Ornatefx Ltd. (“OrnateFX”, “we”) is required to take all reasonable steps to identify, prevent and manage conflicts of interest that arise between OrnateFX and its clients, or between two or more of its clients, in the course of providing services. This document is a summary of our Conflicts of Interest Policy.
Introduction
A conflict of interest exists where the interests of OrnateFX (or one of its associated firms, employees, or agents) and the interests of a client diverge, or where the interests of two or more clients diverge, such that there is a risk of damage to a client's interest.
Identifying conflicts
For each line of business we operate, we ask whether OrnateFX:
- Is likely to make a financial gain, or avoid a financial loss, at the expense of a client.
- Has an interest in the outcome of a service or transaction that is distinct from the client's interest in that outcome.
- Has a financial or other incentive to favour the interests of one client over another.
- Carries on the same business as a client.
- Receives or will receive an inducement from a person other than the client in relation to a service provided to the client.
Examples of conflicts we consider
- Principal dealing. Because we act as principal to client trades, we have a direct economic interest in client outcomes. Our trades against a client are managed via documented risk-warehousing and hedging policies.
- Affiliated providers. Where we use an affiliated entity as a payment processor, liquidity venue, or service provider, the commercial arrangement is on arms-length terms and is reviewed annually.
- Partner rebates. Introducing brokers and affiliates may receive per-trade rebates, which could in principle create an incentive to over-trade. Rebate structures are disclosed and the IB's communications with clients are subject to our marketing-compliance review.
- Research & market commentary. Our research desk may comment on markets in which OrnateFX maintains a principal position. Commentary is factual and informational, not investment advice.
- Employee personal-account trading. Employees may trade markets we offer. See section 06.
How we manage them
Measures include (but are not limited to):
- Information barriers between front-office, risk and research functions.
- Separate reporting lines for compliance and internal audit.
- Remuneration policies that avoid direct linkage between compliance-sensitive activity and individual compensation.
- Pre-trade and post-trade monitoring by an independent risk function.
- Mandatory training on conflicts for all front-office and partner-desk staff.
- A Conflicts Register maintained by Compliance and reviewed periodically.
Inducements & rebates
We do not pay or receive any fee or commission, or provide or receive any non-monetary benefit, in connection with the provision of an investment service to a client, except where (a) the fee or benefit is designed to enhance the quality of the service to the client, (b) it does not impair compliance with our duty to act in the best interests of the client, and (c) its existence, nature and amount is clearly disclosed to the client.
Personal-account dealing
Employees with access to material non-public information are subject to a Personal Account Dealing Policy that requires pre-clearance of trades in restricted instruments and holding-period requirements. Breaches are subject to disciplinary action.
Disclosure to clients
Where the organisational and administrative arrangements made by OrnateFX to manage a conflict are not sufficient to ensure with reasonable confidence that the risks of damage to the interests of the client will be prevented, we will clearly disclose the general nature and sources of the conflict to the client before undertaking the relevant business, so that the client can make an informed decision.
Review of this policy
This policy is reviewed at least annually and following any material change in OrnateFX's business model, services, or regulatory environment. The latest version is the version published on this page.
Contact
For questions about this policy, contact support@ornatefx.com.