Conflict of interest policy

Conflicts of interest exist in all business and financial services organizations.

We live in a complex world where conflicts of interest abound, however, we recognize that our business is first and foremost based on the trust we have with our clients, and we have an obligation to identify and manage these conflicts.

Therefore, we have adopted a number of policies, procedures and methods to identify, assess and manage these conflicts of interest.

The purpose of this disclosure statement is to identify, in summary form, the conflicts we encounter as an institution and to describe how we address the challenges posed by those conflicts.

We are aware that conflicts may arise in certain circumstances between MHMarkets, its directors and employees, and other related and affiliated companies.

To prevent and minimize the risk that such conflicts may result in harm to our clients’ interests, we have adopted certain internal systems, procedures and controls as follows:

• Personal account transaction restrictions for all employees.
• Internal disclosure requirements for all employees that cover the giving and receiving of gifts or other items in connection with our business.
• Internal separation of functions when multiple functions performed by the same person would increase the risk of conflict.
• Maintain an independence policy that requires our directors and employees to act in the best interest of our clients regardless of any conflicts of interest.
• Restrictions on access to data stored in electronic or paper form. Our directors, officers and employees are required to maintain the confidentiality of all information entrusted to them, except where disclosure is required by law.
• In addition, employees may not use such information for personal gain.
• When we believe that these measures are not sufficient to prevent the risk of harm to our clients from a particular conflict, we will make a general statement that allows our clients to consider their situation and decide whether to continue using our services.
• In particular, we provide investment advice or recommendations to a client who is also using the trading services of a related organization or affiliate.
• We arrange the transaction or arrange for a third party to provide the transaction services for a fee or commission charged by us or a subsidiary.
• Such general disclosures may be made orally or in writing prior to or at the time of the transaction.
• For any other conflicts that we determine will result in a risk of harm, we will make special disclosures, either orally or in writing, when we discover the conflict.