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We’re not FCA regulated,

We just hold ourselves to that standard.

From onboarding to execution, we align with the standards that matter — because regulation is the floor, not the ceiling.

Date Created: 03 April 2025

Last Updated: 06 April 2025 [v1.0]

Issuing Party: EWG
Receiving Party: EWG Members

Clarifying Club Terms

EWG Private
Investment Club
Membership Operating Statement

Welcome to the EffortlessWealthGroup Private Investment Club.

EffortlessWealthGroup (EWG) operates strictly as a Private Investment Club. All content contained in this brochure is intended solely for existing or prospective members who have been directly invited to participate in the club. EWG does not publicly market or promote any investment products.

No financial advice is provided by EWG. Members are responsible for making their own informed decisions regarding any opportunities discussed within the club. EWG does not manage or control member funds. All capital allocations are voluntary and self-directed.

Access to opportunities, AMPs (Asset Management Protocols), or related services is made

available exclusively within the closed membership network and may be subject to approval. EWG and its team operate solely as facilitators of private member information and do not act in a regulated capacity.

Membership in EWG does not constitute investment advice, legal advice, or financial planning. By participating in the club, all members acknowledge that they are acting on their own behalf and take full responsibility for their own decisions.

End of Membership Operating Statement.

Date Created: 03 April 2025

Last Updated: 06 April 2025 [v1.0]

Issuing Party: EWG
Receiving Party: EWG Members

Clarifying Club Terms

Governance & Terms of Engagement Framework

Introduction

This Governance & Terms of Engagement Framework (Framework) is issued by EFFORTLESSWEALTHGROUP LIMITED (collectively, “EffortlessWealthGroup”, “EWG”, “We”, “Us” or “Our”), a Private Investment Club, incorporated in England and Wales under company number 16252357, operating within the Standard Industrial Classification (SIC) code: 94990: Activities of Other Membership Organizations, whose registered office is 3rd Floor, 86-90 Paul Street, London, England, EC2A 4NE.

This Framework is issued to: Members of EWG defined as an individual who owns an approved EWG Membership Account.

This Framework sets forth the terms under which Members (“Members”, “You” or “Your") engage with EWG and with one another. By accessing the opportunities provided by EWG, Members agree to be legally bound by the terms outlined herein. The primary purpose of is to:

Establish a clear and cohesive framework for the operation of EWG as a private investment club.

Define the roles, responsibilities, and expectations of all Members.

Outline the processes and guidelines for investment activities and member interactions within EWG. THEREFORE, the parties acknowledge and agree as follows:

Membership in EffortlessWealthGroup (EWG) is conditioned upon the acceptance of and compliance with the terms outlined in this document. Both parties recognize the framework of their collaborative engagement as detailed below and agree to adhere to these stipulations as foundational elements of their engagement.

Furthermore, the governance and management of EWG are strictly governed by the provisions set forth within these pages. This includes the structure of decision-making, roles and responsibilities of Members, and the operational protocols that ensure EWG’s integrity and effectiveness. Compliance with these governance rules is essential for the sustainability and success of EWG, binding all Members and officers to uphold the club’s standards and objectives as described herein.

01. Identification & Strategic Intent

Identification

1.1. The entity herein formally recognised as EffortlessWealthGroup Private Investment Club, henceforth referred to as "EWG", has been established as a Private Investment Club.

Legal Entity

1.2. EWG is formally incorporated as a company limited by shares in England and Wales. This legal structure establishes EWG as a separate legal entity, distinct from its individual Members. As such, the club possesses the ability to own assets, incur liabilities, enter into contracts, and engage in legal proceedings under its corporate name. We are not an unincorporated association. Implications of being a separate legal entity include but are not limited to:

1.2.1. Limited Liability: EWG Members are not shareholders and thus hold no equity in the club. Consequently, Members are not financially liable for the club’s debts or legal actions beyond their individual contributions made as Membership dues or investments. This structure provides a significant layer of protection, ensuring that Members' personal assets are secure from any legal claims against the club.

1.2.2. Perpetual Existence: Unlike a partnership, EWG's existence is not dependent on its Membership composition. The club can continue indefinitely, even as individual Members join or leave, contributing to stability and longevity.

1.2.3. Corporate Governance: EWG is governed by a set of bylaws, which outline the processes for making decisions, electing officers, and managing club affairs. This structure ensures that operations are conducted in a systematic and transparent manner.

1.2.4. Regulatory Compliance: As a corporate entity, EWG is subject to regulatory oversight, which includes compliance with financial reporting, tax obligations, and other statutory requirements. This reinforces our commitment to integrity and accountability in managing the club's resources.

1.3. This structured approach to legal governance not only enhances operational efficiency but also aims to strengthen Member confidence by clearly delineating the boundaries of responsibility and control.

Operating Statement

1.4. This statement of operation clarifies how we operate and what Membership means.

1.5. EWG operates strictly as a Private Investment Club. EWG does not publicly market or promote any investment products.

1.6. No financial advice is provided by EWG. Members are responsible for making their own informed decisions regarding any opportunities discussed within the club. EWG does not manage or control Member funds. All capital allocations are voluntary and self-directed.

1.7. Access to opportunities, Asset Management Protocols (AMPs), or related services is made available exclusively within the closed Membership network and may be subject to approval. EWG and its team operate solely as facilitators of private Member information and do not act in a regulated capacity.

1.8. Membership in EWG does not constitute investment advice, legal advice, or financial planning. By participating in the club, all Members acknowledge that they are acting on their own behalf and take full responsibility for their own decisions.

Purpose Statement

1.9. EWG exists to reshape the global landscape of investing by addressing the core barriers that have held investors back for decades.

1.10. We aim to achieve this by standing by our 4 guiding values and guiding principles:

1.10.1. Understand: Gain deep insights into our Members' investment psychology to tailor our services to their real needs.

1.10.2. Rebuild: Establish a foundation of trust by connecting our Members with exclusive investment circles and high-quality opportunities.

1.10.3. Simplify: Streamline the investment process by providing clear, comparable, and confident choices that empower Members’ decision-making.

1.10.4. Expand: Cultivate a vibrant community of high-caliber investors, facilitating the free flow of knowledge, opportunities, and wealth creation, thereby expanding the circle of trust, transparency and prosperity without diluting quality.

Strategy

1.11. How we obtain, present and manage opportunities to EWG Members:

1.11.1. Source: Our network of partners and industry insiders constantly scouts for exceptional investment opportunities that meet the EWG Investment Vehicle Criteria. Once an opportunity meets our rigorous benchmarks, we engage with its founders and begin the due diligence process.

1.11.2. Vet: We bypass intermediaries to sit directly with the founders, the visionaries driving the opportunity forward. Our thorough vetting process ensures that the investment aligns with EWG’s high standards.

1.11.3. Simplify: We repackage intricate investment models into clear, structured, and investor-friendly vehicles. This enables investors to easily compare curated opportunities within our ecosystem.

1.11.4. Track: We continuously monitor the performance of every vehicle. Our proactive algorithms detect instability or emerging risks, prompting timely removal of underperforming investments, while highlighting high-performing ones.

1.11.5. Invite: Every opportunity within EWG is invite-only, ensuring that trust and relationships are foundational. We prioritize sustainable, strategic growth, rewarding investors for
sharing opportunities and contributing to a high-caliber investment community.

02. Membership

Becoming a Member

2.1. Membership in EWG is a private, invitation-only opportunity. Prospective Members must receive a personal invitation link from an existing member who qualifies as an EWG Associate, which is defined in 05. Marketing EWG - Clause 5.5

2.2. This model underscores the private nature of EWG, ensuring the maintenance of social ties within the club whilst supporting its ethos as an exclusive community.

Account Creation Process

2.3. Upon accessing the invitation link, prospective Members are directed to the EWG platform to establish their account. The account setup requires:

Full Legal Name,

Email Address,

Mobile Phone Number,

Password,

A declaration of the relationship with the inviter, selected from the following the available drop-down menu items which are currently as follows:
- Close Friend/Family,
- Colleague/Former Colleague,
- Business/Professional Contact,
- Other (must state alternative category),
And lastly, a brief description (one-sentence summary) of how the prospective member knows the inviter.

2.4. Once complete, the sponsor is automatically notified with a request to verify your stated affiliation. Following sponsor confirmation, the final approval is conducted by the administrative body of EWG.

Fees

2.5. Membership in EWG is provided without any initial fee, emphasizing our commitment to accessibility and value for our Members.

Rights of Members

2.6. Members of EWG enjoy a suite of rights designed to empower their investment experience and enhance their engagement within the club:

2.6.1. Access to Information: Members have full access to all club communications, investment research, and performance data.

2.6.2. Vetted Investment Opportunities: Members receive exclusive access to carefully vetted investment opportunities.

2.6.3. Accrued Profits: Members have the right to access any profits accrued from their investments.

2.6.4. Voting Privileges: Each member has the right to vote on significant decisions regarding the club’s investment strategies and the allocation of collective capital.

Responsibilities of Members

2.7. Membership in EWG carries with it certain responsibilities to ensure the integrity and success of the club:

2.7.1. Due Diligence: Members are expected to conduct their own due diligence on all investment opportunities presented.

2.7.2. Participation in Meetings: If available, Members should participate in the annual Members' conference to stay informed of club operations and contribute to collective decision-making.

2.7.3. Compliance with Club Policies: Members must adhere to all club policies and guidelines as set forth in this document and other official communications.

03. Capital Allocation

Member-Directed Capital Allocation Via Voting

3.1. Each member of EWG retains the exclusive right to vote on the allocation of their own capital. This personal veto power ensures that Members have direct control over their investment choices within the framework of the opportunities provided by the club.

3.2. Personal veto voting occurs during Step 2 of the setup process, after Members have been given time to review the opportunities available.

3.3. Even in instances where only one investment opportunity is available, Members are still required to cast a vote if they wish to proceed with capital allocation to that singular opportunity. This process underscores the importance of each member's consent and active participation in club investments.

3.4. Members are required to review all terms of service associated with their selected opportunity prior to finalizing their votes. This review is crucial for ensuring that Members are fully aware of the conditions, risks, and benefits associated with the capital allocation.

Ensuring Confidence

3.5. To ensure transparency, safeguard member interests, and maintain the high standards of the EffortlessWealthGroup Private Investment Club, all prospective Members are required to undergo a Readiness Check consisting of five carefully curated questions. This preliminary assessment is designed to verify each member’s understanding of the club's operational mechanisms, the scope of Membership responsibilities and our flagship opportunity with AXIS.

3.6. It is our utmost priority to ensure that each member engages with the club equipped with complete clarity, robust confidence, and unequivocal certainty. The Readiness Check aims to prepare Members thoroughly before they proceed with any further participation in the club’s activities. This process underscores our commitment to maintaining an informed and well-prepared Membership base, fostering a conducive environment for effective and confident participation in capital allocation activities.

3.7. To foster trust and ensure Members proceed with complete assurance, EWG implements a mandatory 24-hour Deployment Assurance Period. This crucial phase is designed to give Members sufficient time to reflect on their allocation decisions, ask further questions and confirm their commitment without pressure.

3.8. At the conclusion of the Deployment Assurance Period, Members are required to give their final confirmation by choosing to proceed. This step is vital for maintaining the integrity of the investment process and ensuring that all Members are confident in their choices.

3.9. This approach strongly aligns with EWG’s commitment to building and maintaining trust with its Members

Capital Allocation Procedures

3.10. Following the 24-hour Deployment Assurance Period, Members are guided through the capital allocation process. This structured approach ensures that all steps are transparent and compliant with Private Investment Club guidelines.

3.11. Members specify their capital contribution in predetermined increments called Tranches, each tranche is simply a unit of participation within any given opportunity.

3.12. Members choose their preferred method for transferring capital, From 4 available options, each designed to provide secure, efficient, and compliant channels for the transfer of funds:

Debit/Credit Card via a secure payment link;

Manual Bank Transfer;

Crypto Wallet Connection or

Crypto Wallet Deposit (QR Code / Provided Wallet Address).

3.13. In cases where a crypto QR code needs to be generated, EWG endeavours to send this to the Member’s email the same day, if requested by 17:00 (London, GMT) or the next business day by 10:00 if requested after 17:00.

3.14. To complete the allocation, Members must submit proof of their transfer, such as a screenshot or PDF document, ensuring verifiability.

3.15. All member funds are collected in segregated accounts specifically designated for member allocations. This not only enhances security but also ensures that funds are efficiently deployed to our partners, whereby they account for a single incoming source, rather than accounting for a vast number of incoming sources; essentially maintaining a streamlined process for capital deployment.

3.16. EWG utilizes a variety of banking and transaction services to facilitate the efficient setup and management of your Capital Management Account. To ensure flexibility and optimal service for our members, EWG reserves the right to select and alternate between available banking options based on efficiency and cost-effectiveness. Currently, our primary partners include:

3.16.1. ANNA (Payrnet): For streamlined bank transfers and financial transactions.

3.16.2. WISE: For cross-border transactions, offering favorable exchange rates and lower fees.

3.16.3 Coinbase: For facilitating transactions across hundreds of blockchain currencies.

3.20. It is important to note that EWG may modify its list of partners or add new ones as deemed necessary to enhance our service offerings. Members will be notified of any significant changes to the banking and transaction services that may affect the management of their Capital Management Account.

3.21. Of each capital allocation, a specified percentage, per tranche, is retained as a Finders & Facilitation Fee by EWG, with the remainder deployed through the selected opportunity. This fee funds commissions back to the EWG Associate who brought you the opportunity and supports the operational excellence, education and service provided to EWG Members.

Communication and Notifications

3.22. Members will receive sequential email notifications at each critical stage of the capital allocation process. These updates provide timely and detailed information regarding the status and location of their funds from the initial transfer to the final deployment.

3.23. All communications aim to keep Members well-informed in compliance with Private Investment Club standards, ensuring that each member has full visibility into the journey of their allocated capital.

Profit Withdrawals and Tax Considerations

3.24. EWG recognizes that flexibility in accessing profits is crucial for our Members. While we strive to provide instant access to realized profits where possible, the nature of each investment opportunity can affect the availability of these withdrawals. Each investment has unique characteristics, and accordingly, the terms for withdrawing profits may vary — ranging from immediate access to scheduled disbursements on a weekly, bi-weekly, monthly, quarterly, or even yearly basis.

3.25. To ensure transparency and informed decision-making, EWG commits to providing clear and detailed information about the profit withdrawal terms for each opportunity within the Deployment Brief. This information is made available prior to any voting and capital allocation procedures, ensuring that all Members understand the liquidity terms and can make educated decisions about their investments based on their personal cash flow needs and investment strategies. This approach not only aligns with our commitment to member satisfaction but also reinforces the trust placed in us to curate and present opportunities prudently.

3.26. As a global entity accommodating Members from various tax jurisdictions, it is crucial to recognize that profits may be subject to taxation based on your residential country and its tax regulations. EffortlessWealthGroup does not provide tax advice or withhold taxes from your distributions. Members are strongly advised to consult with a qualified tax advisor to fully understand the tax implications of their profits, ensuring compliance with local laws and proper reporting of income.

04. Marketing EWG

Overview

4.1. These specific terms constitute the EffortlessWealthGroup Private Investment Club Marketing Policy and are designed to preserve the private, exclusive nature of EWG, ensuring that all promotional activities are conducted in accordance with legal standards and maintain the integrity of our private Membership structure.

Core Marketing Principles

4.2. To promote EWG opportunities, prospective Associates must first pass the 30-question EWG Associates Qualifier, ensuring they meet our elite standards of Club knowledge and integrity.

4.3. EWG operates on an invite-only basis. Marketing efforts must reflect the private and exclusive nature of the club, avoiding any public solicitation or mass marketing techniques.

4.4. Promotion of the club is restricted to private channels and is not to be conducted in any public forum or via mass communication methods.

Eligibility to Market EWG

4.5. An EWG Associate is a qualified EWG Member, eligible for specific EWG Marketing roles based on their desired engagement level:

4.5.1. Contributors: Associates who introduce at least one new member, focusing primarily on casual, now-and-then introductions with no requirements or quotas and a limited commission structure. Contributors are responsible for referring at least one new Member to the club.

4.5.2. Partner: Higher-tier Associates who not only refer new Members but actively contribute to EWG’s growth, maintaining consistent Member introductions and benefiting from enhanced revenue sharing. Their responsibilities and benefits include:

Minimum Referral Requirement: Partners must refer a minimum of 10 Members to EWG to attain a Partner Status and continue to bring in at least three Members each month to maintain their status.

Revenue Sharing: Partners earn a higher tier of commissions and a share of the club’s revenue, reflecting their ongoing contributions to EWG’s Assets Under Management (AUM).

4.5.3. Associates can be Active or Inactive EWG Members based on whether they currently have capital allocated within an available EWG offering.

4.6. At EffortlessWealthGroup, the integrity and exclusivity of our network are paramount. To become an EWG Associate, either as a Contributor or Partner, and to gain access to your unique referral link, you must first successfully complete the EWG Associates Qualifier. This rigorous process ensures that all Members are well-informed and committed to upholding the standards of our elite wealth-building ecosystem.

4.7. Prospective Associates must score 100% across 30-questions that make up the EWG Associates Qualifier. This qualifier assesses understanding of our legal and commission structures, general expectations, and the details of any available products at the time of the examination.

4.8. The exam ensures that all Associates are equipped to introduce EWG opportunities with precision and integrity, maintaining the high trust and value of our network.

4.9. Attempts and Review: Candidates are allowed three attempts to pass the qualifier. Failing all attempts results in a revocation of access, requiring a formal review and approval process before any further attempts can be made.

4.10. This structured approach near-guarantees that every EWG Associate can contribute meaningfully to our community, fostering a secure, knowledgeable, and trustworthy environment for wealth building.

4.11. Successful Contributors and Partners are required to adhere strictly to EWG’s marketing guidelines, ensuring that all promotional activities are conducted privately and do not constitute public solicitations. EWG Associates must also ensure that their activities comply with relevant financial regulations to prevent any legal or regulatory issues related to financial promotions and privacy.

Prohibited & Permitted Marketing Practices

4.12. Prohibited Marketing Practices include:

4.12.1. Public Advertising: Members must refrain from promoting or advertising EWG in any public forum, including social media platforms, public websites, or through any form of public solicitation.

4.12.2. General Solicitation: No "Apply Now" calls to action are to be used in any external communications. All invitations to join the club must be personal and direct, extended only to known contacts such as friends, family, and professional colleagues.

4.12.3. Promotional Content: Members must avoid publishing any content that could be interpreted as a public offering or an open invitation to join EWG.

4.13. Permitted Marketing Practices:

4.13.1. Personal Network Invitations: Members are permitted to share information about EWG within their established personal networks, under the following conditions:

Direct and Discrete Sharing: Invitations to join EWG should be extended through one-to-one discussions, friendship gatherings, direct messages or in small group communications involving no more than 25 individuals.

Established Online Group Relationships: The online group to which the information is being communicated, e.g. a WhatsApp Group, must have a verifiable history of existing as a cohesive unit for at least three months prior to the communication.

4.13.2. Subtle Website References: If Members have personal or professional websites discussing their investments, any reference to EWG must be subtle and clearly indicate that the club is a private, Membership-only entity.

Commissions & Earnings

4.14. When you, as an EWG Associate, introduce a new Member to the club, this person becomes a part of your direct network, or Tier One. You earn commissions from the investments of these directly referred Members.

4.15. Linked Referrals: If your directly referred Members (Tier One) go on to refer additional Members (Tier Two), these Tier Two Members become your linked referrals. You continue to earn a percentage of the revenue generated from the activities of these Tier Two Members.

4.16. Tier Limitation: Earnings from referrals do not extend beyond Tier Two. This means as an EWG Associate, you do not earn commissions from the activities of Members referred by your Tier Two Members or beyond (Tier Three and lower).

4.17. Figure 1 visually depicts this structured referral system for easier understanding

EffortlessWealthGroup - Brochure Archive (6).png

Figure 1 - Referral System Earning Potential

4.18. This structured referral system ensures that rewards are attributed to Associates who contribute directly or indirectly to the growth of the club, but it also maintains a controlled expansion by limiting commissionable tiers.

4.19. Each investment opportunity presented by the EWG will be accompanied by distinct marketing bonuses, which are designed to incentivize Associates to promote these opportunities within their networks. The specific commission structure for marketing each opportunity will be added to Appendix A of these terms as a continually growing appendix and communicated to all EWG Associates at the launch of the opportunity. Associates are encouraged to review these details thoroughly to understand the potential rewards for their promotional efforts.

Member Communication and Training

4.20. EWG will provide regular updates to Members about marketing policies and expectations to prevent any inadvertent policy breaches.

4.21. EWG may, from time to time, conduct training sessions to educate Members on compliant marketing practices and the importance of maintaining the club's private nature.

Compliance Monitoring and Enforcement

4.22. Monitoring: EWG reserves the right to monitor Member activities as they pertain to the marketing of the club to ensure compliance with these policies.

4.23. Enforcement Actions: Violations of marketing policies may result in disciplinary actions, up to and including termination of Membership.

4.24. This marketing policy is subject to periodic review and may be updated to reflect changes in regulatory requirements or club strategies. All amendments will be communicated to Members through official channels.

of maintaining the club's private nature.

05. Governance & Operations

Organizational Structure and Roles

5.1. To maintain an orderly and efficient operational framework, EWG delineates specific roles within its organizational structure. This ensures clarity in responsibilities and fosters an environment conducive to informed decision-making and effective management.

Leadership Roles

5.2. Chief Executive Officer (CEO) and Founder: Pierre Yamfam serves as the CEO and Founder of EWG, guiding the strategic direction and overarching management of the club. His role involves spearheading development initiatives, overseeing club operations, and ensuring alignment with our mission and values.

5.3. Director of Finance: This role is responsible for monitoring and managing the club’s financial activities, ensuring transparency in fund allocations and financial integrity.

5.4. Voting Coordinator: Manages and oversees all voting processes, ensuring that they are conducted fairly and efficiently, and that results are accurately recorded and implemented.

5.5. Director of Marketing: Directs all marketing initiatives, ensuring that they are in line with club policies and effectively communicate the value of EWG to current and prospective Members.

5.6. Director of Legal Compliance: Ensures that all club activities are in compliance with relevant laws and regulations, reviews club policies for legal integrity, and advises on any legal matters that arise.

5.7. Records Manager: Responsible for maintaining accurate and secure records of all club activities, including member interactions, financial transactions, and meeting outcomes.

5.8. Each role contributes to the seamless operation of EWG, ensuring that member interests are safeguarded while advancing the club’s objectives. Regular assessments are conducted to evaluate the effectiveness of each role and to make adjustments as necessary in response to evolving club needs and external factors.

5.9. EWG is committed to maintaining a fully staffed operational structure. To this end, EWG endeavors to fill all designated positions promptly and ensure that no role remains vacant for an extended period, thereby upholding continuous and efficient management of club activities.

5.10. This structured approach to governance not only ensures compliance and operational efficiency but also supports the club’s commitment to transparency and member empowerment. Each role is crucial for maintaining the integrity and success of the investment club, and detailed role responsibilities are outlined in the club’s operational manual.

Decision-Making Processes

5.11. EWG is dedicated to prioritizing the best interests of our Members in all decision-making processes while simultaneously upholding the integrity and sustainability of the club. Our decision-making framework is designed to reflect these priorities consistently and transparently.

5.12. Member-Centric Decision-Making: EWG shall make all decisions with a primary focus on the benefits and welfare of its Members. Each decision must undergo a thorough evaluation process to ensure it aligns with member interests and contributes positively to their financial and operational expectations.

5.13. Integrity of the Entity: While focusing on member interests, EWG shall also preserve the integrity and longevity of the club as an entity. Decisions are made considering not only immediate member benefits but also the long-term health and stability of the club. This includes prudent risk management, adherence to legal and ethical standards, and maintaining the club’s reputation.

5.14. Transparent Reporting and Accountability: All significant decisions, especially those affecting club operations or member assets, shall be documented and made accessible to Members for review. Transparency in these decisions fosters trust and ensures that Members are well-informed of the actions taken on their behalf.

5.15. Inclusive Decision-Making: Whenever feasible, EWG will involve Members in the decision-making process, particularly for substantial changes in policy, or structural adjustments within the club. This may involve structured voting processes, surveys, or member meetings to gather input and achieve consensus.

5.16. Responsiveness to Change: EWG commits to remaining adaptable and responsive to both external market conditions and internal Membership dynamics. Decision-making processes will include mechanisms to swiftly address and incorporate changes, ensuring that the club remains resilient and responsive to the needs of its Members.

5.17. By adhering to these clauses, EWG ensures that all decisions are made with a balanced approach, considering both the immediate and long-term needs of its Members while maintaining the club’s structural and ethical standards. This approach is set to both enhance member satisfaction and trust alongside secure the club’s position as a reliable and esteemed private investment club.

Criteria for Club-Wide Voting

5.18. This section outlines the specific circumstances under which EWG will engage its Members in club-wide voting to ensure that all significant decisions reflect the collective input and consent of the Membership.

5.19. Voting Triggers include and are currently limited to:

5.19.1. Partnership Performances: A vote will be triggered if a Partner’s performance falls below a predefined threshold, as detailed in the Deployment Brief. This ensures member interests are safeguarded against sustained underperformance.

5.19.2. Approval of New Offerings: Before any new Partner is added to our portfolio, it must receive approval from the Membership through a formal voting process, ensuring alignment with member interests and risk preferences.

5.19.3. Changes in Partner Structure or Fees: Any significant changes to the fees, lock-up periods, or overall investment structure of an opportunity will prompt a vote to obtain member consensus on these critical changes.

5.19.4. Compliance Adjustments: Changes in regulations or legal conditions affecting a Partner’s operations will necessitate a club-wide vote to decide on necessary adjustments or continuance of the opportunity under new conditions.

5.19.5. Major Corporate Decisions: Events such as mergers, acquisitions, or major operational changes within a Partner's company will be subject to member voting, ensuring transparency and member involvement in substantial corporate decisions.

5.19.6. Routine and Periodic Reviews: Annual Review: All active Partners will undergo an annual review, voted on by Members to determine their continued participation based on performance and alignment with club goals.

5.19.7. Response to Market Conditions: Significant market downturns or geopolitical events that could impact the performance of Partners will trigger a strategic review and potential vote to reassess the club’s position and strategy.

5.19.8. Emergency Actions: Any serious allegations or investigations related to a Partner, deemed to potentially jeopardize member investments, will immediately trigger an emergency voting procedure to address and resolve the concerns swiftly.

5.20. Execution and Documentation: All votes will be conducted in accordance with the established voting procedures detailed in the club’s governance documents, ensuring that each voting process is conducted fairly, transparently, and with full documentation for future reference.

Annual Members' Conference Procedures

5.21. The EffortlessWealthGroup Annual Members' Conference serves as a pivotal forum for reviewing the past year's activities, discussing strategic directions, and making critical decisions that require member involvement. This conference underscores our commitment to transparency, member engagement, and collective decision-making.

5.22. The conference is scheduled annually, with the exact date and location communicated to all Members at least three months in advance. If circumstances necessitate a virtual meeting, appropriate arrangements and technical instructions will be provided to ensure full accessibility and participation.

5.23. The agenda for the conference is prepared by the Executive Committee and distributed to all Members one month prior to the meeting. Members have the opportunity to submit additional items for the agenda up to two weeks before the conference.

5.24. All Members are encouraged to attend in person or participate virtually. Registration for the conference opens one month prior and closes one week before the scheduled date to allow for adequate preparation of materials and accommodations.

5.25. The meeting is chaired by the CEO or an appointed senior member of the management team. Each agenda item is presented by the relevant department head or a designated expert.

5.26. Members are given the opportunity to discuss each item, ask questions, and provide feedback during the designated discussion periods.

5.27. Voting on formal resolutions or changes proposed during the conference is conducted through a secure electronic voting system, ensuring that all Members, whether attending in person or virtually, can cast their votes. Results are tallied and announced before the conclusion of the meeting.

5.28. Minutes of the meeting are recorded and include details of all discussions, decisions, and voting outcomes. These minutes are made available to all Members within two weeks post-conference.

5.29. Decisions made during the conference are assigned to the appropriate teams or individuals for implementation. Progress on these actions is monitored by the management team and reported to Members through regular updates.

Record-Keeping Standards

5.30. EWG is committed to maintaining comprehensive and precise records to ensure transparency, compliance, and efficient management. Our record-keeping system is designed to securely store and manage detailed data pertaining to all aspects of member engagement and club operations.

5.31. EWG’s Record Categories & Procedures include but are not limited to:

5.32. Onboarding Process Records:

5.32.1. Sign-up Records: Documentation of initial member registration, including date of entry and member identification details.

5.32.2. Readiness Check Results: Outcomes of the readiness assessments completed by Members to ensure understanding of club operations and investments.

5.32.3. Associates Qualification Results: Records of results from the qualification tests taken by Members aspiring to become EWG Associates.

5.32.4. Member Bio Questions: A compilation of responses to biographical questions asked during the onboarding process to better understand member backgrounds and investment preferences.

5.33. Legal and Compliance Documentation:

5.33.1. Reviewed and Signed Legal Terms: Archives of all legal documents reviewed and signed by Members, affirming their agreement to club terms and policies.

5.34. Transactional and Activity Records:

5.34.1. Voting Records: Detailed accounts of all votes cast by Members on various club decisions, including dates, items voted on, and outcomes.

5.34.2. Deposit Transfers: Logs of all monetary transfers into the club, including amounts, dates, and sources of the funds.

5.34.3. Associate Commissions and Earnings: Detailed tracking of commissions and earnings distributed to Associates, aligned with club profitability and individual performance metrics.

5.35. Security and Accessibility:

5.35.1. All records are stored in secure, encrypted databases with access restricted to authorized personnel only. This ensures the protection of sensitive member information and compliance with data protection regulations.

5.35.2. Members have the right to access their personal records upon request, subject to verification procedures to protect member privacy and data integrity.

5.36. Regular Audits and Updates:

5.36.1. EWG conducts regular audits of its record-keeping practices to ensure ongoing accuracy and compliance with legal standards. Any discrepancies found during audits are promptly addressed and corrected.

5.36.2. Updates to record-keeping practices are made as needed to adapt to new technological advancements or regulatory changes, ensuring that the system remains state-of-the-art and compliant with industry best practices.

5.37. By adhering to these rigorous record-keeping standards, EWG ensures that all member data and club transactions are meticulously documented and maintained. This not only facilitates efficient club management but also reinforces member confidence in the integrity and accountability of the club’s operations.

06. Confidentiality

Definition

6.1. "Confidential Information" refers to all non-public data that is designated as confidential or proprietary by one party (the "Disclosing Party") and is disclosed to another party (the "Receiving Party") in connection with the activities of EWG. This includes information shared during the course of this Governance & Terms of Engagement documentation. Types of Confidential Information include:

6.1.1. Proprietary Knowledge: Includes proprietary processes, methodologies, trading algorithms, Asset Management Protocols (AMPs), and financial models.

6.1.2. Personal and Financial Data: Covers client names, data, financial information, and personal identifiers.

6.1.3. Strategic and Operational Plans: Encompasses strategic plans, marketing strategies, and details of partnership agreements.

6.1.4. Financial Arrangements: Relates to pricing structures, fee arrangements, and terms of revenue sharing.

6.1.5. Documented Secrecy: Any information explicitly marked as confidential or that should reasonably be expected to be treated as confidential.

6.1.6. Contractual Details: The terms, conditions, and even the existence of this Governance document.

Exclusions to Confidentiality

6.2. Confidential Information does not include data that:

6.2.1. Is or becomes public knowledge through no fault of the Receiving Party.

6.2.2. Was already known to the Receiving Party prior to disclosure, free from confidentiality obligations.

6.2.3. Is independently developed by the Receiving Party without direct reliance on the confidential information.

6.2.4. Is disclosed after receiving explicit written consent from the Disclosing Party.

Obligations of Confidentiality

6.3. EWG and its Members must:

6.3.1. Preserve the confidentiality of all proprietary information.

6.3.2. Refrain from disclosing, commercializing, distributing, or exploiting any Confidential Information beyond the agreed terms of this documentation without explicit written permission from the Disclosing Party.

Upon Termination

6.4. Should this agreement terminate, each party must, upon request, promptly return or securely destroy all Confidential Information received from the other party, including all copies, summaries, or derivatives thereof.

Warranties and Disclosure Rights

6.5. Each party warrants that it possesses the full legal right to disclose the information provided under this agreement without contravening third-party rights.

6.6. The complete Governance & Terms of Engagement document, including all terms and detailed schedules, will be accessible as part of the due diligence documentation provided to EWG Members for thorough review.

07. Right To Terminate

Termination For Convenience

7.1. Members of EWG may terminate their Membership at any time for any reason through the following procedure:

7.1.1. Navigate to the “Close Account” option within your EWG Dashboard. This action triggers an automated pre-written email addressed to the EWG Front Desk Team (hq@effortlesswealthgroup.com).

7.1.2. Review the email, make any necessary adjustments to ensure the email fits your specific scenario, and send it to formally request termination of your Membership.

7.1.3. Upon receipt of your termination request, a representative from EWG will contact you to confirm the request and discuss the next steps.

7.1.4. The representative will assist in consolidating your capital allocations and detailing any necessary actions required to liquidate and secure your investments across your active opportunities.

7.1.5. You will be provided with a timeline for the complete exit process, ensuring that all financial transactions and obligations are concluded in a timely and orderly manner.

7.1.6. A final review of your account will be conducted to ensure that all financial dealings are settled, and any outstanding balances are addressed.

Termination For Cause

7.2. Either party may terminate this Agreement immediately upon written notice if the other party breaches any material term of this Agreement, including but not limited to:

7.2.1. Failure to adhere to Member onboarding obligations: Neglect or misconduct in the Member onboarding process as specified in this Framework.

7.2.2. Fraud and Anti-Money Laundering Violations: Engagement in fraudulent activities or breaches of anti-money laundering practices as defined by regulatory standards and the terms of the agreement.

7.2.3. Breach of marketing guidelines: Engaging in unauthorized public promotion or advertising of club activities, contrary to the established marketing restrictions outlined in this Framework.

7.2.4. Breach of confidentiality obligations: Unauthorized disclosure or misuse of confidential information provided under the terms of this Framework.

7.2.5. Legal or regulatory non-compliance: Actions which violate legal or regulatory requirements pertinent to this Framework.

7.3. Upon such termination, the breaching party shall be liable for all applicable remedies available to the non-breaching party in law or equity.

7.4. Upon termination of Membership and at the request of the member, EWG will provide all data held on the client, including transaction records and account activities, to ensure transparency and compliance with data protection regulations.

Survival Clause

7.5. Any provision of this Framework that, by its explicit terms, or implied by its nature, is intended to survive termination—including Intellectual Property Rights, Confidentiality, and obligations related to data protection—shall survive termination or expiration of this Agreement.

08. Standard Terms

Limitation of Liability

8.1. Within the governance and rules of engagement for EWG, the following limitations of liability apply:

8.2. EWG shall not be liable for any special, indirect, incidental, consequential, exemplary, or punitive damages arising from or related to the member’s participation in club activities. This includes, but is not limited to, loss of data, loss of profits or revenue, cost of capital, downtime costs, or loss of business opportunities, regardless of whether such damages arise under contract, tort, statute, or any other legal theory, and even if EWG has been advised of the possibility of such damages.

8.3. Members are not liable for any indirect, incidental, consequential, or punitive damages related to their participation in the club’s activities. This includes, but is not limited to, the actions of other Members, investment outcomes, and operational decisions made by EWG. Liability for Members is limited to their active capital contributions, except in cases of gross negligence or intentional misconduct.

8.4. This limitation of liability is crucial to maintaining the club's operational integrity and protects against unforeseen liabilities that could arise from its activities, ensuring that both the club and its Members can focus on productive and mutually beneficial engagements.

Insurance Obligations

8.5. EWG commits to maintaining insurance coverage that complies with applicable legal requirements and is deemed necessary for the protection of its operations and Members. This includes, but is not limited to, professional indemnity insurance and any other coverage relevant to its activities and jurisdiction.

8.6. Member Responsibilities Regarding Insurance: Members are encouraged to maintain personal insurance coverage appropriate to their participation in investment activities, as deemed prudent or necessary. While EWG ensures its own coverage for organizational activities, it does not extend this to individual member activities or responsibilities outside of club-directed operations.

8.7. Non-Limitation of Liability Due to Lack of Insurance: The lack of adequate insurance coverage by any party, whether EWG or an individual member, does not limit or otherwise alter that party’s liability under the rules and engagement terms set by EWG. Each party’s liability will be determined based on their actions and compliance with the agreed terms, irrespective of their insurance status.

Assignment and Delegation

8.8. Members of EWG shall not assign, transfer, delegate, or subcontract any rights, duties, or obligations under the Governance & Terms of Engagement, in whole or in part, without obtaining prior written consent from EWG. Subject to this restriction, these rules will bind and benefit both parties' successors and permitted assigns.

Governing Law and Jurisdiction

8.9. This Framework shall be governed by and interpreted according to the laws of the United Kingdom, without regard to conflict of law provisions. All parties agree that any disputes arising out of or in connection with this Framework shall be resolved exclusively by the courts of competent jurisdiction located within the United Kingdom.

Severability

8.10. Should any provision of this Framework be declared invalid, unenforceable, or void by a court of competent jurisdiction, such provision shall be modified or severed to the extent necessary to make the remainder of the Agreement valid, enforceable, and legally operative. The remaining provisions shall continue in full force and effect.

Independent Entity Clause

8.11. Nothing in the Governance & Terms of Engagement shall be construed to create a relationship of employer-employee, principal-agent, joint venture, or partnership beyond the express terms outlined within this document. Both EWG and its Members acknowledge that they are independent entities, engaging cooperatively under the terms set forth to mutual benefit without forming any additional fiduciary relationships or legal bindings not explicitly stated herein.

Force Majeure

8.12. Neither party shall be liable for any failure or delay in fulfilling obligations under this Agreement due to events beyond their reasonable control, including but not limited to acts of government authorities, terrorism, natural disasters, fire, storm, flood, earthquake, prolonged shortages of energy, strikes, or similar force majeure events. If such an event persists for more than thirty (30) days, either party may terminate this Agreement immediately upon written notice.

Entire Framework

8.13. This Framework, including all attached or referenced documents, constitutes the entire understanding between EWG and its Members regarding the subject matter herein and supersedes all previous communications, understandings, agreements, or commitments, whether oral or written. This Framework may only be amended, modified, or altered by EWG whereby all Members must be notified in writing upon the publication of the updated Framework’s terms.

By continuing to use the EWG platform and its connected services, you confirm you have reviewed, fully understood, and accepted all terms outlined within the Governance & Terms of Engagement Framework of EffortlessWealthGroup. This document will come into full force and effect as of the date and time in which you signed up to the platform and formally created your EWG account.

This Governance & Terms of Engagement document may be executed electronically or physically, in counterparts, each of which shall constitute an original, and all of which together shall constitute one binding agreement.

End of Governance & Terms of Engagement Framework.

09. Appendix A - Commissions Structure.

OPPORTUNITY: EWG X AXIS: AMP Leveraged Account

9.1. As a Contributor or Partner, you are entitled to earn commissions from Members you successfully refer to the EWG X AXIS: AMP Leveraged Account opportunity.

9.2. At any point you may be involved in a commission scenario as a direct referrer, earning from your Tier One Members or as a Link earning from your Tier Two Members.

9.3. Within this opportunity, Members earn in 3 ways and according to the following guidelines: Finders & Facilitation Fee

Finders & Facilitation Fee

9.4. For each $11K Tranche, $10K is allocated to your referred Member’s AXIS leveraged trading account, and $1K is retained by EWG as a Finders & Facilitation Fee.

9.5. With a Contributor status, the commissions you’ll earn, either as a direct referrer earning from your Tier One Members or as a Link earning from your Tier Two Members, are as follows:

Figure 3a: Finders & Facilitation Commissions Table For EWG Contributors

9.6. With a Partner status, the commissions you’ll earn, either as a direct referrer earning from your Tier One Members or as a Link earning from your Tier Two Members, are as follows:

Figure 3b: Finders & Facilitation Commissions Table For EWG Partners

9.7. Below is a depiction of how the Finders & Facilitation Commissions are split across all entities.

EffortlessWealthGroup - Brochure Archive (10).png

Figure 3c: Finders & Facilitation Commissions Distribution Chart

Profit Split

9.8. When Member’s connected AMP generates profit, their AXIS account reflects it in real time. EXODUS, for example, targets a 4% monthly profit, on the $100k trading account, which equates to approximately $4,000 per month.

9.9. With a Contributor status, the profits you’ll earn, either as a direct referrer earning from your Tier One Members or as a Link earning from your Tier Two Members, are as follows:

Figure 4a: Profit Split Table For EWG Contributors

9.10. With a Partner status, the profits you’ll earn, either as a direct referrer earning from your Tier One Members or as a Link earning from your Tier Two Members, are as follows:

Figure 4b: Profit Split Table For EWG Partners

9.11. Below is a depiction of how the Profits are split across all entities.

EffortlessWealthGroup - Brochure Archive (11).png

Figure 4c: Profit Split Distribution Chart

Rebates

9.12. AXIS pays $10 USD per lot traded on the Member’s account. With approximately 88 lots traded monthly with EXODUS, this generates $880/month in rebates for EWG.

9.13. With a Contributor status, the rebates you’ll earn, either as a direct referrer earning from your Tier One Members or as a Link earning from your Tier Two Members, are as follows:

Figure 5a: Rebates Table For EWG Contributors

9.14. With a Partner status, the rebates you’ll earn, either as a direct referrer earning from your Tier One Members or as a Link earning from your Tier Two Members, are as follows:

Figure 5b: Rebates Table For EWG Partners

9.11. Below is a depiction of how the Rebates are split across all entities.

EffortlessWealthGroup - Brochure Archive (12).png

Figure 4c: Profit Split Distribution Chart

End of Appendix A: Commissions Structure

Date Created: 04 April 2025

Last Updated: 06 April 2025 [v1.0]

Issuing Party: EWG
Receiving Party: EWG Members

Clarifying Club Terms

Concierge Service Agreement.

Introduction

This Concierge Service Terms of Use (Terms) is issued by EFFORTLESSWEALTHGROUP LIMITED (collectively, “EffortlessWealthGroup”, “EWG”, “We”, “Us” or “Our”), a Private Investment Club, incorporated in England and Wales under company number 16252357, operating within the Standard Industrial Classification (SIC) code: 94990: Activities of Other Membership Organizations, whose registered office is 3rd Floor, 86-90 Paul Street, London, England, EC2A 4NE.

These Terms are issued to: Members of EWG defined as an individual who owns an approved EWG Membership Account.

01. Overview

1.1. Welcome to the Concierge Priority Service provided by EffortlessWealthGroup (EWG). By engaging with this service, you acknowledge and agree to the terms and conditions outlined in this document. This service is designed to offer dedicated administrative assistance in the setup and management of your account where you will have direct access to managing your capital allocation, acting strictly under the direction of our clients. Our goal is to facilitate a smoother, more efficient account setup process, allowing you to focus on your financial goals with greater ease and confidence.

02. Scope of Service

2.1. The Concierge Priority Service provided by EffortlessWealth Group (EWG) is strictly administrative. As an intermediary, EWG facilitates the setup and management of your Capital Management Account according to the specific instructions provided by our Members. Our services include, but are not limited to:

2.1.1. Assisting with the completion and submission of application forms for your Capital Management Account.

2.1.2. Providing guidance on the necessary documents required for account setup.

2.1.3. Coordinating communications between the Member and EWG’s Partners involved in various investment opportunities.

2.2. It is important to note that EWG does not manage, trade, or offer financial advice regarding any funds or assets. Our role is limited to assisting in the administrative aspects of managing your Capital Management Account, ensuring that Members can direct their capital allocations to selected opportunities through EWG’s Partners, within the parameters set by their chosen investment vehicles.

03. Member Authorisation

3.1. As a member engaging with the Concierge Priority Service, you are required to provide explicit authorization for EffortlessWealth Group (EWG) to assist in the setup and management of your Capital Management Account. This authorization includes granting permission for EWG to input your information into application forms and submit the necessary documentation on your behalf.

3.2. As part of our service, members are required to provide specific information to facilitate the setup and ongoing management of their accounts. This information may include, but is not limited to:

3.2.1. Personal Identification: Full name, date of birth, proof of ID (such as a passport or driver’s license).

3.2.2. Contact Information: Email address, mobile number, and residential address.

3.2.3. Proof of Residence: Utility bills, bank statements, or government-issued documents dating within the last three months.

3.2.4. Financial Information: Details on where funds should be allocated, including bank account numbers, crypto wallet addresses, or PayPal accounts.

3.2.5. Investment Preferences: Types of investments of interest, preferred sectors, risk tolerance levels.

3.2.6. Regulatory Compliance Data: Information required to comply with anti-money laundering (AML) and know your customer (KYC) regulations.

04. No Financial Advice or Management

4.1. EWG strictly provides administrative services related to the setup and management of your Capital Management Account. It is important to clarify that EWG does not:

4.1.1. Offer financial, legal, or investment advice.

4.1.2. Make financial decisions on behalf of members.

4.1.3. Control, manage, or have access to member funds.

4.2. Members are solely responsible for the financial decisions made within their Capital Management Account. EWG’s role is limited to providing administrative support as directed by the members. This ensures that all investment decisions remain the exclusive responsibility of the member, aligning with our policy to empower members while maintaining clear boundaries of our service capabilities.

05. Risk and Liability

5.1. EWG's role in facilitating the setup and management of your Capital Management Account is purely administrative. It is important for members to understand the following aspects regarding risk and liability:

5.1.1. Delays and Rejections: EWG is not liable for any delays or rejections in account setup or capital allocations caused by third-party financial institutions or investment partners. Our responsibility is limited to submitting information and coordinating communications as directed by members.

5.1.2. Misuse of Information: EWG takes extensive measures to ensure the security and proper handling of all member information. However, EWG is not responsible for the misuse of information once it is in the hands of third-party service providers or if the member inadvertently shares sensitive data.

5.1.3. Financial Losses: EWG does not control or manage member funds and, therefore, cannot be held liable for any financial losses, errors, or fraudulent activities that occur within the member's Capital Management Account or associated investments.

5.1.4. Member's Responsibility: Members are responsible for their financial decisions and the outcomes of such decisions. It is crucial that members review all documentation and transactions thoroughly before finalizing them to ensure they understand the associated risks.

5.2. EWG is committed to providing a reliable and secure service, but it is essential for members to be aware of and manage the risks associated with their financial activities.

06. Compliance and Regulatory Adherence

6.1. Although EWG is not an FCA regulated entity, we aim to adhere to the guidelines to the highest standard. EWG is committed to upholding the highest standards of compliance and regulatory adherence in all aspects of its services. This commitment ensures that both EWG and its members operate within the bounds of applicable laws and regulations, which include but are not limited to:

6.1.1. Financial Conduct Authority (FCA) Regulations: EWG strictly follows guidelines and regulations set forth by the FCA to ensure transparency, fairness, and integrity in all financial dealings.

6.1.2. Anti-Money Laundering (AML) Laws: EWG adheres to AML regulations by implementing rigorous checks and balances to prevent the misuse of financial services for money laundering activities.

6.1.3. Know Your Customer (KYC) Requirements: As part of our compliance with AML directives, EWG conducts thorough KYC procedures to verify the identity of our members and understand their financial activities.

6.1.4. Data Protection Regulations: EWG complies with data protection laws, ensuring that all member information is handled securely and with the utmost confidentiality.

6.2. EWG continuously monitors regulatory developments to adapt and update its compliance practices. This proactive approach not only protects our operations but also safeguards our members’ interests.

07. Confidentiality & Data Security

7.1. At EWG, we prioritize the confidentiality and security of our members' data as fundamental aspects of our service. In accordance with our Know Your Client (KYC) Policy, which we strongly encourage all members to review, EWG employs stringent measures to protect personal and financial information from unauthorized access, use, or disclosure. This policy details our comprehensive approach to maintaining data security and outlines the responsibilities of both EWG and our members in safeguarding personal information.

08. Dispute Resolution

8.1. At EWG, we are committed to providing exceptional service and ensuring member satisfaction. However, we recognize that disputes may occasionally arise. To address these effectively, EWG has established a clear and accessible dispute resolution process:

8.1.1. Initial Contact: Members are encouraged to contact our customer service team directly for any concerns or disputes related to our services. You can reach us through several methods for your convenience:

Phone: +44 (0) 800 001 6386

Email: hq@effortlesswealthgroup.com

Live Chat: Available on our website for real-time assistance.

Postal Address: EWG HQ, 3rd Floor, 86-90 Paul St, London, England, EC2A 4NE.

8.1.2. Our team is trained to handle inquiries promptly and professionally, ensuring that all concerns are addressed efficiently.

8.1.3. Escalation Procedure: If the initial resolution does not meet the member’s expectations, the dispute can be escalated to our senior management team. A detailed review will be conducted, and a response will be provided within a specified timeframe, usually within 1 - 3 business days.

8.1.4. External Resolution: In cases where disputes cannot be resolved internally to the member’s satisfaction, we advise members on appropriate external bodies they can approach for further resolution. This may include mediation or contacting a financial ombudsman service.

8.1.5. Documentation and Follow-up: All disputes are thoroughly documented, and follow-up actions are taken to prevent future occurrences. This documentation helps EWG improve its services and address underlying issues effectively.

8.2. EWG strives to resolve all disputes amicably and expediently, maintaining transparency and fairness throughout the process.

09. Amendments to the Terms of Service

9.1. EWG reserves the right to amend these Terms of Service at any time to reflect changes in the law, our service offerings, or our business practices. Such amendments are essential for maintaining compliance and ensuring the continued efficacy of our services. Members will be notified of any significant changes in the following ways:

9.1.1. Email: Members will receive an email detailing any changes to the Terms of Service.

9.1.2. Website Updates: The latest version of the Terms of Service will always be accessible on our website.

9.1.3. Direct Communications: For substantial changes, additional communication may be provided through direct messages or postal mail.

9.2. Members are encouraged to review the amended Terms of Service to understand how the changes may affect their use of EWG's services. Continued use of the services after such changes will constitute acceptance of the new Terms of Service.

10. Termination of Service

10.1. EWG values a clear and transparent relationship with our members and understands that circumstances may change. Members may decide to terminate their use of EWG services at any time. The process for termination includes the following steps:

10.1.1. Notice of Termination: Members wishing to terminate their services must notify EWG using the details in Section 13: Contact Information. The notice should include the member’s account information and the desired date of termination.

10.1.2. Data Retention and Deletion: In compliance with data protection laws, EWG will retain member data for a legally specified period after termination. After this period, all personal data will be securely deleted from our systems, unless otherwise required by law.

10.1.3. Confirmation of Termination: EWG will confirm the termination of services in writing, providing members with a record of the end of the service relationship.

10.2. Members are advised to consider the implications of termination carefully, especially in relation to ongoing or pending transactions.

11. Acknowledgment & Agreement

11.1. By proceeding with the Concierge Priority Service provided by EWG, you, as a member, confirm the following:

11.1.1. Understanding and Agreement: You have read and fully understand the Terms of Service outlined in this document. You agree to abide by these terms and acknowledge that they govern your use of EWG's services.

11.1.2. Authorization for Services: You authorize EWG to perform administrative tasks as specified in the Scope of Service section. This authorization includes the handling of your information and documents necessary for managing your Capital Management Account according to your instructions.

11.1.3. Non-Discretionary Role: You acknowledge that EWG acts without discretionary authority over your accounts or funds. All decisions regarding the management and disposition of your investments remain your sole responsibility.

11.1.4. Acceptance of Risks: You recognize that financial investments involve risks, and you accept those risks as part of your decision to use EWG's services.

11.1.5. This acknowledgment is a crucial part of ensuring that all members are aware of their rights and responsibilities when using EWG's services and that they have granted explicit consent to operate within the terms provided.

12. Contact Information

12.1. Should you have any questions or require further clarification regarding the Terms of Service or any aspect of EWG’s services, please do not hesitate to contact us using any of the following methods:

12.1.1. Email: You can reach us at hq@effortlesswealthgroup.com for all inquiries.

12.1.2. Phone: +44 (0) 800 001 6386

12.1.3. Email: hq@effortlesswealthgroup.com

12.1.4. Live Chat: Available on our website for real-time assistance.

12.1.5. Postal Address: EWG HQ, 3rd Floor, 86-90 Paul St, London, England, EC2A 4NE.

12.2. We are dedicated to providing you with the highest level of customer service and support.

Client Confirmation Statement

As a member of EffortlessWealth Group (EWG), by proceeding with the Concierge Priority Service, I hereby provide my explicit and full authorization for EWG to assist in the setup of my Capital Management Account in accordance with the details I have provided. I acknowledge that EWG's role is strictly administrative and does not include financial management, investment decision-making, or the provision of financial advice. I confirm that all the information I have supplied is accurate and complete, and I authorize EWG to use this information solely for the purpose of providing the services outlined in this agreement.

End of Concierge Service Agreement.

Date Created: 04 April 2025

Last Updated: 06 April 2025 [v1.0]

Issuing Party: EWG
Receiving Party: EWG Members

Combatting Money Laundering

Anti-Money Laundering (AML) Policy

Introduction

This Anti-Money Laundering (AML) Policy (Policy) is issued by EFFORTLESSWEALTHGROUP LIMITED (collectively, “EffortlessWealthGroup”, “EWG”, “We”, “Us” or “Our”), a Private Investment Club, incorporated in England and Wales under company number 16252357, operating within the Standard Industrial Classification (SIC) code: 94990: Activities of Other Membership Organizations, whose registered office is 3rd Floor, 86-90 Paul Street, London, England, EC2A 4NE.

This Policy is issued to: Members of EWG defined as an individual who owns an approved EWG Membership Account.

01. Overview

1.1. EWG is committed to preventing the misuse of its services for money laundering or terrorist financing activities. This policy outlines the responsibilities and processes EWG adheres to, in compliance with regulatory standards and best practices.

1.2. The Anti-Money Laundering (AML) Policy at EWG is a critical component of our internal compliance measures. This policy is designed to prevent the laundering of funds obtained through illegal activities. Our AML practices adhere to widely recognized standards and comply with regulatory requirements applicable to financial institutions, ensuring that EWG operates with integrity and transparency in all financial dealings.

02. Objective

2.1. The AML Policy of EWG aims to:

2.1.1. Prevent criminal elements from utilizing EWG for money laundering or terrorist financing.

2.1.2. Enable EWG to effectively manage and mitigate associated financial and reputational risks.

2.1.3. Ensure compliance with applicable legal and regulatory requirements.

03. Scope of Application

3.1. This policy applies to all members, employees, and partners of EWG. It covers all operations and transactions that could potentially be used for illegal purposes, emphasizing the importance of vigilance and compliance across all activities.

04. AML Compliance Structure

4.1. AML Compliance Officer: An appointed AML Officer oversees the implementation of AML procedures, ensuring compliance across all levels of the organization.

4.2. Member Identification Procedures (KYC): Comprehensive Know Your Client (KYC) processes are in place to accurately identify and verify the identity of members and their sources of funds.

4.3. Reporting Obligations: EWG adheres to strict reporting requirements for any suspicious activities, cooperating fully with regulatory and law enforcement bodies as necessary.

4.4. Cashless Transactions: EWG does not engage in cash transactions nor opens deposit accounts; all Member contributions are processed through cashless settlements. EWG maintains stringent records of all Member transactions to ensure transparency and regulatory compliance. Additionally, EWG reserves the right to halt any fund transfers if there is suspicion of illicit activities. In such instances, EWG is obligated to report suspicious activities to the relevant regulatory authorities without prior notification to the involved parties. This protocol is in place to uphold the integrity of all operations within our Private Investment Club.

05. Member Due Diligence

5.1. Risk-Based Approach: EWG employs a risk-based approach to monitor and manage the risks associated with each member, adjusting scrutiny levels based on the risk profile.

5.2. Enhanced Due Diligence: For high-risk categories, enhanced due diligence measures are undertaken to ensure a deeper understanding of Member activities and fund sources.

06. Monitoring and Reporting

6.1. Continuous Monitoring: Transaction monitoring systems are in place to detect unusual patterns of activity that may signify money laundering or terrorist financing.

6.2. Suspicious Activity Reporting: EWG has mechanisms to report suspicious activities to appropriate authorities without delay, ensuring legal compliance and mitigating potential risks.

07. Training and Awareness

7.1. Regular Training: All employees receive regular training on AML regulations and the latest trends in financial crime to ensure they remain vigilant and informed.

7.2. Awareness Programs: EWG conducts awareness programs to educate members about the risks of money laundering and the importance of compliance with AML policies.

08. Review and Update of AML Policy

8.1. Regular Reviews: The AML policy is reviewed regularly to capture changes in legislation, emerging risks, and operational adjustments.

8.2. Policy Updates: We may update our AML Policy from time to time. Any changes we make to our AML Policy in the future will be updated on this page with the ‘Last Updated’ date amended and, where appropriate, we will notify you by post or email.

09. Record Keeping

9.1. Document Retention: All records related to financial transactions and Member verifications are retained for a minimum period as prescribed by law, ensuring that information is available for investigative or audit purposes.

End of Anti-Money Laundering (AML) Policy.

Date Created: 04 April 2025

Last Updated: 06 April 2025 [v1.0]

Issuing Party: EWG
Receiving Party: EWG Members

Clarifying Club Terms

Know Your Client (KYC) Policy

Introduction

This Know Your Client (KYC) Policy (Policy) is issued by EFFORTLESSWEALTHGROUP LIMITED (collectively, “EffortlessWealthGroup”, “EWG”, “We”, “Us” or “Our”), a Private Investment Club, incorporated in England and Wales under company number 16252357, operating within the Standard Industrial Classification (SIC) code: 94990: Activities of Other Membership Organizations, whose registered office is 3rd Floor, 86-90 Paul Street, London, England, EC2A 4NE.

This Policy is issued to: Members of EWG defined as an individual who owns an approved EWG Membership Account.

01. KYC Policy Objective

1.1. The objective of the KYC policy at EffortlessWealthGroup (EWG) is to prevent the misuse of our services for money laundering or terrorist financing activities. Implementing robust KYC procedures allows EWG to better understand and manage its clients and their financial transactions effectively, thereby enhancing our ability to manage risks. In the event of any suspicious activities, EWG is committed to documenting and reporting such instances to the appropriate regulatory authorities in compliance with legal and regulatory requirements. Additionally, accounts associated with fraudulent activities will be promptly closed to safeguard the integrity of our operations.

02. KYC Prevention Objectives

2.1. The prevention objectives of EWG's KYC policy are designed to safeguard the integrity and security of our operations:

2.1.1. Data Integrity: To maintain the confidentiality and integrity of sensitive data obtained from Member account information and transactional activities.

2.1.2. Crime Prevention: To deter criminal elements from utilizing EWG for money laundering activities.

2.1.3. Member Understanding: To enhance the understanding of our Members and their financial dealings, which aids in more effective risk management.

2.1.4. Suspicious Activity Monitoring: To establish robust controls for the detection and reporting of suspicious activities in line with applicable laws and procedures.

2.1.5. Regulatory Compliance: To ensure adherence to all applicable laws and regulatory guidelines, thus upholding EWG's commitment to legal and ethical standards.

03. Required Documents for Account Opening

3.1. EWG requires the following documents from individuals when opening an account to ensure compliance with KYC regulations:

3.1.1. Identification Proof: A copy of a valid National ID, Passport, or Driving License showing the Member's photo and signature.

3.1.2. Proof of Residence: A copy of a recent Utility Bill, Bank Statement, or Residence Certificate displaying the Member's name and address, dated within the last 3 months.

04. Verification Process

4.1. If a Member is unable to provide a recent proof of residence at the time of account opening, they will have a thirty-day grace period to submit this document. During this period, the account will be considered partially verified, allowing only capital allocation and capital growth monitoring.

4.2. Should the thirty-day period elapse without the proof of residence being provided, the account will be closed, and any accrued profits will be transferred to the Member. Capital allocations are fully committed upon account activation, and a Member’s principal capital is non-withdrawable or refundable.

4.3. Full account verification is achieved once all required documents are submitted to EWG.

05. Capital Allocation: Proof of Transfer

5.1. For proof of transfer at the stage of capital allocation, EWG requires either a screenshot or PDF file, which will be requested via an on-platform, file upload button, after the Member selects their preferred method of funding.

5.2. At any point during your EWG Membership or within 6 months of a cancelled membership, EWG reserves the right to request the following in relation to your capital allocation:

5.2.1. A copy of your credit/debit card, used to allocate capital (front side with only the last 4 digits visible, back side with the CVV covered).

5.2.2. Bank statement of the account used to send the capital allocation, showing other transactions covered.

5.3. If you have any questions, please do not hesitate to contact our support team at onboarding@effortlesswealthgroup.com.

06. Document Security and Confidentiality

6.1. EFFORTLESSWEALTHGROUP LIMITED prioritizes the security of our members' documents with the highest level of respect and confidentiality. All documents submitted to us during the KYC process are protected with state-of-the-art encryption technologies throughout the review process, ensuring your personal information remains secure and private. We adhere to the highest standards of data protection and are registered with, and follow the provided guidelines of, the Information Commissioners Office, registration number: ZB881519.

07. Introduction to KYC Tiers

7.1. At EffortlessWealthGroup, we implement a tiered approach to our Know Your Client (KYC) process. This structured system is designed to enhance user experience and facilitate easier access to our services, while also ensuring robust compliance with Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) regulations. To meet our commitment to regulatory standards and protect against financial crimes, we reserve the right to collect and verify KYC data within our pre-set verification tiers.

08. Trigger Events for KYC Verification

8.1. Verification of KYC data is generally routine but becomes particularly crucial under specific circumstances that might indicate increased risk. These trigger events include:

8.1.1. Unusual account activity that deviates significantly from a member's typical transaction pattern.

8.1.2. Transactions that surpass predefined thresholds, internally determined and purposely not shared publicly to avoid criminals from circumnavigating the thresholds.

8.2. By adopting a tiered KYC approach, EWG can efficiently manage risk without compromising the security or the operational efficacy of our investment platform. This method allows us to adapt to the evolving needs of our members and the regulatory landscape.

09. Member Responsibilities

9.1. Members are required to ensure that all information provided to EWG is accurate, complete, and up-to-date. It is the member's responsibility to comply with all applicable regulatory requirements. This includes promptly updating any changes to personal information and adhering to all legal and regulatory frameworks that govern their activities within the private investment club. Members are encouraged to consult with legal or financial advisors to fully understand their obligations under these regulations.

End of Know Your Client (KYC) Policy.

Date Created: 04 April 2025

Last Updated: 06 April 2025 [v1.0]

Issuing Party: EWG
Receiving Party: EWG Members

Protecting Your Privacy

Privacy Policy

Introduction

This Privacy Policy (Policy) is issued by EFFORTLESSWEALTHGROUP LIMITED (collectively, “EffortlessWealthGroup”, “EWG”, “We”, “Us” or “Our”), a Private Investment Club, incorporated in England and Wales under company number 16252357, operating within the Standard Industrial Classification (SIC) code: 94990: Activities of Other Membership Organizations, whose registered office is 3rd Floor, 86-90 Paul Street, London, England, EC2A 4NE.

This Policy is issued to: Members of EWG defined as an individual who owns an approved EWG Membership Account.

01. Overview

1.1. Thank you for visiting the EWG Platform: www.effortlesswealthgroup.com (the “Platform”).

1.2. This is a Privacy Policy, in accordance with the General Data Protection Regulation (GDPR), of the EWG Platform and Connected Services.

1.3. EWG needs to gather and use certain information about individuals. In data protection terminology EWG is defined as the “Data Controller” in respect of the personal information you provide us with.

1.4. What Is This Policy For?

1.5. We value your privacy and want to be accountable to you, and transparent with you, in the way that we collect and use your personal information. We also want you to know your rights in relation to your personal information.

1.6. This Privacy Policy tells you what to expect when we collect and use your personal information. We have tried to make it simple and easy for you to read and find the information that is most relevant to you. It also describes how this personal data must be collected, handled and stored to meet our data protection standards and to comply with the law.

1.7. We are always looking to improve the information we provide to our Members. If you have any questions or feedback on this privacy policy, please let us know using our contact details.

1.8. Who Does This Policy Apply To?

1.9. This Privacy Policy applies to the collection, storage and use of personal information about you.

1.10. “You” refers to both Existing and Prospective EWG Members as well as Partners or any other people that EWG has a relationship with or may need to contact. These parties may be defined as the “Data Subjects”.

1.11. Specifically, this Privacy Policy provides you with details about the personal information we collect and hold about you, how we use your personal information and your rights regarding your personal information. It does not cover any use of your personal information by other Members whether they have accessed your information via our Platform or otherwise. That use will be governed by each relevant entity’s own privacy policy.

02. What We Do: Operating Statement

2.1. This statement of operation clarifies how we operate and what membership means.

2.2. EWG operates strictly as a Private Investment Club. EWG does not publicly market or promote any investment products.

2.3. No financial advice is provided by EWG. Members are responsible for making their own informed decisions regarding any opportunities discussed within the club. EWG does not manage or control Member funds. All capital allocations are voluntary and self-directed.

2.4. Access to opportunities, Asset Management Protocols (AMPs), or related services is made available exclusively within the closed membership network and may be subject to approval. EWG and its team operate solely as facilitators of private Member information and do not act in a regulated capacity.

2.5. Membership in EWG does not constitute investment advice, legal advice, or financial planning. By participating in the club, all members acknowledge that they are acting on their own behalf and take full responsibility for their own decisions.

03. How We Collect Your Personal Information

3.1. We will collect personal information as requested during your Member onboarding, as detailed in the EWG Know Your Client (KYC) Policy and as provided in your preferences once logged in.

04. How We Use Your Personal Information

4.1. We collect, use, and store your personal information for the following purposes:

4.1.1. Onboarding and Account Management: To facilitate your onboarding process as an EWG Member, maintain your Member Profile, and manage your ongoing membership and participation in investment opportunities.

4.1.2. Investment Opportunities: To enable you to explore and engage with investment opportunities offered through the EWG platform, including viewing details of potential investments and participating in voting on Asset Management Protocols (AMPs).

4.1.3. Communication and Support: To facilitate communication between you and EWG for service support, including technical assistance and responding to inquiries or requests.

4.1.4. Compliance and Legal Obligations: To comply with legal, regulatory, and compliance obligations, including but not limited to anti-money laundering (AML) and counter-terrorism financing (CTF) requirements.

4.1.5. Statistical Analysis and Platform Improvement: To conduct data analysis that helps us improve the functionality and user experience of our platform. This involves aggregating information to ensure content is presented effectively for you and improving platform security.

4.1.6. Customization and Preferences: To store information about your preferences, allowing us to customize our platform according to your individual interests and recognize you when you return.

4.1.7. Market Research: To conduct market research and statistical analysis to better understand your needs and interests, enhancing our service offerings and platform.

4.1.8. Security Measures: To enhance the security of our platform, ensure the integrity of our operations, and protect against fraud, unauthorized transactions, claims, or other liabilities.

4.1.9. Promotional Communications: Depending on your preferences and applicable laws, to send you promotional communications that may be of interest.

05. How We Use Your Personal Information

5.1. We determine the legal basis for processing your personal information in accordance with this Privacy Policy to ensure compliance with applicable laws.

5.2. Pre-Registration Data Processing: For personal data processed before Members register on the EWG Platform, such as when an existing Member shares a referral link with you before you have registered.

5.3. Sharing with Other Members: Your personal information may be shared with other EWG Members as part of our network activities. If you withdraw your consent, you may no longer be able to engage fully with the EWG Platform. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

5.4. Post-Withdrawal Use of Information: In certain circumstances, personal information may continue to be used post-withdrawal of consent, for example, if there are unresolved issues or claims that require investigation or resolution.

5.5. Member Engagement: When you engage with investment opportunities through the EWG Platform, it is necessary to process your personal information to fulfill our contractual obligations and ensure compliance with the operational standards of EWG.

5.6. Legal and Regulatory Compliance: We may be required to process your personal information to comply with legal obligations, such as in response to a legal request from law enforcement or other government agencies.

5.7. Public Interest: In certain limited circumstances, we may process personal information to perform tasks carried out in the public interest, such as participating in regulatory actions or investigations related to financial activities within the scope of EWG operations.

06. How And Why We Share Your Personal Information

6.1. EWG may share your personal information within our corporate group for internal administrative purposes. This includes but is not limited to ensuring consistent service quality, corporate strategy alignment, compliance with regulatory requirements, and conducting research and development. These activities are conducted under the basis of our legitimate interests.

6.2. Sharing with Third Parties: We collaborate with various third-party service providers and partners to enhance our services. This may include:

6.2.1. Payment processors and banking institutions for financial transactions.

6.2.2. IT and cloud service providers for data management and storage.

6.2.3. Legal and security consultants for ensuring compliance with applicable laws and regulations.

6.3. Third parties that receive personal information from EWG are obligated to protect it and are restricted from using such information for purposes beyond what is specified in our service agreements with them.

6.4. We may disclose your personal information:

6.4.1. To facilitate business development such as mergers, acquisitions, or asset sales.

6.4.2. In response to legal requests or to comply with legal obligations.

6.4.3. To protect the rights and safety of EWG, our members, and third parties, especially in situations that involve potential threats or fraud.

6.5. We may use and share anonymised or aggregated data with third parties for analytical and strategic purposes. This data does not reveal your identity and is used to understand Member trends and enhance service offerings.

6.6. We do not sell, rent, or trade your personal information with third parties without your explicit consent. If you have consented to a specific use of your personal information, you have the right to withdraw this consent at any time. To withdraw consent or discuss the processing of your information, please contact us directly.

07. How Long We Store Your Personal Information

7.1. We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. The length of time we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights. Please contact us for more specifics.

08. Your Rights

8.1. You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at legals@effortlesswealthgroup.com.

8.2. You have the following rights:

8.2.1. Right of access - You have a right of access to any personal information we hold about you. You can ask us for a copy of your personal information; confirmation whether your personal information is being used by us; details about how and why it is being used; and details of what safeguards are in place if we transfer your information outside of the European Economic Area ("EEA").

8.2.2. Right to update your information - You have a right to request an update to any of your personal information which is out of date or incorrect.

8.2.3. Right to delete your information - You have a right to ask us to delete any personal information which we are holding about you in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us via email at legals@effortlesswealthgroup.com.

8.2.4. We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are, using the email address above.

8.2.5. Right to restrict use of your information - You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us via email at legals@effortlesswealthgroup.com.

8.2.6. We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are, using the email address above.

8.2.7. Right to stop marketing - You have a right to ask us to stop using your personal information for direct-marketing purposes. If you exercise this right, we will stop using your personal information for this purpose.

8.2.8. Right to data portability - You have a right to ask us to provide your personal information to a third-party provider of services.

8.2.9. This right only applies where we use your personal information based on your consent or performance of a contract and where our use of your information is carried out by an automated process.

8.2.10. Right to object - You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information based on our, or another person's legitimate interest.

8.3. We will consider all such requests and provide our response within a reasonable period (and in any event within 30 days of your request unless we tell you we are entitled to a longer period allowed by applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.

8.4. If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.

09. Marketing Use

9.1. We may collect and use your personal information for undertaking marketing by email, social media, telephone and/or post.

9.2. We may send you certain marketing communications (including electronic marketing communications to existing Members) if it is in our legitimate interests to do so for marketing and business development purposes.

9.3. However, we will obtain your consent to direct marketing communications where we are required to do so by law and if we intend to disclose your personal information to any third party for such marketing.

9.4. If you wish to stop receiving marketing communications, you can unsubscribe, change your marketing preferences or contact us via email at legals@effortlesswealthgroup.com.

10. How We Keep Your Personal Information Secure

10.1. EWG is committed to protecting your personal information from loss, theft and misuse. We take all reasonable precautions to safeguard the confidentiality of your personal information, including through the use of appropriate organisational and technical measures.

10.2. These rules describe how keep your data secure:

10.2.1. When data is stored on paper, it is be kept in a secure place where unauthorised people cannot see it;

10.2.2. When not required, the paper or files should be kept in a locked drawer or filing cabinet;

10.2.3. Employees should make sure paper and printouts are not left where unauthorised people could see them (e.g. on a printer);

10.2.4. Data printouts should be shredded and disposed of securely when no longer required and within 5 working days;

10.2.5. When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts;

10.2.6. Data should be protected by strong password authentication that are changed regularly and never shared between employees;

10.2.7. If data is stored on removable media (e.g. a Data Stick or DVD), these should be kept securely locked away when not being used;

10.2.8. Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing service;

10.2.9. Servers containing personal data should be located in a secure place away from general office space;

10.2.10. Data should be backed up frequently and tested regularly, in line with company standard backup procedures;

10.2.11. If data is stored to laptops, smartphone or tablets it should be deleted as soon as possible after it has been used and, in any event, no longer than 12 hours after the data has been received; and

10.2.12. All servers and computers containing data should be protected by approved security software and a firewall.

10.3. During provision of your personal information to us, your personal information may be transferred over the internet. Although we make every effort to protect the personal information which you provide to us, the transmission of information over the internet is not completely secure.

10.4. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our Platform and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorised access to it.

10.5. Where we have given you, or where you have chosen, a password which enables you to access your profile and account on our Platform, you are responsible for keeping this password private and confidential. Please do not share your password with anyone.

11. Cookies

11.1. Some pages on our Platform use cookies, which are small files placed on your internet browser when you visit our Platform. We use cookies to offer you a more tailored experience in the future, by understanding and remembering your browsing preferences.

11.2. Our Platform uses cookies to distinguish you from other Members of our Platform. This helps us to provide you with a better experience when you browse our Platform and allows us to improve our site.

11.3. Where we use cookies on our Platform, you may block these at any time. To do so, you can activate the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our Platform or to use all the functionality and services provided through our Platform.

11.4. We use third party analytics providers to collect information about your use of our Platform, this allows us to improve how our service works. The information allows us to see the overall patterns of usage on our site and helps us record any difficulties you have with it.

11.5. These third-party analytics providers use cookies and other, similar technologies to collect information about the use of the site and to report statistics and trends to us without identifying you individually.

11.6. More information can be found by reviewing our Cookie Policy.

12. Links To Other Websites

12.1. Our Platform may contain hyperlinks to other websites that are not operated by us. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of such third-party websites or any association with their operators. This Privacy Policy only applies to the personal information that we collect or which we receive from third-party sources, and we cannot be responsible for personal information about you that is collected and stored by third-parties.

13. Changes To Our Privacy Policy

13.1. We may update our Privacy Policy from time to time. Any changes we make to our Privacy Policy in the future will be updated on this page with the ‘Last Updated’ date amended and, where appropriate, we will notify you by post or email.

14. Further Questions And How To Make A Complaint

14.1. If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact legals@effortlesswealthgroup.com.

14.2. You may also make a complaint to the Information Commissioner's Office (ICO), or the data protection regulator in the country where you usually live or work, or where an alleged infringement of the General Data Protection Regulation (GDPR) has taken place.

End of Privacy Policy.

Date Created: 04 April 2025

Last Updated: 06 April 2025 [v1.0]

Issuing Party: EWG
Receiving Party: EWG Members

Clarifying Club Terms

Cookie Policy

Introduction

This Cookie Policy (Policy) is issued by EFFORTLESSWEALTHGROUP LIMITED (collectively, “EffortlessWealthGroup”, “EWG”, “We”, “Us” or “Our”), a Private Investment Club, incorporated in England and Wales under company number 16252357, operating within the Standard Industrial Classification (SIC) code: 94990: Activities of Other Membership Organizations, whose registered office is 3rd Floor, 86-90 Paul Street, London, England, EC2A 4NE.

This Policy is issued to: Members of EWG defined as an individual who owns an approved EWG Membership Account.

01. Overview

1.1. Thank you for visiting the EWG Platform: www.effortlesswealthgroup.com (the “Platform”).

1.2. Some pages on our Platform use cookies, which are small files placed on your internet browser when you visit our Platform. We use cookies to offer you a more tailored experience in the future, by understanding and remembering your browsing preferences. By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy. You can modify your cookie settings at any time.

02. About Cookies

2.1. Cookies consist of pieces of text, often including unique identifiers, that are sent by web servers to web browsers, and which may then be sent back to the server each time the browser requests a page from the server.

2.2. Cookies can be used by web servers to identify and track Members as they navigate different pages on a website and to identify Members returning to a website.

2.3. Our Platform may use specific unique identifiers associated with your device, such as the device Advertising ID (a random and resettable ID on your device) and other data such as your geo-location or your network location.

2.4. Cookies may be either “persistent” cookies or “session” cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the browser and will remain valid until its set expiry date (unless deleted by the user before the expiry date). A session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

03. Our Cookies

3.1. Our Platform uses cookies to distinguish you from other Members of our Platform. This helps us to provide you with a better experience when you browse our Platform and allows us to improve our site.

3.2. Where we use cookies on our Platform, you may block these at any time. To do so, you can activate the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our Platform or to use all the functionality and services provided through our Platform.

3.3. We use third party analytics providers to collect information about your use of our Platform, this allows us to improve how our service works. The information allows us to see the overall patterns of usage on our site and helps us record any difficulties you have with it.

3.4. We use both “Session” and “Persistent” Cookies as well as “Essential” and “Functional” Cookies on this website.

3.5. Below is a table of certain cookies we use:

3.6. We may update our Cookie Policy from time to time. Any changes we make to our Cookie Policy in the future will be updated on this page with the ‘Last Updated’ date amended and, where appropriate, we will notify you by post or email. EWG aims to update this cookie policy within 30 days of the updated use of cookies.

3.7. EWG reviews and updates where necessary, its cookie and privacy policy every 12 months.

3.8. A full list of all cookies will be made available upon request. You can request this information by contacting us via email at: legals@effortlesswealthgroup.com.

End of Cookie Policy.

Date Created: 04 April 2025

Last Updated: 06 April 2025 [v1.0]

Issuing Party: EWG
Receiving Party: EWG Members

Understanding The Risk

Risk Warning Policy

Introduction

This Risk Warning Policy (Policy) is issued by EFFORTLESSWEALTHGROUP LIMITED (collectively, “EffortlessWealthGroup”, “EWG”, “We”, “Us” or “Our”), a Private Investment Club, incorporated in England and Wales under company number 16252357, operating within the Standard Industrial Classification (SIC) code: 94990: Activities of Other Membership Organizations, whose registered office is 3rd Floor, 86-90 Paul Street, London, England, EC2A 4NE.

This Policy is issued to: Members of EWG defined as an individual who owns an approved EWG Membership Account.

01. Overview

1.1. This policy cannot outline all the risks associated with the investments we make available to you. Before engaging with any investment, ensure you fully understand its nature and your exposure to risk. Investments vary widely in their potential risks and rewards, and it is crucial that any investment you consider is suitable for your personal circumstances and financial capacity. We strongly advise you to seek independent professional advice before committing to any investment.

02. Regulatory Risk and Member Protection

2.1. EFFORTLESSWEALTHGROUP LIMITED (EWG) operates strictly as a Private Investment Club under the official name: EffortlessWealthGroup Private Investment Club, and, as such, is not regulated by the Financial Conduct Authority (FCA) or any other financial regulatory body. As such, investments made through EWG do not carry the protections usually afforded by regulated investment activities, such as access to the Financial Services Compensation Scheme (FSCS) or the Financial Ombudsman Service (FOS). Members should be aware that their capital is at risk, and EWG does not offer any form of compensation scheme should something go wrong. It is recommended that members seek independent advice and ensure they fully understand the risks associated with the investment opportunities offered by EWG.

03. General Risks

3.1. All investment opportunities facilitated by EWG carry inherent risks. This section outlines general risks associated with participating in financial markets or other investment venues. These risks include, but are not limited to, market volatility, economic fluctuations, and external factors beyond EWG's control. It is important for members to understand that the value of investments can fluctuate, potentially resulting in a loss, including the loss of the principal amount invested. Further detailed risk information may be provided as relevant throughout your engagement with our services. We encourage all members to carefully consider their personal risk tolerance and investment objectives in light of potential losses and market uncertainties.

3.2. Past performance is not a guide to future performance. Our service is provided on an execution-only basis, which means we will not give you any form of investment advice or tax advice, or advise you about the merits of a particular transaction or otherwise. In providing our Services, we are not required to assess the suitability for you of the Investments or Services provided or offered and therefore you will not benefit from the protection of the FCA Rules on assessing suitability. The Services offered by us and the Investments those services provide access to may not be suitable for you. If you have any doubts as to the merits of an Investment, you should seek advice from an independent financial adviser who is authorised under the Financial Services and Markets Act 2000 to advise on such Investments.

04. Operational Risk

4.1. Operational risks refer to the potential losses stemming from inadequate or failed internal processes, people, systems, or from external events. This includes but is not limited to system outages, human error, or disruptions from unforeseen events like natural disasters. In the context of the EWG's operations, these risks could affect the management and execution of transactions or the accuracy of information and reporting. Members should be aware that while preventative measures and controls are rigorously applied, the inherent nature of such risks means that they cannot be completely eliminated. As such, members are encouraged to understand the scope of operational risks involved and consider the impact these may have on their investment decisions.

05. Liability and Understanding Risks

5.1. EWG is not liable for any damages arising from uncontrollable events such as force majeure incidents, government restrictions, military actions, suspension of activities, and other circumstances beyond our control. Engaging with EWG affirms your understanding of the inherent risks associated with our investment environment. Membership entails exposure to market risks experienced by participants in investment markets.

5.2. Investments carry potential risks along with opportunities for gains. By electing to allocate your funds to available opportunities, you acknowledge that the outcomes projected on the EWG platform cannot be assured. It is crucial for members to recognize that while opportunities for gains exist, there is also a risk of loss.

06. Insolvency Risk

6.1. Members should be aware that the insolvency or default of EFFORTLESSWEALTHGROUP LIMITED, operating under the trade name EWG, or any partners involved in managing the club's operations, could result in significant financial losses. In such events, there may be a need to liquidate or close positions and you may not recover the full value of your originally allocated capital, potentially incurring partial or total losses.

6.2. As part of your membership with EWG, you are required to acknowledge and understand the full spectrum of risks associated with your participation, including any operational disruptions or insolvencies that could affect asset values and investment returns.

6.3. It is crucial to familiarize yourself with all relevant details and governing regulations as outlined in the EWG Governance & Rules of Engagement Framework, along with a comprehensive understanding of the general principles governing our investment opportunities.

07. Current Scope of Investments

7.1. This clause is specifically designed to accommodate the inclusion of additional investment classes and opportunities in the future. Each class will be outlined under this section with specific investment opportunities and their associated risks listed as sub-items, ensuring clarity and compliance with regulatory requirements for each class of investments.

7.2. As of the last update, the investment opportunities provided by EWG, exclusively to its Private Investment Club Members are presented in the table below:

We’re not FCA regulated,

We just hold ourselves to that standard.

EWG Private Investment Club Membership Operating Statement

Welcome to the EffortlessWealthGroup Private Investment Club.

End of Membership Operating Statement.

Governance & Terms of Engagement Framework

Introduction

01. Identification & Strategic Intent

02. Membership

03. Capital Allocation

04. Marketing EWG

05. Governance & Operations

06. Confidentiality

07. Right To Terminate

End of Governance & Terms of Engagement Framework.

09. Appendix A - Commissions Structure.

Figure 3a: Finders & Facilitation Commissions Table For EWG Contributors

​

9.6. With a Partner status, the commissions you’ll earn, either as a direct referrer earning from your Tier One Members or as a Link earning from your Tier Two Members, are as follows:

Figure 3b: Finders & Facilitation Commissions Table For EWG Partners

​

9.7. Below is a depiction of how the Finders & Facilitation Commissions are split across all entities.

Figure 3c: Finders & Facilitation Commissions Distribution Chart ​

Figure 4a: Profit Split Table For EWG Contributors

​

9.10. With a Partner status, the profits you’ll earn, either as a direct referrer earning from your Tier One Members or as a Link earning from your Tier Two Members, are as follows:

Figure 4b: Profit Split Table For EWG Partners

​

9.11. Below is a depiction of how the Profits are split across all entities.

Figure 4c: Profit Split Distribution Chart​

Figure 5a: Rebates Table For EWG Contributors

9.14. With a Partner status, the rebates you’ll earn, either as a direct referrer earning from your Tier One Members or as a Link earning from your Tier Two Members, are as follows:

Figure 5b: Rebates Table For EWG Partners

​

9.11. Below is a depiction of how the Rebates are split across all entities.

Figure 4c: Profit Split Distribution Chart​

End of Appendix A: Commissions Structure

Concierge Service Agreement.

Introduction

01. Overview

02. Scope of Service

03. Member Authorisation

04. No Financial Advice or Management

05. Risk and Liability

06. Compliance and Regulatory Adherence

07. Confidentiality & Data Security

08. Dispute Resolution

09. Amendments to the Terms of Service

10. Termination of Service

11. Acknowledgment & Agreement

12. Contact Information

Client Confirmation Statement

End of Concierge Service Agreement.

Anti-Money Laundering (AML) Policy

Introduction

01. Overview

02. Objective

03. Scope of Application

04. AML Compliance Structure

05. Member Due Diligence

06. Monitoring and Reporting

07. Training and Awareness

08. Review and Update of AML Policy

09. Record Keeping

End of Anti-Money Laundering (AML) Policy.

Know Your Client (KYC) Policy

Introduction

01. KYC Policy Objective

02. KYC Prevention Objectives

03. Required Documents for Account Opening

04. Verification Process

05. Capital Allocation: Proof of Transfer

06. Document Security and Confidentiality

07. Introduction to KYC Tiers

08. Trigger Events for KYC Verification

09. Member Responsibilities

End of Know Your Client (KYC) Policy.

Privacy Policy

Introduction

01. Overview

EWG Private
Investment Club
Membership Operating Statement

Figure 3c: Finders & Facilitation Commissions Distribution Chart

Figure 4c: Profit Split Distribution Chart

Figure 4c: Profit Split Distribution Chart