Conflicts of interest

As part of our commitment to adhere to the highest ethical standards and to be as transparent as we can about how we do business, we have established systems and processes that allow us to identify, prevent or manage any conflicts of interest which may arise when we provide services to our customers. 

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What do we mean by conflicts of interest?

Conflicts of interest can arise where our interests or the interests of our staff might conflict with our customers’ interests. They can also happen where our staff’s interests come into potential conflict with Freetrade’s interests.

Some examples of potential conflicts that could occur would be where we could:

• try to make a financial gain (or avoid a financial loss) at the expense of our customers;
• receive a benefit from a third party / intermediary, whether financial or non-financial, to use that  third party / intermediary for execution of customer orders or otherwise providing services to our customers
• have a financial, or other incentive to favour the interest of one customer, or group of customers, over the interests of another

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How do we prevent or manage conflicts of interest?

Firstly, by design. We’re building Freetrade for our customers and that remains our priority. That’s why we always try our very best to design and develop our product and operations in such a way that conflicts of interest are avoided. 

Secondly, we establish policies and procedures to ensure conflicts of interest are identified, managed and mitigated. We strive to address conflicts in a fair, equitable and transparent manner, consistent with the best interests of our customers. We deal with and manage relevant conflicts as follows:

• We will avoid conflicts that are prohibited by law, as well as conflicts that cannot be effectively addressed. 
• We will manage acceptable conflicts by applying internal controls and review processes.
• Where relevant, we will provide customers with information regarding certain conflicts, so that they are able to independently assess their significance when evaluating our products and services.

We keep a record of all identified conflicts of interest and monitor these to ensure that they are managed correctly. Where we are unable to put in place controls that are sufficient to mitigate the material risk or damage to a customer’s interests, we will disclose this conflict to the customer before carrying out any business on their behalf.

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Order execution

We execute your orders in accordance with our Order Execution Policy. 

We do not receive financial or non-financial benefit from any trade execution venues or counterparties in return for sending our customers’ orders to them (sometimes known as ‘payment for order flow’). 

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Investments offered

We offer stocks, ETFs and investment trusts, which are traded on trading venues. We do not receive any financial or non-financial benefit from the issuer of these investments, or anyone acting on the issuer’s behalf, for offering or promoting products.

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Gifts and hospitality

Employees are not permitted to accept gifts, hospitality or other benefits that might be in  conflict with our obligation to act in the best interests of our customers.

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Personal Account Dealing

We have policies and procedures in place to monitor personal trading of all employees.

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Proxy voting

Freetrade will receive payments from Say Technologies LLC related to the proxy voting service we are providing to our customers. The payments are originally paid by the issuers of the shares and are intended to cover expenses incurred in processing and forwarding proxy material, annual reports and information statements to you as the underlying investor. The amounts of these payments may change over time but will always be paid in line with FINRA rules, which breaks down the specific fee schedule. You can find the FINRA rules here.

The actual amount we receive in relation to an individual customer will be variable on the number of positions the customer holds, whether the holding is more than 1 whole share, how many meetings / special meetings / special mailings the company has, and the date at which the customer holds the share (i.e. its only paid on the date the proxy is sent out). Say Technologies LLC will keep part of the original payments from the issuing companies.

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