POLICY ON INTEREST CONFLICT
Policy on Interest Conflict
In accordance with the Investment Services and Activities and Regulated Markets Law of 2007, the Company is obliged to construct and implement a policy on conflicts of interest and provide a copy to all clients, as well as potential clients.
Moreover, the Policy must outline the Company’s approach to conduct a fair management of any conflicts of interest that may arise from time to time between the managers and employees, employees and Trade12’s clients, and between one client and another.
The Policy on Interest Conflict is established in order to indicate in writing the Company’s procedures for identifying, managing , and disclosing the conflicts of interest to reduce the client disadvantage risk and legal liability, as well as damage to the reputation and commercial interests of the Company. Furthermore, this Policy ensures that Trade12 abides by the legislative requirements and internal procedures of the Company.
The Policy on Interest Conflict is applicable to all the managers, employees, clients, or any other party that is involved directly or indirectly with the Company. This Policy is aimed at determining, preventing, and managing conflicts of interest between the above mentioned parties.
Identifying an Interest Conflict
A conflict of interest may occur when the interests of Trade12 or its employees could come in conflict with the Company’s duty to the Client. This may involve a circumstance wherein:
Managing Interest Conflicts
In order to avoid any possible interest conflicts, Trade12 has established these procedures. The procedures presented below are being reviewed on a regular basis for modifications to be made in case of a loophole.
Generally, the measures to be implemented for the management of interest conflicts in order to ensure the requisite level of independence include:
Directives and Regulations
Some of the measures and rules that are established include the following:
Compliance Officer and the Broker Department
The compliance officer is responsible for deciding on whether to permit or reject a transaction in the light of interest conflicts. In the event that an interest conflict may arise from the transaction, it is also the compliance officer’s duty to inform the Client. The Assessment of Appropriateness is strictly implemented in order to ensure the effective monitoring of the compatibility of the delivery of brokerage services to Clients.
All of Trade12’s employees must possess adequate knowledge of the forbidden practices in relation to transactions. Employees have the responsibility to inform the compliance officer in the event that any of these occurs:
When the measures undertaken by the Company are not adequate to ensure that the risks of damage to Client interest will be controlled or prevented, Trade12 will disclose the source and nature of the interest conflicts to a Client before conducting investment transactions with that Client.
The disclosure of such information will be provided in written form and will also cover substantial details that will allow the Client to make an informed decision in relation to the specific service wherein the interest conflict may emerge.
A copy of this Policy on Interest Conflict is uploaded on Trade12’s official website and may be amended from time to time. Before signing the service agreement, the Client shall acknowledge the existence of such Policy and shall agree to its Terms.
Furthermore, Trade12 holds the right to review and modify this Policy if deemed necessary. Further details regarding the Policy on Interest Conflict shall be provided upon request, and any inquiries regarding this Policy and the Company’s arrangements shall be addressed to the Compliance Department.
Customer Support Department