The purpose of this policy is to guarantee that the compliance of the legislative requirements, departmental, and general procedures is met.
In accordance with the common directives and the law, regulators are responsible to maintain, establish and implement effective conflict of interest policies, in writing, appropriate to the size and type of organization of the regulator, and the nature, scale and complexity of its business.
In addition, in accordance with the investment services activities and regulated market law (issue year), regulators must take all necessary precautions to identify any conflicts of interest between itself, including its managers and employees, tied agents or other relevant persons (as well as between clients and anybody which is relevant to the body by control) which arises in the due course of service/product/ancillary provision.
A) The company/relevant person makes a financial gain/loss at the expense of a client.
B) The company or a relevant person has the interest in the outcome of a specific service which is provided to the client, or the transaction carried out on behalf of the client, which is different from the clients’ interest in the specific outcome.
C) The company or relevant persons have incentives financial stature in favor of the interest of another client or group of clients over the interests of the client.
D) The company or relevant persons, whether linked directly or indirectly linked by the control of the company, carries on the same business as a client.
E) The company or relevant persons, or a person directly/indirectly linked by control to the company, receives or is intended to receive from somebody other than a client, imbursement in the form of money, good or service, other than standard commission or fee of that service.
– The company
A conflict may arise between a combination of any of the above, and more. This includes external, as well as internal conflicts.
– Where an employee trader or a member of senior management has a personal position in a lot of currency, and is the involved in receiving order or advising clients in relation to the currency in question.
– Where an employee or senior member of management has a personal account with the company and the position held by the client is altered in a direction whereby the company is gaining and the employee is suffering a loss due to the movement of the market.
– The Company is likely to sustain an overall financial gain by not executing a client’s specific order.
– Where an employee or member of the Senior Management has a personal account with the Company and the position held by the client moves in such a direction as to where the Company is gaining and the employee is suffering a loss due to the movement of the market.
– And more, these are only some examples.
The following measures are adopted by the company for the ensuring of the required degree of independence:
1) Measures which prevent, or control the exchange of information between relevant persons, engaged in activities which involve a risk of conflict of interest
2) Employees which are dealing with the company’s own account, which they trade on, and are fully aware of the hedging policy of the company to not provide its clients with advice.
3) Employees which are dealing and have knowledge of the hedging policy within the company are not allowed, under any circumstance to have direct communication with the clients.
Please note: that due to the nature of the operation, such conflict of interest is isolated.
Separate supervision of relevant persons whose principal function which have the principal function of carrying out actions on the company departments which may have conflicts of interests, or conflicts with clients:
i) Dealing department
ii) Own account trading department
Please note: due to the nature of the operation, such conflict of interest is remote.
The removal of any direct link between the reimbursement of relevant persons, principally engaged with one activity, and the reimbursement of other relevant persons which were initially engaged in another activity, where conflict of interest may arise in relation to those activities:
I) Own accounts trading members of staff can not link the performance of their re-imbursement to the company
II) Dealing room employees will not link their re-imbursement with clients’ performance.
– Measures taken to prevent of limit any person from practices of inappropriate influence over investment or ancillary services carried out by the relevant person.
– Measures taken in order to control the simultaneous involvement of a relevant persons separate investment/ancillary services or activities such as the own accounts trading department, and the dealing department.
B) Record keeping
The company maintains a record that is updated constantly, of the investment/ancillary/investment activity services carried out by the company, or on its behalf in which a conflict of interest may entail a material risk of damage to the interests of one or more clients has been raised.
The policy is available for review by clients upon request, and is summarized to the companies’ clients through a separate document.