Conflict of Interest Policy

Document Control

Document Owner: ActivBrokers
Approval Date: 01/01/2022
Revisions/Changes: Initial version

Introduction
- General
- Definition of a Conflict of Interest
- Objectives
Identification of Conflicts of Interest
Procedures to Manage Conflicts of Interest
- General Practices
- Ensuring Fair Treatment of Clients
- Notification Procedures for Employees
- Disclosure to Clients
- Placing Client’s Interests First
- Asset Segregation
- Use of Client Financial Instruments
- Prohibited Practices
Additional Information

1. Introduction

1.1 General

ActivBrokers (hereinafter “the Company”) is committed to identifying, managing, and mitigating conflicts of interest that may arise in the course of its operations. This policy establishes standards and guidelines to manage potential conflicts between the Company, its employees, and its clients to ensure transparency and fairness.

1.2 What is a Conflict of Interest?

A conflict of interest arises when the interests of the Company or its employees potentially conflict with the interests of a client or group of clients. Conflicts can also occur between different clients. In such cases, ActivBrokers must prioritize the client’s interests.

1.3 Objectives

This policy aims to ensure that:

The interests of ActivBrokers’ clients are treated fairly and with integrity.
Potential conflicts are identified and managed effectively.
Clients are informed of any unavoidable conflicts of interest.

2. Identification of Conflicts of Interest

ActivBrokers identifies conflicts by considering factors such as:

The potential for financial gain at a client’s expense.
Interests of the Company or its employees that may differ from those of clients.
Instances where one client’s interests may conflict with another’s.

Some common conflicts of interest include:

When the Company has financial incentives to favor certain transactions.
When confidential information may provide an unfair advantage.
When employees may benefit personally from actions taken on behalf of a client.

3. Procedures to Manage Conflicts of Interest

3.1 General Practices

To manage conflicts, ActivBrokers implements several measures:

Distinct operations between departments to minimize information-sharing that could create conflicts.
Systems to ensure best execution practices, providing optimal results for clients.
Secure access control to prevent unauthorized access to sensitive client information.

3.2 Ensuring Fair Treatment of Clients

ActivBrokers has established procedures to maintain fair treatment of all clients:

Employees are trained to prioritize client interests.
A “Chinese Wall” structure is in place to restrict information flow between departments with potentially conflicting interests.
Monitoring of order execution to ensure clients receive the best possible outcomes.

3.3 Notification Procedures for Employees

Employees must report potential conflicts of interest to the Compliance Officer. Notifications include:

Personal investments that may conflict with client interests.
Financial instruments held by employees or their affiliates.
Any external affiliations that could pose a conflict.

A record of personal transactions and potential conflicts is maintained by the Compliance Officer for regular review.

3.4 Disclosure to Clients

If a conflict of interest cannot be mitigated, ActivBrokers will disclose it to the affected client before proceeding with any transactions. This disclosure will:

Clearly state the nature of the conflict.
Describe the steps taken to manage the conflict.
Allow the client to make an informed decision about continuing the business relationship.

3.5 Placing Client’s Interests First

All employees are expected to prioritize clients’ interests over the interests of the Company or themselves. Employees should act with integrity and avoid any actions that might compromise the client’s financial well-being.

3.6 Asset Segregation

ActivBrokers keeps client assets separate from the Company’s own funds. This segregation minimizes the risk of misuse of client assets and protects them in the event of the Company’s insolvency.

3.7 Use of Client Financial Instruments

ActivBrokers will not use a client’s financial instruments for its own benefit or that of another client unless:

The client has given explicit consent.
The usage terms have been disclosed and agreed upon by the client.

3.8 Prohibited Practices

The following practices are prohibited to prevent conflicts of interest:

Employees may not use client information for personal gain.
No one may use inside information for trading before its public release.
Inducements or gifts from third parties that could influence decisions are not permitted.

4. Additional Information

This Conflict of Interest Policy will be reviewed periodically to ensure compliance with regulatory requirements. For any questions regarding this policy or to address potential conflicts, clients are encouraged to contact ActivBrokers’ support team.

This policy ensures that ActivBrokers remains committed to transparency, integrity, and fairness in all business operations.

Risk Disclosure