Conflicts of interest policy

1. Situations that can give rise to a conflict

• We earn revenue from spreads, commissions and financing charges on client activity.
• We may hedge client exposure, which means our own positions can move in the opposite direction to yours.
• Staff may hold personal positions in instruments we offer.
• We may receive or provide fees to introducers, affiliates and other partners.
• Our AI features generate signals used by many clients at the same time.

2. How we manage them

• Separation of duties and information barriers between commercial, risk and control functions.
• A personal account dealing policy with pre approval and monitoring for staff.
• Remuneration structures that do not reward staff for outcomes that harm clients.
• Published pricing and fees so costs are transparent before you trade.
• A conflicts register maintained and reviewed by our compliance function.

3. Disclosure and declining business

Where organisational measures are not sufficient to prevent a risk of harm, we disclose the conflict to you clearly before providing the service. Where a conflict cannot be managed adequately, we decline to act.

4. Review

This policy is reviewed at least annually. You may request further information about how we manage a specific conflict by writing to legal@cfxmarkets.com.