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Contract reading

What HEADWAY legally published, but does not want you to read

Every clause below is published by HEADWAY itself, on its own website, today. The finding is not that the text exists. It is the distance between what a client is shown and what a client agreed to. Read from its own documents on .

Contracting entity: JAROCEL PTY LTD

sole discretiondeemed acceptancehidden feeprofit voidingunilateral amendmentwithdrawalsaccount limitsforum waiverkyc freezecomplaint deadline

Headway can refuse your withdrawal if it decides you have not traded enough. It can hold your balance for 180 days on a fraud flag. A suspected second account lets it cancel every trade you ever made. You get two working days to complain, on its own form.

Back to HEADWAY

Contract risk

Money at risk
7.5/10

Where this contract sitsHow far this contract goes, overall. Under 2 is nothing beyond the ordinary; 6 to 9 means several clauses put money you have already earned at risk; 9 and above reads as designed to make payout refusable.

0510
CriticalClauses that can cost you money you have already earned or deposited, or that remove your ability to challenge it.
6
FlaggedEvery clause worth knowing about, at all three severities. Ordinary terms that every broker has are not counted.
15
DocumentsHow many of the broker's own legal files this reading is based on. Each one was downloaded and hashed on the date shown.
5
ContradictionsPlaces where a promise the broker makes in public is not kept by the clause that governs it.
1

How the 15 break downThe same flagged clauses, split by how much each one can cost you. Severity is our reading of the clause, not the broker's label.

Critical6
Warning7
Notice2

section 61 of 63is where the deepest clause sits, 97% of the way into the document it is in

The numbers in this contractFigures taken from this broker's own clauses, so the labels differ from broker to broker. The four in the panel above are the same on every report.

3 of these 4 figures come from a clause we rate critical, which means it can take your money or your profit rather than only delay it.

Critical2 working daysTime to complain. Jump to the clause this comes from.Two working days to complain, on Headway's form onlyCritical180 daysWithdrawal limit. Jump to the clause this comes from.Your balance can be held for 180 days on a fraud flagCritical1Profit at risk. Jump to the clause this comes from.A matching name can cancel every trade you have made20%Account limit. Jump to the clause this comes from.Leverage and margin can change on positions you already hold

What the documents say

15 clauses worth knowing about, worst first, each quoted from HEADWAY's own files

01

Headway can add fees to your withdrawal, or reject it outright, if it decides you have not traded enough. Clause 2.7 lets it make that call alone, and never says how much trading is enough.

Why this matters

You can deposit, change your mind, and find the exit priced or closed because you did not trade. Nothing in the contract tells you what would release your own money.

Exhibit 1CriticalHarder than usualNew

If the Client requests a withdrawal of funds without generating sufficient trading activity (as determined by the Company at its sole discretion), the Company reserves the right to charge additional administrative and processing fees to cover the transaction costs of payment systems, or to reject the withdrawal request.
Clause 2.7 in Client Agreement, p.5
Read from the broker's site on Archived copyOpen the reference
Our own capture of hw.online, taken on Aug 25, 2026Withdrawal refusable if Headway decides you traded too little (clause 2.7)This capture shows the page the quotation was taken from. The words themselves are not marked in it, so please read the quotation above as the evidence.Visit this page on the broker's siteDownload the full size image file

Where it sits: section 8 of 63 in the Client Agreement, near the start.

Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA or CySEC must return client money on request and cannot make a payout depend on how much a client traded. This contract lets Headway charge more, or refuse, when it judges the trading insufficient.

HEADWAY is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

  • Worse together with Exhibit 7The contract allows a fee on the way out and states no amount for it anywhere.
02

You get two working days to bring a claim, counted from when the problem happened rather than when you noticed it. Clause 9.1.2 throws out anything not sent on Headway's own Claim Form.

Why this matters

A bad fill on Friday has to be claimed by Tuesday or you lose the right to raise it. Miss a later request from Headway by five working days and your accounts can be closed too.

Exhibit 2CriticalHarder than usual2 working days

Claims are accepted within two (2) working days (Monday - Friday) since the moment the grounds for a claim appeared.
Clause 9.1.3 in Client Agreement, p.20
Read from the broker's site on Archived copyOpen the reference
Our own capture of hw.online, taken on Aug 25, 2026Two working days to complain, on Headway's form only (clause 9.1.3)This capture shows the page the quotation was taken from. The words themselves are not marked in it, so please read the quotation above as the evidence.Visit this page on the broker's siteDownload the full size image file

Buried at section 48 of 63 in the Client Agreement, 76% of the way through.

What it costsA trade goes wrong at 4pm on Friday. Your two working days run out at the close of business on Tuesday.

Set against a regulated standard: FCA (UK), FSCA (South Africa)

Firms licensed by the FCA must accept a complaint, give a final response, and let the client take it free to an independent ombudsman. Clients of FSCA licensed firms can go to the FAIS Ombud. This contract gives you two working days and names no outside body.

HEADWAY is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

What happens, and when

The stages this clause runs through, taken from the broker's own document
TriggerWhat the broker may then doClause
Within 2 working daysYou must send the Claim Form to claim@hw.site. Anything else is not considered.9.1.3
Within 5 working daysHeadway confirms it received your form.9.1.4
Within 10 working daysHeadway gives you an outcome, or explains the delay and sets its own new date.9.1.6
5 working days to answer HeadwayMiss a request from Headway and your claim is rejected and your accounts may be closed.9.1.7
  • Worse together with Exhibit 12The window is short and the only evidence that counts inside it belongs to Headway.
03

Headway can freeze your whole balance for up to 180 calendar days when it flags activity as possible fraud. Clause 3.3.1 lets it suspend withdrawals on suspicion alone, with no deadline on the investigation.

Why this matters

Your money sits at Headway for half a year while it decides. The contract gives you no way to shorten that and no payment for the wait.

Exhibit 3CriticalHarder than usual180 daysNew

In cases where a transaction or account activity is flagged for potential fraud, identity theft, or financial crime, the Company reserves the right to place an administrative hold on the account balance for a period of up to one hundred and eighty (180) calendar days.
Clause 3.3.8 in Client Agreement, p.8
Read from the broker's site on Archived copyOpen the reference

Where it sits: section 16 of 63 in the Client Agreement, near the start.

What it costsA hold that runs its full length puts your balance out of reach for 180 calendar days. Ask on 1 March and you could still be waiting in late August.

04

Headway can merge your accounts, move losses from one onto the funds of another, and cancel all the profit you made. Clause 4.6.5 runs on its own finding that you used separate profiles to get around risk limits.

Why this matters

A winning account can be emptied to cover a losing one you also hold. The clause voids every profit you generated, not only the trades it objects to.

Exhibit 4CriticalRarely seenNew

In the event that the Company establishes that a Client operates multiple trading accounts under distinct registration profiles to bypass risk limits (e.g., opening opposing/hedged transactions on the same instrument across different accounts over weekends, news releases, or session gaps), the Company reserves the absolute right to consolidate the accounts, deduct losses exceeding the balance of one account from the available funds of any other account controlled by the Client, and nullify all generated profits.
Clause 4.6.5 in Client Agreement, p.12
Read from the broker's site on Archived copyOpen the reference

Where it sits: section 25 of 63 in the Client Agreement, 40% of the way through.

Our readingNetting losses across a client's accounts appears in other agreements. Cancelling all profit on top of the set off turns a risk control into a penalty with no ceiling.

  • Worse together with Exhibit 5A suspected second Personal Area starts the process that this clause then finishes.
05

Headway can cancel all your past and current trades if it suspects you hold a second Personal Area. Clause 1.3 says a match in name or identity documents is enough, and it acts at its own discretion without telling you first.

Why this matters

You share a common name with another client and your entire trading history can be unwound. Headway also closes the extra accounts and accepts no liability for what you lose.

Exhibit 5CriticalHarder than usual1New

In the event the Company suspects that the Client holds more than one personal area (including, but not limited to, matches in name and/or identification documents), the Company reserves the right, at its sole discretion and without prior notice to the Client, to: cancel all previous and current trading transactions of the Client; terminate all personal areas except one; and close any trading accounts associated with the terminated personal areas.
Clause 1.3(c) in Client Agreement, p.3
Read from the broker's site on Archived copyOpen the reference

Where it sits: section 4 of 63 in the Client Agreement, near the start.

06

Headway's website tells you it turns away residents of FATF blacklisted countries. The contract goes much wider, barring the United States, Canada, the United Kingdom and every country in the European Economic Area.

Why this matters

You can open an account from London or Dublin, see nothing on the site that stops you, and be in breach of clause 1.3 from the first day. Breach is what unlocks the clauses that cancel your trades and freeze your funds.

Exhibit 6CriticalHarder than usualNew

the United States of America, Canada, the United Kingdom, Member States of the European Economic Area (EEA), and any other jurisdiction designated by the Company from time to time at its sole discretion.
Clause 1.3(g) in Client Agreement, p.4
Read from the broker's site on Archived copyOpen the reference
Our own capture of hw.online, taken on Aug 25, 2026The claim, on Risk Warning block in the site footer on Headway's privacy policy pageVisit this page on the broker's siteDownload the full size image file

Where it sits: section 5 of 63 in the Client Agreement, near the start.

  • Worse together with Exhibit 3Signing up from a barred country gives Headway the breach it needs to suspend withdrawals and void results.

Headway names its charges but never their size

No fee figure appears anywhere in the 25 pages of the Headway client agreement. Clause 7.2 lets Headway change the size of any commission without telling you first, and clause 2.11 binds you to a Deposit and Withdrawal Policy that was not published on the site. Separate clauses add penalty charges when a deposit comes from a third party or your original payment method stops working.

Cost disclosure2 clauses flagged

The agreement names commissions, swaps and processing charges but sets no figure for any of them. Clause 7.2 lets Headway change the size of every cost without telling you first.

Why this matters

You accept charges you cannot read before you sign. The Deposit and Withdrawal Policy that would hold the numbers is named in clause 2.11 but was not published on the site.

Exhibit 7WarningHarder than usual

The Company is entitled to change the size of commissions and other costs without prior notification of the Client.
Clause 7.2 in Client Agreement, p.18
Read from the broker's site on Archived copyOpen the reference

Buried at section 42 of 63 in the Client Agreement, 67% of the way through.

Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA or CySEC must disclose costs and charges to a retail client before that client trades. This contract puts the amounts on a website page and reserves the right to change them without notice.

HEADWAY is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

Losing access to the card or wallet you deposited with lets Headway charge you a higher rate to pay you out. A deposit that arrives from someone else draws a penalty commission on the deposit and on any later withdrawal.

Why this matters

A closed bank account or an expired card turns your withdrawal into a more expensive one. Neither clause states the rate, so you find out what it costs after you ask for your money.

Exhibit 8WarningHarder than usualNew

Charge an additional administrative processing fee or an elevated commission structure on such a withdrawal to mitigate the associated operational, compliance, and currency conversion risks.
Clause 3.4.3 in Client Agreement, p.8
Read from the broker's site on Archived copyOpen the reference

Where it sits: section 17 of 63 in the Client Agreement, 27% of the way through.

Headway can change the rules on trades you already hold

Clause 4.7.1 lets Headway cut your leverage at any time and apply it to open positions, and clause 4.6.2 closes those positions once the margin level hits 20%. Clause 11.2 says you accept any updated agreement, and clause 8.3 treats anything posted on the website as delivered to you an hour later. Clause 2.10 allows termination with or without cause on 24 hours notice.

Unilateral control2 clauses flagged

Headway can cut your leverage or raise margin at any time and apply it to trades that are already open. Positions are then closed automatically once your margin level reaches 20%.

Why this matters

A rule change made while you sleep can push a healthy position into forced closure. Leverage is the borrowing that lets you trade more than your balance, and less of it means more of your own money must sit behind the same trade.

Exhibit 9WarningStandard wording20%

The Company reserves the absolute right to modify the leverage on the Client's account at any time, with or without prior notification. The Company has the right to apply these leverage limits to both newly opened positions and active, already opened positions.
Clause 4.7.1 in Client Agreement, p.12
Read from the broker's site on Archived copyOpen the reference

Where it sits: section 26 of 63 in the Client Agreement, 41% of the way through.

What it costsAn account using $1,000 of margin is closed out automatically once its equity falls to $200.

  • Worse together with Exhibit 12Headway sets the price that decides the margin level and also sets the level itself.

Clause 11.2 says you accept the changes in an updated agreement, with no notice period and no way to refuse. Anything Headway posts on its website counts as delivered to you one hour later.

Why this matters

You are bound by wording you never saw, an hour after it appears on a page you had no reason to open. Headway can also close your account with or without cause on 24 hours notice.

Exhibit 10WarningHarder than usual

The Client accepts the changes in the updated Agreement.
Clause 11.2 in Client Agreement, p.24
Read from the broker's site on Archived copyOpen the reference

Buried at section 61 of 63 in the Client Agreement, 97% of the way through.

The agreement names no law and no court

Nowhere in the Headway client agreement is a governing law or a competent court identified, and no independent complaints body is named. Clause 9.4.1 lets Headway settle anything the agreement does not cover according to what it calls universal best practice. Clause 1.6 cancels any statement made to you by Headway or an introducer that is not written into the document.

Forum and law1 clause flagged

The agreement never says which country's law applies or which court hears a dispute. Where a situation is not covered, clause 9.4.1 lets Headway decide it by what it calls universal best practice.

Why this matters

You cannot tell where you would sue or under what law before you deposit. Clause 1.6 also cancels anything a Headway agent or introducer told you that is not in the document.

Exhibit 13WarningRarely seen

Claim situations not stated in the present Agreement are considered by the Company according to the universal best practice.
Clause 9.4.1 in Client Agreement, p.21
Read from the broker's site on Archived copyOpen the reference

Buried at section 51 of 63 in the Client Agreement, 81% of the way through.

Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA or CySEC must tell a retail client which law governs the contract and give access to an independent complaints scheme. This contract names neither.

HEADWAY is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

Our readingAlmost every retail trading agreement names a governing law and a forum, even an inconvenient one. Leaving both out removes the reference point a client would use to work out their rights.

Headway can require apostilled papers and a video interview

Clause 3.3.3 lets Headway demand that your documents be notarised, legalised or apostilled, along with source of funds, source of wealth, bank statements and tax returns. Clause 3.3.6 adds a mandatory video call. A delay in answering is treated as a material breach that can end your account, and no deadline is given that you could plan around.

Document demands1 clause flagged

Headway can require your documents to be notarised, legalised or apostilled, and can call you to a video interview at any point. A slow reply counts as a material breach that can end your account.

Why this matters

An apostille costs money and takes weeks in most countries, and the contract sets no deadline you can plan around. Being late is treated the same as refusing.

Exhibit 11WarningHarder than usualNew

Requiring previously submitted or new documents to be notarized, certified, legalized or apostilled upon the Company's specific request;
Clause 3.3.3 in Client Agreement, p.7
Read from the broker's site on Archived copyOpen the reference

Where it sits: section 14 of 63 in the Client Agreement, near the start.

Headway calculates the quotes and declares them correct

Clause 10.5.2 of the Headway agreement makes you accept its quotes as exclusively correct and bars any claim based on prices from another source. Clause 10.5.3 lets Headway revisit those quotes later and revise the financial results of trades executed on them. Headway publishes no conflict of interest policy, and the 2026 version removed the only reference to market maker accounts.

Price authority1 clause flagged

Headway calculates the quotes you trade on, and clause 10.5.2 says you accept them as exclusively correct. You cannot argue that another source showed a different price.

Why this matters

The company on the other side of your trade decides what your trade was worth. It can also revisit those quotes later and revise the financial results, and it publishes no conflict of interest policy.

Exhibit 12WarningHarder than usual

The Client unconditionally accepts the quotes provided by the Company to its Clients as exclusively correct; no claims about the quotes provided by the Company being different from the quotes of other sources can be accepted for consideration.
Clause 10.5.2 in Client Agreement, p.23
Read from the broker's site on Archived copyOpen the reference

Buried at section 57 of 63 in the Client Agreement, 90% of the way through.

Small idle accounts are archived quietly after 45 days

Headway charges no inactivity fee, which puts it ahead of most brokers. Clause 4.8.1 does let it archive an account after 45 calendar days without activity, but only where the balance is $5 or less. Clause 4.8.2 then deletes every pending order with no notice before or after.

In plain words

Dormancy means an account left unused.

Dormancy1 clause flagged

An account with $5 or less and no activity for 45 days can be deactivated and archived. Headway deletes every pending order on it and tells you nothing before or after.

Why this matters

Pending orders you left running can disappear without a message. Headway charges no dormancy fee, so the money at stake here is small.

Exhibit 14NoticeStandard wording45 daysNew

The Company classifies a trading account as "Inactive" if it satisfies all of the following cumulative criteria: No trading activity has occurred, no open positions are maintained, no deposits or withdrawals have been executed for a continuous duration of forty-five (45) calendar days (or less for specialized non-deposit bonus accounts), and the remaining balance is equal to or less than 5 USD (or its currency equivalent).
Clause 4.8.1 in Client Agreement, p.14
Read from the broker's site on Archived copyOpen the reference

Where it sits: section 30 of 63 in the Client Agreement, 48% of the way through.

What happens, and when

The stages this clause runs through, taken from the broker's own document
TriggerWhat the broker may then doClause
Day 45With no trading and a balance of $5 or less, Headway can treat the account as inactive.4.8.1
Once inactiveHeadway archives the account and deletes all pending orders, with no notice either way.4.8.2

JAROCEL PTY LTD of South Africa is who you contract with

Clause 1.1 names JAROCEL PTY LTD, registration number 2021/883863/07, of East London, South Africa, trading as Headway and licensed by the FSCA under number 52108. The same company and licence number appear on Headway NOVA, a tokenized property product on hwnova.site with a separate client agreement. The contract says nothing about segregating your money and names no compensation scheme.

In plain words

On a principal basis, as your counterparty, means the broker takes the other side of your trade itself. Your loss is then the firm’s gain, so it has an interest in how your trade ends.

Counterparty1 clause flagged

You contract with JAROCEL PTY LTD of East London, South Africa, trading as Headway and licensed by the FSCA under number 52108. The same company and the same licence number sit on Headway NOVA, which sells tokenized Dubai property under its own agreement.

Why this matters

The contract says nothing about keeping your money separate from the company's own, and names no compensation scheme if it fails. Clause 1.1 also registers your account at hw.site, a third address that is not where this agreement is published.

Exhibit 15NoticeStandard wording

This Client Agreement (hereinafter the “Agreement”) is made by and between JAROCEL PTY LTD (operating under the trading name “Headway”), a company incorporated under registration number 2021/883863/07, having its registered address at 3 Flamingo Crescent, Beacon Bay, East London, 5241, South Africa (hereinafter the “Company”) and any individual or legal entity that registers an account at https://hw.site/, its associated mobile applications, or related URL domains (hereinafter the “Client”).
Clause 1.1 in Client Agreement, p.3
Read from the broker's site on Archived copyOpen the reference

Where it sits: section 2 of 63 in the Client Agreement, near the start.

Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA or CySEC must hold retail client money in segregated accounts and belong to a compensation scheme. This contract says nothing about segregation and names no scheme.

HEADWAY is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

Where the marketing and the contract disagree

A promise made in public, set against the clause that governs it

01

The public page names only FATF blacklisted countries, while the contract also bars the US, Canada, the UK and the whole EEA.

Said in public, in English

Headway does not offer its services to residents of countries that were, are, or will be blacklisted by the FATF.

Risk Warning block in the site footer on Headway's privacy policy page

We took a picture of this page. It is shown once, with the finding it belongs to. See our capture of hw.online

In the contract · clause 1.3(g)

the United States of America, Canada, the United Kingdom, Member States of the European Economic Area (EEA), and any other jurisdiction designated by the Company from time to time at its sole discretion.

What changed quietly

This is our first reading of Headway, so there is nothing yet to compare it against.

  • ADDEDClause 1.3(g) · 2024-02-16 (archived) to 2.2

    The 2024 agreement barred no countries at all, and the 2026 version excludes the US, Canada, the UK and the EEA.

    The Client is not a citizen, permanent resident, or tax resident of, and is not accessing the Company's website or Services from, any Restricted Jurisdiction.

  • ADDEDClause 3.3.8 · 2024-02-16 (archived) to 2.2

    The 180 day hold on a client's balance is new and had no equivalent in the 2024 agreement.

    In cases where a transaction or account activity is flagged for potential fraud, identity theft, or financial crime, the Company reserves the right to place an administrative hold on the account balance for a period of up to one hundred and eighty (180) calendar days.

  • REWRITTENClause 4.6.5 · 2024-02-16 (archived) to 2.2

    Headway added the power to merge the accounts and cancel all profit, on top of moving losses between them.

    the Company reserves the absolute right to consolidate the accounts, deduct losses exceeding the balance of one account from the available funds of any other account controlled by the Client, and nullify all generated profits.

  • REWRITTENClause 4.6.2 · 2024-02-16 (archived) to 2.2

    Positions are now force closed at a margin level of 20% instead of 0%, so liquidation comes much earlier.

    if the Margin Level drops to or below twenty percent (20%) of the required margin needed to sustain open positions.

  • REWRITTENClause 2.7 · 2024-02-16 (archived) to 2.2

    The 2024 rule let a first withdrawal through without extra checks, and the 2026 wording removes that and covers every withdrawal.

    If the Client requests a withdrawal of funds without generating sufficient trading activity (as determined by the Company at its sole discretion), the Company reserves the right to charge additional administrative and processing fees to cover the transaction costs of payment systems, or to reject the withdrawal request.

  • REWRITTENClause 5.4 · 2024-02-16 (archived) to 2.2

    The only mention of market maker accounts in the whole agreement was removed, leaving nothing about how Headway earns on your trades.

    Any increase in the volume of hedged (locked) positions within the Client's account(s) (specifically for Underlying Assets that are subject to Hedged Margin rules under the contract specifications) shall result in a corresponding reduction of Margin requirements for those specific new hedging orders.

The documents this reading is based on

5 files, all published by HEADWAY. Each shows when we read it and a fingerprint of its wording.

WIKILIX keeps the copy of each file it read, and does not republish it: what is published is the fingerprint of its wording. Download the file yourself and hash its text, lowercased with runs of whitespace collapsed, and a matching fingerprint means the wording quoted above is still the wording HEADWAY publishes.

How this reading was done

Every clause above was read out of a document HEADWAY publishes itself

This reading was published on .

Documents
3 of 5downloaded from the broker's site, and 3 read in full
Pages opened
46pages walked to find those documents, footer links included
Older copies
2earlier versions downloaded, 1 identical to the copy we hold by fingerprint
Marketing pages
11public pages set against what the contract says
Position measured
15clauses whose position was counted: which numbered section of the document holds them, out of how many

Who the contract is with

JAROCEL PTY LTD

You contract with JAROCEL PTY LTD, a South African company registered as 2021/883863/07 and trading as Headway. The same company holds FSCA licence 52108 and also runs Headway NOVA, which sells tokenized Dubai property under a separate client agreement. Clause 1.1 says your account is registered at hw.site, while the agreement itself is published on hw.online.

Quotations are copied verbatim from the documents named above, with the clause number and the page each one came from. Where a clause is quoted in another language, the original is shown first and the English is a translation.

The plain-language parts, what a clause means for a client, how ordinary it is, and how it reads against a regulated standard, are WIKILIX's analysis and are labelled as such on every card. This is a reading of public documents, not legal advice and not an allegation of wrongdoing.

In fairness, and what we could not check

A reader who knows the edges of the work can trust the middle of it

Headway caps its own withdrawal processing at two business days, which is faster than most brokers promise. Negative balance protection is automatic by default, so a loss below zero is written off unless Headway decides you caused it deliberately. There is no inactivity fee at all, and the dormancy rule only reaches accounts holding $5 or less. The 2026 version names the legal entity, its registration number and its address in clause 1.1. The 2024 version said only Headway.

hw.online blocked us, so we could not open Headway's marketing pages, its copy trading pages or the other language versions of the site. We read the client agreement, the privacy policy and the AML agreement in full, and the 2024 client agreement in full. We found a second client agreement for Headway NOVA at hwnova.site/client-agreement/ and could not open it, so nothing here rests on it. The Risk Warning and the Deposit and Withdrawal Policy that clause 2.11 binds you to were not on the site. The older AML agreement is the same file as today's, so we checked its fingerprint instead of reading it again.

How to check any of this yourself

Every quote above links to the HEADWAY file it came from. This is what to do with it.

Open the three stepsFind the words in the source, work out the fingerprint, and read what a difference does and does not prove.

Open the source and search for the words

Every quote has a link under it. Open the file, or the web page, and search it for the words we quote. The clause number next to the quote tells you where to look.

If the words are not there any more, the source may have changed after we read it. That is worth knowing too. We keep the date we read it, and a code worked out from its wording, so the quote stays checkable.

What a fingerprint is

A fingerprint is a code worked out from what a source says. Change one word and the code changes completely. We keep two codes for every file we read, and the panel on each source shows both.

The first is the code of the exact file we downloaded. The second is the code of its wording alone, with capital letters lowered and runs of spaces collapsed. When the same words are saved as a new file, the first code changes and the second one stays the same.

Only the first code can be worked out on your own computer. Save the file, then run one of these, putting the name of the file you saved where the example is. The panel on each source prints the command with that source's real file name already in it.

macOS or Linux:
  shasum -a 256 the-file-you-saved.pdf

Windows:
  certutil -hashfile the-file-you-saved.pdf SHA256

The two codes are different from each other, and they are not meant to match. Comparing one against the other proves nothing.

What a difference means, and what it does not

A different file code on its own proves nothing. A PDF saved again with a new date inside it is a new file saying exactly the same thing.

A different wording code means the words themselves changed. That is the one that matters, and it is why we keep it.

Even then, a change is not proof of bad faith. Companies update their documents. What this report says is what the document said on the day we read it, and every quote carries that date.

A source that is a web page and not a file has no file to save, so only the code of its wording is shown.

How this report is made

Every clause quoted above comes from a document HEADWAY publishes on its own website, downloaded and hashed on the date shown, with the clause number and page recorded so any reader can check it. We do not allege anything the documents do not say, and we do not judge HEADWAY on anything other than its own published terms and its own public marketing. Where a clause has a qualifier that softens it, the report says so. Last read Aug 25, 2026.

If you represent HEADWAY and a clause has changed, been withdrawn, or is being read out of context, tell us and we will re-read the documents and update this page. Corrections from the broker are welcome and are published with the reading they change. Contact us.

This is a reading of a contract, not legal advice and not a ruling on HEADWAY. Whether its licence is real and current is a separate check on the broker profile.

Back to the HEADWAY profile