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1. Purpose

QFEX Bermuda Ltd. (“QFEX”) is committed to the highest standards of integrity, fairness, and transparency in all business dealings. This Conflicts of Interest Policy outlines how QFEX identifies, prevents, manages, and discloses conflicts of interest that may arise in the course of its activities. The policy is designed to:
  • Protect the interests of clients;
  • Uphold market integrity;
  • Ensure compliance with Bermuda Monetary Authority’s requirements and guidance and recognised international standards.
QFEX ensures that conflicts do not compromise the fair treatment of clients or the ethical operation of its markets.

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2. What is a Conflict of Interest?

A conflict of interest arises where QFEX, its employees, contractors, or affiliates have interests that may impair, or be perceived to impair, QFEX’s ability to act in the best interests of its clients. These may be:
  • Personal conflicts: e.g., employee incentives, relationships, or personal account dealings.
  • Institutional conflicts: e.g., competing business interests across QFEX functions.

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3. Key Potential Conflicts

While QFEX seeks to minimise conflicts through its business model (e.g., not providing personal financial advice), potential conflicts include:
  • Offering services linked to products manufactured or promoted by third parties.
  • Preferential access to systems (e.g., latency advantages, co-location, or connectivity).
  • Allocation of fees, rebates, or referral rewards which may incentivise certain behaviours.
  • Decisions related to client order execution, cancellation, or error-handling, which may affect outcomes differently across clients.
  • Employees or affiliates trading on their own accounts in a way that could conflict with client interests.

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4. Identification, Prevention, and Management

QFEX employs a structured framework to identify and address conflicts: Identification methods:
  • Compliance monitoring and surveillance systems.
  • Internal audits and risk assessments.
  • Regular workshops and staff attestations.
Mitigation measures:
  • Segregation of duties between business units.
  • Strict information barriers and confidentiality areas.
  • Pre-clearance and monitoring of staff trading (including blackout periods).
  • Adjustments to remuneration to remove conflicting incentives.
  • Restrictions or bans on certain outside business activities.
Governance controls:
  • Amer Bhatti is the appointed Conflicts Officer and responsible for oversight and escalation.
  • Maintenance of a Conflicts Register (updated quarterly or as needed) by Conflicts Officer.
  • Maintenance of a Gifts and Hospitality Register (updated when notification received) by Conflicts Officer.
  • Independent audit and compliance reviews.
  • Mandatory training for all employees and contractors.
Prohibitions:
  • No misuse of client order information.
  • No acceptance of gifts and hospitality, inducements, or entertainment that could improperly influence decisions. All gifts and hospitality, inducements and entertainment must be notified to the Conflicts Officer ideally before they take place or within 5 working days.

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5. Disclosure and Client Protection

If a conflict cannot be fully eliminated, QFEX will:
  • Disclose the general nature and source of the conflict to the affected client(s) in a clear, durable, and timely format; and
  • Provide sufficient detail for clients to make an informed decision before proceeding.
Clients will always retain the right to decline participation in services where they feel a disclosed conflict creates undue risk.

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6. Monitoring, Review, and Accountability

  • This Policy is reviewed at least annually by the Compliance function and formally approved by the Board.
  • It is also reviewed ad hoc whenever new products, services, or business models are introduced.
  • Updates are published on QFEX’s website to maintain transparency.
  • A summary of conflicts identified and managed will be reported annually to the Board and made available to regulators on request.

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7. Commitment

QFEX is committed to:
  • Acting honestly, fairly, and professionally in the best interests of its clients.
  • Ensuring that conflicts of interest are managed robustly and transparently.
  • Continuously improving systems and controls to reflect evolving regulatory expectations and market practices.
Approved by: QFEX Bermuda Ltd. – Board of Directors
Review Date: Next scheduled review – September 2026