Summary of the Conflicts of Interest UK Policy

INTRODUCTION
1. The Conflicts of Interest Policy ("Policy") is issued pursuant to the European Directive 2014/65/EU of 15 May 2014 on markets in financial instruments. Interactive Brokers (U.K.) Limited ("IBUK") is committed to its general obligation to act with integrity and fairness towards its clients. The Policy complements IBUK's overall general obligation and sets out how IBUK manages potential conflicts of interest where IBUK provides electronic brokerage services to its clients.
2. This document summarises the general circumstances which may give rise to a conflict of interest entailing a material risk of damage to the interests of one or more clients and specifies procedures that IBUK follows and measures that IBUK has adopted in order to prevent and manage such conflicts.
GENERAL
1. IBUK provides to its clients execution-only electronic brokerage services. All trading decisions on clients' accounts are made only by the account holders or by individuals or entities which were granted a power of attorney by the account holders and entered into the Interactive Brokers Group's ("IB") Trading platforms for fully automated electronic order routing to market and order execution.
2. IBUK does not engage in proprietary trading or offer investment advice, nor does it engage in corporate finance business, mutual funds or managed investment schemes.
IDENTIFICATION OF CONFLICTS OF INTEREST
1. In view of the nature of the IBUK business model, services offered and activities performed, IBUK takes all appropriate steps to identify, prevent and manage circumstances which may give rise to material conflicts with respect to the relationships between two clients and between IBUK's clients and IBUK, its group companies, IBUK's or its group companies' employees, or any person directly or indirectly linked to IBUK or its group companies by control. In particular, IBUK considers parties who:
  - are likely to make a financial gain, or avoid a financial loss, at the expense of the client;
  - have an interest in the outcome of a service provided to the client or of a transaction carried out on behalf of the client, which is distinct from the client's interest in that outcome;
  - have a financial or other incentive to favor the interest of one client or group of clients over the interests of another client or group of clients;
  - carry on the same business as the client; or
  - receive money or non-monetary benefits like goods or services from a third party in relation to a service provided to the client other than the standard fees and commissions or otherwise benefit from IBUK's own remuneration and incentive structures.
IBUK POLICIES TO PREVENT AND MANAGE ANY POTENTIAL CONFLICTS OF INTEREST

IBUK has identified a range of circumstances which may give rise to a potential conflict of interest and, albeit not a material risk to IBUK clients, potential conflicts are prevented or managed by the corresponding measures and controls:
1. Best execution policy and IBUK affiliate order flow
  Our arrangements for acting in clients' best interests when executing orders on behalf of our clients and/or facilitating clients' access to IBUK affiliates are designed to ensure that IBUK meets applicable conflicts of interest and best execution obligations regardless of any other interests
  1. Market Access through an IBUK Affiliate
    Where IBUK relies on a third party to access a venue, this is usually carried out through an IBUK affiliate. Any IBUK affiliate receiving a client order does not levy any additional charge on the client. For certain execution venues, IBUK may rely on a broker outside of the IB Group. Order routing is not dependent on whether any rebate may be provided to IBUK or other entities in the IB Group by any third party brokers and IBUK's standard charges apply as disclosed without any additional markup imposed by IBUK.
  2. Execution Venue Selection
    As part of a pre-existing structure, an IBUK affiliate may receive payments from select execution venues or liquidity providers for certain client order flow in U.S. exchange-listed stocks and ETFs. Under no circumstances will IBUK receive any portion of any such payments. The venue selection criteria are unrelated to any rebate or incentive for IBUK or any of its affiliate. Decision related to the routing of orders and products offered on a single venue or hedged with sole liquidity providers are made after considering the integrity of the arrangement and its adequacy to avoid any conflict of interest arising.
  3. Order Handling
    In the event that a manual order entry is necessitated by significant business disruption or circumstances otherwise covered in our continuity plan, IBUK will allow for execution in accordance with the time of the order reception and carry out comparable client orders sequentially and promptly unless the characteristics of the order or prevailing market conditions make this impracticable, or the interests of the client require otherwise.
    IBUK also endeavours to ensure that no one client or any client group of IBUK or its affiliates would be in a more advantageous position based on any exercise of allocation discretion.
2. Inducement and Remuneration Structure of Intermediary and Referrers
  
  IBUK's commission structure is independent from the charging structure of any intermediary. IBUK receives no rebate from nor provides any incentive to, any intermediary with respect to any clients' investment.
  1. Charging Structure of Referral scheme
    The sub account clients are made aware of the arrangement including the referral fee payable to the referrers. This referral fee is either a one-off fee or payable for accounts maintained over a certain period.
  2. Third Party Research
    IBUK and its affiliates provide research produced by third parties. Care is taken to ensure that the charging structure applicable to the client is transparent and does not create any incentive to IBUK's clients. There is no direct link between the content of any research and IBUK's charging structure.
3. Code of Conduct of IBUK Employees
  1. Gift and Entertainment
    IBUK has in place policies and procedures for the acceptance of gifts and entertainment which applies to all IBUK employees.
  2. Remuneration Policy
    IBUK's remuneration structure does not give incentives to activities that may conflict with the interest of the client or reward behaviours that disadvantage the interests of our clients in favour of IBUK or other clients.
  3. Outside Business Activities
    All employees are required to identify and obtain approval to engage in certain types of outside business interests.
  4. Standards of Conduct and Confidential Information
    All employees are prohibited from disclosing confidential information and from using such information for their own interests.
  5. Personal Account Dealing Regulations and Procedure
    All employees are required to identify personal trading accounts and are prohibited from engaging in certain types of transactions for their personal accounts.
  6. Information Barriers
    Where required, IB has established adequate information barriers (i.e. Chinese Walls) between IB proprietary trading affiliates and IB customer brokerage affiliates.
REGISTRATION OF CONFLICTS OF INTEREST
1. IBUK maintains and operates effective organisational and administrative arrangements with a view to taking all reasonable steps to prevent conflicts of interest from adversely affecting the interests of our clients.
2. IBUK maintains a register of the investment services and activities and ancillary services carried out by or on behalf of IBUK which could give rise to a conflict of interest. This register serves to facilitate the management of potential conflicts of interest.
DISCLOSURES
1. If arrangements made by IBUK are not sufficient to ensure, with reasonable confidence, that risks of damage to the interests of the client can be prevented, IBUK shall disclose the nature, sources of the conflict of interest and the steps to be taken to mitigate those risk to the client before undertaking business for the client.
2. The disclosure will be made with sufficient specific description of the conflicts of interest that arise in the provision of IBUK's services and the risks to the clients that arise as a result of the conflicts of interest to enable the client to take an informed decision with respect to the service in the context of which the conflict of interest arises.
REVIEW AND MANAGEMENT OVERSIGHT

The Policy is reviewed on a regular basis and at least once a year.