Conflicts of Interest Policy

1. Identifying and Managing conflicts of Interest summary

In accordance with its obligations to you, the Firm seeks to ensure that its clients are properly notified where there is or could be a conflict of interest.

2. How are conflicts managed?

The Firm has prepared a Conflicts of Interest Policy, which identifies the types of conflicts it faces and the controls it operates in order to mitigate those conflicts. The policy is reviewed to ensure the record of conflicts is up to date and relevant and the appropriate mitigating controls are in place. The review is reported to the Management Body of the Firm.

The Firm has implemented procedures, controls and segregation of duties appropriate for its business profile. Staff are segregated operationally, such that they report to functional managers and each have distinct password protected IT access.

The Firm also has specific policies and procedures on when and how employees are permitted to undertake personal account transactions, restrictions on the offering and receipt of gifts to or from clients and other businesses counterparties. We also monitor staff external interests to ensure they do not conflict with their duties to the Firm and its clients.

Finally, we monitor the way in which staff are remunerated in order to ensure that remuneration structures do not conflict between staff and the Firm’s clients’ best interests. Thereby, we have defined a strict policy regarding inducements by prohibiting to pay or receive any payments or non-monetary benefits to/from third parties.

3. What conflicts of interest have arisen?

The nature of the financial services market is such that conflicts of interest can sometimes develop. It is the case that, organisational controls within the Firm (summarised above) are not sufficient to ensure, with reasonable confidence, that the related risks are mitigated.

Generally, a conflict of interest arises where the interests of the Firm and its associates are different from its clients. For example, where the Firm discharges its duty to one client it might create a conflict with another client.

4. Next steps

The Firm will continue to monitor and review the matter closely, applying its systems and controls to ensure this conflict of interest and any attendant risks are mitigated to the fullest possible extent. If you should require any further information please contact the Firm’s Compliance Officer at eucompliance@milltechfx.com.