1. INTRODUCTORY PROVISIONS

In accordance with applicable financial regulations and industry standards, Broking FX is committed to identifying, managing, and disclosing any actual or potential conflicts of interest that may arise in the provision of financial services.

We ensure that all services are delivered:

  • Honestly and fairly
  • With due skill, care, and diligence
  • In the best interests of our clients

We also disclose any personal interests, incentives, or circumstances that may influence our services and take all reasonable steps to ensure fair client treatment.

2. PURPOSE AND APPLICATION

The purpose of this Policy is to:

  • Identify and manage conflicts of interest
  • Prevent any bias that may negatively affect clients
  • Ensure transparency in all business activities

This Policy applies to:

  • Broking FX
  • All employees, representatives, and partners
  • Any third party involved in delivering financial services

3. IDENTIFICATION OF CONFLICTS OF INTEREST

A conflict of interest arises when personal, financial, or other interests may:

  • Influence objective decision-making
  • Compromise fairness or impartiality
  • Result in potential harm to clients

Types of Conflicts:

  • Actual Conflict – A direct conflict exists
  • Potential Conflict – A situation that may lead to conflict
  • Perceived Conflict – A situation that appears to create bias

Key Risk Factors Considered

Broking FX evaluates whether:

  • Staff benefit financially at the expense of clients
  • There is a vested interest in a transaction outcome
  • Client interests are overridden by third-party interests
  • Any incentives influence decision-making

4. INTERNAL CONTROLS & PROCEDURES

To manage conflicts, Broking FX will:

  • Train employees on this Policy
  • Monitor compliance continuously
  • Conduct annual reviews of the Policy
  • Maintain proper documentation and records

5. RELATIONSHIPS WITH THIRD PARTIES

Broking FX:

  • Does not maintain relationships that compromise objectivity
  • Ensures all third-party interactions are transparent
  • Avoids arrangements that could negatively impact clients

6. OWNERSHIP & INTEREST DECLARATION

  • Broking FX has no ownership structures that affect impartial service delivery
  • No representatives hold interests that could influence client outcomes
  • No profit-sharing or financial arrangements exist that conflict with client interests

7. DISCLOSURE MEASURES

If a conflict of interest cannot be avoided:

  • The client will be informed clearly and in writing
  • The nature and risks of the conflict will be explained
  • Client consent will be obtained before proceeding

8. CONFLICT MANAGEMENT PROCESS

  • All conflicts must be reported internally
  • A designated authority will review and decide on actions
  • A Gifts Register is maintained for transparency
  • Continuous monitoring ensures compliance

9. PERMITTED FINANCIAL INTERESTS

The following are allowed if they are reasonable and transparent:

  • Fees agreed upon with clients
  • Standard commissions permitted by law
  • Fair-value benefits or services
  • Non-exclusive training and educational materials

10. PROHIBITED FINANCIAL INTERESTS

The following are strictly prohibited:

  • Cash payments or equivalents from third parties
  • Gifts, travel, hospitality, or incentives influencing decisions
  • Any benefit that may compromise impartiality

⚠️ Exception: Minor benefits within legally permitted limits may be allowed.

11. EMPLOYEE REMUNERATION

Employees will not be rewarded for:

  • Prioritizing quantity of business over quality
  • Favoring specific products or providers unfairly
  • Acting against client interests

12. NON-COMPLIANCE

Failure to comply with this Policy may result in:

  • Internal investigation
  • Disciplinary action
  • Corrective measures

13. RECORD KEEPING

Broking FX maintains records related to:

  • Conflicts of interest
  • Transactions and financial activities
  • Compliance monitoring

Records are retained for 5–7 years as required by law.

14. DEFINITIONS

Key terms include:

  • Conflict of Interest – Any situation affecting impartiality
  • Financial Interest – Any monetary or non-monetary benefit
  • Third Party – External entities involved in service delivery
  • Employee – Any staff, representative, or authorized individual

15. CONTACT DETAILS

For any questions, concerns, or to report a conflict of interest:

Mail Id: –
support@brokingfx.com 
service@brokingfx.com

All reports will be handled confidentially.