Conflict of Interest Policy

1. Identification of Conflicts

Thermo Markets proactively identifies and manages conflicts of interest between: the broker itself, its employees, clients, liquidity providers, and business partners.

2. Potential Conflicts

• Execution conflict: the broker may act as counterparty depending on the current execution model. This potential conflict is mitigated by automated pricing based on market feeds and a policy of no manual intervention in execution
• Partner/affiliate remuneration via disclosed spread markup
• Employees may not trade the platform's instruments
• Gifts and hospitality subject to strict limits

3. Conflict Register

We maintain an updated register of all identified conflicts and mitigation measures. The register is reviewed quarterly by the Compliance Officer.