Principles for dealing with conflicts of interest
As a transaction-oriented, contractually bound broker operating under the liability umbrella of Wolfgang Steubing AG, Frankfurt am Main, we attach particular importance to professionalism and a trusting client relationship. We ensure that our employees provide all services with the highest degree of expertise, care and diligence in the interests of our clients. We regard the quality of our services, the integrity and reliability of our employees, fairness in dealing with our customers and, of course, compliance with legal requirements, practices and market standards as the fundamental principles of our business success. To safeguard these principles, we take far-reaching organizational precautions to avoid conflicts of interest and the risk of harming client interests. However, conflicts of interest cannot generally be ruled out in transaction-oriented business. Conflicts of interest can arise within the company, with affiliated companies that have a stake in Montega Markets GmbH or for which we or they act contractually on our behalf, the management, employees, our clients and between our clients.
Conflicts of interest may arise, for example, from the fact that we initiate orders for financial instruments as a tipster for which a contractual partner of Montega Markets GmbH holds short-term trading positions due to its activity as a specialist on a stock exchange as a market maker or as a designated sponsor or in its other activities. It is also possible that bodies or employees of our company hold positions in securities in which a contractual partner of the company is active as a specialist, market maker, lead broker or designated sponsor or for which it has client orders.
Conflicts of interest may also arise due to the monitoring of capital market transactions of an issuer for whose value a client order exists with a contractual partner, or due to personal relationships of employees or management with issuers and their employees, for example from advisory or supervisory board activities, or due to the payment of performance-related remuneration to employees.
Conflicts of interest may also arise, for example, from the fact that we initiate orders for financial instruments as a tipster or accompany capital market transactions of issuers for which a company in which we hold an interest publishes research reports. It is also possible that executive bodies or employees of our company hold positions in securities for which a company in which we hold an interest prepares research reports.
In order to prevent conflicts of interest from arising or to minimize any conflicts of interest that may arise, we have created a compliance organization that performs its tasks permanently, independently and without instructions, is separate from business, trading and settlement and reports directly to the Managing Director. The following preventive measures have been taken to protect customer interests:
- the establishment of confidentiality areas (Chinese walls) by means of spatial, visual and acoustic barriers to prevent the flow of information
- the maintenance of a restricted list with trading bans for employees in relation to securities included in the restricted list
- the obligation of all employees to disclose all private securities transactions (so-called "personal transactions") by submitting duplicates of their custodian institutions
- the obligation to inform the compliance officer if conflicts of interest arise
- the prohibition of personal transactions against known client orders
- an internal whistle-blowing process (whistle-blower system) and the provision of an internal reporting office in accordance with the HinSchG
- an internal policy on benefits and the offer and acceptance of gifts
- regular auditing of the compliance office by the internal audit department/external auditors
- Regularly informing the management about compliance and anomalies.
As a matter of principle, our employees are prohibited from conducting personal transactions in securities that they manage in the transaction business. For us and our employees, the principle of giving priority to the interests of the customer over the company's own interests also applies. Our employees are prohibited from concluding transactions at conditions that are not in line with the market and from concluding transactions that create the appearance of unfairness or are likely to call into question the credibility of the company or its employees. If there is any scope for judgment or discretion in determining the reference value, this must always be exercised independently and honestly. The principle that the interests of the customer take precedence over the interests of the employee and the company must be taken into account.
Compliance with the above regulations is subject to ongoing monitoring by the Compliance Office, which is reported to the management and may lead to personnel consequences. If a conflict of interest is unavoidable in an individual case, the client concerned will be informed of this before the transaction is concluded. If a conflict of interest is unavoidable in individual cases, the client concerned will be informed of this before the transaction is concluded.