Prop Firm Code of Conduct

1. Public Rule Disclosure
   Firms shall publish all evaluation criteria, program rules, risk controls, and payout conditions in clear, plain language accessible to all participants prior to engagement.
2. Version Control and Change Log
   All material changes to rules, criteria, assessment logic, and payout policies must be tracked with version history and published with effective dates.
3. No Hidden Conditions
   All conditions that may materially affect a participant’s evaluation outcome, continuation, or compensation must be disclosed upfront and without ambiguity.
4. Trading Environment, Execution Model, and Economic Model Disclosure
   Firms shall clearly disclose, prior to a participant’s engagement and in plain, accessible language, whether participant trading activity takes place in a live market, a simulated environment, or a hybrid model. Firms shall also disclose whether, and under what circumstances, participant orders may be hedged, mirrored, routed, internalized, or otherwise reflected in live markets.

Firms shall further disclose, in terms reasonably sufficient for participant understanding and certification review, the principal features of the firm’s economic model relevant to participant treatment and payout capacity, including the principal sources from which payouts are funded, and any A-book / B-book classification methodology, if applicable. Such disclosures must not be misleading, must be kept materially accurate and up to date, and must be revised promptly where the underlying model or practices materially change.

1. Rule Enforcement Uniformity
   Firms shall enforce all program rules and discipline decisions consistently across all genuine market participants, irrespective of account size, geography, or tenure.
2. Deterministic Outcomes Where Applicable
   Automated evaluation outcomes shall be reproducible from official records. If discretion is applied, it must be documented and justified with evidence.
3. No Hidden Conditions
   All conditions that may materially affect a genuine market participant’s evaluation outcome, continuation, or compensation must be disclosed upfront and without ambiguity.
4. Prohibition of Arbitrary Changes During Active Participation
   No material rule change shall be applied retroactively to an active genuine participant’s ongoing challenge or funded account without explicit, documented consent, unless the classification of such participant has changed based on Clause 8 below.
5. Firms Right of Rules Modification

Firms reserve the right to modify evaluation methodology and enforcement rules using arbitrary changes in instances where abusive or deceptive participant activity can be documented and reasonably proven within the guidelines of the Monitoring and Enforcement Protocol to preserve market integrity.

1. Objective Risk Controls
   Firms shall define and implement risk controls (drawdowns, exposure, position size and payout limits, volatile market parameters, account block or close-only) that are fair, objective, consistent, clearly described and reasonably warranted to ensure market credibility.

Where a Firm applies drawdown controls for market participants, the methodology must be clearly disclosed, consistently applied, and expressed in a manner that is objective, reproducible, and reasonably capable of verification by the Participant against the Participant’s own account records or statement history.

At a minimum, the Firm must disclose the precise formula, reference points, and calculation method used to determine drawdown status, including whether drawdown is calculated by reference to balance, equity, starting balance, peak balance, trailing thresholds, or any other metric.

Where a genuine market Participant progresses to a funded account stage, any drawdown threshold should, as a matter of fair practice, lock at the starting balance of that funded account rather than continue to trail dynamically, unless a different methodology is clearly disclosed in advance, justified on objective risk grounds per Clause B.(8) of this Code of Conduct, and remains fully reproducible and verifiable by the Participant against their trading statement.

A Firm must not apply a drawdown methodology that is opaque, misleading, inconsistently described, or incapable of being independently checked by reference to the Firm’s disclosed formula and the Participant’s account records.

1. Appropriate Risk Feedback
   Genuine market participants shall receive timely information regarding risk breaches, performance triggers, and impending evaluation status changes.
2. No Misleading Anti-Abuse Criteria

Prohibited trading behavior and anti-abuse rules — including, but not limited to, those relating to latency, order routing, execution patterns, “consistency,” or similar concepts — must be:

• Clearly and precisely defined in plain, unambiguous language;
• Objectively describable, such that the criteria can be understood without reliance on subjective interpretation;
• Reasonably capable of independent verification, based on recorded trading data, system logs, or other auditable evidence; and
• Fully disclosed to market participants within a reasonable time prior to enforcement, including any thresholds, parameters, or conditions that may trigger a violation, excluding instances of persistent prohibited trading activity and abuse that presents immediate risk to market integrity business continuity.

Such rules must not rely on vague, discretionary, or retroactively applied interpretations that cannot be substantiated through documented evidence.

1. Right to Restrict Abusive Market Participants
   Firms shall have the right to restrict, terminate and ban abusive market Participants in instances where the trading activity or conduct of such Participants is clearly documented and can be reasonably proven within the definitions of Clause B of the Code of Conduct to be:

• Undermining the integrity of the market;
• Causing immediate material harm or risk to business continuity;
• Obfuscating abusive, deceptive or manipulative trading patterns

Firms must be able to demonstrate that any enforcement action taken under these criteria is consistent, evidence-based, and reproducible, and that the underlying rationale is grounded in legitimate market integrity, risk management and business sustainability considerations.

1. Criteria for Payouts
   The conditions, timelines, and methods for participant payout must be clearly stated and published.
2. Standardized Denial Rationales
   Any denial or withholding of payout must be accompanied by specific reference to the rule or condition violated and corresponding evidence from retained records.
3. Fair Timing and Process
   Payout processing and decision timelines must be reasonable and consistently applied, with clear dispute escalation procedures.

Adequate Financial Resources

Firms shall maintain financial resources, liquidity, and operational capacity reasonably sufficient to support their business model, meet payout obligations as they fall due, and continue operations in an orderly manner.

Financial Information for Certification Review

At the certification stage, and thereafter upon reasonable request or as part of ongoing monitoring, a Firm must provide the Financial Commission with financial information reasonably sufficient to assess the Firm’s solvency, financial resilience, and payout capacity. Such information may include audited financial statements, management accounts, cashflow statements, reserve disclosures, or other equivalent financial records.

Payout Liability and Financial Controls

A Firm shall maintain policies and controls reasonably designed to ensure that anticipated payout liabilities are identified, monitored, and managed separately from general operating demands. Where applicable and feasible, the Firm should maintain segregation, ring-fencing, reserve allocation, or comparable internal controls to support payout obligations.

Stress Testing and Financial Resilience Assessment

As part of certification, the Firm shall participate in a voluntary financial resilience and stress-testing review administered or requested by the Financial Commission, including scenario-based assessment of payout obligations, liquidity strain, operational disruption, or adverse business conditions reasonably relevant to the Firm’s model.

Going-Concern and Adverse Financial Developments

A Firm must promptly disclose to the Financial Commission any material deterioration in its financial condition, including insolvency risk, inability to meet payout obligations, going-concern uncertainty, material creditor action, or other financial event that may adversely affect Participants or the Firm’s ability to comply with certification standards.

No Misleading Representations as to Financial Capacity

A Firm shall not make misleading statements regarding its financial strength, payout reliability, reserves, capitalization, or ability to meet trader obligations.