Legal Documentation

In order to meet our obligations under PRIIPs (Packaged Retail Investment and Insurance Products) regulation, we have produced the following key information documents for each product type we offer. These documents are aimed to help you better understand our products, including the risks, costs and examples of potential gains and losses associated with them, and any other relevant information.

• FX (Rolling Spot Forex Contract/CFD)
• Indices (CFD)
• Gold (CFD)
• Silver (CFD)
• US Oil/UK Oil (CFD)

Your privacy is of paramount importance to us. At Hantec Markets we protect personal data and confidentiality of the information and respect the privacy rights of our existing and prospective customers.

Hantec Markets collects data to operate effectively and provide you with a valuable service while ensuring that your needs are met.

This privacy notice explains what personal data we collect from you in connection with the provision of our products or services to you or from your use of our products and services, as well as through our interactions with you through our website or applications. This notice also outlines how the data that we collect is used.

Data Controller

This Privacy Notice applies to the data processing activities carried out by Hantec Markets Limited who acts as a Data Controller of your personal information.

Hantec Markets Limited is registered in England and Wales, company number 06819047, principal place of business 5‑6 Newbury Street, London EC1A 7HU, registration number with the Information Commissioner is ZA188388.

If you have any questions about this notice or wish to exercise your rights in relation to your personal information, please contact the Data Protection Officer:

• Call: +44 (0) 207 036 0882
• Email: [email protected]
• Write to us: Compliance Department, Hantec Markets, 5‑6 Newbury Street, London EC1A 7HU

What Type of Personal Data We Collect and How We Collect It?

The data we collect depends on the context of your interactions with us, the choices you make, including the products and services you use or wish to start using. The data we collect about you can include the following:

• Name and contact data: We collect your full name, email address, personal postal address, phone number, and other similar contact data.
• Demographic data: We collect data about you such as your date and place of birth, gender, country, and preferred language.
• Location data: For certain products and services, we collect imprecise data about your location that includes, for example, a location derived from your IP address.
• Profession and employment details: We collect details of your employment and your source of income.
• Government-issued photographic identification: We collect copies of passports, national ID cards, driving licenses and other acceptable forms of ID that contain photos.
• Financial and tax information: We collect information about your income, assets and liabilities, balances of your accounts, trading and financial statements, bank details, tax identification numbers and other identification numbers used for tax purposes.
• Trading information: We keep records of the products you trade with us and their performance.
• Credentials: We collect passwords, password hints, and similar security information used for authentication and account access.
• Content: We collect the content of all telephone conversations and electronic communications between us that result in placing and/or closing an order or a trade, including communications that are intended to result in placing and/or closing an order or a trade, irrespective of the outcome.

We collect the content of files and communications we receive from you, when necessary to provide you with the products and services you use or intend to use. This includes files and communications sent and received by us via Outlook, our Client Portal and by post.

• To perform essential business operations (including monitoring and improving) and provide the products and services we offer;
• To perform administration on the account you may hold with us on an on-going basis, including keeping records we hold accurate and up-to-date;

• Other companies within the Hantec Group.
• Vendors, service providers and specialist advisers who have been contracted to provide us with administrative, IT, financial, compliance, legal, regulatory, insurance, research or other services and who work on our behalf for the purposes described in this notice and may need access to personal data to provide those functions.

In such cases, the contractors must abide by our data processing agreements and are not allowed to use personal data they receive from us for any other purpose.

• Introducing brokers with whom we have a mutual contractual relationship;
• Anyone authorised by you.

We may also disclose personal data to:

• Courts, tribunals, law enforcement or other government agencies, applicable competent authorities as required by law or requested to comply with applicable law for internal investigations and reporting or respond to valid legal process;

The disclosure of personal information to the affiliates and other third parties set out above may involve the transfer of data to other jurisdictions outside the UK. Such countries may not have the same data protection laws as the UK. For such transfers of personal data we have put in place the Standard Contractual Clauses based on the International Data Transfer Agreement (IDTA) and the UK Addendum. To the extent we transfer your information outside the UK, we will ensure that transfer is lawful and that there are appropriate security arrangements. Please contact us on [email protected] should you require more information on international data transfer arrangements.

Security of Personal Data

• Records of identification evidence (customer due diligence/KYC) are kept for a period of five years from the ending of the business relationship with the customer, i.e. the closing of the account or accounts.
• Records relating to all orders and all transactions carried out by us on behalf of our clients containing all the information and details of the identity of the client, and the information required is kept for the period of five years from the ending of the business relationship with the customer, i.e. the closing of the account or accounts.
• Records of communications, including telephone and other electronic communications, are retained for five years from the ending of the business relationship with the customer, i.e. the closing of the account or accounts.

If you have opted out of receiving any marketing communications from us we will add you to a “do not contact” list to ensure we comply with your opt-out right and that your details will not be put back on the marketing list at later stages.

Data subject rights

The GDPR provides the following rights for you:

• The right to be informed – If you ask us, we will provide you with various pieces of information about the data processing activities undertaken by us. This information is provided in this Privacy Notice.
• The right of access – If you make a request, we will provide you with confirmation whether your personal information is being processed by us and a copy of that personal information. Should you wish to see your own collection data, request for information can be made by email: [email protected].
• The right to rectification – If the data we hold about you is inaccurate or incomplete you have the right to rectify it. If we have disclosed your information to others for the purposes described in this notice, we will inform them about the rectification where possible. If you ask us and where possible and lawful to do so, we will also let you know who we have disclosed your personal information to (the recipients).
• The right to data erasure (the right to be forgotten) – You can ask us to delete or remove your personal information in certain circumstances such as where we no longer need it and we have no compelling reasons or legal basis for holding it or, where applicable, you withdraw your consent. Such request will be subject to any retention limits we are required to comply with in accordance with applicable laws and regulations. If we have shared your personal information with others, we will inform them about the erasure where possible. If you ask us and where possible and lawful to do so, we will also let you know who we have disclosed your personal information to (the recipients).
• The right to restrict processing – In certain circumstances such as when you believe that the data we hold about you is inaccurate or object to us processing it you can restrict processing by asking us to suppress the processing of your personal information until the accuracy of it is verified. This will not stop us from storing your personal information though. We will inform you before we lift any restriction. If we have shared your personal information with others, we will let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your personal information with (the recipients).
• The right to restrict processing – In certain circumstances such as when you believe that the data we hold about you is inaccurate or object to us processing it you can restrict processing by asking us to suppress the processing of your personal information until the accuracy of it is verified. This will not stop us from storing your personal information though. We will inform you before we lift any restriction. If we have shared your personal information with others, we will let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your personal information with (the recipients).
• The right to data portability – This allows you, in certain circumstances, to obtain personal information you have provided us with and move, copy or transfer it between service providers of your choice.
• The right to object – You can ask us to stop processing your personal information and we will do so, if:

– Processing is based on our legitimate interests, except if we can demonstrate overriding compelling legitimate grounds to continue processing or the processing is for the establishment, exercise or defence of legal claims;

– Processing is for direct marketing; and

– Processing is for purposes of historical research and statistics

You can always choose whether you wish to receive promotional e-mails or telephone calls from Hantec Markets. You can also opt-out of (or unsubscribe from) receiving marketing emails at any time by clicking on the unsubscribe link at the bottom of the latest email you received from us.

Rights in relation to automated decision making and profiling – you have the right not to be subject to a decision when:

• it is based on automated processing; and
• it produces a legal effect or a similarly significant effect on you.

At Hantec Markets we do not make decisions about you based solely on an automated process without any human involvement including profiling (automated processing of personal data to evaluate certain things about you).

The right to lodge a complaint

If you have concerns or complaints about any aspects of our privacy practices, you can contact us by email at [email protected] and this will be investigated promptly by the Data Protection Officer.

If you are dissatisfied with our response to your complaint, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO). You can do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

Annual MIFIDPRU public disclosure report: 31 March 2024

The terms ‘we’, ‘us’, ‘HML’ and ‘our’ are used in this disclosure to refer to Hantec Markets Limited.

Introduction

In January 2022 the FCA introduced the Investment Firms Prudential Regime (IFPR). The IFPR is implemented through a new prudential sourcebook in the FCA Handbook, The Prudential Sourcebook for MiFID Investment Firms (MIFIDPRU). MIFIDPRU sets out the detailed prudential requirements that apply to a MIFIDPRU investment firms and seeks to cover the potential harms posed by investment firms to their clients and the markets they operate in. These rules are available on the FCA website and can be found at https://www.handbook.fca.org.uk/handbook/MIFIDPRU.

This document sets out certain disclosures relating to our business that we are required to publish under this new regime.

Content of the disclosures

This document covers the following key areas:
– Basis for disclosures – important information about how these disclosures have been formed
– Risk management – how HML manages risks within its business
– Governance arrangements
– HML’s Own Funds – the levels of Own Funds held by HML with a full breakdown, and
– Own Funds regulatory requirements – the level of Own Funds in HML and the regulatory thresholds.

Basis for disclosure

This document sets out the disclosures that we are required to make. These disclosures have not been audited and do not form part of the annual audited financial statements, and they should not be relied upon when making any judgements about the financial position of HML.

These disclosures are based on the calculations made in accordance with MIFIDPRU based on information related to HML’s Annual Report and Accounts, which are made up to 31 December 2023. HML’s financial year is 1 January to 31 December.

These disclosures are made on an annual basis as soon as practical after HML publishes its annual financial statements.

HML may also make more frequent public disclosure where particular circumstances demand it, for example, in the event of a major change to its business model.

Risk management

Hantec Markets Limited is a private limited company regulated by the Financial Conduct Authority (FCA). HML carries out a regulated activity of dealing in investments, offering Contracts for Differences (CFDs) to Retail and Professional clients. CFD products are offered through the online trading platform MT4. CFDs allow clients at HML to gain indirect exposure to the price movements in underlying FX pairs, stock indices, and commodities.

Hantec Markets maintains an internal risk management and control system, which is a set of tools, documents, and processes that support the management and control of risks. We have established, implemented, and maintain adequate risk management policies and procedures, including effective procedures for risk assessment. They focus on identifying the risks relating to the firm’s activities, processes, and systems that may cause the business plan to become unviable, assess the likelihood that such events could crystallise, and, where the assessment reveals a risk of business failure that is unacceptably high when considered against the firm’s risk appetite or tolerance, adopt effective arrangements, processes, systems, or other measures to prevent or mitigate that risk.

Effective risk management at HML is driven as much by the governance and culture of the firm as by any risk management tools, such as policies and procedures. Risk management has the commitment of the Board and senior management and is recognised as being the way that the firm does business. Risk management responsibilities are built into role descriptions, forming a part of day-to-day responsibilities and routines and the objectives that are set.
Strategic risk management is a Board responsibility. At a strategic level, the statement of risk appetite that underpins the strategic direction and sets the parameters for decision-making is the key. The risk appetite statement reflects the values and strategy of the business, taking into account any regulatory expectations in priority areas.

Anchoring risk management into planning processes enhances strategic planning, and enables decision-making that informs the best way forward, and ensures that appropriate controls are built into all areas of HML’s activity.

Consumer duty requirements are integrated into the risk management framework and day-to-day routines and processes of the firm. Acting to deliver good customer outcomes is also at the centre of firms’ strategy and business objectives. HML’s Board and senior management ensure the firm’s customers are getting outcomes consistent with the Duty.

The strategic plan of HML, as agreed by the Board, is to grow profits but within a conservative risk appetite, by expanding its offering of execution trading services to an increasingly diversified product and customer base achieved by the following strategic goals:
• increase the institutional client base;
• increase the retail client base; and
• increase volume traded.

The business plan is reliant on maintaining existing business and organic growth based on client referrals, management contacts, and increasing trades undertaken by existing clients.

As a result of its normal business activities, HML is exposed to a variety of risks, the most significant of which are market, operational, liquidity, counterparty and credit risks. Operational risk is defined as the risk of loss resulting from inadequate or failed internal processes, people, and systems, or from external events. This includes regulatory, legal, and compliance risks. Market risk is the potential for loss of income or a decrease in the value of net assets caused by currency fluctuations.

Counterparty and credit risk is the risk that counterparties will not meet their financial obligations. Risks can also arise for clients through failures in incident management, inadequate complaints servicing, and as a loss or severe restriction in critical servicing. Strategic and business risks are managed with the focus on maintaining a conservative risk appetite.

Below are some specific risks that HML is exposed to, broken down into those that relate to HML’s own funds requirements, concentration risk, and liquidity risk.

ICARA process

The internal Capital Adequacy Assessment (ICARA) process is central to a HML’s risk management framework, which is not only integral to how the firm manages its risks but is also central to how the FCA manages the risk of the firm that it supervises. Being the centrepiece of HML’s risk management processes, it incorporates business model assessment, forecasting and stress testing, recovery planning, and wind-down planning. As part of the ICARA process, we also demonstrate how we meet an OFAR to ensure that HML holds sufficient own funds and liquid assets to remain viable throughout the economic cycle and to allow the business to wind down in an orderly way.

As part of the ICARA process, the HML Board oversees and assesses:
• HML’s processes, strategies, and systems;
• the major sources of risks faced by HML that may impact its ability to meet its obligations;
• the results of internal stress testing of these risks; and
• the amounts and types of financial resources and internal capital, including Own Funds and liquidity resources, and whether these are adequate both as to amount and quality to ensure that there is no significant risk that its liabilities
can’t be met as they fall due.

The outcome of the ICARA is formally approved by the HML’s Board at least annually, with more frequent reviews if there is a material change to the business or the operating environment.

 Own Funds’ risks

Own Funds are a measure of the firm’s financial resources. The level of Own Funds is important, as they must meet the threshold levels set out in the FCA’s rules and regulations. These threshold levels reflect, amongst other factors, the potential risks and harms to the firm’s clients, the firm itself, and the markets the firm operates in, which arise from the firm’s business activities, for example, significant market downturns or defaults by key counterparties.

HML’s Own Funds assessments look at the following risks, although this list is not exhaustive:
Operational & Regulatory Control;
The FCA Client Assets Sourcebook (CASS) Framework;
Data Management;
Fraud and financial crime;
Operational Resilience and Business Continuity;
Capital and Liquidity risk;
Concentration risk;
Credit and Counterparty risk;

The likelihood of risks emerging, and the financial impact they may have, should they materialise, are reflected in the assessment of the Own Funds. This assessment determines the minimum amount of Own Funds HML must hold at all times.

These assessments are refreshed as and when risks change or new risks emerge. The level of HML’s Own Funds held can be found in the Own Funds section below.

Concentration risk

High exposure to certain counterparties, credit lines, or channels can result in an increased risk to HML. The concentration risks identified for HML are:

HML liquid assets/cash concentration

The firm’s own cash is placed with several banks, and in the event of a default by these banks, HML would rank amongst other creditors in respect of the amount deposited. We manage this risk through careful selection, vetting, and constantreview of the credit ratings of the banks, as well as regular monitoring of the amounts we hold in these bank accounts.

HML client money concentration

HML places client money (i.e. money held on behalf of clients) with third-party banks and liquidity providers. HML accepts
that from time to time it does have concentrations of exposures to banking counterparties, which could give rise to an increased level of risk. However, HML attempts to minimise this risk by maintaining a diverse portfolio of providers’ relationships and meeting the CASS rules at all times.

LP (Liquidity Providers) concentration

Managing concentrations by assignment of credit and operating limits on an individual LP level restricts the total amount of exposure and by having multiple Liquidity Providers to ensure that such exposures remain within predefined limits.

Liquidity risk

This is the risk that HML, although meeting the required level of own funds and liquid assets, either may not have sufficient resources available to meet its obligations when they come due or can only secure them at an excessive cost.

HML is exposed to liquidity risk in the event of downturns in revenue, where HML’s recurring revenue is insufficient to meet HML’s overheads. HML manages this risk through regular monitoring of the liquid assets held against the thresholds. In addition, HML assesses the liquidity position in stressed conditions over future years to ensure it maintains sufficient liquid assets.

HML is also exposed to liquidity risk in respect of execution obligations to its clients arising from the firm’s counterparties’ inability to fulfil their settlement obligations, exposing HML to potential losses from having to cover failed client positions with other LPs using its liquid assets. In addition, HML has an arrangement in place relating to the settlement of customer trades to mitigate the issues with delayed settlements.

HML holds all client money with several banks and liquidity providers in accounts that have been opened as client money transaction accounts, which are distinguished from any accounts containing money that belong to them. This is also to ensure that counterparties understand and agree that they will not have any recourse or right against money standing to the credit of the settlement accounts in respect of any sum owed to them or to any other third person. Any liquidity risks with respect to these holdings are managed by diversifying the funds across banks and providers.

HML’s own assets are predominantly liquid assets, that is cash held with banks.

Governance arrangements

HML’s Board of directors, which includes executive and non-executive directors, defines, oversees, and is accountable for the implementation of governance arrangements that ensure effective and prudent management of the firm, including the segregation of duties in the organisation and the prevention of conflicts of interest, and in a manner that promotes the integrity of the market and the interests of clients.

The HML Board has overall responsibility for the firm and:
• approves and oversees the implementation of the firm’s strategic objectives, risk strategy, and internal governance;
• ensures the integrity of the firm’s accounting and financial reporting systems, including financial and operational controls and compliance with the regulatory system.
• oversees the process of disclosure and communications;
• has responsibility for providing effective oversight of senior management;
• monitors and periodically assesses:
– the adequacy and implementation of the firm’s strategic objectives in the provision of investment services
and/or activities and ancillary services;
– the effectiveness of the firm’s governance arrangements; and
– the adequacy of the policies relating to the provision of services to clients, and
takes appropriate steps to address any deficiencies; and
• has adequate access to information and documents which are needed to oversee and monitor managementdecision-making.

HML ensures that the members of the Board meet the requirements of SYSC 4.3A.3R and:
• are of sufficiently good repute;
• possess sufficient knowledge, skills, and experience to perform their duties;
• possess adequate collective knowledge, skills, and experience to understand the firm’s activities, including the main risks;
• reflect an adequately broad range of experiences;
• commit sufficient time to perform their functions in the firm; and
• act with honesty, integrity, and independence of mind to effectively assess and challenge the decisions of senior management where necessary and to effectively oversee and monitor management decision-making.

The HML Board recognises that risks will be present throughout the activities that HML undertakes. The HML Board meets on a quarterly basis and is responsible for ensuring that HML has a suitably robust governance and risk management framework in place to ensure the adequate identification, assessment, and mitigation of risks inherent to the company.

HML’s governance arrangements also include a clear organisational structure with well-defined, transparent, and consistent lines of responsibility, effective processes to identify, manage, monitor, and report the risks the firm is or might be exposed to, and internal control mechanisms, including sound administrative and accounting procedures and effective control and safeguard arrangements for information processing systems.

This is ultimately to ensure that clients’ money and HML’s own assets are suitably protected.

The HML Board

The HML Board is responsible for promoting the long-term sustainable success of the company and generating value for shareholders. It has overall responsibility for oversight of the business and affairs of HML, the establishment and periodic assessment of the implementation of HML’s strategy, the establishment and oversight of HML’s risk strategy, the monitoring of regulated capital as applicable, and the maintenance of high standards of corporate governance.

The Board monitors and oversees HML’s operations, ensuring competent and prudent management, sound planning, appropriate policies, proper procedures for the maintenance of adequate accounting and other records and systems of
internal control, and compliance with statutory and regulatory obligations.
The HML Board will perform a regular review of the adequacy of HML’s ICARA process and approve the contents of HML’s ICARA document, in particular the key assumptions in the document.

The table below shows the number of directorships held by each member of the HML Board.

Promoting inclusion and diversity

HML has diversity and inclusion at the top of its agenda to attract, train, and retain employees, attain long-term and sustainable results, and contribute to a better future for everyone.

The HML Board aims for a composition that is balanced and diverse in terms of experience, nationality, ethnicity, age, and gender of the individual members. The HML Board recognises that diversity, and especially diversity of thought, can bring insights and behaviours that may make a valuable contribution to its effectiveness.

Own Funds

Own Funds can be made up of different categories of capital called: common equity tier 1 capital, additional tier 1 capital, and tier 2 capital. The items that fall into each of these categories can be seen in the Table A below.

Under MIFIDPRU, HML is required to disclose:
• a reconciliation of common equity tier 1 items, additional tier 1 items, tier 2 items, and the applicable filters and
deductions applied in order to calculate the Own Funds of the firm, provided in the Table A;
• a reconciliation of 1 (above) with the capital in the balance sheet in the audited financial statements of the firm – provided in the Table B; and
• a description of the main features of the common equity tier 1 instruments, additional tier 1 instruments and tier 2 instruments issued by the firm, provided in the Table C.

The required information is presented in the three tables below and is based on the HML Annual Reports and Accounts as of 31 December 2023.

Table A: Composition of regulatory Own Funds

All HML’s Own Funds are made up of common equity tier 1 capital.

Table B – Own Funds: reconciliation of regulatory Own Funds to balance sheet in the audited financial statements

Table B below shows the assets, liabilities and shareholders’ equity of HML cross-referenced to Table A above:

Table C: Own Funds: main features of own instruments issued by HML

Own funds requirements

The level of regulatory capital that must be held to absorb losses is the ‘Own Funds Threshold’ requirements. In accordance with MIFIDPRU, HML is required to hold Own Funds in sufficient quantity and quality.

The level of actual Own Funds held by HML is explained above. This section describes how we have arrived at the Own Funds Threshold requirements.

Components of the assessment

To determine the own funds requirement of HML, an assessment of three key items is required.

These are:
• the Permanent Minimum Capital – this is defined by the regulation and is £750,000 for HML;
• the Fixed Overhead Requirement – this is a level equal to a quarter of HML’s overheads – this level is £1,714,593; and
• the ‘K’ factors. These factors are applied to three key metrics for HML. These are explained below, and for HML, the Kfactor
total is £491,715+ £ 908,500 additional own funds to address risks from ongoing activities.

The ’Own Funds’ requirement is the largest of these three key items.

HML’s K-Factors

There are three K-factors:
K-CMH – the amount of client money that HML is holding on behalf of its clients multiplied by 0.4%; and
K-DTF – the daily value of trades that a HML enters through the execution of client orders multiplied by 0.01%
K-NPR (Net Position Risk) – calculated on the non-trading book balance sheet FX exposure of the firm.
K-TCD – the value of the exposures is multiplied based on replacement cost and any add‐ons for potential future exposure,
accounting for the mitigating effects of effective netting and the exchange of collateral.

K-factor figures are broken down in accordance with MIFIDPRU requirements:

The total K-factor requirement is £491,715.

MIFIDPRU contains details on other K-factors which do not apply to HML. 

Meeting the Overall Financial Adequacy Rule 

HML must always meet the ‘overall financial adequacy rule’. This rule states that HML must, at all times, hold Own Funds and liquid assets that are adequate, both in their amount and quality, to make sure HML is able to remain financially viable throughout the economic cycle with the ability to address any material potential harm that may result from its ongoing activities. In addition, HML must ensure that it has adequate own funds and liquid assets so that its business can be wound down in an orderly manner, minimising harm to consumers or other market participants.

HML meets this requirement through regular monitoring of:
• the Own Funds held by HML compared with the Own Funds Thresholds calculated according to MIFIDPRU;
• and the liquid assets held by HML compared with the Liquid Assets Thresholds calculated according to MIFIDPRU.

These assessments are dynamic and reflect the evolution of the ‘K’ factors above as well as the assessments of risks explained earlier. However, based on this yearly snapshot, we can see that the Own Funds level of £5,391,778 is in excess of the £1,714,593 Own Funds Threshold level.

Data for the Own Funds Threshold Level is based on final audited accounts dated 31 December 2023.

The equivalent position for liquidity is as follows:

Data for Liquid assets held is based on 31 December 2023. Data for the Liquid Assets Threshold is based on final audited accounts dated 31 December 2023.

Remuneration Policies and Practices

Qualitative disclosures

HML’s pay strategy is designed to reward the achievement of long-term sustainable performance and attract and motivate individuals, regardless of gender, ethnicity, age, disability, or any other factor unrelated to performance or experience with HML, while performing their role in the long-term interests of our stakeholders, demonstrating integrity, expertise, commitment, innovation, quality, and passion along the way.

To achieve this objective, effective governance of remuneration practices is of key importance. The design and implementation of remuneration policies and procedures at HML are overseen by the Remuneration Committee to ensure that the employee remuneration process is aligned with the firm’s business performance and strategy. Performance is judged not only on what is achieved over the period but, more importantly, on how it is achieved, as we believe the latter contributes to the long-term sustainability of the business.

Total remuneration, both, fixed and variable, is the key focus of our remuneration framework, with variable pay in the form of annual incentive is differentiated by performance and adherence to HML values.

HML has adopted a top-down approach to its remuneration and only pays bonuses out of risk-adjusted profits. To ensure a risk- and performance-aligned remuneration process, HML uses “bonus pools” that link the variable remuneration of each individual employee with bonus pools and the total amount of variable remuneration at a firm’s level. When determining remuneration pools, awards, and allocations to employees, this allows HML consider and apply performance measures and risk adjustments at various levels, including taking into account all types of current and future risks.

The fixed and variable components of the total remuneration are appropriately balanced. The fixed component represents a sufficiently high proportion of the total remuneration to enable the operation of a fully flexible policy on variable remuneration, including the possibility of paying no variable remuneration component to the employees.

HML’s remuneration strategy is delivered through HML reward system that consists of three key elements:

Governance Framework and Oversight

As of 31.03.2024, 5 members of staff have been identified as material risk takers (MRT’s) under SYSC 19G.5,:

Quantitative disclosures

The total amount of remuneration awarded to all HML staff in 2023 is as follows:

The total amount of remuneration awarded to senior management and other material risk takers (MRT’s) in 2023 is as follows:

Risk Disclosure

This website has been produced by Hantec Markets Limited (‘HML’) which is authorised and regulated by the Financial Conduct Authority [Registration No. 502635].

Warning: demo platform

The virtual funds available via your demo platform allow you to familiarise yourself with our trading platforms, and any gains or losses incurred while trading in a demo environment are not suggestive of results you may achieve when trading on a live platform. Access to your demo platform is only valid for 30 days, which will be terminated thereafter, however you will be able to trade in a live environment once your account has been opened and funded.

Warning: internet trading risks

There are risks associated with using an internet trading system. These include, but are not limited to: error in hardware, software, internet connection or any force majeure (i.e. flood; extraordinary weather condition; earthquake, or other act of God; fire; war; insurrection; riot; labour dispute; accident; action of government; communications or power failure; or equipment or software malfunction). HML or our affiliates (‘we’, ‘our’ or ‘us’) cannot control the signal power, its reception or routing via internet, configuration of your equipment or reliability of its connection. Therefore, we cannot be responsible for any communication failure, distortion or delay (although we will attempt to minimise the possibility of system failure). Please call us immediately if you are unable to access your account and we will execute your orders over the phone. Please note for security reasons you will need to go through our identification process before we accept any orders from you. If we are unable to identify you we will not be able to carry out your orders.

Warning: risks of margin trading

Trading in currency and bullion, particularly margin trading, involves the potential for profit as well as the risk of loss. This may vastly exceed the amount of money you commit to any trade or transaction. Movements in the price of currency or bullion rates are influenced by a variety of factors of global origin, many of which are unpredictable. Violent movements in the price of foreign exchange or bullion rates may result in action by the market. As a result you may be unable to settle adverse trades. Our staff are unable to guarantee the accuracy of any market predictions (should they offer such predictions) and cannot guarantee a maximum loss that you may suffer.

General advice warning

Any general advice provided by us, or on our website, or via our trading platform, does not take into account your financial situation, personal objectives or needs. CFD and currency trading is not suitable to all. We highly recommend you practice risk free on a demo account before investing any funds. You should then consider your objectives, financial situation and needs, and take all reasonable steps to fully understand the possible outcomes of trades and strategies that can be employed.

Copyright

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Introduction

As a financial institution, Hantec Markets Limited (hereafter “Hantec Markets”) faces actual and potential conflicts of interest from time to time. By identifying the existing and potential conflicts of interest, Hantec Markets will take all sufficient steps to establish, implement and maintain an effective Conflicts of Interest Policy to prevent or mitigate any risk that may damage the interests of our clients.

This statement discloses the conflicts of interest that you, as an existing or potential customer, might face when engaging in business dealings with Hantec Markets; the laws and regulations subject to conflicts of interest that Hantec Markets is required to comply with; and the Policy Hantec Markets adopts for the aim of preventing and managing the conflicts of interest.

Laws and Regulations

The FCA recognises that conflicts of interest exist in the financial services industry and does not aim to eliminate them. Nevertheless, Principle 8 of the FCA’s Principles for Business (PRIN) sets out that a firm must manage conflicts of interest fairly, both between itself and its customers, and between a customer and another customer. Furthermore, within the Senior Management Arrangements, Systems and Controls (SYSC) of the FCA handbook, in particular the SYSC 10, firms are required to manage the conflicts so that they do not damage the customers’ interest. Under the Markets in Financial Instruments Directive (“MiFID II”),  Hantec Markets is required to maintain and operate effective organisational and administrative controls to take all appropriate steps to identify, prevent or manage conflicts of interest.

Identification of Conflicts

A conflict of interest may arise where our interests or those of a member of our staff could conflict with a duty we have to a client. Part of staff training in this area is to recognise and remediate or escalate potential conflicts in the course of business. However, to help identify potential conflicts of interest, we have considered a number of areas. The following services and activities have the possibility to give rise to a conflict of interest and potentially, but not necessarily, be detrimental to the interests of our clients:

• Hantec Markets may receive or will receive from a person other than the customer an inducement, other than standard commission or fee in relation to a service provided to the customer;
• Hantec Markets  may carry on the same business as the customer;
• Hantec Markets is likely to make a financial gain, or avoid a financial loss, at the expense of the customer;
• Hantec Markets may have a financial or other incentive to favour the interest of another customer(s) over the interests of the customer;
• Hantec Markets may have an interest in the outcome of a service provided to or a transaction carried out on behalf of the customer, which is different from the customer’s interest in that outcome; or
• Hantec Markets may have an interest in maximising trading volumes in order to increase commission revenue, which opposes the client’s objective to minimise transaction costs.

These are general potential conflicts that will be managed in accordance with this Conflicts of Interest Policy. Any additional conflicts will be recorded in the Register of Conflicts of Interest.

Management of Potential Conflicts Identified

Hantec Markets keeps records of the business activities or services carried on by us (or which are carried on our behalf) so that we can identify any conflict that might arise that would have a material risk of damage to the interests of our customers.

Employees are required to report specific potential conflicts of interest in writing to the Compliance department as soon as practicable. To identify the potential conflicts of interest that require reporting, employees take into account whether Hantec Markets or its employee:

• could be in a position where the ability to act in a client’s best interests is potentially affected by any other matter
• is aware of any situation where the interest of one client may conflict with those of another
• is likely to make a profit or avoid a loss at the expense of the client
• has an incentive, financial or otherwise, to favour the interest of one client or group of clients over another;

Trading for Group Companies

Other sister companies within the Hantec group may hold accounts with Hantec Markets. Such accounts will be treated the same as any other client accounts with regard to the priority and execution of orders.

Personal Account Dealing

Hantec Markets has policies and procedures to monitor employees’ personal account dealing. Hantec Markets requires its employees to apply good judgement and act with integrity, taking all appropriate steps to avoid personal Conflicts in their personal account dealings and proactively escalate personal conflicts that do arise.

Best Execution

Hantec Markets’ Execution Policy is created to ensure that when executing orders, Hantec Markets acts in the client’s best interest. This applies irrespective of any potential or existing conflicts of interest and reduces the risk of Hantec Markets acting in favour of itself or a client over another client.

Managing Conflicts of Interest

Hantec Markets maintains a register of the potential conflicts of interests that have been identified. The records contained within the register allow the appropriate management of specific conflicts, whilst information on the management of general type of conflicts of interest is recorded in this Policy.

Review

Hantec Markets is devoted to provide more services and products to meet our customers’ demand. At the same time, Hantec Markets frequently reviews and assesses our conflicts of interest policy so that it can ensure the adequacy of such policy in compliance with our regulatory obligations.

Hantec Markets Policy

As required by law, Hantec Markets implements and maintains an effective Conflicts of Interest Policy for the aim of preventing conflicts of interest or potential conflicts of interest from causing a material risk of damage to the interests of customers.

Hantec Markets’ conflicts of interest policy adopts procedures and measures to manage and control the conflicts of interest identified, including segregation of duties and responsibilities; separate supervision of relevant persons; Personal Account Dealing policy, Gifts and Inducement policy, public interest disclosure policy; acting in the best interest of the clients; and in some cases declining to act for a customer or potential customer. These are also monitored on an ongoing basis within the company’s Compliance Monitoring Programme.

Hantec Markets also maintains and operates effective product governance arrangements to ensure that our products meet the needs of our clients and remain appropriate at all times.

Disclosure

Whilst Hantec Markets is devoted to implement and maintain our conflicts of interest policy, in some cases, such policy might not be sufficient to prevent risks of damage to the interest of a customer. In such a case, as a solution of last resort, Hantec Markets shall disclose the general nature and sources of conflicts of interest to the customer so that enables the customer to make an informed decision whether to proceed with the transaction in question.

Scalping is a form of trading which we consider to be an unacceptable practice and a type of market abuse. Scalping might be wrongfully used to return profits by taking advantage of internet latencies, delayed prices, off market/bad prices or through high volumes of transactions targeting tick fluctuations (rather than price movements) where trades are opened and closed very quickly.

If, in our sole discretion, we consider you to have partaken in this form of scalping, it will be considered as a breach of our Terms and Conditions and as such we reserve the right to:

• Make immediate changes to your account, including but not limited to, the liquidity provided by us and the spread quoted.
• Immediately terminate your account and your access to our servers.
• Void any trade (i.e., treat the trade as if the trade had never taken place) which was part of any Scalping activity.
• Close any trade, which was part of any Scalping activity, on the basis of our current market price.

We can exercise the above rights even if you have entered into (or refrained from entering into) such arrangements with third parties relating to the relevant trade and even if you may suffer a trading loss as a result.

Please be advised that all trading activity is monitored closely, and in the event it is identified that you are Scalping we reserve the right to close your account with immediate effect.

This statement details Hantec Markets Limited’s policy with regard to FCA Principle 6: “A firm must pay due regard to the interests of its customers and treat them fairly”.

The fair treatment of customers is one of the key principles of the Financial Conduct Authority in the UK. The FCA requires firms to be able to demonstrate that they are consistently treating their customers fairly. At Hantec Markets the Directors and Senior Management are committed to ensuring that the FCA principle of Treating Customers Fairly (TCF) is applied in all aspects of our business activities.

We recognise that fair treatment of our customers is about adding value to the service we offer. To ensure that we are continuously providing our customers with a valuable service we aspire to:

• protect the interests of our customers in all areas of our dealings with them and at each stage of the product life cycle, from promotion right through to after-sales service
• meet the needs of each customer by offering a transparent and professional service, and to constantly review our service to identify areas where we can improve it

Our Commitment to you

• To ensure the products that we offer are appropriate for you and are consistent with your needs;
• To provide timely and best execution at all times;
• To maintain a superior level of system and platform availability;
• To ensure all staff implement TCF in their daily business activities;
• To ensure your complaints are assessed fairly and impartially and handled professionally should you ever become unhappy with our service;
• To encourage staff to recommend improvements to service following customer complaints;
• To ensure that promotional material is clear, compliant and appropriately targeted ;
• To provide accurate, complete and timely communications;
• To ask for and listen to your feedback and place your interests first.