Conflicts of Interest Policy

CONFLICTS OF INTEREST POLICY

The trades.com website is owned by Credos d.o.o. (“Credos”), which is an investment firm regulated by the Croatian Financial Services Supervisory Agency. In accordance with the European Union’s Markets in Financial Instruments Directive (“MiFID”), Credos is required to provide data on its approach to conflicts of interest and its policy with regard to the fair management of any conflicts of interest: both between Credos, our directors, employees and our clients, and between your interests and those of Credos’ other clients.

CONFLICT OF INTEREST DEFINITION

Credos classifies a conflict of interest as any scenario in which either Credos or an individual is in a position, in some manner, to take advantage of an official or professional capacity for personal or corporate benefit.

CONFLICT OF INTEREST PROTOCOLS

Far-reaching measures have been adopted by Credos to avert, and control the exchange of information between relevant individuals engaged in activities that entail the risk of a conflict of interest. For example, Credos has prevented any direct link between the  remuneration of relevant individuals principally engaged in one specific activity and the remuneration of other relevant individuals principally engaged in another  specific activity.

CONFLICT OF INTEREST DISCLOSURE

When the measures Credos has undertaken to manage conflicts of interest are insufficient to assure, with reasonable certainty, that the risk of harm to clients’ interests will be averted, Credos will disclose the conflicts of interest to the client so as to avert a risk of harm to clients’ interests. Before executing a transaction or delivering an investment or ancillary service to a client, Credos must disclose any potential or actual conflict of interest. The disclosure will be within a sufficient time frame via durable means.

RECORD MAINTENANCE

Credos keeps a regularly updated record of the types of investments and ancillary services or investment activities carried out by Credos, or on its behalf, in which a conflict of interest involving a material risk of harm to the interests of one or more clients has occured