Potential Conflict of Interest Policy

This Potential Conflict of Interest Policy (hereinafter called the "Policy") is designed to identify, disclose, and manage any potential conflicts of interest that may arise between the Company, its Clients, or among Clients themselves. The aim of this Policy is to ensure that all such conflicts are addressed transparently and fairly, thereby protecting the interests of all parties involved.

By using our services, you hereby acknowledge that you have read, understood, and agreed to the terms and procedures set forth herein.

1. Procedure for Reporting Potential Conflicts

In the event you believe a conflict of interest may exist, you are required to raise such concerns in accordance with the procedures outlined in this Policy. Specifically, you must submit a detailed concern to the Company, which includes:

  • Full name
  • Trading account number
  • Registered email address
  • A comprehensive description of the issue

Such concerns should be submitted to our official email address for review. The Company will then assess and address the matter in accordance with this Policy and the Terms and Conditions of Use.

The Company may request further information or documentation to conduct a thorough investigation. Should the claim be determined to be unfounded or complex, the Company reserves the right to decline or dismiss the concern.

2. Authority to Suspend or Terminate Activities

If a conflict of interest is identified or confirmed, the Company reserves the right to suspend, cancel, or terminate any ongoing trades or activities within the affected account. Additionally, if the conflict involves more than one party, the Company may disclose the nature of the conflict to the relevant parties to facilitate resolution.

3. Identification of Potential Conflicts

To effectively manage potential conflicts of interest, the Company actively monitors and evaluates circumstances that may lead to such conflicts. Specific scenarios that may indicate the existence of a conflict of interest include, but are not limited to:

  • The Company or its employees stand to gain financially or avoid financial loss at the expense of a Client.
  • One Client stands to profit or avoid loss at the expense of another Client.
  • The Company, its employees, or a Client expects compensation from a third party for services provided to the Client, beyond agreed-upon fees or commissions.

4. Measures for Managing and Preventing Conflicts

When a potential conflict of interest is identified, the Company may take various measures to mitigate or prevent the conflict, including:

  • Restricting the exchange of sensitive information between conflicting parties.
  • Monitoring the activities of service providers to ensure no conflicting interests arise.
  • Ensuring that Client remuneration is not directly tied to the financial outcomes of another Client’s activities.
  • Limiting or restricting any party from unduly influencing services or investments.
  • Preventing parties from gaining improper access to confidential information or systems.
  • Establishing protocols to prevent improper inducements, ensuring full transparency where legitimate inducements exist.

5. Obligations of the Parties and Limitations on Disclosure

You hereby acknowledge that the Company is not obligated to provide advisory services regarding any conflict of interest that may arise. However, the Company reserves the right to disclose the nature of the conflict to the relevant parties, where such disclosure is necessary for resolution.

Furthermore, you agree that:

  • Any conflict of interest will be reviewed within 7-14 business days. The resolution may take longer, depending on the complexity of the issue.
  • You shall cooperate fully in the resolution process.
  • You will not disclose or publicly comment on any unresolved conflict of interest. Such premature disclosures may result in legal action.
  • Any attempt to blackmail, threaten, or harass the Company or its employees will not be tolerated and may result in legal action, suspension, or termination of access to the Company's services.

6. Final Provisions

By continuing to use the Company’s services, you confirm that you have read, understood, and agreed to the procedures and measures outlined in this Potential Conflict of Interest Policy.

The Company retains the right to amend or modify this Policy at any time. Any changes will become effective immediately upon publication on the Company’s website.