Last updated: October 2026
Introduction and scope
Elev8 Markets is an Investment Dealer (Full Service Dealer excluding Underwriting) regulated by the Financial Services Commission ('FSC') in Mauritius under the license number GB21027161 (hereinafter referred to as the 'Company').
The Company has a duty to act honestly, fairly and professionally, in accordance with the best interests of its clients. All Supervised Persons must refrain from engaging in any activity or having any personal interest that creates, or may appear to create, a conflict of interest.
The Company provides execution-only services in contracts for difference ('CFDs') to its clients on a non-advisory basis, as set out in the Customer Agreement. The Company does not provide investment advice, personal recommendations, or portfolio management services. This Policy sets out how the Company identifies, prevents or manages, and, where necessary, discloses conflicts of interest arising from its business model and from the conduct of its Supervised Persons and Introducing Brokers. This Policy forms part of the Agreement, as defined in the Customer Agreement, and may be amended from time to time in accordance with its terms.
Definitions
For the purposes of this Policy, 'Supervised Persons' means the Company's directors, officers, employees, authorised representatives, and other persons acting on behalf of the Company and subject to its supervision.
'Compliance Officer' or 'CO' means the person appointed by the Company to oversee compliance with applicable legal and regulatory requirements and the Company's internal policies and procedures. 'Introducing Broker' or 'IB' has the meaning given in the Customer Agreement.
'Relatives' means, in relation to a Supervised Person, his or her spouse or civil partner, children (including stepchildren), parents, siblings, and any other person living in the same household.
'Connected Persons' means the Relatives of a Supervised Person and any entity controlled, directly or indirectly, by a Supervised Person or any of his or her Relatives.
General principles and prohibited activities
A conflict of interest may arise when the Supervised Person's personal interest interferes with, or appears to interfere with, the interests of the Company or its clients. It may also arise where a Supervised Person's actions or interests make it difficult for him or her to perform his or her duties and responsibilities for the Company honestly, objectively, and effectively.
While it is impossible to describe all of the possible circumstances in which a conflict of interest may arise, the following activities are prohibited:
- Supervised Persons must not favour the interests of one client over another, for example, larger accounts over smaller accounts, accounts in which a Supervised Person has a personal or financial interest, or accounts belonging to his or her close friends or relatives.
- Supervised Persons are prohibited from using confidential information about clients' pending orders, open positions or trading activity for their personal benefit or for the benefit of any third party, whether directly or indirectly.
Compliance Officer
In accordance with the FSC's Anti-Money Laundering and Countering the Financing of Terrorism Handbook, the CO may undertake additional compliance-related responsibilities, where permitted by applicable requirements, provided that such functions are control functions compatible with the CO's independence, such as the role of the Money Laundering Reporting Officer (MLRO). Where this is the case, the Company must ensure that any potential conflicts between the CO's compliance responsibilities and other functions are identified, documented and appropriately managed. The CO must remain independent of the Company's core operating activities and must not be involved in soliciting business. The CO shall not hold any business-line role, including any dealing, risk management, sales, marketing, or IB management function.
Directors and Officers
The following principles apply to the Company's directors and, where indicated, its officers:
- The Company shall maintain an interests register in accordance with the Companies Act 2001 (the 'Interests Register'), in which the interests declared by directors are recorded. The Interests Register is separate from the internal conflicts-of-interest register maintained by the CO, described under 'Other measures' below.
- The personal interests of a director, or persons closely associated with the director, must not take precedence over the interests of the Company or its clients.
- Directors should make every reasonable effort to avoid conflicts of interest or situations where others might reasonably perceive there to be a conflict of interest.
- Directors and members of management must disclose any actual or potential conflict to the Board fully, promptly, and in writing. Where an actual or potential conflict does arise, the director concerned must declare the nature and extent of the interest, ensure that it is entered in the Company's Interests Register, and must not participate in the deliberation on, or vote on, the matter. The declaration and the director's abstention shall be recorded in the minutes of the Board.
- Directors should recognise that their duty and responsibility as directors is always to act in the interests of the Company and not any other party.
- Directors and officers must treat confidential matters relating to the Company, learned in their capacity as directors or officers, as strictly confidential and must not divulge them to anyone without the authority of the Board. The Board must consider each such request on its merits and on a case-by-case basis.
Managing conflicts of interest
The Company identifies and manages conflicts of interest that may arise while providing services to its clients.
Conflicts of interest may arise between the Company (including its Supervised Persons and Introducing Brokers) and its clients, or between one client and another. The main conflicts arising from the Company's business model, and the measures the Company has adopted to manage them, are described below.
Company acting as principal and counterparty
The Company acts as principal and is the counterparty to all clients' CFD transactions. Client positions can only be opened and closed with the Company, at the prices quoted by the Company on its Trading Platform. The Company may, at its discretion, offset (hedge) all or part of its exposure with external liquidity providers; however, it remains the counterparty to the client in all cases. As a result, the Company's financial interests may differ from, or be opposed to, those of its clients, as the Company may benefit when a client incurs a loss on a position that the Company has not hedged. The Company manages this conflict through its order-execution arrangements, pricing and execution controls, monitoring, segregation of duties, independent Compliance oversight, and the fair and consistent treatment of clients in accordance with the Customer Agreement and the measures set out below:
Price and execution controls
- The Company's prices are derived from external price feeds and liquidity sources. Pricing parameters, including spread settings, are documented and approved in accordance with the Company's internal governance, and changes are logged.
- All clients within the same account type are subject to the same pricing and execution parameters. Supervised Persons may not manually intervene in the prices quoted to, or the execution of orders of, an individual client.
- Spreads may only be widened in the circumstances set out in the Customer Agreement, such as irregular market conditions, changes in trading conditions, or Force Majeure Events, and not by reference to an individual client's positions or trading results.
- Knowledge of clients' open positions, pending orders, or stop-loss levels is not used to influence the prices quoted to clients.
- The cancellation or amendment of transactions due to off-market quotes or Manifest Errors is carried out only on the basis of objective, documented criteria and is subject to review by Compliance.
Monitoring of spreads, slippage, and execution quality
- The Company regularly compares its quoted prices against independent market reference sources and monitors actual spreads against the trading conditions published on its Website.
- Slippage is monitored to ensure that it is applied symmetrically, so that clients may receive a better price as well as a worse price than the price requested, depending on market conditions.
- The Company also monitors order rejections, execution speed, platform latency, and trade cancellations or adjustments. Exception reports are reviewed by Compliance, material findings are escalated to the Board, and records are retained.
Segregation of duties
- The dealing and risk management functions, which are responsible for pricing, execution settings and hedging, are separated from sales, client support, marketing, and IB management functions.
- Staff whose remuneration is linked to sales or client acquisition have no access to, and cannot influence, pricing, execution settings, or risk management decisions. Access rights to trading platform settings are restricted by role, and changes require dual approval and are logged.
Independent Compliance oversight
- The CO is independent of the Company's business and operating functions, reports directly to the Board and has unrestricted access to the Company's records, systems and staff.
- The CO reviews the monitoring reports described in this Policy, maintains the conflicts-of-interest register, reviews new products, promotions and remuneration arrangements for potential conflicts, and reports to the Board at least annually on the effectiveness of the Company's conflicts management arrangements. The Company's arrangements are also subject to an independent audit.
Liquidity providers and hedging counterparties
Where the Company hedges its exposure, it may receive rebates, volume-based discounts or other benefits from liquidity providers or hedging counterparties, and a liquidity provider or hedging counterparty may be a related or group entity. Such arrangements may create an incentive to route hedging flows, or to set pricing or execution parameters, in a way that benefits the Company or its group rather than its clients. To manage this conflict, liquidity providers and hedging counterparties are selected and periodically reviewed on the basis of objective, documented criteria, including price quality, execution quality, reliability, and creditworthiness. Any rebate or other benefit received from a liquidity provider or hedging counterparty is disclosed to the CO and recorded in the conflicts-of-interest register, and no such benefit may influence the prices quoted to, or the execution of orders of, clients. Any arrangement with a related or group entity must be on arm's-length terms, approved by the Board, and subject to review by the CO.
Introducing Brokers (IBs)
- The Company may pay IBs commissions or rebates calculated by reference to the trading activity of the clients they introduce. This may give IBs an incentive to encourage clients to trade more frequently or in larger volumes than is in the clients' interests.
- To manage this conflict, IBs are subject to due diligence and written agreements. IBs may not provide investment advice, manage client accounts or trade on behalf of clients, make misleading statements, or present themselves as acting on behalf of the Company beyond the scope of their agreement.
- The Company monitors IB-introduced accounts for signs of excessive trading, misleading promotion, or other misconduct, and may suspend or terminate IB arrangements where concerns arise. Clients may request details of the basis of remuneration paid to their IB and may request to change or unsubscribe from their IB as set out in the Customer Agreement.
Employee remuneration and incentives
- The Company's remuneration arrangements are approved by the Board and designed so that they do not encourage Supervised Persons to act against the interests of clients.
- Variable remuneration of client-facing staff is not linked to client trading losses, client trading volumes, or the Company's revenue from acting as counterparty, and takes into account qualitative criteria such as compliance with internal policies, complaints, and the fair treatment of clients. The remuneration of Compliance staff is independent of the performance of the business areas they oversee.
Client incentive and loyalty programs
The Company may offer loyalty programs, rewards, or promotions in which benefits are linked, in part, to clients' trading activity. As the Company is the counterparty to client trades, such programs may encourage clients to trade more than they otherwise would. Any such program is reviewed by Compliance before launch, is governed by published terms and conditions, is accompanied by appropriate risk warnings, and must not be designed to encourage clients to trade beyond their means or experience.
Personal trading
- In accordance with the Customer Agreement, Supervised Persons, their Relatives, and other Connected Persons may not open or operate trading accounts with the Company.
- Supervised Persons must disclose to the CO any trading accounts they hold with other providers in CFDs or other leveraged products, and the CO may require the pre-approval of transactions and periodic account statements.
- Supervised Persons must not use information about client orders, positions, or the Company's hedging activity for personal trading, must not trade ahead of or against client orders, and must not copy or replicate client trading strategies. Supervised Persons must confirm compliance with these requirements annually.
Fair treatment of clients
- The Company treats all clients fairly and consistently and applies the same trading conditions to all clients within the same account type. No client or group of clients receives preferential pricing or execution because of their relationship with a Supervised Person or IB.
- Information provided to clients about the Company's products, costs, and risks is clear, fair, and not misleading. Complaints relating to pricing or execution are reviewed by persons independent of the matter complained of, in accordance with the Company's Customer Complaint Policy, and clients may escalate unresolved complaints to the Office of the Ombudsperson for Financial Services.
Other measures
The Company manages conflicts of interest more generally through:
- information barriers ('Chinese walls') and segregation of duties between dealing, risk management, sales, and control functions: independent oversight by the Compliance function and the Board;
- disclosure to affected clients where the Company's arrangements are not sufficient to ensure, with reasonable confidence, that the risk of damage to client interests will be prevented. Disclosure is a measure of last resort and will include sufficient detail to enable clients to take an informed decision;
- declining to provide the service where the conflict cannot be managed effectively.
Gifts and entertainment
Supervised Persons should not accept inappropriate gifts, favours, entertainment, special accommodations, or anything else of material value that could influence their decision-making or make them feel beholden to a person or firm.
Similarly, Supervised Persons should not offer gifts, favours, entertainment, or other things of value that could be viewed as overly generous or intended to influence decision-making or to make a client feel beholden to the Company or the Supervised Person.
No Supervised Person may receive any gift, service, or other thing of more than de minimis value from any person or entity that does business with or on behalf of the Company, including liquidity providers, Introducing Brokers, and service providers.
No Supervised Person may give or offer any gift of more than de minimis value to existing clients, prospective clients, or any entity that does business with or on behalf of the Company without the prior written approval of the CO.
A gift or item of hospitality is considered de minimis where it is of modest value, is given or received only occasionally, and could not reasonably be perceived as capable of influencing the recipient's decisions or impairing the Company's duty to act in the best interests of its clients. Where in doubt, Supervised Persons must consult the CO before accepting or offering any gift or hospitality.
Additionally, the receipt of an occasional dinner, a ticket to a sporting event or the theatre, or comparable entertainment shall also be considered to be of de minimis value if the person or entity providing the entertainment is present. All gifts and hospitality, given or received, must be declared to the CO and recorded in the Company's gifts-and-entertainment register, irrespective of their value, and are reviewed by the CO. No Supervised Person may give or accept cash gifts or cash equivalents to or from a client, prospective client, or any entity that does business with or on behalf of the Company.
Bribes and kickbacks are criminal acts strictly prohibited by law. Supervised Persons must not offer, give, solicit, or receive any form of bribe or kickback.
Political and charitable contributions
Supervised Persons who make political and charitable contributions in cash or services must report each such contribution to the CO, who will compile and report thereon as required under relevant regulations. Supervised Persons are prohibited from considering the Company's current or anticipated business relationships as a factor in soliciting political or charitable donations.
Confidentiality
Supervised Persons shall respect the confidentiality of information acquired in the course of their work and shall not disclose such information unless authorised or legally required to do so. They may not use confidential information acquired in the course of their work for their personal advantage. Supervised Persons must keep all information about clients, including former clients, strictly confidential. This includes clients' identities, personal and financial circumstances, account information, payment details and trading activity, unless disclosure is authorised by the client or required by law. Client information, including information on open positions, orders, and trading strategies, may only be used for legitimate purposes such as order execution, risk management, hedging, and regulatory compliance, and must never be used to disadvantage clients. Client personal data may be shared with Introducing Brokers or other third parties only as permitted by the Company's Privacy Policy and the Data Protection Act 2017.
Service on board of directors
Supervised Persons shall not serve on the board of directors of publicly traded companies absent prior authorisation from the CO. Any such approval may only be granted if it is determined that such board service will be consistent with the interests of the Company and its clients, and appropriate measures are in place to manage any conflict of interest or access to confidential information. A Supervised Person serving as a director of a private company may be required to resign, either immediately or at the end of the current term, if that company goes public during his or her term as director.
Relationships with regulatory bodies
Supervised Persons may interact with representatives from regulatory bodies during the course of their work. They are expected to cooperate with regulators and comply promptly with all applicable disclosure obligations. Any contact with a regulatory body, other than routine contact made by or through the CO, must be reported promptly to the CO.
Review of this Policy
This Policy is reviewed by the CO at least annually, and whenever there is a material change to the Company's business model, products, or regulatory obligations, and any amendments are approved by the Board. The current version is published on the Company's Website. Clients may request further information about this Policy by contacting support@elev8.com.