Conflicts of Interest Policy

1. Introduction

Vakto is required by applicable regulations to maintain and operate effective organisational and administrative arrangements to identify, prevent, manage, and disclose conflicts of interest. This policy sets out how we identify and manage conflicts that may arise in connection with our business activities and the provision of services to clients.

2. Identification of Conflicts

• —Conflicts between Vakto's interests and those of its clients.
• —Conflicts between the interests of different clients.
• —Conflicts arising from the personal interests of employees and directors.
• —Conflicts arising from our role as market maker or matched principal broker.
• —Conflicts arising from remuneration structures that may incentivise inappropriate behaviour.
• —Conflicts arising from relationships with third parties including introducing brokers and affiliates.

3. Managing Conflicts

Where potential conflicts of interest are identified, we manage them through a combination of: information barriers (Chinese walls) between business areas; supervision and monitoring procedures; ensuring staff receive appropriate training; maintaining clear policies on personal account dealing; and establishing clear governance frameworks for decisions where conflicts may arise.

4. Order Execution Conflicts

As a provider of CFD contracts, Vakto may act as principal in all transactions, meaning we take positions opposite to client trades. We manage this potential conflict through our no-dealing-desk execution model, competitive pricing, and commitment to best execution. We do not manipulate prices to the detriment of clients, and our pricing reflects underlying market rates from our liquidity providers.

5. Remuneration Policies

Our remuneration policies are designed to avoid creating incentives that could lead employees to act contrary to clients' best interests. Employee compensation is not tied to trading volumes in a manner that would incentivise inappropriate advice or action. We prohibit inducements that conflict with our duty to act in clients' best interests.

6. Introducing Brokers and Affiliates

Where we receive or pay remuneration to introducing brokers or affiliates, we ensure this does not create a conflict that impairs our duty to act in clients' best interests. Material conflicts arising from these relationships are disclosed to affected clients. We conduct due diligence on all introducing brokers and monitor referred client activity.

7. Personal Account Dealing

All employees are subject to a Personal Account Dealing Policy that restricts and monitors personal trading activity. Employees are prohibited from trading on the basis of material non-public information. All personal trades must be pre-approved by compliance and are subject to regular review.

8. Disclosure

Where, despite our policies and procedures, a conflict of interest cannot be adequately managed, we will make appropriate disclosure to the affected client(s) prior to conducting business with them. Such disclosure will be sufficiently detailed to enable clients to make an informed decision about our services.

9. Review and Update

Our Conflicts of Interest Policy is reviewed at least annually by senior management and our compliance function. It is updated as necessary to reflect changes in our business activities, regulatory requirements, or identified deficiencies in our controls.