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Conflicts of interests

The regulation of the conflict of interest policy (hereinafter referred to as the “Policy”) is designed to ensure the legitimacy of activities, as well as compliance with all rules and procedures aimed at resolving any conflicts of interest between CTmatador and its Clients.

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CTmatador undertakes to apply such processes that would allow building adequate relations between company representatives, its managers, employees, and other persons who are directly or indirectly associated with CTmatador, on the one hand, and all customers, on the other hand, so that resolve all possible conflicts that may arise in the process of providing Investment and other services.

Identification

Conflicts of interest may arise between the CTmatador and individuals and legal entities that may use the platform to conclude contracts for personal or corporate interests. The following are situations that could lead to a conflict of interest:

The company or person representing the company receives financial profit or avoids losses at the expense of the client.

The company or person representing the company is interested in the result of the provision of a service or transaction carried out on behalf of the client, which differs from the interest of the client as a result.

A company or a person representing the company offers advantages or benefits to one client (a group of clients) at the expense of another client.

The company or person representing the company receives a recommendation from a non-client to provide the client with a particular service or product or receives a commission for these services and products.

The situations described above are extremely rare. Most often, conflicts may arise between the following parties:

Independence

To guarantee a high degree of independence, CTmatador has taken the following measures:

Prevention or control in the exchange of information between the parties.

Shared responsibility control between group people.

Measures to limit the impact on the investor.

Measures to prevent and control the transfer of the order and decision-making on the investment portfolio and the calculation of their effectiveness.

The top management of the company is obliged:

Follow the principles of compliance with the conflict of interest policy regularly and fully.

Creation of a unified approach to identify and prevent any situations fraught with conflict.

To increase the level of awareness and responsibility of all persons, including through training (primarily company employees and third parties).

Provide systems that provide the Customer with information about conflicts within the limits of what is permissible and possible.

Support the principle of independence.

Separation of obligation and rights

The company is building effective “Chinese walls” in strict accordance with the law. In particular, limits of liability are established in order to avoid a situation where one side of the conflict influences the other side of the conflict. In particular, restrictions apply to workers. They are given limited access to the information and documents of the Company in the course of resolving the conflict related to this employee.

Reporting Conflicts

In the event of an explicit and implicit conflict, the CTmatador employee must first pass all the information to his immediate supervisor, who has more authority to help and assess the situation, and who can fill out the form necessary for regulatory authorities:

Gifts and benefits

If one of our employees receives gifts, entertainment, or other forms of hospitality, this may lead to a potential conflict between the interests of the donor and the recipient of hospitality and the interests of one or more of our clients. We have a policy that obliges our employees to declare and request approval of any form of gift or entertainment at a certain level to ensure impartiality. We will not accept promotions or other benefits from those who have a material interest in the subject of the strategy, including the supplier who developed the strategy.

Customer Information Security

We do not use your information except to provide you with our services. We do not share your specific information with third parties without your consent unless required by law or regulation.