1. Introduction
1.1 AlgoFX (hereinafter referred to as “Company”) is incorporated by the Republic of Mauritius exclusively for all commercial, financial, lending, borrowing, trading, service activities, and the participation in other enterprises, as well as to provide brokerage, training and managed account services in currencies, commodities, indexes, CFDs, and leveraged financial instruments. The objects of the Company are all subject matters not forbidden by International Business Companies (Amendment and Consolidation), one of the largest business conglomerates in South Eastern Europe.
1.2 The purpose of the conflicts of interest policy (hereinafter the “Policy”) is to set out the Company’s approach in identifying the circumstances which may give rise to a conflict of interest, the Company’s measures for preventing the rise of such conflicts of interest, as well as managing conflicts of interest which may arise during the course of its normal business activities.
1.3 The Company is committed to act honestly, fairly, and professionally and in the best interests of its Clients and to comply, in particular, with the principles set out in the above legislation when providing investment services and other ancillary services related to such investment services.

2. Definition
2.1 The term “conflict of interest” is used to describe a situation which has the potential to undermine the impartiality of a person because of the possibility of a clash between the person’s self-interest and professional interest, i.e., the Company obtaining a financial or any other kind of benefit from the Client during the provision of investment services to the Client.

3. Scope
3.1 The Policy applies to all “Relevant Persons” in relation to the Company as defined in the Law including, but not limited to, all Company’s directors, employees, any persons directly or indirectly linked to the Company by control, who might be exposed to conflicts of interests arising between their personal interests and/or the interests of the Company with the interests of the Company’s Clients and all interactions of the Company with its Clients as well as between one Client and another, in the course of providing any investment services.

4. Relevant persons’ duty
4.1 All “Relevant Persons” have a duty, to the extent possible, to avoid any activities that could create conflicts of interest. It is imperative to firstly refrain from creating or contributing to the creation of conflicts of interest and, where such exist, to take all necessary measures for minimizing the impact to Client’s best interest as per section “Management of conflicts of interest.”
4.2 All “Relevant Persons,” when faced with a possible conflict of interest situation, shall immediately notify the Compliance Officer of the conflict of interest situation.
4.3 It is of most importance that the members of the Board of Directors have a duty to avoid to the extent possible activities that could potentially create conflicts of interest. For that purpose, the following actions are in place in order to minimize the possibility of creating conflicts of interest:
(a) A member’s duty to notify BoD prior to involvement in an activity, e.g., serving on another management body that could raise or contribute to conflict of interest.
(b) A member’s duty to promptly disclose any matter that may result in, or has already resulted in, a conflict of interest.
(c) A member’s duty to abstain from voting on any other matter where the member may have a conflict of interest or where the member’s objectivity or ability to properly fulfill duties to the directorship may be otherwise compromised.

5. Identification of potential conflicts of interest
5.1 For the purposes of identifying the types of conflicts of interest that arise in the course of providing investment and ancillary services or a combination thereof and whose existence may damage the interests of a Client, the Company takes into consideration, by way of minimum criteria, the following:
(a) The Company, the Execution Venue, and/or any related person of the Company is likely to make a financial gain or avoid financial loss at the expense of the Client.
(b) The Company, the Execution Venue, and/or any related person of the Company 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.
(c) The Company, the Execution Venue, and/or any related person of the Company has a financial or other incentive to favour the interest of another Client or group of Clients over the interests of the Client.
(d) The Company, the Execution Venue, or a related person carries on the same business as the Client.
(e) The Company, the Execution Venue, or a related person 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.

6. Potential conflicts of interest within a group of companies
6.1 The Company, as a member of AlgoFX, must take into consideration any circumstance which might give rise to a conflict of interest as a result of the structure and business activities of any other members within the Group.
6.2 The Company shall identify, with reference to the specific investment services and activities and/or any ancillary services carried out by or on behalf of the Company, any circumstances which constitute or give rise to a conflict of interest entailing a material risk of damaging the interests of one or more Clients.
6.3 The Company has adopted procedures and measures set out in section 9 of this Policy in order to manage conflicts of interest and ensure that Relevant Persons which are engaged with the provision of investment or ancillary services or activities carry on those activities on a level of independence appropriate to the size and activities of the Company and of the Group.

7. Examples of conflicts of interest
7.1 While it is not feasible to define precisely or create an exhaustive list of all relevant conflicts of interest that may arise, as per the current nature, scale and complexity of the Company’s business, the following list includes circumstances which constitute or may give rise to a conflict of interest entailing a material risk of damage to the interests of one or more Clients, as a result of providing investment and/or ancillary services:
(a) The Company may have information regarding Clients’ orders and may engage in transactions on behalf of other Clients or on its own account while such Client orders are still being executed.
(b) A Client may be treated less favourably compared to other Clients in relation to the execution of their orders or in respect of benefits such as research or other non-monetary inducements.
(c) The Company or a Relevant Person receives or provides inducements from or to third parties in connection with investment services provided to Clients.
(d) The Company or a Relevant Person has an interest in the outcome of a service provided to a Client, which is distinct from the Client’s interest in that outcome.
(e) The Company or a Relevant Person may receive benefits such as gifts, entertainment, or preferential treatment that could influence their behaviour in a manner that conflicts with the interests of the Client.

8. Disclosure of information
8.1 The Company gives priority to identifying, preventing and managing conflicts of interest. However, if the measures taken by the Company are not sufficient to ensure, with reasonable confidence, that risks of damage to the interests of the Client will be prevented, the Company shall clearly disclose the general nature and/or sources of conflicts of interest to the Client before undertaking business on its behalf.
8.2 Such disclosures shall be made in a durable medium and shall include sufficient detail, considering the nature of the Client, to enable the Client to take an informed decision with respect to the investment or ancillary service in the context of which the conflict of interest arises.
8.3 The Company reserves the right not to proceed with a transaction or matter giving rise to the conflict of interest where the conflict cannot be managed in any other way.

9. Management of conflicts of interest
9.1 The Company has established adequate and appropriate internal procedures for ensuring that conflicts of interest are managed effectively. These include, but are not limited to:
(a) Effective procedures to prevent or control the exchange of information between Relevant Persons engaged in activities involving a risk of conflict of interest.
(b) The separate supervision of Relevant Persons whose principal functions involve carrying out activities on behalf of, or providing services to, Clients whose interests may conflict, or who otherwise represent different interests.
(c) The removal of any direct link between the remuneration of Relevant Persons principally engaged in one activity and the remuneration of, or revenues generated by, different Relevant Persons principally engaged in another activity, where a conflict of interest may arise.
(d) Measures to prevent or limit any person from exercising inappropriate influence over the way in which a Relevant Person carries out investment or ancillary services.
(e) Measures to prevent or control the simultaneous or sequential involvement of a Relevant Person in separate investment or ancillary services or activities where such involvement may impair the proper management of conflicts of interest.
(f–q) [Additional measures as previously listed remain unchanged.]

10. Final resolution of conflicts
10.1 Where conflicts of interest exist and the established internal procedures are insufficient to ensure with reasonable confidence that the risk of damage to client interests will be prevented, the Company shall disclose the conflict to the client and/or decline to act.

11. Inducement
11.1 The Company may pay and/or receive fees and/or commissions and/or any non-monetary benefits to/from third parties in relation to a business relationship with a Client only where the payment or benefit:
(a) Is designed to enhance the quality of the relevant service to the Client; and
(b) Does not impair compliance with the Company’s duty to act honestly, fairly and professionally in accordance with the best interests of the Client.

12. Staff remuneration
12.1 Determination of appropriate remuneration of staff members and other Relevant Persons takes into account measures to prevent conflicts of interest, including adherence to performance appraisal policies and ensuring no one is rewarded for favouring one Client over another.

13. Client’s consent
13.1 The Client acknowledges and understands that the Company may have conflicts of interest in the course of providing investment services and consents to the handling of those conflicts in accordance with this Policy.

14. Amendment/review
14.1 The Company has the right to amend the current Policy at its sole discretion and at any time it considers appropriate.
14.2 The Company shall review and update, as necessary, the Policy on a regular basis, at least annually.

15. Further information
15.1 For further details with regards to the Company’s conflicts of interest policy, Clients may contact the Company using the contact details provided on the Company’s website.