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The company is conscious of the necessity that it should deliver its services to clients with care, knowledge, precision and that in doing so it must act in the client’s best interest. The company will take all reasonable steps to identify potential conflicts of interest between the interest of the firm (including its managers, employees and, if applicable, its tied agents) and its duties owed to its clients, as well as between differing interests of two or more of its clients, to each of whom the institution owes specific duties. This requirement is an obligation of means, not of results. As a basic principle the company will put the interests of its clients before any other interest.
The company, based on the nature of the services it provides, has identified the below situations which could potentially generate a conflict of interests. The company has policies and procedures in place which avoid these situations. The company equally has policies and procedures in place which monitor the arising of situations with a potential conflict of interests so they can either be avoided or the company can act in the best interest of the client. Where the organizational and administrative provisions that have been taken are not sufficient to ensure that the interests of the client are not damaged, the company shall, before acting on behalf of the client, disclose to the latter the nature, and, where applicable, the source of the remaining conflict of interest. This communication may be of a general nature.
(a) The institution is likely to make a financial gain, or avoid a financial loss, at the expense of the client.
The company does not routinely have situations of this nature. Any such potential case should be reported to the management of the company which will deal with it in respect of all applicable rules and regulations.
(b) The institution has an interest in the outcome of a service provided to the client or of a transaction carried out on behalf of the client, which is distinct from the client’s interest in that outcome.
The company does not provide investment advice offering clients to invest in a particular financial instrument for the short or long term.
(c) The institution has a financial or other incentive to favor the interest of another client or group of clients over the interests of the client. The company does not divide its clients into client categories based on criteria such as account size or order volume (e.g. platinum, gold, silver and bronze clients). All clients have access to all services and all financial instruments the company provides. Each order is handled in the same way according to the same procedure. All clients deal at the same spreads and are charged the same commissions, unless they benefit from a volume discount. All clients have access to the same support desk and each client query is dealt with following the same procedure.
(d) The company carries on the same business as the client.
The company does not carry on the same business as the client. It does not engage in proprietary trading.
(e) The company receives or will receive from a person other than the client an inducement in relation to a service provided to the client, in the form of monies, goods or services, other than the standard commission or fee for that service.
The company does not maintain any contractual relationship with suppliers or other parties which result in an inducement of a monetary or other nature.
Any other (potential) case of conflict of interest should be reported to the management of the company which will deal with it in respect of all applicable rules and regulations.