CONFLICTS OF INTEREST POLICY
1. Introduction
1.1. Tradexfin Limited (formerly known as “Trading Point (Seychelles) Limited”) operating under the trading
name XMTrading is a Securities Dealer Licensee regulated and authorised by the Financial Services
Authority (“FSA”) in Seychelles under the Licence Number: SD010 (hereinafter called the “Company”).
1.2. The Company is operating under the Securities Act 2007 (the “Act”), Securities (Conduct of Business)
Regulations 2008, Securities (Forms and Fees) Regulations 2008, Securities (Prospectus) Regulations
2008, Securities (Takeovers) Regulations 2008, Securities (Takeovers) Regulations 2008 and theSecurities (Advertisements) Regulations 2008 (collectively the “Act and Applicable Regulations”).
1.3. In accordance with the Act and Applicable Regulations, the Company is required to take reasonable
steps to detect and avoid conflicts of interest and provide its clients with its Conflicts of Interest Policy(hereinafter the “Policy”). The Company is committed to acting honestly, fairly and professionally andin the best interests of its clients and to complying, in particular, with the principles set out in the above
Applicable Regulations when providing investment services and other ancillary services related to suchservices.
2. Purpose and scope
2.1. The purpose of this document is to set out the Company’s approach to identify and manage conflictsof interest which may arise during the course of its business activities.
2.2. The Company has taken all appropriate steps to identify and prevent or manage conflicts of interest
which may arise between the Company, including its directors, managers, employees and any person
directly or indirectly linked to the Company by control and its clients or between one client and anotherthat arise in the course of providing any investment and ancillary services, or combinations thereof,including the Company’s own remuneration scheme and other incentive structures. Accordingly, thisPolicy sets out the necessary procedures, controls and practices in place to ensure that any conflictsof interest are identified and prevented or appropriately managed.
2.3. In case where the steps taken by the Company to prevent conflicts of interest from adversely affecting
the interest of its clients are not sufficient to ensure, with reasonable confidence, that risks of damage
to client interests will be prevented, the Company shall clearly disclose to the client, in a durable
medium, the general nature and sources of conflicts of interest as well as the risks to the client thatarise as a result of the conflicts of interest and the steps taken to mitigate those risks before undertaking
business on its behalf.
Such disclosure shall be a measure of last resort and shall include sufficient detail, taking into account thecharacteristics of the client to enable that client to take an informed decision with respect to the service
in the context of which the conflict of interest arises.
2.4. The disclosure shall clearly state that the organisational and administrative arrangements establishedby the investment firm to prevent or manage that conflict are not sufficient to ensure, with reasonableconfidence, that the risks of damage to the interests of the client will be prevented. The disclosure shall
include specific description of the conflicts of interest that arise in the provision of investment and/orancillary services, taking into account the nature of the client to whom the disclosure is being made.
The description shall explain the general nature and sources of conflicts of interest, as well as the risks
to the client that arise as a result of the conflicts of interest and the steps undertaken to mitigate theserisks, in sufficient detail to enable that client to take an informed decision with respect to the investment
or ancillary service in the context of which the conflicts of interest arise.
2.5. The Policy applies to all the Company’s directors, employees, any persons directly or indirectly linked
to the Company (hereinafter called “related persons”) and refers to all interactions with all clients.

Email: info@xmtrading.com | Web: www.xmtrading.com | Address: F20, 1st Floor, Eden Plaza, Eden Island, Seychelles3. Identification of conflict of interests
3.1. For the purposes of identifying the types of conflict of interest that arise in the course of providing
investment and ancillary services or a combination thereof, and whose existence may damage theinterests of a client, the Company takes into account, by way of minimum criteria, whether the Companyor a relevant person is in any of the following situations:a) The Company or relevant person is likely to make a financial gain, or avoid a financial loss, at theexpense of the client;b) The Company or relevant person has an interest in the outcome of a service provided to the client orof a transaction carried out on behalf of the client, which is distinct from the client's interest in thatoutcome;c) The Company or relevant person has a financial or other incentive to favour the interest of anotherclient or group of clients over the interests of the client;d) The Company or relevant person carries out the same business as the client; ore) The Company or relevant person receives or will receive from a person other than the client aninducement in relation to a service provided to the client, in the form of monies, goods or services, otherthan the standard commission or fee for that service.
4. Procedures and controls to managing conflicts of interests
4.1. This Policy includes the following content:a) identifies, with reference to the specific investment services and activities and ancillary services carriedout by or on behalf of the Company, the circumstances which constitute or may give rise to a conflictof interest entailing a material risk of damage to the interests of one or more clients; andb) specifies procedures to be followed and measures to be adopted in order to prevent or manage suchconflicts.
4.2. In general, the procedures and controls that the Company follows to manage the identified conflicts ofinterest include, but are not limited to, the following measures:a) effective procedures to prevent or control the exchange of information between relevant persons
engaged in activities involving a risk of a conflict of interest where the exchange of that information may
harm the interests of one or more clients;b) the separate supervision of relevant persons whose principal functions involve carrying out activities
on behalf of, or providing services to, clients whose interests may conflict, or who otherwise represent
different interests that may conflict, including those of the Company;c) the removal of any direct link between the remuneration of relevant persons principally engaged in one
activity and the remuneration of, or revenues generated by, different relevant persons principallyengaged in another activity, where a conflict of interest may arise in relation to those activities;d) measures to prevent or limit any person from exercising inappropriate influence over the way in whicha relevant person carries out investment or ancillary services or activities; ande) measures to prevent or control the simultaneous or sequential involvement of a relevant person inseparate investment or ancillary services. Such measures include, but are not limited to, the following:
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•A ‘need to know’ policy governing the dissemination of confidential or inside information within theGroup;
Chinese walls restricting the flow of confidential and inside information within our company, andphysical separation of departments;
Procedures governing access to electronic data;
Segregation of duties that may give rise to conflicts of interest if carried on by the same individual;
Personal account dealing requirements applicable to relevant persons in relation to their owninvestments;
A gifts and inducements log registering the solicitation, offer or receipt of certain benefits;
The prohibition of external business interests conflicting with our interests as far as the Company’sofficers and employees are concerned, unless prior Board approval is provided;A policy designed to limit the conflict of interest arising from the giving and receiving of inducements;
Organisational and administrative arrangements to limit the conflict of interest arising from the giving
and receiving of inducements.

Email: info@xmtrading.com | Web: www.xmtrading.com | Address: F20, 1st Floor, Eden Plaza, Eden Island, Seychelles

4.3. The Company also undertakes on-going monitoring of business activities to ensure that internalcontrols to prevent or manage conflicts of interest are appropriate.
4.4. The Compliance Department shall be responsible for identifying and managing potential conflicts ofinterests and reporting directly to the Board of Directors and Senior Management in relation to the latter.
The Compliance Department shall also update the relevant internal procedures and ensure compliancewith such procedures.
5. Disclosure
5.1. Where a conflict arises and the Company is aware of it, it will disclose the conflict to the client prior toundertaking investment business for that client or, if it does not believe that disclosure is appropriate to
manage the conflict, we may choose not to proceed with the transaction or matter giving rise to theconflict.
5.2. The Company reserves the right to assess and periodically review, at least annually, and, if necessary,amend this Policy and its arrangements, at its sole discretion, whenever it deems fit or appropriate, inorder to address any deficiencies.
5.3. This Policy does not form part of the Company’s Terms and Conditions of Business and is not intended
to be contractually binding or impose or seek to impose any obligations on us which we would nototherwise have, but for the Act and Applicable Regulations.

Email: info@xmtrading.com | Web: www.xmtrading.com | Address: F20, 1st Floor, Eden Plaza, Eden Island, Seychelles