Goldmill Markets Conflict of Interest Policy
- Introduction
Goldmill Markets (“Company”) is committed to providing its clients with transparent and ethical services. The Company recognizes the importance of managing conflicts of interest and has implemented this Conflict of Interest Policy (“Policy”) to identify, prevent, and manage potential conflicts of interest.
- Types of Conflicts of Interest
The following are examples of situations that may create conflicts of interest:
a. Personal interests of employees, directors, or related parties that conflict with the interests of clients;
b. Trading or investment strategies that benefit the Company at the expense of clients;
c. Incentives or remuneration structures that encourage employees or agents to act in their own interests rather than in the interests of clients;
d. Relationships with third-party service providers, such as brokers or liquidity providers, that may create a conflict of interest;
e. Insider trading or misuse of confidential information;
f. Any other situation that may create a conflict of interest.
- Identification and Prevention
The Company has implemented the following measures to identify and prevent conflicts of interest:
a. Regular training for employees on identifying and managing conflicts of interest;
b. Implementation of strict policies and procedures to manage conflicts of interest, including the use of information barriers and the segregation of duties;
c. Review of potential conflicts of interest in relation to new products, services, or business lines;
d. Regular review of existing relationships with third-party service providers to ensure that any potential conflicts of interest are identified and addressed;
e. Disclosure of any potential conflicts of interest to clients, where appropriate.
- Management of Conflicts of Interest
If a conflict of interest is identified, the Company will take the following steps to manage the conflict:
a. Disclosure of the conflict to the affected client(s);
b. Implementation of measures to mitigate the conflict, such as information barriers or the segregation of duties;
c. Review of the effectiveness of the measures taken to manage the conflict.
- Disclosure
The Company will disclose any potential conflicts of interest to clients, where appropriate, in a clear and concise manner. The disclosure will include information on the nature of the conflict, the measures taken to manage the conflict, and any potential impact on the client’s investment.
- Record Keeping
The Company will maintain records of all conflicts of interest identified and the measures taken to manage those conflicts. The records will be kept for a minimum of five years and will be made available to regulatory authorities upon request.
- Review
The Company will regularly review and update this Policy to ensure that it remains effective in identifying, preventing, and managing conflicts of interest.
- Conclusion
The Company is committed to managing conflicts of interest in a transparent and ethical manner. By implementing this Policy, the Company aims to ensure that its clients can have confidence in its services and that their interests are protected.
