Terms And Conditions

1. About these Terms and the Parties

These Terms and Conditions (the “Terms”) are a legally binding agreement between you and Integrated Equities Limited (“IEL”, “we”, “us”), a public company incorporated in Pakistan, licensed by the Securities and Exchange Commission of Pakistan (“SECP”) as a securities broker and a holder of a Trading Right Entitlement Certificate (“TREC”) of the Pakistan Stock Exchange Limited (“PSX”). They govern your download, access and use of the IEL Trade mobile application for Android and iOS (the “App”).

The App delivers two distinct service layers: (a) Trading Services — an electronic channel for the brokerage relationship you establish with IEL under your Account Opening Documents; and (b) Content Services — market information, analytics tools, alerts and community features, parts of which may be offered on paid subscription. Part B of these Terms supplements (and is always subordinate to) your Account Opening Documents; Part C governs Content Services.

2. Definitions

“Account” means your App user profile, mapped to your Unique Identification Number (“UIN”) where you are a brokerage customer. “Account Opening Documents” means the standardised account opening form and Customer Relationship Form (including its Annexure A terms and conditions) or Sahulat account documentation prescribed under the PSX Regulations, together with the Risk Disclosure Document and any special terms you sign with IEL. “CDC” means the Central Depository Company of Pakistan Limited; “NCCPL” means the National Clearing Company of Pakistan Limited. “Contract Note” means the confirmation of an executed trade issued under the Securities Brokers (Licensing and Operations) Regulations, 2016 (the “Brokers Regulations”). “Market Information” means market data, quotes, news, research, ratings, charts and other information made available through the App. “Schedule of Charges” means IEL’s prevailing schedule of brokerage commission and charges published on the App and at https://iel.net.pk. “Trading Day” means a day on which the PSX is open for trading. Terms defined in the Securities Act, 2015, the Brokers Regulations or the PSX Regulations have the same meaning here.

3. Hierarchy and Precedence

These Terms operate subject to, and are to be read together with, the instruments below. If there is any conflict, the instrument higher in the order prevails, and nothing in these Terms excludes, restricts or reduces any right, protection, duty or liability arising under any of them:

Securities Act 2015 & Futures Market Act 2016 → SECP rules & regulations → PSX, CDC & NCCPL regulations → Account Opening Documents (incl. CRF Annexure A) → these Terms

Your Account Opening Documents remain the master contract for the trading relationship. These Terms restate certain of their protections only for your convenience and never replace them.

4. Acceptance, Amendments and Versioning

You accept these Terms by an affirmative in-app action (for example, tapping “I Agree”). IEL records the version you accepted and the date and time of acceptance. Downloading or browsing alone does not create a brokerage relationship. Trading Services are activated only after your Account Opening Documents are completed, and you have expressly accepted them and the Risk Disclosure Document.

Amendments: (a) changes touching the trading relationship or the roles and responsibilities of IEL as a broker take effect only in accordance with the mechanism prescribed under the PSX Regulations (notification by the Exchange with the approval of the SECP), and we will notify you through the App and your email of record; (b) changes confined to Content Services take effect no earlier than seven (7) days after notice through the App, and material changes require your fresh acceptance. Continued use is never treated as acceptance of a change to trading-relationship terms. A version log of these Terms is maintained at https://iel.net.pk.

5. Eligibility, Capacity and Sanctions

You may open an Account only if you are at least eighteen (18) years of age, of sound mind and not an undischarged insolvent. Accounts for minors are opened and operated exclusively through a guardian in accordance with CDC and PSX procedures. Joint accounts and authorised persons are governed by your Account Opening Documents.

Trading Services are offered from Pakistan in respect of securities traded on the PSX. If you are a non-resident (including a non-resident Pakistani), you may invest only through the channels prescribed under the State Bank of Pakistan’s Foreign Exchange Manual — a Special Convertible Rupee Account (SCRA) or a Roshan Digital Account — and access may be restricted until those arrangements are verified. You represent that you are not designated or proscribed under any United Nations Security Council resolution or under the laws of Pakistan, are not resident in or acting for any person in a jurisdiction subject to an applicable comprehensive embargo, and are not named on any applicable sanctions list (including, for app-store distribution, relevant U.S. Government lists). You will maintain only one App profile, mapped to your UIN.

PART B — TRADING SERVICES (SUPPLEMENT TO YOUR ACCOUNT OPENING DOCUMENTS)

6. Account Opening, KYC/AML, Sanctions Screening and FATCA/CRS

IEL is a regulated person under the SECP Anti-Money Laundering and Countering Financing of Terrorism Regulations, 2020 and the Anti-Money Laundering Act, 2010. You agree to provide true, complete and current information and documents; to verification of your identity through NADRA Verisys or biometric verification; to screening (at onboarding and on an ongoing basis) against applicable sanctions and proscribed-persons lists; to enhanced due diligence where you are a politically exposed person or otherwise assessed as higher risk; and to provide evidence of source of funds or income on request. You will promptly notify IEL of any changes to your particulars and will provide FATCA/CRS self-certifications where applicable.

IEL may decline to open an Account, and may refuse a transaction, suspend, restrict or freeze an Account, or file reports with the Financial Monitoring Unit, where required or permitted by law — in some cases without prior notice, because the law prohibits “tipping off”. Dormant or inoperative accounts are reactivated only on your request after fresh NADRA Verisys or biometric verification. Records relating to you are retained for at least five (5) years after the relationship ends, as the law requires, notwithstanding any deletion request.

7. Access, Security and Credentials

Trading Services are protected by your credentials and mandatory two-factor authentication (OTP or equivalent). Social-media sign-in is not available for Trading Services. Your credentials are personal: do not share them, and notify IEL immediately at 0333-4298666 or support@iel.net.pk of any suspected compromise, upon which access will be suspended pending re-verification. IEL will never ask you for your password or OTP. Communications between the App and IEL’s systems are encrypted and digitally authenticated, and IEL maintains the systems-security, monitoring, back-up and business-continuity controls required of brokers offering internet-based trading services. Nothing in this clause shifts the burden of establishing the authenticity of an order, which remains on IEL as prescribed by the Customer Relationship Form.

8. Orders, Execution and Alternate Channels

Orders placed through the App are subject to validation, credit and margin checks and applicable position limits. IEL may, acting reasonably and in accordance with its risk-management and credit policy, decline, cap or require margin for an order, and will make the reason available to you on request. Orders are executed on the PSX in accordance with the PSX Regulations; erroneous trades are handled under the Exchange’s procedures. If the App is unavailable, you may place, modify or cancel orders by recorded telephone line at 0333-4298666 during market hours (“call-and-trade”).

9. Contract Notes, Statements and Electronic Communications

You authorise IEL to issue Contract Notes electronically to your designated email of record (and in-app), not later than the start of the next Trading Day after execution. You may change your email of record only by written or verified in-app instruction; IEL keeps delivery logs. If you prefer physical Contract Notes, you may designate so in your Account Opening Documents. A transaction recorded in a Contract Note is conclusive and binding unless you object to unauthorised execution or an error within one (1) Trading Day of receipt. Account statements are available in-app and on request. You consent to the recording of telephone lines and electronic order channels and to receiving statements, margin calls and notices electronically; electronic records and signatures are valid under the Electronic Transactions Ordinance, 2002.

10. Client Money, Payments and Settlement

All funds for trading must originate from your own bank account and move through banking channels (crossed cheque, bank draft, pay order or electronic transfer). IEL does not accept cash deposits. Your funds are kept in bank account(s) titled “clients”, segregated from IEL’s own funds, with client-wise records maintained; where client funds are placed in a profit-bearing account, profit accrued on your unutilised funds is passed on to you unless you have specified otherwise in writing. Credit balances are paid to you through banking channels within one (1) Trading Day of your request, subject to margin requirements. Subscription fees for Content Services are never routed through the “clients” account and are not set off against your trading balances without your written authority.

11. Custody and Corporate Actions

Securities purchased for you are held in your CDC sub-account established under IEL’s participant account (or, if you maintain one, your CDC Investor Account). Movements to any collateral account occur only as permitted by the PSX Regulations and under intimation as required. IEL facilitates corporate actions — entitlements, bonus and rights, electronic dividends to your designated bank account (IBAN) and e-voting — in accordance with CDC procedures.

12. Margins, Liquidation and Settlement Default

Margin requirements, margin calls, liquidation on failure to meet a margin call within one (1) Trading Day, and the treatment of securities on settlement default (including transfer to a collateral account under intimation to the PSX) are governed by your Account Opening Documents (Annexure A) and the PSX Regulations, which apply to orders placed through the App exactly as they apply to any other channel. Margin calls may be delivered in-app and by email, each of which constitutes a call “in writing”.

13. Brokerage, Charges and Taxes

Brokerage commission and the levies of the PSX, CDC, NCCPL and SECP apply per the Schedule of Charges; changes are notified in advance through the App. Capital gains tax on disposal of securities is computed and collected through NCCPL under section 37A and the Eighth Schedule of the Income Tax Ordinance, 2001, by reference to your tax status; maintaining your filer/Active Taxpayers List status is your responsibility. Withholding taxes and provincial sales tax on brokerage services apply at prevailing rates. You consent to the sharing of your data with NCCPL and the tax authorities for computation, collection and reporting. Taxes on subscription fees are as displayed at the point of purchase.

14. Risk Disclosure

You acknowledge that you have received, read and understood the Risk Disclosure Document provided with your Account Opening Documents, and that internet-based trading carries additional risks — including connectivity failure, latency, device compromise and order duplication — which the call-and-trade channel and the security measures in clause 7 mitigate but cannot eliminate. Every research report distributed through the App carries the standard warning below, which also governs your use of the App generally:

Investment in the securities market is subject to market risks. Read all the related documents carefully before investing.

15. Market Conduct — Your Undertakings

You will not use the App or any information obtained through it to engage in, facilitate or conceal insider trading, false trading, market rigging, price manipulation, fraudulent or deceptive devices, or the circulation of false or misleading information or rumours (including through comments or community features), each of which is an offence under the Securities Act, 2015 and the PSX Regulations. You will cooperate with the surveillance and enquiries of IEL, the PSX and the SECP. IEL may remove content, freeze or suspend an Account and report conduct to the authorities where it reasonably suspects a contravention.

16. Virtual Assets — Prohibition

The App offers no virtual-asset services of any kind. IEL does not accept payment in, deal in, advise on or promote virtual assets, and nothing in the App is an offer, solicitation or promotion of any virtual asset. Posting or transmitting virtual-asset promotion or solicitation through the App is prohibited; such content will be removed and may be reported. This clause reflects the Virtual Assets Act, 2026 and the directions of the Pakistan Virtual Assets Regulatory Authority.

PART C — CONTENT AND SUBSCRIPTION SERVICES

17. Market Information and Research

Market Information is compiled from the PSX and other sources and may be delayed or contain errors originating with the source; it is provided for your information and does not constitute an offer, solicitation or personalised investment advice, and does not take account of your individual circumstances. PSX market data delivered through the App is licensed for your personal, internal use only: you must not redistribute, republish, sell, commercially exploit, deep-link or systematically extract it, or use it to create any product, index or service, and you must not remove proprietary notices.

Research, ratings and analyst opinions distributed through the App are prepared and distributed under the Research Analyst Regulations, 2015 (as amended): IEL and its research analysts act in a fiduciary capacity towards clients in relation to such research; every report defines the meaning, benchmark and time horizon of each rating (a ratings glossary is published in the App), carries the standard warning at clause 14 verbatim, and contains the required disclosures, including disclosure of any use of artificial intelligence in its preparation. Research is distributed on a non-selective basis — released to all entitled recipients at the same time, with no advance access for any person or subscription tier. Third-party research is distributed only after review, with its conflicts of interest disclosed. Trading Services are execution services: IEL provides investment advice, if at all, only as an activity incidental to brokerage and without separate compensation.

18. Subscriptions and Billing

Paid subscription tiers comprise enhanced data depth, analytics tools, alerts, charting and convenience features only. They do not include, and their price is not consideration for, investment advice or any privileged access to research: research distribution is independent of subscription status. Prices and applicable taxes are displayed before purchase.

Billing is processed by Apple (App Store), Google (Google Play) or IEL’s named payment processor; IEL does not itself store your full card details. For card verification, the processor may debit a nominal amount (less than Rs. 10) and immediately reverse it. Subscriptions auto-renew at the then-current price unless you cancel at least twenty-four (24) hours before the end of the current period, through the App or your store account settings. IEL will not charge an expired payment instrument, and will not charge any alternate instrument without your fresh authorisation; on payment failure, access to paid features is simply suspended. Free trials are limited to one per person per service, and any unused trial period lapses on purchase. You may cancel at any time with effect from the end of the current period. Refunds are governed by the IEL Refund Policy published in the App and at https://iel.net.pk; where IEL permanently discontinues a paid feature mid-period, you receive a pro-rata refund of the fee attributable to the unexpired period.

19. User Content and Feedback

You are solely responsible for content you post through the App (“User Content”) and represent that you own or are authorised to post it and that it contains no malicious code. You must not post content that is unlawful, defamatory, abusive, obscene or misleading, that violates another’s rights, that circulates market rumours (clause 15) or that promotes virtual assets (clause 16). You grant IEL a non-exclusive, royalty-free, worldwide, sublicensable licence to host, reproduce, display, moderate, adapt and remove User Content in operating the App, and you waive moral rights in User Content to the maximum extent permitted by law. Feedback and suggestions are assigned to IEL and treated as non-confidential. IEL may moderate, remove or retain User Content, and may preserve it where the law so requires notwithstanding a deletion request.

20. Intellectual Property and Licence

IEL grants you a limited, personal, non-exclusive, non-transferable and revocable licence to use the App and its content for your own lawful, non-commercial purposes. All intellectual property in the App, the Market Information and IEL’s marks remains with IEL or its licensors. You must not copy, modify, distribute, resell, publicly display, create derivative works from, reverse engineer, scrape, access by automated means, interfere with security features of, or build a competing service using, the App or its content, except as the law permits.

21. Third-Party Services and App-Store Notices

Links to third-party sites and use of third-party or open-source software are subject to the third party’s terms, and IEL is not responsible for third-party sites it does not control — provided that nothing in this clause limits IEL’s own duties in respect of services IEL itself provides. Apple: if you use the App on an iOS device, these Terms are an agreement between you and Integrated Equities Limited only — not Apple Inc. Apple has no obligation to provide maintenance or support, is responsible (to the extent of applicable law) only for refunding the App purchase price where a warranty is not met, and is not responsible for any other claim relating to the App; Apple and its subsidiaries are third-party beneficiaries of these Terms and may enforce them against you. In-app purchases and auto-renewal on iOS are managed through your Apple account settings on the 24-hour rule at clause 18. Google: equivalent provisions apply to distribution through Google Play.

PART D — PRIVACY, LIABILITY AND LEGAL

22. Privacy and Data Protection

The IEL Privacy Policy, published in the App and at https://iel.net.pk, forms part of these Terms and explains what personal data we collect and why. In summary: your data is used to open and operate your Account, execute and settle trades, meet legal obligations and provide the App; it is shared, as required, with the PSX, SECP, CDC, NCCPL, the Financial Monitoring Unit, tax authorities, courts and IEL’s vetted service providers; calls and electronic order channels are recorded; data is protected by encryption and access controls; and records are retained for at least five (5) years after the relationship ends as the law requires. IEL does not sell your personal data. In the event of a data breach affecting you, IEL will notify you and the relevant authorities in accordance with applicable law, including the Prevention of Electronic Crimes Act, 2016.

23. Service Availability, Force Majeure and Business Continuity

IEL uses reasonable efforts to keep the App available and will give advance notice of scheduled maintenance where practicable, and prompt in-app or email notice of material incidents. IEL is excused from performance only by events genuinely beyond its reasonable control — such as acts of government, suspension of trading by the Exchange, war, natural disaster, or failure of public telecommunications or utilities not attributable to IEL — and never by its own negligence or its failure to maintain the systems, back-up and continuity arrangements required of it. During any App outage, the call-and-trade channel at clause 8 remains available in market hours.

24. Liability

Nothing in these Terms excludes, restricts or purports to exclude or restrict: (a) any duty or liability IEL owes you under the Securities Act, 2015, the Futures Market Act, 2016, any rules or regulations made under them, the regulations of the PSX, CDC or NCCPL, or any other applicable law; (b) IEL’s duty to act with due skill, care and diligence; or (c) IEL’s liability for its fraud, wilful default or negligence. Any provision that would have that effect is void to that extent, as Regulation 18 of the Brokers Regulations provides, and these Terms are to be read accordingly.

Subject to the paragraph above: Market Information and third-party content are provided on an “as available” basis and may be delayed, incomplete or inaccurate at source, and you should verify information material to a decision; IEL is not liable for loss caused solely by events described in clause 23; you are responsible for your own investment decisions and for your device and connectivity; and in respect of Content Services only — and excluding Trading Services and every matter referred to in the paragraph above — IEL’s aggregate liability arising from a claim is limited to the subscription fees you paid in the twelve (12) months preceding the event giving rise to the claim.

25. Indemnity

You will indemnify IEL, its directors, officers and employees against claims, losses and reasonable costs arising from your breach of these Terms, your violation of law or of a third party’s rights, or misuse of your Account — except to the extent the loss is caused by IEL’s breach of duty, fraud, wilful default or negligence. IEL will notify you of a claim within a reasonable time, will not settle it without consulting you, and will take reasonable steps to mitigate loss.

26. Suspension, Dormancy and Termination

IEL may suspend or restrict the App or an Account for security, legal or regulatory reasons, for material breach, or for non-payment of subscription fees (paid features only), giving prior notice except where the law prohibits it or urgent risk requires immediate action. You may close your Account at any time. On closure of a brokerage account, whether by you or by IEL: open positions are settled or transferred in an orderly manner; your credit balance is paid through banking channels within one (1) Trading Day (subject to margins and settled obligations); and your securities are transferred per your instructions in accordance with CDC procedures. Dormant accounts are reactivated as clause 6 provides. On death or incapacity, the Account is dealt with under the succession procedures of the CDC and PSX. Clauses 6 (retention), 13, 15–16, 19–20, 24–25 and 27–28 survive termination.

27. Complaints, Dispute Resolution and Governing Law

Step 1 — IEL Complaints Desk: write to support@iel.net.pk, call 0333-4298666 (Helpline/WhatsApp: 0345 0091263), or use the in-app complaint form. Every complaint receives a unique reference and an acknowledgement within two (2) working days, and IEL endeavours to resolve it within fifteen (15) working days. Step 2 — PSX: if unresolved, you may complain to the Pakistan Stock Exchange. Step 3 — SECP: you may lodge a complaint with the SECP through its Service Desk Management System at https://sdms.secp.gov.pk. Step 4: disputes may be referred to arbitration where the PSX Regulations so provide. These Terms are governed by the laws of Pakistan, and subject to the foregoing — and without prejudice to the powers of the SECP and the complaint and arbitration mechanisms of the PSX — the courts at Lahore have exclusive jurisdiction.

28. General

Notices: IEL may give notices in-app, by email to your email of record, by SMS or by post; notices are deemed received on transmission (or, for post, in the ordinary course). You may give notice at the contact points in clause 29. Assignment: you may not assign your rights; IEL may assign to a successor or affiliate subject to applicable regulatory requirements. Entire agreement: these Terms, your Account Opening Documents, the Privacy Policy, the Refund Policy and the Schedule of Charges are the entire agreement for the App, and the instruments listed in clause 3 always prevail. Severability: an invalid provision is severed and the remainder stands. No waiver: a failure to enforce is not a waiver. Language: the English text governs; an Urdu courtesy translation is available on request.

29. Contact

• Integrated Equities Limited — SECP Securities Broker Licence No. [293]; PSX TREC No. [293]
• Address: 30 Cricketers Colony, Netsol Avenue, Ring Road Ghazi Interchange, Lahore Cantt, Pakistan
• Phone: 0333-4298666
• Email: Help@iel.net.pk • Website: https://iel.net.pk
• Unresolved complaints: PSX, or SECP Service Desk Management System — https://sdms.secp.gov.pk