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Interactive Brokers Ireland Limited Summary of the Conflicts of Interest Policy
The Conflicts of Interest Policy ("Policy") is issued pursuant to the European Directive
2014/65/EU of 15 May 2014 on markets in financial instruments.
Interactive Brokers Ireland Limited
("IBIE") is committed to its general
obligation to act with integrity and fairness towards its clients.
The Policy complements
IBIE's overall general
obligation and sets out how IBIE
conflicts of interest where
brokerage services to its clients.
This document summarises the general circumstances which may give rise to a conflict of interest entailing a
material risk of damage to the interests of one or more clients, and specifies
has adopted in order to prevent and manage
such conflicts, taking also into account the
relationships with other members of the Interactive
Brokers group ("IB Group").
provides execution-only electronic brokerage services to its clients. IB does not employ any
human "brokers" that manage client accounts. All trading in an IB client account is self-directed by
the client or, if the client notifies IB in writing, by an independent advisor or other third-party
selected by the client.
IB customer service personnel are specifically prohibited from providing any investment or
trading or tax
advice to customers.
Customers (or the third-parties clients authorise to trade for them) enter their trades online and
are then transmitted over the internet to IB for execution on various exchanges and
market centres. These
trades are then executed against other market participants on the open
es not take the other side of client trades or engage in proprietary trading, offer
advice, engage in corporate finance business, mutual funds or managed investment
generally not affected by fluctuations in prices of particular
products or markets.
IBIE's risk management system seeks to ensure that each customer's positions are continuously
checked and brought into margin compliance if account equity falls short of margin
requirements in order to
resolve margin deficiencies and prevent account deficits that could
potentially affect IB or its customers.
IDENTIFICATION OF CONFLICTS OF INTEREST
In view of the nature of the
business model, services offered and activities performed,
steps to identify, prevent and manage circumstances which may give rise to
material conflicts with
respect to the relationships such as those between: (i) two clients; (ii)
clients and IBIE; (iii)
IBIE and IB Group companies; (iv) employees of
or its group companies, or
any person directly or indirectly linked to
or its group companies by control. In particular,
considers parties who
are likely to make a financial gain, or avoid a financial loss, at the expense of the client;
have an interest in the outcome of a service provided to the client or of a transaction carried
out on behalf of the client, which is distinct from the client's interest in that outcome;
have financial or other incentive to favour the interest of one client or group of clients over the
interests of another
client or group of clients;
carry on the same business as the client; or
receive money or non-monetary benefits like goods or services from a third party in relation
to a service provided
to the client other than the standard fees and commissions or
otherwise benefit from IBIE's own remuneration
and incentive structures to have a potential
conflict of interest with
IBIE POLICIES TO PREVENT AND MANAGE ANY POTENTIAL CONFLICTS OF INTEREST
has identified a range of circumstances which may give rise to a potential conflict of interest,
none of which are a material risk to IBIE
clients. These potential conflicts are prevented or managed by the following
measures and controls:
Best execution policy
has implemented the following measures to meet its best execution obligation to act in clients'
interests when executing clients' orders.
Execution Venue Selection
The venue selection criteria are unrelated
to any rebate or incentive for
or any of its affiliates.
related to the routing of orders and products offered on a single venue or hedged with
sole liquidity providers are
made after considering the integrity of the arrangement and its adequacy
to avoid any conflict of interest arising.
In the event that a manual order entry is necessitated by significant business disruption or
otherwise covered in our continuity plan,
will allow for execution in accordance
with the time of the order
reception and carry out comparable client orders sequentially and
promptly unless the characteristics of the
order or prevailing market conditions make this
impracticable, or the interests
of the client require otherwise.
Inducement and Remuneration Structure of Intermediary and Referrers
IBIE's commission structure is independent from the charging structure of any intermediary.
receives no rebate from nor provides any incentive to, any intermediary with respect to any clients'
Charging Structure of Referral scheme
Clients are made aware of any arrangement in which a third-party is paid a fee for referring the
client to IB. This
referral fee is either a one-time
payment or payable for accounts maintained over a
Third Party Research
and its affiliates provide research produced by third parties. Care is taken to ensure that the
structure applicable to the client is transparent and does not create any incentive to
clients. There is no
direct link between the content of any research and
IBIE's charging structure.
Code of Conduct of IBIE Employees
Gift and Entertainment
IBIE has in place policies and procedures for the acceptance of gifts and entertainment which applies to all IBIE employees.
IBIE's structure for compensating employees does not give incentives to activities that may conflict
interest of the client or reward behaviours that disadvantage the interests of our clients in
Outside Business Activities
All employees are required to identify and obtain approval to engage in certain types of outside business interests.
Standards of Conduct and Confidential Information
All employees are prohibited from disclosing confidential information and from using such
information for their
own interests. Where some employees within the IB Group may provide
IBIE, an appropriate
degree of separation and independence is maintained when these
employees provide support in the area of
work delegated to them.
Personal Account Dealing Regulations and Procedure
All employees are required to identify personal trading accounts and are prohibited from engaging in certain types of transactions for their personal accounts.
Where required, IB has established adequate information barriers (i.e. Chinese Walls) between IB proprietary trading affiliates and IB customer brokerage affiliates.
Business Activities of Other Members within the IB Group
clients may trade in markets where IB Group affiliates act as liquidity providers or have
activity which involves investing in the same instrument as a client. The activities of the IB
affiliates may affect
market levels and thus affect client levels including stop-loss levels. Any IB
Group employees, who are given
access to sensitive information on
a need-to-know basis due to the
nature of the business or their job function,
are under an obligation not to misuse any information
that is available to them to make a financial gain or avoid
financial loss to the detriment of clients.
REGISTER OF CONFLICTS OF INTEREST
maintains and operates effective organisational and administrative arrangements with a
view to taking
all reasonable steps to prevent conflicts of interest from adversely affecting the
interests of our clients.
maintains a register of the investment services and ancillary services carried out by or on
which could give rise to a conflict of interest. This register serves to facilitate the
management of potential
conflicts of interest.
If arrangements made by
are not sufficient to ensure, with reasonable confidence, that risks
damage to the interests of the client can be prevented,
shall disclose the nature and sources of the
conflicts of interest and the steps
to mitigate those risks to the client before
for the client.
The disclosure will be made with sufficient specific description of the conflicts of interest that
arise in the
IBIE's services and the risks to the clients
that arise as a result of the conflicts
of interest to enable
the client to make an informed decision with respect to the service in the
context of which the conflict of interest
REVIEW AND MANAGEMENT OVERSIGHT
The Policy is reviewed on a regular basis and at least once a year.