Conflicts of

Interest Policy
 Conflicts of Interest Policy
Table of Contents

Conflicts of Interest Policy

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1. INTRODUCTION
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2. IDENTIFICATION OF POTENTIAL CONFLICTS OF INTEREST

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3. MANAGING CONFLICTS OF INTEREST

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4. DISCLOSURE OF CONFLICTS OF INTEREST 9

1. INTRODUCTION

Capital Com Online Investments Ltd (hereafter the “Company”) is an

incorporated company in the form of International Business Company with
company number 209236B and registered at the address The Bahamas
Financial Centre, 3rd Floor, Shirley & Charlotte Streets, P.O. Box N-4865,
Nassau, Bahamas. The Company is authorized and regulated by the
Securities Commission of the Bahamas (the "SCB") under the license number
SIA/F245.

The purpose of this Conflicts of Interest Policy (the “Policy”) is to outline a

suitable approach and response to the identification and management of
conflicts of interest. The Company will take all reasonable steps to identify
conflicts of interest between itself, including its managers, employees or any
person directly or indirectly linked to the Company by control and its clients
or between one client and another that arise in the course of providing any
investment services.

The Company maintains and operates effective organizational and

administrative arrangements to prevent and manage conflicts of interest
that may arise during the provision of any investment services, from
adversely affecting the interests of its clients. In case where, the
aforementioned arrangements are not sufficient to ensure, with reasonable
confidence, that the risks of damage to the interests of the clients will be
prevented, the Company shall clearly proceed with the disclosure of such
conflict. The said disclosure shall be done in a durable medium indicating
the general nature and source of conflicts of interest, the risks to the client
with sufficient details so as to allow the client to take an informed decision
with regards to its investment as well as the steps taken to mitigate such
risks.

The Company has the right to amend the current Policy at its discretion and
at any time it considers is suitable and appropriate. The Company shall
review and amend ,as necessary, the current policy at least on an annual
basis to take account of changes to operations or practices and, further, to
make sure it remains appropriate to any changes in law, technology and the
general business environment. In case of any amendment, the Company
shall notify the Financial Services Authority prior to any changes made
within the Policy.

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2. IDENTIFICATION OF POTENTIAL CONFLICTS OF INTEREST

To adequately manage conflicts of interest, the Company shall identify all

relevant conflicts timeously. The Company will employ different mechanisms
to ensure that all conflicts are identified.

The Company shall identify all conflicts of interest, their severity and
document controls to mitigate the conflicts. It is not possible to list all
situations which could constitute a conflict. The facts of each situation will
determine whether the interest in question is such as to bring it within the
area of potential conflict.

All employees, including management, will be responsible for identifying

specific instances of conflict and required to notify the Compliance function
of any conflicts they become aware of. The Compliance Officer (the "CO")
will assess the implications of the conflict and how the conflict should be
managed in conjunction with the board. In the case where a specific
incident to be reported concerns the CO, the notification shall be made to
the Company’s Representative Officer.

For the purposes of identifying the types of conflicts of interest that arise in
the course of providing investment services and whose existence may
damage the interests of a client, the Company takes into account, by way
of minimum criteria, the question of whether the Company or a relevant
person, or a person directly or indirectly linked by control to the Company, is
in any of the following situations, whether as a result of providing investment
services or activities:
The Company or a relevant person is likely to make a financial gain, or
avoid a financial loss, at the expense of the client
The Company or a relevant person 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
The Company or a relevant person has a financial or other incentive to
favour the interest of another client or group of clients over the interests
of the client
The Company or a relevant person carries on the same business as the
client
The Company or a relevant person receives or will receive from a person
other than the client, an 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;

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For the purpose of this Policy, a “relevant person”, in relation to the

Company means any of the following:

a director, partner or equivalent or manager of the Company

an employee of the Company , as well as any other natural person

whose services are placed at the disposal and under the control of the

Company who is involved in the provision of investment services and

activities

a natural person who is directly involved in the provision of services to

the Company under an outsourcing arrangement for the purpose of the

provision by the Company of investment services and activities.

3. MANAGING CONFLICTS OF INTEREST

The Company has established suitable and adequate internal procedures

for minimising any potential conflicts of interest. The Company maintains a

compliance department that is an independent unit within the Company.

Among the duties of the CO is to monitor any possible deviation from the

Company’s internal policies and procedures as well as identifying and

managing any possible conflicts of interest. Once a conflict has been

identified it needs to be appropriately and adequately managed. The

Compliance function will assess each conflict and determine if the conflict is

actual or perceived and what the value of the conflict or exposure is and

the potential reputational risk. Compliance will then decide whether it is

viable to go ahead with the transaction or if the conflict is too severe. If

Compliance decides that the particular conflict can be mitigated, then

controls to manage the conflict should be put in place and documented.

The Company will manage conflicts of interest fairly, between itself and its

clients, between itself and its employees and between its customers and will

organise and control their internal affairs responsibly and effectively.

The Company and its employees should act as per the principle of placing

clients’ interests before self-interests and Company’s interests in order to

avoid conflicts of interest in the fulfillment of professional activities on the

securities market. To ensure client’s fair treatment, the Company will

introduce the following procedures:

The Company shall avoid any conflict of interest with clients and, where

such a conflict unavoidably arises, ensure fair treatment to the client by

complete disclosure or by declining to act.

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Employees are also prohibited to keep investor accounts in other Brokers
without Company’s prior authorization and are obliged to bring this to
Company’s attention. They are also obliged to authorize the Company
to directly request transaction reports from the other Brokers
If the Company has a material interest in a transaction to be entered
into with or for a client, or a relationship which gives rise to a conflict of
interest in relation to the transaction, the Company shall not knowingly
either advise, or deal in the exercise of discretion, in relation to that
transaction. The only exception is when the Company has fairly
disclosed that material interest or relationship, as the case may be, to
the client or the client has taken reasonable steps to ensure that neither
the material interest nor relationship adversely affect the interests of the
client
There is a clear distinction between the different departments’
operations as these are described in the Company’s IOM
The Company shall be informed promptly of any personal transaction
entered into by a relevant person, either by notification of that
transaction or by other procedures enabling the Company to identify
such transactions. In the case of outsourcing arrangements, the
Company shall ensure that the Company to which the activity is
outsourced maintains a record of personal transactions entered into by
any relevant person and provides that information to the Company
promptly on request
A person shall be replaced by another person in his/her duties only prior
consent of the CO and approval by the Representative Officer. Such a
consent will be given by the CO after all issues of possible conflict of
interest have been reviewed
The security features of the Company’s software prevents unauthorized
access to sensitive information in order to benefit the Company over its
clients or one client over another
The Company’s employees are prohibited from investing in securities for
which they have access to non-public or confidential information
Transactions by the Company’s employees are neither performed nor
executed by themselves, but by another member of staff of the
Company concerning accounts opened with the Company
A record shall be kept of the personal transaction notified to the
Company or identified by it, including any authorisation or prohibition in
connection with such a transaction.

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 The Company must take reasonable steps to ensure that neither it nor
any of its employees or agents either offers or gives, or solicits or
accepts, any inducement that is likely to conflict with any duties owed to
its clients
No employee shall either knowingly or recklessly make a statement,
promise or forecast that is misleading, false or deceptive to any
customer or conceal material facts at any time.
More specifically, the Company states some of the policies and procedures
that it has implemented for managing possible conflicts of interest below:
Effective procedures to prevent or limit any person from exercising
inappropriate influence over the way in which a relevant person carries
out investment services or activities
The separate supervision of relevant persons whose principal functions
involve carrying out activities on behalf of, or providing services to,
clients whose interests may conflict, or who otherwise represent different
interests that may conflict, including those of the Company
Measures to prevent or control the simultaneous or sequential
involvement of a relevant person in separate investment services or
activities where such involvement may impair the proper management
of the conflicts of interest
The removal of any direct link between the remuneration of relevant
persons principally engaged in one activity and the remuneration of, or
revenues generated by, different relevant persons principally engaged in
another activity, where a conflict of interest may arise in relation to those
activities
Measures to prevent or control the exchange of information between
relevant persons engaged in activities involving a risk of a conflict of
interest where the exchange of that information may harm the interests
of one or more clients.
The procedures followed and measures adopted in the Policy include the
following, as are necessary and appropriate for the Company to ensure the
requisite degree of independence:
No relevant person may purchase or sell a security or cause the
purchase or sale of a security for any account while in possession of
inside information relating to that security
No relevant person may recommend or solicit the purchase or sale of any
security while in possession of inside information relating to that security.

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 No relevant person may purchase or sell or cause the purchase or sale of
a security for an employee or employee-related account or a proprietary
account of the Company or an account over which an employee
exercises investment discretion, while in possession of proprietary
information concerning a contemplated block transaction in the security
or for a customer account when such customer has been provided such
information by any relevant person
Procedures set for regular review and monitoring of the execution
arrangements with the execution venue, hedging/ liquidity or price
providers as well as on a continuous basis
Procedures in regards to the monitoring of access to electronic data
Relevant persons engaged in research activities should not discuss
unreleased information, opinions, recommendations, or research analysis
in progress with Company associated persons engaged in sales
activities, or any person within or outside the Company who does not
have a valid business need to know the information
Establishment of an ongoing monitoring program based on which regular
checks are conducted for the assessment of the Company’s procedures,
policies and internal controls
The Company may distribute marketing communication to its clients,
only if the said communication is reviewed and approved by the CO prior
to distribution. The CO also ensures that such communication has the
appropriate disclosure statement as well as meeting the relevant
definition of marketing communication
The four-eye principle is implemented to avoid any abuse of position
In order to minimize the relevant person’s own transactions, personal
account dealing restrictions are in place.

The Company is committed to having an effective and appropriate

compliance culture to enable it to deal with any new potential conflicts of
interest which may arise in the future. The Company’s employees are
therefore required to monitor any new circumstances giving rise to potential
conflicts of interest and to implement appropriate measures to address
these.

For the purpose of this Policy, a “personal transaction” is considered a trade

in a financial instrument effected by or on behalf of a relevant person, where
at least one of the following criteria are met:
the relevant person is acting outside the scope of the activities he
carries out in his professional capacity;

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 the trade is carried out for the account of any of the following persons:
the relevant person
any person with whom he has a family relationship, or with whom he
has close links
a person in respect of whom the relevant person has a direct or
indirect material interest in the outcome of the trade, other than
obtaining a fee or commission for the execution of the trade.
Segregation of Company’s assets from clients’ assets
The Company shall maintain separate accounting records between its own
assets and those of its clients to facilitate the protection of clients’ assets
and the prevention of the use of customer assets by the Company or by
other third parties so as to minimise the risk of the loss or diminution of client
assets, or of rights in connection with those assets, as a result of misuse of
the assets, fraud, poor administration, inadequate record-keeping or
negligence. In addition, the Company has legally secure segregation of
clients’ assets from the Company’s assets in case the Company becomes
bankrupt. For this purpose, the Company maintains separate books and
accounting records for each client.
Forbidden Business Practices
The Company shall prohibit those business practices which in the regular
course of events might give rise to conflicts of interest. The following
business practices shall indicatively be forbidden:
The provision to clients of investment services for the purpose of
influencing the price of financial instruments for the benefit of the
Company or for the benefit of any relevant persons, or of Company’s
clients in general, especially with regard to transactions that the
Company or relevant persons intend to carry out prior to or after the
provision of the service
The use by the Company or by its relevant persons of information
regarding client transactions, for the benefit of the Company, and the
disclosure of such information to third parties
Dealing by the Company itself or by any relevant persons in financial
instruments in respect of which the Company has drawn analysis reports
or has made research findings prior to the publication of the respective
reports and findings
The preferential treatment of relevant persons to the detriment of its
clients in the course of the provision to them of investment services.

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 The carrying out of transactions by relevant persons for their own

account or for the account of persons related to them on the basis of

confidential information that the above persons have obtained in the

course of their employment with the Company.

All employees must be aware of the above forbidden business practices,

and shall have the responsibility of informing the CO immediately in case

they monitor any violation of the above provisions.

Should you have any questions in relation to the Company’s Conflicts of

Interest Policy, please contact the Compliance department of the Company.

4. DISCLOSURE OF CONFLICTS OF INTEREST

In case where, the organisational and administrative arrangements

established by the Company to prevent or manage a conflict are not

sufficient to ensure, with reasonable confidence, that the risks of damage to

the interests of the clients will be prevented, the Company shall clearly

proceed with the disclosure of such conflict.

Prior to carry out a transaction or provide an investment service to a client,

the Company should disclose any actual or potential conflict of interest to

the client provided that the measures taken by the Company are not

sufficient to ensure that the risks of damage to the interests of the client will

be avoided.

The above disclosure shall include sufficient detail, taking into account the

nature of the client, source of conflicts of interest, the risks to the client to

enable him to take an informed decision with respect to the investment

service in the context of which the conflict of interest arises. The Company

reserves the right not to proceed with the transaction or matter giving rise

to the conflict if such disclosure is not sufficient to manage a conflict.

The Management and employees of the Company should disclose the

following information to the CO:

Opening and closing personal accounts at any other Broker for own

investments purpose

All personal transactions performed. Notification should be provided

within 24 hour

Securities held by the employe

Transactions executed by the Company in which the employee may

have an interest or a conflict