1. Scope

    The European Parliament and Council adopted in 2004 the Directive on Markets in Financial Instruments (the MiFID), which has come intoeffect as from 1/11/2007.
    Under this Directive, investment firms are required to establish, implement and maintain a conflicts of interest policy.

  2. Purpose
    This policy is created by Fenix Capital Markets Trading Ltd for the purpose of:
    • Indemnifying potential conflict of interest
    • Disclose activities that cause conflict of interest by default
    • Outline procedures to manage or/and control conflict of interest

    With this document Fenix Capital Markets Trading Ltd aims to reduce client’s risk and/or disadvantage and Company’s’ legal liability and/or financial damage that can be caused to both client and company

  3. Policy
    In accordance with the requirements of MiFID, Fenix Capital Markets Trading Limited has adopted a policy for the identification and management of conflicts of interest, in relation to investment and ancillary services and investment activities (as such terms are defined in MiFID) carried out by or on behalf of Fenix Capital Markets Trading Ltd.
    The policy concerns conflicts of interest that may arise between Fenix Capital Markets Trading Ltd, including its managers, employees and tied agents, or any person directly or indirectly linked to it by control, and its clients or between one client and another, in the course of providing any investment or ancillary services, or combinations thereof.
    Fenix Capital Markets Trading Ltd implements the policy so as to respect market transparency and integrity and with a view to taking all reasonable steps designed to prevent conflicts of interest from adversely affecting the interests of its clients.
    Fenix Capital Markets Trading Ltd takes all reasonable steps to:
    1. Identify the circumstances which constitute or may cause a conflict of interest, arising in the course of providing investment or ancillary services or a combination thereof and entailing a material risk of damage to one or more clients, and
    2. Manage such conflicts.

    The conflicts of interest policy of the Fenix Capital Markets Trading Ltd is designed with a view to taking all reasonable measures to:

    • Prevent conflicts of interest from adversely affecting clients’ interest. Such measures include the possibility of declining to carry out atransaction or declining to provide services
    • Protect clients’ best interests in all business activities and maintain the confidentiality of information across all levels.

    The Compliance officer has the overall responsibility of the maintenance of policies and procedures regarding conflicts of interest. The Internal Audit function executes periodical auditing in order to ensure that the policy and procedures regarding conflicts of interest are strictly followed. Both functions are independent from business units.

  4. Organisational and administrative arrangements and controls
    In general, the procedures and controls implemented by Fenix Capital Markets Trading Ltd regarding conflicts of interest include the following measures:
    • Segregation (Chinese Walls) between business activities likely to generate conflicts of interest. These arrangements ensure physical separation of departments, prevent undue circulation of confidential information, and prevent the use of confidential information in ways that may damage market integrity or clients’ interests
    • Procedures designed to identify, prevent, manage and/or disclose conflicts of interest when providing various investment or ancillary services or combinations thereof
    • Administrative and organizational arrangements designed to ensure the independence of investment research
    • Procedures to ensure the proper execution of client orders, particularly in relation to allocation of assets or financial instruments, and primacy of clients’ orders over trading for Fenix Capital Markets Trading Ltd own account
    • Staff dealing procedures allow exposal of sensitive information and control over trades only to persons needed to execute their duties and responsibilities as assigned to them.
    • Remuneration policies for Fenix Capital Markets Trading Ltd employees specifically designed to remove any direct link between the remuneration of relevant persons principally engaged in one activity and the remuneration of, or revenues generated by, different relevant persons principally engaged in another activity, where a conflict of interest may arise in relation to those activities
    • Official table of charges, fees and commissions. Where our organisational or administrative arrangement are not sufficient to ensure, with reasonable confidence, that risks of damage to client interests will be prevented, Fenix Capital Markets Trading Ltd will either decline to act or, where confidentiality considerations permit, will disclose the general nature and/or sources of conflicts of interest to the client or potential client, before undertaking business on its behalf, in order to enable that client to take an informed decision with respect to the investment or ancillary service in the context of which the conflict of interest arises.
  5. Additional information

    Additional details on the conflicts of interest policy of Fenix Capital Markets Trading Ltd are available upon request.

  6. Disclosure of Conflict of Interest
    Taking into consideration the services the Company offers, potential Conflict of Interest circumstances may include, but are not limited to:
    • Divergent Investment Advice given to clients on the same product This may occur during Company’s daily operations as Clients may have different portfolio or investment objectives resulting in opposite or variant service by the company
    • Transition of Clients Orders in non-sequentially or any way that favour a Client over another Client All Orders are received and transmitted in timely manner unless specified by the Client in a written agreement with the Company. In this case the Company will receive and transmit the Orders in a fair manner
    • Remunerations Pay and bonuses are linked to the profits of the Company or the business or department where an employee works. Pay and bonuses linked to the performance of another department, with possible conflicting interests, is avoided at all times
    • Gift and/or other financial incentives between Clients and Company Any type of gift, bonus or other actions that can be consider as an incentive from Client to Company and is not previously agreed upon in the form of a contract of service it is under the Companies discretion for acceptance. In such case the company will immediately disclose such event among its clients and under no circumstances such action will result to favourable treatment among Clients
  7. Review

    Fenix Capital Markets Trading Ltd reserves the right to review and/or amend its conflicts of interest policy and arrangement whenever it deems this appropriate.