Conflict of Interest
The scope of the Policy adopted by Cryptos Fund Trading™ consists of identifying and managing any Conflicts of Interest that may arise between Cryptos Fund Trading™ and its clients and to comply with all requirements of the applicable laws.
Cryptos Fund Trading™ establishes, implements, and maintains a Policy on Conflicts of Interest and provides information regarding the adequate management of any Conflicts of Interest between itself, including its managers and employees and/or any associate, affiliate or subsidiary, as well as any person directly or indirectly linked to Cryptos Fund Trading™ (the “Related Persons”), and its clients that arise in the course of providing its services.
- Identification of Conflict of Interest
Situations in which Conflicts of Interest can occur include cases where:
- CryptosFundTrading™ or a Related Person is likely to make a financial gain or avoid a financial loss, at the expense of the client.
- CryptosFundTrading™ or a Related Person has an interest in the outcome of a service provided to the client, or of the transaction carried out on behalf of the client, which is different from the client’s interest in that outcome.
- CryptosFundTrading™ or a Related Person has financial or other incentives to favor the interest of another client or group of clients over the interests of the client.
- CryptosFundTrading™ or a Related 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 money, goods, or services, other than the standard commission or fee for that service.
- A conflict of interest may arise, between the following parties:
- Between the client and CryptosFundTrading™;
- Between and CryptosFundTrading™ and its Related Persons;
- Between a client of CryptosFundTrading™ and the Related Persons of CryptosFundTrading™.
- Adopted Measures
The following measures have been adopted by Cryptos Fund Trading™ to prevent any conflicts of interest which might arise while Cryptos Fund Trading™ conducts its business:
- Cryptos Fund Trading™ undertakes to carry out ongoing monitoring of its business activities to ensure that its internal control is adequate.
- Cryptos Fund Trading™ undertakes effective procedures to prevent or control the exchange of information between the Related Persons engaged in activities involving a risk of a Conflict of Interest if the exchange of that information may harm the interests of one or more clients.
- CryptosFundTrading™ takes measures to prevent or limit any person from exercising inappropriate influence over the way in which the Related Persons carry out its portfolio management services or ancillary services.
- CryptosFundTrading™ ensures segregation of duties that may give rise to conflicts of interest if carried on by the same individual.
- When Cryptos Fund Trading™ executes an order for a client it shall not give any preferential treatment to that client to the detriment of other clients or disclose the details of a client’s order to another client.
- CryptosFundTrading™ executes all orders electronically, in accordance with policies that comply with relevant rules and regulations in relation to transactions which are executed for the account of the clients.
- Cryptos Fund Trading™’s procedures ensure that Cryptos Fund Trading™’ and its Related Persons shall not misuse the information provided to them in relation to the portfolio management services carried out on behalf of clients.
- All Related Persons of Cryptos Fund Trading™ are prohibited from dealing on personal accounts to avoid any actual or possible conflicts of interest.
- All Related Persons of CryptosFundTrading™ are prohibited from accepting any inducements from any person, which are likely to conflict to a material extent with any duty which CryptosFundTrading™ and/or its Related Persons owe in connection with the fair conduct of the portfolio management services
- Disclosure of Conflict of Interest
- Prior to carrying out a transaction or providing a portfolio management service or an ancillary service to a client, Cryptos Fund Trading™ shall disclose any actual or potential Conflict of Interest. Conflicts of Interest shall be disclosed in sufficient time and in lasting form.
- Any Conflict of Interest shall be reported to the manager of Cryptos Fund Trading™, who shall be responsible for keeping records of all Conflicts of Interest.
For questions/comments regarding the Conflict of Interest Policy, please contact us.