Conflict of Interest Policy

OVERVIEW

St. Vincent and the Grenadines Forex Brokerage Company and EMD Financials LLC(EMD Forex) own conflict of interest policy, we have in place arrangement to identify, monitor und manage conflicts of interest that may arise between ourselves and our clients.

A conflict of interest is a situation in which someone in a position of trust has competing professional or personal interest. Such competing interests can make it difficult to fulfil his or her duties impartially. A conflict of interest may exist even if no unethical or improper act results from it. EMD Financials LLC is committed to identifying, monitoring and managing all actual and potential conflicts of interest that can arise or exist.

PURPOSE

To document appropriate information which is to be provided to our clients, at any time requested, in relation to the policies we have in place to manage conflicts of interest. The following information is a summary of the potential conflicts that may exist or arise and the
action undertaken to mitigate these.

GIFTS

On occasions the employees may give gifts or receive them from clients, companies or other institutions in recognition of the service provided. Care is taken to ensure that these gifts are not excessive and do not create an obligation or “debt”. A “token of appreciation may be accepted, as long as this is not perceived as an inducement for preferential treatment. However, certain business related activities involve the entertainment of clients and as a general accepted business practise are unlikely to be interpreted as an inducement or payment.

INDUCEMENT

EMD Financials LLC is an independent Financial Service provider. We have business relationships with third party service providers, we do not receive any fees and/or non-monetary benefits which could impair our work to act in the best interest of our clients.

REMUNERATION

The remuneration of the employees consist of a salary and a KPI-based bonus structure. For the sales team a commission based structure is applicable.

DEALING FOR CLIENT ACCOUNT

EMD Financials LLC does not act as counter party to any transactions executed by its clients. EMD Financials LLC receives and transmits client’s orders and transactions.

DISCLOSURE & REVIEW

Where a conflict arises, EMD Financials LLC will, if it is aware of it, disclose to the client prior to undertaking investment business for a client or, if it doesn’t believe that disclosure is appropriate to manage to conflict, we may chose not to proceed with the transactions or the matter given rise to the conflict, without necessarily providing any reason/s to the client.

We reive the Conflict of Interest Policy at least on an annual basis or should a material change occur, which is not contemplated in the current Conflict of Interest Policy.