CONFLICT OF INTEREST POLICY

1. INTRODUCTION

CaravanFX Limited (the “Company”) is committed to acting honestly, fairly, and professionally in the best interests of its clients.

This Conflict of Interest Policy (“Policy”) outlines the circumstances that may give rise to conflicts of interest and the measures taken by the Company to manage such conflicts.

2. SCOPE

This Policy applies to:

all services provided by the Company;
all employees, officers, and associated persons;
all interactions with clients and third parties.

3. IDENTIFICATION OF CONFLICTS

Conflicts of interest may arise where:

the Company may benefit at the expense of a client;
the Company acts as counterparty to client trades;
different clients have opposing interests;
employees have personal interests in transactions;
third-party relationships influence decision-making.

4. EXECUTION MODEL CONFLICT

The Company may operate a hybrid execution model, including:

Market Maker (B-book);
STP execution.

In certain cases, the Company may act as principal (counterparty) to client trades, which may create a potential conflict of interest.

5. PRICING AND SPREADS

The Company determines:

pricing feeds;
spreads;
execution conditions.

These may differ from external market sources.

6. COPYTRADING AND PAMM CONFLICTS

Conflicts may arise where:

traders receive compensation based on performance;
strategies involve higher risk-taking;
allocation decisions affect multiple clients.

The Company does not guarantee performance and does not endorse any specific trader.

7. EMPLOYEE CONFLICTS

Employees are prohibited from:

using confidential information for personal gain;
engaging in insider trading;
trading against clients.

Employees must disclose potential conflicts.

8. THIRD-PARTY RELATIONSHIPS

Conflicts may arise from relationships with:

liquidity providers;
payment providers;
Introducing Brokers (IBs);
affiliates.

The Company conducts due diligence to mitigate such risks.

9. MANAGEMENT OF CONFLICTS

The Company applies measures including:

internal controls and supervision;
segregation of duties;
monitoring of trading activity;
compliance oversight.

10. DISCLOSURE OF CONFLICTS

Where a conflict cannot be fully mitigated, the Company will:

disclose the nature of the conflict to the Client.

11. CLIENT CONSENT

By entering into a relationship with the Company, the Client acknowledges and accepts that conflicts of interest may exist.

12. RECORD KEEPING

The Company maintains records of:

identified conflicts;
actions taken.

13. POLICY REVIEW

This Policy is reviewed periodically.

14. CONTACT INFORMATION

support@caravanfx.com

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