Summary Conflicts of Interests Policy

This summary of our Conflicts of Interest Policy outlines how we will manage actual and potential
conflicts of interest that may arise through the provision of our services to our clients.

1 Introduction
Exness (UK) Ltd (“Exness” or “the Firm” or “We”) is authorised and regulated by the Financial
Conduct Authority (“FCA”) and has adopted a Conflicts of Interest Policy (“Policy”) to address actions
and transactions that may give rise to actual or potential conflicts of interest. This Policy aims to
meet our regulatory obligations and maintain the trust and confidence of our clients and
counterparties, thereby upholding our reputation for integrity and fair dealing. The Policy makes up
one part of our ongoing commitment to adhere to the highest standards of ethical conduct in
relation to our treatment of our clients as well as the management of conflicts of interests in
accordance with the MiFID II standards as implemented in the FCA Handbook.

2 Identification of Conflicts

Exness has appropriate procedures in place for the identification of any potential and actual conflicts
that may arise between:
• Interests of Exness (including its managers, employees, tied agents and any person directly
or indirectly linked to the Firm by control) and its clients; or
• Interests of two or more clients, as Exness owes a separate duty to each of them.

Our ultimate objective is to prioritise our clients’ best interest.

3 Prevention and Management

We will take all necessary and appropriate steps to prevent any conflicts beforehand where possible,
and will manage any unavoidable conflicts as required. All staff within Exness understand that the
identification, prevention and management of conflicts is central to the Firm’s regulatory culture.
We monitor all activities that may give rise to conflicts of interests and ensure the segregation of
duties and responsibilities of our staff to prevent these.

Compliance with the rules is high on our agenda and we employ a number of techniques to manage
conflicts, and our Senior Management is fully engaged and has oversight of these as follows:

• We use physical and electronic information barriers (or Chinese Walls) to stop and control
the flow of information between certain parts of the business;
• We consider any potential conflicts that may arise when developing new products or
services or making other changes to our business model or operations;
• We update the Policy and the Conflicts Register, as necessary, on an ongoing basis and
formally consider the continued adequacy of the arrangements in place (including
whether over reliance occurs on disclosures);
• We maintain effective policies and procedures for the prevention of any conflicts that may
be caused by inducements, gifts/entertainment, our remuneration structures, personal
account dealing or external business interests;
• We provide internal guidance and training to all staff to raise their awareness of the current
regulatory framework, including how to deal with conflicts of interests when they arise.

Exness (UK) Ltd: Company number: 08861481

Authorised and Regulated by the Financial Conduct Authority
107 Cheapside, London, EC2V 6DN United Kingdom
Website: www.exness.co.uk email: support@exness.uk , phone: +44 442033186028
4 Disclosure

As a measure of last resort, where all our reasonable efforts to prevent or manage a conflict of
interests are not sufficient, we will consider whether the disclosure of an unavoidable conflict is
appropriate. We will provide sufficient detail to enable our clients to make an informed decision on
the services we are providing to them and the protection of their own interests.

5 Compliance and supervision

All Exness staff are responsible for complying with our Policy. Senior Management ensures that the
systems and controls in place meet the requirements imposed by the applicable regulations at all
times.

This policy is owned by Compliance, and is reviewed on an annual basis.

December 2021

Exness (UK) Ltd: Company number: 08861481

Authorised and Regulated by the Financial Conduct Authority
107 Cheapside, London, EC2V 6DN United Kingdom
Website: www.exness.co.uk email: support@exness.uk , phone: +44 442033186028