INTRODUCTION

• We are Wealthyhood Europe AEPEY, an investment services company incorporated under the laws of Greece (business registry 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 clients.
• 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 clients.
• Without limitation to the above, Wealthyhood has implemented organisational and administrative arrangements designed to prevent conflicts of interest from adversely affecting the interests of its clients, including, as appropriate:
  • (a) the segregation of duties and responsibilities between relevant functions;
  • (b) information barriers and access controls to prevent the inappropriate exchange of confidential information;
  • (c) escalation and decision making procedures for the identification and management of conflicts of interest; and
  • (d) independent oversight by the Compliance Function.
• These arrangements are proportionate to the nature, scale and complexity of Wealthyhood’s business and are subject to periodic review.

WHAT IS A CONFLICT OF INTEREST

• A conflict of interest occurs when the interests of Wealthyhood, its managers, directors and employees, or any parties associated with Wealthyhood, are in competition with the interests of one or more clients. This can also include conflicts between “Relevant Persons”, as this term is specified pursuant to the of Decision 2/452/01.11.2007 of the Board of Directors of the Hellenic Capital Market Commission and the Delegated Regulation (EU) 2017/565, and the firm itself. For the purposes of this Policy, “Relevant Persons” include directors, managers, employees and any other persons whose services are placed at the disposal and under the control of Wealthyhood and who are involved in the provision of investment services or activities. Essentially, conflicts arise when an individual or organisation stands to benefit - financially or otherwise - in a way that could harm or disadvantage a client.
• Conflicts of interest may occur in various relationships, including:
  • (a) Wealthyhood and a client;
  • (b) One client and another client;
  • (c) A Relevant Person of Wealthyhood and a client;
  • (d) A Relevant Person 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 client;
  • (b) Wealthyhood has an interest in the outcome of a service or transaction that differs from the client’s interest;
  • (c) Confidential information held for one client could benefit another client;
  • (d) Wealthyhood has a financial or other incentive to favor the interests of one client or group of clients over another;
  • (e) A Relevant Person is remunerated in ways that could encourage actions against the clients’ best interests;
  • (f) Wealthyhood or its Relevant Persons receive benefits from third parties that could influence services provided to clients.
• Identifying and managing these conflicts is crucial to ensure fairness and maintain the trust of Wealthyhood's clients.

PREVENTING & MANAGING CONFLICTS

• At Wealthyhood, we take proactive steps to prevent and manage conflicts of interest to ensure that our clients’ interests are always prioritised. Our approach involves a combination of well-thought-out design, robust policies, and transparent processes.
• Firstly, our commitment to clients 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 client’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 clients.
• 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 clients.
  • (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.
• Wealthyhood evaluates and reviews the conflict of interest policies and procedures periodically, at least on an annual basis, and takes appropriate measures to address any identified deficiencies, assessing whether Wealthyhood’s services have relied excessively on the disclosure of conflicts of interest to clients.
• All of our employees are required to carefully examine and fully understand our policies and practices regarding conflicts of interest.
• At Wealthyhood, we maintain detailed records of all identified or potential conflicts of interest, the services or activities affected, the measures adopted to manage such conflicts, and the outcome of any escalation. These records are maintained by the Compliance Function and reviewed periodically. They allow us to continuously monitor and manage any conflicts that may arise, ensuring that appropriate measures are taken to prevent any harm to our clients. In cases where we are unable to implement sufficient controls to mitigate risks, we will disclose the conflict to the client 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 client harm, we will disclose the conflict.
• Where Wealthyhood’s organisational and administrative arrangements are not sufficient to ensure, with reasonable confidence, that the risks of damage to the interests of a client will be prevented, Wealthyhood will clearly disclose the general nature and/or sources of the conflict of interest to the client before undertaking business on the client’s behalf. Such disclosure shall be made in a durable medium and shall include sufficient detail, taking into account the nature of the client, to enable the client to make an informed decision. Disclosure of conflicts of interest shall be used as a measure of last resort and shall not substitute for the implementation of effective organisational and administrative arrangements.
• 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 clients place in us, ensuring that their interests are always at the forefront of our decision-making.
• Wealthyhood applies the principle of proportionality when identifying and managing conflicts of interest and ensures that the measures adopted remain appropriate in light of changes to its business model, services or regulatory obligations. This Policy is reviewed at least annually and updated where necessary.

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 clients, 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 client 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 clients, ensuring that all decisions are made without external incentives.
• Wealthyhood does not accept or retain any fees, commissions or non monetary benefits from third parties in relation to the provision of investment services to clients, except where such benefits are permitted under applicable law and are designed to enhance the quality of the relevant service without impairing Wealthyhood’s duty to act in the best interests of its clients. Any permitted minor non monetary benefits are subject to appropriate controls, are recorded by Wealthyhood, and do not give rise to conflicts of interest that could adversely affect clients.
• 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 clients' 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 Wealthyhood and its clients. 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 clients, not because of external incentives.
• We offer a variety of financial instruments, such as stocks and ETFs, that are accessible through our platform and/or app. 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, while the decisions of which investments to choose remain entirely yours.

GIFTS & HOSPITALITY

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

PERSONAL ACCOUNT DEALING

• Wealthyhood has robust policies and procedures in place to monitor and manage the personal trading activities of all Relevant Persons, ensuring that any personal transactions are aligned with our commitment to fairness and transparency.
• The term “personal account dealing” refers to transactions carried out outside the scope of the professional activities of Relevant Persons, either on their own behalf or on behalf of third parties.
• For the avoidance of doubt, for the scope of the rules and policies on personal account dealing, “third parties” shall include all the persons with whom a Relevant Person:
  • (a) has a familial relationship or close ties. Such familial relationships shall include (i) a spouse or a partner considered equivalent to a spouse under applicable law; (ii) dependent children or stepchildren; (iii) any other relatives who, as of the date of the transaction, have been a member of the household with the Relevant Person for at least one calendar year.
  • (b) has a relationship such that, although not falling within the above categories, the individuals concerned have a direct or indirect material interest (e.g., financial) that may be affected by the outcome of the transaction. This category includes, indicatively (i) non-dependent children; (ii) member of the household; (iii) flatmates, etc.
• The purpose of Wealthyhood’s personal account dealing policies is to prevent prohibited transactions, as defined by Regulation (EU) No 596/2014 and Greek Law 4514/2018, as well as transactions that would constitute the misuse or unlawful disclosure of confidential information, particularly in relation to clients or transactions with or on behalf of clients of Wealthyhood.
• Personal account dealing by Relevant Persons is subject to internal controls, including pre trade approvals, monitoring and record keeping arrangements, designed to prevent market abuse, the misuse of confidential information and conflicts of interest with clients. Breaches of personal account dealing rules may result in disciplinary action.

CONTACT US

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