Under the rules of the BVI Financial Services Commission, this policy provides information on the Conflict of Interest for FTD Limited (together referred as ‘‘FTD”, ‘‘we”, ‘‘our” or ‘‘us”) (the ‘‘Conflict of Interest Policy”).
This Conflict of Interest Policy (hereinafter, the “Policy”) is provided to you pursuant to which the Company is required to take all appropriate steps to detect and avoid conflicts of interest.
The Company is committed to act honestly, fairly, and professionally and in the best interests of its customers and to fulfill all the requirements of the relevant applicable law when providing investment services and other additional services related to such investment services.
This document’s purpose is to demonstrate the Company’s approach to the identification and management of conflicts of interest that may occur during the course of its regular business operations. This document also identifies circumstances that can result in a conflict of interest
The Company shall take all reasonable measures for the identification, management, prevention, and/or disclosure of any conflict of interest within its organization, with its Customers, and between its Customers, to avoid conflicts of interest from adversely affecting the Customers’ interests.
This policy applies to all its directors, employees, any persons directly or indirectly linked to the Company (hereinafter called “Related Persons”) and refers to all interactions with all Customers.
When the Company deals with the Customer, the Company or Related Persons may have an interest, relationship or arrangement that is material in relation to the Transaction concerned or that it conflicts with the Customer’s interest.
While it is not possible to define precisely or create an exhaustive list of all relevant conflicts of interest that may arise, as per the current nature, scale, and complexity of the Company’s business, the following list includes circumstances which constitute or may give rise to a conflict of interest entailing a material risk of damage to the interests of one or more Customers, as a result of providing investment services:
In general, the procedures and controls that the Company follows to manage the identified conflicts of interest include, but are not limited to, the following measures:
By sealing a Customer Agreement with the Company, the Customer consents to the application of this Policy. Additionally, the Customer consents to and authorizes the Company to deal with the Customer in any manner which the Company considers appropriate, notwithstanding any conflict of interest or the existence of any material interest in a Transaction, without prior reference to the Customer.
When the measures taken by the Company to manage conflicts of interest are not sufficient to ensure, with reasonable confidence, that the risk of damage to customer’s interest will be prevented, the Company will disclose the Conflicts of Interest to the customer in order to prevent a Risk of Damage to Customer’s Interest. Prior to carrying out a transaction or providing an investment or an ancillary service to a customer, the Company must disclose any Actual or Potential Conflict of Interest. The disclosure will be in sufficient time, in a durable fashion.
For record-keeping purposes, the Company maintains an accurate log which will be updated regularly of all types of investments and ancillary services or investment activities carried out by the Company or on its behalf; in which a conflict of interest entailing a material risk of damage to the interests of one or more customers has arisen.
The Company reserves the right to review and/or amend its Policy and arrangements whenever it deems this appropriate without notice to the Customer.