EXECUTIVE SUMMARY 

 

CXM Prime Ltd (“CXM Prime”) CXM Prime Office No. 518 15 St Helen's Place, London, England, EC3A 6DQ,  Registered in England and Wales, Company Number: 13407617 is authorised and regulated by the Financial Conduct Authority (“FCA”) FRN: 966753 and is, therefore, required to conduct its business in line with the FCA’s Principles for Businesses (“PRIN”). In relation to conflicts of interest, the following principles are of particular significance: 

 

• Principle 1: Integrity – a firm must conduct its business with integrity. 

• Principle 6: Customers’ Interest – a firm must pay due regard to the interests of its customers and treat them fairly. 

• Principle 8: Conflicts of Interest - A firm must manage conflicts of interest fairly, both between itself and its customers and between a customer and another client. 

 

Specific requirements relating to conflicts of interest are set out within the Senior Management Arrangements, Systems and Controls (SYSC) section of the FCA handbook and, in particular, in SYSC 10.  

 

A conflict of interest is a situation in which someone in a position of authority or trust has competing professional or personal interests. Such competing interests can make it difficult for individuals to fulfil their duties impartially. A conflict of interest may exist even if no unethical or improper act results from it.    

 

This Policy defines the requirements for identification, reporting and management of actual or potential conflicts of interest while working for, or on behalf of, CXM Prime Ltd. This Policy forms part of CXM Prime’s wider conduct risk framework.  

 

The identification and management of conflicts of interest continues to be an area of focus for the regulator. Failure to implement appropriate systems and controls could expose CXM Prime to regulatory sanctions by the FCA, including fines, restriction of business or removal of regulatory permissions to conduct business.  Moreover, an increasing number of countries are adopting laws to prohibit bribery even if it takes place outside of their borders. Under the UK Bribery Act, a bribery offence can be committed by provision of a financial or ‘other advantage’ to an individual. Inappropriate and conflicted personal/business relationships could, under certain circumstances, amount to an advantage which could lead to an individual being accused of bribery. 

 

Examples of conflicts of interest that are inherent within CXM Prime’s business model and the mitigating systems and controls are provided within this policy.  

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OWNERSHIP  

 

Owning Function: Compliance. 

Policy Owner: Head of Compliance.   

 

The Head of Compliance is responsible for ensuring that the systems, controls and procedures applied by CXM Prime Limited are appropriate to identify and manage conflicts of interest, with approval from senior management and the Board of Directors. 

 

OBJECTIVES 

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The objective of this policy is to ensure that CXM Prime has appropriate systems and controls to enable it to take all reasonable steps to identify and prevent or manage, and where effective management cannot be achieved, to disclose, conflicts of interest arising out of the services it provides between:  

 

(1)  the firm, including its managers, employees and appointed representatives, or any person directly or indirectly linked to them by control, and a client of the firm; or 

(2)  one client of the firm and another client.  

 

SCOPE & APPLICATION  

 

This is a personal conduct policy which forms part of CXM Prime’s wider conduct risk framework. Compliance with this policy is mandatory for all employees, consultants and other personnel working for the company. 

 

For CXM Prime employees, breach of this policy may result in disciplinary action, up to and including dismissal. Breach of this policy by any individual who is not an employee may result in other appropriate action being taken in relation to the individual and/or the business which supplies services to CXM Prime, including termination of the relevant contract(s). 

 

This policy is not contractual. CXM Prime reserves the right to amend, suspend or terminate this policy. 

 

References to employees include any person falling within the scope of this policy unless specified otherwise. 

 

LINKS TO OTHER CONTROLS, POLICIES OR EXTERNAL REQUIREMENTS 

 

This policy is pursuant to, and in compliance with, the following regulations and legislations:  

  

• The EU Markets in Financial Instruments Regulation (MiFIR) and Directive (MiFID);   

• Financial Conduct Authority’s (FCA) Systems and Controls (SYSC) 10 sourcebook; and   

• Principle 8 of the FCA Principles for Business states that “a firm must manage conflicts of interest fairly, both between itself and its customers and between a customer and another client”. 

 

This policy should be read in conjunction with the following documents and guidance: 

 

• Gifts and Hospitality Policy; 

• Anti-Bribery and Corruption Policy; 

• Personal Account Dealing Policy; 

• Bribery Act 2010 including Ministry of Justice guidance; and 

• Financial Conduct Authority “Financial crime: a guide for firms”.   

 

PERIODIC REVIEW

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This policy will be reviewed by the Head of Compliance and approved by the Board of Directors on a regular basis or more frequently to reflect changes in regulatory or legal obligations or business strategy. 

 

GENERAL PRINCIPLES

 

CXM Prime Ltd will take all appropriate steps to identify conflicts of interests between itself (including managers, employees, or any person directly or indirectly linked by control) and any client; or between one client and another that arise or may arise in the course of providing any service to clients in the course of carrying on regulated activities or ancillary services. 

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For the purposes of identifying conflicts of interest, CXM Prime will take into account, as a minimum, whether CXM Prime or a person who is within the scope of this policy, or a person directly or indirectly linked by control to CXM Prime:

 

• is likely to make a financial gain, or avoid a financial loss, at the expense of the client; 

• 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; 

• has a financial or other incentive to favour the interest of another client or group of clients over the interests of the client; 

• carries on the same business as the client; or 

• receives or will receive from a person other than the client a benefit 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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Effective organisational and administrative arrangements will be maintained and operated with a view to taking appropriate steps to prevent conflicts of interest from adversely affecting the interests of its clients.  

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In relation to the identification and management of conflicts of interest CXM Prime will take into account: 

• the risk that a conflict of interest may adversely affect the interests of a client, a group of clients or all of our clients; 

• the nature, scale and complexity of its business in the UK and internationally; and 

• the nature and range of products and services offered in the course of that business. 

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Although CXM Prime is committed to maintaining effective procedures to identify and prevent conflicts of interest, it will also work to prevent such conflicts of interest from arising. CXM Prime will ensure that staff receive training which will enable them to identify situations which might lead to conflicts of interest arising and determine the appropriate actions to take. 

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IDENTIFYING CONFLICTS OF INTEREST 

 

Identification of personal conflicts of interest 

 

A conflict of interest arises when the personal, social, financial or political interest of an employee or a person falling within the scope of this policy may influence or appear to influence their loyalty to, or objective exercise of their duties for, CXM Prime.  

 

A good test to determine whether a conflict exists is the “trust test”. Could others reasonably be expected to trust your judgement on a particular matter if they had knowledge of your personal relationship, interest or circumstances? 

 

You should always be able to satisfy yourself that: 

 

• The interests of CXM Prime and its clients are paramount when business and commercial activities are being agreed or carried out by you and those around you. 

• CXM Prime resources are not used to support or benefit your personal activities or those of your relatives, business associates or friends. 

• Business decisions are not influenced by friendship, business associations or family connections. 

• You do not allow, or appear to allow, a personal relationship to unduly influence your decision making or judgement. 

• Your giving or accepting of any gift or hospitality will not create the perception that you might not exercise your judgment independently and in the best interests of CXM Prime and its clients.  

 

The following are some common examples which may lead to a conflict of interest and require a declaration to the Head of Compliance.  

 

• You or a family member, business associate or close friend have an investment or other economic interest in: 

• a partner or business in which CXM Prime has an interest (or a business which you are aware CXM Prime is actively considering making an investment in), or; 

• a customer or supplier of CXM Prime and you are involved with the selection, evaluation or management of CXM Prime’s relationship with any of these. 

• You have a second job. 

• Your CXM Prime Limited job involves you carrying out CXM Prime Limited business transactions with a family member, business associate or a close friend. 

• You are responsible for hiring, supervising, managing, career planning or setting the employment terms and conditions of any relative, business associate or close friend. 

• You have a close personal relationship, of any nature, with someone who works with or for you, within your area of business or where you are able to influence or control their salary, bonus or employment terms, conditions or career development. 

• You have a close personal relationship with someone who works for a client or supplier organisation, or who is a client or supplier themselves or a competitor. 

 

A personal relationship should be considered in the context of the “trust test” - could others reasonably be expected to trust your judgement on a particular matter if they had knowledge of your personal relationship, interest or circumstances? 

 

Where a person falling within the scope of this policy is unsure as to whether a potential conflict of interest exists, he/she should seek guidance immediately from the Head of Compliance.  

 

 

Identification of business conflicts of interest 

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A number of conflicts of interest specific to CXM Prime’s business activities have been identified and are detailed in this section of the policy along with the supporting management arrangements.    

 

Principal trading 

CXM Prime trades as principal in bilateral transactions with its customers. It makes its own prices and executes client orders on a non-advised basis. CXM Prime does not engage in proprietary trading or enter into speculative positions in the market.  

 

Best execution

CXM Prime manages potential conflicts of interest arising out of the trading activities (for example, price slippage; liquidity issues; expiry of contracts) of clients by operating an Order Execution Policy to deliver “best execution” for its clients. This policy is available separately and best execution is subject to ongoing monitoring. 

 

Outside business interests

A conflict of interest may arise where an employee or person falling within the scope of this policy has a direct, or indirect, interest in an outside business activity.  This may be where the employee has a connection, or where the employee’s family has a connection. The connection may be from a directorship, significant shareholding, employment or consultancy. 
 
No employee may engage in any other employment or provide services to any other person unless specifically approved in writing in advance by the CEO and the Head of Compliance. Outside directorships (including non-executive directorships) must be approved in advance by the CEO and the Head of Compliance. It is not permissible for an employee to participate or be interested in any outside business interests which may interfere with the employee’s work or which are likely to put the employee in a position where he may have a conflict of interest with the firm or its clients.   

 

CXM Prime’s new joiner procedure requires disclosure of any connection which could or could be seen to have the effect of compromising the employee’s judgment.  All material disclosures are escalated to the Head of Compliance to determine whether or not that connection may continue. All employees are required to provide an annual attestation to confirm that they have not acquired any outside business interests or to notify the Head of Compliance immediately upon a change in circumstances in relation to outside business interests.    

 

Intra group directorships 

Where a senior manager of CXM Prime holds a directorship with another member of the CXM Prime Limited group of companies, a conflict of interest may arise out of the responsibilities of that person to the respective companies. To manage and mitigate intra-group conflicts of interest, all multi-directorships within the group shall be disclosed. In addition, for all material strategic and operational decisions, records are maintained via the minutes of the relevant forums to evidence that the potential for a conflict of interest was identified and to demonstrate how the conflict was managed. 

 

Personal account dealing

Included within CXM Prime’s controls relating to conflicts of interest is the requirement for employees to adhere to the firm’s Personal Account Dealing (“PA Dealing”) procedures. 

   

Whilst PA Dealing procedures are set out in a separate policy, employees must not deal in any form of shares, securities, investments or instruments while in possession of price or commercially sensitive information. This would be Insider Dealing, the penalties for which are severe and can include custodial sentences.  

  

CXM Prime’s PA Dealing procedures are designed to reduce the risk to employees and the firm and also to offer protection to clients, by prohibiting any transactions that constitute Market Abuse or where a customer’s interest could be adversely affected. 
 

Payment for order flow (PFOF) 

Payment for order flow (PFOF) occurs when a broker exercises discretion to direct client orders to a particular liquidity provider/market maker on the basis that the broker receives payment for doing so. PFOF represents a conflict of interest between the broker and the client and is likely to be inconsistent with the broker’s obligations in respect of best execution and the FCA’s inducements rules.     

 

All prices offered by CXM Prime are derived from those received from its liquidity providers. All client trades are executed by CXM Prime via its trading platform and the resultant market risk exposure is either internalised or hedged. Furthermore, the firm acts as principal in all client trades which are bilateral transactions between it and its clients. CXM Prime does not, therefore, engage in PFOF.        

 

Gifts, hospitality, entertainment and inducements

Gifts, entertainment, hospitality and inducements which are given or received by employees of CXM Prime could lead to potential conflicts of interest. To manage this risk, the firm has a Gifts and Hospitality Policy (available separately) which forms part of the firm’s Compliance Manual.                                                                                                                                    

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All employees are required to act with the highest standards of integrity to avoid any allegations of conflicts of interest. 

Employees must not accept any cash payments, significant gifts or hospitality. However, token gifts may be accepted, provided they have not been solicited, have not been given as a business inducement and will not compromise the employee’s integrity or give rise to a potential conflict of interest.   

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Information control (markets and clients) 

 

The inappropriate use of either market or customer information could give rise to potential conflicts of interest between the firm and a client or between one client of the firm and another. To manage this risk, employees are required to apply the rules and principles set out within the firm’s Compliance Manual and supporting systems and controls which aim to prevent insider trading, market manipulation and the misuse of market or price related information. Employees are strictly prohibited from undertaking a personal account position through either front-running the client order or copying a client order and from encouraging others to do so. 
 
The trading and personal information of a client is never disclosed to third parties. Trading information is used by the Compliance function to meet the firm’s obligation to monitor for suspicious activity and/or suspicious transactions.   

 

In order to control access to the market and client related information, physical access protocols are applied so that different areas of CXM Prime’s business are strictly controlled. Employees will normally only be given access to information that they require in order to discharge their duties.  

 
CXM Prime does not currently issue or distribute investment research and does not provide investment advice.   

 

Segregation of duties

CXM Prime has implemented measures to ensure that it has appropriate procedures for the supervision and/or functional segregation of its employees and/or parts of its business carrying out activities for clients whose interests may conflict, or where the interest of its clients and itself may potentially conflict.  

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CXM Prime has a defined team structure to provide segregation of duties designed to manage, control or prevent actual and potential conflicts of interest.  

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The organisation chart creates clear lines of authority allowing for the separate supervision of officers 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.  

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If any employee believes that a change in reporting lines gives rise to a conflict of interest, they should inform the Head of Compliance immediately.   

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The Compliance function undertakes regular reviews of each team’s operations and the roles undertaken by the individuals within the teams to ensure the team structures, segregation of duties and lines of authority continue to be appropriate. 

 

Client Losses 

Analysis of client trading indicates that the majority of clients lose money as a result of trading CFDs and similar OTC derivative products notwithstanding that CXM Prime offers its services on a non-advised basis. This presents a potential conflict of interest where CXM Prime internalises the market risk arising out of the trading positions of clients.   

The likelihood of loss is made clear to clients in financial promotions and in client communications.  

 

CXM Prime treats clients in the same way regardless of whether it internalises market risk. CXM Prime is committed to providing clients with as much information as necessary within the confines of offering a non-advised service to enable them to make informed decisions about whether to use the firm’s products.   

 

MANAGING CONFLICTS OF INTEREST

 

CXM Prime has established internal policies, procedures to enable it to identify and manage potential conflicts of interest.  

 

CXM Prime Limited and operates effective organisational and administrative procedures to manage and prevent the identified conflicts of interest from constituting or giving rise to a material risk of damage to the interests of its clients. CXM Prime also undertakes ongoing monitoring of business activities to ensure that internal controls are appropriate.  

 

The measures adopted are designed to ensure that relevant persons engaged in different business activities involving a potential conflict of interest carry on those activities at a level of independence and to the materiality of the risk of damage to the interests of the client.  

 

A number of controls and management arrangements associated with conflicts of interest which are inherent within CXM Prime’s business model are set out in section 8.2 of this policy. Further procedures and controls that CXM Prime applies to the management of conflicts of interest include the following, each of which is intended to ensure the requisite degree of independence.  

 

Ethical Walls 

Where required, CXM Prime Limited establishes and maintains an “Ethical wall” in order to create a barrier so that information held by one part of the business is withheld from, and cannot be used by, persons in another part of the business. Their operation and effectiveness are overseen and monitored by the Compliance function and reported to the senior management of the firm.  These arrangements include: 

 

• Effective procedures 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; and 

• 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. 

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Remuneration   

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. 

 

CXM Prime’s remuneration arrangements and the way in which employee performance is assessed are not structured in a manner that encourages behaviour which is not in the best interest of CXM Prime’s clients and which does not promote sound risk management practices. 

 

Moreover, the remuneration of employees involved in the provision of services to clients is designed to encourage responsible business conduct, the fair treatment of clients and to avoid conflicts of interest in the relationships with clients. 

 

Role Profiles and Performance Reviews

Employment duties are designed to limit the potential for conflicts of interest and help prevent or limit an employee from exercising inappropriate influence over the way any other employee or group of employees carry out services or activities. All employees are regularly assessed for competency in their roles and to ensure the discharge of their responsibilities appropriately reflects: 

• measures to prevent or limit any person from exercising inappropriate influence over the     way in which a relevant person carries out investment or ancillary services or activities; and 

• 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.  

 

Inducements 

CXM Prime has an obligation under the FCA’s “clients’ best interest rule” and its Principles for Businesses to act honestly, fairly and professionally in accordance with the best interests of its clients.   

 

In order to meet these obligations, CXM Prime takes all appropriate steps to ensure that no employee solicits or accepts from any person, or gives or offers to give to any person, any gift, inducement or other benefit that cannot properly be regarded as justifiable in all the circumstances and which might therefore influence either person’s independence or business judgement or which could create a conflict with any duty owed to CXM Prime or its clients. 

An inducement or benefit can be a fee, commission or other benefit (e.g. hospitality, telephone line) that is provided to or received from a third party. Gifts and hospitality are dealt with separately within CXM Prime’s Gifts and Hospitality Policy.  

Any other payments or benefits provided or received to or from a third party are required to be assessed to ensure that they: 

• Do not impair CXM Prime’s duty to act in the best interest of its client(s);  

• enhance the quality of the service being provided to its client(s); and 

• Are disclosed to its client(s). 

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If the above conditions are not met, CXM Prime is not permitted to pay or accept fees/commissions or benefits in connection with the investment services that it provides to clients. 

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A fee, commission or non-monetary benefit is designed to enhance the quality of the relevant service to a client only if: 

- it is justified by the provision of an additional or higher-level service to the client and is proportional to the level of inducements received;  

- it does not directly benefit the recipient, its shareholders or employees without tangible benefit to the client;  

- it is justified by the provision of an ongoing benefit to the client in relation to an ongoing inducement; and, 

- the provision of the service to the client is not biased or distorted as a result of the fee, commission or non-monetary benefit. 

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Records will be kept of inducements that are considered by CXM Prime and maintained by the Compliance function.  

 

Research 

CXM Prime does not distribute or receive investment research.  

 

Marketing Communications 

Marketing communications that are also Financial Promotions comply with CXM Prime’s Financial Promotions Policy and the associated procedures.  

 

Product Governance 

As a distributor of CFDs, CXM Prime must establish, implement and maintain product governance arrangements. These arrangements include appropriate systems and controls to identify, prevent or manage conflicts of interest, including remuneration. Further details are provided within the Product Governance Policy.  

 

Training 

Ongoing training is available to employees in relation to conflicts of interest. Training may be delivered by a combination of classroom and online material. 

 

Whistleblowing 

CXM Prime has a Whistleblowing Policy, which encourages its employees to raise issues of serious workplace malpractice without fear of reprisal.  Such issues include undeclared and unmanaged conflicts of interest by another CXM Prime employee, or group of employees. 

 

Conflicts of Interest Register 

CXM Prime maintains a dedicated conflict of interest register for appropriate record keeping of all potential and actual conflicts. The conflict of interest register is maintained by the Head of Compliance.   

 

ESCALATION OF CONFLICTS OF INTEREST

 

The Head of Compliance acts as the coordination point in relation to conflicts of interest.  Any actual or potential conflict of interest, whether it arises at the commencement of a client relationship or at some other time, must be reported immediately to the Head of Compliance using the Conflict of Interest Declaration Form in Appendix 1 to this policy.  

 

Following a notification, approval must be obtained from the Head of Compliance before employees proceed with any related business activities.  The Head of Compliance will inform the relevant employees of the outcome of the conflict of interest assessment by email. 

 

The outcome of the conflict of interest assessment may include any of the following: 

 

1. Approval – unconditional approval to a conflict check.  This could occur where no potential conflict of interest has been identified or where sufficient mitigating measures have already taken place. 

2. Conditional approval – approval subject to certain specified conditions being met.  This could occur where a potential or actual conflict of interest has been identified and appropriate mitigating measures can be put in place to manage the conflict.  In some circumstances, the Head of Compliance may deem it necessary that a disclosure is made to clients.  Heads of business will work to record evidence of any conditions that are being met. 

3. Referral – where a decision on a potential or actual conflict of interest cannot be immediately made, the Head of Compliance will consider the matter further before determining an outcome.  

4. Rejection – the Head of Compliance may reject a conflict of interest.  This could occur where a potential or actual conflict of interest has been identified and cannot be managed. The Head of Compliance may then recommend that CXM Prime should not proceed with the proposed business unless alternative arrangements can be implemented. If alternative arrangements are identified, they must go through a Conflict Check by the Head of Compliance before they can be approved and implemented. 

 

Where the Head of Compliance provides an approval or conditional approval for a conflict of interest, the relevant employees involved are responsible for ensuring that the Head of Compliance is kept informed of any changes to the proposed business activity or detail of the potential conflict of interest. 

 

All decisions will be documented in CXM Prime’s Conflicts of Interest Register along with the supporting rationale.  

 

DISCLOSURE OF CONFLICTS OF INTEREST 

 

Disclosure 

CXM Prime Ltd will not over-rely on disclosure to address actual or potential conflicts of interest and will not allow disclosure to become the default position in relation to conflicts of interest. 

 

If CXM Prime’s administrative and organisational arrangements to manage conflicts of interest are not sufficient to ensure, with reasonable confidence, that risks of damage to the interests of a client will be prevented then CXM Prime will clearly disclose the general nature and source of the conflict of interest to the client before undertaking business for the client. The disclosure will be made in a durable medium and will contain sufficient detail to enable the client to make an informed decision about the service being offered by CXM Prime in the context of which the conflict of interest arises.  

 

The disclosure may include: 

 

• A statement that the organisational and administrative arrangements established by CXM Prime to manage or prevent the conflicts of interest are not sufficient to ensure with reasonable confidence that the risks of damage to the interest of the client will be prevented; 

• The general nature of the sources of the conflict of interest; 

• A specific description of the conflict of interest that arises in the provision of the services to the client taking into account the nature of the client to whom the disclosure is made. 

 

The content of the disclosure should ensure that careful consideration is given prior to disclosure as to whether the disclosure can in fact be legitimately disclosed.  For example, it may not be possible due to client confidentiality, where a disclosure may inadvertently disclose confidential information pertaining to other clients. 

 

All disclosures will be approved by the Head of Compliance who will seek guidance and approval from the Board of Directors, as required.  

 

The client will confirm whether or not they wish CXM Prime to continue providing services or deal on their behalf.  

 

CXM Prime acknowledges the FCA’s expectation that disclosures should be considered as a measure of last resort to be used only where the effective organisational and administrative arrangements established by CXM Prime to prevent or manage its conflicts of interest are not sufficient to ensure, with reasonable confidence, that risks of damage to the interests of the client will be prevented.  

 

Declining to Act 

Where a conflict of interest is identified and there is no effective way of dealing with it, CXM Prime will give consideration to whether it would be appropriate to decline to act for or deal with a client.  

 

RECORDING OF CONFLICTS OF INTEREST 

 

The Compliance function maintains and regularly updates a conflicts of interest register, which details all conflicts which may arise out of the business activities of the firm and the controls employed by the firm to manage those conflicts. The register also records those situations: 

 

1. where a conflict of interest has been disclosed to a client and where the client has decided to proceed with the relationship; 

2. where a conflict of interest has been disclosed to a client and where the client has decided not to proceed with the relationship; and 

3. where CXM Prime has determined that a conflict of interest exists which cannot be effectively managed and has decided that it would not be appropriate to decline to act for or deal with a client.  

 

The Compliance function will review the Conflicts of Interest Register to ensure that no trends are visible that would suggest that CXM Prime’s interests have been put ahead of clients’ interests.  

 

All records relating to the conflicts of interest framework will be retained for a period of at least 5 years. Copies of each Conflicts of Interest Policy will be kept for at least 5 years after it is superseded.  Conflicts of interest registers will be retained indefinitely.