Conflicts of Interest Policy

Under guidance from our regulator and in accordance with the FSC’s Principles for Businesses InterTrader Ltd is required to manage conflicts of interest fairly, both between itself and its customers and between customers.

InterTrader Ltd is committed to treating its customers fairly and it will never knowingly put itself in a position whereby its own interests, or its duty to another party, prevent it from discharging its duty to a customer.

If InterTrader Ltd has a relationship that gives rise to a conflict with the interests of any of its customers, it will not knowingly act for that customer without taking reasonable steps to ensure the fair treatment of that customer.

All employees are required to comply with InterTrader Ltd independence policy. The InterTrader Ltd independence policy effectively states that, when dealing with a customer, employees must disregard any corporate or personal relationship, arrangement or interest that is likely to influence the information given to, or actions undertaken on behalf of, a customer in relation to the transaction or service in question. When providing information to, or undertaking action on behalf of, a particular customer, employees must pay due regard to the interests of that particular customer and should disregard the interests of any other party.

We have created procedures that will manage actual and/or potential conflicts and we will record all activities that we carry out from which a material conflict could potentially arise. We have implemented Chinese walls and the segregation of functions that should act to minimise the occurrence of any such situation.

In order to ensure transparency and minimize conflicts of interest, InterTrader limited has adopted a policy to cover the rules for refusing, receiving and disclosing gifts and entertainment. We maintain a corporate register of all gifts or entertainment which create or may appear to create a conflict of interest or which exceed a value of €50.00 in any month. As such our staff are allowed to receive gifts and or entertainment that are not considered lavish or could lead to a conflict.

If InterTrader Ltd decides that a conflict of interest cannot be managed effectively by disclosing the conflict of interest to the customer or by its policy of independence, it will decline to act for that customer. This will be a Senior Management decision.