Conflict of Interest Policy

1.1. A conflict of interest may arise where the Company, its employees, its affiliates, or any person directly or indirectly linked to the Company has an interest that may conflict with the duty owed to a client, or where the interests of one client conflict with those of another client.

1.2. The Company has identified the following situations as potential sources of conflicts of interest:

• Counterparty Relationship: As the Company acts as the counterparty to client trades, it may profit when a client incurs a loss and vice versa. This creates an inherent conflict between the Company's financial interest and the client's interest.
• Employee Trading: Employees or directors of the Company who trade in financial instruments may have personal interests that conflict with the interests of the Company's clients.
• Remuneration and Incentives: Compensation structures for employees (including performance-based bonuses) may create incentives that conflict with the duty to act in the best interests of clients.
• Introducing Brokers and Affiliates: Relationships with introducing brokers (IBs), affiliates, or business partners who receive remuneration for referring clients may create conflicts relating to the suitability of services offered.
• Information Asymmetry: Employees or departments within the Company may have access to non-public information that could be used to the disadvantage of clients.
• Order Execution:The Company's execution practices, including pricing and liquidity management, may create situations where the Company's interests are not aligned with those of its clients.

2.1. The Company has implemented the following organisational and administrative arrangements to prevent or manage conflicts of interest:

• Information Barriers (Chinese Walls): The Company maintains information barriers between departments to prevent the improper flow of confidential or market-sensitive information.
• Personal Account Dealing Policy: All employees are subject to a personal account dealing policy that restricts and monitors personal trading activities to prevent conflicts with client interests.
• Remuneration Policy: The Company's remuneration policy is designed to avoid creating incentives that conflict with the duty to act in clients' best interests. Variable remuneration is not solely linked to revenue or trading volume metrics.
• Order Execution Policy: The Company maintains a fair and transparent Order Execution Policy to ensure that client orders are executed fairly and consistently.
• Segregation of Duties: Key functions within the Company (including compliance, risk management, and client-facing operations) are appropriately segregated to minimise the risk of conflicts.
• Gifts and Inducements Policy: The Company maintains a gifts and inducements policy that restricts the acceptance or offering of gifts, hospitality, or other benefits that could create a conflict of interest.
• Training and Awareness: All employees receive regular training on identifying and managing conflicts of interest as part of their compliance training.

3.1. Where the Company's organisational and administrative arrangements are not sufficient to ensure, with reasonable confidence, that the risk of damage to a client's interests will be prevented, the Company will clearly disclose the nature and/or source of the conflict of interest to the affected client before undertaking any business on their behalf.

3.2. The disclosure will be made in a durable medium and will include sufficient detail to enable the client to make an informed decision about whether to proceed with the service in the context of the disclosed conflict.

3.3. Disclosure is a measure of last resort. The Company will always first seek to prevent or manage the conflict through its organisational arrangements before resorting to disclosure.

4.1. The Company maintains a Conflicts of Interest Register, which records all identified conflicts and the measures taken to manage them. The register is reviewed and updated regularly by the Compliance Department.

4.2. This Policy is reviewed at least annually by the Board of Directors and the Compliance Department to ensure its continued effectiveness and compliance with Applicable Regulations.

4.3. The Compliance Department is responsible for monitoring the effectiveness of the Company's conflict management arrangements and for reporting any material issues to senior management.

4.4. Any changes to the Company's business model, services, or organisational structure that may give rise to new or changed conflicts of interest will trigger a review and, if necessary, an update of this Policy.

5.1. If you believe that a conflict of interest has arisen or may arise in connection with the services provided by NextTrade, we encourage you to report your concern to our Compliance Department at compliance@nexttrade.com.

5.2. All reports will be investigated promptly and treated confidentially. Please see our Complaint Handling Procedure if you wish to submit a formal complaint.

If you have any questions about this Conflict of Interest Policy, please contact us: