This Conflicts of Interest Policy (the “Policy”) is issued by Kohle Capital Markets Limited (the “Company”, “we”, “us”, or “our”) and sets out how the Company identifies, manages, and discloses conflicts of interest arising in connection with digital services operated under the KCM Trade brand (the “Services”).
This page provides an overview of the Company’s conflicts framework. The full Conflict of Interest Policy (PDF) (v4) contains the complete policy. In the event of any inconsistency, the PDF document prevails.
The Company holds an Investment Dealer (Full Service Dealer) licence (Licence No. C117022600, SEC-2.1B) issued by the Financial Services Commission of Mauritius (FSC Mauritius) and is subject to obligations regarding the management and disclosure of conflicts of interest under the Securities Act 2005 (Mauritius) and applicable FSC Rules.
1. Scope
This Policy applies to:
- All activities conducted by the Company in connection with the provision of the Services
- All employees, officers, directors, and authorised representatives of the Company
- All arrangements with third parties, including introducing brokers, affiliates, liquidity providers, and technology partners
- All financial instruments made available through the Services
2. Identified Conflicts of Interest
A conflict of interest arises when the interests of the Company, its employees, or its related parties are, or may be, in conflict with the interests of a user. The Company has identified the following categories of conflict that are relevant to its business:
2.1 Principal Trading (Market Maker Model)
The Company acts as principal or market maker in relation to most transactions executed through the Services. In this capacity, the Company takes the opposite side of a user’s position. This creates a potential conflict between the Company’s financial interest and the user’s interest in obtaining the best possible execution outcome.
Users are made aware of this arrangement through the Risk Disclosure Statement, the Terms of Service, and this Policy.
2.2 Pricing and Spread Revenue
As a market maker, the Company determines the bid and ask prices at which users trade. The Company earns a portion of its revenue from the spread between the bid and ask price. This creates an incentive to quote spreads wider than those strictly required for liquidity management purposes.
The Company addresses this conflict by applying consistent, transparent pricing across all user segments and monitoring spread levels against prevailing market conditions.
2.3 Introducing Brokers and Affiliates
The Company may remunerate introducing brokers and affiliates for referring users to the Services. Such remuneration arrangements may create an incentive for referrers to recommend the Services without adequate regard to the user’s individual suitability.
The Company requires all introducing brokers and affiliates to comply with applicable laws and the Company’s regulatory standards, and to refrain from making claims that misrepresent the Services or the risks involved. The standards applicable to IB and affiliate promotional content are set out in the Marketing and Advertising Compliance Policy.
2.4 Copy Trading Arrangements
The Services include copy trading functionality provided through Pelican Exchange Limited (operating the platform at copy-trade.io). A conflict may arise where users copy the positions of other traders who receive remuneration based on the number or activity of their followers, potentially creating incentives that are not aligned with the user’s own objectives.
Users are advised to review the additional risk disclosures applicable to copy trading before using this feature.
2.5 Corporate Group and Related Party Transactions
The Company is part of the KCM Group, which includes:
- Kohle Capital Markets Pty Ltd — regulated by ASIC (AFSL 489437), operating in Australia
- Kohle Technology Limited — registered in Hong Kong, providing technology services
Transactions between group entities are conducted on commercial terms and are subject to internal governance and applicable regulatory requirements.
2.6 Staff Personal Account Dealing
Employees, officers, and directors of the Company may trade financial instruments in their personal capacity, including instruments available through the Services. Such personal trading may, in certain circumstances, conflict with the interests of users or the Company’s obligations to provide fair and consistent execution.
2.7 Staff Remuneration Structures
The Company’s remuneration framework, including any performance-related compensation for employees or business development staff, may create incentives that are not fully aligned with the best interests of all users.
3. Management Measures
The Company has implemented the following measures to manage and mitigate identified conflicts of interest:
3.1 Disclosure
Material conflicts are disclosed to users through this Policy, the Risk Disclosure Statement, the Order Execution Policy, and the Terms of Service. Users are informed that the Company may act as principal counterparty to their trades.
3.2 Information Barriers
The Company maintains information barriers, where appropriate, to prevent the flow of information between areas of the business that could give rise to conflicts if shared.
3.3 Independent Compliance Function
The Company maintains a compliance function that is operationally independent from business development and trading activities. The compliance function is responsible for monitoring adherence to this Policy and applicable regulatory obligations.
3.4 Personal Account Dealing Controls
The Company has implemented a personal account dealing policy for employees, officers, and directors that includes:
- Pre-clearance requirements for personal trades in instruments available through the Services
- Restrictions on trading in advance of or concurrent with client orders
- Prohibition on trading on the basis of material non-public information
3.5 Consistent Pricing Standards
The Company applies a consistent pricing methodology across all users and does not vary execution quality on the basis of individual user characteristics in a manner that disadvantages those users.
3.6 Remuneration Controls
The Company’s remuneration structure is designed to minimise incentives that may conflict with the interests of users, including by ensuring that staff compensation is not directly and disproportionately linked to execution outcomes that would disadvantage users.
3.7 Introducing Broker Oversight
The Company conducts due diligence on introducing brokers and affiliates prior to establishing referral arrangements and monitors the conduct of such parties on an ongoing basis.
4. Residual Conflicts
Where the management measures described in Section 3 are insufficient to adequately mitigate a conflict, the Company will:
- Disclose the general nature and sources of the conflict to the relevant user or users
- Provide information about the steps taken to mitigate the risk of the conflict
- Do so in sufficient time for the user to make an informed decision
5. Monitoring and Review
The Company reviews this Policy at least annually, or following any material change in its business activities, organisational structure, or applicable regulatory requirements. The register of identified conflicts is maintained and updated on an ongoing basis by the compliance function.
The full Conflict of Interest Policy (PDF) (v4) is available for download.