Conflict of Interest Policy

Introduction and Purpose

Tradeiators (operated by SAL Innovations in Malta) is committed to the highest standards of fairness, transparency, and impartiality in all its business operations and competitive platform activities. This Conflict of Interest Policy ("Policy") establishes clear guidelines to ensure that personal interests do not improperly influence professional duties or the integrity of our trading competitions. The purpose of this Policy is to protect the reputation and trustworthiness of Tradeiators by identifying and managing any conflicts of interest that could undermine fair play or ethical business conduct. By adhering to this Policy, we affirm our commitment to clear, honest practices and a level playing field for all participants.

Scope and Applicability

This Policy applies to all stakeholders of Tradeiators across every department, role, and level of involvement. It is binding on:

Company Personnel: All employees, staff, officers, and contractors of SAL Innovations.
Management and Directors: All members of senior management and the Board of Directors.
Platform Users and Participants: All users of the Tradeiators platform, including traders taking part in competitive battles or tournaments.

Everyone listed above is expected to comply with this Policy at all times during their engagement with Tradeiators. The Policy covers all activities related to the company and the platform, ensuring that whether one is making business decisions or competing in a trading battle, they do so free from conflicting interests.

Definition of Conflict of Interest

A conflict of interest exists whenever an individual's personal interest interferes with, or appears to interfere with, the interests of the company or the fairness of the Tradeiators platform. In simple terms, it is a situation where someone's private motivations could affect their ability to act objectively and in the best interests of Tradeiators or its user community. This includes circumstances that create even the perception of divided loyalties or bias.

Common situations that constitute a conflict of interest include:

Personal Financial Gain: When an individual stands to benefit financially from a decision or outcome at Tradeiators.
Influence of Personal Relationships: When family, friendship, or romantic relationships affect objective decision-making.
Competing Roles or Engagements: When outside employment, directorships, or business activities conflict with one's role at Tradeiators.
Use of Insider Information: When someone uses confidential or privileged information gained through Tradeiators for personal benefit.
Collusion or Unfair Advantage in Competitions: For platform users, any secret agreement or unethical behavior that skews competition results.
Gifts, Hospitality, or Incentives: Accepting gifts, favors, or hospitality that could appear to influence one's objectivity.

These examples are not exhaustive. Any situation that could cast doubt on a person's impartiality or loyalty to the company's and community's best interests may be considered a conflict of interest. Both actual conflicts and potential or perceived conflicts fall under this Policy and must be addressed appropriately.

Individual Responsibilities and Obligations

All covered individuals have a duty to act in the best interests of SAL Innovations and the Tradeiators community. To uphold this duty, the following responsibilities must be observed:

Avoid Conflicts When Possible: Individuals should proactively avoid situations that create a conflict of interest.
Declare and Disclose: If a potential or actual conflict of interest arises, it must be promptly disclosed to the appropriate authority.
Recusal and Abstention: Individuals must recuse themselves from any decision-making, influence, or access to sensitive information related to the conflict.
Honesty and Transparency: All stakeholders are expected to be honest and transparent about any situation that could constitute a conflict.
Adherence to Guidance: Once a conflict is disclosed, the individual must follow the directives given to manage the conflict.
Lead by Example (Management and Directors): Management and Board members have an additional obligation to model exemplary conduct and uphold this Policy rigorously.

By fulfilling these responsibilities, each individual helps maintain an environment of trust and integrity. Remember that the onus is on the individual to recognize potential conflicts and act appropriately. When in doubt, err on the side of disclosure and seek advice.

Identifying and Disclosing Conflicts of Interest

Early identification of conflicts is vital. Everyone should continually assess their own activities and relationships to spot any interests that could conflict with their role or the platform's fairness. Key steps include:

Be Vigilant: Stay aware of situations that could create a conflict. Regular training and ethical awareness programs may be provided.
Self-Assessment: Individuals should ask themselves if they have any personal interest that might make it difficult to perform their duties impartially.
Prompt Disclosure: As soon as a potential conflict is identified, it must be reported. Do not wait for a conflict to actually influence a decision.
Disclosure Details: When disclosing, provide full and relevant details – who is involved, what the interest is, and how it conflicts with your role.
No Retaliation: Tradeiators strictly prohibits any form of retaliation against someone who discloses a conflict of interest in good faith.

It is important to note that identifying and disclosing a conflict of interest is not a sign of wrongdoing – rather, it is a professional obligation and a critical step to ensuring integrity. Coming forward with a concern will not in itself jeopardize one's standing.

Preventing and Managing Conflicts of Interest

Tradeiators will take proactive measures to prevent conflicts of interest and will implement effective procedures to manage any conflicts that do arise. Our approach includes:

Policy Awareness and Training: We ensure that all employees, management, and relevant stakeholders are educated about this Policy.
Conflict Disclosure Process: The company maintains a formal process for disclosing conflicts, including annual disclosure questionnaires for directors and managers.
Monitoring and Oversight: A designated Compliance Officer or ethics committee will oversee conflict of interest matters.
Risk Assessment: Management will periodically assess the company's operations to identify areas where conflicts are most likely to occur.
Preventative Measures: Where possible, the company will implement rules to avoid conflicts before they happen.
Management and Resolution: When a conflict is confirmed, steps may include recusal/removal, mitigating controls, divestment, or collusion response.
Documentation: All identified conflicts and actions taken will be documented to ensure accountability.
Follow-Up: After a conflict is managed, the situation will be periodically re-evaluated to ensure it remains under control.

In every case, the chosen method of management will aim to neutralize the conflict's impact on impartial decision-making. Our goal is to resolve conflicts in a way that upholds integrity while treating all parties involved fairly.

Commitment to Fairness, Transparency, and Impartiality

At all times, Tradeiators and SAL Innovations will operate under the principles of fairness, transparency, and impartiality. This Conflict of Interest Policy is an integral part of that commitment. Decisions — whether they concern internal business operations or the outcomes of trading battles — must be made solely on merit and legitimate criteria, free from bias or undue influence.

To reinforce this commitment:

Fair Competition: We ensure that the rules of any contest or competitive feature on the Tradeiators platform are applied equally to all participants. No user or employee should have an unfair edge.
Transparency: The company will be open about how it handles conflicts. When appropriate, we will communicate our conflict management decisions to relevant stakeholders.
Impartial Governance: Those in governance and oversight roles are expected to exercise their authority impartially. The company will support mechanisms such as independent audits to verify that processes remain unbiased.

Every stakeholder – from a new platform user to the CEO – can trust that Tradeiators is committed to doing business ethically. By faithfully enforcing this Policy, we protect the integrity of our platform and ensure that success is determined by skill, effort, and legitimate merit alone.

Enforcement and Compliance

Compliance with this Conflict of Interest Policy is mandatory. Tradeiators will enforce the Policy consistently through the following means:

Accountability: If an individual is found to have violated this Policy, the matter will be taken seriously. Employees or directors may face disciplinary action up to and including termination. Platform users may face sanctions including disqualification, suspension, or ban from the platform.
Investigations: Suspected conflicts of interest or violations will be investigated promptly and fairly. The Compliance Officer will lead or oversee investigations, maintaining confidentiality to the extent possible.
Remediation: If a conflict of interest breach has harmed the company's interests or the fairness of a competition, remedial steps will be taken to correct any injustice caused by the conflict.
Continuous Improvement: SAL Innovations will periodically review and update this Policy and its enforcement practices. Feedback from stakeholders and lessons learned from any incidents will be used to strengthen our conflict of interest management.