Our Promise · §1
Our Commitment to Fair Practice
KoveTrade is committed to maintaining the highest standards of integrity and fairness in all our business dealings. We recognise that conflicts of interest may arise in the normal course of our business and have established this policy to identify, prevent, and manage such conflicts effectively. Our goal is to ensure that the interests of our clients are always protected and that we operate in a transparent and ethical manner.
Definition · §2
What is a Conflict of Interest?
A conflict of interest arises when the interests of KoveTrade, its employees, or its affiliates may conflict with the interests of our clients. Conflicts can take many forms, including but not limited to:
Financial Interests
Where KoveTrade or its employees may benefit financially at the expense of a client
Personal Relationships
Where personal connections between employees and clients may influence decision-making
Competing Interests
Where KoveTrade provides services to multiple clients whose interests may conflict
Third-Party Arrangements
Where relationships with third parties create incentives conflicting with client interests
Detection · §3
Identifying Conflicts of Interest
KoveTrade maintains robust processes for identifying potential and actual conflicts of interest. All employees are required to be vigilant in recognising situations where conflicts may arise and to report them promptly to the compliance department. We conduct regular assessments of our business activities, organisational structure, and service offerings to proactively identify areas where conflicts may occur.
Section 4 · Resolution
Managing Conflicts of Interest
Identify
Employees spot potential conflicts and report to compliance
Assess
Compliance evaluates severity and potential client impact
Manage
Apply barriers, disclosures, or segregation of duties
Disclose
Inform affected clients clearly before proceeding
Disclosure
We disclose conflicts to affected clients clearly, enabling informed decisions.
Information Barriers
Chinese walls prevent inappropriate sharing of confidential information between departments.
Segregation of Duties
Roles and responsibilities are separated to prevent undue influence over client outcomes.
Declining to Act
Where a conflict cannot be adequately managed, we may decline to provide services entirely.
Best Execution · §5
Order Execution and Best Execution
KoveTrade is committed to achieving the best possible result for our clients when executing orders. Our execution policy takes into account price, costs, speed, likelihood of execution and settlement, order size, and nature. We regularly monitor the effectiveness of our execution arrangements and make improvements as needed.
Internal Controls · §6
Employee Trading & Personal Account Dealing
All KoveTrade employees are subject to strict personal account dealing policies designed to prevent front-running or exploitation of their position to the detriment of clients.
Employees must obtain prior approval before executing personal trades in financial instruments
All personal trading accounts must be fully disclosed to the compliance department
Trading ahead of client orders (front-running) is strictly prohibited
Violations are subject to disciplinary action including termination
Remuneration · §7
Inducements and Remuneration
KoveTrade has policies in place to ensure that remuneration and incentive structures do not create conflicts that could adversely affect the quality of service provided to clients. We do not accept or pay inducements that would conflict with our duty to act in the best interests of our clients. Any fees, commissions, or non-monetary benefits received or paid to third parties are disclosed to clients and are designed to enhance the quality of the service provided.
External Partners · §8
Third-Party Relationships
KoveTrade maintains various relationships with third-party service providers, liquidity providers, and business partners. We carefully manage these relationships to ensure they do not create conflicts of interest that could disadvantage our clients. All third-party arrangements are subject to due diligence and ongoing monitoring by our compliance team.
Oversight
Monitoring & Review
Our compliance department conducts periodic reviews of business activities, employee conduct, and organisational structure. This policy is reviewed and updated at least annually to reflect regulatory changes and best practices.
Documentation
Record Keeping
KoveTrade maintains comprehensive records of all identified conflicts, measures taken to manage them, and any disclosures made to clients. Records are retained per regulatory requirements and are available for inspection by relevant authorities.
Transparency · §11
Disclosure to Clients
Where KoveTrade identifies a conflict of interest that cannot be adequately managed through our internal procedures, we will disclose the nature and source of the conflict to affected clients before undertaking any business with them. This disclosure will be made in sufficient detail to enable clients to make an informed decision about whether to proceed with the relevant service or transaction.
Escalation · §12
Reporting Concerns and Complaints
If you believe that a conflict of interest has adversely affected you, or if you have any concerns about how KoveTrade manages conflicts of interest, we encourage you to report your concerns to our compliance department. All reports will be investigated promptly and thoroughly, and appropriate corrective action will be taken where necessary. You may also file a complaint through our formal complaints process.
Contact our Compliance Department
All reports investigated within 5 business days
Section 13 · Compliance
Regulatory Compliance
This policy has been developed in accordance with applicable regulatory requirements across all jurisdictions in which KoveTrade operates. We are committed to full compliance with all regulatory obligations relating to the management of conflicts of interest.
MiFID II
Markets in Financial Instruments Directive II
EU
FCA
Financial Conduct Authority
UK
CySEC
Cyprus Securities & Exchange Commission
Cyprus
SEC
Securities and Exchange Commission
USA
ADGM FSRA
Financial Services Regulatory Authority
Middle East
Questions about our compliance?
Our compliance department is committed to maintaining the highest standards of transparency and fairness in all dealings with clients.