AgeFX - CONFLICTS OF INTEREST POLICY
1. Introduction
This Conflicts of Interest Policy (“the Policy”) is provided to you (our Client or prospective Client)
in accordance with the Investment Services and Activities and Regulated Markets Law of 2017 (L.
87(Ι)/2017) (the “Law”), which has transposed Directive 2014/65/EU of the European Parliament
and of the Council of 15 May 2014 on markets in financial instruments (the “MiFID II Directive”)
into national law, pursuant to which AgeFX (“the Company”) is required to take all appropriate
steps to detect and avoid conflicts of interest.
The Company is committed to act honestly, fairly and professionally and in the best interests of
its Clients and to comply, in particular, with the principles set out in the above Law when providing
investment services and other ancillary services related to such investment services.
The purpose of this document is to set out the Company’s approach in identifying and managing
conflicts of interest which may arise during the course of its normal business activities. In addition,
this document identifies circumstances which may give rise to a conflict of interest.
2. Scope
The Policy applies to all its directors, employees, associates and any persons directly or indirectly
linked to the Company (hereinafter called “Related Persons”) and refers to all interactions with
all Clients.
3. Criteria of identifying conflicts of interest
For the purposes of identifying the types of conflicts of interest that may arise in the course of
providing investment and ancillary services or a combination thereof and whose existence may
damage the interest of a Client, the Company takes into account, by way of minimum criteria, the
question of whether the Company or a Relevant Person, or a person directly or indirectly linked
by control to the Company, is in any of the following situations, whether as a result of providing
investment or ancillary services or investment activities or otherwise:
(a) The Company or a 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 district from the
Client’s interest in that outcome;
(b) The Company or a relevant has a financial or other incentive to favour the interest of
another Client or group of Clients over the interests of the Client;
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(c) The Company or a 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;
(d) The Company or a Related Person carries on the same business as the Client;
(e) the Company provides a service to a Client and the Company or another member of the
Group has a material interest in the transaction;
(f) The Company acts as agent for the client in relation to transactions in which another
member of the Group acts as principle;
(g) A transaction is effected in financial instruments in respect of which the Company or
another member of the Group may benefit from a commission, fee, or non-monetary
benefit payable otherwise than by the Client;
(h) The Company may have an indirect interest in a transaction while another member of the
Group may have a direct interest in the same transaction;
4. Identification of Conflicts of Interest
When the Company deals with the Client, the Company, an associate or some other person
connected with the Company may have an interest, relationship or arrangement that is material
in relation to the Transaction concerned or that it conflicts with the Client’s interest. While it is
not feasible to define precisely or create an exhaustive list of all relevant conflicts of interest that
may arise, as per the current nature, scale and complexity of the Company’s business, the
following list includes circumstances which constitute or may give rise to a conflict of interest
entailing a material risk of damage to the interests of one or more Clients, as a result of providing
investment services:
(a) the Company may have an interest in maximizing trading volumes in order to increase its
commission revenue, which is inconsistent with the Client’s personal objective of minimizing
transaction costs;
(b) the Company’s bonus scheme may award its employees based on the trading volume etc.;
(c) the Company may receive or pay inducements to or from third parties due to the referral of
new Clients or Clients’ trading;
(d) The Company may use entities which are members of its Group as Execution Venues (see
below);
4.1.As per the current nature, scale and complexity of the Group, the following list includes
circumstances which constitute or may give rise to a conflict of interest entailing a material
risk of damage to the interests of one or more Clients, as applicable. The Company may:
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(a) effect transactions in which it or any other member of the Group has, directly or indirectly, a
material interest, which may involve a potential conflict with Company’s duty to its Clients;
(b) use another member of the Group for placing deposits, execution and clearing of transactions;
(c) effect transactions in securities in respect of which the Company or another member of
the Group may benefit from a commission or fee payable otherwise than by the Client, and/or
the Company or another member of the Group may also be remunerated by the counterparty
to any such transaction;
(d) execute client orders with entities belonging to the Company’s Group where the revenues of
those entities is largely generated from client’s trading losses;
It should be noted that the above circumstances which constitute or may give rise to a conflict of
interest, are not necessarily detrimental to the interests of Clients.
5. Procedures and Controls for Managing Conflicts of Interests
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:
(a) 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;
(b) The separate supervision of relevant persons whose principal functions involve carrying
out activities on behalf of, or providing services to, Clients whose interest may conflict, or
who otherwise represent different interests that may conflict, include those of the
Company;
(c) The removal of any direct link between the remuneration of relevant persons principally
engaged in one activity and the remuneration of, or revenues generated by, different
relevant persons principally engaged in another activity, where a conflict of interest may
arise in relation to those activities;
(d) Measures to prevent or limit any person from exercising inappropriate influence over the
way in which a relevant person carries out investment or ancillary services or activities;
(e) A policy designed to limit the conflict of interest arising from the giving and receiving of
inducements;
(f) Chinese walls restricting the flow of confidential and inside information within the
Company, and physical separation of departments;
(g) Procedures governing access to electronic data;
(h) Segregation of duties that may give rise to conflicts of interest if carried on by the same
individual;
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(i) Prohibition of external business interests conflicting with our interests as far as the
Company’s officers and employees are concerned, unless Board of Directors approval is
provided;
(j) Establishment of in-house Compliance Department to monitor and report on the above to
the Company’s Board of Directors;
(k) A “need-to-know” policy governing the dissemination of confidential or inside information
within the Company;
(l) Appointment of Internal Auditor to ensure that appropriate systems and controls are
maintained and report to the Company’s Board of Directors;
(m) Establishment of the “four-eyes” principle in supervising the Company’s activities;
(n) Measures to prevent or control the simultaneous or sequential involvement of a Related
Person in separate investment services where such involvement may impair the proper
management of conflicts of interest;
(o) The Company undertakes on-going monitoring of business activities to ensure that internal
controls are appropriate;
(p) Establishment of Personal Transactions Policy;
(q) Staff members are required to immediately notify the Company in case they perceive that
a conflict of interest may be created due to the undertaking of a specific task/work;
(r) Advises/recommendations on transactions are prohibited;
(s) Staff members are forbidden to accept gifts, promotions, discounts or any other monetary
or benefit in kind from Clients or third parties, which may create conflicts of interest. Gifts
of low value may be accepted after approval from the Company;
(t) Divisions and legal entities of the Group operate with appropriate independence from one
another;
(u) There is controlled flow of information between different Group entities/outsourcing
service providers where, otherwise, the risk of a Conflict of Interest may harm the interests
of a Client;
(v) Supervisory arrangements provide for separate supervision of staff of the different Group
entities where necessary for the fair management of Conflicts of Interest, as applicable;
(w) In circumstances not covered by the points above and given the nature of a conflict of
interest situation, the Chief Compliance Officer and/or the Senior Management shall
decide whether to allow a transaction by notifying the Client, or not allow the transaction
all together;
6. Client’s Consent
By entering into a Client Agreement with the Company for the provision of Investment Services,
the Client is consenting to an application of this Policy on him. Further, the Client consents to and
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authorizes the Company to deal with the Client in any manner which the Company considers
appropriate, notwithstanding any conflict of interest or the existence of any material interest in a
Transaction, without prior reference to the Client.
In the event that the Company is unable to deal with a conflict of interest situation it shall revert
to the Client.
7. Disclosure of Information
If during the course of a business relationship with a Client or group of Clients, the organizational
or administrative arrangements/measures in place are not sufficient to avoid or manage a conflict
of interest relating to that Client or group of Clients, the Company will disclose the conflict of
interest before undertaking further business with the Client or group of Clients.
8. Amendment of the Policy and Additional Information
The Company reserves the right to review and/or amend its Policy and arrangements whenever
it deems this appropriate without notice to the Client.
Should you require any further information and/or have any questions about conflicts of interest
please direct your request and/or questions to support@agefx.io .
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