The purpose of this document is to provide information on Spread Co Limited’s (Spread Co) policy on conflicts of interest and its approach to managing any conflicts of interest fairly: both between Spread Co, our directors, employees, group companies and associates (the Spread Co Group) and our clients, and between your interests and those of other clients. It is required under the EU Markets in Financial Instruments Directive (MiFID) and will apply from 1 November 2007.

1. Spread Co’s Conflicts Policy

Spread Co aims to establish and maintain effective systems, controls and procedures which are designed to identify and manage actual and potential conflicts of interest in the course of its business that pose a material risk to clients’ interests

Spread Co keeps a record of potential conflicts of interest which could arise during its activities and takes into account, among other things, whether the Spread Co Group:

• is likely to make a financial gain, or avoid a loss, at the expense of a client
• has an interest in the outcome of a service or transaction provided to a client, which is distinct from the client’s own interest in that outcome
• has a financial or other incentive to favour the interest of a client or group of clients over the interests of another client
• carries on the same business as the client
• receives 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.

Dealing in contracts for differences as principal, personal account dealing, inducements and gifts and entertainment are all examples of situations in which potential conflicts of interest may arise.