{"id":3247,"date":"2025-09-12T15:45:06","date_gmt":"2025-09-12T12:45:06","guid":{"rendered":"https:\/\/gcfxdemo.etriplesoft.com\/?page_id=3247"},"modified":"2025-09-12T15:45:06","modified_gmt":"2025-09-12T12:45:06","slug":"conflicts-of-interest-policy-complaints-handling-procedure","status":"publish","type":"page","link":"https:\/\/gcfxdemo.etriplesoft.com\/index.php\/legal\/conflicts-of-interest-policy-complaints-handling-procedure\/","title":{"rendered":"Conflicts of Interest Policy Complaints Handling Procedure"},"content":{"rendered":"
[vc_row full_width=”stretch_row” customize_bg_mobile=”1″ css=”.vc_custom_1757679529418{padding-top: 180px !important;padding-bottom: 210px !important;}” custom_styles_mobile=”.vc_custom_1757679529421{padding-top: 100px !important;padding-bottom: 100px !important;}” custom_styles_landscape=”.vc_custom_1757679529419{padding-top: 100px !important;padding-bottom: 100px !important;}”][vc_column][vc_btn title=”Download in PDF” color=”black” align=”right” i_icon_fontawesome=”fa fa-solid fa-download” css=”” add_icon=”true” link=”url:https%3A%2F%2Fgcfxdemo.etriplesoft.com%2Fwp-content%2Fuploads%2F2025%2F09%2FConflicts-of-Interests-Policy-v1-24.03.2023.pdf|target:_blank”][vc_column_text css=””]GLOBAL CAPITAL MARKET LIMITED
\nCONFLICTS OF INTERESTS POLICY
\nPOLICY OBJECTIVE
\nThis Conflicts of Interests Policy (\u201cthe Policy\u201d) is issued in accordance with the applicable Labuan legislations including (but not
\nlimited to) Labuan Companies Act 1990, Labuan Financial Services and Securities Act 2010 and others, to which Global Capital
\nMarket Limited (\u201cthe Company\u201d) is required to take all reasonable steps to detect and avoid conflicts of interest within the
\nCompany\u2019s organization & operation.
\nThe Company is committed to act honestly, fairly and professionally and in the best interests of its Clients and to comply, in
\nparticular, with the principles set out in the above legislation when providing services of Money Broking business, as defined
\nunder Section 86 of the Labuan Financial Services and Securities Act 2010 (\u201cServices\u201d).
\nThe purpose of this Policy is to set out the Company\u2019s approach in identifying and managing conflicts of interest which may arise
\nduring the course of its normal business activities. In addition, this Policy identifies circumstances which may give rise to a conflict
\nof interest. It is applied to all its directors, employees, any persons directly or indirectly linked to the Company (hereinafter called
\n\u201cRelated Persons\u201d) and refers to all interactions with all Clients.
\nCRITERIA OF IDENTIFYING CONFLICTS OF INTEREST
\nWhen the Company deals with or on behalf of the Client, the Company, an associate or some other person connected with the
\nCompany, may have an interest, relationship or arrangement that is material in relation to the transaction concerned or that
\nconflicts with the Client\u2019s interest. The Company hereby identifies and discloses a range of situations and circumstances which
\nmay give rise to a conflict of interest and potentially but not necessarily be detrimental to the interests of one or more Clients.
\nFor the purpose of identifying the types of conflicts of interest that may arise in the course of providing investment services
\nwhose existence may damage the interest of a Client, the Company will take into account (whether the Company or a relevant
\nperson) any of the following situations;
\ni.
\nii.
\niii.
\nThe Company or a relevant person is likely to make a financial gain, or avoid a financial loss, at the expense of the Client;
\nThe Company or a relevant person has an interest in the outcome of a service provided to the Client or of a transaction carried
\nout on behalf of the Client, which is district from the Client\u2019s interest in that outcome;
\nThe Company or a relevant person has a financial or other incentive to favor the interest of another Client or group of Clients
\nover the interests of the Client;
\niv. The Company or a relevant person carries on the same business as the Client;
\nv. The Company or a relevant person receives or will receive from a person other that the Client an inducement in relation to a
\nservice provided to the Client, in the form of monies, goods or services, other than the standard commission or fee for that
\nservice.
\nIDENTIFICATION OF CONFLICT OF INTEREST
\nWhile it is not feasible to define precisely or create an exhaustive list of all relevant conflicts of interest that may arise (as per the
\ncurrent nature, scale and complexity of the Company\u2019s business), the following list includes circumstances which constitute or
\nmay give rise to a conflict of interest entailing a material risk of damage to the interests of one or more Clients, as a result of
\nServices:
\ni.
\nii.
\nThe Company may be advising and providing other services to associates or other Clients of the Company who may have
\ninteresting Financial Instruments or Underlying Assets, which are in conflict or in competition with the Client\u2019s interests;
\nThe Company may have an interest in maximizing trading volumes in order to increase its commission revenue, which is
\ninconsistent with the Client\u2019s personal objective of minimizing transaction costs;
\nPage 1 of 3
\n[Global Capital Market Conflict of Interests Policy v1.0 2023\/2024]\nGLOBAL CAPITAL MARKET LIMITED
\niii.
\nThe Company may receive commissions and\/or other inducements from its Liquidity provider for the transmission of Client
\nOrders;
\niv. The Company\u2019s employee bonus scheme may award its employees based on the financial results of the Company which are
\nlinked\/associated with the trading volume generated by Clients;
\nv. The Company or a Related person has an interest in the outcome of a service provided to the Client or of a transaction carried
\nout on behalf of the Client, which is distinct from the Client’s interest in that outcome;
\nvi. The Company or a Related person has a financial or other incentive to favor the interest of another Client or group of Clients
\nover the interests of the Client;
\nvii. The Company or a related person carries on the same business as the Client;
\nviii. The Company may have relationships with many third-party product providers\/financial institutions who may remunerate
\nthe Company via inducements\/commissions\/fees and the Company may favor one over another in the recommendation
\nprocess if higher inducements\/commissions\/fees are provided;
\nix. We may compensate providers of strategies which are copied by other clients, based on number of subscribers they have.
\nPROCEDURES AND CONTROLS FOR MANAGING CONFLICTS OF INTEREST
\nIn general, the procedures and controls that the Company follows to manage the identified conflicts of interest include the
\nfollowing measures (list is not exhaustive):
\ni.
\nii.
\niii.
\nThe Company undertakes ongoing monitoring of business activities to ensure that internal controls are appropriate;
\nThe Company undertakes effective procedures to prevent or control the exchange of information between Related Persons
\nengaged in activities involving a risk of a conflict of interest where the exchange of that information may harm the interests
\nof one or more Clients;
\nThe separate supervision of Related Persons whose principal functions involve providing services to Clients whose interests
\nmay conflict, or who otherwise represent different interests that may conflict, including those of the Company;
\niv. Measures to prevent or limit any person from exercising inappropriate influence over the way in which the Related Person
\ncarries out investment services;
\nv. Measures to prevent or control the simultaneous or sequential involvement of a Related Person in separate investment
\nservices where such involvement may impair the proper management of conflicts of interest.
\nvi. A policy designed to limit the conflict of interest arising from the giving and receiving of inducements.
\nvii. Chinese walls restricting the flow of confidential and inside information within the Company, and physical separation of
\ndepartments.
\nviii. Procedures governing access to electronic data.
\nix. Segregation of duties that may give rise to conflicts of interest if carried on by the same individual.
\nx. Personal account dealing requirements applicable to Related Persons in relation to their own investments.
\nxi. Establishment of Compliance Department to monitor and report on the above to the Company\u2019s Board of Directors.
\nxii. Prohibition on officers and employees of the Company having external business interests conflicting with the interests of the
\nCompany without the prior approval of the Company’s Board of Directors.
\nxiii. A \u201cneed-to-know\u201d policy governing the dissemination of confidential or inside information within the Company.
\nxiv. Appointment of Internal Auditor to ensure that appropriate systems and controls are maintained and report to the Company\u2019s
\nBoard of Directors.
\nxv. Establishment of the \u201cfour-eyes\u201d principle in supervising the Company\u2019s activities.
\nCLIENT\u2019S CONSENT
\nBy entering into a Client Agreement with the Company for the provision of Services, the Client is consenting to an application of
\nthis Policy on him. Further, the Client consents to and authorizes the Company to deal with the Client in any manner which the
\nCompany considers appropriate, notwithstanding any conflict of interest or the existence of any material interest in a Transaction,
\nwithout prior reference to the Client. In the event that the Company is unable to deal with a conflict-of-interest situation it shall
\nrevert to the Client.<\/p>\n

GLOBAL CAPITAL MARKET LIMITED
\nDISCLOSURE OF INFORMATION
\nIf during the course of a business relationship with a client or group of Clients, the organizational or administrative
\narrangements\/measures in place are not sufficient to avoid or manage a conflict of interest relating to that Client or group of
\nClients, the Company will disclose the conflict of interest before undertaking further business with the Client or group of Clients.
\nLANGUAGES
\nLanguage of communication between the Company and the Client shall be in English. All binding contractual documentation is
\navailable in English.
\nUpon its sole discretion the Company, may communicate with the Client in other language than English, however in case of any
\ndiscrepancy between the meanings of any communications and\/or meanings, or any other communications forming part of this
\nPolicy or any other agreements, information or communication in any other language, the meaning of the English Language
\nversion shall prevail.
\nThe Company or third parties may have provided the Client with translations of this Policy. The original English versions shall be
\nthe only legally binding version. In case of discrepancies between the English version and other translations in the Client’s
\npossession, the original English version provided by the Company on the website shall prevail.
\nREVIEW OF CONFLICTS OF INTERESTS POLICY
\nGLOBAL CAPITAL MARKET LIMITED is committed to continuously improve this policy and it will be reviewed regularly (at least
\nevery six months) for effectiveness and updated.
\nThis Conflicts of Interests Policy is supported by management. GLOBAL CAPITAL MARKET LIMITED commits to providing this policy
\nto all employee and displaying it in its business with clients.[\/vc_column_text][\/vc_column][\/vc_row]\n<\/div>","protected":false},"excerpt":{"rendered":"

[vc_row full_width=”stretch_row” customize_bg_mobile=”1″ css=”.vc_custom_1757679529418{padding-top: 180px !important;padding-bottom: 210px !important;}” custom_styles_mobile=”.vc_custom_1757679529421{padding-top: 100px !important;padding-bottom: 100px !important;}” custom_styles_landscape=”.vc_custom_1757679529419{padding-top: 100px !important;padding-bottom: 100px !important;}”][vc_column][vc_btn title=”Download in PDF” color=”black” align=”right” i_icon_fontawesome=”fa fa-solid fa-download” css=”” add_icon=”true” link=”url:https%3A%2F%2Fgcfxdemo.etriplesoft.com%2Fwp-content%2Fuploads%2F2025%2F09%2FConflicts-of-Interests-Policy-v1-24.03.2023.pdf|target:_blank”][vc_column_text css=””]GLOBAL CAPITAL MARKET LIMITED CONFLICTS OF INTERESTS POLICY POLICY OBJECTIVE This Conflicts of Interests Policy (\u201cthe Policy\u201d) is issued in accordance with the applicable Labuan legislations including (but not limited to) Labuan Companies Act 1990, Labuan Financial Services and Securities Act 2010 and others, to which Global Capital Market Limited (\u201cthe Company\u201d) is required to take all reasonable steps to detect and avoid conflicts of interest within the Company\u2019s organization & operation. The Company is committed to act honestly, fairly and professionally and in the best interests of its Clients and to comply, in particular, with the principles set out in the above legislation when providing services of Money Broking business, as defined under Section 86 of the Labuan Financial Services and Securities Act 2010 (\u201cServices\u201d). The purpose of this Policy is to set out the Company\u2019s approach in identifying and managing conflicts of interest which may arise during the course of its normal business activities. In addition, this Policy identifies circumstances which may give rise to a conflict of interest. It is applied to all its directors, employees, any persons directly or indirectly linked to the Company (hereinafter called \u201cRelated Persons\u201d) and refers to all interactions with all Clients. CRITERIA OF IDENTIFYING CONFLICTS OF INTEREST When the Company deals with or on behalf of the Client, the Company, an associate or some other person connected with the Company, may have an interest, relationship or arrangement that is material in relation to the transaction concerned or that conflicts with the Client\u2019s interest. The Company hereby identifies and discloses a range of situations and circumstances which may give rise to a conflict of interest and potentially but not necessarily be detrimental to the interests of one or more Clients. For the purpose of identifying the types of conflicts of interest that may arise in the course of providing investment services whose existence may damage the interest of a Client, the Company will take into account (whether the Company or a relevant person) any of the following situations; i. ii. iii. The Company or a relevant person is likely to make a financial gain, or avoid a financial loss, at the expense of the Client; The Company or a relevant person has an interest in the outcome of a service provided to the Client or of a transaction carried out on behalf of the Client, which is district from the Client\u2019s interest in that outcome; The Company or a relevant person has a financial or other incentive to favor the interest of another Client or group of Clients over the interests of the Client; iv. The Company or a relevant person carries on the same business as the Client; v. The Company or a relevant person receives or will receive from a person other that the Client an inducement in relation to a service provided to the Client, in the form of monies, goods or services, other than the standard commission or fee for that service. IDENTIFICATION OF CONFLICT OF INTEREST While it is not feasible to define precisely or create an exhaustive list of all relevant conflicts of interest that may arise (as per the current nature, scale and complexity of the Company\u2019s business), the following list includes circumstances which constitute or may give rise to a conflict of interest entailing a material risk of damage to the interests of one or more Clients, as a result of Services: i. ii. The Company may be advising and providing other services to associates or other Clients of the Company who may have interesting Financial Instruments or Underlying Assets, which are in conflict or in competition with the Client\u2019s interests; The Company may have an interest in maximizing trading volumes in order to increase its commission revenue, which is inconsistent with the Client\u2019s personal objective of minimizing transaction costs; Page 1 of 3 [Global Capital Market Conflict of Interests Policy v1.0 2023\/2024] GLOBAL CAPITAL MARKET LIMITED iii. The Company may receive commissions and\/or other inducements from its Liquidity provider for the transmission of Client Orders; iv. The Company\u2019s employee bonus scheme may award its employees based on the financial results of the Company which are linked\/associated with the trading volume generated by Clients; v. The Company or a Related person has an interest in the outcome of a service provided to the Client or of a transaction carried out on behalf of the Client, which is distinct from the Client’s interest in that outcome; vi. The Company or a Related person has a financial or other incentive to favor the interest of another Client or group of Clients over the interests of the Client; vii. The Company or a related person carries on the same business as the Client; viii. The Company may have relationships with many third-party product providers\/financial institutions who may remunerate the Company via inducements\/commissions\/fees and the Company may favor one over another in the recommendation process if higher inducements\/commissions\/fees are provided; ix. We may compensate providers of strategies which are copied by other clients, based on number of subscribers they have. PROCEDURES AND CONTROLS FOR MANAGING CONFLICTS OF INTEREST In general, the procedures and controls that the Company follows to manage the identified conflicts of interest include the following measures (list is not exhaustive): i. ii. iii. The Company undertakes ongoing monitoring of business activities to ensure that internal controls are appropriate; The Company undertakes effective procedures to prevent or control the exchange of information between Related 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; The separate supervision of Related Persons whose principal functions involve providing services to Clients whose interests may conflict, or who otherwise represent different interests that may conflict, including those of the Company; iv. Measures to prevent or limit any person from exercising inappropriate influence over the way in which the Related Person carries out investment services; v. Measures to prevent or control the simultaneous or sequential involvement of a Related Person in separate investment services where such involvement may impair the proper management of conflicts of interest. vi. A policy designed to limit the conflict of interest arising from the giving and receiving of inducements. vii. Chinese walls restricting the flow of confidential and inside information within the Company, and physical separation of departments. viii. Procedures governing access to electronic data. ix. Segregation of duties that may give rise to conflicts of interest if carried on by the same individual. x. Personal account dealing requirements applicable to Related Persons in relation to their own investments. xi. Establishment of Compliance Department to monitor and report on the above to the Company\u2019s Board of Directors. xii. Prohibition on officers and employees of the Company having external business interests conflicting with the interests of the Company without the prior approval of the Company’s Board of Directors. xiii. A \u201cneed-to-know\u201d policy governing the dissemination of confidential or inside information within the Company. xiv. Appointment of Internal Auditor to ensure that appropriate systems and controls are maintained and report to the Company\u2019s Board of Directors. xv. Establishment of the \u201cfour-eyes\u201d principle in supervising the Company\u2019s activities. CLIENT\u2019S CONSENT By entering into a Client Agreement with the Company for the provision of Services, the Client is consenting to an application of this Policy on him. Further, the Client consents to and authorizes the Company to deal with the Client in any manner which the Company considers appropriate, notwithstanding any conflict of interest or the existence of any material interest in a Transaction, without prior reference to the Client. In the event that the Company is unable to deal with a conflict-of-interest situation it shall revert to the Client. GLOBAL CAPITAL MARKET LIMITED DISCLOSURE OF INFORMATION If during the course of a business relationship with a client or group of Clients, the organizational or administrative arrangements\/measures in place are not sufficient to avoid or manage a conflict of interest relating to that Client or group of Clients, the Company will disclose the conflict of interest before undertaking further business with the Client or group of Clients. LANGUAGES Language of communication between the Company and the Client shall be in English. All binding contractual […]<\/p>\n","protected":false},"author":1,"featured_media":0,"parent":3200,"menu_order":0,"comment_status":"closed","ping_status":"closed","template":"","meta":{"footnotes":""},"class_list":["post-3247","page","type-page","status-publish","hentry"],"_links":{"self":[{"href":"https:\/\/gcfxdemo.etriplesoft.com\/index.php\/wp-json\/wp\/v2\/pages\/3247","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/gcfxdemo.etriplesoft.com\/index.php\/wp-json\/wp\/v2\/pages"}],"about":[{"href":"https:\/\/gcfxdemo.etriplesoft.com\/index.php\/wp-json\/wp\/v2\/types\/page"}],"author":[{"embeddable":true,"href":"https:\/\/gcfxdemo.etriplesoft.com\/index.php\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/gcfxdemo.etriplesoft.com\/index.php\/wp-json\/wp\/v2\/comments?post=3247"}],"version-history":[{"count":1,"href":"https:\/\/gcfxdemo.etriplesoft.com\/index.php\/wp-json\/wp\/v2\/pages\/3247\/revisions"}],"predecessor-version":[{"id":3249,"href":"https:\/\/gcfxdemo.etriplesoft.com\/index.php\/wp-json\/wp\/v2\/pages\/3247\/revisions\/3249"}],"up":[{"embeddable":true,"href":"https:\/\/gcfxdemo.etriplesoft.com\/index.php\/wp-json\/wp\/v2\/pages\/3200"}],"wp:attachment":[{"href":"https:\/\/gcfxdemo.etriplesoft.com\/index.php\/wp-json\/wp\/v2\/media?parent=3247"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}