Conflicts of Interest Policy

Summary

Spreadex Limited is authorised and regulated by the Financial Conduct Authority to carry out investment business. We provide an ‘execution only’ service to clients trading CFDs as well as sports and financial spread betting. One of the requirements within the scope of our authorisation is to take all reasonable steps to identify conflicts of interest between the firm and a client of the firm; or one client of the firm and another, which arise or may arise within our normal course of business.

Spreadex Limited pays due regard to the interests of all of it’s clients and at all times aims to treat them fairly. We will never intentionally put ourselves in a position whereby our interests or our duty to external parties prevents us from discharging our duties to our clients. Conflicts of interest can arise in a variety of circumstances hence; in keeping with the Spreadex business ethos, we seek to ensure that any potential conflicts of interest which may arise are properly managed. The firm maintains a conflicts of interest policy which is applicable to all directors, employees and any other persons directly or indirectly affiliated to our business.

General

For a conflict of Interest to arise Spreadex Limited or a linked person or company must benefit and there must be a possible disadvantage to a client. Spreadex Limited aim to keep a record of the kinds of activity we carry on in which a conflict could arise or has arisen, and, in doing so we take account of the activities of our group companies and employees. Spreadex Limited maintains procedures to prevent or manage actual or potential conflicts which include, though are not limited to, the following:

• Employees of Spreadex and their Immediate families are not permitted to maintain personal accounts with the firm.
• Performance bonuses for Spreadex employees are discretionary and do not precisely correlate with profits generated from profits generated by their activities.
• Spreadex employees are prohibited from accepting any gift and/or favour of whatever kind from any client or supplier of the company without the prior written consent of their manager.
• Spreadex’s Code of Conduct requires employees to disclose the existence of any external activities, relationships or financial interests which may present potential conflicts of interest between the firm and its clients.

where a conflict arises which Spreadex become aware of, we will make a disclosure to the client concerned prior to providing an investment service. If making a disclosure to the client is deemed inappropriate to manage the conflict, we may decide not to proceed with the investment service or the situation giving rise to the conflict.