Legal Documentation
Execution Policy
Overview of Best Execution requirement
Hantec Markets Limited is authorized and regulated by the Financial Services Commission (“FSC”) and under the Code of Business Conduct issued by the FSC, we are obliged to act in our clients’ best interests and, other than in certain circumstances described below, where we execute or arrange the execution of orders, we are required to take all reasonable steps to obtain the best possible result for our clients(known as delivering ‘’best execution’’) and to establish and implement an order execution policy and related procedures to allow us to do so.
We have internal policies and procedures governing how we will act when we execute orders for our clients. We continually strive to provide the best possible level of service to all of our clients. Consequently, our policies and procedures are under constant review and may be revised at any time without prior notice.
Execution Venues
We deal with clients as principal and not as agent. This means that we are the execution venue and so clients transact directly with us and not on an exchange or another external market. Trades that clients undertake with us are non-transferable, which means that if a client opens a position with us, they must close the position with us.
Execution Factors
We apply the following execution factors:
The Price – While we always aim to act in the best interest of our clients we cannot guarantee that the price at which we permit clients to execute a trade will be better than elsewhere. Prices on Currency products are sourced from independent third party providers who supply liquidity to the OTC Currency market.
The Cost – We add a mark-up to the prices from our liquidity providers and publish the ‘’marked-up’’ prices that include our income. We will base the closing price of the relevant currency for the purposes of margin requirements and any balance credits/debits.
Speed and Likelihood of Execution – Trades may be executed on our platform or by telephone or other forms of communication. Screen and telephone trades are subject to liquidity and market conditions and so we cannot guarantee that a client’s trade will be opened or closed instantaneously. The speed and likelihood of execution is also subject to software, hardware and telecom/data line use and we cannot guarantee that this will not be free of interruption of suspension.
Quantity – We set the minimum and maximum quantity that clients may place on a trade. This is influenced by market conditions and firm policy and changes from time to time.
Execution Criteria
When arranging a transaction or executing a client order, we will take into account the following criteria for determining the relative importance of the execution factors referred to above:
- The characteristics of the client;
- The characteristics of the client order; and
- The characteristics of the financial instruments that are the subject of that order.
Dealing with Client Orders
Subject to market conditions a client order will be executed at our price or very close to our price. The price clients receive at execution is not guaranteed as the market may widen, become very volatile or even gap. There is no guarantee that a client’s order will be executed.
Specific Instructions
If clients have any particular requirements as to how we act when dealing with them, then they must let us know and we will do our best to accommodate them. However, clients should be aware that where they give us specific instructions that are incompatible with our normal order execution policies and procedures, their specific instructions will take precedence.
This may result in a different outcome that would have been achieved had our normal policies and procedures been followed and we will not be required to deliver best execution in respect of the aspects of a client order which are covered by their specific instructions.
Our normal policies and procedures take account of the costs that we would incur in transacting business. Transactions may be subject to additional charges. Where this applies, we will notify clients of the applicable charges before their order is executed.
Our Duty of Best Execution
When executing orders for Currency and Bullion or other OTC financial derivative products, we will take all reasonable steps to achieve the best possible outcome taking into account our Execution Policy and specific instructions received from our clients.
Our policy cannot provide a guarantee, however, that the price at which we permit our customers to execute an order will always be better than one which is or might have been available elsewhere.
Achieving ‘Best Execution’
To achieve the best possible result, we will take a number of factors into account, including price, costs, speed of execution, likelihood of execution and settlement, size, nature of the order or any other factors relevant to the execution of that order.
We will use our own commercial experience and judgment in determining the relative importance of these factors, however, we have rated prices as the most important factor for obtaining the best possible result.
We will review this policy at regular intervals and will monitor and review external pricing sources. Any updated policy together with a general notice informing customers of such change will be promptly posted to the website as and when this policy is materially updated. You agree that the posting of a revised policy electronically on the website as constituting actual notice to you.
Risk Disclosure
Risk Disclosure
This website has been produced by Hantec Markets Limited (‘HML’) which is authorised and regulated by the Financial Services Commission [License Number: C114013940]
Warning: demo platform
The virtual funds available via your demo platform allow you to familiarize yourself with our trading platforms, and any gains or losses incurred while trading in a demo environment are not suggestive of results you may achieve when trading on a live platform. Access to your demo platform is only valid for 30 days, which will be automatically terminated thereafter. You will however be able to trade in a live environment once your account has been opened and funded.
Warning: internet trading risks
There are risks associated with using an internet trading system. These include, but are not limited to: error in hardware, software, internet connection or any force majeure (i.e. flood; extraordinary weather condition; earthquake, or other act of God; fire; war; insurrection; riot; labor dispute; accident; action of government; communications or power failure; or equipment or software malfunction). HML or our affiliates (‘we’, ‘our’ or ‘us’) cannot control the signal power, its reception or routing via internet, configuration of your equipment or reliability of its connection. Therefore, we cannot be responsible for any communication failure, distortion or delay (although we will attempt to minimize the possibility of system failure). Please call us immediately if you are unable to access your account and we will execute your orders over the phone. Please note for security reasons you will need to go through our identification process before we accept any orders from you. If we are unable to identify you we will not be able to carry out your orders.
Warning: risks of margin trading
Trading in currency and bullion, particularly margin trading, involves the potential for profit as well as the risk of loss. This may vastly exceed the amount of money you commit to any trade or transaction. Movements in the price of currency or bullion rates are influenced by a variety of factors of global origin, many of which are unpredictable. Violent movements in the price of foreign exchange or bullion rates may result in action by the market. As a result you may be unable to settle adverse trades. Our staff are unable to guarantee the accuracy of any market predictions (should they offer such predictions) and cannot guarantee a maximum loss that you may suffer.
General advice warning
Any general advice provided by us, or on our website, or via our trading platform, does not take into account your financial situation, personal objectives or needs. CFD and currency trading is not suitable to all. We highly recommend you practice risk free on a demo account before investing any funds. You should then consider your objectives, financial situation and needs, and take all reasonable steps to fully understand the possible outcomes of trades and strategies that can be employed.
Copyright
Except where noted otherwise, all material on the website (the “Site”) is our copyright with all rights reserved. No part of the materials on this Site, including but not limited to the text, graphics and html code, may be reproduced or transmitted in any form by any means without our prior written permission.
Your Use of the Site
You may download materials from this Site for non-commercial and personal use only, provided that the intellectual property rights or other proprietary notices remain unchanged and visible. No right or interest in any downloaded materials is transferred to you as a result of any such downloading. You agree that you will not otherwise copy, modify, display, distribute, sell or transmit any material on the Site in any manner without our prior written permission. Furthermore, you shall not, under any circumstances, use the Site for any purpose that is prohibited by these terms and conditions or any applicable laws.
Appropriateness Warning
The information you provided on your Hantec Markets Limited account application indicates one or more of the following:
- You have less than six months prior experience self-trading margined CFD and Currency products;
- Your annual income is less than $25,000.00 USD (or currency equivalent);
- Your liquid net worth is less than $10,000 USD (or currency equivalent); or
- You are under 21 or over 65 years
We need to inform you that trading in CFD/Currency may not be appropriate for you. Such trading carries a high degree of risk and may result in losses greater than your initial deposit. Hantec Markets Limited provides an execution-only service to its clients and you will need to rely upon your own skill and judgement when trading these markets.
By opening an account with us, we assume that you have read, understood and accepted this warning, you agree that one or more of the below statements apply to you.
Attitude to risk and investment objectives:
- You understand the risks of CFD/Currency trading and you confirm that you have the necessary knowledge and expertise to fully appreciate the risks.
- You understand that CFD/Currency trading is highly leveraged and that you could lose your entire original You are able to assess the risks involved and deem them appropriate for you.
Investing experience and expertise
- You have gained sufficient experience and expertise in dealing in shares and other similar investment instruments, and you understand the complexities of CFD/Currency.
- You have attended relevant courses or seminars on CFD/Currency trading that have given you sufficient knowledge and expertise to assess the risks.
You have attended relevant courses or seminars on CFD/Currency trading that have given you sufficient knowledge and expertise to assess the risks that may arise from
Conflicts Policy
Conflicts Policy – Introduction
As a financial institution, Hantec Markets Limited (hereafter “HML”) faces actual and potential conflicts of interest from time to time. By identifying the existing and potential conflicts of interest, HML endorses all reasonable steps to establish, implement and maintain an effective conflict of interest policy to prevent any risk that may damage the interests of our customers.
This statement discloses the conflicts of interest you, as an existing or potential customer, might face when engaging in business dealings with HML; the laws and regulations subject to conflicts of interest that HML is required to comply with; and the policy HML adopts for the aim of preventing and managing the conflicts of interest.
Laws and Regulations
Conflicts of interests exist in the financial services industry and the Code of Business Conduct issued by the Mauritius Financial Services Commission recognises that whilst situations of conflict of interests must be avoided, in case a conflict arises, customers should be treated fairly. Furthermore, as a licensee of the Mauritius Financial Services Commission under the Securities Act 2005, HML is required to manage the conflicts so that they do not damage the customers’ interest.
Identification and Examples of Conflicts that might arise
In general, conflicts of interest may be caused by the superior knowledge of employees and the variety of products on offer and may arise between a firm and a customer, or between a customer and another customer.
When a firm provides service to a customer, conflicts of interest may arise in one or more of the following situations when a firm or a relevant person:
- is likely to make a financial gain, or avoid a financial loss, at the expense of the customer;
- has an interest in the outcome of a service provided to or a transaction carried out on behalf of the customer, which is different from the customer’s interest in that outcome;
- has financial or other incentives to favour the interest of another customer(s) over the interests of the customer;
- carries on the same business as the customer; or
- receives or will receive from a person other than the customer an inducement, other than standard commission or fee in relation to a service provided to the customer.
- In respect to HML, the following is the main conflict of interest that may occur when providing services to our customers.
Hantec Markets Limited Policy
As required by law, HML implements and maintains an effective conflict of interest policy for the aim of preventing conflicts of interest or potential conflicts of interest from causing a material risk of damage to the interests of customers.
HML keeps records of our business activities so that we can identify any conflict that might arise that would have a material risk of damage to the interests of our customers. HML’s conflicts of interest policy adopts procedures and measures to manage and control the conflicts of interest identified, including segregation of duties and responsibilities; separate supervision of relevant persons; Personal Account Trading policy, Gifts and Inducement policy, prevention and control of the exchange of information; acting on the best interest of the customers; and in some cases declining to act for a customer or potential customer.
Hantec Global Policy
As required by law, HG implements and maintains an effective conflict of interest policy for the aim of preventing conflicts of interest or potential conflicts of interest from causing a material risk of damage to the interests of customers.
HG keeps records of our business activities so that we can identify any conflict that might arise that would have a material risk of damage to the interests of our customers. HGs’ conflicts of interest policy adopt procedures and measures to manage and control the conflicts of interest identified, including segregation of duties and responsibilities; separate supervision of relevant persons; Personal Account Trading policy, Gifts and Inducement policy, prevention and control of the exchange of information; acting on the best interest of the customers; and in some cases declining to act for a customer or potential customer.
Disclosure
Whilst HML is devoted to implement and maintain our conflicts of interest policy, in some cases, such policy might not be sufficient to prevent risks of damage to the interest of a customer. In such a case, HML shall disclose the general nature and sources of conflicts of interest to the customer so that enables the customer to make an informed decision whether to proceed with the transaction in question.
Review
HML is devoted to providing more services and products to meet our customers’ demand. At the same time, HML frequently reviews and assesses our conflicts of interest policy so that can ensure the adequacy of such policy in compliance with applicable law.
Scalping Policy
Scalping is a form of trading which we consider to be an unacceptable practice and a type of market abuse. Scalping might be wrongfully used to return profits by taking advantage of internet latencies, delayed prices, off market/bad prices or through high volumes of transactions targeting tick fluctuations (rather than price movements) where trades are opened and closed very quickly.
If, in our sole discretion, we consider you to have partaken in this form of scalping, it will be considered as a breach of our Terms and Conditions and as such we reserve the right to:
- Make immediate changes to your account, including but not limited to, the liquidity provided by us and the spread quoted.
- Immediately terminate your account and your access to our servers.
- Void any trade (i.e., treat the trade as if the trade had never taken place) which was part of any Scalping activity.
- Close any trade, which was part of any Scalping activity, on the basis of our current market price.
We can exercise the above rights even if you have entered into (or refrained from entering into) such arrangements with third parties relating to the relevant trade and even if you may suffer a trading loss as a result.
Please be advised that all trading activity is monitored closely, and in the event it is identified that you are Scalping we reserve the right to close your account with immediate effect.
Privacy Notice
Your privacy is of paramount importance to us. At Hantec Markets, we protect the personal data and confidentiality of the information and respect the privacy rights of our existing and prospective customers.
Hantec Markets collects data to operate effectively and provide you with a valuable service while ensuring that your needs are met. Where your personal data is provided to Hantec Markets Limited (Mauritius) in connection with us providing or offering products or services to you if you are an individual located in Europe, please note the following.
This privacy notice explains what personal data we collect from you in connection with the provision or offering of our products or services to you or from your use of our products and services, as well as through our interactions with you through our website or applications. This notice also outlines how the data that we collect is used.
Data Controller
This Privacy Notice applies to the data processing activities carried out by Hantec Markets Limited who acts as a Data Controller of your personal information.
Hantec Markets Limited is registered in the Republic of Mauritius, company number 127483 C1/GBL, principal place of business Suite 207, 2nd Floor, The Catalyst, Silicon Avenue, 40 Cybercity, 72201 Ebene, Republic of Mauritius.
If you have any questions about this notice or wish to exercise your rights about your personal information, please get in touch with us:
- Call: +41 225 510215
- Email: compliance-mu@hmarkets.mu
- Please write to us: Compliance Department, Suite 207, 2nd Floor, The Catalyst, Silicon Avenue, 40 Cybercity, 72201 Ebene, Republic of Mauritius.
What Type of Personal Data We Collect and How We Collect It?
The data we collect depends on the context of your interactions with us, the choices you make, including the products and services you use or wish to start using. The data we collect about you can include the following:
- Name and contact data: We collect your full name, email address, personal postal address, phone number, and other similar contact data.
- Demographic data: We collect data about you, such as your date and place of birth, gender, country, and preferred language.
- Location data: For certain products and services, we collect imprecise data about your location that includes, for example, a location derived from your IP address.
- Profession and employment details: We collect details of your employment and your source of income.
- Government-issued photographic identification: We collect copies of passports, national ID cards, driving licenses and other acceptable forms of ID that contain photos.
- Financial and tax information: We collect information about your income, assets and liabilities, balances of your accounts, trading and financial statements, bank details, tax identification numbers and other identification numbers used for tax purposes.
- Trading information: We keep records of products you trade with us and their performance.
- Credentials: We collect passwords, password hints, and similar security information used for authentication and account access.
- Content: We collect the content of all telephone conversations and electronic communications between us that result in placing and/or closing an order or a trade, including communications that are intended to result in placing and/or closing an order or a trade, irrespective of the outcome.
- We collect the content of files and communications we receive from you when necessary to provide you with the products and services you use or intend to use. This includes files and communications sent and received by us via Outlook, our Client Portal and by post.
- We also gather the information you provide to us and the content of messages you send to us, such as feedback and service reviews you write or questions and information you provide for customer support. When you contact us, such as for customer support, phone conversations or chat sessions with our business development team may be monitored and recorded.
You provide this data directly, such as when you apply for an account with Hantec Markets, sign up for a demo, request access to MultiTerminal, fill in contact forms, inquire about Hantec Markets products and services, sign up for a webinar or to receive market research, analysis and reports, subscribe to news and updates, and in the course of customer service correspondence.
We may also collect your personal information through IB referral schemes or from publicly available sources.
We obtain some personal information through your use of our website or through the use of cookies and other tracking technologies on our website, in particular by recording which pages you browse on our website.
Cookies are small pieces of information sent by a web browser so they can later be read back from that browser. Cookies may be used on some pages of our Online Platform and website to provide users with a more customised browsing experience. For further detailed information about cookies and how you can control and delete them, please refer to the Cookies section on our website.
You have choices about the data we collect. When you are asked to provide personal data, you may decline. However, if you choose not to provide information that is necessary to fulfil your request for a specific product or service, we may not be able to provide you or the institution you represent with the requested product or service.
How do we use your personal information?
Hantec Markets uses the data we collect for the following purposes:
- To perform essential business operations (including monitoring and improving ) and provide the products and services we offer;
- To perform administration on the account, you may hold with us on an ongoing basis, including keeping records we hold accurate and up-to-date;
We will process certain personal information about you or your directors, officers, beneficial owners (if applicable) or any other associated employees in order to carry out anti-money laundering and international terrorist financing checks and related actions which we consider appropriate to meet any legal obligations imposed on us relating to, or to pursue our legitimate interests in relation to the prevention of fraud and other forms of crime (money laundering, terrorist financing, bribery and corruption, tax evasion, cyber-crime) and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions. We may also process your information to detect and prevent scalping, market abuse, or any other unethical trading in accordance with our existing policies and procedures.
We use the data to carry out analysis and monitoring that enable us to operate, fulfil our legal and regulatory responsibilities and obligations, including regulatory and supervisory reporting, make informed decisions, and report on the performance of our business. This includes disputes/complaints handling and resolution, reporting tax-related information to tax authorities, record retention for screening purposes, etc., to pursue our and, in some circumstances, our clients’ legitimate interests.
To monitor and record telephone conversations and electronic communication for investigation and fraud prevention purposes, for crime detection, prevention, investigation and prosecution, and to enforce or defend our rights, ourselves or through delegation of such responsibilities or rights to third parties in order to comply with a legal obligation imposed on us or to pursue our legitimate interests in relation to such matters or the processing in the public interest.
We use the data we collect to communicate with you and personalize our communications with you. For example, we may contact you by phone or e-mail or other means in order to respond to your query we may receive via our website, e-mail, client portal, chat system or by phone.
To effectively communicate and deliver information to you, including marketing and promotional communications about products and services that may be of interest to you or the institution you represent. Where we send you these communications, we will either do so for the purposes of the legitimate interests pursued by us or with your consent.
For any processing that is necessary to perform a relevant contract with you, comply with our legal obligations and/or which is necessary for our legitimate interests as set out above and/or where processing is necessary for reasons of public interest.
Additionally, you can sign up for email subscriptions and choose whether you wish to receive promotional communications (daily and weekly reports, promotions, new product offerings, news and announcements, webinars) from Hantec Markets Limited by email.
Disclosure of personal information
Your personal data will be treated as strictly confidential and as part of using it for the purposes set out above, we may share your personal information with:
- Other companies within the Hantec Group
- Vendors, service providers and specialist advisers who have been contracted to provide us with administrative, IT, financial, compliance, legal, regulatory, insurance, research or other services and who work on our behalf for the purposes described in this notice and may need access to personal data to provide those functions. Vendors, service providers and specialist advisers who have been contracted to provide us with administrative, IT, financial, compliance, legal, regulatory, insurance, research or other services and who work on our behalf for the purposes described in this notice and may need access to personal data to provide those functions.
- Introducing brokers with whom we have a mutual contractual relationship;
- Anyone authorised by you
We may also disclose personal data to:
- Courts, tribunals, law enforcement or other government agencies, applicable competent authorities as required by law or requested to comply with applicable law for internal investigations and to report or respond to valid legal process;
Security of Personal Data
Hantec Markets is committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use or disclosure. For example, we store the personal data you provide on computer systems that have limited access and are in controlled facilities. When we transmit highly confidential data electronically, we protect it through the use of encryption.
We train our employees who handle personal information to ensure confidentiality of personal data and privacy rights of individuals are respected at all times.
Retention period or criteria used to determine the retention period.
Hantec Markets retain personal data for as long as necessary to provide you or the institution you represent with the products and services, and/or for other essential purposes for which data was collected, depending on the legal basis for which that data was obtained and whether we are under any additional legal or regulatory obligations to retain your personal information. Because these needs can vary for different data types in the context of different legal and regulatory requirements, actual retention periods can vary.
If you have opted out of receiving any marketing communications from us, we will add you to a “do not contact” list to ensure we comply with your opt-out right and that your details will not be put back on the marketing list in later stages.
Data subject rights
You have the following rights, in certain circumstances, in relation to your personal information:
- Right to be informed about the data processing activities undertaken by us. This information is provided in this Privacy Notice.
- Right to access your personal information.
- Right to rectify your personal information.
- Right to request that your personal information is erased. Subject to any retention limits, we are required to comply with in accordance with applicable laws and regulations.
- Right to restrict the use of your personal information.
- Right to data portability (In certain specific circumstances.
- Right to object to the processing of your personal information.
You can always choose whether you wish to receive promotional e-mails or telephone calls from Hantec Markets. You can also opt-out of (or unsubscribe from) receiving marketing emails at any time by clicking on the unsubscribe link at the bottom of the latest email you received from us.
The right to lodge a complaint
If you have concerns or complaints about any aspects of our privacy practices, you can contact us by email at compliance-mu@hmarkets.mu, and this will be investigated promptly by us.
If you are dissatisfied with our response to your complaint, you have the right to lodge a complaint with the supervisory authority in the EU Member State of your habitual residence or place of work or in the place of the alleged infringement.
Anti-Money Laundering and Counter-Terrorism
Contents
Overview
Definition
Risk-based Approach
Anti Money Laundering Program
Suspicious Transaction Reports (STRS)
Customer Due Diligence
Enhanced Due Diligence (EDD)
Politically Exposed Person (PEP)
Monitoring Accounts For Suspicious Transactions
Record Keeping
1. Overview
This Anti-Money Laundering and Counter-Terrorism Policy has been designed to act as a general policy guideline for Hantec Markets Limited. (“Hantec” or the “Company”). This policy has been designed to ensure that the Company complies with all the relevant laws and regulations under which it is governed and regulated which include the following amongst others:
Financial Services Act 2007;
Code On The Prevention Of Money Laundering & Terrorist Financing 2012;
Financial Intelligence and Anti-Money Laundering Act 2002;
Securities Act 2005; and
The relevant acts, guidelines, rules and regulations under the laws of Mauritius.
The Company aims to prevent, detect and not knowingly facilitate money laundering and terrorism financing activities. The management of the Company places extremely high importance on assisting in discovering any money laundering scheme. It is the policy of the Company and its affiliates to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities.
2. Definitions
“Transaction” means any deposit, withdrawal, exchange or transfer of funds.
“Money laundering” is the conversion of criminal monetary proceeds into clean money, so that it may be used as if it was legitimately acquired funds. It can also be seen as the change/concealment of the form of the proceeds in order to shrink the huge volumes of cash generated by criminal activity. These proceeds include those derived from a variety of criminal activities including tax evasion, terrorism, sale of drugs, corruption, theft, etc.
Generally, money laundering occurs in three stages. Cash first enters the financial system at the “placement” stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler’s cheques, or deposited into accounts at financial institutions. At the “layering” stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. At the “integration” stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses. Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal the origin or intended use of the funds, which will later be used for criminal purposes.
3. Risk Based Approach
The possibility of being used to assist with money laundering and terrorist financing poses many risks for Hantec Markets Limited., including regulatory action and damage to reputation leading to loss of business.
These risks must be identified, assessed and mitigated, which are done for all business risks faced by the Company. The Company believes that if it knows its client well and understands its requirements thoroughly, it will be better placed to assess risks and spot suspicious activities. The risk-based approach means that Hantec Markets Limited. focuses its resources on the areas of greatest risk. The benefits in using this approach is that this is more efficient and effective use of resources proportionate to the risks faced, it minimizes compliance costs and burdens on clients and there is greater flexibility to respond to emerging risks as money laundering and terrorist financing methods change.
4. Anti-Money Laundering Reporting Officer
The Company shall designate an Anti-Money Laundering Reporting Officer (“MLRO”), who is also qualified in terms of experience, knowledge and training and to whom any internal report of suspicious transactions must be made. The MLRO will be fully responsible for the Company’s AML/CFT program and report to the Board of the Company or a committee thereof of any material breaches of the internal AML/CFT policy and procedures and of the AML/CFT laws, codes and standards of good practice.
The duties of the MLRO will include monitoring the Company’s compliance with AML/CFT obligations, overseeing communication and AML/CFT training for employees. The MLRO will also ensure that proper AML records are kept. When warranted, the MLRO will ensure Suspicious Transactions Reports (“STR”) are duly filed. The MLRO will also be responsible for ensuring that the Company has adequate customer identification and verification program in place at all times and in accordance with requirements of the law. The MLRO shall also prepare reports on an annual basis and such other periodic reports as he deems necessary to the Board of the Company or a committee thereof dealing with:
the adequacy/shortcomings of internal controls and other AML/CFT;
procedures implemented;
recommendations to remedy the deficiencies identified above;
the number of internal reports made by staff; and
the number of reports made to the Financial Intelligence Unit.
The Company and the MLRO shall ensure that the employees are properly trained and are fully aware of the Company’s AML/CFT policies and procedures. The Company will also perform criminal and disciplinary checks on all employees before they are hired. The Company will develop on-going employee training under the supervision of the MLRO.
5. Suspicious Transaction Reports (STRS)
Internal suspicious transaction reports are not to be disclosed to anybody other than to the MLRO. The MLRO making an STR is protected from civil, criminal or disciplinary action in respect of any information contained in the report, unless the information was disclosed in bad faith. The MLRO is obliged to keep records in a form that will allow a transaction to be completely reconstructed at any time by the authorities. All STR records are to be kept for a period of at least seven years. The MLRO and the Company’s employees must not alert the customer of the fact that a potentially suspicious transaction is being reported/ investigated so as not to commit the offence of tipping off. The MLRO will consider each internal potentially suspicious transaction and determine whether of gives rise to ground of suspicion such that an STR obligation is triggered.
6. Customer Due Diligence (“CDD”)
Effective Customer Due Diligence/‘know your customer’ (“CDD”) measures are essential to the management of money laundering and terrorist financing risk. CDD is identifying the client and verifying their true identity on the basis of documents, data or information obtained from a reliable and independent source both at the moment of starting a business relationship and on an ongoing basis. Identification of a client is getting to know a client’s identifying details, such as their name and address, his financial status and the capacity in which he is entering into the business relationship with the Company. Verification is obtaining evidence which is satisfactory to the Company and which supports the claim of identity. The Company will
collect certain identification information from each customer who opens an account;
utilize risk based measures to verify the identity of each customer who opens an account; and
record customer identification information and the verification methods and results;
Prior to opening of account, the Company collect the following information:
For all accounts, if applicable, for any person, entity or organization opening a new account and whose name is indicated on the account:
Name, incorporation number, legal status, date and country of incorporation or registration (for an entity other than an individual);
Date and place of birth (for an individual);
Occupation, public position held and where appropriate, the name of the employer (for an individual) or Anti-Money Laundering and Counter-Terrorism Financing Policy (for an entity other than an individual);
A current address, which will be residential (for an individual) or registered office address and principal place of business (where different from the registered office, for an entity other than an individual);
Passport number and country of issuance, identification card number and country of issuance of any other government issued document evidencing nationality or residence and bearing a photograph or other similar safeguard e.g. national identity cards, current valid passports or current valid driving licenses; and
The identity of underlying principles (including beneficial owners, controllers, directors or equivalent)with ultimate effective control over the capital or assets of an entity other than an individual in addition to evidence that any person who purports to act on behalf of the legal person is duly authorized and identify that person.
Where the underlying principals are not individuals, the Company shall investigate further to establish the identity of the natural persons ultimately owning or controlling the business. When opening an account for a foreign business or enterprise that does not have identification number, the Company will request alternative government approved documentation certifying the existence of the business or enterprise.
Customers who refuse to provide information
If a potential or existing customer either refuses to provide the information described above or such information as the Company may require or appears to have intentionally provided misleading information, the Company shall not open a new account and, after considering the risks involved, will consider closing any open account(s) of an existing customer.
Verifying information
Based on the risk, and to the extent reasonable and practicable, the Company will ensure that it has a reasonable belief that it knows the true identity of its customers by using risk based procedures to verify and document the accuracy of the information received about the customers. In verifying the customer’s identity, the Company will analyze any logical inconsistencies in the information obtained. Customer’s identity must be verified when:
Establishing a business relationship with a new client;
The Company suspects money laundering or terrorist financing; or
The Company has doubts about the veracity or adequacy of documents, data or information previously obtained for the purpose of CDD.
Where verification of identity is conducted after the establishment of the business relationship, verification will be completed as soon as is practicable after the business relationship has been established.
Methods of verification
The Company will verify customer identity through documentary evidence and non-documentary evidence (electronic verification). The Company will use documents to verify customer identity when appropriate documents are available. In light of the increased instances of identity fraud, the Company will supplement the use of documentary evidence by using the non-documentary means described below whenever possible. It may also use such non-documentary means, after using documentary evidence, if still uncertain about whether the true identity of the customer is known.
In analyzing the verification information, the Company will consider whether there is a logical consistency among the identifying information provided, such as the customer’s name, date of birth, street address and telephone number.
Appropriate documents for verifying the identity of customers include, but are not limited to, the following:
For an individual: a current government issued identification evidencing nationality, residence, and bearing a photograph or similar safeguard, such as a driver’s license or passport; and
For a person other than individuals, documents showing the existence of the entity, such as Certificate of Incorporation, Articles of incorporation, a government issued business license (if applicable), etc.
The Company will not be required to take steps to determine whether the document that the customer has provided for identity verification has been validly issued and it may rely on government issued identification as verification of a customer’s identity. If, however, it appears that the document shows some obvious form of fraud, the Company will consider that factor in determining whether it can form a reasonable belief that it knows the customer’s true identity.
The Company will use the following non-documentary methods of verifying identity:
Contacting a customer;
Independently verifying the customer’s identity through the comparison of information provided by the customer with information obtained from Internet and/or other source;
Checking references with other financial institutions; or
Obtaining a financial statement.
Non documentary methods of verification will be used in the following situations:
When the Company is unfamiliar with the documents the customer presents for identification verification;
When there are other circumstances that increase the risk that the Company will be unable to verify the true identity of the customer through documentary means.
Lack of verification
Should the Company reasonably believe that the true identity of a customer cannot be established, it will do any or a combination of the following:
Not proceed with or terminate any business with the customer;
File a STR in accordance with applicable laws and regulations.
7. Enhanced Due Diligence (EDD)
This Anti-Money Laundering and Counter-Terrorism Policy has been designed to act as a general policy guideline for Hantec Markets Limited. (“Hantec” or the “Company”). This policy has been designed to ensure that the Company complies with all the relevant laws and regulations under which it is governed and regulated which include the following amongst others:
The regulatory measures requires further research and identification of clients who may pose a high risk of money laundering to better assess the risks they pose.
If the Company has assessed that the business relationship or occasional transaction is a high risk relationship, based on the customer’s individual risk status, that is, the nature of the customer, the business relationship, its location, or any other specificity of the business relationship, it will apply EDD measures. By way of non-exhaustive examples, circumstances when EDD will be applied are:
If the Company establishes a business relationship with a customer from a country that has insufficient anti-money laundering and countering financing of terrorism systems or measures in place; or
If a customer seeks to conduct, through Hantec Markets Limited., a complex, unusually large transaction or unusual pattern of transactions that have no apparent or visible economic or lawful purpose
The Company may in all circumstances consider that the level of risk involved is such that enhanced due diligence should apply to a particular situation.
In addition to CDD, the following enhanced requirements under EDD will apply:
Information relating to the source of the funds or the source of wealth of the customer will be required.
Carrying out more frequent and extensive ongoing monitoring on the customer and comparison with provided lists of terrorists and other criminals within openly accessible media sources (World-Check, internet) will be conducted.
Seek further information from the customer or from the Company’s own research and third party sources in order to clarify or update the customer’s information, obtain any further or additional information, clarify the nature and purpose of the customer’s transactions with the Company.
If suspicious information is found indicating possible money laundering or terrorist financing activity, the MLRO shall file a STR in accordance with applicable law and regulations.
8. Politically Exposed Person (PEP)
Politically exposed person are individuals who are or have been entrusted with prominent public functions, including government heads, senior politicians, judicial or military officials, important political party officials including their family members or close associates of the politically exposed person.
The Company will review public information, including information available on the Internet or in databases, to determine whether any account holders, who conduct transactions in amounts over 10,000 USD (or equivalent), are PEPs. If information indicating that an account holder may be a PEP is found, and upon taking additional reasonable steps to verify this information, it is determined that the individual is, in fact, a PEP the Company will:
Take enhanced due diligence measures to establish the source of funds and source of wealth of the PEP.
Conduct enhanced ongoing monitoring of the business relationships involving the PEP.
Establish or continue the business relationship only with senior management approvals.
If suspicious information is found indicating possible money laundering or terrorist financing activity, the MLRO shall file an STR in accordance with the applicable laws and regulations.
9. Monitoring Accounts For Suspicious Transactions
The Company will monitor a sufficient amount of account activity to permit the identification of patterns of unusual size, volume, pattern or type of transactions, geographic factors such as whether jurisdictions designated as “non-cooperative” are involved, or any of the “red flags” identified below. The Company will look at transactions, including trading and wire transfers, in the context of other account activity to determine if a transaction lacks financial sense or is suspicious because it is an unusual transaction or strategy for that customer. The Company will closely monitor any transaction of over USD 10,000 (or equivalent) for identification of any suspicious activity.
The MLRO will be responsible for this monitoring, will document when and how it is carried out, and will report suspicious transactions to the appropriate authorities, when necessary. Examples of suspicious transactions, behaviors or activities that should raise a “red flag” and cause further inquiry. These “red flags” may alert the employees of the Company to possible suspicious activity. Some examples of “red flags” that could cause further investigation include:
Customers who wish to maintain a number of trustee or client accounts that do not appear consistent with the type of business, including transactions involving nominee names.
Matching withdrawals with deposits by different ways on the same or previous day.
Exposure or abuse of transfers without completing trading operations on the trading account.
Revelation of unusual nature of operations that do not have obvious economic substance or obvious legal purpose.
Customers who give conflicting information to different staff members.
Large cash withdrawals from a previously inactive account, or from an account which has just received an unexpected large credit from abroad.
A customer exhibits an unusual level of concern for secrecy, particularly with regard to the customer’s identity, type of business or source of assets.
A corporate customer lacks general knowledge of its own industry.
A customer is unconcerned with the risks, commissions or other costs associated with trading.
Revelation of circumstances implying that the operations are performed for the purpose of money laundering or financing terrorism.
Responding to red flags and suspicious activity
When a member of the Company detects any “red flag”, he must file an incident report without delay to the MLRO. He may also be required to investigate the activity further under the direction of the MLRO. This may include gathering additional information internally or from third party sources, classifying the account as a high risk account, placing the account under heightened supervisory review, which includes, but is not limited to, depending on the situation, turning the account over to the MLRO for review of all orders prior to entry, daily review of all trading activity, review of all money transfer requests, review of all deposits, contacting the authorities, freezing the account, or filing a STR. The Company shall not inform anyone outside of law enforcement or other competent authorities about a STR.
10. Record Keeping
When transferring funds, the Company will record in its database at least the following information:
The execution date of the transmittal order;
The name and address of the recipient;
The amount of the transmittal order;
The identity of the recipient’s financial institution, and;
The account number of the recipient.
For each transmittal order that the Company accepts, it will retain in its files any payment instructions received from the transmitter with the transmitter’s order and any form relating to the transmittal of funds that is completed by the person placing the transmittal. STR Maintenance and Confidentiality All employees of the Company shall be aware of to whom and in what format their suspicions must be reported. They will also receive training from the MLRO upon, and during the course of, their employment.
The MLRO shall hold AML records, STRs and supporting documentation confidential and ensure that STRs are filed as required. This information will not be communicated to anyone other than law enforcement or other competent authorities. Once an internal suspicion report is made to the MLRO or an STR has been submitted to the FIU, no employee of the Company shall warns or inform the owner of any funds of any report or any action that is to be taken in respect of any transaction concerning such funds. When an STR has been made to the FIU with respect to a particular customer, the Company shall ensure that due care is taken during subsequent enquiries so as not to alert the customer about the disclosure. Appropriate measures shall be taken by the Company to ensure that the offence of tipping off is not committed.
Negative Balance Protection Policy
Terms and Conditions
Introduction
- Hantec Markets Ltd is authorized and regulated by the Mauritius Financial Services Commission (FSC) in the Republic of Mauritius. License Number: C114013940 (hereinafter the “Company” or “Hantec”).
- The negative balance protection policy (hereinafter the “Negative Balance Protection Policy” or “NBPP”) offered by Hantec will be available to Eligible Clients only subject to the terms listed hereinafter (known as “Terms and Conditions”).
- Subject to, and without prejudice to, the Client Agreement and all other business terms and policies, the NBPP is available to Hantec clients who have satisfied the Eligibility Criteria for the offer (“Eligible Clients”) as set out in the sections hereinafter.
- Only persons who can form legally binding contracts under the laws applicable in their country of residence may participate in the NBPP. Without limiting the foregoing, participation in the NBPP is not allowed for persons under the age of 18 or otherwise under legal age in their country of residence.
- Collusion of Intermediaries/Related Parties of any kind, including but not limited to abusing the NBPP is prohibited. If the registration and / or trading data of a Client corresponds with the registration and / or trading information, including but not limited to IP address, of another client, Hantec reserves the sole right in its absolute and sole discretion to regard this matching as a reason for immediate disqualification from Eligibility to the NBPP. For the purposes hereof, the term “Intermediaries/Related Parties”, when used in these Terms & Conditions, unless the context otherwise requires, shall mean to include any person or entity bearing a relationship with any other Hantec client, including, without limitation:
- family members, such as brothers, sisters, spouses, ancestors, lineal descendants and collateral descendants;
- person or entity, directly or indirectly through one or more intermediaries, controls, or whom, directly or indirectly, through one or more intermediaries, is controlled by, or is under common control with any other Hantec client; for purposes of this definition, the term control (including, with correlative meaning, the terms “controlled by“ and “under common control with”), as used with respect to any Hantec client, shall mean the possession, directly or indirectly through one or more intermediaries, of the power to direct or cause the direction of management policies of such person or entity, whether through ownership of voting securities or otherwise.
- Eligible Clients’ main account and any sub-accounts, including funds held in a wallet and accounts held in joint ownership constitute a single contractual agreement and are treated as one account (known as an “Account”) for the purpose of realized client balances in connection with the NBPP. This means that all account opening conditions, agreements and provisions between Hantec with regards to the main account are equally valid and applicable to all accounts held by an Eligible Client individually and/or jointly, and any realized negative balances may be netted against other accounts either held in the same name and/or being controlled from the same IP address or related IP addresses.
- In the case of a Force Majeure Event causing extreme volatility in the markets, Hantec has the right and the sole discretion to nullify the NBPP and the NBPP will not be actioned for any and all Eligible Clients.
- In this Clause 5, a “Force Majeure Event” means an emergency or an exceptional market condition event beyond the control of Hantec, which includes but is not limited to and determined in our reasonable opinion:
- any act, event or occurrence (including without limitation any strike, riot or civil commotion, act or threat of terrorism, war, industrial action, acts and regulations of any governmental or supra national bodies or authorities) that, in our opinion, prevents us from maintaining an orderly market in any of our products
- act of God (such as, but not limited to, fires, explosions, earthquakes, drought, tidal waves and floods);
- war, hostilities (whether war be declared or not), invasion, act of foreign enemies, mobilisation, requisition, or embargo;
- rebellion, revolution, insurrection, or military or usurped power, or civil war;
- contamination by radio-activity from any nuclear fuel, or from any nuclear waste from the combustion of nuclear fuel, radio-active toxic explosive, or other hazardous properties of any explosive nuclear assembly or nuclear component of such assembly;
- riot, commotion, strikes, go slows, lock outs or disorder, unless solely restricted to employees of the Supplier or of his Subcontractors;
- the suspension or closure of any market or the abandonment or failure of any event on which we base, or to which we in any way relate, our quote, or the imposition of limits or special or unusual terms on the trading in any such market or on any such event;
- the occurrence of an excessive movement in the any global foreign currency markets that are related to our markets for any products or our anticipation (acting reasonably) of the occurrence of such a movement;
- any breakdown or failure of transmission, communication or computer facilities, interruption of power supply, or electronic or communications equipment failure; or
- failure of any relevant vendor, intermediate broker, agent or principal of ours, custodian, sub-custodian, dealer, exchange, clearing house or regulatory or self-regulatory organisation, for any reason, to perform its obligations.
- Eligible Clients, who meet the criteria set forth herein will receive additional protection from the NBPP whereby any trading losses which exceed the existing net deposited funds on your Account will be cleared, up to a maximum of 10,000 USD (known as an “Adjustment”).
- The Adjustment will only be made to Eligible Clients who have no open trades on their Account and an Adjustment calculation at any point in time will always factor both realized and unrealized profits and/or losses.
- This NBPP applies to both new and existing clients of Hantec only. Existing Clients and Clients who are introduced to Hantec via an Introducing Broker (IB) are also eligible for the NBPP.
- The maximum clearance that can be applied to any Account is 10,000 USD, regardless of the size of the Eligible Client’s initial deposit or further deposits.
- Please note that it may take up to 24 business hours before any Adjustment is added to the account of an Eligible Client who meets all the criteria set forth herein.
- Hantec reserves the right, at its reasonable and sole discretion:
- to decline the eligibility of any client to the NBPP; and
- to disqualify and remove any relevant trading activity from any client who tampers or attempts to tamper with the operation of the NBPP, or breaches these terms, the Client Agreement and/or any of the Hantec terms and policies set forth on Hantec’s website.
- Hantec reserves the right, at its reasonable discretion, to discontinue the offering of this NBPP to any of its clients at any time and without prior notice.
- Hantec reserves the right to alter, amend or terminate the NBPP or any aspect of it at any time. Prior notice of such changes will be given to clients and Hantec will post any such changes on its website and/or terms and conditions. It is recommended that Eligible Clients of the NBPP consult these Terms & Conditions on Hantec’s website regularly. Please note that all Eligible Clients accept and agree to abide by any such alterations, amendments and/or changes.
- Any indication or suspicion, in Hantec’s sole discretion, of any form of arbitrage (including but not limited to risk free profiting), abuse (including but not limited to participant’s trading activity patterns that indicate that the participant solely aims to benefit financially from the Adjustment without being genuinely interested in trading in the markets and/or taking market risk), fraud, manipulation, cash-back arbitrage connected to an Adjustment or any other forms of deceitful or fraudulent activity, will nullify the NBPP and the NBPP will not be actioned. In these circumstances, Hantec reserves the right, at its sole discretion to close/suspend (either temporarily or permanently) all such Eligible Client’s real trading account(s) with Hantec, cancel all orders and annul all suspected previous trades of such Eligible Client. In these circumstances, Hantec shall not be liable for any consequences of the Adjustment cancelation, including, but not limited to, order(s) closure by stop out.
Key Information Documents
In order to meet our obligations under PRIIPs (Packaged Retail Investment and Insurance Products) regulation, we have produced the following key information documents for each product type we offer. These documents are aimed to help you better understand our products, including the risks, costs and examples of potential gains and losses associated with them, and any other relevant information.
Privacy notice
Your privacy is of paramount importance to us. At Hantec Markets we protect personal data and confidentiality of the information and respect the privacy rights of our existing and prospective customers.
Hantec Markets collects data to operate effectively and provide you with a valuable service while ensuring that your needs are met.
This privacy notice explains what personal data we collect from you in connection with the provision of our products or services to you or from your use of our products and services, as well as through our interactions with you through our website or applications. This notice also outlines how the data that we collect is used.
Data Controller
This Privacy Notice applies to the data processing activities carried out by Hantec Markets Limited who acts as a Data Controller of your personal information.
Hantec Markets Limited is registered in England and Wales, company number 06819047, principal place of business 5‑6 Newbury Street, London EC1A 7HU, registration number with the Information Commissioner is ZA188388.
If you have any questions about this notice or wish to exercise your rights in relation to your personal information, please contact the Data Protection Officer:
- Call: +44 (0) 207 036 0882
- Email: compliance-uk@hmarkets.co.uk
- Write to us: Compliance Department, Hantec Markets, 5‑6 Newbury Street, London EC1A 7HU
What Type of Personal Data We Collect and How We Collect It?
The data we collect depends on the context of your interactions with us, the choices you make, including the products and services you use or wish to start using. The data we collect about you can include the following:
- Name and contact data: We collect your full name, email address, personal postal address, phone number, and other similar contact data.
- Demographic data: We collect data about you such as your date and place of birth, gender, country, and preferred language.
- Location data: For certain products and services, we collect imprecise data about your location that includes, for example, a location derived from your IP address.
- Profession and employment details: We collect details of your employment and your source of income.
- Government-issued photographic identification: We collect copies of passports, national ID cards, driving licenses and other acceptable forms of ID that contain photos.
- Financial and tax information: We collect information about your income, assets and liabilities, balances of your accounts, trading and financial statements, bank details, tax identification numbers and other identification numbers used for tax purposes.
- Trading information: We keep records of the products you trade with us and their performance.
- Credentials: We collect passwords, password hints, and similar security information used for authentication and account access.
- Content: We collect the content of all telephone conversations and electronic communications between us that result in placing and/or closing an order or a trade, including communications that are intended to result in placing and/or closing an order or a trade, irrespective of the outcome.
We collect the content of files and communications we receive from you, when necessary to provide you with the products and services you use or intend to use. This includes files and communications sent and received by us via Outlook, our Client Portal and by post.
- To perform essential business operations (including monitoring and improving) and provide the products and services we offer;
- To perform administration on the account you may hold with us on an on-going basis, including keeping records we hold accurate and up-to-date;
- Other companies within the Hantec Group.
- Vendors, service providers and specialist advisers who have been contracted to provide us with administrative, IT, financial, compliance, legal, regulatory, insurance, research or other services and who work on our behalf for the purposes described in this notice and may need access to personal data to provide those functions.
In such cases, the contractors must abide by our data processing agreements and are not allowed to use personal data they receive from us for any other purpose.
- Introducing brokers with whom we have a mutual contractual relationship;
- Anyone authorised by you.
We may also disclose personal data to:
- Courts, tribunals, law enforcement or other government agencies, applicable competent authorities as required by law or requested to comply with applicable law for internal investigations and reporting or respond to valid legal process;
The disclosure of personal information to the affiliates and other third parties set out above may involve the transfer of data to other jurisdictions outside the UK. Such countries may not have the same data protection laws as the UK. For such transfers of personal data we have put in place the Standard Contractual Clauses based on the International Data Transfer Agreement (IDTA) and the UK Addendum. To the extent we transfer your information outside the UK, we will ensure that transfer is lawful and that there are appropriate security arrangements. Please contact us on compliance-uk@hmarkets.co.uk should you require more information on international data transfer arrangements.
Security of Personal Data
Hantec Markets retain personal data for as long as necessary to provide you or the institution you represent with the products and services, and/or for other essential purposes for which data was collected, depending on the legal basis for which that data was obtained and whether we are under any additional legal or regulatory obligations to retain your personal information. Because these needs can vary for different data types in the context of different legal and regulatory requirements, actual retention periods can vary.
- Records of identification evidence (customer due diligence/KYC) are kept for a period of five years from the ending of the business relationship with the customer, i.e. the closing of the account or accounts.
- Records relating to all orders and all transactions carried out by us on behalf of our clients containing all the information and details of the identity of the client, and the information required is kept for the period of five years from the ending of the business relationship with the customer, i.e. the closing of the account or accounts.
- Records of communications, including telephone and other electronic communications, are retained for five years from the ending of the business relationship with the customer, i.e. the closing of the account or accounts.
If you have opted out of receiving any marketing communications from us we will add you to a “do not contact” list to ensure we comply with your opt-out right and that your details will not be put back on the marketing list at later stages.
Data subject rights
The GDPR provides the following rights for you:
- The right to be informed – If you ask us, we will provide you with various pieces of information about the data processing activities undertaken by us. This information is provided in this Privacy Notice.
- The right of access – If you make a request, we will provide you with confirmation whether your personal information is being processed by us and a copy of that personal information. Should you wish to see your own collection data, request for information can be made by email: compliance-uk@hmarkets.co.uk.
- The right to rectification – If the data we hold about you is inaccurate or incomplete you have the right to rectify it. If we have disclosed your information to others for the purposes described in this notice, we will inform them about the rectification where possible. If you ask us and where possible and lawful to do so, we will also let you know who we have disclosed your personal information to (the recipients).
- The right to data erasure (the right to be forgotten) – You can ask us to delete or remove your personal information in certain circumstances such as where we no longer need it and we have no compelling reasons or legal basis for holding it or, where applicable, you withdraw your consent. Such request will be subject to any retention limits we are required to comply with in accordance with applicable laws and regulations. If we have shared your personal information with others, we will inform them about the erasure where possible. If you ask us and where possible and lawful to do so, we will also let you know who we have disclosed your personal information to (the recipients).
- The right to restrict processing – In certain circumstances such as when you believe that the data we hold about you is inaccurate or object to us processing it you can restrict processing by asking us to suppress the processing of your personal information until the accuracy of it is verified. This will not stop us from storing your personal information though. We will inform you before we lift any restriction. If we have shared your personal information with others, we will let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your personal information with (the recipients).
- The right to restrict processing – In certain circumstances such as when you believe that the data we hold about you is inaccurate or object to us processing it you can restrict processing by asking us to suppress the processing of your personal information until the accuracy of it is verified. This will not stop us from storing your personal information though. We will inform you before we lift any restriction. If we have shared your personal information with others, we will let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your personal information with (the recipients).
- The right to data portability – This allows you, in certain circumstances, to obtain personal information you have provided us with and move, copy or transfer it between service providers of your choice.
- The right to object – You can ask us to stop processing your personal information and we will do so, if:
– Processing is based on our legitimate interests, except if we can demonstrate overriding compelling legitimate grounds to continue processing or the processing is for the establishment, exercise or defence of legal claims;
– Processing is for direct marketing; and
– Processing is for purposes of historical research and statistics
You can always choose whether you wish to receive promotional e-mails or telephone calls from Hantec Markets. You can also opt-out of (or unsubscribe from) receiving marketing emails at any time by clicking on the unsubscribe link at the bottom of the latest email you received from us.
Rights in relation to automated decision making and profiling – you have the right not to be subject to a decision when:
- it is based on automated processing; and
- it produces a legal effect or a similarly significant effect on you.
At Hantec Markets we do not make decisions about you based solely on an automated process without any human involvement including profiling (automated processing of personal data to evaluate certain things about you).
The right to lodge a complaint
If you have concerns or complaints about any aspects of our privacy practices, you can contact us by email at complaints-uk@hmarkets.co.uk and this will be investigated promptly by the Data Protection Officer.
If you are dissatisfied with our response to your complaint, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO). You can do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.
MIFIDPRU Public Disclosure
Annual MIFIDPRU public disclosure report: 31 March 2024
The terms ‘we’, ‘us’, ‘HML’ and ‘our’ are used in this disclosure to refer to Hantec Markets Limited.
Introduction
In January 2022 the FCA introduced the Investment Firms Prudential Regime (IFPR). The IFPR is implemented through a new prudential sourcebook in the FCA Handbook, The Prudential Sourcebook for MiFID Investment Firms (MIFIDPRU). MIFIDPRU sets out the detailed prudential requirements that apply to a MIFIDPRU investment firms and seeks to cover the potential harms posed by investment firms to their clients and the markets they operate in. These rules are available on the FCA website and can be found at https://www.handbook.fca.org.uk/handbook/MIFIDPRU.
This document sets out certain disclosures relating to our business that we are required to publish under this new regime.
Content of the disclosures
This document covers the following key areas:
– Basis for disclosures – important information about how these disclosures have been formed
– Risk management – how HML manages risks within its business
– Governance arrangements
– HML’s Own Funds – the levels of Own Funds held by HML with a full breakdown, and
– Own Funds regulatory requirements – the level of Own Funds in HML and the regulatory thresholds.
Basis for disclosure
This document sets out the disclosures that we are required to make. These disclosures have not been audited and do not form part of the annual audited financial statements, and they should not be relied upon when making any judgements about the financial position of HML.
These disclosures are based on the calculations made in accordance with MIFIDPRU based on information related to HML’s Annual Report and Accounts, which are made up to 31 December 2023. HML’s financial year is 1 January to 31 December.
These disclosures are made on an annual basis as soon as practical after HML publishes its annual financial statements.
HML may also make more frequent public disclosure where particular circumstances demand it, for example, in the event of a major change to its business model.
Risk management
Hantec Markets Limited is a private limited company regulated by the Financial Conduct Authority (FCA). HML carries out a regulated activity of dealing in investments, offering Contracts for Differences (CFDs) to Retail and Professional clients. CFD products are offered through the online trading platform MT4. CFDs allow clients at HML to gain indirect exposure to the price movements in underlying FX pairs, stock indices, and commodities.
Hantec Markets maintains an internal risk management and control system, which is a set of tools, documents, and processes that support the management and control of risks. We have established, implemented, and maintain adequate risk management policies and procedures, including effective procedures for risk assessment. They focus on identifying the risks relating to the firm’s activities, processes, and systems that may cause the business plan to become unviable, assess the likelihood that such events could crystallise, and, where the assessment reveals a risk of business failure that is unacceptably high when considered against the firm’s risk appetite or tolerance, adopt effective arrangements, processes, systems, or other measures to prevent or mitigate that risk.
Effective risk management at HML is driven as much by the governance and culture of the firm as by any risk management tools, such as policies and procedures. Risk management has the commitment of the Board and senior management and is recognised as being the way that the firm does business. Risk management responsibilities are built into role descriptions, forming a part of day-to-day responsibilities and routines and the objectives that are set.
Strategic risk management is a Board responsibility. At a strategic level, the statement of risk appetite that underpins the strategic direction and sets the parameters for decision-making is the key. The risk appetite statement reflects the values and strategy of the business, taking into account any regulatory expectations in priority areas.
Anchoring risk management into planning processes enhances strategic planning, and enables decision-making that informs the best way forward, and ensures that appropriate controls are built into all areas of HML’s activity.
Consumer duty requirements are integrated into the risk management framework and day-to-day routines and processes of the firm. Acting to deliver good customer outcomes is also at the centre of firms’ strategy and business objectives. HML’s Board and senior management ensure the firm’s customers are getting outcomes consistent with the Duty.
The strategic plan of HML, as agreed by the Board, is to grow profits but within a conservative risk appetite, by expanding its offering of execution trading services to an increasingly diversified product and customer base achieved by the following strategic goals:
• increase the institutional client base;
• increase the retail client base; and
• increase volume traded.
The business plan is reliant on maintaining existing business and organic growth based on client referrals, management contacts, and increasing trades undertaken by existing clients.
As a result of its normal business activities, HML is exposed to a variety of risks, the most significant of which are market, operational, liquidity, counterparty and credit risks. Operational risk is defined as the risk of loss resulting from inadequate or failed internal processes, people, and systems, or from external events. This includes regulatory, legal, and compliance risks. Market risk is the potential for loss of income or a decrease in the value of net assets caused by currency fluctuations.
Counterparty and credit risk is the risk that counterparties will not meet their financial obligations. Risks can also arise for clients through failures in incident management, inadequate complaints servicing, and as a loss or severe restriction in critical servicing. Strategic and business risks are managed with the focus on maintaining a conservative risk appetite.
Below are some specific risks that HML is exposed to, broken down into those that relate to HML’s own funds requirements, concentration risk, and liquidity risk.
ICARA process
The internal Capital Adequacy Assessment (ICARA) process is central to a HML’s risk management framework, which is not only integral to how the firm manages its risks but is also central to how the FCA manages the risk of the firm that it supervises. Being the centrepiece of HML’s risk management processes, it incorporates business model assessment, forecasting and stress testing, recovery planning, and wind-down planning. As part of the ICARA process, we also demonstrate how we meet an OFAR to ensure that HML holds sufficient own funds and liquid assets to remain viable throughout the economic cycle and to allow the business to wind down in an orderly way.
As part of the ICARA process, the HML Board oversees and assesses:
• HML’s processes, strategies, and systems;
• the major sources of risks faced by HML that may impact its ability to meet its obligations;
• the results of internal stress testing of these risks; and
• the amounts and types of financial resources and internal capital, including Own Funds and liquidity resources, and whether these are adequate both as to amount and quality to ensure that there is no significant risk that its liabilities
can’t be met as they fall due.
The outcome of the ICARA is formally approved by the HML’s Board at least annually, with more frequent reviews if there is a material change to the business or the operating environment.
Own Funds’ risks
Own Funds are a measure of the firm’s financial resources. The level of Own Funds is important, as they must meet the threshold levels set out in the FCA’s rules and regulations. These threshold levels reflect, amongst other factors, the potential risks and harms to the firm’s clients, the firm itself, and the markets the firm operates in, which arise from the firm’s business activities, for example, significant market downturns or defaults by key counterparties.
HML’s Own Funds assessments look at the following risks, although this list is not exhaustive:
Operational & Regulatory Control;
The FCA Client Assets Sourcebook (CASS) Framework;
Data Management;
Fraud and financial crime;
Operational Resilience and Business Continuity;
Capital and Liquidity risk;
Concentration risk;
Credit and Counterparty risk;
The likelihood of risks emerging, and the financial impact they may have, should they materialise, are reflected in the assessment of the Own Funds. This assessment determines the minimum amount of Own Funds HML must hold at all times.
These assessments are refreshed as and when risks change or new risks emerge. The level of HML’s Own Funds held can be found in the Own Funds section below.
Concentration risk
High exposure to certain counterparties, credit lines, or channels can result in an increased risk to HML. The concentration risks identified for HML are:
HML liquid assets/cash concentration
The firm’s own cash is placed with several banks, and in the event of a default by these banks, HML would rank amongst other creditors in respect of the amount deposited. We manage this risk through careful selection, vetting, and constantreview of the credit ratings of the banks, as well as regular monitoring of the amounts we hold in these bank accounts.
HML client money concentration
HML places client money (i.e. money held on behalf of clients) with third-party banks and liquidity providers. HML accepts
that from time to time it does have concentrations of exposures to banking counterparties, which could give rise to an increased level of risk. However, HML attempts to minimise this risk by maintaining a diverse portfolio of providers’ relationships and meeting the CASS rules at all times.
LP (Liquidity Providers) concentration
Managing concentrations by assignment of credit and operating limits on an individual LP level restricts the total amount of exposure and by having multiple Liquidity Providers to ensure that such exposures remain within predefined limits.
Liquidity risk
This is the risk that HML, although meeting the required level of own funds and liquid assets, either may not have sufficient resources available to meet its obligations when they come due or can only secure them at an excessive cost.
HML is exposed to liquidity risk in the event of downturns in revenue, where HML’s recurring revenue is insufficient to meet HML’s overheads. HML manages this risk through regular monitoring of the liquid assets held against the thresholds. In addition, HML assesses the liquidity position in stressed conditions over future years to ensure it maintains sufficient liquid assets.
HML is also exposed to liquidity risk in respect of execution obligations to its clients arising from the firm’s counterparties’ inability to fulfil their settlement obligations, exposing HML to potential losses from having to cover failed client positions with other LPs using its liquid assets. In addition, HML has an arrangement in place relating to the settlement of customer trades to mitigate the issues with delayed settlements.
HML holds all client money with several banks and liquidity providers in accounts that have been opened as client money transaction accounts, which are distinguished from any accounts containing money that belong to them. This is also to ensure that counterparties understand and agree that they will not have any recourse or right against money standing to the credit of the settlement accounts in respect of any sum owed to them or to any other third person. Any liquidity risks with respect to these holdings are managed by diversifying the funds across banks and providers.
HML’s own assets are predominantly liquid assets, that is cash held with banks.
Governance arrangements
HML’s Board of directors, which includes executive and non-executive directors, defines, oversees, and is accountable for the implementation of governance arrangements that ensure effective and prudent management of the firm, including the segregation of duties in the organisation and the prevention of conflicts of interest, and in a manner that promotes the integrity of the market and the interests of clients.
The HML Board has overall responsibility for the firm and:
• approves and oversees the implementation of the firm’s strategic objectives, risk strategy, and internal governance;
• ensures the integrity of the firm’s accounting and financial reporting systems, including financial and operational controls and compliance with the regulatory system.
• oversees the process of disclosure and communications;
• has responsibility for providing effective oversight of senior management;
• monitors and periodically assesses:
– the adequacy and implementation of the firm’s strategic objectives in the provision of investment services
and/or activities and ancillary services;
– the effectiveness of the firm’s governance arrangements; and
– the adequacy of the policies relating to the provision of services to clients, and
takes appropriate steps to address any deficiencies; and
• has adequate access to information and documents which are needed to oversee and monitor managementdecision-making.
HML ensures that the members of the Board meet the requirements of SYSC 4.3A.3R and:
• are of sufficiently good repute;
• possess sufficient knowledge, skills, and experience to perform their duties;
• possess adequate collective knowledge, skills, and experience to understand the firm’s activities, including the main risks;
• reflect an adequately broad range of experiences;
• commit sufficient time to perform their functions in the firm; and
• act with honesty, integrity, and independence of mind to effectively assess and challenge the decisions of senior management where necessary and to effectively oversee and monitor management decision-making.
The HML Board recognises that risks will be present throughout the activities that HML undertakes. The HML Board meets on a quarterly basis and is responsible for ensuring that HML has a suitably robust governance and risk management framework in place to ensure the adequate identification, assessment, and mitigation of risks inherent to the company.
HML’s governance arrangements also include a clear organisational structure with well-defined, transparent, and consistent lines of responsibility, effective processes to identify, manage, monitor, and report the risks the firm is or might be exposed to, and internal control mechanisms, including sound administrative and accounting procedures and effective control and safeguard arrangements for information processing systems.
This is ultimately to ensure that clients’ money and HML’s own assets are suitably protected.
The HML Board
The HML Board is responsible for promoting the long-term sustainable success of the company and generating value for shareholders. It has overall responsibility for oversight of the business and affairs of HML, the establishment and periodic assessment of the implementation of HML’s strategy, the establishment and oversight of HML’s risk strategy, the monitoring of regulated capital as applicable, and the maintenance of high standards of corporate governance.
The Board monitors and oversees HML’s operations, ensuring competent and prudent management, sound planning, appropriate policies, proper procedures for the maintenance of adequate accounting and other records and systems of
internal control, and compliance with statutory and regulatory obligations.
The HML Board will perform a regular review of the adequacy of HML’s ICARA process and approve the contents of HML’s ICARA document, in particular the key assumptions in the document.
The table below shows the number of directorships held by each member of the HML Board.
Executive | Non-executive | |
Bashir Nurmohamed | 1 | |
Man-Woon James Yu | 2 | |
Richard Cohen | 9 | 1 |
Ngok Fung Lam | 2 | 1 |
Chi Bun Tang | 2 | 13 |
Colin James Barrett | 2 |
Promoting inclusion and diversity
HML has diversity and inclusion at the top of its agenda to attract, train, and retain employees, attain long-term and sustainable results, and contribute to a better future for everyone.
The HML Board aims for a composition that is balanced and diverse in terms of experience, nationality, ethnicity, age, and gender of the individual members. The HML Board recognises that diversity, and especially diversity of thought, can bring insights and behaviours that may make a valuable contribution to its effectiveness.
Own Funds
Own Funds can be made up of different categories of capital called: common equity tier 1 capital, additional tier 1 capital, and tier 2 capital. The items that fall into each of these categories can be seen in the Table A below.
Under MIFIDPRU, HML is required to disclose:
• a reconciliation of common equity tier 1 items, additional tier 1 items, tier 2 items, and the applicable filters and
deductions applied in order to calculate the Own Funds of the firm, provided in the Table A;
• a reconciliation of 1 (above) with the capital in the balance sheet in the audited financial statements of the firm – provided in the Table B; and
• a description of the main features of the common equity tier 1 instruments, additional tier 1 instruments and tier 2 instruments issued by the firm, provided in the Table C.
The required information is presented in the three tables below and is based on the HML Annual Reports and Accounts as of 31 December 2023.
Table A: Composition of regulatory Own Funds
All HML’s Own Funds are made up of common equity tier 1 capital.
Item | Amount (GBP) | Source based on reference numbers/letters of the balance sheet in the audited financial statement | |
1 | OWN FUNDS | 5,391,778 | Page 11, Total equity |
2 | TIER 1 CAPITAL | 5,391,778 | |
3 | COMMON EQUITY TIER 1 CAPITAL (CET1) | 5,391,778 | |
4 | Fully paid-up capital instruments | 3,000,000 | Page 11, Called up share capital |
5 | Share premium | 338,015 | Page 11, Share premium account |
6 | Retained earnings | 2,053,763 | Page 11, Profit and loss reserves |
7 | CET1 instruments of financial sector entities where the institution has a significant investment | 0 | |
8 | Accumulated other comprehensive income | 0 | |
9 | Other reserves | 0 | |
10 | Adjustments to CET1 due to prudential filters | 0 | |
11 | Other funds | 0 | |
12 | (-) TOTAL DEDUCTIONS FROM COMMON EQUITY TIER 1 | 0 | |
13 | CET1: Other capital elements, deductions and adjustments | 0 | |
14 | ADDITIONAL TIER 1 CAPITAL | 0 | |
15 | Fully paid up, directly issued capital instruments | 0 | |
16 | Share premium | 0 | |
17 | (-) TOTAL DEDUCTIONS FROM ADDITIONAL TIER 1 | 0 | |
18 | Additional Tier 1: Other capital elements, deductions and adjustments | 0 | |
19 | TIER 2 CAPITAL | 0 | |
20 | Fully paid up, directly issued capital instruments | 0 | |
21 | Share premium | 0 | |
22 | (-) TOTAL DEDUCTIONS FROM TIER 2 | 0 | |
23 | Tier 2: Other capital elements, deductions and other adjustments | 0 |
Table B – Own Funds: reconciliation of regulatory Own Funds to balance sheet in the audited financial statements
Table B below shows the assets, liabilities and shareholders’ equity of HML cross-referenced to Table A above:
Balance sheet as in published/audited financial statements | Under regulatory scope of consolidation | Cross reference to Table A statements | ||
As at the end of the period | As at the end of the period | As at the end of the period | ||
Assets – Breakdown by asset classes according to the balance sheet in the audited financial statements | ||||
Fixed Assets | ||||
Tangible Assets | 210,148 | n/a | n/a | |
Investments | 0 | n/a | n/a | |
Current Assets | ||||
Debtors | 1,722,739 | n/a | n/a | |
Cash at bank and in hand | 3,807,847 | n/a | n/a | |
Total Assets | 5,740,734 | n/a | n/a | |
Liabilities – Breakdown by liability classes according to the balance sheet in the audited financial statements | ||||
Creditors: amounts falling due within one year | 294,078 | n/a | n/a | |
Creditors: amounts falling due after more than one year | 54,878 | n/a | n/a | |
Total Liabilities | 348,956 | n/a | n/a | |
Shareholder’s equity | ||||
Share capital | 3,000,000 | n/a | Item 4 | |
Share premium | 338,015 | n/a | Item 5 | |
Retained earnings | 2,053,763 | n/a | Item 6 | |
Total Shareholders’ equity | 5,391,778 | n/a | Item 1 |
Table C: Own Funds: main features of own instruments issued by HML
Issuer | Hantec Markets Limited |
Governing law(s) of the instrument | England and Wales |
Transitional Basel III rules | Common Equity Tier 1 |
Post-transitional Basel III rules | Common Equity Tier 1 |
Eligible at solo/group/consolidated | Solo |
Instrument type (types to be specified by each jurisdiction) | Equity |
Amount recognised in regulatory capital (£m) | 3 |
Par value of the instrument (£m) | 3 |
Issue price of instrument (£m) | 100% |
Redemption price of instrument | n/a |
Accounting classification | Shareholders Equity |
Original date of issuance | 03/06/2010 |
Perpetual or dated | Perpetual |
Original maturity date | n/a |
Issuer call subject to prior supervisory approval | No |
Optional call date, contingent call dates and redemption amount | n/a |
Subsequent call dates, if applicable | n/a |
Fixed or floating dividend/coupon | Variable |
Coupon rate and any related index | n/a |
Existence of a dividend stopper | No |
Fully discretionary, partially discretionary or mandatory | Fully discretionary |
Existence of step up or other incentive to redeem | No |
Noncumulative or cumulative | Noncumulative |
Convertible or non-convertible | Non-convertible |
Write-down feature | No |
Own funds requirements
The level of regulatory capital that must be held to absorb losses is the ‘Own Funds Threshold’ requirements. In accordance with MIFIDPRU, HML is required to hold Own Funds in sufficient quantity and quality.
The level of actual Own Funds held by HML is explained above. This section describes how we have arrived at the Own Funds Threshold requirements.
Components of the assessment
To determine the own funds requirement of HML, an assessment of three key items is required.
These are:
• the Permanent Minimum Capital – this is defined by the regulation and is £750,000 for HML;
• the Fixed Overhead Requirement – this is a level equal to a quarter of HML’s overheads – this level is £1,714,593; and
• the ‘K’ factors. These factors are applied to three key metrics for HML. These are explained below, and for HML, the Kfactor
total is £491,715+ £ 908,500 additional own funds to address risks from ongoing activities.
The ’Own Funds’ requirement is the largest of these three key items.
HML’s K-Factors
There are three K-factors:
K-CMH – the amount of client money that HML is holding on behalf of its clients multiplied by 0.4%; and
K-DTF – the daily value of trades that a HML enters through the execution of client orders multiplied by 0.01%
K-NPR (Net Position Risk) – calculated on the non-trading book balance sheet FX exposure of the firm.
K-TCD – the value of the exposures is multiplied based on replacement cost and any add‐ons for potential future exposure,
accounting for the mitigating effects of effective netting and the exchange of collateral.
K-factor figures are broken down in accordance with MIFIDPRU requirements:
K-Factor | Value (£) |
K-CMH | 53,925 |
K-DTF | 11,468 |
K-TCD | 47,569 |
K-NPR | 4378,753 |
Total K-Factor Assessment | 491,715 |
The total K-factor requirement is £491,715.
MIFIDPRU contains details on other K-factors which do not apply to HML.
Meeting the Overall Financial Adequacy Rule
HML must always meet the ‘overall financial adequacy rule’. This rule states that HML must, at all times, hold Own Funds and liquid assets that are adequate, both in their amount and quality, to make sure HML is able to remain financially viable throughout the economic cycle with the ability to address any material potential harm that may result from its ongoing activities. In addition, HML must ensure that it has adequate own funds and liquid assets so that its business can be wound down in an orderly manner, minimising harm to consumers or other market participants.
HML meets this requirement through regular monitoring of:
• the Own Funds held by HML compared with the Own Funds Thresholds calculated according to MIFIDPRU;
• and the liquid assets held by HML compared with the Liquid Assets Thresholds calculated according to MIFIDPRU.
These assessments are dynamic and reflect the evolution of the ‘K’ factors above as well as the assessments of risks explained earlier. However, based on this yearly snapshot, we can see that the Own Funds level of £5,391,778 is in excess of the £1,714,593 Own Funds Threshold level.
Data for the Own Funds Threshold Level is based on final audited accounts dated 31 December 2023.
Level of Own Funds held | Own Funds Threshold | Excess held |
£5,391,778 | £1,714,593 | £3,677,185 |
The equivalent position for liquidity is as follows:
Liquid Assets | Liquid Assets Threshold | Threshold Excess held |
£ 3,813563 | £1,238,288 | £2,575,276 |
Data for Liquid assets held is based on 31 December 2023. Data for the Liquid Assets Threshold is based on final audited accounts dated 31 December 2023.
Remuneration Policies and Practices
Qualitative disclosures
HML’s pay strategy is designed to reward the achievement of long-term sustainable performance and attract and motivate individuals, regardless of gender, ethnicity, age, disability, or any other factor unrelated to performance or experience with HML, while performing their role in the long-term interests of our stakeholders, demonstrating integrity, expertise, commitment, innovation, quality, and passion along the way.
To achieve this objective, effective governance of remuneration practices is of key importance. The design and implementation of remuneration policies and procedures at HML are overseen by the Remuneration Committee to ensure that the employee remuneration process is aligned with the firm’s business performance and strategy. Performance is judged not only on what is achieved over the period but, more importantly, on how it is achieved, as we believe the latter contributes to the long-term sustainability of the business.
Total remuneration, both, fixed and variable, is the key focus of our remuneration framework, with variable pay in the form of annual incentive is differentiated by performance and adherence to HML values.
HML has adopted a top-down approach to its remuneration and only pays bonuses out of risk-adjusted profits. To ensure a risk- and performance-aligned remuneration process, HML uses “bonus pools” that link the variable remuneration of each individual employee with bonus pools and the total amount of variable remuneration at a firm’s level. When determining remuneration pools, awards, and allocations to employees, this allows HML consider and apply performance measures and risk adjustments at various levels, including taking into account all types of current and future risks.
The fixed and variable components of the total remuneration are appropriately balanced. The fixed component represents a sufficiently high proportion of the total remuneration to enable the operation of a fully flexible policy on variable remuneration, including the possibility of paying no variable remuneration component to the employees.
HML’s remuneration strategy is delivered through HML reward system that consists of three key elements:
Key elements | Purpose |
Fixed remuneration | This includes salary. Attract and retain employees by paying market competitive pay for the role, skills and experience required for the business. These payments are fixed and do not vary with performance. |
Variable remuneration | This includes a discretionary annual bonus. Drive and reward performance based on annual financial and non-financial measures consistent with the medium- to long-term strategy, stakeholder interests and adherence to HML values. Awards vary with performance achievement, and we have the discretion to assess the extent to which performance has been achieved. |
Benefits | Ensure market competitiveness. This includes the provision of defined contribution pension scheme allowance and medical insurance. |
Governance Framework and Oversight
As of 31.03.2024, 5 members of staff have been identified as material risk takers (MRT’s) under SYSC 19G.5,:
Member of staff | Primary criterion in SYSC 19G.5.3 R relevant for this MRT. | |
1. | Executive Management | The staff member is a member of the senior management. |
2. | Head of Treasury CASS Oversight | The staff member is a member of the senior management. The staff member is responsible for managing a |
3. | Compliance Oversight Money Laundering Reporting Officer (MLRO) | The staff member has managerial responsibilities for the activities of a control function. The staff member is responsible for managing a material risk within the firm and has managerial responsibilities for the prevention of money laundering and terrorist financing. |
4. | Risk Manager | The staff member is responsible for managing a material risk within the firm. |
5. | Global Head of IT | The staff member works for a firm with permission to carry on regulated activities and is responsible for managing information technology. |
Quantitative disclosures
The total amount of remuneration awarded to all HML staff in 2023 is as follows:
Fixed Remuneration | Variable Remuneration |
1,529,940 | 397,621 |
The total amount of remuneration awarded to senior management and other material risk takers (MRT’s) in 2023 is as follows:
Total amount of remuneration awarded | The fixed remuneration awarded | The variable remuneration awarded | |
Senior management | 454,916 | 374,916 | 80,000 |
Other MRT | 283,898 | 241,898 | 42,000 |
Other staff | 1,188,747 | 913,126 | 275,621 |
Risk Disclosure
Risk Disclosure
This website has been produced by Hantec Markets Limited (‘HML’) which is authorised and regulated by the Financial Conduct Authority [Registration No. 502635].
Warning: demo platform
The virtual funds available via your demo platform allow you to familiarise yourself with our trading platforms, and any gains or losses incurred while trading in a demo environment are not suggestive of results you may achieve when trading on a live platform. Access to your demo platform is only valid for 30 days, which will be terminated thereafter, however you will be able to trade in a live environment once your account has been opened and funded.
Warning: internet trading risks
There are risks associated with using an internet trading system. These include, but are not limited to: error in hardware, software, internet connection or any force majeure (i.e. flood; extraordinary weather condition; earthquake, or other act of God; fire; war; insurrection; riot; labour dispute; accident; action of government; communications or power failure; or equipment or software malfunction). HML or our affiliates (‘we’, ‘our’ or ‘us’) cannot control the signal power, its reception or routing via internet, configuration of your equipment or reliability of its connection. Therefore, we cannot be responsible for any communication failure, distortion or delay (although we will attempt to minimise the possibility of system failure). Please call us immediately if you are unable to access your account and we will execute your orders over the phone. Please note for security reasons you will need to go through our identification process before we accept any orders from you. If we are unable to identify you we will not be able to carry out your orders.
Warning: risks of margin trading
Trading in currency and bullion, particularly margin trading, involves the potential for profit as well as the risk of loss. This may vastly exceed the amount of money you commit to any trade or transaction. Movements in the price of currency or bullion rates are influenced by a variety of factors of global origin, many of which are unpredictable. Violent movements in the price of foreign exchange or bullion rates may result in action by the market. As a result you may be unable to settle adverse trades. Our staff are unable to guarantee the accuracy of any market predictions (should they offer such predictions) and cannot guarantee a maximum loss that you may suffer.
General advice warning
Any general advice provided by us, or on our website, or via our trading platform, does not take into account your financial situation, personal objectives or needs. CFD and currency trading is not suitable to all. We highly recommend you practice risk free on a demo account before investing any funds. You should then consider your objectives, financial situation and needs, and take all reasonable steps to fully understand the possible outcomes of trades and strategies that can be employed.
Copyright
Except where noted otherwise, all material on the website (the “Site”) is our copyright with all rights reserved. No part of the materials on this Site, including but not limited to the text, graphics and html code, may be reproduced or transmitted in any form by any means without our prior written permission.
Your Use of the Site
You may download materials from this Site for non-commercial and personal use only, provided that the intellectual property rights or other proprietary notices remain unchanged and visible. No right or interest in any downloaded materials is transferred to you as a result of any such downloading. You agree that you will not otherwise copy, modify, display, distribute, sell or transmit any material on the Site in any manner without our prior written permission. Furthermore, you shall not, under any circumstances, use the Site for any purpose that is prohibited by these terms and conditions or any applicable laws.This website has been produced by Hantec Markets Limited (‘HML’) which is authorised and regulated by the Financial Conduct Authority [Registration No. 502635].
Appropriateness Warning
The information you provided on your Hantec Markets Limited account application indicates one or more of the following:
- You have less than six months prior experience self-trading margined CFD and Currency products;
- Your annual income is less than $25,000.00 USD (or currency equivalent);
- Your liquid net worth is less than $10,000 USD (or currency equivalent); or
- You are under 21 or over 65 years
We need to inform you that trading in CFD/Currency may not be appropriate for you. Such trading carries a high degree of risk and may result in losses greater than your initial deposit. Hantec Markets Limited provides an execution-only service to its clients and you will need to rely upon your own skill and judgement when trading these markets.
By opening an account with us, we assume that you have read, understood and accepted this warning, you agree that one or more of the below statements apply to you.
Attitude to risk and investment objectives:
- You understand the risks of CFD/Currency trading and you confirm that you have the necessary knowledge and expertise to fully appreciate the risks.
- You understand that CFD/Currency trading is highly leveraged and that you could lose your entire original You are able to assess the risks involved and deem them appropriate for you.
Investing experience and expertise
- You have gained sufficient experience and expertise in dealing in shares and other similar investment instruments, and you understand the complexities of CFD/Currency
- You have attended relevant courses or seminars on CFD/Currency trading that have given you sufficient knowledge and expertise to assess the risks that may arise from.
Hantec Markets Limited offers demo accounts where you can practice trading against realistic Forex prices and we would encourage you to try this before trading with real money.
Conflicts of Interest Policy
Introduction
As a financial institution, Hantec Markets Limited (hereafter “Hantec Markets”) faces actual and potential conflicts of interest from time to time. By identifying the existing and potential conflicts of interest, Hantec Markets will take all sufficient steps to establish, implement and maintain an effective Conflicts of Interest Policy to prevent or mitigate any risk that may damage the interests of our clients.
This statement discloses the conflicts of interest that you, as an existing or potential customer, might face when engaging in business dealings with Hantec Markets; the laws and regulations subject to conflicts of interest that Hantec Markets is required to comply with; and the Policy Hantec Markets adopts for the aim of preventing and managing the conflicts of interest.
Laws and Regulations
The FCA recognises that conflicts of interest exist in the financial services industry and does not aim to eliminate them. Nevertheless, Principle 8 of the FCA’s Principles for Business (PRIN) sets out that a firm must manage conflicts of interest fairly, both between itself and its customers, and between a customer and another customer. Furthermore, within the Senior Management Arrangements, Systems and Controls (SYSC) of the FCA handbook, in particular the SYSC 10, firms are required to manage the conflicts so that they do not damage the customers’ interest. Under the Markets in Financial Instruments Directive (“MiFID II”), Hantec Markets is required to maintain and operate effective organisational and administrative controls to take all appropriate steps to identify, prevent or manage conflicts of interest.
Identification of Conflicts
A conflict of interest may arise where our interests or those of a member of our staff could conflict with a duty we have to a client. Part of staff training in this area is to recognise and remediate or escalate potential conflicts in the course of business. However, to help identify potential conflicts of interest, we have considered a number of areas. The following services and activities have the possibility to give rise to a conflict of interest and potentially, but not necessarily, be detrimental to the interests of our clients:
- Hantec Markets may receive or will receive from a person other than the customer an inducement, other than standard commission or fee in relation to a service provided to the customer;
- Hantec Markets may carry on the same business as the customer;
- Hantec Markets is likely to make a financial gain, or avoid a financial loss, at the expense of the customer;
- Hantec Markets may have a financial or other incentive to favour the interest of another customer(s) over the interests of the customer;
- Hantec Markets may have an interest in the outcome of a service provided to or a transaction carried out on behalf of the customer, which is different from the customer’s interest in that outcome; or
- Hantec Markets may have an interest in maximising trading volumes in order to increase commission revenue, which opposes the client’s objective to minimise transaction costs.
These are general potential conflicts that will be managed in accordance with this Conflicts of Interest Policy. Any additional conflicts will be recorded in the Register of Conflicts of Interest.
Management of Potential Conflicts Identified
Hantec Markets keeps records of the business activities or services carried on by us (or which are carried on our behalf) so that we can identify any conflict that might arise that would have a material risk of damage to the interests of our customers.
Employees are required to report specific potential conflicts of interest in writing to the Compliance department as soon as practicable. To identify the potential conflicts of interest that require reporting, employees take into account whether Hantec Markets or its employee:
- could be in a position where the ability to act in a client’s best interests is potentially affected by any other matter
- is aware of any situation where the interest of one client may conflict with those of another
- is likely to make a profit or avoid a loss at the expense of the client
- has an incentive, financial or otherwise, to favour the interest of one client or group of clients over another;
Trading for Group Companies
Other sister companies within the Hantec group may hold accounts with Hantec Markets. Such accounts will be treated the same as any other client accounts with regard to the priority and execution of orders.
Personal Account Dealing
Hantec Markets has policies and procedures to monitor employees’ personal account dealing. Hantec Markets requires its employees to apply good judgement and act with integrity, taking all appropriate steps to avoid personal Conflicts in their personal account dealings and proactively escalate personal conflicts that do arise.
Best Execution
Hantec Markets’ Execution Policy is created to ensure that when executing orders, Hantec Markets acts in the client’s best interest. This applies irrespective of any potential or existing conflicts of interest and reduces the risk of Hantec Markets acting in favour of itself or a client over another client.
Managing Conflicts of Interest
Hantec Markets maintains a register of the potential conflicts of interests that have been identified. The records contained within the register allow the appropriate management of specific conflicts, whilst information on the management of general type of conflicts of interest is recorded in this Policy.
Review
Hantec Markets is devoted to provide more services and products to meet our customers’ demand. At the same time, Hantec Markets frequently reviews and assesses our conflicts of interest policy so that it can ensure the adequacy of such policy in compliance with our regulatory obligations.
Hantec Markets Policy
As required by law, Hantec Markets implements and maintains an effective Conflicts of Interest Policy for the aim of preventing conflicts of interest or potential conflicts of interest from causing a material risk of damage to the interests of customers.
Hantec Markets’ conflicts of interest policy adopts procedures and measures to manage and control the conflicts of interest identified, including segregation of duties and responsibilities; separate supervision of relevant persons; Personal Account Dealing policy, Gifts and Inducement policy, public interest disclosure policy; acting in the best interest of the clients; and in some cases declining to act for a customer or potential customer. These are also monitored on an ongoing basis within the company’s Compliance Monitoring Programme.
Hantec Markets also maintains and operates effective product governance arrangements to ensure that our products meet the needs of our clients and remain appropriate at all times.
Disclosure
Whilst Hantec Markets is devoted to implement and maintain our conflicts of interest policy, in some cases, such policy might not be sufficient to prevent risks of damage to the interest of a customer. In such a case, as a solution of last resort, Hantec Markets shall disclose the general nature and sources of conflicts of interest to the customer so that enables the customer to make an informed decision whether to proceed with the transaction in question.
Execution Policy
Overview of Best Execution requirement
Hantec Markets Limited is authorised and regulated by the UK Financial Conduct Authority (FCA) and under the FCA rules, we are obliged to act in our clients’ best interests and, other than in certain circumstances described below, where we execute or arrange the execution of orders, we are required to take all sufficient steps to obtain the best possible result for our clients(known as delivering ‘’best execution’’) and to establish and implement an order execution policy and related procedures to allow us to do so.
We have internal policies and procedures governing how we will act when we execute orders for our clients. We continually strive to provide the best possible level of service to all of our clients. Consequently, our policies and procedures are under constant review and may be revised at any time without prior notice.
Execution Venues
We deal with clients as principal and not as agent. This means that we are the execution venue and so clients transact directly with us and not on an exchange or another external market. Trades that clients undertake with us are non-transferable, which means that if a client opens a position with us, they must close the position with us
Execution Factors
We apply the following execution factors:
The Price – While we always aim to act in the best interest of our clients we cannot guarantee that the price at which we permit clients to execute a trade will be better than elsewhere. Prices on leveraged products are sourced from independent third-party providers who supply liquidity to the market.
The Cost – We add a mark-up to the prices from our liquidity providers and publish the ‘’marked-up’’ prices that include our income. We will base the closing price of the relevant instrument for the purposes of margin requirements and any balance credits/debits.
Speed and Likelihood of Execution – Trades may be executed on our platform or by telephone or other forms of communication. Screen and telephone trades are subject to liquidity and market conditions and so we cannot guarantee that a client’s trade will be open or closed instantaneously. The speed and likelihood of execution are also subject to software, hardware and telecom/data line use and we cannot guarantee that this will not be free of interruption of suspension.
Quantity – We set the minimum and maximum quantity that clients may place on a trade. This is influenced by market conditions and firm policy and changes from time to time.
Execution Criteria
When arranging a transaction or executing a client order, we will take into account the following criteria for determining the relative importance of the execution factors referred to above:
- The characteristics of the client including the categorisation of the client as retail, professional or an eligible counterparty;
- The characteristics of the client order; and
- The characteristics of the financial instruments that are the subject of that order.
Dealing with Client Orders
Subject to market conditions a client order will be executed at our price or very close to our price. The price clients receive at execution is not guaranteed as the market may widen, become very volatile or even gap. There is no guarantee that a client’s order will be executed.
Specific Instructions
If clients have any particular requirements as to how we act when dealing with them, then they must let us know and we will do our best to accommodate them. However, clients should be aware that where they give us specific instructions that are incompatible with our normal order execution policies and procedures, their specific instructions will take precedence.
This may result in a different outcome that would have been achieved had our normal policies and procedures been followed and, for Retail Clients and Professional Clients, we will not be required to deliver the best execution in respect of the aspects of a client order which are covered by their specific instructions.
[Our normal policies and procedures take account of the costs that we would incur in transacting business. Transactions may be subject to additional charges. Where this applies, we will notify clients of the applicable charges before their order is executed.]
Our Duty of Best Execution
When executing orders for all the instruments we offer, we will take all sufficient steps to achieve the best possible outcome taking into account our Execution Policy and any specific instructions received from our clients.
Our policy cannot provide a guarantee, however, that the price at which we permit our customers to execute an order will always be better than one which is or might have been available elsewhere.
Achieving ‘Best Execution’
To achieve the best possible result, we will take a number of factors into account, including price, costs, speed of execution, the likelihood of execution and settlement, size, nature of the order or any other factors relevant to the execution of that order.
We will use our own commercial experience and judgment in determining the relative importance of these factors, however, we have rated prices as the most important factor for obtaining the best possible result.
If we have classified a client as a Professional Client we will consider relevant FCA guidance to determine whether they are relying on us to deliver the best execution. We understand that clients may be relying upon us to deliver the best execution but the importance of execution may take precedence over price.
If we have classified a client as an Eligible Counterparty, there is no requirement under the FCA rules for us to deliver the best execution to them. However, we will comply with this policy in relation to Eligible Counterparty Business and maintain records of data which are used to set our prices.
We will review this policy at regular intervals and will monitor and review external pricing sources.
We will give clients 14 days written notice where we make any change to this policy and the client disclosure relating to this policy on our website.
Scalping Policy
Scalping is a form of trading which we consider to be an unacceptable practice and a type of market abuse. Scalping might be wrongfully used to return profits by taking advantage of internet latencies, delayed prices, off market/bad prices or through high volumes of transactions targeting tick fluctuations (rather than price movements) where trades are opened and closed very quickly.
If, in our sole discretion, we consider you to have partaken in this form of scalping, it will be considered as a breach of our Terms and Conditions and as such we reserve the right to:
- Make immediate changes to your account, including but not limited to, the liquidity provided by us and the spread quoted.
- Immediately terminate your account and your access to our servers.
- Void any trade (i.e., treat the trade as if the trade had never taken place) which was part of any Scalping activity.
- Close any trade, which was part of any Scalping activity, on the basis of our current market price.
We can exercise the above rights even if you have entered into (or refrained from entering into) such arrangements with third parties relating to the relevant trade and even if you may suffer a trading loss as a result.
Please be advised that all trading activity is monitored closely, and in the event it is identified that you are Scalping we reserve the right to close your account with immediate effect.
Treating Customers Fairly
This statement details Hantec Markets Limited’s policy with regard to FCA Principle 6: “A firm must pay due regard to the interests of its customers and treat them fairly”.
The fair treatment of customers is one of the key principles of the Financial Conduct Authority in the UK. The FCA requires firms to be able to demonstrate that they are consistently treating their customers fairly. At Hantec Markets the Directors and Senior Management are committed to ensuring that the FCA principle of Treating Customers Fairly (TCF) is applied in all aspects of our business activities.
We recognise that fair treatment of our customers is about adding value to the service we offer. To ensure that we are continuously providing our customers with a valuable service we aspire to:
- protect the interests of our customers in all areas of our dealings with them and at each stage of the product life cycle, from promotion right through to after-sales service
- meet the needs of each customer by offering a transparent and professional service, and to constantly review our service to identify areas where we can improve it
Our Commitment to you
- To ensure the products that we offer are appropriate for you and are consistent with your needs;
- To provide timely and best execution at all times;
- To maintain a superior level of system and platform availability;
- To ensure all staff implement TCF in their daily business activities;
- To ensure your complaints are assessed fairly and impartially and handled professionally should you ever become unhappy with our service;
- To encourage staff to recommend improvements to service following customer complaints;
- To ensure that promotional material is clear, compliant and appropriately targeted ;
- To provide accurate, complete and timely communications;
- To ask for and listen to your feedback and place your interests first.
Cookies
We respect your privacy and are committed to full transparency about what cookies that are enabled on our site and how you can easily manage these.
What are Cookies?
Cookies are tiny pieces of information stored as text files on your computer or device when you visit certain web pages. They are used by web developers to help users navigate their websites efficiently. Cookies do not harm your computer or device. They are not programmes, cannot execute code, deliver viruses or extract personal information from your computer.
If you have cookies enabled on your browser, a cookie will be stored on the device, on each subsequent page you visit, and sent back to the web server by the browser. Cookies are designed to hold a very small amount of data specific to a user and the website they are using.
Hantec Markets do not store any identifiable personal information within cookies such as credit card or bank details.
Most sites on the internet use cookies and their purpose is to:
- verify your identity for security reasons and block abusing user
- determine what browser you are using and its settings to display content correctly
- allow the site owners and third-party advertisers to modify content according to your preference
Hantec Markets’ Cookies Policy
We are using three types of cookies on our site:
- Functional Cookies are required for the smooth running of the website. If these are disabled you won’t be able to access key pages of the site
- Analytical and Performance Cookies collect anonymous information about how visitors use the site. They help us understand your preferences so we can offer you a better
- Marketing Cookies collect information about your browsing habits in order to present you with more relevant content and adverts based on your browsing activity.
These cookies are essential for the proper functioning of the website. They allow the website to remember choices you make while browsing the site such as your language preferences. They remember user choices and enable the personalisation of content. These cookies are anonymous and do not track your browsing activity on other websites. If they are disabled you won’t be able to access key pages of the site.
Type of Cookie | Source of Cookie | Function |
---|---|---|
Referral ID | Hantec Markets | Identifies the referral ID, and allows the website to determine if the registering clients came from a referral. |
Campaign | Hantec Markets | Allows the website to determine if the registering clients should be under a campaign. |
IP Address | Hantec Markets | It identifies the client’s IP Address, and allows the website to determine the location country. |
Country | Hantec Markets | Identifies the client’s location country, and allows the website to display the appropriate content to the client. |
Country Code (2-ISO) | Hantec Markets | Identifies the client’s location country code, and allows the website to display the appropriate content to the client. |
Chatra Functional | Third Party | This is used to support our Live Chat function. A random token is assigned to each user. No personal data is recorded. |
Analytical and Performance Cookies
These cookies collect anonymous information about how visitors use the site. These cookies do not collect information that identifies you. All collected information is aggregated and as such completely anonymous. Their unique purpose is to help us understand user preferences and their interests so we can offer a better browsing experience.
Some of the systems we use to track web traffic and site usage are provided by third-party companies such as Google.
Type of Cookie | Source of Cookie | Function |
---|---|---|
Google Analytics | Third Party | Registers a unique ID that is used to generate statistical data on how the visitor uses the website. |
Google Analytics Throttle | Third Party | Used by Google Analytics to throttle request rate. |
Marketing Cookies
The purpose of this type of cookie is to collect information about your browsing habits to provide advertising that is more relevant to you. The cookies remember which websites you have visited and are usually placed by third party companies with our permission. They serve to limit the number of times you see the same advertisement as well as to measure the effectiveness of advertising campaigns.
Type of Cookie | Source of Cookie | Function |
---|---|---|
Google Analytics | Third Party | Used to send data to Google Analytics about the visitor’s device and behaviour. Tracks the visitor across devices and marketing channels. |
Facebook Ads | Third Party | Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers. |
Facebook Impression | Third Party | Used by Facebook to register impression on pages with the Facebook login button. |
Facebook Pixel | Third Party | Used by Facebook to see how many people take action on ads and which Facebook Ad led to a conversion. |
Third Party | Used by the social networking service, LinkedIn, for tracking the use of embedded services. | |
Third Party | Used by the social networking service, Twitter, for tracking the use of embedded services. |
Cookie Management
Cookies Management
You can manage cookies by modifying your web browser settings on your computer or tablet. For mobile phones you might have to check you phone user guide.
Google Chrome
- Click the menu icon in the browser’s toolbar
- Select ‘Settings’
- Click ‘Show advanced settings’
- Choose ‘Privacy’ and then ‘Content settings’
- To enable cookies, in the ‘Cookies’ section, tick ‘Allow local data to be set (recommended)’. This option enables both first and third-party cookies.
- To allow only first-party cookies, enable ‘Block all third-party cookies without exception’
- To disable cookies, select ‘Block sites from setting any data’
There are several levels of cookie activation in Chrome. To find out more, click here.
Mozilla Firefox
- Click on the menu button at the top of the browser (or ‘Tools’ if using Windows XP)
- Select ‘Options’
- Click ‘Privacy’
- Set ‘Firefox will’ to ‘Use custom settings for history’
- Select ‘Accept cookies from sites’ and your preferred treatment of third-party cookies
- To disable cookies, remove the check mark from ‘Accept cookies from sites’
- Click ‘OK’ to close the window
There are several levels of cookie activation in Firefox. For more information, click here.
Opera
- In the browser’s menu, select ‘Settings’
- Under cookies, tick ‘Allow local data to be set (recommended)’
- To disable cookies, select ‘Block sites from setting any data’
- To stop only third-party cookies, select ‘Block third-party cookies and site data’
There are several levels of cookie activation in Opera. For more information, click here.
Safari
- In the menu bar, select ‘Safari’, then choose ‘Preferences’
- Click on ‘Privacy’
- Under ‘Cookies and website data:’, select ‘Allow from the websites I visit’
- To disable cookies, select ‘Always block’
There are several levels of cookie activation in Safari. For more information, click here.
Microsoft Internet Explorer
Versions 9-11
- Select ‘Tools’ from the top of your browser
- Choose ‘Internet Options’
- Navigate to the ‘Privacy’ tab
- Click ‘Advanced’. Here you can choose to ‘Accept’ ‘Block’ or ‘Prompt’ both first and third-party cookies
- To disable cookies, tick ‘Block’
There are several levels of cookie activation in Internet Explorer. For more information, click here.
Microsoft Edge
- Click the menu button
- Choose ‘Settings’ and then ‘View advanced settings’
- Under ‘Cookies’ choose either ‘Don’t block cookies’ or ‘Block only third party cookies’
- To disable cookies, click on ‘Block all cookies’
There are several levels of cookie activation in Microsoft Edge. For more information, click here.
If you have any questions regarding our privacy policy or security measures, please email info-mu@hmarkets.mu.
This website uses cookies. We use cookies to personalise content and improve our services, to provide social media features and to analyse our traffic. We process this information about use of our site with our analytics partners who may combine it with other information that you’ve provided to better our services. You consent to our cookies if you continue to use our website. For more information visit the Cookie page and read our updated Privacy Notice. To change your settings, visit the Cookies Management page.
Cookies are small text files that can be used by websites to make a user’s experience more efficient.
Youtube API services
YouTube Terms of Service here
Cookies
We respect your privacy and are committed to full transparency about what cookies that are enabled on our site and how you can easily manage these.
What are Cookies?
Cookies are tiny pieces of information stored as text files on your computer or device when you visit certain web pages. They are used by web developers to help users navigate their websites efficiently. Cookies do not harm your computer or device. They are not programmes, cannot execute code, deliver viruses or extract personal information from your computer.
If you have cookies enabled on your browser, a cookie will be stored on the device, on each subsequent page you visit, and sent back to the web server by the browser. Cookies are designed to hold a very small amount of data specific to a user and the website they are using.
Hantec Markets do not store any identifiable personal information within cookies such as credit card or bank details.
Most sites on the internet use cookies and their purpose is to:
- verify your identity for security reasons and block abusing user
- determine what browser you are using and its settings to display content correctly
- allow the site owners and third-party advertisers to modify content according to your preference
Hantec Markets’ Cookies Policy
We are using three types of cookies on our site:
- Functional Cookies are required for the smooth running of the website. If these are disabled you won’t be able to access key pages of the site
- Analytical and Performance Cookies collect anonymous information about how visitors use the site. They help us understand your preferences so we can offer you a better
- Marketing Cookies collect information about your browsing habits in order to present you with more relevant content and adverts based on your browsing activity.
These cookies are essential for the proper functioning of the website. They allow the website to remember choices you make while browsing the site such as your language preferences. They remember user choices and enable the personalisation of content. These cookies are anonymous and do not track your browsing activity on other websites. If they are disabled you won’t be able to access key pages of the site.
Type of Cookie | Source of Cookie | Function |
---|---|---|
Referral ID | Hantec Markets | Identifies the referral ID, and allows the website to determine if the registering clients came from a referral. |
Campaign | Hantec Markets | Allows the website to determine if the registering clients should be under a campaign. |
IP Address | Hantec Markets | It identifies the client’s IP Address, and allows the website to determine the location country. |
Country | Hantec Markets | Identifies the client’s location country, and allows the website to display the appropriate content to the client. |
Country Code (2-ISO) | Hantec Markets | Identifies the client’s location country code, and allows the website to display the appropriate content to the client. |
Chatra Functional | Third Party | This is used to support our Live Chat function. A random token is assigned to each user. No personal data is recorded. |
Analytical and Performance Cookies
These cookies collect anonymous information about how visitors use the site. These cookies do not collect information that identifies you. All collected information is aggregated and as such completely anonymous. Their unique purpose is to help us understand user preferences and their interests so we can offer a better browsing experience.
Some of the systems we use to track web traffic and site usage are provided by third-party companies such as Google.
Type of Cookie | Source of Cookie | Function |
---|---|---|
Google Analytics | Third Party | Registers a unique ID that is used to generate statistical data on how the visitor uses the website. |
Google Analytics Throttle | Third Party | Used by Google Analytics to throttle request rate. |
Marketing Cookies
The purpose of this type of cookie is to collect information about your browsing habits to provide advertising that is more relevant to you. The cookies remember which websites you have visited and are usually placed by third party companies with our permission. They serve to limit the number of times you see the same advertisement as well as to measure the effectiveness of advertising campaigns.
Type of Cookie | Source of Cookie | Function |
---|---|---|
Google Analytics | Third Party | Used to send data to Google Analytics about the visitor’s device and behaviour. Tracks the visitor across devices and marketing channels. |
Facebook Ads | Third Party | Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers. |
Facebook Impression | Third Party | Used by Facebook to register impression on pages with the Facebook login button. |
Facebook Pixel | Third Party | Used by Facebook to see how many people take action on ads and which Facebook Ad led to a conversion. |
Third Party | Used by the social networking service, LinkedIn, for tracking the use of embedded services. | |
Third Party | Used by the social networking service, Twitter, for tracking the use of embedded services. |
Cookie Management
Cookies Management
You can manage cookies by modifying your web browser settings on your computer or tablet. For mobile phones you might have to check you phone user guide.
Google Chrome
- Click the menu icon in the browser’s toolbar
- Select ‘Settings’
- Click ‘Show advanced settings’
- Choose ‘Privacy’ and then ‘Content settings’
- To enable cookies, in the ‘Cookies’ section, tick ‘Allow local data to be set (recommended)’. This option enables both first and third-party cookies.
- To allow only first-party cookies, enable ‘Block all third-party cookies without exception’
- To disable cookies, select ‘Block sites from setting any data’
There are several levels of cookie activation in Chrome. To find out more, click here.
Mozilla Firefox
- Click on the menu button at the top of the browser (or ‘Tools’ if using Windows XP)
- Select ‘Options’
- Click ‘Privacy’
- Set ‘Firefox will’ to ‘Use custom settings for history’
- Select ‘Accept cookies from sites’ and your preferred treatment of third-party cookies
- To disable cookies, remove the check mark from ‘Accept cookies from sites’
- Click ‘OK’ to close the window
There are several levels of cookie activation in Firefox. For more information, click here.
Opera
- In the browser’s menu, select ‘Settings’
- Under cookies, tick ‘Allow local data to be set (recommended)’
- To disable cookies, select ‘Block sites from setting any data’
- To stop only third-party cookies, select ‘Block third-party cookies and site data’
There are several levels of cookie activation in Opera. For more information, click here.
Safari
- In the menu bar, select ‘Safari’, then choose ‘Preferences’
- Click on ‘Privacy’
- Under ‘Cookies and website data:’, select ‘Allow from the websites I visit’
- To disable cookies, select ‘Always block’
There are several levels of cookie activation in Safari. For more information, click here.
Microsoft Internet Explorer
Versions 9-11
- Select ‘Tools’ from the top of your browser
- Choose ‘Internet Options’
- Navigate to the ‘Privacy’ tab
- Click ‘Advanced’. Here you can choose to ‘Accept’ ‘Block’ or ‘Prompt’ both first and third-party cookies
- To disable cookies, tick ‘Block’
There are several levels of cookie activation in Internet Explorer. For more information, click here.
Microsoft Edge
- Click the menu button
- Choose ‘Settings’ and then ‘View advanced settings’
- Under ‘Cookies’ choose either ‘Don’t block cookies’ or ‘Block only third party cookies’
- To disable cookies, click on ‘Block all cookies’
There are several levels of cookie activation in Microsoft Edge. For more information, click here.
You can also visit independent information providers such as www.allaboutcookies.org. It is possible to simply block third-party cookies.
If you have any questions regarding our privacy policy or security measures, please email info-mu@hmarkets.mu.
This website uses cookies. We use cookies to personalise content and improve our services, to provide social media features and to analyse our traffic. We process this information about use of our site with our analytics partners who may combine it with other information that you’ve provided to better our services. You consent to our cookies if you continue to use our website. For more information visit the Cookie page and read our updated Privacy Notice. To change your settings, visit the Cookies Management page.
Cookies are small text files that can be used by websites to make a user’s experience more efficient.
YouTube API services
YouTube Terms of Service here