Use of and access to this website and any related websites (collectively, the “website”), and the features of this website is conditioned on your acceptance of the terms of use. By using or accessing this website, you expressly acknowledge that you have read and understood the website terms of use, and that you agree to be bound by them. If you do not agree to be bound by the terms of use, you are not permitted to use or access the website.

Graham Capital Management, L.P. (“Graham” or “we”) may change these terms of use and the privacy policy at any time by posting the updated version on the applicable website(s). By using the website after any such update has been posted, you are agreeing to the terms of such updated version. We encourage you to review these terms of use and the privacy policy regularly.

The content on this website is provided by Graham for information purposes only.

Although the website may include investment-related information, nothing on the website is intended to, nor will, constitute an offer (or an invitation to make an offer) to buy, sell or to provide any investment services or advice in any jurisdiction. The website is neither an offer to sell nor a solicitation of an offer to purchase interests in any fund, investment product, style or strategy.

Nothing on the website is intended to be, and you should not consider anything on the website to be, investment, accounting, tax or legal advice.

Offers and sales will be made only pursuant to the applicable fund offering documents and complete documentation of the relevant investment opportunity, as well as in accordance with the applicable securities laws. The website is qualified in its entirety by reference to such documentation, including the investment objectives, risk factors, potential conflicts of interest and fee disclosures set forth therein. In the event of any inconsistency between the information on the website and the terms of the relevant offering documents of a fund, the terms in the offering documents shall prevail.

There can be no assurance that an investment strategy will be successful. The past performance of any investment, investment strategy or investment style is not indicative of future performance. Fund offering documents contain risk warnings that are specific to each fund that may be described on the website.

The website, and the information on it, are not addressed to any person to whom it is unlawful to make such information available.

The content on the website has been obtained from, or is based on, sources believed by graham to be reliable, but is not guaranteed as to its accuracy or completeness. The website, including all content, is provided as is and as available. We disclaim all representations and warranties, express or implied, of any kind with respect to the website and its content including warranties of merchantability, fitness for a particular purpose and non-infringement of intellectual property and proprietary rights.

Without limiting this general disclaimer, we do not warrant to the availability, accuracy, completeness, timeliness, functionality, reliability, sequencing or speed of delivery of the website or the content. The content is current only as at the date it is first posted and may no longer be true or complete when viewed by you. Graham is under no obligation or responsibility to update or correct any information on the website.

Graham and its affiliates, and the officers, partners, employees, and agents of Graham and its affiliates shall have no liability for any errors (as a result of negligence or otherwise, to the fullest extent permitted by law) for the Website or any content on the Website or for the consequences of any party’s reliance thereupon. Your sole remedy for dissatisfaction with your use of the Website is to stop using the Website.

You agree to indemnify, defend, and hold harmless Graham and its affiliates, and the officers, partners, employees, and agents of Graham and its affiliates, from and against any and all claims, liabilities, damages, losses, or expenses, including legal fees and costs, arising out of or in any way connected with your access to or use, or attempted access or use, of the Website.

The information presented on the Website, including any articles, statements or opinions, is Graham’s proprietary information and is to be used for informational purposes, and in accordance with these Terms of Use, only. Any disclosure, reproduction, distribution, modification or other use without the express written consent of Graham is strictly prohibited. All information on the Website remains subject to Graham’s rights pursuant to applicable copyright, patent, and other intellectual property laws and regulations. All information remains subject to all relevant copyright laws. Nothing on the Website should be considered as granting any license or right under any trademark of Graham or any third party.

The Website may contain links to third party websites or contain content provided by third parties. Graham does not have control or oversight over any third party content and does not make any representation as to the accuracy or completeness of such websites or information. We do not accept any liability arising out of the information contained on any linked website or content on the sites provided by a third party and the use of such websites, information and content is at your own risk.

Any links from or to other third party websites do not imply any endorsement by Graham or any of its affiliates of such third party websites, any content thereto or such websites’ operators or providers.

The Website does not constitute an offer or promise of employment with respect to any employment position described on the Website or provide any binding or any terms or conditions of employment. Without notice, Graham may eliminate, modify or change any aspects of any employment position described on the Website. Any employment offer that may ensue as a result of your submission of information to Graham shall be solely in accordance with the specific terms of such employment offer, and not the terms of the Website.

Some of the individual Websites linked to, or pages contained within, the Website, or if you are accessing or using the Website from a particular jurisdiction or for a particular purpose, may require you to agree to supplemental terms, conditions, disclaimers and/or disclosures (“Supplemental Terms”). In the event of a conflict between these general Terms of Use and any applicable Supplemental Terms, the applicable Supplemental Terms will govern for any individual Website(s) or page(s) on which they appear, or for the jurisdictions or purposes for which they were intended.

In the event any provision or portion of these Terms of Use is held to be invalid or unenforceable for any reason, in whole or in part, the remaining provisions and/or portions shall be unaffected thereby and shall remain in full force and effect to the fullest extent permitted by applicable law. Your access to and use of the Website and these Terms of Use are governed by the laws of the State of Connecticut and disputes arising from or related to your access to and use of the Website shall be adjudicated exclusively in a forum located in the State of Connecticut. You hereby appoint the Secretary of State of the State of Connecticut as your agent for service of process in any such proceeding.

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Welcome to Graham Capital Management

By entering this website you are agreeing to its Terms of Use.

The risk of loss in trading commodities can be substantial. You should therefore carefully consider whether such trading is suitable for you in light of your financial condition. The high degree of leverage that is often obtainable in commodity trading can work against you as well as for you. The use of leverage can lead to large losses as well as gains.

In some cases, managed commodity accounts are subject to substantial charges for management and advisory fees. It may be necessary for those accounts that are subject to these charges to make substantial trading profits to avoid depletion or exhaustion of their assets. The disclosure document contains a complete description of the principal risk factors and each fee to be charged to your account by the commodity trading advisor (“CTA”). The regulations of the commodity futures trading commission (“CFTC”) require that prospective clients of a CTA receive a disclosure document when they are solicited to enter into an agreement whereby the CTA will direct or guide the client’s commodity interest trading and that certain risk factors be highlighted. This brief statement cannot disclose all of the risks and other significant aspects of the commodity markets. Therefore, eligible investors should carefully study the disclosure document to determine whether such trading is appropriate for you in light of your financial condition. Eligible investors are encouraged to access the disclosure document by contacting Graham, which will be provided  at no additional cost. The CFTC has not passed upon the merits of participating in this trading program nor on the adequacy or accuracy of the disclosure document. Other disclosure statements are required to be provided to you before a commodity account may be opened for you.  By accepting the terms of this statement and entering the site you are confirming your understanding of this statement.

Any “benefit plan investor” (e.g. An IRA or other ERISA investor) investor is hereby deemed to represent to Graham Capital Management (“Graham”) that an independent fiduciary (as defined in the ERISA fiduciary rule) is exercising its independent judgment with regard to such investor’s investment in any Graham managed fund and is aware of and acknowledges and agrees that Graham and its affiliates are relying on the exception set forth in clause (c)(1) of the ERISA fiduciary rule (i.e., the “transactions with independent fiduciaries with financial expertise” exception) with respect to any communications made to the investor or the investor’s fiduciary that are considered recommendations concerning any transaction and such benefit plan investor.

Although the site may include investment-related information, nothing on the site is a recommendation that you purchase, sell or hold any security or other investment, or that you pursue any investment style or strategy.

We do not give any advice or make any representations through the site as to whether any investment is suitable to you or will be profitable.

Nothing on the site is intended to be, and you should not consider anything on the site to be, investment, accounting, tax or legal advice. If you would like investment, accounting, tax or legal advice, you should consult with your own financial advisors, accountants or attorneys regarding your individual circumstances and needs.

The past performance of any investment, investment strategy or investment style is not indicative of future performance.

If you have been provided with a password to access the site you are solely responsible for maintaining the confidentiality and security of your password. You may not disclose your password to any third party. You accept full responsibility for any use of your password. You must notify Graham immediately of any actual or suspected loss, theft or unauthorized use of your password.

We are not obligated to inquire as to the authority or propriety of any use of or action taken under your password. We will not be responsible for any loss to you that arises from such use or action or from your failure to comply with these provisions.

The site, including all content, is provided as is and as available.

We disclaim all representations and warranties, express or implied, of any kind with respect to the site and the content including warranties of merchantability, fitness for a particular purpose and non-infringement of intellectual property and proprietary rights.

Without limiting our general disclaimer, we do not warrant the availability, accuracy, completeness, timeliness, functionality, reliability, sequencing or speed of delivery of the site or the content.