1.    Introduction and Purpose

‍This Conflict of Interest Policy (“Policy”) sets out how Amari Markets Ltd. (the “Company”, “Amari Markets”, “we”, “us”, or “our”) identifies, manages, and discloses conflicts of interest that may arise in the course of providing services to Clients (“Client”, “you”, “your”).A conflict of interest occurs where the interests of the Company or its directors, officers, employees, or affiliates may diverge from, or appear to diverge from, the interests of a Client. This Policy aims to ensure transparency, protect the integrity of the Company’s operations, and safeguard Clients, while limiting liability for the Company.

2.    Scope

‍This Policy applies to all activities conducted by the Company, including:
a)  trading platform operations;
b)  order execution and pricing;
c)  marketing and referral arrangements;
d)  relationships with liquidity providers and affiliates;
e)  internal employee conduct.
f)   It applies to all directors, officers, employees, contractors, and agents of the Company.

3.    Potential Conflicts of Interest

‍Conflicts of interest may include, but are not limited to, the following:
‍
3.1   Counterparty Risk
The Company may act as the counterparty to certain Client transactions. In such cases, the Company may profit where the Client incurs a loss.

3.2   Fees, Commissions, and Spreads
The Company generates revenue through spreads, commissions, overnight financing charges, and other fees. These charges may differ depending on market conditions or product type.

3.3   Liquidity Providers and Affiliates
The Company may route orders through liquidity providers, affiliates, or third parties with which it has financial arrangements. These relationships may affect pricing or execution quality.

3.4   Employee Trading
Directors, officers, or employees of the Company may engage in personal trading for their own accounts. Such trading may overlap with Client interests.

3.5   Referral and Incentive Arrangements
The Company may enter into referral, partnership, or incentive schemes that create potential conflicts between Clients referred through such arrangements and those onboarded directly.

4.    Company’s Approach to Managing Conflicts

‍The Company has implemented systems and controls designed to identify and mitigate conflicts of interest, including:
a)  maintaining internal policies on order handling, risk management, and employee conduct;
b)  monitoring for abusive or unfair practices;
c)  separating functions where necessary to reduce conflicts;
d) disclosing general conflicts to Clients in advance.
e)  The Company does not guarantee the elimination of all conflicts of interest.

5.    Client Acknowledgment and Acceptance

‍The Client acknowledges and accepts that:
a)  conflicts of interest may arise in the course of the Company’s business;
b)  such conflicts do not invalidate transactions executed on the Platform;
c)  the Company is not obliged to disclose every individual conflict in real time, but may disclose conflicts in general terms;
d)  they trade entirely at their own initiative, risk, and responsibility, regardless of the existence of any conflict.
e)  The Client expressly waives any right to bring claims, demands, or proceedings against the Company in connection with losses, damages, or opportunity costs alleged to arise from conflicts of interest.

6.    No Fiduciary Duty

‍The Client acknowledges that the Company does not act as a fiduciary, trustee, or adviser to the Client. The existence of conflicts of interest does not impose fiduciary duties on the Company, nor does it create an obligation to prioritize the Client’s interests above those of the Company.

7.     Indemnity

‍The Client agrees to indemnify and hold harmless the Company, its directors, officers, employees, affiliates, and service providers against any liability, claim, penalty, fine, or expense (including legal costs) arising from disputes, proceedings, or enforcement actions connected to conflicts of interest alleged or actual.

8.    Disclosure of Conflicts

‍The Company may disclose potential conflicts of interest through its website, policies, or contractual documents. Such disclosure may be general in nature. The Client acknowledges that they have been informed of the possibility of conflicts and accepts that transactions entered into with the Company remain valid and binding.

9.    Amendments to the Policy

‍The Company reserves the right to amend, update, or modify this Policy at any time. Amendments shall be effective immediately upon publication on the Company’s official website or Platform. Continued use of the Platform constitutes the Client’s acceptance of the revised Policy.

10.   Governing Law and Dispute Resolution

‍This Policy shall be governed exclusively by the laws of Saint Lucia. Any dispute, controversy, or claim arising out of or relating to this Policy shall be resolved exclusively by binding arbitration in Saint Lucia, conducted under the International Arbitration Rules of the Singapore International Arbitration Centre (SIAC), as adopted by the Company. The Client irrevocably waives the right to bring claims in any other jurisdiction.