1. Introduction
 
Basel Financial Inc. is required to maintain and operate effective organizational and administrative arrangements with a view to taking all reasonable steps to identify, monitor and manage conflicts of interest. Basel Financial Inc. has put in place a policy to safeguard its clients’ interests. The key information is summarized below. Detailed information is obtainable on request from the client’s Account Manager.
 
2. Our Conflicts of Interest Policy

Basel Financial Inc. is an unrestricted financial advisor and an international investment company specialized in OTC CFD trading online. Like any financial services company, Basel Financial Inc. is potentially exposed to conflicts of interest in relation to various activities. However, the protection of our clients’ interests is our main concern:
 

• We will identify circumstances which may give rise to conflicts of interest entailing
• We have established appropriate mechanisms and systems to manage those conflicts; and
• We will maintain systems in an effort to prevent damage to our clients’ interests through identified conflicts

3. Conflicts of interest
 
Conflicts of interest’ are impossible to rule out. Our policy defines conflicts of interest as:

• First, conflicts of interest between Basel Financial Inc. and you. For instance, if we are providing a service to you and, beyond that, we have a material interest, relationship or arrangement in the transaction or product or service; the decisive factor is whether we make a profit or avoid a loss to your disadvantage; or
• Second, conflicts of interest between our clients if we are acting for you and for another client and your two interests conflict materially.

We have identified such conflicts of interest in our business. These could include:

• Providing services in different capacities at the same time, e.g. Management services and services for the issue of trading financial instruments;
• Giving to you investment advice or providing a portfolio management service;
• Acting as an agent for more than one client in a transaction; for personal gain
• Selling Basel Financial Inc. products to you; for personal gain
• Providing services to issuers of financial instruments which we transact for you or about which we advise you
• Trading or dealing in financial instruments which we transact for you or about which we advise you;
• Holding confidential information on other clients which, if we can disclose or use, would affect the services provided to you;
• Accepting gifts or entertainment that could be construed as conflicting with our duties to our clients;
• Basel Financial Inc. employees pursuing activities outside Basel Financial Inc. or maintaining personal relationships potentially detrimental to the client;
• Personal relationships between Basel Financial Inc. employees and clients and additional activities of Basel Financial Inc. employees outside

4. Our measures
 
The measures we have adopted to manage identified conflicts are summarized below. We consider them appropriate to our efforts to take reasonable care that, in relation to each identified potential conflict of interest, we act impartially to avoid a material risk of harming your interests.
 
a. Policies and procedures
 
We have adopted many policies and procedures throughout our business to manage potential conflicts of interests. Our employees receive guidance and training in these policies and procedures, and they are subject to monitoring and review processes.
 
b. Information barriers 
 
Our employees respect the confidentiality of client information and do not disclose it or use it inappropriately. For particularly sensitive cases, we have established walls and adopted wall procedures to prevent unauthorized exchange of information between employees and to organize the separation of staff members concerned.
 
c. Separate supervision/functions 
 
Two departments or businesses which, if run together, could encounter conflicts of interest will be managed by different senior staff members.
 
d. Pay 
 
Pay and bonuses are linked to the profits of Basel Financial Inc. or the business or department where an employee works. Pay and bonuses linked to the performance of another department, with possible conflicting interests, will be avoided at all times.
 
e. Inducements 
 
Inducements from third parties in relation to a service provided to you are acceptable to Basel Financial Inc. only if (1) the inducement is disclosed to you and (2) it is either the payment of a normal fee or commission to continue the quality of our services to you and does not impair our duty to act in your best interests.
 
f. Personal account dealing 
 
To prevent conflicts arising from the use of information obtained from clients, and market abuse in general, all employees are subject to personal account dealing rules.
 
g. Employees’ activities outside Basel Financial Inc. 
 
Our employees are subject to rules designed to avoid conflicts of interest with activities they undertake outside Basel Financial Inc.
 
h. Gifts 
 
Basel Financial Inc. employees will not accept any gifts other than those considered normal in their line of business. Excessive gifts from clients may result in a conflict of interest, something we are committed to avoiding.
 
i. Disclosure
 
Where there is no other way of managing a conflict, or where the measures in place do not sufficiently protect your interests as a client, the conflict will be disclosed to allow you to make an informed decision on whether to continue using our service in the situation concerned.
 
j. Declining to act
 
We may decline to act for a client in cases where we believe the conflict of interest cannot be managed in any other way.