Overview
A conflict of interest is a situation where the Firm or an employee, or other associate of the Firm has competing professional or personal interest, which may prevent services being provided to clients in an independent or impartial manner.
Pulp International Business Ltd FxPulp is committed to identifying, monitoring and managing all actual and potential conflicts of interest that can or may arise between us and our clients and any person directly or indirectly associated with the Firm. We are required to establish, implement and maintain a written Conflicts of Interest policy.
This document provides information in relation to the policies we have in place to manage conflicts of interest.
Identifying Conflicts
Pulp International Business Ltd FxPulp takes all reasonable steps to identify conflicts of interest that arise or may arise, in the course of the provision of services(s) to clients between:
- The firm, including managers, employees and appointed representatives;
- Any person directly or indirectly linked to the Firm; and
- Amongst clients of the Firm.
Types of Conflicts
Pulp International Business Ltd FxPulp will take into account whether the Firm, or relevant person, or a person directly or indirectly linked to the Firm;
- 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 service provided to a client;
- Has a financial or other incentive to favour the interest of a client or group of clients over the interests of another client;
- Receives, or will receive from a person, other than a client an inducement in relation to a service provided to a client, in the form of monies, goods or services, other than the standard commission or fee for that service.
Gifts and Inducements
In accordance with the rules of our regulator the Cyprus Securities and Exchange Commission (CySEC), we are prohibited from accepting a fee, commission or other non monetary benefit which is likely to conflict with the duty the Firm owes to its clients.
The Firm may receive non-monetary benefits from product providers or other third parties. Such benefits are typically of a modest nature and generally relate to the provision of literature, participation in seminars, training and hospitality. The provisions of such benefits are designed to enhance the quality of the services we provide to our clients.
We may occasionally receive gifts from clients a provider in recognition of services provided. We take care to ensure that these gifts are of a modest nature and do not create any obligations or debts.
Details of any gifts or inducements over the value of 250 (EUR) must be reported to the Compliance Department who in turn must record this in the relevant log.
Business Interest and Suitability
Occasions may arise where we or one of our other clients have some form of interest in business being transacted for you. If this happens or we come aware that our interests or those of one of our other clients conflicts with your interests, we will write to you and obtain your consent before we carry out your instructions, and detail the steps we will take to ensure fair treatment.
When we make personal recommendations to specific investments we are required to take reasonable steps to ensure that the recommendation is suitable for the clients needs and circumstances.
Outside Activities and other Potential Conflicts of Interest
Employees must never permit their personal interest to conflict with, or to appear to conflict with, the interests of the Firm. When faced with a situation involving a potential conflict of interest, ask yourself whether public disclosure of the matter could embarrass Pulp International Business Ltd FxPulp or you, or would lead an outside observer to believe a conflict of interest, including those in which you may have been placed inadvertently due to either business or personal relationship with customers, suppliers, business associates, or competitors of Pulp International Business Ltd FxPulp, or with other FxPulp employees Limited.
Disclosure of Conflicts of Interest
Where we identify that an actual or potential conflict of interest exists we will notify you in writing of that fact to enable you to make an informed decision about whether or not you wish to proceed.
Recording Conflicts of Interest
Pulp International Business Ltd FxPulp will keep and maintain a record of circumstances in which a conflict of interest may, arise, or has arisen, as a result of the activities carried out by the Firm.
Managing Conflicts
To ensure that Pulp International Business Ltd FxPulp manages conflicts of interest effectively, the Chief Executive Officer will have overall responsibility to enabling that the Firm identifies and manages any conflicts of interest appropriately effectively, and in line the with the by The Cyprus Securities and Exchange Commission (CySEC) Rules and guidance.
Staff Understanding
All of our employees are made aware of this policy to highlight and emphasize the importance of identifying and managing conflicts of interest.
Review
Our conflicts of interest policy is reviewed on a regular basis and at least on an annual basis.
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