CONFLICTS OF INTEREST POLICY


The Finexo website is owned by Safecap Investments Ltd (“Safecap”) an investment firm regulated by the Cyprus Securities and Exchange Commission with license number CIF 092/08. Safecap is required, in accordance with the European Union’s Markets in Financial Instruments Directive ("MiFID") and in accordance with the Investment Services Activities and Regulated Market Law 2007 in Cyprus to provide information on the Company’s policy on conflicts of interest and its approach to managing any conflicts of interest fairly: both between Finexo our directors, employees and our clients, and between your interests and those of other clients.

DEFINITION OF CONFLICT OF INTEREST

Safecap defines a conflict of interest as any situation where either Safecap or an individual is in a position to exploit a professional or official capacity in some way for either corporate or personal benefit.

CONFLICT OF INTEREST MEASURES

Extensive measures have been adopted by Safecap to prevent, control and manage the exchange of information between relevant persons engaged in activities involving a risk of a conflict of interest. For example, Safecap has removed any direct link between the remuneration of relevant persons principally engaged with one activity and the remuneration of different relevant persons principally engaged in another activity.

DISCLOSURE OF CONFLICT OF INTEREST

When the measures taken by Safecap to manage conflicts of interest are not sufficient to ensure, with reasonable confidence, that the risk of damage to clients’ interests will be prevented, Safecap will disclose the conflicts of interest to the client in order to prevent a risk of damage to clients’ interests. Prior to carrying out a transaction or providing an investment or an ancillary service to a client, the Company must disclose any actual or potential conflict of interest. The disclosure will be in sufficient time, in a durable means.

RECORD KEEPING

Safecap maintains a record, which is regularly updated, of the kinds of investments and ancillary services or investment activities carried out by Safecap or on its behalf in which a conflict of interest entailing a material risk of damage to the interests of one or more clients has arisen.