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.
When the Company deals/transacts with the Client, the Company (or an associate or some other person connected with the Company) may have an interest, relationship or arrangement in relation to the Transaction concerned or that it conflicts with the Client’s interest.
The Company has identified the following circumstances which constitute or may give rise to a conflict of interest entailing a risk of damage to the interests of one or more Clients, as a result of providing investment services:
• 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;
• the Company may be providing other services to associates or other Clients of the Company who may have interests in Financial Instruments or Underlying Assets, which are in conflict or in competition with the Client’s interests;
• the Company is likely to make a financial gain, or avoid a financial loss, at the expense of the client;
• the Company’s bonus scheme may award its employees based on the trading volume etc.;
• the Company may receive or pay inducements to or from third parties due to the referral of new Clients or Clients' trading;
• the Company or a Related 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;
• the Company or a Related person has a financial or other incentive to favor the interest of another Client or group of Clients over the interests of the Client;
• the Company or a related person carries on the same business as the Client.
• the Company may have a financial or other incentive to favor the sale of a particular product or service to a Client which is not in the best interest of the Client.
In general, the procedures and controls that the Company follows to manage the identified conflicts of interest include the following measures (the list is not exhaustive):
• The Company undertakes ongoing monitoring of business activities to ensure that internal controls are appropriate.
• The Company undertakes effective procedures to prevent or control the exchange of information between Related 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.
• The separate supervision of Related Persons whose principal functions involve providing services to Clients whose interests may conflict, or who otherwise represent different interests that may conflict, including those of the Company.
• Measures to prevent or limit any person from exercising inappropriate influence over the way in which the Related Person carries out investment services or ancillary services or activities.
• 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.
• The establishment of a Compliance Department which is responsible for the monitoring and reporting on the above to the Company’s Board of Directors.
• A policy designed to limit the conflict of interest arising from the giving and receiving of inducements.
• Chinese walls restricting the flow of confidential and inside information within the Company, and physical separation of departments.
• Procedures governing access to electronic data.
• Segregation of duties that may give rise to conflicts of interest if carried on by the same individual.
• Personal account dealing requirements applicable to Related Persons in relation to their own investments;
• Prohibition on officers and employees of the Company having external business interests conflicting with the interests of the Company without the prior approval of the Company's board of directors.
• A “need-to-know” policy governing the dissemination of confidential or inside information within the Company.
• Appointment of Internal Auditor to ensure that appropriate systems and controls are maintained and report to the Company’s Board of Directors.
• Establishment of the “four-eyes” principle in supervising the Company’s activities.
• The Company provides and expects relevant Employees to attend or take regular training of conflicts management and conflicts of interest related topics.
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 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 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.
The Company is constantly conducting an in-depth analysis of its business and organizational arrangements including best execution arrangements, inducement practices, remuneration practices and investment research/marketing communication procedures, to ensure that all likely conflict of interest situations are identified regardless of materiality.
The company’s portfolio management and brokerage department are independent and segregated from each other.
Mr. Tomer Chubara is the he of portfolio management he and his team does not determine the costs or commissions associated with the brokerage services. Employees of both departments are independent of each other. So in this case there is no conflict of interest as both departments are adequately segregated from each other.
The Company must adequately consider how to manage all conflicts of interest before resorting to disclosure. This will be a last resort after all appropriate steps have been taken.
If during the course of a business relationship with a Client or a 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 a group of Clients.
The disclosure will:
• be in a durable medium;
• clearly state that the organizational and administrative arrangements established by the Company to prevent or manage the conflicts are not sufficient to ensure, with reasonable confidence, that the risks of damage to the interests of the Client will be prevented;
• include a specific description of the conflicts of interest that arise in the provision of investment services and ancillary services;
• explain the risks to the Client that arise as a result of the conflicts of interest and the steps undertaken to mitigate these risks;
• include sufficient detail, taking into account the nature of the client, to enable the Client to make an informed decision with respect to the services in the context of which the conflict of interest arises.
If a client decides not to go ahead with the service due to the conflict disclosed, the Company will have no choice but to decline the provision of services if the conflict cannot be effectively managed.
The Company reserves the right to review and/or amend its Policy and arrangements whenever it deems this appropriate according to the terms of the Client Agreement between the Company and the Client. Should you require any further information and/or have any questions about conflicts of interest please direct your request and/or questions toinfo@mexem.com
October 2023
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