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Conflicts of Interest

Conflicts Policy – Introduction

As a financial institution, Hantec Markets Limited (hereafter “Hantec Markets”) faces actual and potential conflicts of interest from time to time. By identifying the existing and potential conflicts of interest, Hantec Markets will take all sufficient steps to establish, implement and maintain an effective conflicts of interest policy to prevent or mitigate any risk that may damage the interests of our customers.

This statement discloses the conflicts of interest that you, as an existing or potential customer might face when engaging in business dealings with Hantec Markets; the laws and regulations subject to conflicts of interest that Hantec Markets is required to comply with; and the policy Hantec Markets adopts for the aim of preventing and managing the conflicts of interest.

Laws and Regulations

The FCA recognises that conflicts of interest exist in financial services industry and does not aim to eliminate them. Nevertheless, Principle 8 of the FCA’s Principles for Business (PRIN) sets out that a firm must manage conflicts of interest fairly, both between itself and its customers and between a customer and another customer. Furthermore, the Senior Management Arrangements, Systems and Controls (SYSC) of the FCA handbook, in particular the SYSC 10, firms are required to manage the conflicts so that they do not damage the customers’ interest. Under the Markets in Financial Instruments Directive (“MiFID II”); Hantec Markets is required to maintain and operate effective organisational and administrative controls to take all appropriate steps to identify, prevent or manage conflicts of interest.

Conflicts of Interest Examples

A conflict of interest may arise where our interests or those of a member of our staff could conflict with a duty we have to a client. Part of staff training in this area is to recognise and remediate or escalate potential conflicts in the course of business. However, to help identify potential conflicts of interest, we have considered a number of areas, including the following situations when a firm or a relevant person:

  • is likely to make a financial gain, or avoid a financial loss, at the expense of the customer
  • has an interest in the outcome of a service provided to or a transaction carried out on behalf of the customer, which is different from the customer’s interest in that outcome;
  • has a financial or other incentive to favour the interest of another customer(s) over the interests of the customer;
  • carries on the same business as the customer; or
  • receives or will receive from a person other than the customer an inducement, other than standard commission or fee in relation to a service provided to the customer.

Management of Potential Conflicts Identified

Fees may only be paid/received to/from third parties in line with the specific MiFID tests:

  • The existence, nature and amount of the fee, commission or benefit, or, where the amount cannot be ascertained, the method of calculating that amount, is clearly disclosed to the customer, in a manner that is comprehensive, accurate and understandable, prior to the provision of the relevant investment or ancillary service;
  • The payment of the fee or commission, or the provision of the non-monetary benefit is designed to enhance the quality of the relevant service to the customer;
  • It does not impair compliance with the Firm’s duty to act in the best interests of the customer;
  • And, persons will be prevented from exercising inappropriate influence over the way in which a relevant person carries out services.

Hantec Markets Policy

As required by law, Hantec Markets implements and maintains an effective conflicts of interest policy for the aim of preventing conflicts of interest or potential conflicts of interest from causing a material risk of damage to the interests of customers.

Hantec Markets keeps records of our business activities so that we can identify any conflict that might arise that would have a material risk of damage to the interests of our customers. Hantec Markets’ conflicts of interest policy adopts procedures and measures to manage and control the conflicts of interest identified, including segregation of duties and responsibilities; separate supervision of relevant persons; Personal Account Trading policy, Gifts and Inducement policy, prevention and control of the exchange of information; acting on the best interest of the customers; and in some cases declining to act for a customer or potential customer. These are also monitored on an ongoing basis within the company’s Compliance Monitoring Programme.


Whilst Hantec Markets 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 customer. In such a case, as a solution of last resort, Hantec Markets shall disclose the general nature and sources of conflicts of interest to the customer so that enables the customer to make an informed decision whether to proceed with the transaction in question.


Hantec Markets is devoted to provide more services and products to meet our customers’ demand. At the same time, Hantec Markets frequently reviews and assesses our conflicts of interest policy so that it can ensure the adequacy of such policy in compliance of the FCA rules.

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