1. INTRODUCTION1.1. Virtue Technology Group Inc operating under the trading name VirtueForex is a Securities Dealer Licensee regulated and authorised by the Centro Bancario Internacional (CBI) in Panama under the AVISO Licence.
2. PURPOSE AND SCOPE2.1. The purpose of this document is to set out the Companyʼs approach to identify and manage conﬂicts of interest which may arise during the course of its business activities. If the Company has a material interest in a transaction to be entered with or for a client, or a relationship which gives rise to a conﬂict of interest in relation to the transaction, the Company shall not knowingly either advise, or deal in the exercise of discretion, in relation to that transaction unless the Company has:
2.2. The aim of our Policy is to identify and prevent conﬂicts of interest which may arise between the Company and its clients or between one client and another. Accordingly, we have adopted a conﬂicts of interest policy setting out the procedures, practices and controls in place to achieve this.
2.3. The Policy applies to all its directors, employees, any persons directly or indirectly linked to the Company (hereinafter called related persons) and refers to all interactions with all clients.
3. IDENTIFICATION OF CONFLICT OF INTERESTS3.1. For the purposes of identifying the types of conﬂict of interest that arise in the course of providing investment and ancillary services or a combination thereof and whose existence may damage the interests of a client, the Company takes into account, whether the Company or a relevant person, is in any of the following situations:
3.1.1. The Company or relevant person is likely to make a ﬁnancial gain, or avoid a ﬁnancial loss, at the expense of the client;
3.1.2. The Company or relevant person has an interest in the outcome of a service provided to the client or of a transaction carried out on behalf of the client, which is distinct from the client’s interest in that outcome;
3.1.3. The Company or relevant person has a ﬁnancial or other incentive to favour the interest of another client or group of clients over the interests of the client;
3.1.4. The Company or relevant person carries out the same business as the client;
3.1.5. The Company or relevant person receives or will receive 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.
4. PROCEDURES AND CONTROLS TO MANAGING CONFLICTS OF INTERESTS4.1. In general, the procedures and controls that the Company follows to manage the identiﬁed conﬂicts of interest include, but are not limited to, the following measures:
4.1.1. Eﬀective procedures to prevent or control the exchange of information between relevant persons engaged in activities involving a risk of a conﬂict of interest where the exchange of that information may harm the interests of one or more clients.
4.1.2. Measures to prevent or control the simultaneous or sequential involvement of a relevant person in separate investment or ancillary services. Such measures include, but are not limited to, the following:
- a. A ʻneed to knowʼ policy governing the dissemination of conﬁdential or inside information within the Group.
- b. Chinese walls restricting the ﬂow of conﬁdential and inside information within our company, and physical separation of departments.
- c. Procedures governing access to electronic data.
- d. Segregation of duties that may give rise to conﬂicts of interest if carried on by the same individual.
- e. A gifts and inducements log registering the solicitation, oﬀer or receipt of certain beneﬁts.
- f. The prohibition of external business interests conﬂicting with our interests as far as the Companyʼs oﬃcers and employees are concerned, unless board approval is provided.
- g. A policy designed to limit the conﬂict of interest arising from the giving and receiving of inducements.
- h. Establishment of in-house Compliance Department to monitor and report on the above to the Companyʼs Board of Directors.
4.1.3. The Company has a Compliance Department that is responsible for identifying and managing potential conﬂicts of interests. The above will also update the relevant internal procedures and ensure compliance with such procedures.
5. DISCLOSURE5.1. Where a conﬂict arises and the Company is aware of it, it will disclose the conﬂict to the client prior to undertaking investment business for that client or, if it does not believe that disclosure is appropriate to manage the conﬂict, we may choose not to proceed with the transaction or matter giving rise to the conﬂict.
5.2. The Company reserves the right to review and/or amend its Policy and arrangements, at its sole discretion, whenever it deems ﬁt or appropriate.
5.3. Our Conﬂicts of Interest Policy is a policy only, it is not part of our Terms and Conditions of Business and is not intended to be contractually binding or impose or seek to impose any obligations on us which we would not otherwise have, but for the Act and Applicable Regulations.