1. Purpose and scope 

Bound was launched in 2020 with the vision of making currency conversion and hedging great value, fair, and most of all, easy. Today, our platform helps hundreds of businesses protect themselves from currency risk across the world. Earning and maintaining the trust of our customers, clients, and stakeholders is central to our values and strategy. This trust depends on our ability to operate with transparency, objectivity, and independence and free from undue influence or bias. This policy outlines Bound’s approach to identifying, managing, mitigating, and disclosing conflicts of interest in line with the Financial Conduct Authority’s (FCA) regulatory requirements. This policy applies to all Bound employees, directors, contractors and any other persons directly linked to Bound, whose activities may pose a conflict of interest. 

2. Regulatory requirements 

1. What is a conflict of interest? 

   A conflict of interest arises when the interests of Bound or its people clash with the duty owed to customers, clients, or other stakeholders potentially impairing objective decision-making or leading to unfair outcomes. Bound recognises two primary types of conflict.

   
   

2. Business conflicts.

   These can arise: 

   • between Bound (including employees or linked persons) and one or more customers; 

   • between two or more Bound customers; 

   Examples of potential business conflicts include: 

   • making a financial gain or avoiding a financial loss at the expense of the firm’s customers; 

   • if Bound receives simultaneous orders from two customers to transact in a thinly traded currency pair, executing one order may impact the pricing or execution quality of the other;

   • holding an interest in the outcome of a product or service provided to a customer, or a transaction carried out on behalf of a customer, which is different from the customer’s interest in the outcome; the use of confidential customer or business information in a way which would be detrimental to the interests of our customers;

   • a remuneration structure encouraging employees to behave in a manner which would be detrimental to the interests of customers and is not consistent with ensuring good outcomes; or 

   • conflicting interests when promoting products and services. 

     
     

3. Personal conflicts. 

   These may occur where an individual’s private interests (financial or non-financial) may conflict with their professional duties. Examples include: 

   • holding paid or unpaid external employment; 

   • serving as a director, trustee, or advisor to another organisation; or 

   • close relationships with suppliers, vendors, or clients.

   Actual, potential, and perceived conflicts are all treated with equal importance. 

   
   

2. FCA requirements 

Bound is required to identify and manage any situations where the firm’s interests, or those of employees or other clients, could conflict with a client’s best interests. The FCA requires firms to: 

• identify conflicts that could harm clients; 

• prevent or manage those conflicts through proper systems and controls; 

• disclose any conflicts that cannot be properly managed; 

• keep records of all conflicts and how they are dealt with; 

• review arrangements regularly to ensure they remain effective; and 

• always act in the client’s best interests. These requirements are outlined in the FCA Handbook, primarily SYSC and COBS, and MiFID II. 

4. Policy requirements 

Bound aims to prevent conflicts where possible and manage and mitigate those that do arise. Where conflicts cannot be mitigated through controls, they are disclosed to customers in accordance with SYSC 10.1.8R. 

1. Personal conflicts 

Employees must disclose any personal conflicts to their line manager. These will be reviewed and approved by Compliance. Personal conflicts will be reviewed periodically to ensure no undue influence on decision-making or client outcomes. Directors are required to disclose any potential conflicts of interest, to include the nature and extent of any interests that they have in any existing or proposed transactions or arrangements with the firm. Senior Manager Functions are subject to annual fitness and propriety assessments which includes a requirement to declare any personal conflicts.

2. Business conflicts 

Business conflicts are identified through the course of business and must be disclosed and documented in the Conflicts of Interest Register. Following identification, each conflict is owned by a Senior Manager, who is accountable for assessing the impact, implementing mitigating controls and ensuring these are operating effectively. Common control mitigation techniques include segregation of duties, independent review or approvals, information barriers, restrictions on activities, or disclosure to customers, as a measure of last resort. The Conflicts of Interest Register is owned by Compliance and is periodically reviewed by Senior Managers. Compliance performs an annual review and challenge of the Register and provides an annual update on business conflicts to the Risk Committee. 

3. Policies and frameworks 

The business maintains a series of policies and frameworks to support the identification and management of conflicts of interest. 

These include: 

• Anti-Bribery and Corruption Policy 

• Gifts & Hospitality Policy 

• Remuneration Policy

• Client Order and Best Execution Policy

• Personal Account Dealing Policy 

• Whistleblowing Policy

5. Roles and responsibilities 

• All employees – read and understand the Policy, disclose personal conflicts and escalate business conflicts to their line manager and / or director.

• Senior managers – own and review business conflicts in their respective areas of accountability, design and monitor controls, and notify Compliance of any unresolved conflicts. 

• HR – manage and maintain records of employee personal conflicts, oversee disclosure processes and perform ongoing review of employee personal conflicts.

• Company Secretarial – manage and maintain records of Board director personal conflicts. 

• Compliance – maintain the Conflicts of Interest Register, provide training and guidance to employees and directors, perform an annual review of the Register Provide reporting to the Risk Committee. 

6. Training and awareness 

All relevant employees must complete mandatory conflicts of interest training annually. Senior Managers and control owners are provided with additional guidance tailored to their responsibilities

7. Monitoring 

Adherence to the policy will be reviewed by the Compliance Team on a periodic basis. 

8. Whistleblowing 

If any employee believes that the requirements of the Policy are not being followed, they are encouraged to raise their concerns initially with their line manager. If an employee feels unable to report their concern internally, they should refer to the Whistleblowing Policy.

9. Breaching the Policy 

Any employees who fail to comply with the requirements within the Policy may be subject to further action. 

10. Ownership and review of the Policy

This Policy is owned by Compliance and is reviewed at least annually, or earlier where regulatory or business developments require.