Disclosures

E-mail Confidentiality Notice

This message is for the named person’s use only. It may contain confidential, proprietary or legally privileged information. No confidentiality or privilege is waived or lost by any transmission errors. If you receive this message in error, please immediately delete it and all copies of it from your system, destroy any hard copies of it and notify the sender. You must not, directly or indirectly, use, disclose, distribute, print, or copy any part of this message if you are not the intended recipient. ULYSSES COMMODITIES LLC (“Ulysses”) and each of its subsidiaries each reserve the right to intercept and monitor all electronic communications through its networks if legally allowed. Message transmission is not guaranteed to be secure. This message is for information only and its accuracy is not guaranteed; it is not an opinion. Price/yield information is indicative and may be changed without notice.

In order to direct execution orders, Modify or cancel such orders, receive your daily/monthly trade confirmation (“Customer Information”) via Instant Messenger (“IM”) and or email, you (“Customer”) acknowledge, confirm and consent that the following terms shall govern such transmissions, and will apply per every given transmission: Customer has requested that Ulysses Commodities, LLC (“Ulysses”) transmit and communicate market orders, alter/modify or cancel such orders in Covered Products and Services and respective Customer Information via the Internet by IM and or E-mail transmission. This consent for transmission may also equally apply to daily, monthly and annual statements/confirmations/bills, and any other sensitive customer information. Customer understands that this consent to electronic transmission of orders and statements is revocable, but will remain in effect until Ulysses receives explicit written notice from customer to revoke such consent.

By engaging business w/ Ulysses, and everytime customer engages business with Ulysses, customer has given her/his firm’s consent that Ulysses transmit such information through E-mail and or Instant Messenger and/or other means under the following conditions:

1. Ulysses makes no warranties or representations, express or implied, regarding the Instant Messenger (“IM”) or e-mail service and shall not be liable for any interruptions, delays, inaccuracies, errors, omissions or any faults in the IM and or e-mail service, however occurring.
2. Customer will indemnify and hold Ulysses or any of its subsidiaries or affiliates harmless against any and all claims by parties or third parties in any way connected to or arising out of the use of IM and or e-mail service.
3. Performance of IM and/or e-mail service will be excused if prevented by circumstances beyond the reasonable control of Ulysses, including but not limited to: Acts of God or public enemy, fire or other casualty, labor disputes, or failure of communications companies.
4. Customer will be responsible for informing Ulysses of changes in its services (Communication Company, IT Providers, etc) with regard to changes in the e-mail address or IM itself. Failure to communicate new or changed IM and or e-mail addresses will result in failure to receive/transmit communications in this manner, or in exposing third parties to confidential information
5. Customer warrants and represents that it fully understands the risks associated with the transmission of information by use of the internet, including but not limited to the tampering with, or unauthorized use of the Customer’s Information by unauthorized third parties and that it will implement the highest standard of care to prevent any unauthorized receipt or use of Customer’s Information.
6. Privacy of Instant Messages/E-mails: unless otherwise specified in writing customer information relayed through IM’s/E-mail and or other means will be confidentially and strictly held with Ulysses. It will not be forwarded, distributed, or otherwise copied and pasted to other 3rd parties unless required to do so by law to comply with regulatory concerns. Other customers who copy/paste, distribute, present, discuss or otherwise pass on information from Ulysses to other 3rd parties, are exposing themselves to potential liquidated damages to be determined by the severity and confidentiality of the information transmitted. Customer/s hereby absolve and indemnify any liability on Ulysses as a result of dealing with a negligent 3rd party customer that has transmitted their information and violated this policy, even if such information was passed on by Ulysses. While Ulysses will employ reasonable means to care for customer confidentiality given the difficult constraints and rapid fire transmission of electronic transmission, such indemnification shall be absolute for Ulysses.
7. All information above shall complement and supplanted to the Privacy Policy of the firm. When in conflict the version provider stricter indemnification and protection of liability on Ulysses shall prevail.
8. Ulysses reserves the right to modify or discontinue this service at any time without notice.

PERSONAL TRADING POLICY

Discretionary Accounts
In order to exercise discretion over a futures customer’s account, NFA requires a person to be:

1. Registered as a CTA or
2. Registered as an AP for a minimum of two years and to have two years’ working experience in that capacity.

A customer must provide a specific written authorization (namely power of attorney) to open a discretionary account. NFA Rule 2-8 also requires a firm to have written review procedures for discretionary accounts and that a supervisory employee review discretionary trading activity on a regular basis.

It is Ulysses Commodities policy not to undertake any accounts on a discretionary basis at this time.

Proprietary Accounts
Ulysses Commodities LLC is an agency execution brokerage, as such we maintain the highest fiduciary duty to our clients, and we do not engage in any proprietary trading of any sorts with the clients. If in the future this policy shall change, all customers must receive a written acknowledgement of such material change in the business model.

Bunched Order Allocation
The Commission has proposed amending Regulation 1.35(a-1)(5) to provide procedures for end-of-day allocation of bunched orders for both cleared and uncleared products. In addition, under the proposed amendments, Futures Commission Merchants and Introducing Brokers would be able to serve as eligible account managers for bunched orders provided that, consistent with Regulations 155.3 and 155.4, they do not bunch proprietary orders with customer orders.

Employee Trading Personal Account
Ulysses Commodities Operating Agreement Article 5, Section 5.6a(i) discusses the firm’s “Covered Products and Services” this shall be defined as exchange cleared and listed commodities instruments for both futures and options contracts.
Ulysses Commodities LLC is strictly an execution agency brokerage desk generating revenue based on commission income; as such our fiduciary duty is first and foremost to our institutional clientele. As such it is against firm policy to day trade such Covered Products and Services. This extends to all exchange (ICE and or NYMEX) cleared futures and or options contracts. AP’s and or Principles that are found trading against clients, or in Covered Products and Services can be terminated for cause immediately.
Exceptions apply to the following products:

1. Peripheral financial instruments in which AP or Principles cannot affect liquidity, or price of Covered Products and Services are acceptable. Examples include: Stocks of commodities companies, commodity ETF’s, Bond of oil producers, MLP’s, and so forth.
2. Disclosure/Audited records – all AP’s and principles must, upon request of either: supervisor, client, or regulatory agency, produce trading records.

INTRODUCING BROKER ACCOUNT - TERMS OF SERVICE

In consideration of you ("Customer") opening an account and engaging Ulysses Commodities LLC ("Ulysses") to act as execution agency brokerage on your behalf, for the purchase or sale of commodity futures, commodity options, forward contracts, physical or cash commodities, and exchange for physical ("EFP") or Covered Products and Services transactions (Collectively "Commodity Contracts"), Customer consents and confirms that the following terms will legally bound such relationship, and confers consent per every transaction engaged with Ulysses: I. Customer acknowledges the following:

1. The purchase and sale of Commodity Contracts is speculative, involves a high degree of risk and is suitable only for persons who can assume the risk of loss in excess of their margin deposits or of their entire option premium. Customer understands that because of the low margin normally required in Commodity Contract trading, price changes in Commodity Contracts may result in significant Customer losses, which losses may substantially exceed Customer’s margin deposits and any other deposits Customer may make. Customer also acknowledges that Customer has received, has read and understands this agreement risk disclosures.
2. Customer understands that there are no guarantees of profit or guarantees against loss in Commodity Contract trading. Customer has received no such guarantees from Ulysses or from any of its representatives. Customer acknowledges its awareness of the risks inherent in Commodity Contract trading and is financially able to bear such risks and withstand any losses incurred.
3. Customer authorizes Ulysses to execute such transactions for the Customer’s account, to act as counterparty to Commodity Contracts and to exercise commodity options for Customer’s account in accordance with Customer’s oral or written instructions. Ulysses shall have the right to refuse to accept any of Customer’s orders. Ulysses shall also have the right to tape record all telephone conversations with Customer.
4. Customer understands that Ulysses acts solely as an execution brokerage desk, and does not take any principle positions, unless otherwise notified in writing. Furthermore, it is firm policy to disclose any positions brokers maintain in their individual Personal Trading Accounts in Covered Products and Services as defined under firm’s policies, and may change from time to time
5. Ulysses shall not be responsible to Customer in any case for an approved third party approved by the customer for error or negligence on the third’s party’s part or for anyone who is not an not employees of Ulysses.
6. Customer acknowledges that the execution of futures may imply anticipation of making or accepting delivery. Customer hereby authorizes Ulysses to take all action deemed necessary by Ulysses in the event Ulysses might be faced with taking physical delivery for customer’s orders and customer hereby agrees to indemnify Ulysses from all costs associated therewith. Ulysses may, in its sole discretion, take necessary action to prevent such occurances.
7. Customer acknowledges the right of Ulysses to limit execution without notice to the Customer, if Ulysses is so compelled by any regulatory agency due to open positions outnumbering open position limits mandating by the CFTC, as specificed in 1.73 or any other DCM or regulatory limitations adn regulations.

II. Customer shall deposit with their Prime Broker / FCM / Clearing House the applicable initial and maintenance margin requirements; pay interest, commission charges in effect from time to time, (whichcommissions may be shared by more than one of Customer’s agents) and other fees and charges, as well ascosts to Ulysses occasioned by carrying the account of the Customer. Customer will pay any commissionsattributable to Ulysses either directly or through their clearing house/FCM/Prime Broker and pay the interest and service charges on any balances overdue by more than 30 days, as per invoices as well as costs of attorney’s fees incurred in collecting any such deficit or defending claims brought by Customer in which Ulysses is the prevailing party. Fees and charges, in addition to commissions and interest, may include, butare not limited to rollover fees and charges, currency conversion fees and charges, account transfer fees andcharges, and any fees and charges imposed by any interbank agency, bank, contract market or other regulatory or self-regulatory organization. Ulysses reserves the right to change its fee structure at any time.

III. Customer understands and acknowledges that Ulysses acts as execution agent for all transactions which are executed on commodity futures exchanges and or bilaterally over the counter. Customer acknowledges that in circustances where Ulysses unitentionally ends up the guarantor of the financial responsibility of the Customer or vicariously liable for customer’s actions that Ulysses has full authority and consent of customer to protect, prevent and take necessary action to absolve itself of any financial liabilities or otherwise. Therefore, Customer agrees to hold Ulysses harmless with respect to any and all such related actions.

IV. If Customer directs Ulysses to enter into any Commodity Contracts denominated in a foreign currency, than any profit or loss arising as a result of a fluctuation in the exchange rate affecting such currency will be entirely for Customer’s account and risk. Ulysses acts solely as an execution desk.

V. Customer acknowledges that:

1. any market recommendations and information communicated to Customer by Ulysses do not constitute anoffer to sell, or the solicitation of an offer to buy any commodity, or any commodity futures contract;
2. such recommendations and information, although based upon information obtained from sources believedby Ulysses to be reliable, may be incomplete and may not be verified
3. Ulysses makes no representation, warranty or guarantee as to, and shall not be responsible for, the accuracyor completeness of any information or trading recommendation furnished to Customer. Customerunderstands that Ulysses and/or its officers, directors, affiliates, stockholders or representatives may have aposition or positions in and may intend to buy or sell commodities or commodity futures contracts, whichare the subject of market recommendations furnished to Customer, and that the position or positions of Ulysses or any such officer, director, affiliate, stockholder, or representative may or may not be consistent with the recommendations furnished to Customer by Ulysses. Customer is also aware of Personal Trading Disclosure and policy which may change from time to time.

V. All transactions by Ulysses on Customer’s behalf shall be subject to the applicable constitution, rules, regulations, customs, usages, rulings, and interpretations of the exchanges or markets on which such transactions are executed by Ulysses or its agents for Customer’s account (such as the Chicago Mercantile Exchange and its affiliated clearing house, the National Futures Association and to all applicable governmental acts and statutes such as the Commodity Exchange Act or the Commodity Futures Trading Commission Act of 1974) and to rules and regulations made thereunder. Ulysses shall not be liable to Customer as a result of any action taken by Ulysses, or its agents, to comply with any such constitution, rule, regulation, custom, usage, ruling, interpretation, act or statue. If Customer is subject to regulation by any regulatory body, Customer agrees that Ulysses has no duty to ascertain or ensure that Customer is in compliance with any governing statutes or rules.

VI. Customer acknowledges and agrees that Ulysses shall not be responsible to Customer for any losses resulting from conduct or advice (including but not limited to errors and negligence) on the part of anybroker/dealer, futures commission merchant, independent introducing broker, commodity trading advisor,or any other person or entity introducing Customer to Ulysses or having trading authority over the accountof Customer at Ulysses. Customer specifically agrees that Ulysses shall have no obligation to supervise the activities of any such person or entity and Customer will indemnify Ulysses and hold Ulysses harmless fromand against all losses, liabilities, and damages (including attorney’s fees) incurred by Ulysses as a result of anyactions taken or not taken by such person or entity.

VII. Customer authorizes Ulysses to verify the information provided by the customer as Ulysses shall deem appropriate from time to time and as mandated by the NFA and CFTC regulations. Customer understandsthat an investigation may be made pertaining to Customer’s credit standing and that Customer may make awritten request within a reasonable period of time for complete and accurate disclosure of its nature andscope.

VIII. Ulysses shall not be responsible for delays in the execution of orders due to breakdown or failure of transmission, or communication facilities, or to any other cause beyond Ulysses’ control. Since Ulysses doesnot control signal power, its reception or routing via internet, configuration of Customer’s equipment orreliability of its connection, Ulysses shall not be liable for any claims, losses, damages, costs or expenses,including attorneys’ fees, caused, directly or indirectly, by a break-down or failure of any transmission or communication system or computer facility or trading software, whether belonging to Ulysses, Customer,any market, or any settlement or clearing system when Customer trades on-line (via internet, IM, orotherwise electronically).

IX. Confirmation of trades, contracts, statements of account, and any other notices transmitted by Ulysses toCustomer shall be transmitted to either the email address or the physical address shown in and to theattention of the person (s) named in the "Customer Account Documentation" and shall be conclusivelydeemed accurate and complete, and Customer waives and releases any claim relating thereto, if not objected to, in writing, prior to the opening of trading on the contract market on which such transaction occurred on the next business day following the day on which such communication was first received. The price at which an order is executed shall be binding notwithstanding the fact an erroneous report is made. An order which was executed but in error reported as not executed shall be binding. Customer shall direct all objections to Ulysses Commodities LLC 3311 Richmond Avenue; Suite 110; Houston TX 77098

X. Customers not domiciled in the United States (Foreign Accounts) may be asked to comply with requests for special information by Ulysses as required by any governmental unit or regulatory agency. This includes, but is not limited to, special calls for information and or OFAC regulations. In the event of a special call for information, Ulysses shall be required to obtain the information set forth by any governmental unit or regulatory agency requesting information. In addition, failure to respond to a special call for information may cause transactions to be restricted for Customer.

XI. The rights and remedies conferred upon the parties hereto shall be cumulative, and the exercise or waiver of any thereof shall not preclude or inhibit the exercise of additional rights or remedies.

XII. Subject to the Arbitration Agreement between Ulysses and Customer, Customer agrees that any civil action or other legal proceeding between Ulysses or its employees, agents, representatives, affiliated brokers and/orassociated persons, on the one hand, and Customer, on the other hand, arising out of or relating to thisAgreement, transactions hereunder, or Customer’s account shall be brought, heard and resolved in theCourts of Texas and Customer waives the right to have such proceeding transferred to any other location. In addition, Customer waives the right to trial by jury in any such action or proceeding. Any such action orproceeding shall be governed by the law of the State of Texas. No action, including arbitration, andregardless of form arising out of or relating to this Agreement, transactions hereunder, or Customer’s account may be brought by Customer more than one year after the cause of action arose (regardless of thedate of discovery of the alleged injury), provided, however, that any action brought under the provisions ofSection 14 of the Commodity Exchange Act may be brought at any time within two years after the cause ofaction accrues.

XIII. Customer represents that (1) he/she is (or, if Customer is a corporation, that each officer and director is, if Customer is a partnership, that each partner is) an adult of sound mind and is under no legal disability whichwould prevent him/her from trading in commodities, commodity futures contracts, options contracts,forward contracts, foreign exchange or other physical or cash contracts therein or entering into thisAgreement; (2) he/she is (or its officers and directors or its partners are) authorized to enter into this Agreement.

XIV. Customer warrants the accuracy of the information contained in the account application to be complete, true and correct and agrees that Customer will promptly notify Ulysses of any material change in theinformation. Customer further warrants that no one except Customer has an interest in the account and thatCustomer has full power and authority to enter into this Agreement and to engage in the transactions of thekind contemplated herein.

XV. Customer agrees to pay to Ulysses the commissions, fees and other charges as are in effect from time to time, and Customer hereby authorizes Ulysses to request such amount of any such commissions, fees andcharges from Customer’s Account as such commissions, fees and charges are incurred. Ulysses may providenotice electronically or otherwise of any changes in its amount and type of commissions, fees and othercharges, and the effective date of such charges. If Customer is introduced to Ulysses by another party, such other party may receive a portion of any commission paid to Ulysses by Customer.

XVI. This Agreement, including all authorizations, shall inure to the benefit of Ulysses, its successors and assignsand shall be binding upon Customer and Customer’s personal representatives, executors, trustees,administrators, agents, successors, and assigns. In the event of (a) the death or judicial declaration ofincompetence of Customer; (b) the filing of a petition in bankruptcy, or a petition for the appointment of areceiver, or the institution of any insolvency or similar proceeding by or against Customer; (c) the filing ofan attachment against any of Customer’s accounts carried by Ulysses; (d)Customer’s failure to provideUlysses any information requested pursuant to this agreement; or (f) any other circumstances ordevelopments that Ulysses deems appropriate for its protection, and in Ulysses’ sole discretion, it may takeone or more, or any portion of, the following actions: (1) satisfy any obligation Customer may have toUlysses, either directly or by way of guaranty or suretyship, out of any Customer’s funds or property in itscustody or control or in the custody or control of Ulysses; (2) cancel any or all outstanding orders orCommodity Contracts, or any other commitments made with Customer. Any of the above actions may betaken without demand for margin or additional margin, without prior notice of sale or purchase or othernotice to Customer, Customer’s personal representatives, heirs, executors, administrators, trustees, legateesor assigns and regardless of whether the ownership interest shall be solely Customers or held jointly withothers.

XVII. Customer shall indemnify, defend and hold Ulysses, its affiliates, directors, officers, stockholders, employees, agents, successors and assigns harmless from and against any and all liabilities, claims, losses,damages, costs and expenses, including reasonable attorneys’ fees and expenses, incurred by Ulysses, arisingfrom (a) Customer’s failure to fully and timely perform its obligations hereunder, or (b) any of Customer’srepresentations and warranties made being untrue or incorrect. Customer also agrees to pay promptly to Ulysses any and all claims, losses, damages, costs and expenses, including reasonable attorneys’ fees,incurred by Ulysses in enforcement of any of the provisions of this Agreement and any of the transactionscontemplated hereunder, the collection of any amounts due hereunder, and the defense of any action orproceeding, including an arbitration proceeding, brought by Customer against Ulysses in which Ulysses isthe substantially prevailing party.

XVIII. Limitation of Liability: In no event shall Ulysses be liable to customer or any person for indirect, incidental, special, punitive or consequential damages of any kind or nature whatsoever, whether arising under contract,warranty, or tort (including negligence or strict liability) or any other theory of liability even if the possibilityof such damages were disclosed to Ulysses or could have been reasonably foreseen by Ulysses. Thelimitation of liability reflects the allocation of risk between the parties. The limitation specified herein will survive and apply even if any limited remedy specified in this Agreement is found to have failed of itessential purpose.

XX. Customer agrees and acknowledges that: (a) This IB Customer Agreement supplements the FCM Customer Agreement in so far as it sets forth the rights and obligations between Ulysses as introducing broker andCustomer, but is not to be construed as amending, supplementing or superseding the FCM CustomerAgreement as between FCM and Customer. (b) Customer agrees that it will comply with the terms of theFCM Customer Agreement and that any breach by Customer of such terms constitutes a breach byCustomer of this IB Customer Agreement. (c) Customer further agrees that Ulysses may, to the extent permitted by Applicable Law (as defined in the FCM, Clearing House, or Prime Broker, CustomerAgreement), take any action under the FCM Customer Agreement that may take, including withoutlimitation making demand for margin, brokerage commissions or other payments, exercising any of theremedies or limiting scope of service, and that Customer is bound by the terms of the FCM CustomerAgreement in respect of such actions the same as if such actions were taken by FCM.

XXI. Customer represents and warrants that: (a)Customer has full right, power and authority to enter into this IB Customer Agreement and the FCM Customer Agreement, and the person or persons executing suchAgreements on behalf of Customer is (are) authorized to do so; (b) The Agreements are binding onCustomer and enforceable against Customer in accordance with their respective terms; (c) Customer maylawfully establish and open the Account with FCM for the purpose of effecting purchases and sales ofContracts through Ulysses as introducing broker and FCM as futures commission merchant; (d) transactions entered into pursuant to the Agreements will not violate any Applicable Law, other law to which Customeris subject or any agreement to which Customer is subject or a party; and (e) all information provided byCustomer in the Commodity Futures Account Application preceding the FCM Customer Agreement("Application") is true and correct and Customer shall immediately (and in no event later than within onebusiness day) notify Ulysses of any change in such information.

XXII. Customer understands that and acknowledges that to conform and comply with National Futures Association’s record keeping regulation as per CFTC regulations a detailed record trail of all trades will bekept for a period of 5 (five) years.

RISK DISCLOSURE STATEMENT FOR FUTURES AND OPTIONS

This statement is required to be furnished to you in accordance with Rule 1.55, and Rule 33.7 of the Commodity Futures Trading Act. This brief statement does not disclose all of the risks and other significant aspects of trading in futures and options. In light of the risks, you should undertake such transactions only if you understand the nature of the contracts (and contractual relationships) into which you are entering and the extent of your exposure to risk. Trading in futures and options is not suitable for many members of the public. You should carefully consider whether trading is appropriate for you in light of your experience, objectives, financial resources and other relevant circumstances.

I. Effect of ‘Leverage’ or ‘Gearing’

Transactions in futures carry a high degree of risk. The amount of initial margin is small relative to the value of the futures contract so that transactions are ‘leveraged’ or ‘geared.’ A relatively small market movement will have a proportionately larger impact on the funds you have deposited or will have to deposit; this may work against you as well as for you. You may sustain a total loss of initial margin funds and any additional funds deposited with the firm to maintain your position. If the market moves against your position or margin levels are increased, you may be called upon to pay substantial additional funds on short notice to maintain your position. If you fail to comply with a request for additional funds within the time prescribed, your position may be liquidated at a loss and you will be liable for any resulting deficit.

II. Risk-reducing Orders or Strategies

The placing of certain orders (e.g., ‘stop-loss’ orders, where permitted under local law, or ‘stop-limit’ orders) which are intended to limit losses to certain amounts may not be effective because market conditions may make it impossible to execute such orders. Strategies using combinations of positions, such as ‘spread’ and ‘straddle’ positions may be as risky as taking simple ‘long’ or ‘short’ positions. OPTIONS

III. Variable Degree of Risk

Transactions in options carry a high degree of risk. Purchasers and sellers of options should familiarize themselves with the type of option (i.e. put or call) which they contemplate trading and the associated risks. You should calculate the extent to which the value of the options must increase for your position to become profitable, taking into account the premium and all transaction costs. The purchaser of options may offset or exercise the options or allow the options to expire. The exercise of an option results either in a cash settlement or in the purchaser acquiring or delivering the underlying interest. If the option is on a future, the purchaser will acquire a futures position with associated liabilities for margin (see the section on Futures above). If the purchased options expire worthless, you will suffer a total loss of your investment which will consist of the option premium plus transaction costs. If you are contemplating purchasing deep out-of-the money options, you should be aware that the chance of such options becoming profitable ordinarily is remote. Selling (‘writing’ or ‘granting’) an option generally entails considerably greater risk than purchasing options. Although the premium received by the seller is fixed, the seller may sustain a loss well in excess of that amount. The seller will be liable for additional margin to maintain the position if the market moves unfavorably. The seller will also be exposed to the risk of the purchaser exercising the option and the seller will be obligated to either settle the option in cash or to acquire or deliver the underlying interest. If the option is on a future, the seller will acquire a position in a future with associated liabilities for margin (see the section on Futures above). If the option is ‘covered’ by the seller holding a corresponding position in the underlying interest or a future or another option, the risk may be reduced. If the option is not covered, the risk of loss can be "unlimited." Certain exchanges in some jurisdictions permit deferred payment of the option premium, exposing the purchaser to liability for margin payments not exceeding the amount of the premium. The purchaser is still subject to the risk of losing the premium and transaction costs. When the option is exercised or expires, the purchaser is responsible for any unpaid premium outstanding at that time. ADDITIONAL RISKS COMMON TO FUTURES AND OPTIONS

IV. Terms and Conditions of Contracts

You should ask the firm with which you deal about the terms and conditions of the specific futures or options which you are trading and associated obligations (e.g. the circumstances under which you may become obligated to make or take delivery of the underlying interest of a futures contract and, in respect of options, expiration dates and restrictions on the time for exercise). Under certain circumstances the specifications of outstanding contracts (including the exercise price of an option) may be modified by the exchange or clearing house to reflect changes in the underlying interest.

V. Suspension or Restriction of Trading and Pricing Relationships

Market conditions (e.g., illiquidity) and/or the operation of the rules of certain markets (e.g., the suspension of trading in any contract or contract month because of price limits or ‘circuit breakers’) may increase the risk of loss by making it difficult or impossible to effect transactions or liquidate/offset positions. If you have sold options, this may increase the risk of loss. Further, normal pricing relationships between the underlying interest and the future, and the underlying interest and the option may not exist. This can occur when, for example, the futures contract underlying the option is subject to price limits while the option is not. The absence of an underlying reference price may make it difficult to judge ‘fair’ value.

VI. Deposited Cash and Property

You should familiarize yourself with the protections accorded money or other property you deposit for domestic and foreign transactions, particularly in the event of a firm insolvency or bankruptcy. The extent to which you may recover your money or property may be governed by specific legislation or local rules. In some jurisdictions, property which had been specifically identifiable as your own will be pro-rated in the same manner as cash for purposes of distribution in the event of a shortfall.

VII. Commission and Other Charges

Before you begin to trade, you should obtain a clear explanation of all commission, fees and other charges for which you will be liable. These charges will affect your net profit (if any) or increase your loss.

VIII. Transactions in Other Jurisdictions

Transactions on markets in other jurisdictions, including markets formally linked to a domestic market, may expose you to additional risk. Such markets may be subject to regulation which may offer different or diminished investor protection. Before you trade you should inquire about any rules relevant to your particular transactions. Your local regulatory authority will be unable to compel the enforcement of the rules of regulatory authorities or markets in other jurisdictions where your transactions have been effected. You should ask the firm with which you deal for details about the types of redress available in both your home jurisdiction and other relevant jurisdictions before you start to trade.

IX. Currency Risks

The profit or loss in transactions in foreign currency-denominated contracts (whether they are traded in your own or another jurisdiction) will be affected by fluctuations in currency rates where there is a need to convert from them currency denomination of the contract to another currency.

X. Trading Facilities

Most open-outcry and electronic trading facilities are supported by computer based component systems for the order-routing, execution, matching, registration or clearing of trades. As with all facilities and systems, they are vulnerable to temporary disruption or failure. Your ability to recover certain losses may be subject to limits on liability imposed by the system provider, the market, the clearing house and/or member firms. Such limits may vary; you should ask the firm with which you deal for details in this respect.

XI. Electronic Trading

Trading on an electronic trading system may differ not only from trading inan open-outcry market but also from trading on other electronic trading systems. If you undertake transactions on an electronic trading system, you will be exposed to risk associated with the system including the failure of hardware and software. The result of any system failure may be that your order is either not executed according to your instructions or is not executed at all.

XII. Off-Exchange Transactions

In some jurisdictions, and only then in restricted circumstances, firms are permitted to effect off-exchange transactions. The firm with which you deal may be acting as your counterparty to the transaction. It may be difficult or impossible to liquidate an existing position, to assess the value, to determine a fair price or to assess the exposure to risk. For these reasons, these transactions may involve increased risks. Off-exchange transactions may be less regulated or subject to a separate regulatory regime. Before you undertake such transactions, you should familiarize yourself with applicable rules and attendant risks DISCLOSURE STATEMENT RELATING TO NON-CASH MARGIN – CFTC RULE 190.10 (C)

This statement is furnished to you because Rule 190.10(C) of the commodity futures trading commission requires it for reasons of fair notice unrelated to this company’s current financial condition.

1. You should know that in the unlikely event of this company’s bankrupt, property, including property specifically traceable to you, will be returned, transferred or distributed to you, or on your behalf, only to the extent of your pro rata share of all property available for distribution to customer.
2. Further notice concerning the terms for the return of specifically identifiable property will be by publication in a newspaper of general circulation
3. The Commissions’ regulations concerning bankruptcies of commodity brokers can be found at part 17 of Code of Federal Regulations (CFR 17).

OFAC Disclosure

To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to support the efforts of the Treasury via Financial Crimes Enforcement Network (FinCen) and Office of Foreign Asset Control (OFAC). To that affect Ulysses Commodities LLC ("Ulysses") shall not deal with anyone found on OFAC’s Specifically Designated Nationals and Blocked Person’s List. (see: http://www.treasury.gov/resource-center/sanctions/SDN-List/Pages/default.aspx)

By engaging Ulysses Commodities LLC ("Ulysses") you ("Customer") acknowledge that the following terms and conditions shall govern such relationship:

1. To the best of Customer(s) knowledge the firm enforces OFAC’s regulations and doesn’t deal with any individuals or entities found on SDN/Blocked Persons List. (for a complete list of SDN/Blocked Person List, see PDF dated January 24th, 2013:http://www.treasury.gov/ofac/downloads/t11sdn.pdf)
2. Customer(s) is compliant with all FinCen’s and OFAC’s regulations and either it, Customer(s) clearing house, Prime Broker or FCM routinely scans all new individuals/entities with which you conduct business to make sure they are clear as per OFAC: http://sdnsearch.ofac.treas.gov/
3. Customer will immediately notify Ulysses Commodities LLC ("Ulysses") in writing should Customer become involved with such individuals, or entities and Customer acknowledges that at such time Ulysses may halt or suspend its dealing with Customer, or take other actions as mandated by the law. If Ulysses determines that Customer is on the SDN list or is engaging in transactions with others that are prohibited by the economic sanctions and embargoes administered and enforced by OFAC, Ulysses reserves the right to reject any transactions or commercial dealing with such Customer and/or file a blocked assets and/or rejected transaction form with OFAC within 10 days. Ulysses may also do so by calling the OFAC Hotline at (800) 540-6322 immediately.
4. Should Customer cease to meet the regulations as mandated by OFAC and FinCen and altered from time to time, during the firm’s relationship with Ulysses, then Customer agrees to indemnify and hold Ulysses harmless from any regulatory actions that may occur due to any misrepresentation by Customer of its compliant status with OFAC, and any failure to notify Ulysses of any changes thereto or due to Customer continuing

Privacy Policy

The following privacy policy shall govern the relationship you ("Customer") will form with Ulysses Commodities LLC ("Ulysses) in its function as an Introducing Broker, executor of trades, and purveyor of financial services. By engaging Ulysses as an Introducing Broker, Customer consents to the terms below, and this consent shall carry through every transaction Customer engages with Ulysses. Ulysses Commodities LLC (Ulysses) is committed to protecting the privacy, accuracy and reliability of any personal and professional information you ("Customer") choose to provide. Ulysses is further committed to safeguarding such information from loss, misuse, unauthorized access, disclosure and alteration. This privacy policy statement is provided to you on behalf of Ulysses and addresses its data collection, use and disclosure practices. This privacy policy may change from time to time and you will receive written notification of any such changes. If your account was introduced to Ulysses by a third party, such as another introducing broker, or an Futures Commission Merchant, this privacy policy applies only to how your personal and professional information is handled and protected by Ulysses, not how it is handled and protected by the respective third party. Ulysses is limited by its liability to any misuse this or any other third party involved commits.

I. Information Collected

The reason the Ulysses collect information is to create and foster ongoing customer relationships, Furthermore, To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions, including all NFA registered entities as part of their Anti Money Laundering policy, obtain, and record information that identifies each person, and financial entity which opens an account. In the normal course of this process, Ulysses obtains and retains non-public information about you/your entity which is transmitted to us either directly by you or via an approved third party (such as your existing Prime Broker, FCM or another Introducing Broker) in order to open an account. This includes the name and address of your entity, the legal jurisdiction and formation of your legal entity, EIN/ Federal Tax ID number, names of all those with trading authorizations to place orders on the account, names of those with access to request trading information/records from us, and so on. Ulysses may also obtain and retain nonpublic information resulting from day to day trading: account balances, funding, transaction history in the market, and so on. Ulysses will limit such information to such facts as are necessary to establish a relationship with you as a customer and to offer accurate and superior service in the normal course of business as it relates to your account carried with it, and guard such information to the great extend as mandated by the law.

II. Use of Information

Ulysses may use your information in three general purposes:

1. First, Ulysses may use the information to approve and activate an account for you and/or to make changes
or additions to information previously provided to us to open an account for you.
2. Second Ulysses may use it to give your company, your staff, or approved third parties (FCM, Prime Broker, Back Office personal) access to your account and proprietary information in a secured environment in the normal course of business to transmit account activity statement, records or related documents.
3. Third, Ulysses may use the information to comply with regulatory mandates enforced by the law: AML laws, RICO laws, US Patriot Act, FinCEN requests, OFAC’s SDN and Blocked Person Lists, and others.

III. Disclosure of Information

Ulysses takes its responsibility very seriously to keep your information private. Ulysses will not disclose non-public information about our customers except as required and permitted by law and in the following instances: In processing or servicing Covered Products and Services offered that have been consented to, requested or authorized by you, the customer. Ulysses may use your information with affiliates and subsidiaries and/or unaffiliated third parties only as is necessary to verify the accuracy of the information you have provided, to conduct identity, background and possible OFAC/SDN checks, to process or collect payments, to service your account, for audit purposes and/or to ensure regulatory compliance. Ulysses may be required to disclose information by law or legal process for a variety of reasons, including protecting and defending Ulysses’ rights or property or as may be mandated from time to time by regulatory agencies. Ulysses may also be required to disclose information to the regulatory bodies whose jurisdiction it is subject to. Except under the circumstances described above, Ulysses will not disclose any of your information to unaffiliated third parties, unless specifically authorized by you in writing to do so. The confidentiality and conditions of this agreement will continue to be maintained even when you cease to do business with Ulysses.

IV. How Ulysses Commodities LLC Protects Information

Ulysses takes reasonable measures to protect your information from unauthorized access through the use of physical security, and use and access policies for employees. Ulysses safeguards customer information from unauthorized access by their confidentiality policies and/or limiting the number of employees permitted to access such information through personalized staff passwords, and by having in place a process for disciplinary action where appropriate. Additionally, customer, or account activity related information is protected on Ulysses’ back office administration with a variety of security measures such as passwords, and physical access controls. Ulysses Commodities LLC also employs a variety of other mechanisms to protect a user’s data from being lost, misused, or altered inappropriately, and uses experienced, sophisticated, and highly secure third party back up facility through Google and Amazon (AWS). Although Ulysses takes these measures to safeguard against unauthorized use of a user’s data, it cannot control Internet transmissions and cannot provide assurances that information transmitted to it will never be compromised.

V. Information Sharing with Affiliates

Although by law we are permitted to share information with any future affiliates and/or future subsidiaries related to transactions and experiences with your firm, it is our policy not to do so without your authorization, except in the limited circumstances referenced above. Accordingly Ulysses will not share any information either provided by you or obtained from approved (by you) third parties, unless it is necessary to do so for the purposes described above or it is required by law or regulation or unless we have your specific written authorization. At this time Ulysses does not have any subsidiaries and or affiliates. Ulysses Web site is password protected and directed at compliance officers, regulators, employees and other non-public parties that must be given specific permission to access firm information. However, if in the future it may contain hyperlinks to third parties’ Web sites or advertisers on its website, this privacy policy will not apply to those third party Web sites. Ulysses will not be responsible for the privacy policies or content of any other Web site its customers visit or link to, nor will it have control over the use or security of any information provided to its customers or collected by those Web sites. It is recommended that you become familiar with the privacy policies of those Web sites that you visit or link to.

VI.Accuracy of Information

On an ongoing basis Ulysses will evaluate efforts to protect your information and ensure its accuracy. Should you identify any inaccuracy in the information included in any communication you receive from the Ulysses, please notify our Director of Compliance immediately. We will take reasonable steps to ensure it is corrected on a timely basis.

VII. Non-Disclosure of CONFIDENTIAL information

Customers/Client confirm that all trade information, market information disseminated through e-mail, IM, phone, in writing or in person, broker communication and other information transmitted from Ulysses Commodities LLC employees, AP’s, directors, or shareholders to clients of the firm shall be deemed Confidential. By engaging Ulysses, Client gives their consent, and this consent shall carry through every given transaction; this consent shall commit clients to maintaining the confidentiality of such communication from Ulysses to clients, and confirm that transmitting such information to other parties, be it other clients, direct competitors, indirect competitors (of Ulysses) or any other outside entity Ulysses does not desire to communicate such information to may result in damages to Ulysses. Client consents transmitting confidential information to external parties shall constitute breach of this agreement and such breach shall hold clients liable for damages to Ulysses, including but limited to: loss of profits, incidental, consequential, special or punitive damages, regardless of negligence or fault of the Client.

VIII. Version Updates

Ulysses commodities Privacy Policy may be updated from time to time, the latest version shall be kept online and any changes will be posted online. The online version shall be the most up to date version and it is the one that shall prevail if two versions are at odds. Any online access issues can be resolved immediately by contacting aiv@ulysses.biz or any of the firm’s employees, or Director of Compliance. Failure to receive access shall not constitute grounds for negating updated version.

ELECTRONIC TRADING AND ORDER ROUTING SYSTEMS DISCLOSURE STATEMENT

ACKNOWLEDGMENT You ("Customer") hereby confirm your consent to this policy every time you authorize Ulysses Commodities LLC to enter orders to trade in Commodity Contracts on any available electronic trading and order routing systems. You acknowledge having read and understood the Electronic Trading and Order Routing Systems Disclosure Statement, and you have the capacity to undertake the risk involved in such Commodity Contracts.

ELECTRONIC TRADING AND ORDER ROUTING SYSTEMS POLICY

DISCLOSURE STATEMENT: Electronic trading and order routing systems differ from traditional open outcry pit trading and manual order routing methods. Transactions using an electronic system are subject to the rules and regulations of the exchange(s) offering the system and/or listing the contract. By enegating Ulysses you acknowledge acceptance of this policy, and your consent to them every time you engage in a new transaction through us. You should further review the rules and regulations of the respective exchange(s) offering the system and/or listing contracts you intend to trade.

DIFFERENCES AMONG ELECTRONIC TRADING SYSTEMS: Trading or routing orders through electronic systems varies widely among the different electronic systems. You should consult the rules and regulations of the exchange offering the electronic system and/or listing the contract traded or order routed to understand, among other things, in the case of trading systems, the system’s order matching procedure, opening and closing procedures and prices, error trade policies, and trading limitations or requirements; and in the case of all systems, qualifications for access and grounds for termination and limitations on the types of orders that may be entered into the system. Each of these matters may present different risk factors with respect to trading on or using a particular system. Each system may also present risks related to system access, varying response times, and security. In the case of internet-based systems, there may be additional types of risks related to system access, varying response times and security, as well as risks related to third party service providers and the receipt and monitoring of electronic mail.

RISKS ASSOCIATED WITH SYSTEM FAILURE: Trading through an electronic trading or order routing system exposes you to risks associated with system or component failure. In the event of system or component failure, it is possible that, for a certain time period, you may not be able to enter new orders, execute existing orders, or modify or cancel orders that were previously entered. System or component failure may also result in loss of orders or order priority.

SIMULTANEOUS OPEN OUTCRY PIT AND ELECTRONIC TRADING: Some contracts offered on an electronic trading system may be traded electronically and through open outcry during the same trading hours. You should review the rules and regulations of the exchange offering the system and/or listing the contract to determine how orders that do not designate a particular process will be executed.

LIMITATION OF LIABILITY: Exchanges offering an electronic trading or order routing system and/or listing the contract may have adopted rules to limit their liability, the liability of FCMs, and software and communication system vendors and the amount of damages you may collect for system failure and delays. These limitations of liability provisions vary among the exchanges. You should consult the rules and regulations of the relevant exchange(s) in order to understand these liability limitations

POLICY OF TRANSMISSION OF CUSTOMER INFORMATION AND CONFIRMATIONS VIA INSTANT MESSENGER AND/OR E-MAIL

In order to direct execution orders, modify or cancel such orders, receive your daily and monthly trade confirmations and purchase and sale statements ("Customer Information") via Instant Messenger ("IM") and or email, you ("Customer") acknowledge, confirm and consent that the following terms shall govern such transmissions, and will apply per every given transmission:

Customer has requested that Ulysses Commodities, LLC ("Ulysses") transmit and communicate market orders, alter/modify or cancel such orders in Covered Products and Services and respective Customer Information via the Internet by a designated IM and or E-mail transmission. This consent for transmission may also equally apply to daily or periodic statements. Parties acknowledges this consent to electronic transmission of orders and statements is revocable, but will remain in effect until Ulysses receives written notice from customer to revoke such consent. Per Customer request Ulysses will transmit such information through E-mail and or designated Instant Messenger (AIM, Yahoo, YJ, PIVOT, etc) under the following conditions:

1. Ulysses makes no warranties or representations, express or implied, regarding the Instant Messenger ("IM") or e-mail service and shall not be liable for any interruptions, delays, inaccuracies, errors, omissions or any faults in the IM and or e-mail service, however occurring.
2. Customer will indemnify and hold Ulysses or any of its subsidiaries or affiliates harmless against any and all claims by parties or third parties in any way connected to or arising out of the use of IM and or e-mail service.
3. Performance of IM and/or e-mail service will be excused if prevented by circumstances beyond the reasonable control of Ulysses, including but not limited to: Acts of God or public enemy, fire or other casualty, labor disputes, or failure of communications companies.
4. Customer will be responsible for informing Ulysses of changes in its services (Communication Company, IT Providers, etc) with regard to changes in the e-mail address or IM itself. Failure to communicate new or changed IM and or e-mail addresses will result in failure to receive/transmit communications in this manner, or in exposing third parties to confidential information
5. Customer warrants and represents that it fully understands the risks associated with the transmission of information by use of the internet, including but not limited to the tampering with, or unauthorized use of the Customer’s Information by unauthorized third parties and that it will implement the highest standard of care to prevent any unauthorized receipt or use of Customer’s Information.
6. Ulysses reserves the right to modify or discontinue this service at any time without notice.

CUSTOMER COMPLAINT PROCEDURES

Introduction:

Despite our diligent service, adherence to the highest fiduciary duties, and aim to please oour customers; flaring tempers volatile markets and other issues unbeknownst to Ulysses can cause customers to voice strong opinions. Given that we deal only with Eligible Contract Participants (ECP’s) also known as professional or institutional entities, strong opinions may be voiced on a daily basis. How does one differentiate between customers blowing off steam and an official customer complaint?

What qualifies as a complaint?
In a nutshell – a complaint must be formally submitted in writing via THIS FORM

1. A complaint is recognized once the customer writes out a formal customer complaint (as per the form attached) stating the issue in details, stating what sort of action should or should not have been taken, and what lessons going forward are required on behalf of Ulysses. Such written format will allow the prevailing issues to surface. Customers are urged to submit complaint forms ASAP (within 24 hours) e-mails to AP, Principles and all communication cc’d to CC@ulysses.biz – while memories are still fresh, and action can be taken to rectify the situation. The longer time elapsed between incident and complaint submission the less effective Ulysses can be in any time of action it might potentially take.
2. A complaint is also recognized when a regulatory agency, DCM, or attorney on behalf of the client submits written communication regarding trades handled by Ulysses.

The following qualify as Warning Sign that an issues may escalate into a customer complaint:

1. Unusual or highly aggressive behavior by customer/s.
2. Any form of request to escalate a conversation to supervisor
3. Any request for compensatory damages. Reasoning ranging from claims of poor service, claim of trading error (fat finger error, outs,etc), or any other reason When encountered with a Warning Sign, AP’s are to take the following action:

1. If client requests to speak with a supervisor, escalate the call immediately.
2. If a supervisor is not present and an error that may result in compensatory damages, take immediate action to minimized damages, and alert the desk supervisor and/or Ulysses principles as soon as possible.

Internally:

1. TIMELINE: All customer complaints must be dealt with immediately and escalated to supervisor and/ or principle level. Internal company personnel/principles accompanied by the account executive MUST discuss and resolve customer complaint ordecide on steps to resolve/alleviate issuesat hand by the close of the SAME business day. If not in person then byconference call.
2. RESPONSE: Principle that is also registered as AP must RESPOND to all complaints in writing in a timely manner.
3. ARCHIVING: All resolved decisions must be documented in writing. These matters will be stored via an e-mail sent to thee-mailaddress: CC@ulysses.biz with all pertinent documentations, resolutions, evidence, and other notes attached to the e-mail. These must be stored for a period of 5 years from the date of resolution.
4. OUTSIDE COUNSEL: If need be matters are to be escalated to the firm’s counsel for further discussion and supervision.

In conclusion:
In the course of performing fiduciary duties, Ulysses realizes errors or complaints happen, but it is a matter of organizational efficiency to:

1. document these occurrences properly and in writing; and
2. take swift, timely, unified action