Risk Disclosure

Conflicts of Interest Policy

  1. Introduction

    D2M is committed to ensuring that our business is conducted in an honest, fair and professional manner in accordance with the best interests of its clients. All employees of the company are obliged to refrain from doing anything that could be reasonably regarded as creating a conflict of interest in line with their professional responsibilities. It is the policy of the company to avoid any conflict of interest when providing business services to its customers. From time to time, however, we may have interests which conflict with our customers' interests. Our Conflicts of Interest Policy aims to ensure that our clients are treated fairly and with the highest level of integrity and that their interests are protected at all times.

  2. Identification of Conflicts of Interest

    In order to identify the types of conflicts of interest that may arise in the course of providing its business services, D2M will take into account the following situations where D2M and a relevant person including a director, partner manager, employee or other person directly involved in the provision of services to D2M:

    1. Is likely to make a financial gain at the expense of the client;
    2. Is likely to limit or avoid financial loss at the expense of the clients;
    3. Has a financial or other incentive to favor the interest of another client over the interest of the client;
    4. Carries on the same business as the client; or
    5. Receives from a person other than the client in relation to a service provided to the client, in the form of monies, goods or services other than the standard commission or fee for that service.
  3. Potential Conflicts of Interest

    The following situations are some good examples of conflicts which may arise when D2M is providing business services for its clients:

    1. When D2M executes transactions through its trading platform for its clients, D2M acts as principal in all dealings; and
    2. You may have been introduced to D2M by a third party who receives commission or remuneration from your trades.
  4. D2M's Arrangements for Managing Conflicts

    D2M shall adopt a number of approaches within the company to manage conflicts of interest and control the movement of confidential information as shown below:

    1. Procedures to prevent and control the exchange of information between persons at D2M which may harm the interests of one or more clients; and
    2. Controlling the disclosure of client order details of one client to another;
    3. Provision of training to directors and employees of D2M on conflicts of interest management.
  5. Personal Account Dealing

    To prevent conflict arising from the use of information obtained from clients, and the market abuse in general, all directors and employees will not be able to open an account with D2M.

  6. Employee's Activities Outside the Company

    Our employees are subject to rules designed to avoid conflicts of interest with activities they undertake outside D2M.

  7. Declining to Act

    We may decline to act for a client in cases where we believe a conflict of interest cannot be managed in any other way.

  8. D2M's Policy

    D2M recognizes, in certain circumstances, conflicts of interest can arise among D2M, its directors, employees, introducing brokers and all clients. As required by law, D2M implements and maintains an effective conflicts of interest policy for the purpose of preventing conflicts of interest or potential conflicts of interest from causing a material risk of damage to the interest of clients.

  9. Record Keeping

    D2M maintains a record, which is regularly updated, of the kinds of investments and ancillary services or trading activities carried out by D2M or on its behalf in which a conflict of interest entailing a material risk of damage to the interests of one or more clients has arisen, or in the case of an ongoing business service or activity may arise.

  10. Disclosure

    Whilst D2M is devoted to implement and maintain our conflicts of interest policy, in some cases, such policy might not be sufficient to prevent risks of damage to the interest of a client. In such a case, D2M shall disclose the general nature and sources of conflicts of interest to the client so that enables the client to make an informed decision whether to proceed with the transaction in question.

  11. Policy Review

    D2M reserves the right to frequently review and assess the Conflicts of Interest Policy and, if required, amend it to meet and support its clients' needs and ensure that the Policy is compliant with rules. For more information, please contact compliance@d2m-ltd.com

  12. When and How to Contact Us

    If and when you have any inquiries about this Conflict of Interest policy, or you wish to help us to improve this Policy, please notify us by contacting us at: compliance@d2m-ltd.com