Regulatory Disclosures

CF Global Regulatory Disclosures

CF Global Trading, LLC is a broker-dealer registered under the Securities Exchange Act of 1934. The company is a member firm of the Financial Industry Regulatory Authority (FINRA) and the Securities Investor Protection Corporation (SIPC).

The following CF Global entities are under common control of State Street Corporation, CF Global Trading, LLC’s ultimate parent company:

CF Global Trading (UK) Ltd is authorised and regulated by the Financial Conduct Authority, No. 211134
CF Global (Hong Kong) Limited is licensed and regulated by the Securities and Futures Commission
CFGT (EU), Empresa de Investimento S.A. is licensed (n.º 451) and regulated by CMVM - Portuguese Securities Market Commission CMVM - Portal Institucional

This website can be accessed worldwide. The information provided is however only intended for use by any person in any country where such use would not be contrary to local law or regulation. It is the sole responsibility of the recipient to ascertain the terms of and comply with any local law or regulation to which they are subjected.

Please see below the disclosures specific to each CF Global entity.

CF Global Trading, LLC
CF Global (HK) Ltd
CF Global Trading (UK) Ltd

CRYPTOCURRENCY NOTICE: None of the CF Global entities trade cryptocurrencies or accept payment in cryptocurrency.

CF Global Trading, LLC Disclosures

CF Global Trading, LLC is regulated by FINRA and is a member of SIPC.

PRIVACY DISCLOSURE

CF Global Trading, L.L.C. and its Affiliates (collectively “CF Global” or “we”) understand that our clients’ privacy is important and we are committed to maintaining their confidentiality. The following disclosure explains our policy regarding non-public information and the process we have in place to protect our clients’ privacy and the confidential information we receive from our clients.

We collect non-public information about clients and counterparties from various sources (“Personal Data”), which include the following:

- Information we receive on applications and other forms (such as name, address, e-mail address, telephone number, Social Security Number, assets and income);

- Information about our clients' financial transactions with us or others;

- Information that we received from non-affiliated third parties (such as credit rating agencies) or other entities who may service our clients' accounts from time to time.

We may use our clients’ information in order to operate our business in a prudent manner in accordance with industry standards and applicable law, which may include servicing and maintaining accounts and transactions, offering a broad range of services and products, verifying income and assets, responding to inquiries and requests, preventing fraud, monitoring and archiving communications and verifying our clients’ identity in accordance with the USA PATRIOT Act.

We do not disclose any non-public information to any non-affiliated third parties other than as permitted by law. We may disclose or share non-public information about our clients to our affiliates or third parties involved in servicing our clients’ accounts. We do not otherwise provide information about our clients to outside firms, organizations or individuals except to our attorneys, accountants and auditors and as permitted by law. We will, however, release information about our client if directed to do so by such client or if compelled or required to do so by law or self-regulatory organization (“SRO”) regulations.

We restrict access to our clients’ information to those employees who need to know such information to provide products or services to our clients. We maintain physical, electronic and procedural safeguards to guard and protect all clients’ information from unauthorized access, accidental or intentional manipulation, loss and destruction. Employees who violate these policies are subject to disciplinary action, including termination. Our clients’ information is secure and is not shared with a third party unless such third party is involved in servicing our clients’ relationship with CF Global or as required, in limited situations, by law or SRO regulations.

CHOICES AND ACCESS

If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt-out by contacting your client relationship manager, primary point of contact or email: CFGTCompliance@cfglobal.com. Please note we will still send you important administrative and service or transaction-related messages, which you cannot opt out of.

How individuals can access, change or suppress their Personal Data: If you would like to request a review, correct, update, suppress, restrict or delete Personal Data that you have previously provided to us, or if you would like to request to receive an electronic copy of your Personal Data for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact CFGTCompliance@cfglobal.com. We will respond to your request consistent with applicable law. For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. Please note that we may need to retain certain information for recordkeeping and regulatory purposes. Additional Information for the EEA: You also retain the right to complain to a supervisory authority in the EEA competent for your relevant country or region.

RETENTION PERIOD: We will retain Personal Data for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with our client and service their account(s); (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of applicable statutes of limitations, or regulatory investigations.

JURISDICTION AND CROSS-BORDER TRANSFER: Personal Data may be stored and processed in any country where we engage service providers to provide services to our client’s account(s). In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access Personal Data. Transfer may also be made pursuant to contracts in your interest or at your request. Additional Information for the EEA: Where personal data is sent to third parties or service providers in countries outside the EEA, we ensure they have adequate level of data protection according to EEA standards.

SENSITIVE INFORMATION: We do not typically collect sensitive Personal Data in connection with the Services. Please do not send us any Personal Data which would be categorized as special data under GDPR (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership).

SUMMARY & DISCLOSURE OF BUSINESS CONTINUITY PLAN

CF Global has prepared, and has always maintained a current Business Continuity Plan (“BCP”) in compliance with Financial Industry Regulatory Authority (“FINRA”) Rule 4370. This document outlines our plans to continue our business and meet our existing obligations to our clients in the event of a significant business disruption (“SBD”). Our BCP is summarized below:

CF Global’s policy is to respond to a SBD by safeguarding our employees’ lives and our property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of our books and records and allowing our clients to transact business. We will make every reasonable effort to meet our obligations to our clients at all times. We have in place a BCP that outlines essential parts of our business and discusses in detail:

1) Data back-up and recovery (hard copy and electronic);

2) All mission critical systems;

3) Financial and operational assessments;

4) Alternate communications between our clients and us;

5) Alternate communications between our employees and us;

6) Alternate physical location of our employees;

7) Critical business constituents, banks, and counter-party impact;

8) Regulatory reporting;

9) Communications with regulators; and

10) How CF Global shall assure our clients’ prompt access to their funds and securities (if applicable) in the event that we determine that we are unable to continue our business.

During the time that CF Global may not be in operation, we shall provide alternative contact information to our clients via our website at www.cfglobal.com in order to effect transactions and for any other required client activity. In the event you are unable to reach us via the information provided on our website or by calling us at 212.888.4711 please contact our clearing firm RBC Capital Markets, LLC Inc. at 212.428.2380 or 212.618.3268.

Customer Identification Program

To help the U.S. government fight the funding of terrorism and money laundering activities, Federal law requires all U.S. financial institutions, such as CF Global, to obtain, verify and record information that identifies each individual or institution that establishes a customer relationship with such financial institutions.

If a client enters into a customer relationship with CF Global, which includes opening an account at CF Global, we will request certain financial and legal information about such client, including such client’s legal name, tax identification number and address, and the identity of any individuals with any authority or control over such client. We also verify such information to the extent required as follows:

- Taking steps to check the information provided – to verify that the clients are who they say they are.

- Consult applicable governmental agency lists of known or suspected criminals, terrorists and terrorist organizations to determine if anyone on any such list is attempting to open or maintain an account.

- Conduct, in certain instances, additional due diligence when accounts are opened for foreign persons, institutions or other clients.

The U.S. Department of the Treasury, U.S. Securities and Exchange Commission (the “SEC”) and FINRA rules already require clients to provide most of this information.

If a client refuses to provide the information requested or a client’s identity cannot be verified, CF Global may not be able to establish or maintain a business relationship with such client. If such client has already established a relationship with CF Global, we may have to terminate such relationship. If a client establishes a relationship with CF Global and refuses to provide this information, we may be required to report such refusal to appropriate governmental authorities.

Notice: Pursuant to U.S. regulations issued under section 311 of the USA PATRIOT Act, 31 CFR 103.192

We are prohibited from opening or maintaining a correspondent account for, or on behalf of the “Specified Institutions” or Jurisdictions of Primary Money Laundering Concern. (https://www.fincen.gov/resources/statutes-and-regulations/311-special-measures ). The regulations also require us to notify you that your correspondent account with our financial institution may not be used to provide the Specified Institutions with access to our financial institution. If we become aware that the Specified Institutions are indirectly using the correspondent account you hold at our financial institution, we will be required to take appropriate steps to prevent such access, including terminating your account.

Monthly / Quarterly Statements

Unless you specifically request monthly/quarterly statements, you will be presumed to have waived any requirement by CF Global to provide you with such statements. Should your firm require such statements, please contact CF Global’s Compliance Department at 212.888.4673.

Options Disclosure

Options involve risk and are not suitable for all investors. Before trading options read the Characteristics & Risks of Standardized Options booklet.

SEC Rule 606 Order Routing Disclosure

SEC Rule 606 requires all brokers and dealers to make publicly available for each calendar quarter a report on its routing of non-directed orders in national market system securities during that quarter. The reports must identify the significant venues to which clients’ orders were routed for execution during the applicable quarter and disclose certain aspects of the broker or dealer's relationship with such venues. Please use this link to view CF Global’s required reports on the routing of customer orders.

Furthermore, pursuant to SEC Rule 606(b), at the request of any of our clients, we will provide to such requesting client information regarding the identity of the venue to which such requesting client’s orders were routed for execution in the six (6) months prior to such request, whether such orders were directed orders or non-directed orders and the time of the transactions, if any, that resulted from such orders. Should you require such information, please send an email to CFGTcompliance@cfglobal.com with a subject line of “Rule 606 Request” and all pertinent information necessary to identify the orders(s) subject to the request.

Customer Complaints

Any customer complaint should be forwarded to CF Global’s Chief Compliance Officer via email at CFGTCompliance@cfglobal.com or via telephone at 212.888.4673. Physical mail in relation to these items should be directed to: CF Global Trading, L.L.C., Attn: Compliance, 60 East 42^nd Street, Suite 1455 New York, NY 10165.

FINRA Broker Check

FINRA Rule 2267 requires CF Global to provide information about FINRA’s BrokerCheck program. An investor brochure that includes information describing the BrokerCheck program may be obtained from FINRA. The FINRA BrokerCheck hotline number is (800) 289-9999. The FINRA website address is https://www.finra.org/Investors/ToolsCalculators/BrokerCheck/.

SIPC Disclosure

CF Global is a member of the Securities Investor Protection ("SIPC"). Information about account protection coverage provided by SIPC can be obtained by visiting their website at www.sipc.org. The telephone number is 202-371-8300.

Notice to Canadian Clients Under National Instrument 31-103

Pursuant to the international dealer registration exemption in National Instrument 31-103, the Company is informing you of the following:

- CF Global Trading LLC (the “Company”) is not registered in Canada and is advising you, its client, in reliance upon an exemption from the dealer registration requirement under National Instrument 31-103.

- The below list contains CFGT’s agent for service of process for each applicable province:
Borden Ladner Gervais LLP (Laurie J. Cook)
4400 - 40 King Street West
Scotia Plaza
Toronto, Ontario
M5H 3Y4
Borden Ladner Gervais LLP (Jonathan L. Doll)
Centennial Place, East Tower
1900, 520 – 3rd Ave S W
Calgary, AB, Canada
T2P 0R3

- Clients may have some difficulty in enforcing any legal rights they may have against the Company because the Company is resident outside Canada and all or a substantial portion of its assets are situated outside Canada. The Company is not fully subject to the requirements of the Securities Act and the regulations thereunder concerning proficiency, capital, insurance, record keeping, segregation of funds and securities, statements of account and portfolio, and conflicts of interest.

Extended Hours Trading Risk Disclosure

You should consider the following points before engaging in extended hours trading. "Extended hours trading" means trading outside of regular trading hours.” “Regular trading hours” generally means the time between 9:30 a.m. and 4:00 p.m. Eastern Standard Time.

Risk of Lower Liquidity: Liquidity refers to the ability of market participants to buy and sell securities. Generally, the more orders that are available in a market, the greater the liquidity. Liquidity is important because with greater liquidity it is easier for investors to buy or sell securities, and as a result, investors are more likely to pay or receive a competitive price for securities purchased or sold. There may be lower liquidity in extended hours trading as compared to regular trading hours. As a result, your order may only be partially executed, or not at all.

Risk of Higher Volatility: Volatility refers to the changes in price that securities undergo when trading. Generally, the higher the volatility of a security, the greater its price swings. There may be greater volatility in extended hours trading than in regular trading hours. As a result, your order may only be partially executed, or not at all, or you may receive an inferior price when engaging in extended hours trading than you would during regular trading hours.

Risk of Changing Prices: The prices of securities traded in extended hours trading may not reflect the prices either at the end of regular Trading hours, or upon the opening the next morning. As a result, you may receive an inferior price when engaging in extended hours trading than you would during regular trading hours.

Risk of Unlinked Markets: Depending on the extended hours trading system or the time of day, the prices displayed on a particular Extended hours trading system may not reflect the prices in other concurrently operating extended hours trading systems dealing in the same securities. Accordingly, you may receive an inferior price in one extended hours trading system than you would in another extended hours trading system.

Risk of News Announcements: Normally, issuers make news announcements that may affect the price of their securities after regular trading hours. Similarly, important financial information is frequently announced outside of regular trading hours. In extended hours trading, these announcements may occur during trading, and if combined with lower liquidity and higher volatility, may cause an exaggerated and unsustainable effect on the price of a security.

Risk of Wider Spreads: The spread refers to the difference in price between what you can buy a security for and what you can sell it for. Lower liquidity and higher volatility in extended hours trading may result in wider than normal spreads for a particular security.

CF Global (HK) Limited Disclosures

CF Global (Hong Kong) Limited is licensed and regulated by the Securities and Futures Commission. It is a separate but affiliated entity of CF Global Trading, LLC.

Only the products and services referred to on this website offered by CF Global (HK) Limited are available to persons residing in Hong Kong. It is the sole responsibility of the recipient to ascertain the terms of and comply with any local law or regulation to which they are subjected.

CRYPTOCURRENCY NOTICE: CF Global (HK) Limited does not and will not trade cryptocurrencies or accept payment in cryptocurrency.

CF Global Trading, (UK) Ltd Disclosures

CF Global Trading (UK) Ltd is authorised and regulated by the Financial Conduct Authority, No. 211134. It is a separate but affiliated entity of CF Global Trading, LLC.

Order Execution Policy

Introduction

Under the EU Markets in Financial Instruments Directive 2014/65/ EU (MiFID II) and the rules of our regulator, the Financial Conduct Authority [FCA], we are required to have an order execution policy and to take all sufficient steps to obtain the best possible results for our clients when executing or receiving and transmitting client orders.

Scope
Our execution policy is applicable to CF Global Trading (UK) Ltd [CFG]’s Professional Clients and Eligible Counterparties as determined in accordance with the client classification rules of the FCA. CFG does not engage in retail client business.

CFG’s execution policy is applicable to clients and where we have received an order:

a) To execute on their behalf in respect of financial instruments covered by the Markets in Financial Instruments Directive; or
b) Which we pass on (i.e. transmit) at our discretion to another broker or dealer (“third party”) for execution.

This duty of best execution only applies when executing orders “on a client’s behalf”.

We will be executing orders “on a client’s behalf” where the client legitimately relies on us to protect his or her interests in relation to the pricing or other aspects of the transaction that may be affected by how we execute the order. For example, this will be the case when we: -

execute an order by dealing as agent;
execute an order by dealing as matched principal on behalf of a client; and
“work” an order on a client’s behalf.

This policy only applies to transactions in financial instruments falling within the scope of MiFID II. It will therefore cover cash equities and equity-like shares, depositary receipts, debt instruments, funds and derivatives in interest rates, currencies, equity and indices.

Execution Processes

When executing a client order we will seek to obtain the most favourable terms taking into account our regulatory obligations, any specific terms that the client may impose and the sequence that we receive orders. Where there is only one venue and therefore the only pricing consideration is execution time, comparable prices are precluded.

The Quality of Execution

CFG’s policy in providing Best Execution is so far as possible, and subject to the processes set out below, to exercise the same standards and operate the same processes across all the different markets, exchanges and venues on which it executes your orders.

When we execute an order on your behalf, or receive and transmit an order for execution on your behalf, we take all sufficient steps to achieve the best possible result for your order in accordance with MiFID II and our Execution Policy, subject to any specific instructions that you give us, the priorities you place upon us in filling the order, the nature of your order, the market or the source of liquidity (“venue”) in question and any other factors relevant to execution.

The diversity in markets and venues mean that different factors including price, costs, the need for a timely execution, the liquidity of the market, the size of the order, whether it is executed on a regulated market, MTF, OTF or OTC will have to be taken into account when assessing Best Execution. Price is not always the final determinate: Where liquidity is a priority, the best reflected price may be irrelevant. In the absence of express and explicit instructions from you, we will exercise our own discretion in determining the factors that need to be taken into account to provide you with the best possible execution including our understanding and experience of the market in question, our knowledge of your investment process, and the nature of the trading service you require of CFG.

CFG always acts as either agent or matched principal on your behalf and always charges a transparent commission. A “net price” will only be shown when specifically requested by the client. CFG does not mark up or down the price of a security unless explicitly told to do so when facilitating transparent ‘commissions’ in markets such as fixed income and do not take positions for ourselves except in the event of an error.

We believe the policy and processes, defined below, provide the best balance across a range of sometimes conflicting factors to achieve the most favourable terms reasonably available on a consistent basis. CFG is, however, not under an obligation to obtain the best possible result for each individual order, and our commitment to provide you with Best Execution does not mean that we owe you any fiduciary or other responsibilities over and above our specific regulatory obligations.

Execution Factors

CFG will take into consideration a range of different factors to determine the manner in which best execution will be executed including, but not limited to:

Price
Size and nature of the order
Likelihood of execution
Speed of execution
Likelihood of settlement
Cost of execution

Execution Criteria

CFG seeks to obtain the most favourable terms reasonably available when executing an order on your behalf. To achieve this CFG will:

1. Ensure its regulatory obligations are met with regard to client classification;

2. Carefully consider the elements of order execution including the factors set out above, while taking into account

2.1. The characteristics of the client order

2.2. The client’s specific instructions and the sequence with which the order is received

2.3. The characteristics of financial instruments that are the subject of that order

2.4. The characteristics of the execution venues to which that order can be directed

3. Employ sophisticated technology for routing, monitoring and executing orders such that the execution outcome is competitive and in the best interests of the client on a consistent basis; and

4. Regularly review overall execution quality.

Execution Process – Venue Selection

In meeting our obligation to take all sufficient steps to obtain the best possible result when executing your order in transferable securities, we may access various sources of liquidity, including: Regulated Markets. Multilateral Trading Facilities, Systematic Internaliser, Organised Trading Facilities, Market makers and other alternative liquidity providers or non EEA entities performing similar functions.

CFG considers the combined effect of all execution criteria and execution factors referred to above when determining the best venue for execution. Where comparative factors differ across execution venues (e.g. cost of execution, cost of settlement), CFG applies the following priorities to determine the most appropriate venue unless specifically instructed otherwise:

1. Price and size improvement. Dependent on the nature of the order, CFG may be able to obtain a more favourable outcome by accessing alternative pools of liquidity, or aggregating similar orders to realize benefits of scale. CFG will also seek opportunities for client orders to benefit from order size guarantees offered by brokers, exchanges and other market participants;

2. Speed and certainty of execution. Especially during volatile market conditions CFG will focus on execution venues that have a proven track record for providing liquidity and competitive pricing. At all times CFG seeks to provide the fastest execution reasonably possible under the parameters of the client’s instructions; and

3. Overall execution quality and cost. When determining how and where to route or execute an order, CFG draws on extensive experience with various markets, market makers and electronic networks focusing on prompt, reliable and cost effective solutions.

CFG uses electronic systems to route and execute some client orders. When a customer order is received it is routed to the Best Execution venue as determined by the criteria above.

Certain large orders may require special handling to minimize market impact and be managed by CFG’s trading desk in a manner consistent with CFG’s Best Execution principles. This may include algorithmic trading tools where deemed appropriate by the CFG’s traders’ discretion.

CFG uses Direct Electronic Access (DEA) mechanisms through various investment banks and local brokers and do not maintain direct membership to any exchanges, although our associate firm, CF Global Trading LLC, does have membership to ARCA and BATS. In these cases, CFG maintains full control of the order. In other instances, we may transmit the order to another broker as an agent or an introducing broker in which case we monitor the execution closely.

We carefully select the brokers we use and satisfy ourselves that they have arrangements in place to enable us to comply with our Best Execution obligation to you. Orders in Asia and the Americas may be passed to an affiliate.

In extreme volume and volatility situations, exchange system constraints require automated trading solutions to be switched off and/or electronic routing to be suspended in favour of manual execution. Such events lead to further execution delay and increased market volatility. Clients should be aware of the following risks associated with volatile markets, especially at or near the close of the standard trading session: an order may be executed at a substantially different price from the quoted bid or offer, or the last reported sale price at the time of the order entry, or an order may be only partially executed or may be executed in several transactions at different prices; and opening prices may differ substantially from the previous day’s close.

We continuously assess the execution venues available in respect to any product that we trade in order to ensure they continue to allow us to provide you with the best possible results for your orders.

Execution Venues

The CFG execution venues can be found at www.cfglobal.com which details the instruments we are involved with and which execution venues are used for each instrument. The list is not exhaustive but represents those execution venues and vendors that we place significant reliance upon.

We believe that the execution venues detailed are appropriate to providing best execution to you as these venues enable us to obtain, on a consistent basis, the best possible result for the execution of client orders. The charges passed down to the client are consistent with the cost to the firm of dealing with each execution venue so as not to unfairly discriminate against any one execution venue.

Where we are not responsible for the actual execution but instead transmit the order to a third party for execution, we will ensure that the third party is contracted to providing us best execution.
In certain financial instruments, there may only be one execution venue, and in executing a trade in such circumstances we shall presume that we have provided the best possible result in respect of these types of financial instruments.

Fees and Inducements

The fees that CFG charge the client are detailed in a client commission schedule mutually agreed prior to trading. CFG receive no inducements from any execution venue.

Review & Monitoring

CFG monitors the effectiveness of its order execution arrangements and order execution policy on an on-going basis to identify and, where appropriate, correct any deficiencies.

CFG assess the execution venues or the broker to whom we transmit orders for execution. This is to provide for the best possible result for our clients on a consistent basis and to establish whether CFG needs to make changes to its execution arrangements.
As part of CFG’s regular monitoring process, CFG have access to sophisticated Transaction Cost Analysis (TCA) analytics, currently supplied by LiquidMetrix (subject to change) to aid the reviewing and monitoring process. CFG, if requested, can produce these TCA reports to show the quality of execution and process.

Executing brokers used by CFG within the European Economic area (other than EEA member states who have not yet implemented the Best Execution rules of MiFID II) are required to have their own execution arrangements that enable CFG to comply with this policy. CFG will assess and where necessary seek appropriate assurances as to whether these brokers are meeting obligations regarding execution quality. CFG will also assess and seek assurance that brokers in other jurisdictions are consistently providing quality execution.

CFG will review this policy whenever a material event occurs that affects or contributes to the Best Execution outcome. Should no such event occur, the review will take place at least on an annual basis. Our most updated policy is available our website at www.cfglobal.com

Specific Client Instructions

Where you provide CFG with a specific instruction in relation to an order or a part of the order or any particular aspect of it, including the selection of a venue, we will execute the order in accordance with these instructions and in doing so, CFG will be deemed to have taken all sufficient steps to provide the best possible result in respect of that order or aspect of that order. This may prevent us from taking the steps that we have implemented to obtain the best possible result for your order. To the extent that your specific instructions are not comprehensive, we will apply this policy to those aspects not covered by your instructions.

The particular execution roles and responsibilities of CFG and its client will depend on the type of execution instruction received. At all times, the client passing the order to CFG retains responsibility for Best Execution to its end client.

Client Limit Orders

The FCA requires unexecuted client limit orders to be made public immediately unless the client expressly instructs otherwise. By consenting to this policy, you are expressly instructing CFG not to make such orders public unless we believe that by doing so, it will be to your advantage.

CFG are required to gain express consent prior to executing an order in an instrument admitted to trading on a Regulated Market, Systematic Internaliser, MTF or OTF outside of such a Regulated Market, Systematic Internaliser, MTF or OTF.

Please sign and return a copy of this notice to our compliance department since we will otherwise be prevented from achieving the best possible result where this is achieved by executing your order outside of a Regulated Market, Systematic Internaliser, MTF or OTF.

Aggregation and allocation of orders

CFG may, from time to time, aggregate client orders, taking into account ‘Execution Factors’ (see the eponymous section above for details) for a specific trade, but will only do so where we reasonably believe that it is in the overall best interest of each relevant client. For occasions where liquidity is constrained, please see the scenarios below of how we would execute the aggregated orders according to the prevailing market conditions.

If liquidity is not constrained, orders will be worked separately in the market.

Scenario 1:
- Client A is a Buyer of 100 shares, Client B is a Buyer of 500 shares.
- An aggregated Buy order of 200 shares would be created, split evenly between client A & B, until such time that Client A is complete on 100, and Client B has bought 100, at which point Client B continues with their balance of 400 shares.

Scenario 2:
- Client A is a Buyer of 100 shares having bought 50 shares already, Client B is a Buyer of 500 shares. An aggregated Buy order of 100 shares would be created, split evenly between Client A & B, until such time that client A has completed their order of 50 shares, and Client B continues with their balance of 450.

Our communication with each client about a competing order will be at the discretion of the dealing desk, who will understand each relevant clients’ requirements. We will look to maximise each client’s opportunities without disadvantaging any other client.

Alongside our regular best execution monitoring and TCA analysis, on an annual basis, independent sample testing in the form of an assurance report from a third party on sequential trading is conducted to identify and review any incidents where more than 1 trade was executed in the same instrument, on the same day, traded in the same direction (i.e., buy or sell), on the same exchange and currency, by more than one legal entity. This is then presented to the Board for review.

CONSENT FORM TO CF GLOBAL TRADING (UK) LIMITED ORDER EXECUTION POLICY

We consent to CF Global Trading (UK) Limited Order Execution Policy including inter alia:

CF Global Trading (UK) Limited executing orders outside a Regulated Market, Systematic Internaliser, MTF or OTF; and
Unexecuted limit orders not being made public immediately.

FOR AND ON BEHALF OF:

AUTHORISED SIGNATURE(s):

PRINT NAME (s):

DATED:

Please note that we are required to obtain your prior consent to this policy. As a Professional Client or Eligible Counterparty, you will be deemed to provide such consent when you give an order.

Pillar 3 Disclosure

Click here to download the latest Pillar 3 Disclosure in PDF format.

Conflicts of Interest Policy

Contents

Introduction
Conflicts of Interest
Independence
Chinese Walls
Segregation of duties
Disclosing an Interest
Declining to Act
Gifts and Inducements
Appendix A (List of Conflicts)
Appendix B (Gifts Register)

1. Introduction

Principle for Business number 8 (Conflicts of interest) requires CF Global (UK) limited (CFG) to pay due regard to the interests of each customer and to manage any conflicts of interest fairly, both between itself and its customers and between a customer and another client. The specific rules for dealing with conflicts of interest can be found under the Senior Management Systems and Controls (SYSC) rules which can be found at SYSC 10.1 onwards.

2. Conflicts of Interest

Conflicts of Interest appear in situations where CFG:

is likely to make a financial gain, or avoid a financial loss, at the expense of the client;
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;
has a financial or other incentive to favour the interest of another client or group of clients over the interests of the client;
carries on the same business as the client; or
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, other than the standard commission or fee for that service.

We must not knowingly advise, or deal in the exercise of discretion, in relation to that transaction unless we take reasonable steps to ensure fair treatment for the customer.

This is normally achieved by managing the conflict of interest by taking reasonable steps in one or more of the following ways:

identifying the circumstances which may give rise to a conflict of interest;
having procedures in place which would be followed in order to prevent a conflict:
having procedures in place to ensure no conflict with persons whose principal functions involve carrying out activities for clients;
having procedures in place to ensure that there is no direct link between remuneration of individuals engaged in client activity and their remuneration:
declining to act for a customer.

3. Managing Conflicts

CFG may be able to demonstrate that it has taken reasonable steps to ensure fair treatment for its customers by relying on this Conflicts of Interest policy. In such cases, relevant employees are required to disregard any material interest or conflict of interest when advising a customer. If considered appropriate by the directors, CFG may, at its discretion disclose its material interest or conflict of interest to its customer.

The FCA requires firms to identify all known conflicts within this policy (see Appendix A) along with the method of dealing with the conflict. The Firm should pay special attention to the activities of investment research and advice, proprietary trading, portfolio management and corporate finance business, including underwriting or selling in an offering of securities and advising on mergers and acquisitions. In particular, such special attention is appropriate where CFG or a person directly or indirectly linked by control to the firm performs a combination of two or more of those activities.

The measures for dealing with conflicts will be designed to ensure that relevant persons engaged in different business activities involving a conflict of interest carry on those activities at a level of independence, appropriate to the size and activities of the firm and of any group to which it belongs and to the materiality of the risk of damage to the interests of clients.

Examples of types of procedures for managing conflicts

(i) 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;

(ii) 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 firm;

(iii) 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 principally engaged in another activity, where a conflict of interest may arise in relation to those activities;

(iv) measures to prevent or limit any person from exercising inappropriate influence over the way in which a relevant person carries out services or activities; and

(v) measures to prevent or control the simultaneous or sequential involvement of a relevant person in separate services or activities where such involvement may impair the proper management of conflicts of interest.

4. Chinese Walls

Another method by which CFG can manage conflicts of interest is to establish and maintain internal arrangements restricting the movement of information within the firm. This requires information held by a person in the course of carrying on one part of our business to be withheld from, or not to be used by, persons with or for whom we act in the course of carrying on another part of our business. Such an arrangement is referred to as a Chinese Wall.

The FCA’s rules with regard to Chinese Walls are set out in SYSC 10.2. CFG has adopted these rules in determining its own policies with regard to Chinese Walls which is as follows:

(1) when CFG establishes and maintains a Chinese wall it may:

(a) withhold or not use the information held; and

(b) for that purpose, permit persons employed in the first part of its business to withhold the information held from those employed in that other part of the business;

but only to the extent that the business of one of those parts involves the carrying on of regulated activities or ancillary activities.

(2) information may also be withheld or not used by the firm when this is required by an established arrangement maintained between different parts of the business (of any kind) in the same group. This provision does not affect any requirement to transmit or use information that may arise apart from the rules in COBS.

(3) for the purpose of this rule, "maintains" includes taking reasonable steps to ensure that the arrangements remain effective and are adequately monitored, and must be interpreted accordingly.

Attribution of knowledge

When any of the rules of COBS or CASS apply to CFG when it acts with knowledge, the firm will not be taken to act with knowledge for the purposes of that rule if none of the relevant individuals involved on behalf of the firm acts with that knowledge as a result of arrangements established under SYSC 10.2.2 R

Where CFG establishes and maintains a Chinese Wall, individuals on the "other side of the wall" will not be regarded as being in possession of knowledge denied to them as a result of the Chinese Wall.

Acting as outlined above does not amount to market abuse, making misleading statements or engaging in misleading practices.

5. Segregation of Duties

CFG strives to ensure that the performance of multiple functions by its relevant persons does not and is not likely to prevent those persons from discharging any particular functions soundly, honestly and professionally. Our policies concerning the segregation of duties within the firm and the prevention of conflicts of interest are laid out below.

CFG is aware that effective segregation of duties is an important element in the internal controls of a firm in the prudential context. In particular, it helps to ensure that no one individual is completely free to commit the firm’s assets or incur liabilities on its behalf. Segregation also help to ensure that the firm’s governing body receives objective and accurate information on financial performance, the risks faced by the firm and the adequacy of its systems.

CFG ensures that, in general, no single individual has unrestricted authority to do all of the following:

initiate a transaction;
bind the firm;
make payments; and
account for it.

Where CFG is unable to ensure the complete segregation of duties due to its limited employee base, it has adequate compensating controls in place including the frequent review of an area by relevant senior managers.

The firm ensures that its relevant persons are aware of the procedures which must be followed for the proper discharge of their responsibilities.

The firm monitors and, on a regular basis, evaluates the adequacy and effectiveness of its systems, internal control mechanisms and arrangements in relation to conflicts of interest and will take appropriate measures to address any deficiencies.

6. Disclosing an Interest

(1) Disclosing a conflict of interest is not a form of managing that conflict of interest. CFG will only disclose a conflict of interest when CFG's administrative and organisational arrangements have failed in this regard or are not sufficient to ensure, with reasonable confidence, that the risks of damage to the interest of the clients will be prevented. As such, it is a measure of last resort to address CFG's regulatory obligations.

(2) The disclosure must:

(a) be made in a durable medium; and

(b) include sufficient detail, taking into account the nature 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.

Disclosing an interest to a customer would normally be required where the firm has an interest in a transaction on which it is advising or where the firm derives, or will derive, consultancy, non-executive director or other fees from customers involved in a transaction.

Disclosure of a material interest or conflict of interest to a customer must be made in writing. Oral disclosure is to be avoided. Disclosure must be made before we advise our customer on a transaction and we must be able to demonstrate that we have taken reasonable steps to ensure that the customer does not object to our material interest or conflict of interest.

7. Declining to Act

If CFG determines that it is unable to manage a conflict of interest using one of the methods described above, we should decline to act on behalf of the customer concerned.

8. Gifts and Inducements

Clients, for a variety of reasons, may offer gifts to employees such as annual celebrations or to commemorate the completion of a large and/or complicated transaction. Often, it would be considered impolite to refuse. Care must be taken to ensure that such gifts cannot be construed as an inducement to provide a service more favourably to that client ahead of another.

Our rules with regard to gifts and inducements are as follows:

Gifts with a value of less than £150.00 need not be declared
Gifts with a value greater than £150.00 must be notified to the Compliance Officer for inclusion in the Gifts and Inducements register (see Appendix B)
If a client offers more than one gift in a twelve-month period, with a cumulative value of more than £150.00, these must also be declared to the Compliance Officer as well (see Appendix B)
The Compliance Officer will send out a memorandum for all gifts to be declared on an annual basis. This memorandum will include a list of all gifts already declared. Any gifts not already declared which have a value greater than £150.00 must be included on this memorandum.

9. Appendix A (List of Conflicts)

Identified Conflict	Procedures for Dealing with this Conflict
Brokers using knowledge gained to trade for their own account	All Personal Account Trading is notified to the Compliance Officer and then reviewed for potential conflicts of interest.
Favouring one client over another	There is close supervision of the price distribution process on the broking floor by the CEO. This is audited annually by an external provider.
Firm front running client orders	The firm does not take positions
Brokers passing information to third parties during the day	No use of mobile phones on floor and all phone lines recorded.

10. Appendix B (Gifts Register)

Name

Source of Gift

Gift

Estimated Value

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Last update: 2023-11-07

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