Conflict of Interest Policy

Our Commitment to Fair Practice

Citadel Markets Pro is committed to maintaining the highest standards of integrity and fairness in all aspects of our business operations. This Conflict of Interest Policy outlines how we identify, manage, and mitigate potential conflicts that may arise between our interests and those of our clients.

We recognize that conflicts of interest are inherent in the financial services industry, and we are dedicated to ensuring that such conflicts do not adversely affect our clients or compromise the integrity of our services.

What is a Conflict of Interest?

A conflict of interest arises when the interests of Citadel Markets Pro, its employees, or its affiliates may compete or conflict with the interests of our clients. Conflicts may occur in various circumstances, including but not limited to:

• Financial Interests - Situations where we or our employees could gain financially at the expense of a client, or where financial incentives may influence the advice or services provided.
• Personal Relationships - Circumstances where personal relationships or interests may interfere with professional judgment and objectivity in serving our clients.
• Competing Interests - Situations where the interests of one client may conflict with the interests of another client, or where our own trading activities may compete with client orders.
• Third-Party Arrangements - Relationships with third parties that may create incentives to favor certain products, services, or outcomes over others.

Identifying Conflicts of Interest

Citadel Markets Pro has established comprehensive procedures to identify potential conflicts of interest that may arise in the course of providing our services. We continuously monitor and assess our business activities, relationships, and practices to detect conflicts that could impact our clients.

Our identification process includes regular reviews of employee activities, trading practices, business relationships, revenue arrangements, and organizational structures to ensure potential conflicts are promptly recognized and addressed.

Managing Conflicts of Interest

When conflicts of interest are identified, we implement appropriate measures to manage and mitigate them. Our management strategies include:

• Disclosure - We provide clear disclosure to affected clients about the nature and extent of conflicts, enabling them to make informed decisions about their relationship with us.
• Information Barriers - We maintain information barriers (Chinese Walls) between different departments to prevent the misuse of confidential information and ensure independent decision-making.
• Segregation of Duties - We separate functions and responsibilities to prevent any individual or department from exercising inappropriate influence over conflicting interests.
• Declining to Act - In cases where conflicts cannot be adequately managed, we may decline to provide certain services or execute specific transactions to protect client interests.

Order Execution and Best Execution

Citadel Markets Pro is committed to providing best execution on all client orders. We do not engage in practices that would place our interests ahead of our clients, including:

• Trading against client orders for our own account
• Front-running client orders or using advance knowledge of client trading intentions
• Providing preferential treatment to certain clients at the expense of others
• Receiving or providing improper inducements that could compromise execution quality

Our order execution policies are designed to achieve the best possible results for our clients, taking into account price, costs, speed, likelihood of execution and settlement, size, nature, and any other relevant considerations.

Employee Trading and Personal Account Dealing

All Citadel Markets Pro employees are subject to strict personal trading policies designed to prevent conflicts of interest and protect client interests. Our employees must:

• Obtain prior approval for personal trading activities
• Not use confidential client information for personal benefit
• Avoid trading in instruments or markets where they have non-public information
• Disclose personal trading accounts and provide transaction reports for monitoring
• Prioritize client orders over personal trading activities

Inducements and Remuneration

Citadel Markets Pro maintains strict policies regarding inducements, gifts, and entertainment to ensure that such arrangements do not create conflicts of interest or compromise our duty to act in clients' best interests.

We do not offer, pay, solicit, or accept any fees, commissions, monetary or non-monetary benefits that would conflict with our duty to act honestly, fairly, and professionally in the best interests of our clients.

Any remuneration arrangements we have with third parties are structured to enhance the quality of service to clients and do not impair our ability to act in their best interests. Details of such arrangements are disclosed to clients as required by applicable regulations.

Third-Party Relationships

In the course of our business, we may engage with third-party service providers, liquidity providers, introducing brokers, and other business partners. We carefully evaluate these relationships to ensure they do not create material conflicts of interest.

Where we receive payments or other benefits from third parties in connection with services provided to clients, we disclose these arrangements and ensure they are designed to enhance service quality rather than create conflicts.

Monitoring and Review

Citadel Markets Pro maintains a robust monitoring and review framework to ensure ongoing compliance with this Conflict of Interest Policy. Our compliance team conducts regular audits, reviews employee trading activities, assesses business relationships, and evaluates the effectiveness of our conflict management procedures.

This policy is reviewed and updated regularly to reflect changes in our business, regulatory requirements, and industry best practices. All employees receive training on identifying and managing conflicts of interest as part of their ongoing professional development.

Record Keeping

We maintain detailed records of all identified conflicts of interest, the steps taken to manage them, and any disclosures made to clients. These records are kept for the period required by applicable regulations and are available for review by regulatory authorities upon request.

Disclosure to Clients

Where conflicts of interest cannot be avoided, we will provide clear and comprehensive disclosure to affected clients before undertaking any activity that could be affected by the conflict. Our disclosures will include:

• The nature and source of the conflict
• The risks arising from the conflict
• The steps we have taken to mitigate those risks
• Any alternative courses of action available to the client

Reporting Concerns and Complaints

If you believe that Citadel Markets Pro has not adequately managed a conflict of interest, or if you have concerns about potential conflicts, we encourage you to contact us immediately. You can raise concerns through:

• Our customer support team via livechat or email
• Our dedicated compliance department
• Our formal complaints procedure outlined in your client agreement

All complaints will be investigated thoroughly and promptly, and you will receive a written response detailing our findings and any remedial action taken.

Regulatory Compliance

This Conflict of Interest Policy is designed to comply with all applicable regulatory requirements, including but not limited to regulations governing financial services, investment firms, and market conduct. We cooperate fully with regulatory authorities in their oversight of our conflict management practices.