This document sets our Conflicts Policy which we maintain in order to manage conflicts of interest in respect of the duty of care we owe to our clients.
ITG Investing LTD (“the firm”) is legally required to take all steps that are reasonable to identify any conflicts of interest that may occur between the firm, its employees, its clients and any associated third parties or affiliates.
Above all, the interests of the clients are paramount. Every effort will be made to ensure that all clients are treated fairly and professionally.
In the event of a potential conflict where more than one client has an order in the same market, the trades will be filled on a first come, first served basis.
The firm, its employees or any third party associates should not benefit directly from any conflict of interest, apart from its normal business.
You accept that while every effort will be made to ensure no conflict occurs, if there is a time when a conflict occurs, it will be managed professionally and recorded.
Compliance will review the firm’s procedures from time to time.
The following are examples of material interests and conflicts of interest which may occur during the course of our dealings with you:
We may execute hedging transactions, which may impact on the price you pay or receive in relation to such orders.
We may act as principal in trades which you enter into.
We may pay to and accept from third parties (and not be liable to account to you) benefits, commissions or remunerations which are paid or received as a result of orders conducted by you.
Staff at the firm, may on occasion, accept small gifts or hospitality from third parties associated with the business. At no time will this affect or impair their ability to act in the best interest of our clients.