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Fair Trading and Market Conduct Policy

Effective Date: 14/02/2025
Last Updated: 01/04/2025

1. Purpose

ZenithWave Capital Limited is committed to upholding the highest standards of integrity, transparency, and fairness in all trading activities. This policy sets out the principles and expectations for ethical trading practices, ensuring compliance with financial regulations and protecting the integrity of the markets in which we operate.

2. Scope

This policy applies to:

  • All employees, traders, contractors, and partners of ZenithWave Capital Limited.
  • Any individual engaged in proprietary trading, fund management, or investment activities on behalf of the company.

3. Principles of Fair Trading

3.1 Market Integrity

  • Employees and traders must act with honesty and fairness to ensure a fair and efficient market.
  • Any action that creates a false or misleading impression of supply, demand, or price is strictly prohibited.

3.2 Prohibition of Market Manipulation

The following practices are prohibited:

  • Spoofing: Placing and canceling large orders with no intention of execution to mislead the market.
  • Front Running: Trading in advance of client orders for personal gain.
  • Wash Trading: Buying and selling the same financial instrument to create false trading volume.
  • Insider Trading: Using non-public, material information to trade or influence market decisions.

3.3 Ethical Trading Practices

  • Employees and traders must always prioritize clients' and investors' interests over personal gain.
  • Any conflicts of interest must be disclosed to the compliance department.
  • Trading strategies must comply with all applicable financial regulations.

4. Compliance with Regulatory Requirements

  • All trading activities must comply with relevant market regulations, including the Financial Conduct Authority (FCA) guidelines and MiFID II requirements.
  • Employees and traders must maintain accurate trading records and report any suspicious activities.

5. Reporting Violations

  • Any suspected breaches of this policy must be reported immediately to the Compliance Officer or the designated authority.
  • The company will investigate all reports confidentially and take necessary corrective actions.
  • Retaliation against individuals who report violations in good faith is strictly prohibited.

6. Disciplinary Actions

Any violations of this policy will result in disciplinary action, including termination of employment or trading privileges. Severe breaches may lead to legal prosecution and regulatory penalties.

7. Review and Updates

This policy will be reviewed annually to ensure compliance with evolving market regulations.