Conflicts of Interest Policy

01Why this policy exists

We are your counterparty. That single fact creates a conflict that no amount of drafting removes, and the honest thing to do is to name it, explain how it is contained, and let you decide what weight to give it.

This policy is incorporated into the Client Agreement by clause 1.3.1 and expands on Section 13 of it. Where the two differ, the Client Agreement prevails.

02The central conflict

We deal with you as principal. Every contract you hold is with us. We operate a hybrid risk model: some order flow is passed to external liquidity, some is internalised, and some is netted against opposing client flow.

Where a position is not hedged externally, our financial result on it is the inverse of yours. When you win on such a position, we pay. When you lose, we keep.

We state this plainly rather than bury it, because a client who does not understand it cannot properly assess anything else we say.

03What contains it

• Routing is a risk decision, not a client decision. Whether flow is internalised or passed out is determined by exposure, concentration, correlation and the cost of liquidity — not by whether a particular client is expected to be profitable on a particular trade.
• Pricing does not follow routing. The price you receive is derived under clause 5.3 of the Client Agreement from the same aggregated feed and the same logic, whichever way your account is routed. There is no separate price stream for internalised accounts.
• Slippage is symmetrical. We do not operate an asymmetric slippage model designed to favour us, and we do not operate a last-look rejection stage on orders routed to our aggregated liquidity.
• The dealing function is separated from the client-facing functions, and configuration of pricing and dealing parameters is access-controlled and logged.
• Profitability is never a ground for action. Clause 6.17 of the Client Agreement expressly forbids us from voiding a profitable transaction because it was profitable, from treating a win rate or withdrawal frequency as evidence of abuse, or from using the prohibited-practices regime to delay a withdrawal that is properly due. A measure under Section 6 requires a quantitative finding, notification, and a right of reply.

04Introducing partners

Where a partner introduced you to us, we pay that partner a rebate calculated on the volume you trade — up to USD 10 per standard lot, on the schedule at clause 9.5 of the Client Agreement.

The conflict: a partner earns more when you trade more, whatever the result. A partner therefore has a financial interest in your activity that is not aligned with your interest in trading only when you have reason to.

05What contains it

What you should do with this: when a partner encourages you to trade, remember that they are paid for the encouragement.

• The rebate is paid out of our revenue. It is not a charge to you, and your costs are those published for your account type whether or not a partner introduced you.
• The existence and basis of the payment are disclosed to you before you begin trading, and the amount on request.
• A partner is not our agent: it has no authority to advise you, to make representations about our services, to vary your agreement, to handle your money, or to trade on your account unless separately authorised.
• A partner earns nothing on volume traded on an account the partner itself controls, and self-dealing is a prohibited practice under clause 6.4 C4.
• Complaints about a partner's conduct are investigated by us and can end the relationship.

06Copy Trading

We operate the service, and we calculate each strategy provider's displayed statistics ourselves.

The conflict: a provider remunerated by reference to follower volume has an interest in generating volume. And because we calculate and publish the figures on which followers rely, we hold a position of trust over data that affects our own order flow.

07What contains it

• Provider statistics are computed from the trades recorded on the provider's connected account — never from figures the provider submits.
• We do not select, vet, endorse, rank by merit or guarantee any provider, and we say so on the service. Listing is not approval.
• Divergence between a provider account and the accounts following it is monitored, and manipulating the service is a High-severity prohibited practice under clause 6.4 D5.
• Where a provider is remunerated by follower volume, the existence and basis are disclosed on the service before you follow.

08PAMM

The conflict: a manager paid a performance fee on new profit above a high-water mark earns nothing during a drawdown. That is the right incentive most of the time — but it can become an incentive to take more risk to get back above the mark.

09What contains it

• Shares, high-water marks and fees are calculated by us from the records of the pooled account, not from the manager's figures.
• A high-water mark attaches to your share and cannot be reset by the manager, by a change of manager, or by the passage of a losing period.
• We do not select, vet or supervise managers, and we say so.
• Rollover-timing and allocation abuse is a High-severity prohibited practice under clause 6.4 D6, monitored by the measures in Appendix B of the Client Agreement.
• We may suspend a manager or wind a pool down and return each share to its investor.

10Our other conflicts

Liquidity, bridge and technology providers. We have commercial relationships with the firms that price and route our flow. Provider selection is made on execution quality and cost, and a provider's request that we act against a client is not acted on unless it is supported by data we have verified ourselves — clause 6.7.1 of the Client Agreement says so expressly.

Staff remuneration. No client-facing or dealing employee is remunerated by reference to an individual client's trading losses. Personal account dealing by staff is restricted and monitored.

Gifts and inducements. Staff may not accept a benefit from a client, partner or provider that could reasonably be expected to influence their conduct. Anything above a nominal threshold is registered or refused.

Research and commentary. Market content we publish is general information, is not tailored to any client, and is not produced to encourage trading in a direction that suits our book.

Our own revenue. Beyond the cost disclosures we make and the charges itemised in your account history, we are not obliged to report the spread income or hedging outcome we derive from your trading, and we do not.

11How conflicts are governed

• A register records each identified conflict, the risk it presents to clients, the arrangement that manages it, and who owns it.
• Compliance reviews the register periodically and on any material change to the business — a new product, a new partner arrangement, a new provider.
• New products are assessed for conflicts before launch, not after.
• Staff are trained on the conflicts relevant to their role and are required to escalate anything the register does not cover.

12When an arrangement is not enough

Where our arrangements are not sufficient to prevent a risk of damage to your interests, we will disclose the nature and source of the conflict to you before proceeding, in enough detail for you to decide whether to continue. Disclosure is a last resort, not a substitute for managing the conflict.

13The limit of this policy

Be clear about what this document is. It is a set of internal arrangements maintained by us, described by us, and — with no financial services regulator supervising the Company — verified by no one but us.

That is a real limitation and we will not dress it up. What we can offer instead is specificity: the constraints above are written into the Client Agreement as binding terms, the evidence behind any measure taken under Section 6 is available to you at trade level, and the complaints procedure is investigated by a person who was not involved. Those are things you can test. A general assurance of integrity is not.

14Questions and complaints

Ask us about any conflict described here, or any you think we have missed: [email protected].

If you believe a conflict has been managed badly and it has affected you, that is a complaint, and our Complaints Handling Policy (/en/legal/complaints) applies. Raising one is free and will not affect your account.

15Review

This policy is reviewed at least annually and on any material change to our business or to applicable law. The version published on this page is the current version.

Conflicts and compliance: [email protected] | Complaints: [email protected]