Conflicts of interest

The regulation of the conflict of interest policy (hereinafter referred to as the Policy) is to ensure the legality of the activity, as well as of the compliance with all norms and procedures aimed at resolving any conflicts of interest between the Company and its Clients.

The Company undertakes to apply such processes that would allow building adequate relationships between the company representatives, its managers, employees, and other persons who are directly or indirectly connected with the Company on one hand and all the customers on the other hand in a way to resolve all possible conflicts that may arise in the course of rendering Investment and other services.

Identification

Conflicts of interest may arise between the Company and individuals and legal entities that are able to use the platform to open contracts for personal or corporate benefit. Below are the situations that can lead to a conflict of interests:

  1. The company or a person representing the company makes financial gains or avoids losses at the expense of the client.
  2. The company or a person representing the company is interested in the outcome of a service or a trade conducted on behalf of the client, which is different from the client's interest in the outcome.
  3. The company or the person representing the company offers advantages or benefits one client (a group of customers) at the expense of another client.
  4. The company or a person representing the company receives a recommendation from a non-client to provide the customer with a certain service or product, or receives a commission for these services and products.

The situations described above are extremely rare. More often, conflicts may arise between the following parties:

  1. Between the Client and the Company
  2. Between two clients
  3. Between the Company and the employee (s) of the Company
  4. Between the client and the employee (manager) of the Company
  5. Between the departments of the Company

Independence

In order to guarantee a high degree of independence, the Company took the following measures:

  • Prevention or control in the exchange of information between the parties (Chinese wall).
  • Divided control of responsibility between the people of a group.
  • Measures to limit the influence on the investor.
  • Measures to prevent and control the transfer of the order and the decision on the investment portfolio and the calculation of their effectiveness.
  • Senior management of the company undertakes to:
  • Regularly and fully follow the principles of compliance with the conflict of interest policy.
  • Creation of a unified approach, allowing identifying and preventing of any situations fraught with conflicts.
  • Raise the level of awareness and responsibility of all persons, including through training (primarily employees of the company and third parties).
  • Provide systems that provide the Customer with information on conflicts within the limits of the permissible and possible.
  • Support the principle of independence.

Setting the Chinese wall

The company builds effective “Chinese walls”, in strict accordance with the norms of the legislation. In particular, the limits of responsibility are set to avoid a situation where one side of the conflict has an impact on the other side of the conflict. In particular, the limitations apply to employees. They are restricted access to information and documents of the Company in the course of a conflict that is being resolved and is connected with this employee.

Reporting conflicts

In the case of an explicit and implicit conflict, the Company employee must first of all convey all the information to his immediate supervisor, who has more powers to help and assess the situation, and who may fill out the form necessary for the regulatory authorities:

  • Actions taken to resolve the conflict
  • If the actions may be considered sufficient and complete
  • All restrictions applied
  • What the other customers and their status for the Customer in question are