Comflict of Interest Policy

Comflict of Interest Policy

Blue Suisse Limited (“Blue Suisse”) offers financial services to several types of customers (retail / professional clients and eligible counterparties) in relation to financial derivatives, included but not limited to spot Foreign Exchange and Precious Metals Contracts and Contracts for Differences (CFD`s) – refer to Customer Agreement for more information.

Although, Blue Suisse has implemented rigorous internal measures, and seeks to circumvent conflicts of interest situations altogether, it is possible that conflicts of interest may still arise due to the fact that Blue Suisse does not perform its services exclusively for the Customer, but also for third parties, the interests of which may be competing and/or infringe with the ones of the Customer and furthermore due to the fact that Blue Suisse has a commercial interest in concluding business with the Customer. Although, Blue Suisse shall seek to avoid such conflicts, the possibility of these arising cannot be excluded altogether.

Conflicts of Interest

Blue Suisse Limited (“Blue Suisse”) offers financial services to several types of customers (retail / professional clients and eligible counterparties) in relation to financial derivatives, included but not limited to spot Foreign Exchange and Precious Metals Contracts and Contracts for Differences (CFD`s) – refer to Customer Agreement for more information.

Although, Blue Suisse has implemented rigorous internal measures, and seeks to circumvent conflicts of interest situations altogether, it is possible that conflicts of interest may still arise due to the fact that Blue Suisse does not perform its services exclusively for the Customer, but also for third parties, the interests of which may be competing and/or infringe with the ones of the Customer and furthermore due to the fact that Blue Suisse has a commercial interest in concluding business with the Customer. Although, Blue Suisse shall seek to avoid such conflicts, the possibility of these arising cannot be excluded altogether.

Conflicts of interest may arise between Blue Suisse, our management, our employees, Introducing Brokers bound by contract or other persons affiliated with our company and our customers or between our customers. Conflicts of interest may arise in the following scenarios:

1.1. Blue Suisse does not provide its services exclusively to the Customer, Blue Suisse interest with third parties may collide with the customers’ interests. Although Blue Suisse uses its best efforts to avoid such conflicts, it cannot be excluded that this might fail in the individual case. If such conflicts occur, the risk that they are settled at the customer’s expense cannot be excluded;

1.2. On account of the interest of Blue Suisse and its agents in high transaction volumes in the financial instruments chosen and traded in by customer´s and on account of the remunerations for Blue Suisse and its agents resulting from these transactions;

1.3. On account of profit-related remuneration of employees and agents or the granting of additional remuneration to these persons or by these persons (for example (trail) distribution commissions, benefits in money’s worth);

1.4. On account of the interest in obtaining (trail) distribution commissions.

1.5. When preparing financial analyses on currencies and precious metals and financial instrument offered by Blue Suisse;

1.6. On account of the interest of Blue Suisse, its sales units and the agents acting for Blue Suisse in the sale of financial services provided by Blue Suisse on account of internal incentives, success-related remuneration schemes and the granting of additional remuneration.

1.7. On account of personal relationships of the Blue Suisse employees or the management or the affiliated persons or the participation of these persons in supervisory or advisory boards

Blue Suisse would like to point in particular to the following points:

If a third agreement on performance-related remuneration is concluded between Blue Suisse and an investment manager, another conflict of interest may arise consisting in the fact that the manager takes unreasonable risks for achieving a performance as high as possible and the associated increased remuneration. This risk is reduced through an internal observation of the investment decisions made and the combination with other fixed components of remuneration.

Blue Suisse may pay in part success-related commissions and fixed fees to agents and Introducing Brokers bound by contract who refer clients to us with or without reference to an actual transaction or individual transactions. Furthermore, Introducing Brokers may also receive benefits directly from third parties, in particular investment companies and security issuers, in addition to agent commissions paid by us. On request, Blue Suisse will provide the client with further details on these principles.

2. Implementing measures to circumvent conflict of interest.

Blue Suisse itself and its employees have implemented high level measures in order to avoid the influence of inappropriate interests on the carrying out of clients’ orders. These standards include the observation of market rules in continuous consideration of the clients’ interests as well as legal and professional action. The client’s interest is of great priority to us and as a result, the following measures have been implemented, including but not limited to the following:

2.1. Keeping an insider list for controlling sensitive information as well as for preventing abuse of insider knowledge in line with our information security policy and information divulged on a need-to-know basis;

2.2. Drafting of internal memo, policies and procedures to address possible conflicts of interest, among other things, by means of prohibitions to conclude business as well as by a prohibition of financial analysis;

2.3. Employees are subject to Blue Suisse Conflicts of Interest Policy whereby they are obliged to disclose their own financial transactions in relation to foreign exchange and precious metal trading to Blue Suisse Compliance Department. Ongoing training is provided to Blue Suisse employees on how to identify, pre-emptively, such conflicts;

2.4. Removal of any direct link between the remuneration of relevant persons principally engaged in one activity and the remuneration or revenues generated by different relevant persons principally engaged in another activity where a conflict of interest may arise in relation to such activities;

2.5. Where, notwithstanding our best endeavours, a conflict of interest shall subsist and cannot be circumvented, we will disclose them to the client concerned before the carrying out of an Order, or at the first available date.

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