This Conflict of Interest Policy (“Policy”) outlines how Riyadex Financials (Pty) Ltd. (“the Company”, “we”, “us”) identifies, prevents, manages, and discloses potential conflicts of interest in relation to its business activities as a South Africa FSCA-regulated provider of Forex and CFD trading services.

This Policy forms part of the Client Agreement.

1. PURPOSE OF THIS POLICY

The purpose of this Policy is to:

  • Protect the interests of all clients
  • Ensure fairness, transparency, and integrity
  • Comply with South Africa FSCA regulatory requirements
  • Outline the Company’s procedures for identifying and managing conflicts

2. DEFINITION OF CONFLICT OF INTEREST

A conflict of interest may arise when:

  • The Company’s interests conflict with a client’s interests
  • One client’s interests conflict with another client’s interests
  • An employee’s personal interests conflict with those of the Company or clients

Conflicts may be actual, potential, or perceived.

3. COMMON TYPES OF POTENTIAL CONFLICTS

The following situations may give rise to conflicts of interest:

3.1 Company vs. Client Conflicts

  • Acting as counterparty to client trades
  • Pricing and execution differences
  • Offering bonuses or promotions that may encourage excessive risk-taking
  • Liquidity management decisions
  • Risk mitigation and trade rejection during unusual market conditions

3.2 Client vs. Client Conflicts

  • Different pricing or execution speeds for different clients
  • Allocation of liquidity in fast-moving markets
  • Volume-based rebates or commissions received by partners/IBs

3.3 Employee Conflicts

  • Employees trading for personal accounts
  • Employees having knowledge of client positions
  • Undue influence of sales staff encouraging risk-taking
  • Financial incentives tied to client trading volumes

3.4 Third-Party Conflicts

  • Use of Introducing Brokers (IBs)
  • Affiliates earning commissions from client trades
  • Technology providers influencing execution

4. METHODS FOR IDENTIFYING CONFLICTS

The Company identifies conflicts through:

  • Ongoing monitoring of business processes
  • Internal audits and compliance checks
  • Analysis of pricing, execution, and trade flow
  • Employee disclosures and annual declarations
  • Monitoring third-party relationships

5. MEASURES TO MANAGE & PREVENT CONFLICTS

RIYADEX implements several measures to reduce the risk of conflicts negatively impacting clients.

5.1 Segregation of Duties

Where reasonable, the Company segregates:

  • Risk management
  • Trading execution
  • Compliance monitoring
  • Sales/marketing
  • Back-office operations

5.2 Transparent Pricing & Execution

  • Prices are sourced from reputable liquidity providers
  • No artificial price manipulation
  • Orders are executed based on market conditions and available liquidity

5.3 Employee Trading Restrictions

  • Employees must disclose personal trading accounts
  • Employees may be restricted from trading leveraged products
  • Employees cannot misuse client information

5.4 Remuneration Policies

  • Employees are not compensated in ways that encourage client abuse
  • Sales incentives are controlled to prevent aggressive or misleading practices
  • IB/affiliates are monitored for compliance with ethical conduct

5.5 Monitoring & Compliance Oversight

  • Ongoing monitoring of trade execution
  • Identification of suspicious patterns
  • Regular reviews of internal processes
  • Compliance officer oversight

6. AVOIDANCE OF CONFLICTS

Where conflicts cannot be managed or mitigated, the Company may:

  • Decline to act
  • Restrict certain activities
  • Prevent certain staff from involvement
  • Terminate a relationship with a third party

7. DISCLOSURE OF CONFLICTS

If a conflict cannot be adequately mitigated, the Company will:

  • Disclose the conflict to the affected client
  • Provide clear information so the client can make an informed decision
  • Offer alternative arrangements where possible

The Company will never rely solely on disclosure as the primary method of conflict management.

8. CLIENT RESPONSIBILITIES

Clients are expected to:

  • Provide truthful and accurate information
  • Understand the risks associated with leveraged trading
  • Ensure third-party partners (IBs, account managers) are trusted and authorized
  • Avoid engaging in abusive or manipulative practices

9. RECORD KEEPING

RIYADEX maintains records of:

  • Identified conflicts
  • Measures taken to resolve them
  • Employee declarations
  • Third-party agreements
  • Policy reviews and updates

Records are kept in accordance with FSCA requirements.

10. POLICY REVIEW

This Policy is reviewed:

  • Annually
  • When material changes occur in business operations
  • When regulatory requirements change
  • Following internal or external audit recommendations

Updated versions will be published on the Company website.

11. CLIENT CONSENT

By accepting the Client Agreement and using RIYADEX services, the Client:

  • Confirms they have read this Policy
  • Understands the potential for conflicts of interest
  • Consents to the Company’s methods of handling such conflicts