This Conflict of Interest Policy Statement outlines how STI Global Limited ("STI Global") manages the conflicts which can arise within STI Global, between STI Global and its customers and between customers of STI Global. This Policy is reviewed from time to time to take account of changes to operations or practices and, further, to make sure it remains appropriate to any changes in law, technology and the general business environment. This policy applies in respect of all activities undertaken by STI Global and employees of STI Global.
1. STI Global undertakes all trading as principal to it’s customers transactions, it hedges its net risk with counterparties which means that customers aims are more aligned with its own aims notwithstanding it is acting as principal in all transactions. As STI Global does not provide investment advice no conflict can arise from this source. STI Global only offers CFD's, therefore any conflict which could arise between different product lines cannot exist.
2. STI Global takes responsibility for identifying and managing other conflicts of interest arising in its business that may entail a material risk of damage to the interests of customers. STI Global have considered, in particular, the potential conflicts of interest arising out of the execution of transactions for its customers.
3. The following measures have been adopted in relation to other conflicts of interest:
3.1. When STI Global executes an order for a customer it does not give any preferential treatment to that customer to the detriment of other customers and does not disclose the details of one customer order to other customers.
3.2. STI Global executes all orders electronically, in accordance with policies that comply with relevant rules and regulations in relation to transactions which are executed for or on behalf of customers. STI Global's procedures provide for the prompt, fair and expeditious execution of customer orders, relative to other orders. These procedures allow for the execution of otherwise comparable orders in accordance with the time of their receipt.
3.3. STI Global's procedures are established to ensure that orders executed on behalf of customers are promptly and accurately recorded and that it carries out otherwise comparable orders sequentially and promptly unless the characteristics of the order or prevailing market conditions make this impractical or the interest of the customer requires otherwise.
3.4. STI Global's procedures ensure that STI Global, its employees and affiliates cannot misuse information relating to pending customer orders.
3.5. All employees of STI Global are prohibited from dealing on personal accounts to avoid any actual or perceived conflicts of interest.
3.6. All employees of STI Global are prohibited from accepting gifts or other inducements from any person with any material interest which is likely to conflict to a material extent with any duty which STI Global and/or its employees owe in connection with its treating customers fairly policy or any duty which such a recipient owes to customers.
4. STI Global is committed to having an effective and appropriate compliance culture to enable it to deal with any new potential conflicts of interest which may arise in the future. STI Global's employees are therefore required to monitor any new circumstances giving rise to potential conflicts and to implement appropriate measures to address these.
5. In the unlikely event that STI Global's arrangements to manage conflicts of interest are not sufficient to ensure, with reasonable confidence, that risks of damage to the interests of a customer will be prevented, STI Global are required to clearly disclose the general nature and/or sources of conflicts of interest to a customer before undertaking business for them.
If you have any queries about this conflict of interest policy, or you wish to help us improve this Policy, please notify us by contacting us at: firstname.lastname@example.org.