Treating Customers Fairly (TCF)

Treating Customers Fairly (“TCF”) is central to the delivery of our regulatory principles and is used to ensure that an efficient and effective market place help consumers secure a fair deal. Trade Online Group have adopted this ideal as a course of Best Practice, and in an effort to deliver the Highest Levels of business continuity.
Trade Online Group TCF Strategy is focused around the six mandated client outcomes which all registered firms must comply with. The strategy below has been implemented / embedded into Trade Online Group business culture and processes so that we can physically evidence that our clients can:

Expect Trade Online Group to treat them fairly,
Expect Trade Online Group to ensure that TCF is central to its corporate culture,
Expect to receive clear and precise documentation and information from Trade Online Group
Expect to receive a fair and professional service from Trade Online Group
Expect prompt and fair treatment from Trade Online Group in respect of complaints/queries

We will review our TCF policy on a continual rolling basis so that we always observe these directives.
Trade Online Group believe that the dynamics of TCF are best initiated at point of client contact and implementation with the rest of the company geared to TCF follow up. Processes have been employed to capture the widest possible range of Management information on TCF relevant issues. This information is then reviewed to identify client trends and solutions which will lead to an increase in the overall customer experience. Trade Online Group are committed to providing the best trading experience possible to our clients and welcome any comments you may have to help us deliver this.

Order Execution Policy

1 In accordance with the FCA Rules, we have implemented an order execution policy which sets out the reasonable steps that we will take in order to obtain the best possible result for our customers (the “Execution Policy”). Information on our Execution Policy is detailed below.
2 You agree that the terms of the Execution Policy will apply where we are executing orders on your behalf.
3 When executing orders on your behalf, we will take all reasonable steps to obtain the best possible result for you by considering a number of factors which include price, costs, speed, likelihood of execution and settlement, size, nature and any other consideration which we reasonably consider is relevant.
4 We will ordinarily give the price and the costs relating to the execution of your order the highest importance in obtaining the best result for you, although there may be circumstances where we reasonably determine that another factor is more important.
5 A list of the Execution Venues that we use can be found on our providers website This list is not exhaustive but it comprises those Execution Venues on which we place significant reliance.
5.1 We reserve the right to use another Execution Venue where we consider that it is appropriate in the light of our Execution Policy and we may from time to time add or remove an Execution Venue from this list.
5.2 We will regularly assess the Execution Venues available in respect of any products that we trade to identify those that will enable us, on a consistent basis, to obtain the best possible result when executing orders. We will update the list of Execution Venues if this is necessary after such review.
5.3 Other than by updating the website, we will not notify you of any changes to the Execution Venues and you should consult this list from time to time. Alternatively, you can ask your broker.
6 When you provide us with a specific instruction as to the execution of an order that cannot be carried out in accordance with our Execution Policy, our Execution Policy will not apply and we will execute your order in accordance with your specific instructions.
7 From time to time, we may execute your order outside a Regulated Market or a Multilateral Trading Facility. This means that the same investor protection standards may not apply to those transactions.
8 Before we execute your order outside a Regulated Market or a Multilateral Trading Facility, we are required to obtain your express consent and so we will always ask you before we execute your orders in this way.
9 We may send an order that we receive from you to various third parties for execution. A list of these third parties can be found on our providers website. In doing so, we must act in your best interests and comply with clauses 5.3 and 5.4 in these Terms.
10 We will monitor compliance with our Execution Policy.
11 We will review the effectiveness of our Execution Policy on at least an annual basis and whenever a material change occurs that affects our ability to obtain the best possible result for our customers, we will amend this as appropriate. We will let you know if we make any material changes to the Execution Policy by publishing details on our website.
12 You may request in writing that we demonstrate to you that your orders have been executed in accordance with our Execution Policy. We will use reasonable endeavors to deal with such a request within twenty (20) Business Days.
However, if we are unable to satisfy your request within such a timescale, we will write to you confirming our reason for the delay and confirm when you can expect to receive a response.

Conflicts of Interest Policy

Introduction

Trade Online Group is bound by FCA Principles for Business, where Principle 8 states “ A firm must manage conflicts of interest fairly, both between itself and its customers and between a customer and another client”.
The principal activities of Trade Online Group are the provision of investment services to Professional clients.
As a result, a variety of conflicts may arise between Trade Online Group conflicts and those of its clients and between the interests of different clients. Consequently, Trade Online Group has an obligation to:
1. take all reasonable steps to identify conflicts of interest between
(i) Trade Online Group and its clients and
(ii) one client and another;
2. Maintain and operate effective organisational and administrative arrangements with a view to taking reasonable steps designed to prevent conflicts of interest from giving rise to a material risk of damaging clients’ interests;
3. Disclose any conflicts that cannot be managed effectively by our organisational and administrative arrangements to ensure that clients’ interests will not be damaged.
4 Maintain records of Trade Online Group and activities in which conflicts may arise.

Disclosure of conflicts

To identify the types of conflicts of interest which may arise, we take into account whether Trade Online Group or an employee:
a) is likely to make a profit or avoid a loss at the expense of the client;
b) has an interest in the outcome of a service provided to the client or of a transaction carried out on behalf of a client, which is distinct from the client’s own interest in that outcome.
c) has a financial or other incentive to favour the interest of another client or group of clients over the interests of the client;
d) carries on the same business as the client;
e) receives or will receive from a person other than the client an inducement in relation to a service provided to the client, in the form of monies, goods or services; or
f) could be in a position where its ability to act in a client’s best interests is potentially affected by any other matter.
We also seek to identify any situation where the interest of one client may conflict with those of another, in order to ensure fair treatment for each client.

Managing Conflicts of Interests

Trade Online Group has in place policies and procedures which should enable us to manage conflicts of interest when they arise, in particular including those listed below. We may need to take additional steps in particular cases and these will be determined on a case-by-case basis. In most cases, we believe these procedures are sufficient to prevent risks to clients, but we disclose in our terms of business the conflicts which may arise in case in any particular situation these procedures are not alone sufficient.

Independence Policy

We operate a formal independence policy for the business which stipulates that whenever an investment adviser gives advice or recommends a transaction to a client, that individual should disregard any relationship, arrangement or interest of his own, or of the firm which might influence the advice or recommendation.

Best Execution

Our policies for acting in clients’ best interests when executing orders and passing orders to third parties for execution are designed to ensure that we meet out best execution obligations regardless of any other interests.

Chinese Walls

Chinese Walls are formal arrangements that require information held by a person in one part of the business to be withheld from, or not to be used for, people in another part of the business. If non public information is to be passed to an employee on the other side of the Chinese Wall, it must be authorised and recorded.

Allocation Policy

Before allocating investments to clients, we comply with our regulatory obligations to assess suitability or appropriateness. It is our policy to offer allocations to clients for whom the investment is suitable or appropriate, who have sufficient funds in their account on the commitment date and who understand the investment’s terms and conditions and are willing to be bound by them (including any special considerations attached to placings, such as selling restrictions, which are generally for a limited period of time). Our policy is to allocate investments on a pro rata basis wherever practicable.

PA Dealing

Trade Online Group has detailed policies and procedures to monitor employees’ personal account dealing and in certain circumstances restrict dealing as employees’ interests in holding or dealing in securities may conflict with the obligations to clients.

Inducements/Gifts/Hospitality

Employees must not solicit nor accept any inducements which may conflict with Trade Online Group obligations to clients, nor offer inducements which could conflict with the recipient’s obligations to its own clients. Procedures are in place on the giving or receiving gifts or hospitality. We have procedures to comply with FCA rules on inducements. We do not receive benefits from brokers in connection with the placing of orders with them.

Remuneration Policy

Trade Online Group will take care to ensure that it does not give incentives to activities that may lead to conflicts. We will not offer remuneration packages that reward behaviour that disadvantages the interests of clients in favour of Trade Online Group or other clients. Staff are rewarded on the basis of merit.

Privacy Statement

Trade Online Group fully respect your right to privacy. In order for us to carry out our services to you it will be necessary for us to use your personal information [“information”]. Please read our Privacy Policy carefully before continuing with this website.We will process your information for limited purposes that will include: responding to your requests; providing our services in accordance with our terms and conditions; developing and improving our services to you and to other customers; and informing you by letter, telephone or computer about Trade Online Group that may be of interest to you. You may tell us if you do not wish to receive marketing material. We will process this information fairly and lawfully and will store this information in accordance with the relevant data protection legislation.

The information that we will use will depend upon the information that you give to us and the information that is necessary to collate in order to carry out our services for you. In all circumstances the information will be adequate, relevant and not excessive and will be processed in line with your rights.

We will keep your information for as long as is necessary to carry out our services to you or as is required by legislation or other regulation.

We will endeavor to keep your information accurate and secure however if at any time after giving us this information, or in the case that the information becomes out of date, then we ask you to notify us directly and we shall remove or amend the information within a reasonable time frame and in accordance with legislative requirements. Internet communications are not secure unless the data being sent is encrypted. We can not accept any responsibility for unauthorised access by a third party or the incurription of data sent to us. For security purposes we may monitor emails received or issued by us.

It may be necessary for us to disclose your personal information to third parties where it is necessary to carry out the terms of our engagement or to comply with legal or regulatory requirements. In any other circumstances your information will be kept confidential and we will only share your personal information with third parties with your express consent. Your information will not be transferred outside of the UK without your consent.

We may record and monitor phone calls for your protection and ours and to maintain high quality of service standards. Our recordings will be conclusive.

For further information about your rights you may wish to contact the Information Commissioner’s office at www.ico.gov.uk.
To change your personal details or for more details then please contact Trade Online Group and Please allow a reasonable period of time for changes to personal data to be effected.

LOCATION

79 College Road Harrow HA1 1BD London United Kingdom

Phone: +447957017076

Web: www.tradeonline.org.uk