1.  Introduction

QuiqTech LLC (hereafter “Abbado” or the “Company”) is a Company incorporated and registered under the laws of Saint Vincent and the Grenadines

The Company is obligated to proactively address, prevent, and handle conflicts of interest effectively. A commitment is upheld to act with honesty, fairness, and professionalism, always prioritizing the best interests of its clients. This commitment extends to strict adherence to legislation and principles governing the provision of investment services and ancillary services.

2. Scope

This policy is inclusive and applies to all individuals associated with the Company, including directors, employees, and any entities directly or indirectly affiliated with the Company (referred to as “related persons”). Its applicability extends across the provision of all Investment and Ancillary Services to every client.

3. Criteria of identifying conflicts of interest

In determining potential conflicts of interest that may arise during the delivery of investment and ancillary services, or a combination thereof, and which could potentially harm a client’s interests, the Company considers, as a minimum criterion, whether the Company, a Relevant Person, or an entity directly or indirectly controlled by the Company, is involved in any of the following situations, whether through the provision of investment or ancillary services, investment activities, or other means:

• The Company or a relevant person has a vested interest in the result of a service provided to the client or a transaction conducted on behalf of the client, and this interest diverges from the client’s interest in the same outcome;
• The Company or a relevant person possesses a financial or other incentive that may lead to prioritizing the interests of another client or a specific group of clients over the interests of the client;
• The Company or a relevant person receives or is expected to receive an inducement from a person other than the client, involving monetary benefits, goods, or services, which goes beyond the standard commission or fee for the provided service;
• the Company or a Related Person engages in the same business as the Client;
• The Company provides a service to a client, and the Company has a significant interest in the outcome of the transaction;
• the Company may act as principal for the client in relation to the transactions;
• A transaction is effected in financial instruments in respect of which the Company may benefit from a commission, fee, or non-monetary benefit payable otherwise than by the Client.

4. Identification of Conflicts of Interest

The Company or an associate may have an interest, relationship, or arrangement that is material in relation to the transaction concerned or conflicts with the Client’s interest. While it is challenging to precisely define or create an exhaustive list of all relevant conflicts of interest, considering the current nature, scale, and complexity of the Company’s business, the following list includes circumstances that constitute or may give rise to a conflict of interest entailing a material risk of damage to the interests of one or more Clients as a result of providing investment services:

• The Company may match the Client’s Order concerning financial instruments (e.g., Contracts for Differences or “CFDs”) with that of another Client by acting on behalf of both the Client and the other Client;
• The Company may have an interest in maximizing trading volumes to boost its commission revenue, a goal that may conflict with the Client’s individual objective of minimizing transaction costs;
• The Company’s bonus system may reward its employees based on factors such as trading volume;
• The Company may receive or pay inducements to or from third parties as a result of referring new clients or clients’ trading activities, introducing a potential conflict of interest.

It is important to note that the circumstances mentioned above, which constitute or may give rise to a conflict of interest, are not inherently detrimental to the interests of clients.

5. Procedures and Controls for Managing Conflicts of Interests

In general, the Company implements various procedures and controls to effectively manage identified conflicts of interest. These measures include, but are not limited to:

• Implementing effective procedures to prevent or control the exchange of information between relevant persons engaged in activities posing a risk of conflict of interest, particularly when such exchange may harm the interests of clients;

• Separately supervising relevant persons whose principal functions involve activities on behalf of or services to clients with potential conflicting interests;

• Removing any direct link between the remuneration of relevant persons primarily engaged in one activity and the remuneration or revenues generated by different relevant persons engaged in another activity where a conflict of interest may arise;

• Implementing measures to prevent or limit inappropriate influence over the way a relevant person carries out investment or ancillary services or activities;

• Establishing a policy to limit conflicts of interest arising from the giving and receiving of inducements;

• Implementing walls to restrict the flow of confidential and inside information within the company and ensuring physical separation of departments;

• Establishing procedures governing access to electronic data;

• Implementing segregation of duties to prevent conflicts of interest when carried out by the same individual;

• Prohibiting external business interests conflicting with the company’s interests for its officers and employees unless approved by the Board of Directors;

• Establishing an in-house Compliance Department to monitor and report on conflicts of interest to the Board of Directors;

• Implementing a “need-to-know” policy for the dissemination of confidential or inside information within the company;

• Appointing an Internal Auditor to ensure the maintenance of appropriate systems and controls and report to the Board of Directors;

• Implementing measures to prevent or control the simultaneous or sequential involvement of a Related Person in separate investment services where such involvement may impair the proper management of conflicts of interest;

• Conducting ongoing monitoring of business activities to ensure that internal controls are appropriate;

• Establishing a Personal Transactions Policy;

• Requiring staff members to immediately notify the Company if they perceive that a conflict of interest may arise due to the undertaking of a specific task or work;

• Prohibiting the provision of advice or recommendations on transactions;

• Prohibiting staff members from accepting gifts, promotions, discounts, or any other monetary or non-monetary benefits from clients or third parties that may create conflicts of interest. Acceptance of gifts of low value may be allowed after approval from the Company;

• Establishing the “four-eyes” principle in supervising the company’s activities.

In circumstances not covered by the points above and given the nature of a conflict of interest situation, the Compliance Officer and/or Senior Management shall decide whether to allow a transaction by notifying the client or not allow the transaction altogether.

6. Client Consent

By entering into a Client Agreement with the Company for the provision of Investment Services, the Client is expressing consent to the application of this Policy. Additionally, the Client consents to and authorizes the Company to handle the Client in any manner deemed appropriate, irrespective of any conflict of interest or the presence of any material interest in a transaction, without prior consultation with the Client. In cases where the Company encounters difficulties in addressing a conflict-of-interest situation, it will inform the Client accordingly.

7. Disclosure of Information

If during the course of a business relationship with a Client or group of Clients, the existing organizational or administrative measures are deemed insufficient to prevent or address a conflict of interest concerning that Client or group of Clients, the Company will disclose the conflict of interest before engaging in further business with the Client or group of Clients.

8. Amendment of the Policy and Additional Information

The Company retains the right to periodically review and/or modify its Policy and arrangements whenever it deems necessary, without providing prior notice to the Client. For additional information or if you have any inquiries regarding conflicts of interest, please address your requests and/or questions to info@abbado.com.