Conflicts of Interest Policy

Information regarding nuntius’s conflicts of interest policy

1. General Information
   1. Purpose of this document
      By this document, NUNTIUS provides to you information regarding the policy that it has implemented in order to comply with the requirements to have appropriate procedures and policies in order to avoid and/or manage situation of conflicts of interests that may occur during the provision of investment and ancillary services to its clients, in accordance with the applicable legal and regulatory framework.
   2. Regulatory Framework
      For the above purpose, NUNTIUS has established and applies a number of measures and procedures for the avoidance and management of conflicts of interests (hereinafter the “Conflicts of Interests Policy” or the “Policy”) pursuant to, and in compliance with the requirements of Directive 2014/65/EU of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments and amending Directive 2002/92/EC and Directive 2011/61/EU (“MiFID II”), the Greek Law no 4514/2018 regarding the provision of investment services, the exercise of investment activities and the operation of regulated markets which transposed MiFID II into Greek legislation and Delegated Regulation (EU) 2017/565 supplementing Directive 2014/65/EU of the European Parliament and of the Council as regards organisational requirements and operating conditions for investment firms and defined terms for the purposes of that Directive. The said Policy complies as well with Section 9 of the Questions and Answers Document of the European Securities and Markets Authority (“ESMA”) issued on 11 October 2016 with reference ESMA/2016/1454 with respect to the provision of CFDs and other speculative products to retail investors. In this document, we collectively refer to all the above legislations, regulations and guidelines as “Regulations”.
   3. Scope and function of the Conflicts of Interest Policy
      NUNTIUS applies measures and policies appropriate to its size and organization and to the nature, extent and complexity of its activities, in order to avoid or manage conflicts of interest situations and to ensure that
      1. its members of the Board of Directors, partners or equivalent, managers or tied agents (if any),
      2. the members of the Board of Directors, partners or equivalent or managers of tied agent (if any)
      3. NUNTIUS’s employees or the employees of NUNTIUS’s tied agents (if any), as well as any other natural person, whose services are placed at the disposal and under the control of NUNTIUS or a tied agent thereof who is involved in the provision by NUNTIUS of investment services or/and the performance of investment activities
      4. any natural person who is directly involved in the provision of services to NUNTIUS or its tied agents under an outsourcing arrangement for the purpose of the provision by NUNTIUS of investment services or/and the performance of investment activities (hereinafter: “Relevant Persons”) handle the clients with a fair and objective manner and that they behave with the required impartiality. The information provided through this document focuses on the prevention of conflicts of interests in the context of the provision of services related to the execution of orders in FX and CFD products outside regulated markets, MTFs or OTFs.
2. Content of the conflicts of interest policy
   1. Definition of conflict of interest
      NUNTIUS defines a conflict of interest as any situation where there is a conflict between the interests of NUNTIUS or certain persons connected to NUNTIUS and the duty we owe to a client or between the differing interests of two or more of our clients, to whom NUNTIUS owes in each case a duty, with a potential result to ensure a gain or benefit to NUNTIUS, or any connected person or any particular client at the detriment of another client.
   2. Potential situations of conflicts of interests
      1. Persons whose interests may be in conflict Conflicts may arise either during the provision of investment and/or ancillary services or a combination thereof or with any other manner between:
         1. the interests of NUNTIUS or any Relevant Person or as well as any person connected directly or indirectly with them with a relation of control and the interests of one or more of its clients or
         2. the interests of different clients of NUNTIUS
      2. Potential sources of conflicts Such situations may occur when NUNTIUS (or any other Relevant Person) may have a financial benefit or avoid a financial loss, to the detriment of one or more clients or to favor the interests of one client or group of clients against those of another client. This may happen if NUNTIUS: - Has, in relation to the result of a service provided to the client or a transaction carried out on behalf of the client, an interest different than the interest of the client. - Has a financial or other motive to favour the interests of another client or another group of clients to the detriment of the client. - Carries out the same business activity with the client. - Receives or will receive from the client or from a third party a benefit in relation to the service, in the form of money, goods or services, which exceeds the level of the usual commission or remuneration for such a service.
   3. Examples of potential situations of conflict and relevant measures
      Conflicts of interest may arise in several situations during the provision of services. NUNTIUS has identified a number of such potential situations in advance and has taken appropriate steps to assess the risk of their occurrence and, when such risk exists, to avoid them proactively. In some cases, the way in which NUNTIUS is organized and provides its services to clients (provided that all relevant internal procedures are applied), may sufficient to prevent the appearance of situations of conflict that would otherwise be considered possible. In other cases, NUNTIUS has adopted ad hoc arrangements to make sure that specific kinds of situations will not occur or will be identified and addressed in due time. In particular, NUNTIUS has adopted effective procedures (including remuneration policies) to prevent or control the exchange of information between relevant persons engaged in activities involving a risk of a conflict of interest, to ensure the separate supervision of activities bearing a risk of material conflicts of interests, to remove direct links between the remuneration of Relevant Persons principally engaged with one activity and the remuneration of different Relevant Persons principally engaged in another activity, to avoid incentives that may lead Relevant Persons to favor their own interests or the company's interests to the potential detriment of any client and to ensure the fair treatment of clients, to prevent or limit any cases of inappropriate influence over the exercise of any particular activity and to control the simultaneous or sequential involvement of any person in separate investment or ancillary services. Taking into account the activities currently exercised by NUNTIUS in the context of services that may be provided to you, you may find below some indicative examples of situations that could potentially give rise to conflicts of interest, as well as the relevant measures taken by NUNTIUS for the avoidance of such situations:

Examples of potential situations of conflict	General arrangements or ad hoc measures
NUNTIUS or a Relevant Person may have an interest in executing its/his personal orders or orders of a client in more favorable conditions than the orders of another client, or in maximizing the client’s losses (e.g. if the client is a competitor of NUNTIUS or of the Relevant Person)	NUNTIUS has implemented policies and procedures for the monitoring and (when necessary) restriction of personal transactions of the Relevant Persons. Transactions are processed through automated means, based on the time priority of the reception of such order, thus ensuring that the relevant employees will not be allowed to intervene in your transactions. Conflicts related to the personal capacity of the Client are reported to the compliance function as soon as they are identified.
A Relevant Person may have an interest in recommending to a client a particular transaction, in respect of which NUNTIUS or the said Relevant Person may receive a benefit from a third party or taking into account the interests of another client. A Relevant Person may recommend to the client a transaction based exclusively on the remunerations to be received by NUNTIUS or by the employee.	NUNTIUS does not provide investment advice with respect to FX and CFDs transactions and thus cannot recommend you any particular transactions.
NUNTIUS may be regarded as having an interest in maximizing your trading volumes or in maximizing your losses in order to achieve higher remunerations.	The remuneration that NUNTIUS receives for the execution of your transactions, may depend either on the volume of your transactions (when a Liquidity Provider remunerates NUNTIUS by providing a percentage of the spread of your trades) or on the amount of your losses (when a Liquidity Provider trading on its own account against your positions remunerates NUNTIUS based on the profits generated by the Liquidity Provider from your trades and therefore from the amounts that you lose when trading through NUNTIUS). However: - NUNTIUS does not provide investment advice to you with respect to your trades on the financial products available in our platforms and, thus, cannot recommend you any particular transactions.  - Transactions are processed through automated means, based on the time priority of the reception of such order, thus ensuring that the relevant employees will not be allowed to intervene in your transactions - NUNTIUS does not have a way to influence the outcome of your transactions and the persons in charge of the supervision of the processing of your orders (Dealing Desk) are always remunerated with fix amounts and not based on your trading volumes or losses. - NUNTIUS monitors regularly the operation of the systems used for the processing of clients’ orders in a way to exclude any human intervention that is not necessary for the normal operation of such systems. - In all cases, when NUNTIUS’s remuneration depends on the revenue of a Liquidity Provider, the relevant arrangements are made in a way that such remuneration is not calculated on a client-by-client basis, but based on the total PNL of our clients’ positions with the relevant Liquidity Provider, which means that the outcome of your transactions is not directly linked to our remuneration. It is noted as well that NUNTIUS is not part of any group of companies in which could be part any of our Liquidity Providers, which means that NUNTIUS does not have any further interests in the profits realized by the relevant Liquidity Provider. - In accordance with the applicable best execution policy, NUNTIUS is prohibited from directing your transactions to an Execution Venue based on the remunerations to be received by NUNTIUS.

In addition to all the above measures, NUNTIUS has an internal audit function and a compliance function which are in charge of controlling the application of NUNTIUS’s legal and/or regulatory obligations and internal procedures, including the above measures and the satisfaction of the requirement to avoid situations of conflicts of interest.
3. DISCLOSURES AND RECORDS
   1. Disclosure of conflict of interest
      When the measures taken by NUNTIUS to avoid or manage situations of conflicts of interest are not sufficient to ensure, with reasonable confidence, that the risk of damage to clients’ interests will be prevented, NUNTIUS will disclose to the client the specific conflict of interest and the steps taken to mitigate the risks associated thereto, with a durable medium, before providing the service affected by the situation of conflict.
   2. Record keeping
      Nuntius maintains a record, which is regularly updated, of the kinds of investments and ancillary services or investment activities carried out by Nuntius or on its behalf in which a conflict of interest entailing a material risk of damage to the interests of one or more clients has arisen.
   3. Review
      NUNTIUS carries out regular internal review of the measures and procedures applied to ensure that they remain appropriate, effective, comprehensive and proportionate to the nature, scale and complexity of its business activities, especially in terms of the nature and the range of the investment services and activities it undertakes in terms of its business activities, and that appropriate measures for the correction of any deficiencies will be taken without undue delay.