Conflict of Interest Management Policy
1. Introduction
Hola Prime Markets (“the Company”) is committed to conducting its business with integrity, fairness, and transparency. This policy outlines our approach to identifying, preventing, and managing conflicts of interest that may arise:
1.1 Between the Company and its clients. 1.2 Between one client and another.
Our objective is to ensure that all clients are treated fairly, that no client is disadvantaged over another, and that any potential conflicts are handled in a way that protects client interests and complies with applicable laws and regulations.
2. Identification and Management of Conflicts of Interest
2.1 Identification of Conflicts
The Company regularly reviews its operations to identify existing or potential conflicts of interest, including:
2.1.1 Transactions or services that may create competing interests between the Company and a client. 2.1.2 Situations where the interests of one client may conflict with the interests of another client.
2.2 Disclosure of Conflicts
Where a conflict of interest cannot be avoided, the Company will clearly disclose it to the affected clients—either in general terms or in relation to a specific transaction—along with the potential impact on their dealings with us.
2.3 Prohibition of Conflicting Actions
If a conflict of interest cannot be effectively managed or mitigated, the Company will avoid taking any action that could compromise fair treatment or client trust. All services will be delivered with neutrality, fairness, and transparency.
2.4 Protection Against Misuse of Company or Client Funds
Directors, officers, and employees are strictly prohibited from misusing Company or client funds in any manner, including but not limited to:
2.4.1 Unauthorized withdrawals. 2.4.2 Unauthorized lending or financing. 2.4.3 Unapproved fund transfers. 2.4.4 Any non-business-related financial activity.
3. Measures to Mitigate Conflicts of Interest
3.1 Separation of Functions
The Company maintains clear separation between business units engaged in different financial activities.
3.1.1 Access to sensitive information is restricted to authorized personnel only. 3.1.2 Physical and digital security controls prevent unauthorized access to restricted areas or systems.
3.2 Separation of Duties
Employees are assigned roles and responsibilities that minimize the risk of conflicts of interest.
3.2.1 No employee may perform duties across multiple departments without prior approval. 3.2.2 Exceptions are only allowed where there is no risk of conflict and after compliance review.
3.3 Technical Safeguards and System Controls
We use role-based access controls to ensure that employees can only access systems and information relevant to their job functions.
3.3.1 Access to other systems is granted only for operational needs, specific investigations, or report generation.
3.3.2 System structures are designed to prevent unauthorized data exposure or misuse of information that could result in a conflict of interest.
4. Compliance and Enforcement
Compliance with this policy is mandatory for all employees, officers, and business partners of Hola Prime Markets.
Breaches of this policy may result in:
4.1 Disciplinary action, including suspension or termination of employment.
4.2 Legal or regulatory consequences, where applicable.
The Company will continuously review and improve its conflict of interest framework to align with regulatory requirements and industry best practices.
5. Contact Information
[email protected] Registered Address: C/o Renark Management Solutions Ltd, 4th Floor, Docks 4, The Docks, Caudan, Port Louis, Mauritius