Central Markets (London) Ltd is a common platform firm as defined by the Financial Services Authority (FSA). Central FX is part of the Central Markets (CM) group of companies. CM Group is required to establish, implement and maintain an effective Conflicts of Interest Policy in writing, which is appropriate to the size and nature of its businesses.

The policy must take into account the structure of the group and the business activities of all members of the group. This is a summary of the full policy, which is available on request from the Group Head of Compliance.

Identifying conflicts

CM Group is required to take all reasonable steps to identify conflicts of interest between:

• The Company (including its managers and employees) and clients of the firm;
• One client of the firm and another client.

A potential conflict occurs where competing obligations result in material risk of damage to the interests of a client.  In order to prevent this CM Group will take into account whether:

• It is likely to make a financial gain, or avoid a financial loss, at the expense of the client;
• Has an interest in the outcome of a service or transaction provided to the client but which is different from the client’s interest in that outcome;
• Has a financial or other incentive to favour the interests of one client or group of clients over other clients;
• Receives or will receive an inducement form someone other than the client in relation to a service provided to the client in the form of monies, goods or services.

Potential Areas of Conflict

Examples of the types of conflicts which may arise at CM Group include:

• Interests in Competitors, Clients or Suppliers ;
• Inducements ;
• Interest in transactions and personal account dealing;
• Diversion of business opportunity;
• Outside employment and business interests;
• Employee Loyalty;
• Remuneration.

 

Managing Conflicts

The Company takes all reasonable steps to prevent the conflicts identified from giving rise to a material risk of damage to the interests of its clients. 

The CM Group maintains a Conflicts Register the purpose of which is to record and maintain a list of all actual and potential types of conflicts which may cause a material risk of damage to the interests of a client. 

All conflicts will be managed by Senior Management and monitored by the Group Head of Compliance.