The purpose of this document is to provide information on Land-FX UK Ltd.’s policy on conflicts of interest and its approach to managing any conflicts of interest fairly: both between Land-FX UK Ltd. and our clients, and between your interests and those of other clients.
It is required under the EU Markets in Financial Instruments Directive (MiFID) and will apply from 1 July 2016.

Land-FX UK Ltd.’s Conflicts Policy

Land-FX UK Ltd. aims to establish and maintain effective systems, controls and procedures which are designed to identify and manage actual and potential conflicts of interest in the course of its business that pose a material risk to clients’ interests. Land-FX UK Ltd. keeps a record of potential conflicts of interest which could arise during its activities and takes into account, among other things, whether the Land-FX UK Ltd:
• is likely to make a financial gain, or avoid a loss, at the expense of a client;
• has an interest in the outcome of a service or transaction provided to a client, which is distinct from the client’s own interest in that outcome;
• has a financial or other incentive to favour the interest of a client or group of clients over the interests of another client;
• carries on the same business as the client
• receives from a person other than the client, an inducement in relation to a service provided to the client in the form of monies, goods, or services other than the standard commission or fee for that service.

Management of Conflicts

Having identified potential conflicts of interest, Land-FX UK Ltd. has procedures in place to manage conflicts promptly and fairly. The following minimum systems, controls and procedures are in place:
• procedures to ensure that the compliance function operates with appropriate independence;
• procedures to prevent or control the exchange of information between relevant persons engaged in activities;
• involving a conflict of interest, where exchange of that information may harm one or more clients;
• supervisory arrangements providing for the separate supervision of employees, where this is necessary for the fair management of conflicts of interest;
• controls to monitor outside business interests;
• procedures to ensure that disclosures are fair, clear and not misleading, so that clients can make an informed decision;
• rules on personal account transactions to which relevant persons are subject;
• periodic reviews of the effectiveness and continued relevance of Land-FX UK Ltd.’s systems and controls;
• Land FX UK Ltd.’s execution policy, which aims to ensure the best possible outcome on client orders;
• rules on inducements, gifts and entertainment which apply to Land-FX UK Ltd.

Disclosure

When there is no effective way of managing a conflict, this will be disclosed in outline in Land-FX UK Ltd.’s Terms of Business. You may request further information from Land-FX UK Ltd. in relation to such conflicts in order to enable you to make an informed decision about whether to deal with Land-FX UK Ltd. in particular circumstances. In addition, Land-FX UK Ltd. may decline to act for you if the conflict of interest cannot otherwise be effectively managed.