Conflict of Interest Policy

1. Introduction

1.1. Luramic Ltd (the “Company”) is committed to conducting its business with integrity, professionalism, fairness and transparency. As an investment dealer providing liquidity, execution and related services to professional counterparties and institutional clients, the Company recognises that conflicts of interest may arise during the course of its business activities.

1.2. The Company has established, implemented and maintains effective organisational and administrative arrangements designed to identify, prevent, manage, monitor and, where appropriate, disclose conflicts of interest that may arise between:

1. the Company and its clients;
2. one client and another client;
3. the Company's directors, officers, employees or associated persons and its clients; or
4. the Company and any third party with whom it maintains a business relationship.

1.3. This Policy summarises the Company’s approach to managing conflicts of interest and forms part of its overall governance and compliance framework.

2. Purpose and Scope

The purpose of this Policy is to describe the circumstances in which conflicts of interest may arise, the measures implemented by the Company to identify and manage such conflicts, and the procedures followed to ensure that clients are treated fairly and professionally at all times. This Policy applies to the Company, its directors, officers, employees, contractors, outsourced service providers and any person acting on behalf of the Company in connection with the provision of services.

3. Conflict of Interest

3.1. A conflict of interest may arise where the interests of the Company, its shareholders, directors, employees, affiliated entities, service providers or other clients differ from, compete with, or potentially conflict with the interests of a client. Conflicts may be actual, potential or perceived and may arise on a continuous basis or in connection with a specific transaction, execution arrangement, liquidity relationship or business activity. The Company seeks to identify and appropriately manage all categories of conflicts regardless of whether any actual detriment has occurred.

3.2. Given the nature of the Company’s business, conflicts may arise in a variety of circumstances. The Company may act as principal, market maker, liquidity provider, execution venue or counterparty in relation to transactions entered into with clients. Accordingly, the Company may have an economic interest in the outcome of certain transactions, including where positions are retained, hedged, netted, offset or otherwise managed as part of its risk management activities.

3.3. Conflicts may also arise through the Company’s liquidity sourcing and execution arrangements. The Company may obtain liquidity, hedging services or execution services from banks, brokers, exchanges, market makers or other liquidity providers and execution venues. In selecting, maintaining and operating such relationships, the Company may consider a range of factors including pricing, liquidity, execution quality, technological capabilities, operational resilience and commercial terms. Differences in execution outcomes, pricing arrangements or commercial relationships may create potential conflicts which the Company seeks to manage through its governance and oversight framework.

3.4. The Company may further manage risk through internalisation, aggregation, netting, offsetting or hedging arrangements. In certain circumstances, client transactions may be matched against other client transactions or against the Company’s own exposures or may be hedged with external counterparties. Such activities are conducted in accordance with the Company’s risk management, execution and conflict management procedures.

3.5. Conflicts may also arise from remuneration arrangements, incentive structures, business development activities, commercial relationships with affiliated entities, introducing brokers, technology providers, liquidity providers or other strategic partners. Additionally, access to confidential or commercially sensitive information concerning clients, counterparties or business partners may create conflicts requiring appropriate safeguards and controls.

4. Conflict Management Arrangements

4.1. The Company maintains a comprehensive framework designed to identify, assess, monitor and manage conflicts of interest. Responsibility for overseeing the effectiveness of this framework rests with the Board of Directors and senior management, who are responsible for ensuring that appropriate governance arrangements, policies and controls remain in place.

4.2. The Company seeks to maintain appropriate segregation of functions and responsibilities where conflicts may arise. Operational, dealing, risk management, compliance, finance, onboarding and business development functions are subject to organisational arrangements intended to support independent decision-making and reduce the risk of undue influence. The Company also maintains information barriers and access controls designed to prevent the inappropriate use, disclosure or sharing of confidential information. Access to sensitive information is granted only where necessary for the performance of an individual’s duties and responsibilities.

4.3. Directors, officers and employees are required to act honestly, fairly and professionally and to avoid circumstances that could compromise their objectivity or independence. Relevant persons must promptly disclose any personal interests, external business activities, relationships or circumstances that may give rise to an actual or potential conflict of interest. The Company also maintains procedures governing gifts, hospitality, entertainment and other benefits received from or provided to clients, counterparties and business partners in order to prevent inappropriate influence or inducement.

4.4. The Compliance Function monitors the effectiveness of the Company’s conflict management arrangements and may review, assess and escalate identified conflicts where appropriate. Material conflicts may be reported to senior management or the Board for consideration and resolution.

5. Disclosure Of Conflicts

5.1. The Company seeks to prevent and manage conflicts of interest through its organisational and administrative arrangements. However, where the Company reasonably determines that the measures implemented are not sufficient to ensure that a risk of harm to a client’s interests can be effectively prevented, the Company may disclose the nature and source of the relevant conflict to the affected client before undertaking the relevant business activity.

5.2. Any such disclosure will be provided in a clear, fair and non-misleading manner and will enable the client to make an informed decision regarding the relevant service or transaction. Disclosure is considered a measure of last resort and does not replace the Company’s obligation to maintain effective conflict management arrangements.

6. Record Keeping

The Company maintains appropriate records relating to identified conflicts of interest, assessments performed, mitigation measures implemented, disclosures made and decisions taken in connection with conflict management. Such records are retained in accordance with applicable legal, regulatory and internal record-keeping requirements.

7. Review of This Policy

This Policy is reviewed periodically and whenever material changes occur to the Company’s business model, regulatory obligations, organisational structure or conflict risk profile. The Company reserves the right to amend this Policy at any time in order to reflect changes in applicable laws, regulations, business activities or industry practices.

8. Contact Information

Any questions regarding this Conflicts of Interest Policy may be directed to:

Luramic Ltd: Investment Dealer (Excluding Underwriting) licensed and regulated by the Financial Services Commission.
Email: compliance@luramic.com