MarketMates Conflicts of Interest Policy

MarketMates Limited (“MML”,”MarketMates,” “we,” “us,” or “our”) recognises the potential for conflicts of interest to arise in our business operations. This policy outlines our commitment to identifying, managing, and disclosing conflicts of interest to ensure fair treatment of our customers.

Laws and Regulations

MML is licenced by the Mauritius Financial Services Commission (‘FSC’) under the Securities Act 2005, and adheres to the FSC’s Code of Business Conduct and Guidelines on Managing Conflicts of Interest.

Identification and Examples of Conflicts

Conflicts of interest may arise between MML and our customers, or between customers. Examples may include:

  • Employee knowledge or access to information that could influence customer decisions
  • Financial incentives to favour one customer over another
  • Personal trading activities by employees
  • Receipt of inducements from third parties
  • Business activities that compete with customer interests

MarketMates Limited Policy

We maintain an effective Conflict of Interest Policy to prevent material risks to our customer’s interests. The policy covers:

  • Segregation of duties and responsibilities
  • Separate supervision of relevant personnel
  • Personal Account Trading Policy
  • Gifts and Inducement Policy
  • Prevention and control of information exchange
  • Acting in the best interest of customers
  • Declining to act for a customer or potential customer if necessary

Disclosure

If our policy cannot sufficiently prevent risks of damage to our customers’ interests, we will disclose the general nature and sources of conflict to enable informed decision-making.

Register of Interests

We maintain a register of interests, updated regularly, to record and manage conflicts of interest.

Accountability

All staff, management, senior and executive management are accountable for adhering to this policy and reporting any breaches.

Avoiding Conflicts of Interest

We proactively avoid conflicts of interest by:

  • Maintaining high standards of integrity
  • Communicating policies and procedures
  • Ensuring fair treatment of clients
  • Prioritising client interests
  • Making timely disclosures
  • Establishing information barriers
  • Restricting transactions where appropriate

Effective Mechanism

The Board of Directors will review and update this policy periodically to ensure effective implementation.

Audit Committee

The Audit Committee is responsible for reviewing and approving conflicts of interest and related-party transactions

Personal Conflicts of Interest

We have policies in place for anti-bribery, personal account dealing, and disclosure of staff members’ personal relationships.

Business Conflicts of Interest

We have policies in place for sponsorships, investment independence, commission sharing, and fair treatment of clients.

Segregation of Funds

We ensure that client funds are segregated from our proprietary funds.

Disclosure of Multiple Roles

We disclose and manage multiple roles within the Company to avoid conflicts of interest.

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