to us, we will credit your wallet from which the international payment was made with the amount received from the beneficiary’s bank, less our fees and any fees charged by the beneficiary’s bank. Please note that, due to exchange rate fluctuations, this may not be the same amount as the value of the international payment.
16. If the beneficiary’s bank rejects our request to recall the international payment, you may still have to pay fees charged by the beneficiary’s bank and we will debit these fees from your wallet. In these cases, you will not receive any amounts from us for the international payment and will need to contact the beneficiary directly for a refund.
17. We will not be liable (responsible) for any loss you or any third party may suffer if an international payment is delayed, suspended, cancelled or not completed for any other reason. If you cancel an international payment, you indemnify us (hold us blameless) against any loss or damage that we may suffer arising from the cancellation.

1. You can receive an international payment in USD, GBP, EUR or AUD into your corresponding USD, GBP, EUR or AUD wallet. The international payment must be greater than the minimum values that we set from time to time, otherwise we will reject it. We will also reject any Rand amounts received via SWIFT. Any international payment that we reject will be returned to the sender.
2. International payment times are unpredictable and there may be delays. We will only credit funds to your wallet once we have received them and we can only confirm that we have received the funds once we receive a valid proof of payment (MT103) from the sender.
3. You can pay USD, GBP, EUR or AUD directly into your USD, GBP, EUR or AUD wallet using the bank account specified in the “Top Up” wallet section. If you or the sender makes a payment in a currency that differs from the currency of the pocket, the funds will be rejected and returned to sender at the sender’s cost.
4. You may receive payments from any foreign bank account into your wallet. If a third party makes a payment to your wallet, we may request additional information from time to time. This may include information and supporting documentation such as:
   1. Remitter information
   2. Proof of address
   3. Source of funds
   4. Any other related documentation
5. We will only credit your wallet once we have received all the information and documentation we ask for and if they meet our compliance requirements. If you or the sender cannot provide this, we will return the international payment to the sender.
6. We will deduct our fee from  incoming international payments before we credit your wallet, so you will not receive the same amount that was originally sent. Third parties, such as the sending bank or correspondent banks may also charge fees which will reduce the value of the international payment. We will credit your wallet with the amount we receive, less our fees.

1. You will pay all costs associated with the transfer of the international payment and the beneficiary will pay all costs associated with receiving the international payment. This includes the beneficiary’s bank’s fees and any correspondent or intermediary bank’s fees, which means that the beneficiary will not receive the full amount of the international payment after the beneficiary’s bank’s fees and any correspondent or intermediary bank’s fees have been deducted from the international payment. We do not have any control over the amount of the fees charged by the beneficiary’s bank and any correspondent or intermediary bank.
2. Our fees are set at a flat rate and are charged in the currency in which you make the international payment. SWIFT fees may also apply to the international payment.
3. Our fees will be displayed for you to accept before you proceed with the international payment.
4. You authorise us to debit your wallet with any amounts relating to the international payment, including our fees.
5. Please note that when making an international payment using the Shyft App, you will not qualify for any special rates or existing allowances that would otherwise be available if you were making payments using other platforms (for example, staff rates, private client rates and special pensioner rates).

1. You can make a payment directly into the wallet of another registered Shyft user using the Shyft App (Shyft-to-Shyft payment). Shyft-to-Shyft payments may only be made in a single currency. For example, you cannot make a Rand payment into the US Dollar wallet of another user.
2. From time to time, we may impose limits on the amounts you can send or receive in respect of Shyft-to-Shyft payments per month.
3. We keep all records relating to Shyft-to-Shyft payments (including details of the parties and amounts transferred) for a period of five years and are required to make them available to FinSurv on request.

1. You can use the Shyft App to create a virtual card, which can be credited with funds from your wallet. You can apply for up to 10 virtual cards for each type of currency available on the Shyft App.
2. Once you have created your virtual card, we will provide you with a 16-digit virtual card number, an expiry date and a three-digit CVV security code.
3. The virtual card can be used where a physical card is not required (for example on the internet, over the phone or by mail order). It cannot be used where a physical card is required, such as face-to-face transactions at merchants, financial institutions or automated teller machines.
4. To make payments with the virtual card you must give the merchant the card number, expiry date and three-digit CVV security code.
5. A virtual card cannot be used for a transaction that exceeds the available balance on the virtual card. For such a transaction you can pay the difference by another method if the merchant agrees.
6. The virtual card is valid for one year from the date of issue or until the value of the virtual card has been used, whichever is earlier. You can deactivate (stop) and reactivate the virtual card at any time during this period. When the virtual card expires, the remaining balance will be moved to your wallet or account.
7. You can view the balance and transaction history of a virtual card on your profile.
8. The terms in Schedule 1 of the terms apply to your use of the virtual card.

1. When you apply for a Shyft card, you can choose which wallet will be debited with the amount to be credited to the Shyft card.
2. You can top up (credit) your Shyft Card using the Shyft App whether you are in South Africa or abroad, as long as you have access to the Shyft App and sufficient funds in the relevant wallet.
3. You will only be able to use your Shyft Card outside the CMA.
4. You can also use the Shyft App to order a Shyft ZAR card. You will only be able to:
   1. use the Shyft ZAR card in South Africa;
   2. use the Shyft ZAR card for transactions in Rand; and
   3. top up the Shyft ZAR Card with Rand.
5. The terms in Schedule 1 of the terms apply to your use of the Shyft card and the Shyft ZAR card.

1. We may delay or suspend payment of a transaction where:
   1. the amount is not in line with our risk detection parameters (these are measures that we use to help us categorise, evaluate and prioritise risks and they are confidential to us); or
   2. we believe that the transaction, or the batch it is in, is invalid, is linked to any prohibited activity or may harm someone.
2. We may immediately block your card in the following instances, among others:
   1. If we suspect that sanctions will be imposed on you or that you are involved in any activity that does not comply with applicable laws.
   2. If your card has expired and you have not ordered a replacement card.
   3. If you have breached the terms.
   4. If we don’t have all the documents and information we require in terms of FICA.
   5. If we suspect that we or you are exposed to risk through your use of the card.
   6. If we are required by law or by any regulatory authority or payment scheme or ordered by a court of law to do so.
3. Where possible, we will try to give you notice before we block your card. Depending on whether or not it is necessary to protect our rights and those of any affected third parties, we may also secure the money related to the impacted transaction and transfer it into a suspense account.
4. There are circumstances under which transactions can still be processed even after the card is blocked. You are liable for all such transactions.

You can use the Shyft App to use the Shyft Investments product. The terms in Schedule 2 of the terms apply to Shyft Investments.

1. The SDA is provided by the FinSurv to residents who are 18 years old or older. It allows for transactions of up to R1 000 000 per annum, starting on 1 January and ending on 31 December, without requiring you to obtain a tax clearance certificate or provide any documentary evidence.
2. The SDA and dispensation to carry out transactions without the production of any documentary evidence must not be used to disguise transactions that may be refused under normal circumstances.
3. As a resident, once your SDA has been fully used for the calendar year, you will no longer be able to use the Shyft App to buy foreign currency. However, you will still be able to use the other functions offered by the Shyft App. Alternatively, you can conclude further transactions for certain FinSurv Reporting Categories Codes at a Standard Bank branch by providing the required supporting documentation and tax clearance certificate, if necessary.
4. As a resident you acknowledge and declare that:
   1. you are aware of the SDA limit of R1 000 000 for each calendar year;
   2. no transaction will cause you to exceed the SDA limit; and
   3. the transaction falls under the BOP Category Code 511 044 (investment by a resident individual not related to the investment allowance – deposits with a foreign bank).
5. As a foreign national you acknowledge and declare as follows:
   1. The transaction falls under BOP Category Code 417 (foreign national contract worker remittances, excluding compensation).
   2. You will not buy foreign currency with funds that you brought into South Africa or that are ring-fenced. Only funds that you have received or earned in South Africa will be used.
6. If you are a non-resident, we may impose transaction limits from time to time.
7. You must make an electronic FinSurv or a BOP declaration before the transaction is completed. If you make a false declaration, you may have to pay a fine or face prosecution.
8. We are required to report transactions to the FinSurv and, in the case of foreign nationals and non-residents, for the purposes of BOP Reporting. You confirm that the information you have given us for both FICA and reporting to the FinSurv is up to date, true and correct. If required to do so, we may also report the transaction to SARS.
9. You acknowledge that we may be required by various laws to provide your personal information to the Financial Intelligence Centre, the FinSurv and/or SARS.
10. You can not make international payments that require documents to be given to Standard Bank or the FinSurv. Only international payments that do not require such documents may be made.
11. You must make sure that you comply with all regulations.

1. When you use the Shyft App you communicate with us using a device, so there is no direct personal contact between you and us.
2. We will act on all instructions that come from you, even if they are actually coming from someone pretending to be you. After you have successfully signed up for the Shyft App, we may assume that any activity or instruction that we receive from you through the Shyft App is genuine. Even if someone else used your profile or password to send us an instruction through the Shyft App, we may carry out an instruction as if you have authorised it.
3. We are not responsible for any loss or damage you suffer if you enter the wrong details for a transaction or because you repeated a payment instruction (sent it through more than once) and we then made more than one payment. You waive (give up) any claim against us if this happens.

1. You must keep your password secret and safe – someone who knows it could access your profile and steal your money or use your profile information illegally.
2. It is not safe to keep your password on a device.
3. You waive (give up) any claim you may have against us for any loss or damage you may suffer if you have not kept your password safe.
4. No person ever has a good reason to know or ask for your password, so you must never give it to anyone.

1. We are not responsible for any loss or damage you may suffer because someone uses your password or your device. We urge you to password-protect your device against any fraudsters or hackers trying to impersonate you.
2. Do not use any public device, for example a computer at an internet café. Public devices are not safe because you do not know what software or hardware may be on them. For example, they may use spyware to find out numbers or passwords you type on a keyboard. These could be used to find information about your profile and to defraud you or steal money.
3. If your device is lost, stolen or not in your possession (you do not have it with you), you have lost your password or you suspect that someone may have unauthorised access to your password, you must immediately use another device to access the Shyft App and reset your password or contact Shyft support and we will reset it for you. We will not be responsible for any losses you may suffer because you did not notify us. Neither we nor our service providers will be liable for any loss or damages of any kind that may arise as a result of the unauthorised use of your device or password by someone else, either with or without your knowledge.
4. We will never send you a link to disclose your personal information. Please send an email to phishing@standardbank.co.za to report phishing or any suspicious transactions.
5. Immediately inform us and your mobile network operator if your device is stolen or if you believe you have been a victim of a SIM swap and also report the incident to the police station.
6. Immediately change your email password and other passwords if you suspect that your email address or other personal information has been compromised or that your device has been stolen.

1. You must keep your device software up to date. If you do not, the Shyft App may not work properly and this could increase your security risks.
2. We do not guarantee or suggest that any file, download or application on the Shyft App is safe to use on any computer. We cannot guarantee that the system does not have software or data that can negatively affect a computer system, such as viruses, trojans and other malicious (dangerous) software.

You must promptly tell us if your contact details (including your email address and telephone number) change and ensure that we always have complete, accurate and up-to-date contact details for you. If you do not do this, it may impact your rights under these terms. For example, we may not be able to send you security tokens or send you fraud notifications or other important information, such as changes to the terms or any security guidelines relating to the use of the Shyft App and your card. We are not liable if circumstances beyond our control prevent you from receiving communications or security tokens, for example if your mobile network provider is having technical issues, your email address has been compromised or you are a victim of a SIM swap.

1. Defining intellectual property
2. We and our third-party licensors own the intellectual property rights
3. You have a limited right to use the intellectual property
4. We give you the right to use the intellectual property to use the Shyft App and perform transactions on the Shyft App. You may not use the intellectual property for any other purpose. This right starts when you start using the Shyft App and ends according to these terms. When your right ends you must immediately stop using any intellectual property on the Shyft App.
5. If our relationship with you in respect of the Shyft App ends for any reason, your right to access and use the Shyft App, the intellectual property in it, and where applicable, any Shyft card, Shyft ZAR card and virtual card will be cancelled and you must immediately stop all use of the Shyft App, the intellectual property in it and any Shyft card, Shyft ZAR card and virtual card.
6. Prohibitions on the use of intellectual property
   1. copy or claim to have any rights to the intellectual property;
   2. dispute or contest the validity of our ownership over the intellectual property; and
   3. damage the reputation and goodwill associated with our intellectual property.

You will cover (pay for) any loss or damages that we may suffer on your behalf if:

1. you breach any of these terms;
2. you give us wrong instructions or information; or
3. someone used your password or device to access the Shyft App without your permission and this was not due to our own negligence (carelessness).

1. Your use of the Shyft App depends on factors beyond our control, such as the network coverage or availability of your mobile network operator or internet service provider. We are not legally responsible and cannot be blamed for any loss or damages you may suffer if you cannot access the Shyft App due to factors beyond our control.
2. Information on the Shyft App is provided "as is" and we will not be responsible for any damages that may follow if you rely on it.
3. We (our owners, employees, consultants, agents or any person connected to the Group) are not responsible for any direct or indirect loss or damages related to your use of the Shyft App, for any reason, even if we were told that loss or damage was possible. We are not responsible for any loss or damages caused by:
   1. someone finding out your password and using it to register for the Shyft App, using your profile or fraudulently transacting on your Shyft App;
   2. any technical or other problems (interruption, malfunction, downtime or other failures) which affect the Shyft App, our banking system, a third-party system, any part of any database or your device, for any reason;
   3. any information being lost or damaged because of technical problems, power failures, unlawful acts (such as data theft), a harmful computer program or virus, or your own negligence (lack of care);
   4. any failure or problem affecting goods or services provided by any other party, for example, a telecommunication service provider (such as Telkom), mobile network operator, internet service provider, electricity supplier (such as Eskom), or a local or other authority; or
   5. any event that we have no direct or complete control over.
4. We do not support international payments or payments with virtual cards to Crypto Currency Exchanges. We will not be responsible for any loss you may suffer in connection with these payments, including losses resulting from failure to pay.

1. If you have any questions about the Shyft App or if there is anything you do not understand about these terms, please contact us through Shyft support.
2. We will try to resolve queries as quickly as possible, but this may be subject to delays beyond our control as we are reliant on the beneficiary’s bank and other third parties.

When the card is used in a transaction, we assume that this transaction has been authorised by you, even if it took place without your knowledge or consent or was not authorised by you. This means that unless you notified us beforehand of any unauthorised access to or use of your card or passwords, or your card is compromised (someone uses your card without your knowledge or permission), you are liable for all losses in connection with that transaction.

1. There are a number of ways in which you may be able to confirm a transaction. These include:
   1. signing your name;
   2. holding your card in front of a contactless card machine;
   3. entering your card PIN; and
   4. entering your card details and any other information required (including any passwords).
2. Before you confirm a transaction, you must check that the amount is correct and be sure you wish to proceed with the transaction.
3. After you have confirmed a transaction, it may need to be authorised. The available balance you can access will then be reduced. Sometimes a transaction will not be completed after it is authorised, for example where a merchant does not process their transactions until later. If this happens, the transaction amount may be deducted from your card sometime after the transaction took place. You must always make sure that you have enough money on your card to pay for the transaction, irrespective of when the merchant processes it, as you are liable to pay for it.
4. We have the right to decline any transaction, but we will typically only do this in the following instances:
   1. Where the transaction would cause you to exceed your available balance. (If, as a result of a transaction or the posting of other transaction fees, you exceed your available balance, this does not mean that we have extended credit to you and you must immediately take steps to correct this. You are responsible for keeping track of your available balance.)
   2. If the transaction would cause you to exceed any of the limits that apply to your card.
   3. If we believe the transaction is not aligned with the parameters we set for you.
   4. If we believe the transaction may be linked to any prohibited activity.
5. We are not liable if you suffer any loss because of our decision to decline a transaction.

1. You must take all necessary steps to prevent unauthorised or fraudulent use of your card and passwords.
2. You must comply with all security guidelines that we may provide to you from time to time. For example:
   1. When using your card at a merchant’s card machine, you must always keep the card in sight. Try to insert, swipe or tap your card yourself and not hand it over to a merchant or any other person to do this for you.
   2. If you are using an ATM (automated teller machine), always be alert and aware of your surroundings. Never accept help from strangers when using an ATM – if your card is swallowed (retained) by the ATM, or you think your card has been swallowed, contact us immediately to block your card.
   3. Do not write your card PIN on the card or anything that is kept with the card. Be careful that no one can see you enter your card PIN when you use it. To keep your card information confidential, always take your transaction receipts or ATM statements with you.
   4. Protect your passwords and keep them confidential and only use them for the transaction you have received them for – there is no reason for any person, including any of our employees, to use them or know about them. You are liable for the use of the passwords that you receive and for all activities carried out by means of the passwords. Even if you enter your passwords correctly, we cannot guarantee that the transaction is not subject to fraud.
   5. If someone manages to steal or compromise your card and they also have your passwords, they could use the card to do transactions up to the maximum limits that apply and transfer all the money out of your card account.

1. The fees for the use of the card are set out in our Pricing Guide at www.standardbank.co.za.
2. You will not be paid any interest on the available balance.

1. Security problems and unauthorised transactions
   1. If your card is lost or stolen, or if you believe that your passwords have been compromised or that your card has been used to do transactions without your permission, or if you become aware of any suspicious or unauthorised transactions on your card, you must contact us immediately to block your card. If you fail to do so, you may be liable for any losses that result from your failure to notify us or any delay in doing so.
2. Your liability for transactions before the card was blocked
   1. Any transaction where you breached these terms, before or after the card was blocked.
   2. Any transaction that you authorised against your card (including a recurring transaction, such as a magazine subscription), before or after the card was blocked.
   3. Any transaction that you authorised before the card was blocked but that was processed afterwards (for example if the original transaction was processed offline, or if the merchant processed the transaction late).
3. Other transaction disputes
   1. If you are not happy with goods and services you have purchased with your card or if you believe the merchant has charged you incorrectly, you should first try to resolve your dispute with that merchant. It is your responsibility to comply with any terms that a merchant imposes on you in respect of a transaction.
   2. If you have a dispute with a merchant, that dispute does not give you the right to do the following:
      1. Instruct us to refuse to pay the merchant for goods you purchased or services you obtained on your card. (If we make a payment to a merchant for your transaction, it is final.)
      2. Refuse to pay us for payments already made to the merchant, whether or not such payment was made in respect of the goods that are the subject of a dispute.
      3. Instruct us to reverse a payment already made to the merchant.
   3. Merchants are responsible for their transactions and they are separate from Standard Bank. We cannot be held liable if a merchant does not accept your card or if you have a complaint about goods or services that you paid for with your card.

1. In these Terms of Business (hereinafter “the Terms") and, unless the context indicates otherwise:
   1. account statement will mean a periodic statement of the transactions credited or debited to each of the Trading Portfolios (as the case may be).
   2. account summary will mean a statement of your securities portfolio, open positions, cash etc. at a specific point in time in respect of the Trading Portfolios but segregated per denominated currency.
   3. agent will mean an individual person or a legal entity undertaking a transaction on behalf of another individual person or legal entity but in his/its own name.
   4. authorised person will mean a person you authorise to give instructions to Standard Bank on your behalf.
   5. best execution policy will mean Standard Bank's prevailing policy, which is available at Standard Bank’s website, with regard to best execution when executing client orders.
   6. code of ethics will mean Standard Bank's prevailing code of ethics, which is available at http://www.standardbank.co.za.
   7. commissions charges schedule will mean the schedule of commissions, charges, interest and other rates that at any time may be applicable to the services as determined by Standard Bank from time to time. The commissions charges schedule is available on the Shyft App or is set out in an addendum to the Terms and may be supplied to you on written request.
   8. corporate actions will mean a corporate event that is initiated by the issuer of the securities and may impact the price of the relevant security. Corporate actions include share issues, mergers, conversions, share splits, sell-offs and dividends.
   9. dividend reinvestment rate will mean the rate, defined by the issuer of the securities, at which dividends will be converted into securities.
   10. durable medium means any instrument that enables you to store information in a way accessible for future reference for a period of time appropriate to the purposes of the information and which allows the unchanged reproduction of the information stored.
   11. events of default will have the meaning given to this term in Clause 35.4.
   12. ex-date will mean the effective date of the corporate action, which is the date on or after which a security trades without its previously declared dividend or distribution.
   13. inside information will mean non-published information that is likely to have a noticeable effect on the pricing of a contract if it is made public.
   14. instruction deadline will mean the deadline provided to you on the trading platform for you to give instructions regarding a corporate action.
   15. market maker will mean a professional participant in the financial markets who continuously offers purchase and sale prices for a financial instrument in order to buy and sell on behalf of interested clients.
   16. market rules will mean the rules, regulations, customs and practices of any exchange, clearing house or other organisation or market involved in, or otherwise relevant to, the conclusion, execution, terms or settlement of a transaction or contract and any exercise by any such exchange, clearing house or other organisation or market of any power or authority conferred on it.
   17. pay date will mean the value date of the corporate action or the date on which a dividend payment is made or scheduled to be made into the account.
   18. prevailing stocks will mean the form of securities prevailing after a merger between two entities.
   19. principal will mean the individual person or the legal entity that is a party to a transaction.
   20. security will mean any securities or other assets.
   21. services will mean the services to be provided by Standard Bank subject to the terms.
   22. settlement/trade confirmation will mean a notification, which may include an email notification or, in some instances, a pop-up image from Standard Bank to you confirming your entry into a transaction.
   23. trading portfolio will mean any trading portfolio, denominated in United States Dollar or other permitted currency, opened in your name and linked to your Shyft Wallet.
   24. trading platform will mean the Shyft Investments functionality on the Shyft App and any ancillary online trading platform used by Standard Bank under the terms.
   25. transactions will mean any instruction or order executed on your behalf.
2. If there is any conflict between the terms and relevant market rules, the market rules will prevail.

1. You acknowledge, recognise and understand that trading in non-leveraged transactions:
   1. is highly speculative; and
   2. may involve a certain degree of risk.
2. You acknowledge, recognise and understand that:
   1. When you direct Standard Bank to enter into any transaction, any profit or loss arising as a result of a fluctuation in the value of the asset or the underlying asset will be entirely for your account and risk.
   2. You cannot hold Standard Bank responsible for losses incurred because Standard Bank carried out your instructions and/or following its recommendations or suggestions or those of its employees, associates or representatives, unless Standard Bank has exercised gross negligence in this regard.
   3. Unless it is specifically agreed otherwise, Standard Bank will not conduct any continuous monitoring of transactions already entered into by you either electronically or manually. Therefore, Standard Bank cannot be held responsible if the transactions developed differently from how you may have presupposed and/or to your disadvantage.
   4. You have received no guarantees or similar representations from Standard Bank in respect of transacting on the trading platform.

1. Subject to the terms, Standard Bank hereby provides you with a non-exclusive, limited, personal, non-assignable and non-transferable licence to use the trading platform for the duration of the terms.
2. Standard Bank will, subject to the provisions of the terms, open a trading portfolio for you if you have applied for it and provided any additional documentation that Standard Bank requires. You acknowledge and agree that Standard Bank may update or amend the requirements to open further trading portfolios under the same wallet from time to time and that, following such amendment, you will provide Standard Bank with any further documentation that is required.

1. You acknowledge and agree to the following:
   1. Your funds will not be segregated from Standard Bank's funds and may be used by Standard Bank in the course of Standard Bank's business. In the event of Standard Bank's bankruptcy you will have an unsecured claim against the bankrupt estate as an ordinary creditor, but for securities you will have a secured claim provided that your securities are duly separated from the securities of other clients and Standard Bank's own securities.
   2. Standard Bank chooses its bankers at its own discretion and according to its internal policies.
   3. Standard Bank’s account with its bankers (available to you on written request) is not a segregated account. Therefore, in the event of the bankruptcy of its bankers, Standard Bank will have an unsecured claim against the bankrupt estate as an ordinary creditor. You indemnify and hold Standard Bank harmless against any claim arising from the bankruptcy of Standard Bank’s bankers.
   4. Even if you accepted the terms, Standard Bank will be entitled to reject any application to open any trading portfolio or any instruction at its sole discretion and will not be obliged to give reasons for rejecting the application.
   5. Subject to verification by Standard Bank and clause 10.7 below, Standard Bank will only conclude a transaction if it has sufficient funds available in the wallet. You understand and accept that you are responsible for ensuring that sufficient cumulative funds are available in the account and indemnify Standard Bank and hold Standard Bank harmless against any losses that you may suffer if a transaction is not executed because the funds available in your wallet are insufficient at the time Standard Bank receives the instruction.
   6. Standard Bank will, at its sole discretion, debit your wallet with any amount that becomes payable by you, whether in respect of a transaction or otherwise.
   7. You have read and will continue to ensure you understand the disclosures that are displayed on the Shyft App and trading platform from time to time.
   8. You will cooperate fully with Standard Bank, its regulators and/or the police in the event of any fraudulent or other activities on the trading portfolio. If you fail to do so, Standard Bank may limit or restrict access to the Shyft App and/or the trading portfolio.
2. You give consent for Standard Bank to share information relating to any of your trading portfolios and/or your wallet and any activity therein with any of Standard Bank’s affiliates or any relevant authority for the purpose of monitoring for market abuse, financial fraud and money laundering.

1. Subject to you fulfilling its obligations under the Terms, Standard Bank may enter into transactions for you in the following investments and instruments:
   1. a list of Security including stock or other indices as chosen by Standard Bank and notified to you from time to time;
   2. such other investments as Standard Bank may from time to time make available on the Trading Platform.
2. Orders may be placed as market orders to buy or sell as soon as possible at the price obtainable in the market. Limit and stop orders to trade when the price reaches a predefined level are not allowed.
3. In relation to any Transaction, Standard Bank shall act as an Agent for you.
4. You shall, unless otherwise agreed in writing, relative to Standard Bank, enter into Transactions as Principal. If you act as Agent, regardless of whether you identify the Principal to Standard Bank, Standard Bank shall not be obliged to accept the said Principal as a client, and consequently, Standard Bank shall be entitled to consider you as Principal in relation to the Transaction.
5. You acknowledge, recognise and understand that:
   1. All Transactions in exchange-traded investments will be effected subject to, and in accordance with, Market Rules;
   2. Market Rules usually contain far-reaching powers in an emergency or otherwise undesirable situation;
   3. If any exchange or clearing house takes any action which affects a Transaction, directly or indirectly, then Standard Bank is entitled to take any action relevant to the situation and reasonable to the parties in the interests of you and/or Standard Bank; 
   4. Standard Bank shall not be liable for any loss as further stipulated in Clause 37.4 and suffered by you as a result of the acts or omissions of any exchange or clearing house or any action reasonably taken by Standard Bank as a result of such acts or omissions unless Standard Bank has acted with wilful default;
   5. Where any Transaction is effected by Standard Bank as Agent for you, delivery or payment (as appropriate) by the other party to the transaction shall be at your entire risk;
   6. Standard Bank's obligation to deliver investments to you or to account to you or any other person on your behalf for the proceeds of sale of investments shall be conditional upon receipt by Standard Bank of deliverable documents or sale proceeds (as appropriate) from the other party or parties to the Transaction;
   7. Standard Bank may in whole or in part, on a permanent or temporary basis withdraw any account facility provided by Standard Bank to you. Situations where Standard Bank may take such actions include situations where:
      1. Standard Bank considers that you may be in possession of Inside Information;
      2. Standard Bank considers that there are abnormal trading conditions; or
      3. Standard Bank is unable to determine prices in the relevant Transaction due to the unavailability of the relevant market information.
   8. Standard Bank does not provide any advice to you on any tax or legal issues related to any Services. You are advised to obtain individual independent counsel from a financial advisor, auditor or legal counsel with respect to tax and legal implications of the respective Services.
   9. Notwithstanding any other provision of the Terms, in providing its Services, Standard Bank shall be entitled to take any action considered necessary and reasonable to ensure compliance with the Market Rules and all other applicable laws and regulatory decisions.

1. Standard Bank provides the services for use by you. You must not sell, lease, sub-license or provide the services to any third party, directly or indirectly, except as permitted in the terms or with Standard Bank’s written consent. Except for the extraction and reproduction of data pursuant to the normal and intended use of the services by you, no reproduction, extraction or re-use of any content of the services is authorised without the prior and express consent of Standard Bank.
2. You acknowledge that all intellectual and proprietary rights in the services are owned by Standard Bank or any third-party provider of information used by the services and the only rights you have in respect of the services are those specifically provided for in the terms. You undertake to defend, indemnify and hold Standard Bank and its officers, employees and the relevant members of Standard Bank’s affiliate group harmless against any infringement or alleged infringement by you, whether or not arising from your use of the services or of any patent, copyright, or trade mark of Standard Bank or any other third party.
3. You agree to be bound by the various legends, conditions of access, disclaimers, terms and conditions and instructions displayed on the Shyft App or related to the services (collectively, the “User Information”). You acknowledge and agree that Standard Bank has the right to change the functional and technical layout of the services, including the content of the User Information without prior written notice to you.
4. Notwithstanding any provisions in these terms, Standard Bank may terminate or suspend, with or without cause and with or without prior notice, all or any part of the services or your access to the services or the format, nature, composition or availability of the services.

1. You may provide Standard Bank with instructions digitally (which includes instructions provided via the Shyft App as described below) and in limited circumstances Standard Bank may accept instructions from you by telephone. Standard Bank will acknowledge receipt of the instructions orally or in writing, as appropriate, which will include an acknowledgement by way of an electronic confirmation message on the trading platform.
2. In addition to the Terms (and the Best Execution Policy) and the trading platform terms stated in Clause 8, the following terms apply to Transactions executed on the trading platform:
   1. Standard Bank will not be liable for any loss, expense, cost or liability suffered or incurred by you due to failure of the system, transmission failure or delays or similar technical errors unless Standard Bank has wilfully defaulted in this regard.
   2. Even where real-time tradable prices are available to you, the price offered by Standard Bank may have changed before Standard Bank received an order from you. This is due to delayed transmission between you and Standard Bank. If automatic order execution is offered to you, Standard Bank will be entitled to change the price on which your order is executed to the market value at the time the order was received from you.
   3. The trading platform may be available in several versions, which may differ in respect of the level of security applied, products and services available etc. Standard Bank will not be liable to you for any loss, expense, cost or liability suffered or incurred by you because you used a version different from Standard Bank's standard version with all available updates installed.
   4. You will be responsible for all orders and for the accuracy of all information sent through the Shyft App or by any other acceptable means using your name or password or any other personal identification.
   5. Regardless of the fact that the Trading Platform might confirm that a transaction is executed immediately when you transmit instructions through it, only the settlement/trade confirmation forwarded by Standard Bank constitutes Standard Bank's official confirmation of execution.
3. Any instruction sent through the trading platform by you will only be deemed to have been received and will only then constitute a valid instruction when such instruction has been recorded as executed by Standard Bank and confirmed by Standard Bank to you through the settlement/trade confirmation and/or account Statement and the mere transmission of an instruction by you will not constitute a binding contract between Standard Bank and you.
4. You must promptly provide Standard Bank with any instructions it may require. If you do not provide such instructions promptly, Standard Bank may, at its reasonable discretion and at your expense, take any steps that it considers necessary or desirable for its own protection or yours. This provision is similarly applicable in situations where Standard Bank is unable to contact you.
5. Standard Bank may (but will not under any circumstances be obliged to) require confirmation, in such form as Standard Bank may reasonably request, if an instruction is to close any of the Trading Portfolios, your Wallet or remit money due to you or if it appears to Standard Bank that such confirmation is necessary or desirable.
6. Standard Bank may refuse to act upon any instruction from any person authorised by you if Standard Bank considers that the disposal pursuant to the instruction submitted would be in violation of the legislation relevant to the area, market rules, usual market practice, including but not limited to legislation on money laundering or insider trading, or if the disposal by Standard Bank's reasonable discretion will put your and/or the bank's economic solidity at risk.
7. In general, Standard Bank will act according to instructions as soon as practically possible and will, as far as trading instructions are concerned, act consistent with the best execution policy. However if, after instructions are received, Standard Bank believes that it is not reasonably practicable to act upon such instructions within a reasonable time, Standard Bank may defer acting upon those instructions until it is, in Standard Bank's reasonable opinion, practicable to do so or notify you as soon as possible that Standard Bank is refusing to act upon such instructions.
8. It is possible that errors may occur in the prices of transactions quoted by Standard Bank. In such circumstances, without prejudice to any rights it may have under South African law, Standard Bank will not be bound by any Transaction which purports to have been made (whether or not confirmed by Standard Bank) at a price which:
   1. Standard Bank is able to substantiate to you was manifestly incorrect at the time of the Transaction; or
   2. was, or ought to have reasonably been known by you to be, incorrect at the time of the transaction,
9. You agree that Standard Bank may, without notice, record all telephone conversations, internet conversations (chat) and meetings between you and Standard Bank and use such recordings, or transcripts from such recordings, as evidence towards any party (including, but not limited to, any regulatory authority and/or court of law) to whom Standard Bank at its reasonable discretion considers it to be desirable or necessary to disclose such information in any dispute or anticipated dispute between Standard Bank and you. However, technical reasons may prevent Standard Bank from recording a conversation and recordings or transcripts made by Standard Bank will be destroyed in accordance with Standard Bank's normal practice.

1. The right to use the trading platform is personal and you must not allow other persons to use your user ID or password.
2. From the trading platform you can print reports on trading activities and your account balances.
3. Orders may be cancelled, at your request, up until the time of execution. Standard Bank is under no obligation to cancel the order. Orders and cancellations can be done through the trading platform or you can call Standard Bank’s call centre during its hours of operation at the contact numbers specified on the Shyft App. An order will not be considered to be cancelled until you have received a written confirmation from Standard Bank.
4. Standard Bank may modify, suspend or discontinue the trading platform, whether temporarily or permanently, without notice.

Standard Bank is entitled to do anything required to give effect to the terms and to render the services including the following:

1. It can sign any document (including forms of acceptance, letters of renunciation and transfer forms) or agreement on your behalf and appoint any third party.
2. Apply and subscribe for any securities or investments in accordance with the terms.
3. Do whatever is necessary, at its discretion, to protect your rights.

1. You understand and accept that in order to ensure the correct and timely allocation of funds to your trading portfolio, you will only be allowed to transfer funds from your Wallet.
2. For all transfers the funds are booked and at disposal on the relevant trading portfolio after the funds are cleared in your Wallet, provided the funds have actually been cleared and all the relevant information has been provided.
3. You further acknowledge and agree that you will only be entitled to trade when there are sufficient cleared funds reflecting in your wallet.
4. You further acknowledge and agree that events as described in clause 37.4 can cause the booking and availability of funds to be delayed for as long as such events continue.
5. All amounts paid by you to Standard Bank and by Standard Bank to you will be denominated in the currency denominating the trading portfolio into which a payment or refund will be made in the corresponding denominated currency. Should you wish to use funds in a wallet of a different currency you will be required to convert the funds into a currency that is denominated for the relevant trading portfolio.
6. You may trade from a trading portfolio that is not in the currency in which the trade is denominated, subject to the applicable currency conversion fees and commission charges.
7. In the event that you conclude a transaction from a trading account that has a negative cash balance, you will be subject to the interest charges referred to in clause 14 below. The interest will accrue until you pay the outstanding amount due thereon.

1. You will pay to Standard Bank on demand:
   1. any sums that may be required for clearing a debit balance on any of your Wallets;
   2. any amount required for maintaining a positive cash balance on any of your Wallets.
2. If you make any payment that is subject to price fluctuations, withholdings or deductions, you will pay to Standard Bank any additional amount required to ensure that the amount Standard Bank actually receives is the full amount it would have received had no price fluctuations occurred and had no moneys been withheld or deducted.
3. Payments into the various wallets are credited by Standard Bank on condition that it actually receives the amount in question in its bank account. This will apply whether or not it has been explicitly stated in receipts or other notices of or requests for payment.
4. You cannot put up, as collateral or guarantee for any of your obligations towards a third party, any securities held or deposited into the relevant trading portfolio with Standard Bank.
5. All securities will be held by an intermediate broker or eligible custodian appointed by Standard Bank that will be responsible for claiming and receiving all interest payments, income and other rights accruing to you.
6. Standard Bank will not be obliged to account to you for any income it receives for carrying out any of the activities described in this clause.
7. If you fail to provide any deposit or other amount due under the terms in respect of any transaction, Standard Bank may close any open position without prior notice to you and apply the proceeds thereof to payment of any amounts due to Standard Bank or any third party. This is further regulated in clause 35.
8. If you fail to make a payment when it falls due, you will pay interest (from the due date and until payment takes place) on the outstanding amount at an interest rate determined by Standard Bank.
9. Standard Bank will have the right, in addition to any other rights it may have under the terms and notwithstanding anything contained herein, or under South African law in general, to limit the size of your open positions and to refuse orders to establish new positions. Standard Bank will inform you as soon as possible regarding such refused orders and the reason for the refusals. Situations where Standard Bank may exercise such right include the following:
   1. Standard Bank has reason to believe that you may be in possession of Inside Information.
   2. Standard Bank considers trading conditions to be abnormal.
   3. You have a negative cash balance on any wallet.

1. Standard Bank will make available to you a settlement/trade confirmation in respect of any Transaction you enter into. Confirmations will normally be available shortly after the execution of the transaction.
2. An account summary and an investment portfolio statement are available to you through the trading platform. The account summary will normally be updated periodically during the day. The investment portfolio statement will normally be updated every business day with information about the previous business day. Any fees or charges that are levied monthly will only update at the end of the relevant period. By accepting the terms, you agree not to receive any account statements or account summaries in printed form from Standard Bank other than at your specific request.
3. Standard Bank may send any notice or other communication to be provided by Standard Bank under the terms, including account statements and settlement/trade confirmations, to you in electronic form by email or by display on your account summary on the trading platform if it so chooses. You are obliged to provide Standard Bank with an email address for this purpose. An email message is considered received by you when sent from Standard Bank. Standard Bank is not responsible for any delay, alteration, re-direction or any other modification the message may undergo after transmission. A message on the trading platform is considered received by you once Standard Bank has placed it there. It is your responsibility to ensure that your software and hardware setup does not prohibit you from receiving emails or gaining access to the trading platform.
4. You are obliged to verify the contents of all documents, including documents sent in electronic form from Standard Bank. Such documents will, in the absence of manifest error, be deemed conclusive unless you notify Standard Bank in writing to the contrary immediately after you have received them. If you believe you have entered into a transaction that should have produced a settlement/trade confirmation or otherwise a posting on your account, but have not received such confirmation or seen such posting, you must inform Standard Bank immediately by contacting the call centre at the number or email address where you ought to have received such confirmation. In the absence of such information the transaction may, at Standard Bank's reasonable discretion, be deemed non-existent.

1. You will be obliged to pay to Standard Bank the charges set out in the commission charges schedule, which is available on the trading platform or set out in an addendum to these terms and may be supplied to you on request.
2. Standard Bank may vary such charges without notice when the change is to your advantage, or when the grounds for changes are due to external circumstances beyond Standard Bank's control, such as changes in charges from exchanges, clearing houses, information providers or other third-party providers that are passed on to you by Standard Bank.
3. Standard Bank may vary such charges on one month’s notice, which may be given by email, published on the trading platform or set out in the addendum to the terms at Standard Bank’s discretion if:
   1. market conditions, including competitive behaviour, call for changes to Standard Bank conditions;
   2. Standard Bank, for commercial reasons, wishes to change its general cost and pricing structure; and/or
   3. significant details regarding you, based on which individual conditions were provided, have changed.
4. In addition to such charges, you will be obliged to pay all applicable VAT and other taxes, storage and delivery charges, exchange and clearing house fees and all other fees incurred by Standard Bank in connection with any transaction and/or in connection with maintaining your relationship with Standard Bank and maintaining the account.
5. Furthermore, Standard Bank will be entitled to demand that you pay the following expenses separately:
   1. all extraordinary disbursements resulting from your relationship with us, e.g. telephone, telefax, courier and postal expenses in case you request hardcopy settlement/trade confirmations, account statements and other documents that Standard Bank could have delivered in electronic form;
   2. any expenses incurred by Standard Bank as a result of non-performance by you, including a fee determined by Standard Bank for forwarding reminders, legal assistance etc.;
   3. any expenses incurred by Standard Bank in connection with replies to inquiries by public authorities, including a fee determined by Standard Bank for forwarding transcripts and enclosures and preparing copies of these; and
   4. any expenses incurred by Standard Bank in connection with auditor's comments/reports if you requested these.
6. The fees will be charged either as a fixed amount corresponding to payments made, or as a percentage or hourly rate corresponding to the service performed. The methods of calculation can be combined, and Standard Bank reserves the right to introduce new fees.
7. Standard Bank may share commissions and charges with its affiliates or other third parties or receive remuneration from them in respect of transactions it enters into.
8. Unless specified otherwise in the terms, all amounts due to Standard Bank (or agents used by Standard Bank) under the terms will, at Standard Bank's option:
   1. be deducted from any funds held by Standard Bank for you; or
   2. be paid by you in accordance with the provisions of the relevant difference account, settlement/trade confirmation or other advice.
9. Furthermore, you acknowledge, recognise and accept that the procedures described in clause 33 may result in additional indirect costs to you.

1. Subject to the provisions below and unless otherwise agreed in writing, Standard Bank will not be liable to:
   1. pay interest to you on any credit balance in any of the wallets or on any other sum held by Standard Bank; or
   2. account to you for any interest received by Standard Bank on such sums or in connection with any transaction.
2. Standard Bank may vary such interest rates and/or thresholds for interest calculation without notice when changes are to your advantage, or when the grounds for changes are due to external circumstances beyond Standard Bank's control, such as the following:
   1. changes in domestic or foreign monetary or credit policies that affect the general interest level in a way that is of importance to Standard Bank;
   2. other changes in the general interest level, including changes in the money and bond markets, that are of importance to Standard Bank;
3. Standard Bank may, at its own discretion, vary such interest rates on one business day’s notice on the Website or by email, if:
   1. market conditions, including competitive behaviour, call for a change to Standard Bank’s conditions;
   2. Standard Bank wishes to change its general commission, fee and pricing structure for commercial reasons; and/or
   3. there were changes to significant details about you, based on which individual conditions were provided.
4. You are deemed to have accepted such changes if you do not notify Standard Bank, before the proposed date on which they enter into force, that you do not accept them.
5. Standard Bank is entitled, but will not under any circumstances be obliged, to convert:
   1. any realised gains, commissions, interest charges and brokerage fees that arise in a currency other than your currency (i.e. the currency in which the trading portfolio is denominated) to the base currency in your wallet;
   2. any cash currency deposit to another cash currency deposit for the purpose of purchasing an asset denominated in a currency other than the base currency in your wallet.
6. Standard Bank will conduct any currency conversions at a reasonable rate of exchange that it will select and will be entitled to add a mark-up to the rate.

1. You are personally liable for the market risk inherent in Securities trading and for any investment in securities that Standard Bank is requested to perform on your behalf as well as any subsequent loss resulting from the investment.
2. You acknowledge that Standard Bank may from time to time carry out investments for you in securities in which the market is or could become limited and which are therefore difficult to deal in and for which it may be difficult to assess a proper market price.

• Execution of Orders
• When executing an order, Standard Bank will, through its third-party dealer or the relevant market participant, endeavour to secure the best execution reasonably available given the circumstances, including price, costs, speed, likelihood of execution and settlement, volume, nature and other factors relating to the execution of the order.
• Standard Bank will, through its third-party dealer or the relevant market participant, execute your order as soon as possible and to the extent possible on the day of receipt, unless otherwise agreed.
• Under exceptional market conditions (as detailed in clause 30.26 below) Standard Bank reserves the right not to submit an order for execution.
• You will be notified on the trading platform if an order cannot be executed.
• If Standard Bank is unable to obtain and deliver the requested securities, it may be unable to complete your purchase order. The trade will therefore be cancelled, unless Standard Bank is able to obtain the Securities at the usual terms no later than two banking days (in the relevant market) after the value date in question.
• Standard Bank will cancel any order for a security if the security is suspended or transferred to the observation list on the relevant exchange.

Standard Bank will submit orders for execution at your request and recommends that you use the trading platform when trading securities as this provides for swift client identification and thus faster processing of your orders. If you submit an order in another manner, Standard Bank manually verifies the basis of the relevant order before processing and this may result in an extended processing time.

1. Standard Bank offers only transactions and orders as market orders:
   1. Standard Bank offers market orders for securities listed on the relevant stock exchanges. When you have chosen a market order, Standard Bank, through its third-party dealers or market participants, inputs the order directly into the trading system of the relevant stock exchange.
   2. The nature of market orders entails that the trade is done at your expense but in the name of the third-party dealer or the relevant market participant.
   3. Standard Bank is entitled to cancel automatic order routing immediately on your behalf in the case of extraordinary circumstances, including those set out in clause 23.
   4. You cannot enter an order into the trading platform on conditions similar or identical to those of another unexecuted trade that you have entered into the trading platform system.
   5. You must not disclose public market information made available through the trading system of the relevant stock exchange.
2. Executing market orders
   1. You may enter a market order through the trading platform during the trading hours of the relevant stock exchange. Orders communicated to Standard Bank in a different manner will be handled intra-day, provided you submitted the order.
   2. Trades executed on the various stock exchanges are subject to the rules and directives of the relevant stock exchange. For orders you submitted through the trading platform, information about the choices available will be provided on Shyft App or on the trading platform.
   3. An order is executed only to the extent that counterparties are available at the relevant stock exchange.
   4. If an order is submitted outside the relevant stock exchange’s market hours, it will be processed when the market reopens, provided the processing is not restricted by the duration of the order. If an order is partially executed at the closing of the market, the remainder of the trade will be executed when the stock exchange reopens.
   5. All prices quoted on the trading platform will be delayed by 15 minutes in relation to the real-time price on the exchange where the order will be executed.
   6. Pricing for an order quoted on the trading platform will include an amount designated as a market buffer (which will be determined at Standard Bank’s sole discretion). The market buffer allows Standard Bank to ensure that there are sufficient funds in the trading platform to cater for changes in the price of a security from the quoted price to the actual price at time of execution of the trade.
   7. If you place an order outside the trading hours of the relevant exchange and the price of your order, at the time the exchange opens, changes to such an extent that the funds allocated to your trading platform (including any market buffer) are insufficient, then Standard Bank reserves the right to debit your account or wallet even this this results in a negative cash balance on the account or wallet .
   8. You may cancel orders that have not yet been executed and were placed outside the trading hours of the relevant exchange, provided that you only cancel such orders 30 minutes after the exchange has closed for the day and within the first 30 minutes after it has opened for the day.
3. Standard bank also offers transactions and orders as limit orders
   1. Standard Bank offers limit orders for securities listed on the relevant stock exchanges. When you have chosen a limit order, you set the maximum purchase price, or minimum sale price, at which the trade is to be executed. As a limit order may be entered away from the current market price, it may not be executed immediately. If you leave a limit order, you must be aware that you are giving up the certainty of immediate execution in exchange for the expectation of getting an improved price in the future.
   2. You will be able to place limit orders connected to market orders, average price transactions and commission trades in securities. You may limit an order in a defined period, should you want to buy or sell at a specific price. If the price within the period equals or breaches the price indicated, the trade will be executed.
   3. When entering a market order via the trading platform, you must limit the relevant order. However, when executing a market order outside the trading platform, you may add a limit order. If you do not limit a market order, Standard Bank, as well as market makers, market participants and third party service providers will assess at which price your order should be executed.
   4. If you have limited an average price transaction, Standard Bank will only submit the trade for execution, provided it may take place at a price that equals or outperforms the limit price after taking into account Standard Bank’ prevailing mark-up/down for the “all trades” price.
   5. If you have agreed on limiting a trade in securities, Standard Bank will submit the trade for execution only if it can trade at the limit price with its third party broker or relevant market participant. If the order is partially executable, only the non-executed part will be cancelled. You are made aware of the trading terms for limit orders as stipulated by the various stock exchanges.

1. Orders that are entered into the order book and trades that have been merged automatically in or entered into the Trading Platform, must reflect the relevant Securities’ current market value and represent actual orders and trades.
2. The “current market value” of a trade is the price that, based on an overall assessment, reflects the current pricing of the relevant securities. An assessment of the current market value will include the pricing of the instrument on the relevant day, any change in pricing on previous days, the volatility of the instrument and any general change in the pricing of comparable instruments and, if appropriate, any other specific conditions of the trade in question.
3. An order does not reflect the current market value if it has been entered into the order book at a price that, provided the trade is performed automatically, naturally will result in a trade that does not reflect the current market value. The validity of an order must be considered when the current market value is assessed.
4. Standard Bank is entitled to cancel orders and trades that do not reflect the current market value of the relevant security but cannot be held liable for any cancellation of an order or trade.
5. A failed trade will be declared at a specified time on the settlement date in accordance with applicable laws and/or the rules of the relevant stock exchange.

Under exceptional circumstances (as set out in clause 23) and to ensure market integrity a relevant stock exchange may cancel any trade if required.

1. Standard Bank trades securities through its third-party broker or through a market participant that is a member of the relevant stock exchange. The third-party dealer or the market participant decides whether the trade in question is to be executed on the relevant stock exchange. The trade is performed on a commission basis and consequently in the name of Standard Bank or Standard Bank’s third-party broker or the relevant market participant.
2. Your order is submitted for execution only if it is tradable on the relevant stock exchange through the third-party service provider or the relevant market participant. If the trade cannot be executed on the terms outlined above, you will be notified on the trading platform.
3. Your order may be split or merged and can therefore be executed at different prices during the day of trading or on the following days. If an order is split and filled partially over a period of more than one day, the total trading costs may increase. The reason for the increase is that the minimum fee may be charged more than once based on the number of days necessary for the total execution of the order.

1. Standard Bank settles the trade at the market prices available to Standard Bank through its third-party brokers or the relevant market participants. Payment and delivery take place through foreign clearing centres and third-party brokers or the relevant market participants.
2. “Settlement” refers to the payment and delivery related to a Securities trade. The settlement date may be the third exchange day after the trading day or any other day stipulated by the rules of the relevant stock exchange. The settlement day is also the value date. Specific settlement rules and deadlines apply to securities. You may obtain information from Standard Bank about these rules and deadlines.
3. When you purchase securities, you obtain unconditional title of right to the securities only if the final payment to Standard Bank is made on the settlement date. Until final payment is made, Standard Bank reserves the right to the securities you are purchasing. When you sell securities to Standard Bank, Standard Bank's payment of the settlement amount is subject to acquisition, by Standard Bank’s third-party brokers or the relevant market participants, of unconditional title to the securities on the day of settlement.

1. Standard Bank will charge a set fee for each securities transaction.
2. Submitting orders in any manner other than through trading platform may result in increased trading costs.
3. The prevailing trading costs are available on the commissions charges schedule, found on the Shyft App, or are set out in an addendum to the terms.

In exceptional market conditions, Standard Bank reserves the right not to submit an order for execution. Exceptional market conditions may occur where there is a significant deviation between bid and offer prices, where market prices are unavailable for the relevant security or in the event of sudden uncertainties in the global market, or any error that is not subject to any doubt, or an incident caused by a technical or manual mistake at the stock exchange, at Standard Bank or by you, a significant and indisputable violation of legislation or directions or the rules of the relevant stock exchange or any technical disruption in trading and/or clearing systems that is beyond the control of Standard Bank.

You will be notified, through the trading platform, of any corporate action affecting your holdings in the securities. Some of the more common types of corporate actions you may encounter are dividends, stock splits, reverse splits, spin-offs, rights issue, mergers and acquisitions, buybacks, bonus issues and delistings. You are advised to refer to the announcement made by the issuer for the actual or final terms of the relevant corporate action as these may differ from the descriptions provided on the trading platform.

1. Special and infrequent corporate actions not listed above may occur.
2. Special local rules may apply to certain corporate actions and you will be notified on the trading platform of such rules.

You are hereby made aware and acknowledge that in voluntary corporate actions where the alternative to a cash settlement is the settlement in a security that is not supported by Standard Bank, its third-party broker or the relevant market participant, you will not have the option to choose but will be given the cash settlement.

1. It is standard practice, for depositary receipts, to charge an annual administration fee per share depending on the issuing depositary bank. The fee is intended to cover costs for the banks that take on the operational processes necessary to issue and trade the depositary receipt line. Typically, the fee is deducted when dividend payments are made. However, where the depositary receipts do not pay a dividend or did not include the custodial fee in their dividend events, the fee will be administered through fee-only events.
2. The dividend fee is stipulated in the deposit agreement between the depositary bank and the company and is based on industry standards.
3. The fee per depositary receipt is not dependent on the total amount of the dividend being paid but on the amount of the Securities held.

Standard Bank may charge commission and fees in respect of corporate actions. The prevailing trading costs are available on the commissions charges schedule on the Shyft App and are set out in an addendum to the terms.

Taxes and fees may also occur on corporate actions in addition to those that apply to cash dividends, such as fees on a stock dividend or tax on a merger. When such taxes and fees occur, Standard Bank will debit your trading portfolio or wallet accordingly.

You acknowledge and accept that the structure of the custodial relationship between Standard Bank and its third-party brokers or market participants is not practical for you to instruct and exercise any voting rights in respect of any Securities held in your Trading Portfolio.

1. By opening and operating the trading portfolio with Standard Bank, you authorise Standard Bank or Standard Bank’s appointed third-party service provider (Third-party Service Provider) to appoint a custodian to hold on your behalf, for safekeeping, any securities that you deliver to Standard Bank or that Standard Bank buys or receives on your behalf.
2. Standard Bank, through its Third-party Service Provider, will deposit your securities or any part thereof for safekeeping in a central securities depository or electronic scrip registry and may deposit the securities in the depository or registry through a participant chosen by the Third Party.

1. You understand and accept that in order for your securities to be held in the depository referred to in clause 31.2, they must be held in an electronic, uncertificated manner (Dematerialised).
2. Any securities referred to in clause 30.34 must be held in an account in the name of the Third-party Service Provider or, if the Third-party Service Provider is not a participant on that exchange, in an account in the name of the nominee (Nominee) of the participant with whom the Third-party Service Provider deposits the securities.
3. Notwithstanding the aforegoing, Standard Bank will ensure that the securities held in the name of the Third-party Service Provider or the Nominee will be ringfenced from the other assets of that Third-party Service Provider or Nominee.
4. Standard Bank may request a withdrawal of your securities or any part thereof from safe custody only to:
   1. deliver them to you in accordance with your written instruction to deliver them to a third-party securities broker. (In the case of dematerialised scrip, you must give Standard Bank written information required for effecting the transfer.)
   2. deal with the Securities under the terms.
   3. settle transactions in accordance with applicable laws and the rules or regulations of the relevant stock exchange.
   4. lodge the securities on your behalf with any person under a court order or a special resolution of the issuer of the securities approved by the shareholders and, where applicable, sanctioned by a court of law.
   5. accomplish any other lawful purpose under these Terms.

Standard Bank is, in accordance with the best execution policy, entitled to aggregate your orders with its own orders and the orders of any of its affiliates and/or persons connected with Standard Bank including employees and other clients. Furthermore, Standard Bank may split your orders when executing them. However, the orders will only be aggregated or split if Standard Bank reasonably believes it to be in your best interests. On some occasions, aggregation and splitting of your order may result in a less favourable price for you than if the order had been executed separately or mutually.

Standard Bank, its affiliates or other persons or companies connected with Standard Bank may have an interest, relationship or arrangement that is material to a transaction carried out or advice provided by Standard Bank, under the terms, that may be in conflict or in competition with your interests. By accepting the terms and Standard Bank's code of ethics you agree that Standard Bank may transact such business in terms of its conflict of interest policies and management procedures.

1. The provisions contained in this clause supplement any other rights that Standard Bank or any of its affiliates have under the terms and under South African law.
2. Standard Bank reserves the right to retain, or make deductions from, any amounts it owes to or is holding for you if any amounts are due by you to Standard Bank or Standard Bank’s affiliates.
3. You authorise Standard Bank, at Standard Bank's discretion, at any time and without notice, to sell, apply, off-set and/or charge in any manner any or all of your property and/or the proceeds of any of the same of which Standard Bank or any of its affiliates or Agents has custody or control, in order to discharge any or all of your obligations to Standard Bank or to Standard Bank's affiliates.
4. Each of the following events will, in addition to any other specifications in the terms, also constitute an event of default in respect of all your transactions, securities and other business with Standard Bank (even if the Event of Default only relates to part of the business with Standard Bank):
   1. if you fail to make any payment or to do anything else required under the terms or by Standard Bank at its reasonable discretion;
   2. if you die or become of unsound mind;
   3. any action, taken by Standard Bank, that Standard Bank reasonably considers necessary for its own protection or the protection of its affiliates.
5. In an event of default, Standard Bank will at its discretion be entitled:
   1. To sell or charge in any way any or all of your assets and property that may be in the possession or control of Standard Bank or any of its affiliates or agents or call on any guarantee, without any notice or court order. Sale of security, assets and property will take place by means that Standard Bank at its reasonable discretion determines and at the price that Standard Bank at its reasonable discretion determines to be the best obtainable.
   2. To buy or sell any Security, investment or other property where in Standard Bank’s reasonable opinion this is, or is likely to be, necessary in order for Standard Bank to fulfil its obligations under any transaction and you will reimburse Standard Bank for the full amount of the purchase price plus any associated costs and expenses.
6. You authorise Standard Bank to take any or all of the steps described in this clause without notice to you and acknowledge that Standard Bank will not be responsible for any consequences of its taking any such steps, unless Standard Bank has exercised gross negligence in this regard. You will execute the documents and take any action that Standard Bank may request in order to protect the rights of Standard Bank and its affiliates under the terms or under any agreement you may have entered into with Standard Bank's affiliates.
7. If Standard Bank exercises its rights to sell any of your security or property under this clause, it will carry out such sale, without notice or liability to you, on your behalf and apply the proceeds of sale in or towards the discharge of any of your obligations to Standard Bank or Standard Bank's affiliates.
8. Without prejudice to Standard Bank's other rights under the terms or under prevailing law, Standard Bank may, at any time and without notice, combine or consolidate any of the accounts you maintain with Standard Bank or any of its affiliates and off-set any and all amounts owed to, or by, Standard Bank or any of its affiliates in any manner that Standard Bank at its reasonable discretion may determine.

1. You represent and warrant that:
   1. investments or other assets supplied by you for any purpose will, subject to the terms, at all times be free from any charge, lien, pledge or encumbrance and will be beneficially owned by you;
   2. you are in compliance with all laws to which they are subject including all tax laws and regulations, exchange control requirements and registration requirements; and
   3. the information you provided to Standard Bank is complete, accurate and not misleading in any material respect.
2. The above representations and warranties will be considered valid each time you provide instructions to us and for the duration of your relationship with us.

1. You are obliged to compensate Standard Bank for all losses, taxes, expenses, costs and liabilities whatsoever (present, future, contingent or otherwise and including reasonable legal fees) that Standard Bank may suffer or incur as a result of or in connection with:
   1. any breach of the terms by you;
   2. any transaction Standard Bank enters into on your behalf; or
   3. Standard Bank’s taking any of the steps that it is entitled to take in an event of default
2. Standard Bank makes no warranty, express or implied, in respect of its services and expressly disclaims any implied warranties of availability, fitness for a particular purpose, correctness, quality, accuracy, security, completeness, reliability, performance, timeliness, or pricing in respect of the services. Standard Bank is not responsible for maintaining the services or supplying any corrections, updates or releases in respect of the services and is not soliciting any action based on the provision or use of the services.
3. You acknowledge that Standard Bank's obligations in respect of the services, including their availability, proper operation, security, proper performance and accuracy, do not constitute any guarantee or assurance in respect of the services and are limited to an undertaking, on a best endeavours basis, that can reasonably be expected from a professional provider of automated financial services.
4. Consequently and without prejudice to clause 8, Standard Bank its officers, affiliates, employees and agents will not be liable in delict, contract, warranty or otherwise for any direct, indirect or consequential costs, damages, losses or liability, contingent or otherwise, suffered by you or any third party and arising from or pursuant to:
   1. the correctness, quality, accuracy, security, completeness, reliability, performance, timeliness or pricing provided under the services;
   2. any loss (including consequential and other indirect losses), expense, cost or liability (together referred to as "Loss") suffered or incurred by you as a result of or in connection with the provision of the services unless and to the extent that such Loss is suffered or incurred as a result of Standard Bank's wilful default;
   3. any Loss due to actions taken by Standard Bank according to its rights under the Terms,
   4. operational failures preventing the use of the trading platform;
   5. interruptions preventing you from accessing the trading platform;
   6. any failure to provide continuous access to the services or any interruption or disruption of your access or delays or omissions of the services, including delays in processing any instruction that result in such instruction not being executed, arising from, inter alia, a force majeure or other situations that are beyond the control of Standard Bank, interruption of the Service by Standard Bank in the event of a risk of abuse of, or unauthorised access to, the service by third parties or any other situation that, in Standard Bank’s sole opinion, constitutes a risk to the security or the accuracy of the service, volatile market conditions, market disruption, unavailability of pricing or funds for a transaction, overload or shutting down of markets or stock exchanges;
   7. the failure of any Internet connection or communication service to provide or maintain your access to the services;
   8. any erroneous communications between Standard Bank and you;
   9. use of the Internet and email as a means of communication.
5. Standard Bank will not be liable in delict, contract, warranty or otherwise for any direct or indirect loss of profits or anticipated savings or any direct, indirect or consequential damages that you may incur or experience because it has accepted the terms or relied on the services, even if Standard Bank knew of the possibility of such loss or damages.
6. Standard Bank is not responsible for informing you of any difficulties you or other third parties may experience while using the Services or for taking any action in connection with those difficulties.
7. Standard Bank is not liable to you for any damages caused by a representative or a third-party broker or a market participant acting for Standard Bank.
8. Standard Bank is not liable to you for any damages caused by any institution such as a stock exchange, clearing house or a securities depository.
9. You acknowledge, recognise and accept that no market recommendation or information communicated by Standard Bank constitutes an offer to buy or sell, or the solicitation of an offer to buy or sell, a Security and that such recommendation and information, although based on information from sources Standard Bank believes to be reliable, may be based solely on a broker's opinion and may be incomplete, unverified and unverifiable. Standard Bank makes no representation, warranty or guarantee as to and will not be responsible for the accuracy or completeness of any information or trading recommendation provided to you.
10. You understand that neither Standard Bank nor any provider of data on the trading platform guarantees or makes any warranty of any kind, express or implied, regarding the timelines, sequence, accuracy or completeness of any data on the trading platform. You agree that neither Standard Bank nor any provider of data is liable for any losses (including lost opportunity or profits) arising out of or relating to (i) any inaccuracy, defect or omission in the data, (ii) any error or delay in the transmission of the data, or (iii) any interruption in such data and accordingly indemnify and hold Standard Bank and any provider of data harmless against any loss, damage or cost.
11. You indemnify, protect and hold harmless Standard Bank and its officers, affiliates, employees and agents from and against any and all losses, liabilities, judgments, actions, proceedings, claims, damages and costs (including attorney's fees) resulting from or arising out of the use of the services by you or your authorised representatives, including any breaches of the security of the services as well as any access or entry into any of its other systems not covered by the terms), caused directly or indirectly by you or your authorised representatives.

1. Neither party will disclose any information relating to the business, investments, finances or other matters of a confidential nature of the other party of which it may in the course of its duties obtain possession of and both parties will make every reasonable endeavour to prevent any such disclosure. However, this will not apply if a party is obligated to disclose such information by prevailing legislation, or by a legislative or supervising authority, or by another person who according to the law is entitled to demand disclosure, or must disclose it in order to fulfil its obligations pursuant to these terms.
2. By accepting the terms you authorise Standard Bank to disclose any information relating to you that may be required by any law, rule or regulatory authority, including any applicable market rules, without prior notice to you. Furthermore, Standard Bank may disclose requested and relevant information relating to you to third parties in or outside South Africa in order to facilitate the transfer of funds initiated by you.
3. By accepting the terms you permit Standard Bank to transfer personal information about you, submitted to or collected by Standard Bank, to any legal entity within the Standard Bank Group. The Standard Bank Group may transfer such personal information for the purpose of complying with regulatory requirements, providing and performing investment advice and investment and other services that Standard Bank offers, conducting marketing and managing the client relationship. Such personal information may be transferred to Standard Bank Group companies in countries where data protection laws may not provide a level of protection equal to that provided by the laws of South Africa. Furthermore, Standard Bank may share such personal information with a third-party agency working on behalf of Standard Bank for the purpose of performing client analysis to be used by Standard Bank’s sales and marketing and with any introducing broker working on behalf of Standard Bank for the purpose of completing due diligence and approving account applications.

Standard Bank and you undertake, on termination of the agreement, to complete all transactions that are already entered into or under execution and the terms will continue to bind both parties in respect of such transactions. Standard Bank is entitled (i) to deduct all amounts due to it before transferring any credit balances on any of the trading portfolios or wallets to you, (ii) to postpone such until all transactions are completed and settled and (iii) to require you to pay any charges it incurred in transferring your investments.

1. Standard Bank hereby identifies and discloses a range of circumstances that may give rise to a conflict of interest and potentially but not necessarily be detrimental to the interests of a client or clients. Such a conflict of interests may arise if Standard Bank, or any person directly or indirectly controlled by Standard Bank or a client, is likely to make a financial gain, or avoid a financial loss, at the expense of a client. Standard Bank will manage conflicts of interest fairly.
2. Standard Bank has identified the following circumstances that may give rise to a conflict of interests:
   1. Standard Bank may provide advice to clients whose interests may be in conflict or competition with other clients’ interests.
   2. Standard Bank may have an interest that is contrary to clients’ transactions, e.g. when clients trade in markets where Standard Bank acts as a market maker or when Standard Bank and a client wish to invest in the same instrument.
   3. Standard Bank, its employees and related legal persons may have, cease to have, establish or change positions in securities, foreign exchange or other financial instruments covered by an investment recommendation or advice.
   4. Standard Bank’s portfolio managers may trade in securities or other financial instruments on behalf of clients, knowing that the trades will be beneficial to Standard Bank’s, its employees’ or related persons’ positions in the same instruments.
   5. Standard Bank may have an interest in maximising trading volumes in order to increase its commission revenue, which is inconsistent with the client’s personal objective of minimising transaction costs.
   6. Standard Bank may receive inducements from or pay inducements to third parties due to the referral of new clients or clients' trading.