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Company Employees Must:
- Are strictly forbidden to trade for themselves either on the Easy Forex platform or on any other platform or mean either directly or through an intermediary/related party
- Be entitled to the same benefits as those of the parent company, thus avoiding any conflict of interest.
- Follow the same code of operations as the Parent, thus avoiding any conflict of interest.
- Report to their supervisor any potential conflict of interest related to a proposed transaction.
- Report to their supervisor any special relationship he or any related party might have with a proposed transaction that might affect his judgment.
- Not trade for his personal account with a view of short term profit.
- Consider commission rates, timeliness of trade executions, and the ability to maintain anonymity, minimize incomplete trades, and minimize market impact.
- Not trade on material nonpublic information. In the case that an employee holds material non-public information he must report it to the supervisor or the compliance officer and in such case the financial instrument will be placed either in the restricted list or the watch list.
- Employees must provide the compliance officer with copies of their trades each month and quarterly statements of personal holdings.
- The compliance officer will be responsible for reviewing the company’s and employee transactions and to ensure the priority of client interests. Because personnel, regulations, business practices, and products constantly change, the role of the compliance officer (particularly the role of keeping the firm up to date on such matters) is that much more important. In this regard, each staff member will annually confirm in writing receipt of the procedures manual and agree to abide by its terms.
- The compliance officer documents and acts expeditiously to address any compliance breaches and take appropriate disciplinary action on their own authority, independent of management as warranted. If the compliance officer is unable to resolve any breaches on his own, he should sequentially seek the assistance of senior management or Board of Directors or outside counsel as needed. The compliance officer should report violations and other issues related to the procedures on a regular basis to the Board of Directors or the supervisor.
- Not exchange information with other companies belonging to the same Group. Information barriers will be in place to prevent communication of material information and other sensitive information from one company of the group to other companies so as to control the flow of such information.
- Material information will be confined only to persons who have a need to know that information in order to carry out their responsibilities.
- The Head of Own Account trading will also act as a risk management officer and will be responsible in monitoring and reporting to the board any potential risks to the company. Also, he will analyze other risk factors related to the financial services industry and general macroeconomic developments that are likely to influence the environment in which the Company operates.
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