Conflict of interest management policy

Why this page exists

Section 3(1)(b) of the FAIS General Code of Conduct requires a financial services provider to adopt, maintain and publish a conflict of interest management policy. Most published versions say nothing: they define the term, promise to act in the client's best interests, and stop.

This one names the conflict, because there is one, it is structural, and you are entitled to see it before you deal rather than to work it out afterwards.

The main conflict: we trade as principal and we earn a spread

Conexus deals as principal. When you sell Bitcoin to us, we are the buyer. When you buy USDT from us, we are the seller. We are the counterparty to your trade, not an agent placing an order for you on a venue.

We are paid by the spread. The rate we quote you differs from the rate at which we can source or offload the asset in the market. That difference is our margin, and it is how the desk earns its money. There is no separate commission dressed up as a service fee, and there is no arrangement in which someone else pays us to bring you to them.

The conflict follows directly from those two facts: a wider spread is better for us and worse for you. There is no way to structure a principal dealing desk that removes this. Any firm that tells you it has removed it has either hidden the spread somewhere else or is not telling you how it is paid.

What can be done is to make the conflict visible and to constrain it, which is what the rest of this page describes.

How the spread is disclosed at the point of quote

Every firm quote states the rand amount you will receive or pay, net of everything. You are not asked to work out a total from a rate and a fee schedule. The number in the quote is the number that settles.

Alongside it, the quote tells you the reference market rate against which the desk priced and the margin applied at that size, so that the spread is a figure you can see rather than a difference you have to infer. The indicative calculator on this site shows the same margin line before you speak to anyone.

Three further constraints apply. Margin bands are set by policy against ticket size, not negotiated case by case on the basis of how much a client seems to know — a naive client and an experienced one get the same band at the same size. Traders are not paid a commission on the spread earned from an individual trade, so no one at this desk has a personal financial reason to widen your quote. And the general shape of the fee and margin structure is published on the fees and limits page, not disclosed only on request.

No third-party inducements

We do not receive any commission, fee, rebate, referral payment, revenue share, kick-back or other inducement, in cash or in kind, from any third party for directing a client anywhere.

That covers, specifically: banks, other exchanges, other OTC desks, wallet and custody providers, attorneys and conveyancers, estate agents, accountants and tax practitioners, immigration and relocation consultants, and software vendors.

When a trader suggests that you speak to a conveyancer, a tax practitioner or your own bank, we earn nothing from that suggestion and we have no arrangement with the person suggested. If that ever changes, it will be disclosed here and disclosed to you at the time, before you act on the referral — and the same applies in reverse: where a third party has referred you to us, we will tell you if anything was paid for that referral.

The General Code of Conduct also limits gifts and immaterial financial interests. Our internal rule is stricter than the threshold: staff may not accept gifts, entertainment or benefits from clients, counterparties or service providers beyond ordinary business courtesy, and anything received is recorded in the gifts register.

Other conflicts, and how each is handled

Conflict	How it is managed
Personal account dealing by staff	Staff may not trade an asset ahead of a client order in that asset, and personal dealing is subject to pre-clearance and recorded. Front-running is a dismissal matter, not a policy point.
Two clients on opposite sides at the same time	Each is quoted independently against the market at the time of their own quote. We do not match one client's position against another's to their disadvantage, and neither client's price is worsened to improve the other's.
Hedging our own book	Hedges are placed to manage the desk's own exposure after a quote is accepted, never on the strength of a client instruction we have not yet honoured.
Related parties	Dealings with a director, an employee, or an entity connected to one, are quoted on standard terms, flagged in the register and approved by someone independent of the relationship.
Liquidity relationships	We source liquidity where the price and settlement risk are best for the trade in front of us. No counterparty pays for order flow, and no volume commitment obliges us to route a client's trade to a particular venue.
Marketing and content	Nothing on this site is a paid placement, and we publish no testimonials, ratings, awards or partner endorsements. Comparisons address service models, not the pricing of a named competitor.

The order in which conflicts are dealt with

Our policy applies four steps, in this order:

1. Avoid. Where a conflict can be removed by structuring the business differently, it is removed. That is why traders are not paid on spread, and why we accept no inducements.
2. Control. Where it cannot be avoided, it is constrained by a rule that does not depend on individual judgment — policy-set margin bands, pre-clearance, independent approval.
3. Disclose. Where a residual conflict remains, it is disclosed plainly, in writing, and before you commit. Disclosure in a footnote after the event is not disclosure.
4. Decline. Where a conflict cannot be managed to the point where we can act fairly, we decline the business. This is rare, and it is the correct answer when it applies.

The conflicts register

Every identified conflict, actual or potential, is entered in a conflicts of interest register. Each entry records what the conflict is, who is affected, when it was identified, how it is being managed, what was disclosed to the client and when, and who approved the treatment.

The register is maintained by the compliance officer, compliance officer — to be confirmed, reviewed by management, reported to the board, and kept for at least five years. It is available to the FSCA on request. The policy behind it is reviewed at least annually, and staff are trained on it at induction and annually thereafter.

If you think we have a conflict we have not disclosed

Tell us. Write to support@conexus-crypto.com, or raise it formally through the complaints procedure, which has fixed deadlines and an independent review stage.

An undisclosed conflict is a compliance failure on our part, not an awkward question on yours. We would rather be told about one than have a client quietly stop dealing because they suspected it.