01 Policy Statement
Sun Capital FX is committed to acting in the best interests of our clients. Where conflicts of interest cannot be avoided, they must be identified, managed, and disclosed appropriately. This policy is designed to prevent conflicts from adversely affecting client outcomes.
02 Identifying Conflicts
A conflict of interest arises when Sun Capital FX, an employee, or an affiliate has an interest that could compromise, or appear to compromise, the fair treatment of a client. Conflicts may be:
- Actual — an existing conflict;
- Potential — a conflict that may arise;
- Perceived — a situation that could reasonably be perceived as a conflict.
03 Common Conflicts
Given our business model, the following conflicts are most relevant:
- Principal vs. agent — we act as counterparty to some CFDs while also owing you best execution;
- Revenue from client losses — some CFD models profit from client losses. Sun Capital FX operates a STP/A-book model where we offset exposure with liquidity providers, aligning our interests with yours;
- Commercial incentives — we may receive rebates from venues or LPs. These are monitored to ensure they don't compromise execution quality;
- Personal dealing — employees trading for their own accounts;
- Gifts and entertainment — received from or given to third parties.
04 Organizational Safeguards
We maintain the following controls to manage conflicts:
- Information barriers between trading, compliance, and client-facing teams;
- Segregation of duties — no single individual controls end-to-end processes;
- Independent compliance function reporting to the Board;
- Remuneration policy that does not incentivise mis-selling or unfair treatment;
- Conflicts register maintained and reviewed quarterly.
05 Personal Account Dealing
Employees and their close associates may not:
- Trade on the basis of non-public information;
- Front-run client orders;
- Trade in instruments they know a client is about to trade;
- Use company systems for personal trading without pre-approval.
All personal trades require pre-clearance and are logged. Certain roles are subject to trading restrictions or outright prohibition.
06 Gifts and Inducements
Employees may not accept gifts, entertainment, or inducements that could improperly influence business decisions. A register of gifts above a nominal value ($100) is maintained and reviewed by Compliance.
Third-party inducements paid to or received by Sun Capital FX must be disclosed to clients and must enhance the service provided — they may not impair best execution.
07 Disclosure
Where a conflict cannot be managed by our organizational or administrative controls, we disclose it to you clearly before you trade. Disclosure includes:
- The nature of the conflict;
- The risks it presents to your interests;
- The steps we've taken to mitigate it.
08 Monitoring and Training
All employees complete annual conflicts-of-interest training. The Compliance team monitors for breaches using trade surveillance, gift register reviews, and access controls. Any breach is subject to disciplinary action up to and including termination.
09 Client Consent
By opening an account with Sun Capital FX, you acknowledge that you have received this Conflicts of Interest Policy and consent to the disclosure of conflicts as described. You may withdraw consent at any time by closing your account.
10 Review
This policy is reviewed at least annually and updated as business activities or regulations change. Material changes will be notified to clients via the client portal or email.