Markets in Financial Instruments Directive
MiFID (Markets in Financial Instruments Directive) is a European Union law effective as of 1 November 2007, which provides a harmonized regulatory regime for investment services across the European Economic Area.

The main objectives of the Directive are to increase competition and client protection in investment services.

FxPulp activities and services are complied with MiFID requirements. All documentation and procedures are consistent with MiFID rules.

In accordance with MiFID, we are required to provide our clients and potential clients with a summary of its rules:

1. Client Categorization

The directive introduces a new client classification regime and distinguishes between three types of clients:

  1. Retail Clients are clients who are not categorized as Professional Clients nor Eligible Counterparties, and they have the highest level of protection.
  2. Professional Clients: clients classified as Professional are those who meet one of the following descriptions:

    • Investors who possess market knowledge and investment experience and whose main activity is to invest in financial instruments.
    • Authorized companies and entities that operate in the financial markets and not classified as Eligible Counterparties Legal entities such as Credit institutions, Insurance companies, Pension funds companies, etc
    • Large Undertakings meeting at least two of the following criteria:

      • A total balance sheet equal or exceeding 20,000,000 EUR
      • A total net turnover equal or exceeding 40,000,000 EUR
      • A total own capital equal or exceeding 2,000,000 EUR
    • Professional clients have a lower level of protection than Retail clients.
  3. Eligible Counterparties are professional clients or legal entities who provide investment services that involve the reception and transmission or the execution of orders. Clients under this category have the lowest level of protection.
Clients are allowed to request to be reclassified in writing, according to the specifications, conditions, and procedures of MiFID.

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2. Best Execution and Order Handling
An investment firm must take all reasonable steps to obtain the best possible result for their clients taking into account price, costs, speed of execution, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of the order.

3. Complaints Handling
An investment firm must deal with any expression of dissatisfaction about any financial services activity provided or withheld by the Company. Complaints could be made orally, in writing, by e-mail or by telephone; and they will be handled properly, regardless to the subject of the complaint.

Complaints will be forwarded to the Back Office Department, and the complainant shall be contacted within 24 hours and will receive a response within 48 hours, or details of how the complaint will be handled and when a final response will be given.

All actions taken to handle complaints will be documented by the responsible officer, with details, and dates in a Complaint Form as below:


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4. Dealing with Conflicts of Interests
An investment firm is committed to act honestly, fairly and professionally and in the best interests of its clients and to comply, with the principles set out in the MiFID legislation when providing investment services. It is required also to take all necessary measures and procedures to detect and avoid any conflict of interest between the firm and its clients.

The below mentioned is a summary of our policy and procedures for handling and managing potential conflicts of interests.

  • Identifying conflicts of interest, with reference to the related investment services, and circumstances that may result in such conflicts.

    In order to identify the types of conflict of interest that may arise in the course of providing investment services, the company takes into account whether the company or any relevant person is in the following situations:
  1. The Company or that person is likely to make a financial gain, or avoid a financial loss, at the expense of the Client.
  2. The Company or that 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.
  3. The Company or that person has a financial or other incentive to favor the interest of another Client or group of Clients over the interests of the Client.
  4. The Company or that person carries on the same business as the Client.
  5. The Company or that 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.
  • Managing conflicts of interest through internal policies, effective procedures and measures, as summarized below:
  1. Effective procedures to prevent or control the exchange of information between relevant persons engaged in activities that may cause a conflict of interest where the exchange of that information may harm the interests of clients.
  2. 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.
  3. The removal of any direct link between the remuneration of relevant persons 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.
  4. Measures to prevent or limit any person from exercising inappropriate influence over the way in which a relevant person carries out investment services or activities.
  5. Measures to prevent or control the simultaneous or sequential involvement of a relevant person in separate investment or ancillary services or activities where such involvement may impair the proper management of conflicts of interest.

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5. Organizational Requirements
MiFID also specifies strict requirements and procedures governing the internal and business organization of financial services providers which involve compliance, risk management, internal audit, outsourcing, and transactions reported to the supervisory authority.