Finotec Trading UK Limited - Conflicts of Interest Policy
Finotec Trading UK Limited (âFTUKâ) owes a duty to its clients in respect of managing any conflicts of interest which may arise. Therefore this Conflicts of Interest Policy is sponsored by FTUKâs senior management and will be maintained by the companyâs Compliance Officer (âCOâ).
1.1 FTUKâs Regulated Status
FTUK is authorised and regulated by the Financial Services Authority (âFSAâ) under FRN 470392.
Conflicts of Interest may arise between FTUK, its Directors, staff and / or any of its associates its clients and indeed, clientâtoâclient conflicts may also arise. It is the scope of this policy to prevent and deal with these conflicts should they arise and FTUK aim to maintain effective compliance and operational procedures in order to resolve any such situations.
3 POTENTIAL CONFLICTS
Conflicts of Interest may take many forms but they can all be defined as causing material risk or damage to the interests of a client. Such situations include but are not limited to, instances where FTUK or any entity directly associated with it:
(i) Is likely to benefit financially at the expense of a client;
(ii) Is likely to limit or avoid financial loss at the expense of a client;
(iii) Has a particular leaning towards the interest of one client over that of another which could potentially result in financial gain;
(iv) Designs, markets or recommends a product or service without considering the interests of the client; and
(v) Receives funds, goods or services outside standard commissions, fees or other remunerations for that service.
FTUK will seek to employ several methods and procedures to ensure compliance with its Conflicts of Interest Policy. A summary of these is detailed below, although the list is not necessarily exhaustive:
(i) Maintenance of appropriate independence between members of staff who are involved in different activities;
(ii) Physical separation of staff through âChinese Wallsâ where appropriate â restriction of personal or sensitive information;
(iii) FTUK insist that all employees sign and adhere to a Personal Account Dealing Notice. This document applies to ALL employees and Directors; and a record of receipt and signature will be maintained by the CO. The Personal Account Dealing notice applies to employees in relation to their own investments;
(iv) FTUK employ a âGifts and Inducements Policyâ to log and control the receipt of certain gifts by employees and Directors of the company. It is reasonable to allow our employees to receive small gifts and minor hospitality however, if in the opinion of the CO or a Director, the gift is sufficiently lavish or large as to be viewed as a compromise to the best interests of the client, the gift must be reported to and noted by the CO and such benefits of the gift may be denied;
(v) FTUK are an âexecution-onlyâ business and it is not within the scope of the firmâs regulatory permissions for employees to provide investment advice to clients; and
(vi) FTUK operate a âWhistleblowing Policyâ meaning that if any employee believes the company is acting wrongly and incorrectly with regards to any regulatory procedures, they may act by contacting the FSA in confidence.
If a conflict does arise FTUK will disclose this to the client prior to carrying out any business for that client. If the firm does not believe the disclosure is appropriate to manage the conflict, it may opt not to proceed with the transaction or matter giving rise to the conflict.
For more information, please contact FTUKâs Compliance Officer at firstname.lastname@example.org.