Conflict of Interest Policy

Effective Date: 01/04/2025
Company Name: ZenithWave Capital Limited
Registered Address: Southbridge House, Southbridge Place, Croydon, CR0 4HA

1. Purpose

The purpose of this policy is to ensure that no conflict of interest arises within ZenithWave Capital Limited, particularly in relation to our educational and trader funding programs. We are committed to maintaining the highest standards of integrity, impartiality, transparency, and fairness in all aspects of our operations.

2. Avoidance of Conflicts

At ZenithWave Capital, we are dedicated to proactively preventing any situation where a conflict of interest may occur. This includes ensuring that family members, friends, or close associates of our educators, mentors, or assessors do not receive preferential treatment in our programs.

In the event that such a relationship exists, appropriate safeguards such as separation of roles and independent oversight will be applied. Our Internal Quality Assurance (IQA) team ensures that no special privileges are granted to any individual.

3. Separation of Roles

If a student is related to or has a close personal connection with any educator, mentor, or assessor, an alternative staff member will be assigned to evaluate the student’s assessments, trading performance, and progression. This practice is designed to eliminate any potential bias or preferential treatment and to uphold the fairness and credibility of the evaluation and funding process.

4. Impartiality of the IQA

Our Internal Quality Assurance (IQA) personnel operate from a separate location and are structurally and professionally independent from the training and mentoring teams. This setup ensures maximum objectivity and impartial oversight.

The IQA team is responsible for conducting weekly audits of student progress, assessment decisions, and funded trading evaluations. This helps ensure that our standards of transparency, fairness, and consistency are maintained across all programs.

5. Reporting & Disclosure

All employees, mentors, and partners must disclose any potential conflicts of interest—whether personal, financial, or relational—to the Compliance Team at support@zenithwavecapital.com.

If a conflict is identified, the company will determine the appropriate measures to mitigate risk, including reassigning responsibilities or removing the individual from decision-making processes.

6. Responsibilities

6.1 Employees, Mentors & Assessors

• Avoid situations that could result in a conflict of interest.
• Promptly disclose any actual or perceived conflicts.
• Cooperate with any internal review or inquiry.

6.2 Compliance & Management

• Enforce this policy through monitoring and internal reviews.
• Provide guidance and training to staff on how to identify and handle potential conflicts.
• Take appropriate action in cases of policy violations.

7. Consequences

Any breach of this policy may result in disciplinary action, including suspension from duties or termination of engagement. All reports are treated confidentially and investigated thoroughly.

8. Policy Review

This policy will be reviewed annually and updated as required to reflect changes in company operations or regulatory expectations.