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Personal Trading Policy

Effective Date: 01/04/2025

1. Purpose

ZenithWave Capital Limited is committed to maintaining market integrity and ensuring that employees engage in ethical and compliant trading practices. This policy outlines the guidelines for personal trading to prevent conflicts of interest, insider trading, and market abuse.

2. Scope

This policy applies to:

  • All employees, contractors, and affiliates of ZenithWave Capital Limited.
  • Any personal trading activities conducted in financial markets, including stocks, forex, cryptocurrencies, commodities, and derivatives.

3. Compliance with Regulations

Employees must comply with relevant laws and regulations, including:

  • Markets in Financial Instruments Directive (MiFID II)
  • Financial Conduct Authority (FCA) regulations
  • UK insider trading and market abuse laws

Any trading activity that could create a conflict of interest with ZenithWave Capital Limited is strictly prohibited.

4. Pre-Approval for Personal Trades

Employees must obtain written pre-approval from the Compliance Officer before executing personal trades in:

  • Any securities related to company investments, clients, or partners.
  • High-risk or speculative assets that may impact market integrity.

Pre-approval requests must include trade details, rationale, and potential conflicts.

5. Prohibited Trading Activities

  • Insider Trading: Using material, non-public information for personal financial gain.
  • Front-Running: Placing personal trades ahead of client or company orders.
  • Market Manipulation: Engaging in activities that artificially impact asset prices.
  • Trading Restricted Securities: Dealing in securities listed on the company’s Restricted Trading List, which includes assets linked to company operations.

6. Reporting and Monitoring

  • Employees must disclose all personal trading accounts to the Compliance Officer.
  • The company reserves the right to monitor trading activities to ensure compliance.
  • Employees must submit quarterly reports of all trading activities for review.

7. Violations and Consequences

Any violation of this policy may result in disciplinary action, including:

  • Formal warnings
  • Suspension or termination of employment
  • Regulatory reporting and legal consequences
  • Severe violations (e.g., insider trading) may lead to criminal prosecution and financial penalties.

8. Policy Review

This policy will be reviewed annually to ensure alignment with regulatory updates and company operations.