Conflicts of Interest Policy

Introduction and principles

As a provider of financial services, Quay Financials (Gibraltar) Limited, including all its entities is required to maintain and operate effective organizational and administrative arrangements with a view to taking all reasonable steps to identify, monitor and mange conflicts of interest. Quay has put in place a policy to safeguard its clients’ interests.

-Quay faces actual and potential Conflicts of Interest periodically. Quay is fully committed to professionalism and integrity in doing business, thereby treating our customer fairly. In our activities however, we may face actual and potential Conflicts of Interest, both between ourselves and our clients and between one client and another. It is Quay’s policy to take all reasonable steps to identify and manage Conflicts of Interest adequately and to always act in the best interests of our client. We have policies and procedures in place to achieve this goal.

Senior management within Quay are responsible for ensuring that Quay’s systems, controls and procedures are adequate to identify and mange Conflicts of Interest. The Compliance officers of Quay assist in the identification and monitoring of actual and potential Conflicts of Interest.

The protection of its clients’ interest is Quay’s number one concern and so this Policy sets out how:

Quay will identify circumstances which may give rise to conflicts of interest entailing a material risk of damage to its clients’ interests;
Quay has established appropriate mechanisms and systems to manage those conflicts: and
Quay will maintain systems in an effort to prevent damage to its clients’ interests through identified conflicts;
Should a Conflict of Interest be unavoidable, Quay will strive for appropriate and detailed disclosure to the client.

Conflicts of Interest

Within the activities of Quay, Conflicts of Interest may arise in relation to the services that we provide to our clients. In this respect, areas of concern where Conflicts of Interest may arise are: proprietary trading (derivatives, futures and equities), hedging activities, algorithm trading, brokerage (voice brokerage, DVP brokerage and electronic brokerage) and training. For the purposes of this document this policy applies to those Conflicts of Interest that may give rise to a material risk of damage to the interests of a Client.

Conflicts of Interest may take various forms. They may be:

Actual that is involving a direct conflict between current duties and / or interests;
Potential involving likely future conflicts; or
Perceived in circumstances creating the appearance of a conflict.

There are three types of conflicts:

Business-related conflicts of interest;
Personal conflicts of interest;
Conflicts between clients.

Examples of Potential Conflicts of Interest

Non-exhaustive examples of what may be considered typical conflicts of interest that may arise in relation to investment services provided by Quay are:

Quay may engage in business and trading activities for its own account and / or Client accounts whilst other Clients are active in relevant markets at the same time;
Holding confidential information on other clients which, if Quay can disclose or use, would affect the services provided to the Client;
Accepting gifts or entertainment that could be construed as conflicting with - Quay’s duties to its clients;
Quay employees pursuing activities outside Quay or maintaining personal relationships potentially detrimental to the client;

Personal relationships between Quay employees and clients and additional activities of Quay employees outside Quay that could give rise to a conflict of interest.

Managing Conflicts of Interest

Identification of potential Conflicts of Interest

In identifying Conflicts of Interest, Quay will consider all of the factual circumstances and Quay will take into account, inter alia, whether Quay:

Is likely to make a financial gain, or avoid a financial loss, at the expense of the Client;
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;
Has a financial or other incentive to favour the interest of a Client or group of Clients over the interests of another Client;
Carries on the same business as the Client; and / or
Receives or will receive from a person other than the Client and 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.
Quay also strives for awareness amongst all employees to disclose to the Compliance officer any circumstances that may give rise to an actual or potential Conflict of Interest, whereupon certain restrictions wil be imposed on the flow of information and / or the involvement of such person(s) from activities where this actual or potential Conflict of Interest has been identified.

Managing Conflicts of Interest

Quay has policies and procedures in place to prevent the occurrence of Conflicts of Interest and to manage actual and potential issues in this respect. These policies and procedures are set out in the Compliance Manual of Quay.

These documents address the identification and management of actual and potential Conflicts of Interest that may arise and, in particular, set ou procedures that are to be followed in connection with the proper handling of such situations.

In its management of Conflicts of Interest, Qauy has, amongst others, the following arrangements in place:

All our employees receive, and have to explicitly accept, the Compliance Manual of Quay, informing them on the importance Quay places on professionalism and integrity in serving its clients;
Quay has a Chinese Walls policy in place, dividing business units and IT-systems, in order to prevent the flow of information from one business unit to the other, enabling Quay and its employees to carry out business for clients without being influenced by information that is held in other parts of Quay;
Within Quay there is no direct link between the remuneration of employees in one business unit and the remuneration of, or revenues generated by, employees engaged in another business unit, where an actual or potential Conflict of Interest may arise in relation to the activities in those business units;
Quay has a strict policy in place to monitor that all employee’s personal activities, notably personal investments and outside business interests, are in compliance with the Quay Compliance Manual, which includes in its aims the prevention and management of actual and potential Conflicts of Interest.

Disclosure, monitoring and review

Should a Conflict of Interest be unavoidable, we will strive for appropriate and sufficiently detailed disclosure to the client, in order to enable the client to make an informed decision, or w will decide to terminate such activities that have created, or have the potential to create, the Conflict of Interest.

We will assess, on a regular basis, situations in our products and services that may give rise to actual or potential Conflicts of Interest and whether our policies and procedures for the management of such Conflicts of Interest are effective and adequate. If deemed necessary in the interest of our clients, we will implement changes to our policies and procedures in this respect.