Reporting

Conflicts of Interest situations or potential conflicts situations should be reported to the Compliance Officer immediately. Please send an email to contact@fx7capitals.com

Record Keeping

Seven Capitals Foreign Brokerage Limited must keep and regularly update a written record of the kinds of ancillary services or activities carried out by or on behalf of the firm in which a conflict of interest entailing a material risk of damage to the interests of one or more clients has arisen or in case of an ongoing service or activity, may arise. These records will be for a minimum period from the date of creation and are maintained on an ongoing basis by the Compliance Officer.

 

Remuneration & Oversight

The management oversight and determination of appropriate remuneration of members of staff is conducted by Seven Capitals Foreign Brokerage Limited’s Senior Management. Remuneration is based on the overall results of the firm and is not based on the success of any particular transaction.

Remuneration for customer facing and sales staff should be partly based on business production. Staff are subject to appropriate management and supervision to ensure that Seven Capitals Foreign Brokerage Limited is able to demonstrate that it has appropriate and effective arrangements in place to ensure that conflicts of interest are properly managed.

Information barriers

Seven Capitals Foreign Brokerage Limited maintains appropriate policies in its internal policies detailing the potential use of “Insider Lists” and “Information Barriers” often known as Chinese Walls so as to limit or withhold the use of information that is price-sensitive, confidential, and could give rise to market abuse, restrictions on dealing, conflicts of interest, or any other improper or unethical activities. The Compliance Officer monitors along with the relevant business line managers the effectiveness of any Information Barriers that may be required. In certain circumstances staff may need to be taken “across the wall”, should this be required, the Compliance Officer must be notified and a record made thereof.

Segregation of Duties

There are several distinct tasks within the investment management business that could lead to potential conflicts of interest that are mitigated by them being segregated from the individuals directly involved in the task.

Disclosure

In certain cases, Seven Capitals Foreign Brokerage Limited may disclose the general nature and/or source of potential or actual conflicts to its client in writing before undertaking business on its behalf so that the client can decide whether or not to accept these potential conflicts. If it is not possible to avoid or manage a conflict of interest, Seven Capitals Foreign Brokerage Limited may have no choice but to decline to provide the service requested.

Aggregation of orders

Where Seven Capitals Foreign Brokerage Limited aggregates the orders of clients, it must ensure that this does not work to the overall disadvantage of any client whose order is to be aggregated. Seven Capitals Foreign Brokerage Limited makes reference to this within the Order Execution Policy.

Outside employment, external Directorships and business interests

No employee may engage in any additional occupation without the consent of the Company. In certain circumstances, consent may be withheld. Employees must not accept personal fiduciary appointments (such as trusteeships, Director Appointments or executorships other than those resulting from family relationships) without first obtaining written approval from the COO or the Compliance Officer.

Personal account dealing

Employees may only undertake personal investment activities that do not breach applicable law or regulation, do not unduly distract from their employment responsibilities and do not create an unacceptable risk to the company’s reputation. Transactions should also be free

from business and ethical conflicts of interest. Employees must never misuse proprietary or client confidential information in their personal dealings and must ensure that clients are never disadvantaged as a result of their dealings.

Seven Capitals Foreign Brokerage Limited’s Personal Account Dealing Policy has been established to ensure that personal account dealing by members of staff comply with this policy. This includes a requirement for pre-deal approval from the Compliance Officer. Such permission is normally only valid for 24 hours.

Seven Capitals Foreign Brokerage Limited’s Personal Account Dealing policy is set out in the firms’ Compliance Manual.

Inducements including gifts and hospitality

Seven Capitals Foreign Brokerage Limited maintains business relationships with third parties who may remunerate in the form of management and performance fees, which can constitute monetary or non-monetary benefits thereby impairing Seven Capitals Foreign Brokerage Limited’s fiduciary duties to the client. Such payments are classified as inducements. Further details are included in the Compliance Manual.

Gifts and hospitality could lead to potential conflicts of interest. No employee may accept from or give to, any person any gift or other benefit that cannot properly be regarded justifiable in all circumstances. Policies and procedures have been implemented to ensure that staff and their connected persons do not offer or accept gifts or inducements which may give the perception that decisions or actions are not impartial.

These policies are set out in the Compliance Manual. All employees must act with the highest standards of integrity to avoid any allegations of conflicts of interest.

A record is kept by the Compliance Officer of any gifts or hospitality received or given. Where an invitation to a hospitality event could be construed as being a business inducement, it must be declined and the Compliance Officer informed.

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