Financial Spreads Conflicts of Interest Policy

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Financial Spreads - Conflicts of Interest Policy

Financial Spreads is a trading name of Clear Investor Ltd which is an appointed representative of Finsa Europe Limited. Finsa Europe Limited is a company registered in England and Wales ("Financial Spreads", "we", "us") and authorised and regulated by the Financial Conduct Authority ("FCA") with firm number 525164.


We aim to identify and prevent any conflicts of interest which may occur between us and our clients, or between one client and another, to avoid possible adverse effects which may arise.

This policy applies to all directors (executive and non-executive), officers, employees and consultants of Financial Spreads and refers to dealings with all of our clients.


The FCA has detailed requirements relating to the management of conflicts of interest, which are primarily found in the FCA Senior Management Arrangements Systems and Controls sourcebook, section 10.

Our requirements as a firm under these include: TYPES

We have identified the types of conflicts that may occur and which carry a material risk of damage to the interests of a client. These include, but are not limited to, when we or any person directly or indirectly linked to us: OPERATIONS

We have implemented the systems and procedures referred to below, to minimize the potential causes for conflicts of interest, to manage all conflicts of interest and where possible avoid material conflicts of interest. RELATED CORPORATE PARTIES

As part of our business model and regulatory structuring, we utilise the services of one or more related corporate parties in order to provide a diverse range of financial services to a broad range of clients and counterparties and circumstances may arise in which we or our group companies (as defined in s 474 of the Companies Act 2006) may have a material interest in a transaction with or for you or where a conflict of interest may arise between your interests and those of other clients or counterparties of ourselves or our Group.


As part of our business model we provide similar business to business financial services of those offered by Financial Spreads to its clients to the clients of other of our commercial partners other than Financial Spreads. These financial services offered may be conflict with those of Financial Spreads clients, although we do not normally envision that this would in effect mean anything other than ordinary merchant competition in the marketplace for financial services. Should we perceive any disclosable conflict in this regard we would specify this and update this policy.

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