This Risk Disclosure Statement (the "Statement") is issued by Hitomorrow Assessment Data Classification and Analysis L.L.C, incorporated in the United Arab Emirates under Commercial License No. 1275729, which operates the hi2morrow platform and related assessment services ("hi2morrow", "we", "us", or the "Company").
This Statement forms part of the contractual framework and must be read together with the General Terms & Conditions ("GTC"), the Qualification Terms of Service, the Legal Disclosures and Risk Warnings and the Return & Refund Policy. Capitalised terms have the meaning given to them in the GTC or in the Qualification Terms of Service. No statement of risk can be exhaustive.
1.1 This Statement applies to every person who purchases or participates in a Qualification Program or a Test Flight, and to every person to whom real firm capital is subsequently allocated under a separate written agreement.
1.2 The qualification phase. A Qualification Program and a Test Flight run on a simulated account on real-time market data. No securities are bought or sold, no order is transmitted to any exchange, and no counterparty is involved. What a participant risks is the Participation Fee and the time invested. Most participants do not complete a Qualification Program successfully, and that outcome is inherent to an assessment.
1.3 The real capital phase. Where the firm decides to allocate real firm capital, the trader operates a live account through a regulated group entity under a separate written agreement. The capital placed at market risk belongs to the firm: the trader does not deposit money, does not owe the firm trading losses, and acquires no ownership interest in the capital or in the positions. What the trader risks is the engagement and the income derived from it. Section 5 of the Legal Disclosures sets out how the two phases differ.
2.1 Market data in the simulated environment is real-time. Orders are matched by a simulator against that data rather than by an exchange against other market participants.
2.2 A simulated result therefore omits, among other things:
2.3 Results achieved in the simulated environment do not predict results on a real account. They are hypothetical, and hypothetical performance carries inherent limitations, chief among them that it is produced without financial consequence. No representation is made that a result achieved in the simulator would have been achieved, or would be capable of being achieved, in live trading. Past performance, whether simulated or live, is not indicative of future results.
3.1 Volatility. The prices of US-listed securities can move sharply and without warning, on earnings, on corporate announcements, on economic data and on events unrelated to the security itself. A position can move against a trader faster than an order can be placed to close it.
3.2 Price gaps. A security can reopen at a price materially different from the one at which it last traded, including after a halt during the session. Qualification Programs are conducted within the Intraday Trading Period published in the Qualification Terms of Service, which limits exposure to overnight gaps without removing gap risk within the session.
3.3 Liquidity. In thin conditions the quoted price may not be available in the size required, spreads widen, and closing a position may cost materially more than the last traded price suggests. Liquidity is not constant, and it is frequently lowest during periods of rapid price movement.
3.4 Trading halts and suspensions. An exchange or a regulator may halt trading in a security, and market-wide circuit breakers may halt trading altogether. A position cannot be closed while trading is halted, and the price on resumption may be materially worse.
3.5 Corporate actions. Splits, reverse splits, dividends, mergers, tender offers, bankruptcy and delisting affect the price and the tradability of a security, and may result in positions being adjusted, closed or rendered illiquid.
3.6 Short selling. Selling shares that are borrowed rather than owned carries risks that a long position does not. The loss on a short position is not limited to the amount committed to it, borrowed shares may be recalled and the position closed at an unfavourable price, and a rapid rise driven by short covering, commonly described as a short squeeze, can produce very large losses in a short period.
3.7 Leverage. Buying Power at every tier and every Level is materially greater than any amount the participant has paid. Leverage amplifies losses in the same proportion as it amplifies gains, and a small adverse move in a large position produces a loss that is large relative to the risk limits of the day.
3.8 Concentration. Exposure concentrated in a single security, sector or theme increases the effect of a single adverse event. The position limits described in Section 6.6 bound that effect without eliminating it: they are calculated from the price band applied to the security under the Limit Up-Limit Down mechanism of the US equity markets, so that a security whose band is wider carries a smaller permitted position, and every limit halves in the opening and the closing minutes of the session when those bands double.
4.1 An order may be executed at a price worse than the price displayed at the moment it was sent, may be executed in part, or may be rejected.
4.2 Stop orders, including automated risk instructions, specify the level at which an order is generated. They do not guarantee the price at which the resulting order is executed, which is the price available in the market at that moment.
4.3 Positions may be closed by the risk system or by a risk manager where a published limit is reached or where the rules require it, including at the end of the Intraday Trading Period. Any resulting loss is applied to the participant's performance.
5.1 Trading is conducted through software, data feeds, networks and third-party infrastructure, all of which can fail, become unavailable, or deliver inaccurate or delayed data. A failure can occur while positions are open and can prevent a position from being opened, monitored or closed.
5.2 Risks in this category include platform outages and defects, market data errors and latency, loss of internet connectivity, failure of the participant's own equipment or software, power interruption, cyber attack, unauthorised access to an account, and failure of a third-party provider.
5.3 A participant should keep the credentials to their Client Section secure, should notify hi2morrow without delay of any suspected unauthorised access, and should have a means of contacting support if the platform becomes unavailable while a position is open. An open position is not protected during an outage. The consequences of technical failure, including the circumstances in which the Term of an assessment is extended, are set out in the Return & Refund Policy, Section 7.
6.1 Both phases operate under published risk controls, and they are not the same controls in each phase.
In a Qualification Program they are a Daily Loss Limit of 0.250 per cent (1R), which ends the participant's trading for that session without closing a position already open; an AutoStop at 0.375 per cent (1.5R), which closes every open position and of which two (2) are permitted in any calendar month, a third within the same calendar month ending the attempt; and a Maximum Loss equal to the allocation of the Level that the tier opens, being 20R at Associate, 18R at Associate Plus, 14R at Senior, 12R at Lead and 10R at Principal. Nothing reduces the size a participant may take during an attempt.
In the real capital phase the daily controls apply in the same way to the buying power of the Level, with three (3) AutoStops permitted in a calendar month and two (2) where the previous calendar month closed net-negative. Two further controls apply that have no counterpart in the assessment: a Weekly Loss Limit of 0.750 per cent (3R) measured over the trailing five (5) sessions, and a Monthly Loss Limit of 1.500 per cent (6R). The control that ends the engagement is the allocation of the Level, being twenty-one (21) Risk Units less the number of the Level and never fewer than ten (10).
In a Qualification Program those percentages are calculated on the Allocated Buying Power, being the Buying Power allocated to the Qualification Account when the attempt opens and fixed for the whole of it; in the real capital phase they are calculated on the buying power of the Level. In a Qualification Program the Maximum Loss is static: it is measured from the Starting Balance of the Qualification Account and does not move with accumulated profit. In the real capital phase the allocation is not static: it is measured as a drawdown below the highest cumulative result the trader has reached at the current Level, and that highest result is reset whenever the Level changes.
6.2 Risk controls limit the size of a loss. They do not create profit and they do not make an unsuitable product suitable. Reaching a control carries its own consequence: an AutoStop is recorded, and a third AutoStop within one calendar month ends an attempt. In the real capital phase, exceeding the AutoStop allowance for a calendar month reduces the size the trader is permitted to take by one step and requires a review, and each of the weekly and the monthly limits removes the remainder of a period in which profit might otherwise have been produced.
6.3 A risk control specifies the level at which positions are closed. It does not guarantee the price at which the closure occurs, and in fast markets a position may be closed at a price materially worse than that level.
6.4 The consistency rule is not a loss control. One rule applies, on the same terms at every tier: where the net result of a Calendar Day exceeds twenty per cent (20%) of the current Profit Target, the Profit Target becomes the net result of that day divided by 0.20. Nothing is taken away by it. The result of the day counts towards the Profit Target in full, but the amount that must be reached in order to pass rises, so a single large day extends the work required rather than completing it. The Profit Target never falls and is not capped, and a losing Calendar Day does not affect it. The rule does not end an attempt and is not a violation; the balance of the Qualification Account is unaffected by it.
6.5 A Qualification Program runs for two (2) calendar months and a Test Flight runs for one (1) calendar month, in each case from the date on which the Qualification Account is opened. An attempt that has not reached the Profit Target within its Term ends without a passing result.
6.6 The position limits, and what they cannot prevent. Every other control described in this Section is a proportion of buying power, and a proportion of buying power cannot see a price gap. The position limits are the only control expressed against the security itself. The size of a position is limited by reference to the price band applied to that security under the Limit Up-Limit Down mechanism of the US equity markets: the maximum position is the size at which a movement equal to that band would cost 6R, being one and one half per cent (1.5%) of the Allocated Buying Power in a Qualification Program and of the buying power of the Level in the real capital phase. That produces thirty per cent (30%) of that figure in a Tier 1 security or exchange-traded product, fifteen per cent (15%) in any other listed stock and in an American Depositary Receipt, and seven and one half per cent (7.5%) in a security priced between $0.75 and $3.00; a broad-market exchange-traded fund is limited separately to forty per cent (40%), since it carries no single-name event risk. Each of those proportions halves in the opening and the closing minutes of the session, when the exchange bands double. The aggregate of all open positions may not exceed one hundred per cent (100%) of that same figure, and no position in a single security may exceed one half of one per cent (0.5%) of that security's twenty-day median daily volume.
A Qualification Program and a Test Flight are conducted intraday only, and so are Levels L1 to L8 in the real capital phase. Levels L9 to L12 may hold positions overnight after six (6) months, within separate and smaller overnight limits set out in the separate agreement, and a position above those limits is reduced by the system at 15:30 Eastern Time. Positions held overnight are exposed to news and to price movement while the market is closed, and that exposure is not bounded by any daily control.
These limits bound the loss that a gap or a halt can produce. They do not remove it. A security that gaps or is halted can carry a loss past the daily, weekly and monthly limits alike, because no automated instruction can act while there is no price at which to act.
7.1 Completing a Qualification Program successfully does not create any right, entitlement or legitimate expectation to real firm capital, to any profit share, to compensation, or to any contractor or employment relationship. Qualification is the first step; candidates may be invited to the onboarding process that follows it, and the final decision rests with the firm. Section 4 of the Legal Disclosures sets out the position in full.
7.2 A Test Flight leads to no Level and to no allocation of any kind. No result achieved in it is credited towards any Qualification Program. It may produce the Discount Code described in the Return & Refund Policy, Section 2.4(g), and nothing further.
7.3 Every tier is open to every participant and no application or prior approval is required. A higher tier carries greater Buying Power and opens a higher Level, and it neither increases the likelihood of a passing result nor gives any assurance that an allocation will follow. The Maximum Loss of a tier is the allocation of the Level it opens and falls in Risk Units as the tier rises, from 20R at Associate to 10R at Principal, so a higher tier is not a more permissive assessment.
7.4 At the Lead and the Principal tier a passing result does not by itself open the Level attached to the tier. The participant's trading record outside the assessment is verified after the attempt has passed and before any Level is allocated, and where it does not support that Level the participant chooses between the highest Level the record does support and a refund of the full Participation Fee. The Legal Disclosures, Section 5.8, and the Return & Refund Policy, Section 5.8, set out that process.
8.1 Income. Profit share is paid only on verified realised profit. A month that produces no profit produces no profit share, and there is no minimum, no retainer and no guaranteed amount.
8.2 Carry-forward of losses. Profit is shared above the trader's cumulative net result since the last distribution, so a losing month must be recovered before any further profit share arises.
8.3 The weekly and the monthly stop. A loss of 0.750 per cent of the buying power of the Level (3R) over the trailing five (5) sessions ends trading for the remainder of that calendar week. Trading resumes on the following Monday at the size that applied before the stop, and the Level, the allocation and the permitted size are unchanged by it. The measurement is rolling over any five consecutive sessions, so a losing run that spans a weekend counts in the same way as one inside a single week.
A cumulative loss of 1.500 per cent of the buying power of the Level (6R) within a calendar month ends trading for the remainder of that month. Trading resumes at the start of the next calendar month at the size that applied before the stop, and the Level, the allocation and the permitted size are again unchanged. The monthly limit is enforced during the session, at the moment the month-to-date result crosses it, and every open position is closed at that point. A calendar month therefore cannot close worse than 6R; that statement holds only because the limit is enforced within the session, and only in a continuous market, since a price gap or a trading halt can carry a loss past it as it can past any other control.
Both stops remove sessions in which profit might have been produced. A trader who is stopped for the remainder of a week or of a month has no way to recover the loss within that period, and the profit share for the period is reduced accordingly.
8.4 Trading size. The size a trader is permitted to take is one of three steps of the daily unit, being 1.00, 0.70 or 0.50, and there is no step below 0.50. There is no automatic reduction for a run of losing days. Size is reduced by one step only for a stated reason recorded at the time, being an AutoStop allowance exceeded in a calendar month, an adverse assessment of how that month's results were produced, or a decision of the risk manager with the reason logged; a reduction can never increase the size a trader may take. One step is restored after ten (10) consecutive sessions in which no AutoStop occurred and whose combined net result is nil or better, and full size is restored in any calendar month that closes net-positive. While a reduction lasts it reduces the profit that can be produced, and therefore the income from the engagement.
8.5 Loss of a Level, and demotion. The allocation of a Level is measured as a drawdown: the distance between the highest cumulative result the trader has reached at that Level and their result at the time of measurement. Reaching the allocation ends the engagement. There is no cascade to a lower Level on that ground and no second allocation. The highest cumulative result is reset whenever the Level changes, so a trader who is promoted begins the new Level measured from that point rather than from any earlier peak.
Two consecutive calendar months that both close net-negative move the trader down one Level at the second month-end. The step of permitted size in force is carried down with the trader, and the lower Level begins with half of its allocation already used, so that less room remains at the lower Level than a trader arriving there by promotion would have. An accumulated record of rule breaches, or a repeated adverse assessment of how results were produced, may also demote. A third demotion ends the engagement.
A Level is held on the conditions set out in the separate agreement and may be reduced or withdrawn under those conditions. Progression through the ladder carries no timetable and is not forecast.
8.6 Termination. The separate agreement sets out the circumstances in which it may be terminated by either party, and termination ends all income from it, including any expectation of a future profit share.
8.7 Credit risk of the firm. A profit share that has been earned but not yet distributed is an unsecured claim against the contracting group entity. It is not client money, it is not held in a segregated account, and on the insolvency of that entity it ranks with other unsecured claims.
8.8 How a result is produced. Alongside the money limits, each session is assessed on how the result was produced and not on its size alone: losing days by their size relative to the size the trader was permitted that day and by their frequency within the calendar month, days closed by an AutoStop on a separate scale, and profitable days positively. The assessment is reset at the end of each calendar month and does not carry forward. An adverse month reduces the permitted size by one step and requires a review, and a repeated adverse assessment may demote. A calendar month that closes at or above zero cannot cost a trader the engagement or the Level on that assessment, whatever it records. A trader may therefore be reduced in size, or reviewed, in a month in which no money limit was reached.
9.1 The Participation Fee is payable before access is provisioned. It is not a deposit, is not capital, and is neither tradeable nor withdrawable. One attempt is included in the Fee; a second attempt at the same tier may be purchased at half that Fee, and any attempt after the second is charged at the full Fee. A further attempt is a fresh purchase and gives rise to no right to a refund of the attempt that ended. Where an allocation of real firm capital follows and a first profit share distribution is made under the separate agreement, the Fee is returned to the trader in full with that distribution; that return is a term of the trading agreement rather than a refund of the purchase price, it is not owed where no distribution occurs, and the Fee is retained in respect of every attempt that does not lead to an allocation. At the Lead and the Principal tier a further refund is available where the verification of the trading record described in the Legal Disclosures, Section 5.8, does not support the Level purchased, on the terms of the Return & Refund Policy, Section 5.8.
9.2 In the real capital phase, platform, market data and execution costs are deducted from trading profit and loss as set out in the applicable agreement and fee schedule, and they reduce the amount on which profit share is calculated. Currency conversion may apply to a payment or to a distribution, and withholding tax may be deducted from a distribution where the law of a relevant jurisdiction requires it. Taxation depends on the participant's personal circumstances and may change; each participant is solely responsible for their own tax obligations, and hi2morrow does not provide tax advice.
9.3 A Qualification Program and a Test Flight are assessment services, and a participant in that phase is not a client of any regulated investment firm. The protections available to such clients, including any investor compensation scheme, the segregation of client money and the complaints procedures of a financial services regulator, do not apply, and no amount paid as a Participation Fee is client money. Section 10 of the Legal Disclosures sets out the regulatory status of each phase.
9.4 The treatment of paid assessment products differs between jurisdictions and is subject to change. A change in law or in regulatory interpretation may require hi2morrow to alter, restrict or withdraw a product in a participant's country of residence, including during an attempt. Where that occurs, hi2morrow shall notify the participant and shall refund the part of the Participation Fee that corresponds to the unexpired part of the Term at the date on which access ends, calculated by reference to the calendar days of the Term then remaining. That refund is the whole of what is payable in respect of the change, and it does not affect any right of the participant under mandatory law.
10.1 Participation is suitable only for persons who understand the risks described in this Statement, who can afford to lose the Participation Fee entirely, and who are prepared for the possibility that no allocation of real firm capital follows. A participant should not use money required for living costs, for debts or for dependants to purchase an assessment. Trading under a time limit and under daily loss limits is demanding, and decisions taken in order to recover a loss immediately after it occurs are a common cause of further loss.
10.2 hi2morrow receives the Participation Fee whether or not an attempt ends in a passing result, and a second attempt is available at a reduced price. In the real capital phase the firm and the trader share in profit and the firm bears the loss, so the published risk controls exist to bound the firm's loss, and they may end an engagement that the trader would have preferred to continue.
10.3 Participation requires the participant to be at least eighteen (18) years of age, or the age of legal majority in their jurisdiction if higher, and to satisfy the eligibility conditions set out in the Qualification Terms of Service and the GTC. The services are not directed to any person in any jurisdiction where their offer or use would be contrary to local law. Restricted jurisdictions are published in the GTC and may change, and it is the participant's responsibility to satisfy themselves that participation is lawful where they reside.
10.4 Nothing published by hi2morrow, and nothing provided within a Qualification Program, a Test Flight or any educational material, constitutes investment advice, a personal recommendation, a solicitation, or an offer to buy or sell any financial instrument. No assessment of the suitability or appropriateness of any product for a participant is carried out, and none should be inferred from the acceptance of a purchase.
10.5 By purchasing or participating in a Qualification Program or a Test Flight, a participant confirms that they have read and understood this Statement and accept the risks described in it.
10.6 This Statement is governed by the laws of the United Arab Emirates, and in particular the laws applicable in the Emirate of Dubai. The Real Capital Phase is not governed by this instrument: it is governed by the separate written agreement with the relevant group entity and by the law stated in that agreement. The courts of Dubai shall have jurisdiction, subject to mandatory consumer protections in the participant's country of residence. Where the participant is a consumer domiciled in the European Union or the United Kingdom, nothing in this Section deprives them of the right to bring proceedings in the courts of their place of domicile, or of the protection of being sued only in those courts.
10.7 This Statement may be updated. An update does not apply to a Qualification Program or a Test Flight already purchased. The current version is published on the Website and is identified by the version number and effective date at the head of this document.
This Risk Disclosure Statement does not constitute legal, tax or investment advice. The current version is available on this page.
Hitomorrow Assessment Data Classification and Analysis L.L.C United Arab Emirates | Commercial License No. 1275729 Trading as hi2morrow Group entities include Neoway Trading Ltd and Hitomorrow Securities LTD (Republic of Cyprus)