How we identify, avoid, mitigate and, where unavoidable, disclose conflicts of interest, as required under the General Code of Conduct issued in terms of the FAIS Act.
Makeba Markets (Pty) Ltd (FSP 53160) is required under the General Code of Conduct issued in terms of the FAIS Act to establish, maintain, and disclose a Conflicts of Interest Management Policy. This Policy sets out how the Company identifies, avoids, mitigates, and, where unavoidable, discloses conflicts of interest that may arise between the Company (including its representatives and staff) and its Clients.
A conflict of interest arises where the Company's or a relevant person's interest may influence, or appear to influence, the objective performance of obligations owed to a Client, or where the Company or a relevant person has a financial or other incentive to favour its own interest, or that of another client, ahead of the Client's interest.
Where the Company (or an associated liquidity provider) may act as counterparty to a Client's trade, the Company's and the Client's financial interests in the outcome of a trade may, in principle, diverge. The Company manages this through its Order Execution Policy, price transparency, and independent oversight of dealing activity.
Representatives or introducers may receive commission, spread-based remuneration, or introducer fees linked to Client trading activity or referrals. Such arrangements are structured, disclosed, and monitored to avoid incentivising unsuitable recommendations or excessive trading.
Employees and representatives are subject to a personal account dealing policy restricting and requiring disclosure of personal trading that could conflict with Client interests or make use of non-public information.
The Company maintains a gifts and inducements register and limits the value and frequency of gifts or entertainment that employees or representatives may give to or receive from Clients, introducers, or counterparties.
Where the Company outsources functions (such as payment processing, liquidity provision, or technology services), it assesses and monitors such relationships to ensure they do not compromise the Company's duties to Clients.
Where a conflict cannot be adequately managed or avoided, the Company will disclose the nature of the conflict to the affected Client in writing, in sufficient detail and in good time, to allow the Client to make an informed decision about whether to proceed.
The Company earns revenue principally through spreads, and where applicable commissions and overnight financing charges, as set out in our Fees, Charges and Spreads Schedule. The Company does not receive undisclosed payments from third parties in connection with the products it offers. Any financial interest received from a product supplier or liquidity provider is managed and disclosed in accordance with this Policy.
This Policy is reviewed at least annually, and on any material change to the Company's business, products, or remuneration structures. A copy of the full Policy is available on request via our Contact page.