Corporate Information

VCM International Limited (“VCMI”) is a wholly owned subsidiary of Vantage Capital Markets LLP. It is a limited company registered in England and Wales – Registration Number 09555282

Legal Entity Identifier 213800PENPQGFLMQ1704

VCMI is an inter-dealer broker active in derivatives, both on-exchange and OTC. The firm’s focus is in the wholesale markets and its services are offered to an institutional client base. The firm does not offer its services to retail clients or consumers.

The firm’s primary office address and contact details are as follows:

Equitable House
47 King William Street
London
EC4R 9AF
United Kingdom

Tel: +44 (0)203 107 5000

If you require further information regarding the firm or its parent company, Vantage Capital Markets LLP, please contact the firm’s Compliance Department (compliance@vcmllp.com).

Regulatory Status

VCMI is authorised and regulated by the UK’s Financial Conduct Authority (FCA) and is an appointed representative of Vantage Capital Markets LLP.

VCMI is also registered with the US Commodity Futures Trading Commission (CFTC) and is a member of the National Futures Association (NFA). VCMI is registered as an Introducing Broker and approved as a Swap Firm. The firm’s NFA ID is 0487244.

Anti-Money Laundering Program and Customer Identification

Under US Federal law, we are required to establish and maintain an Anti-Money Laundering Program (“AML”). US Federal law requires all financial institutions to obtain, verify and record information that identifies each person who opens an account with VCMI. When an account is opened, we will ask for your name, address, date of birth and a copy of a valid form of government issued photo identification. A corporation, partnership, trust or other legal entity may need to provide other information, such as its principal place of business, local office, employer identification number, certified articles of incorporation, government issued business license, partnership agreement or trust agreement.

Privacy Statement

The Commodity and Futures Trading Commission (the “CFTC”) requires financial institutions, including broker-dealers such as VCMI, to develop privacy policies with respect to personal client information and to notify its clients of such policies.

Broker-dealers typically collect non-public information about a client which includes information the client provides when the client relationship is established, such as its name, address and personal identification numbers. This is used to evaluate and to serve clients needs and to complete client transactions. Many financial institutions also compile customer lists derived from such personally identifiable information.

VCMI does not disclose any non-public information in relation to its clients, or former clients, to affiliates or third parties, except as permitted by law, to process client transactions or to fulfil legal and/or regulatory requirements. VCMI has implemented specific policies and practices with respect to safeguarding the confidentiality and security of client information. VCMI’s staff are instructed to protect such information and are required to comply with these established policies and practices. VCMI has always considered the matter of privacy to be paramount and will continue to protect the interests of its clients.

Business Continuity Plan

VCMI maintains a business continuity plan (“BCP”) which is compliant with NFA and other applicable rules which govern our business. Our BCP would allow us to continue business and meet our existing obligations to clients should there be a disruptive event which affects our ability to do business from our London office. The BCP also contains our contingency plans if we had to cease business due to a serious disruptive event.

The BCP is reviewed on a periodic basis to assess its effectiveness and respond to new or evolving threats to our business. VCMI also maintains policies designed to protect our electronic infrastructure and resist any cyber threat.

Regulatory Disclosure

VCMI is registered as a Swap Dealer by the NFA. Pursuant to the Business Conduct Standards for Swap Dealers and Major Swap Participants with Counterparties (the “ECB Rules”) issued by the CFTC, VCMI is required to comply with certain disclosure obligations to counterparties and prospective counterparties prior to entering into a swap, foreign exchange swap, foreign exchange forward, or mixed swap (“Swaps Transactions”), as those terms are defined under the Commodity Exchange Act and the CFTC rules.

The disclosure information includes:

1. Information relating to the material risk associated with particular Swap Transactions, including market, credit, liquidity, foreign currency, legal, operational and any applicable risks;

2. Material characteristics of the particular Swap Transactions, including the material economic terms, terms relating to the operation of the Swap Transactions and the rights and obligations of the parties during the term of the Swap Transactions; and

3. Material incentives and conflict of interest.

The disclosures provided in the documents may not be applicable to all VCMI’s counterparties and would be relevant if you are US Persons (as defined by the CFTC rules) other than (i) US Persons that are not Swap Dealers or Major Swap Participants (as defined by the CFTC rules); or (ii) non-US branches of US banks that are registered as Swap Dealers or as Major Swap Participants.

Most of the documents in the disclosures have been developed by the International Swaps and Derivatives Association (ISDA). ISDA holds copyrights to certain documents which are attached. These documents may not be reproduced or distributed without ISDA’s written permission, as applicable, except that certain documents as specified on the ISDA website may be reproduced and distributed solely for the use in documenting specific commercial transactions. We further refer you to the ISDA disclaimer below.

This disclosure does not constitute any legal, financial, tax, accounting or other advice by VCMI and you should consult your own attorney, financial advisor, tax advisor or accountant for your own independent professional advice before entering into Swap Transactions with VCMI or the appropriateness of this disclosure for your business.

Please get in touch with your trading contact if you have any questions regarding the information provided above.

ISDA DISCLAIMER: You should only enter into a transaction after securing appropriate legal advice on its provisions. ISDA makes no warranty, express or implied, concerning the respective documents’ suitability for use in any particular transaction and bears no responsibility or liability whatsoever, whether in tort or in contract, in respect of any use of these documents. ISDA, its officers, directors, employees, subcontractors, agents, successors or assigns (collectively, “Covered Parties”) shall not be liable to you for any loss, injury, claim, liability or damage of any kind whatsoever resulting from, arising out of or in any way related to: (a) any errors in or omissions from the documents hyperlinked to from this disclosure to which ISDA holds copyrights (the “ISDA Content”); (b) your use of the ISDA Content; (c) your use of any equipment or software in connection with the ISDA Content; or (d) any delay or failure in performance. To the extent permitted by law, the aggregate liability of the Covered Parties to you in connection with any other claim arising out of or relating to the ISDA Content shall not exceed $500.00, which right shall be in lieu of all other remedies that you may have against ISDA. In no event shall the Covered Parties be liable for any special, indirect, incidental or consequential damages of any kind whatsoever (including, without limitation, attorneys’ fees), lost profits or lost savings in any way due to, resulting from or arising in connection with the ISDA Content contained therein, regardless of any negligence of the Covered Parties. The transaction documentation may contain disclaimers of liabilities that you should review.

Other Disclosures

Other disclosures which are required to be made available in compliance with FCA rules, including Conflicts of Interest and Execution Policies, can be found on Vantage Capital Markets LLP’s website.