Conflicts of Interest

Conflict of Interests Policy



  • Identifying Conflicts of Interest:


W7BT shall identify and document potential conflicts of interest that may arise in the course of its commercial operations. These conflicts can include, among other things:

W7BT’s market transactions which may impact customers;

financial interests of W7BT employees or shareholders which may conflict with customers’ interests;

Use of confidential information for private purposes or on behalf of third parties.



  • Preventing conflicts of interest:


W7BT takes reasonable precautions to prevent conflicts of interest. These measures may include the following:

Implementation of account segregation policies to ensure client funds are kept separate from W7BT funds;

implementation of internal controls to ensure that confidential information is not improperly shared;

Ban speculative trade or other activities that could lead to conflicts of interest.



  • Managing Conflicts of Interest:


In the event of a conflict of interest, W7BT must take the necessary measures to deal with it correctly. These steps may include, but are not limited to:

provide the customer with information on the conflict of interest, including the nature of the conflict and how W7BT recommends that it be resolved;

Refrain from conducting transactions on behalf of the client which may exacerbate the conflict of interest;

Designate an individual to manage the conflict of interest.



  • Conflict of Interest Policy Review:


W7BT shall periodically review its conflict of interest policy and its measures to avoid and manage conflicts of interest. This examination should be conducted by an independent person who is not involved in the conduct of W7BT’s commercial activities. Any changes to the policy should be communicated to clients in an appropriate manner.