Conflicts of interest occur where, the interest of the Firm (or another company with which the Firm is associated), and/or the interests of the Firm’s staff, are in conflict with the interests of one or more customers. A conflict of interest can also arise between the Firm and its employees.

There are various instances where a conflict of interest may occur. Conflicts could be between various persons, such as:

• The Firm and the customer;
• One customer and another customer;
• An employee of the Firm and a customer;
• An employee and the Firm.

Below are some examples of situations that may cause conflicts of interest to materialise, where the Firm:

• would make a financial gain, or avoid a financial loss, at the expense of a customer;
• has an interest in the outcome of a service provided to the customer or of a transaction carried out on behalf of the customer, which is distinct from the customer’s interest in that outcome
• holds knowledge in confidence for one customer which would benefit another;
• has a financial or other incentive to favour the interest of another customer or group of customers over the interests of the customer;
• may be remunerated in a way which encourages it to act against its customers’ interests; and
• receives or will receive from a person other than the customer (including any Lightyear group company) an inducement in relation to a service provided to the customer, in the form of monies, goods or services, other than the standard commission or fee for that service.

We may use a group company to provide certain services to you, such as acting as your custodian or broker. For example, Lightyear Europe AS may use Lightyear U.K. Ltd (a UK group company) or other affiliates to facilitate the execution and clearing of certain trades or the safekeeping of assets. This relationship is managed to ensure that your interests remain protected and that any potential conflicts arising from this intra-group arrangement are identified and mitigated in accordance with this policy.

As per applicable regulations, we take all appropriate and reasonable steps to prevent and manage conflicts of interest. In order to achieve this, the Firm maintains and operates effective organisational and administrative arrangements with a view to taking all reasonable and appropriate steps to prevent and manage conflicts of interest in order to prevent them from adversely affecting the interests of our customers.

If the Firm’s arrangements to manage a potential conflict of interest are not sufficient to ensure with reasonable confidence that the risk of damage to a customer’s interests is prevented, the Firm will disclose the conflict to the customer. The Firm may decline to act in situations where conflicts of interest are unavoidable.

The Firm executes your orders according to our Best Execution and Order Handling Policy.

For order execution services where a group company is used as broker or custodian, we do not receive any additional monetary benefits from this beyond declared execution fees and will execute such orders at prevailing market prices so that the interests of one party do not take precedence over those of the other.

The Firm does not receive any benefit (monetary or otherwise) from any trade execution venues or third-party crypto-assets service provider in return for executing or sending the Firm’s customers’ orders for execution to them.

In relation to crypto-assets, client orders are routed to a third-party provider which also holds clients' crypto-assets. While the provider may source liquidity from multiple venues, execution through a single provider may in certain circumstances limit the ability to obtain the best possible price. We mitigate this through ongoing monitoring of the provider.

The Firm will be providing services to customers in relation to financial instruments made available on Lightyear App. Those services include reception and transmission of orders in relation to Instruments, execution of orders on behalf of customers, safekeeping and administration of financial instruments for the account of clients, and foreign exchange services where these are connected to the provision of investment services. We provide our services on an execution-only basis. This means that our services are non-advised and so we will not provide the customer with any advice of any kind, nor will we provide a view as to whether a particular Instrument is suitable for the customer.

The Instruments that can be purchased or sold through the Lightyear App may change from time to time.

Staff at the Firm are unable to accept gifts that surpass a specified threshold. Additionally, any gifts received by staff will be recorded by the Firm.

If you need to get in touch with the Firm about anything, you can email us at support@lightyear.com. We do not currently offer a dedicated phone helpline.