Scope
This policy applies to Horwick Technologies Ltd, its directors, employees and appointed partners, and to every service we provide under our Terms of Service.
What is a conflict of interest
A conflict arises when the interests of Horwick, its staff or one client could be put ahead of the interests of another client, for example when Horwick earns more from one outcome of a client’s trade than another.
Identifying conflicts
We maintain a register of potential conflicts, reviewed at least annually and whenever we launch a new product or service.
How we manage conflicts
- Separation of functions, so staff handling client orders are independent from those managing Horwick’s own positions.
- Best-execution rules and independent price sources for every order.
- Remuneration that does not reward staff for client trading volume or losses.
- A personal-trading policy that requires staff to pre-clear their own trades.
- Gifts and hospitality rules with a register of anything received.
Disclosure
Where a conflict cannot be prevented, we will tell you clearly about its nature and source before providing the service, so you can make an informed decision.
Monitoring and review
Compliance monitors adherence to this policy and reports to the board. The policy is reviewed at least once a year.
Questions
For questions about this policy, contact [email protected] or use the contact form.