Conflicts of Interest Policy

Spreadex Limited is authorised and regulated by the Financial Conduct Authority to carry out investment business. We provide an ‘execution only’ service to clients who wish to spread bet in both financial and sports markets. One of the requirements within the scope of our authorisation is to take all reasonable steps to identify conflicts of interest between the firm and a client of the firm; or one client of the firm and another, which arise or may arise within our normal course of business.

Spreadex Limited pays due regard to the interests of all of its clients and at all times aims to treat them fairly. We will never intentionally put ourselves in a position whereby our interests or our duty to external parties prevents us from discharging our duties to our clients. Conflicts of interest can arise in a variety of circumstances hence; in keeping with the Spreadex business ethos, we seek to ensure that any potential conflicts of interest which may arise are properly managed. Our conflicts of interest policy is applicable to all directors, employees and any other persons directly or indirectly affiliated to our business.

PRICING POLICY

Our straightforward and transparent pricing mechanism for financial spread betting is detailed within our Financial Spread Betting Handbook and illustrates in a clear and user-friendly manner exactly how our charges are calculated.

PERSONAL ACCOUNT DEALING PROCEDURES

Employees of Spreadex and their immediate families are not permitted to maintain a personal account with the firm. However, should employees wish to hold a spread betting account with a competitor firm, or trade in investments generally, prior permission must be sought from the Compliance Officer or Managing Director. Upon approval, copies of all Confirmations must be forwarded to the firm’s Compliance Officer.

PERFORMANCE REMUNERATION OF TRADERS

Members of our trading teams participate in a six-monthly bonus scheme, whereby bonuses are distributed to individuals depending on the performance of their entire team. Performance bonuses for individual traders are discretionary and do not correlate precisely with the profit generated from events they trade.

The computer system prevents trades from being booked when insufficient funds are available on the client’s account, and credit limits may only be adjusted by authorised staff with the appropriate IT system access rights. Consequently, in the event that a trader wishes to take a trade when a client does not have sufficient funds available on their account, the trader must refer to his senior, who in turn must refer to the credit department within the back office.

The system we have in place offers a degree of credit protection to our clients. We feel it is important to be proactive and conduct our business affairs responsibly. We are mindful of our obligations to the regulator, and accordingly, we take a risk-based approach in order to protect the interests of our customers and treat them fairly. We feel that these procedures mitigate any potential conflict of interest between the trading team, the credit department and the client and his/her propensity to incur excessive debt.

INDUCEMENTS – ACCEPTANCE OF GIFTS

Spreadex employees may not without the prior written consent of their manager accept any gift and/or favour of whatever kind from any client or supplier of the company, or from any prospective client or supplier. Any gifts received must be disclosed to the Compliance Officer and recorded in the gifts register. The items are thereafter placed in a pool and distributed annually to staff by way of an independent ballot. With regards to entertainment offered by clients and business associates, there is a maximum £500 threshold, beyond which, the offer must be referred to a director for prior approval. Employees of Spreadex must not accept from any person any benefit or inducement which is likely to conflict with their duties to the firm or any of the firm's customers.

EMPLOYEE CODE OF CONDUCT

Employees of the firm must disclose the existence of any external activities, relationships or financial interests which may present potential conflicts of interest between the firm and its clients.

Where a conflict arises which we become aware of, we will make a disclosure to the client concerned prior to providing an investment service. If making a disclosure to the client is deemed inappropriate to manage the conflict, we may decide not to proceed with the investment service or the situation giving rise to the conflict.