Conflicts of Interest Policy
3.1 Purpose. AvexFx must identify, prevent, manage and disclose conflicts between itself and its clients, and between one client and another. This summary is provided to clients; the full policy is maintained internally and available on request.
3.2 The central conflict. We act as counterparty to your trades, so your loss may be our gain. This is the most significant conflict in our business and it is inherent in the model, not incidental to it. We manage it by netting opposing client positions against each other, hedging residual exposure with external liquidity providers under board-approved limits, separating the dealing function from sales, automating execution so that no dealer has discretion over an individual client’s fill, and monitoring execution quality against the measures set out in the Order Execution Policy. We do not manage it by relying on goodwill.
3.3 Conflicts we have identified.
Conflict | Why it arises | How it is managed |
|---|---|---|
Principal dealing | We profit when clients lose | Hedging and board-approved exposure limits; dealing separated from sales; execution automated, with no dealer discretion over individual fills |
Spread and mark-up setting | We set the price clients trade at | Mark-ups published; pricing set centrally, not per client; no discretionary widening for individuals |
Introducing brokers and affiliates | Paid on volume or on client losses, so incentivised to encourage overtrading | Introducing brokers are paid a share of the spread or commission generated by the clients they refer. That basis is disclosed to referred clients at referral, and introducing brokers are prohibited from advising clients, managing accounts or trading on a client’s behalf. |
Staff remuneration | Bonuses tied to revenue push staff toward client volume | Remuneration not linked to individual client outcomes; sales staff not compensated on client losses |
Bonuses and promotions | Incentivise deposits and volume against client interest | See 3.4. |
Personal account dealing | Staff may trade the same instruments | Pre-clearance, monitoring, blackout rules, no dealing ahead of client orders |
Order handling | Discretion could favour one client over another | Sequential handling; no aggregation that disadvantages a client; audit trail retained |
Gifts and inducements | Third parties may seek to influence staff | Register maintained; threshold above which acceptance is prohibited |
Group entities | Business passed between AvexFx entities on different licences | Each entity’s role disclosed; client told which entity holds their account |
Outsourced providers | Platform, payment and data providers may have their own interests | Due diligence and contractual terms |
3.4 The bonus promotion. Your homepage currently leads with “Get a 100% bonus and boost your trading power from day one”. Deposit bonuses on leveraged products for retail clients are prohibited under CySEC and ESMA rules and restricted in several other jurisdictions. If a CySEC-authorised entity is named anywhere on the site, this promotion is inconsistent with it. Either withdraw the offer, or scope it explicitly and only to the non-EU entity, with eligibility terms published and geo-restriction enforced at signup.
3.5 Management measures. We maintain organisational and administrative arrangements including: separation of functions and information barriers between dealing, sales and support; a remuneration policy that does not create a direct link between the pay of staff in one function and revenue generated by another whose clients they could disadvantage; rules on personal account dealing; a gifts and inducements register; and independent compliance oversight reporting to the board.
3.6 Disclosure. Where our arrangements are not sufficient to ensure with reasonable confidence that a risk of damage to your interests will be prevented, we disclose the specific conflict to you, in durable form and in enough detail for you to make an informed decision, before we act for you. Disclosure is a last resort, not a substitute for managing the conflict.
3.7 Declining to act. Where a conflict cannot be managed or adequately disclosed, we decline to act.
3.8 Marketing communications and research. Our communications must be fair, clear and not misleading, and must not present a promotion as though it were information. This applies to the website, market commentary, social media, email, and anything an affiliate publishes on our behalf.
Testimonials must come from real, identifiable clients who have consented in writing, must not reference profits or imply a typical result, and must carry attribution a reader can assess. Market analysis and educational material must not be framed so as to encourage trading volume for its own sake, and must carry the risk warning. Where we or our staff hold a position in an instrument we publish commentary on, that interest is disclosed alongside the commentary.
3.9 Register and review. We maintain a register of the kinds of service in which a conflict has arisen or may arise, recording the circumstances and the action taken. The register and this policy are reviewed at least annually and on any material change to the business. Last reviewed 21 September 2026.
