INTRODUCTION

• We are Wealthyhood Europe AEPEY, an investment services company incorporated in Greece (company number 178577960000) with its registered address at Solonos 60, 10672, Athens, Greece (“we”, “us”, “our” or “Wealthyhood”).
• Wealthyhood is authorised and regulated by the Hellenic Capital Markets Commission (HCMC) as an investment firm (“AEPEY” or “Investment Services SA”) under activity licence number 3/1014.
• When undertaking its services, Wealthyhood always acts in the client’s best interests and puts their interests ahead of its own. However, conflicts of interest are inevitable while providing services to customers.
• In line with our commitment to uphold the highest ethical standards and maintain full transparency in our business practices, we have implemented systems and processes designed to identify, prevent, and manage any conflicts of interest that may arise while delivering services to our customers.

WHAT IS A CONFLICT OF INTEREST

• A conflict of interest occurs when the interests of Wealthyhood, its employees, or any parties associated with Wealthyhood, are in competition with the interests of one or more customers. This can also include conflicts between employees and the firm itself. Essentially, conflicts arise when an individual or organisation stands to benefit—financially or otherwise—in a way that could harm or disadvantage a customer.
• Conflicts of interest may occur in various relationships, including:
  • (a) Wealthyhood and a customer;
  • (b) One customer and another customer;
  • (c) An employee of Wealthyhood and a customer;
  • (d) An employee and Wealthyhood.
• Examples of conflicts of interest include situations where:
  • (a) Wealthyhood might make a financial gain or avoid a financial loss at the expense of a customer.
  • (b) Wealthyhood has an interest in the outcome of a service or transaction that differs from the customer’s interest.
  • (c) Confidential information held for one customer could benefit another.
  • (d) Wealthyhood has a financial or other incentive to favor the interests of one customer - or group of customers over another.
  • (e) Employees are remunerated in ways that could encourage actions against the customers’ best interests.
  • (f) Wealthyhood or its employees receive benefits from third parties that could influence services provided to customers.
• Identifying and managing these conflicts is crucial to ensure fairness and maintain the trust of Wealthyhood's customers.

PREVENTING & MANAGING CONFLICTS

• At Wealthyhood, we take proactive steps to prevent and manage conflicts of interest to ensure that our customers’ interests are always prioritised. Our approach involves a combination of well-thought-out design, robust policies, and transparent processes.
• Firstly, our commitment to customers begins with how we design and build our products. From the outset, we strive to create solutions that minimise the possibility of conflicts of interest. Every aspect of our product and operations is developed with the customer’s best interest in mind, ensuring that potential conflicts are avoided wherever possible.
• Secondly, we have established comprehensive policies and procedures to identify, manage, and mitigate conflicts of interest. Our goal is to handle these conflicts in a fair, equitable, and transparent manner, always adhering to the best interests of our customers.
• Specifically:
  • (a) We actively avoid conflicts that are prohibited by law, as well as those that cannot be effectively managed.
  • (b) For conflicts that can be managed, we implement strict internal controls and review processes. This ensures that conflicts are handled in a way that prevents them from negatively impacting our customers.
  • (c) In certain situations, we will inform our customers of conflicts of interest that may affect them, providing them with the necessary information to assess the significance of these conflicts before proceeding with our services.
• We maintain detailed records of all identified conflicts of interest. These records allow us to continuously monitor and manage any conflicts that may arise, ensuring that appropriate measures are taken to prevent any harm to our customers. In cases where we are unable to implement sufficient controls to mitigate risks, we will disclose the conflict to the customer before proceeding with any business on their behalf.
• As part of our commitment to regulatory compliance, we ensure that our organisational and administrative arrangements are effective in preventing and managing conflicts of interest. If we are ever in a position where we cannot confidently manage a conflict to prevent customer harm, we will disclose the conflict.
• In some cases, we may choose to refrain from acting if a conflict is unavoidable and cannot be adequately addressed.
• Through these measures, we aim to safeguard the trust and confidence our customers place in us, ensuring that their interests are always at the forefront of our decision-making.

ORDER HANDLING & BEST EXECUTION

• At Wealthyhood, we execute all customer orders in strict accordance with our Order Handling & Best Execution Policy. Our primary focus is on delivering the best possible outcomes for our customers, ensuring fairness and transparency in every transaction.
• Wealthyhood does not receive any financial or non-financial benefits from trade execution venues or counterparties in exchange for directing customer orders to them. This practice, known as ‘payment for order flow,’ is prohibited in our operations. We are committed to selecting trade execution venues purely based on what is best for our customers, ensuring that all decisions are made without external incentives.
• We ensure that every order is executed with the highest standards, taking into account factors such as price, speed, and likelihood of execution. Our obligation is to act in our customers' best interests, making sure that their orders are handled promptly, fairly, and in line with market best practices.
• Wealthyhood does not engage in proprietary trading or trading on its own account, ensuring that no conflicts of interest arise between the firm and its customers. Our chosen third-party brokers are fully independent and we do not have any associations with these brokers beyond the services they provide.

INVESTMENTS OFFERED

• At Wealthyhood, we offer a range of financial products, including stocks, ETFs, and funds, all of which are traded on recognised trading venues. Our services are provided on an execution-only basis, meaning that we do not offer advice or recommendations regarding the suitability of any investment for individual customers. Our role is to execute your orders efficiently and transparently.
• Wealthyhood does not receive any financial or non-financial incentives from the issuers of the investments we offer or from any party acting on their behalf. This ensures that the products we provide are selected purely based on their merit and potential value to our customers, not because of external incentives.
• We offer a variety of financial instruments, such as stocks and ETFs, that are accessible through our platform. These instruments may change over time to reflect market developments and customer needs, but our commitment to offering a wide selection of quality investments remains constant.
• Our investment services are non-advised, meaning that we do not provide opinions on whether a particular investment is suitable for you. We ensure that your orders are executed efficiently, but the decision of which investments to choose remains entirely with you.

GIFTS & HOSPITALITY

• We have strict policies regarding gifts and hospitality to ensure that our employees always act in the best interests of our customers and to avoid any potential conflicts of interest.
• We enforce a clear threshold on the value of gifts that may be accepted by our employees, and anything exceeding this limit is strictly prohibited.
• Any gifts received by employees, regardless of their value, must be promptly recorded and reported to the firm. This allows us to monitor and ensure that all gifts are managed transparently and that no conflicts arise between the interests of employees and customers.

PERSONAL ACCOUNT DEALING

• Wealthyhood has robust policies and procedures in place to monitor and manage the personal trading activities of all employees, ensuring that any personal transactions are aligned with our commitment to fairness and transparency.

CONTACT US

• If you need to get in touch with Wealthyhood for any reason, our team is available via email at hello@wealthyhood.com.