HF Markets (SV) Ltd

MARKETING POLICY & GUIDELINES

___ ___ ___

Suite 305, Griffith Corporate Centre, P.O. Box 1510, T. +44-2030978571 support@hfm.com
Beachmont, Kingstown, St. Vincent and the Grenadines F. +44-2030978570 www.hfm.com
 HF Markets (SV) Ltd
Marketing Policy and Guidelines

Table of Contents

1. Introduction .................................................................................................................... 3

2. Definitions ...................................................................................................................... 4

3. Policy .............................................................................................................................. 6

4. Continuous Monitoring ................................................................................................... 9

5. Websites Operated By The Company ............................................................................. 10

6. Principles On Marketing Material .................................................................................. 10

7. The Prominence Of Risk Warnings ................................................................................. 15

8. Information Addressed To Clients .................................................................................. 15

9. Marketing Department ................................................................................................. 17

10. Education And Training Of Marketing Employees .......................................................... 17

11. Investment Research ..................................................................................................... 18

12. Record Keeping Procedures ........................................................................................... 19

13. Review And Amendment Of The Policy .......................................................................... 20

14. Applicability Of The Policy ............................................................................................. 20

15. Appendix 1 – Examples Of Good And Poor Practice ........................................................ 21

16. Appendix 2 – General Guidelines For Investment Research ............................................ 22

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Registered in the Financial Services Authority St. Vincent & the Grenadines.
Registration number 22747 IBC 2015
 HF Markets (SV) Ltd
Marketing Policy and Guidelines

1. Introduction

HF Markets (SV) Ltd (hereinafter the “Company” or “we”) which is a member of the HF
Markets Group, is incorporated under the laws of Saint Vincent and the Grenadines with
Registration 22747 IBC 2015 having its registered office at Suite 305, Griffith Corporate
Centre, P.O. Box 1510, Beachmont, Kingstown, Saint Vincent and the Grenadines. The
Company is authorised as an International Business Company under the International
Business Companies (Amendment and Consolidation) Act, Chapter 149 of the Revised Laws
of Saint Vincent and Grenadines, 2009 (herein the “Law”).

The objects of the Company are all subject matters not forbidden by International Business
Companies (Amendment and Consolidation) Act, Chapter 149 of the Revised Laws of Saint
Vincent and the Grenadines, 2009, in particular but not exclusively all commercial, financial,
lending, borrowing, trading, service activities and the participation in other enterprises as
well as to provide brokerage, training and managed account services in currencies,
commodities, indexes, CFDs and leveraged financial instruments.

The Company in accordance with the provisions of the Law, ensures that all information
addressed to or disseminated to its Clients and/or Prospective Clients, including Marketing
Communications and marketing activities, is fair, clear, transparent and not misleading.

The purpose of this Marketing Policy (herein the “Policy”) is to set out the guidelines and
procedures followed by the Company and/or its employees and/or its Affiliates when
providing information including but not limited to Marketing Communication which is
addressed to its Clients and/or Prospective Client, and the monitoring methods used by the
Company to ensure that the Company’s employees and/or Affiliates act under the
requirements of the Law and/or the obligations of their agreement with the Company.

The Policy aims to provide the Company’s employees and/or its Affiliates with awareness
concerning the provision and/or dissemination of information to Clients and/or Prospective
Clients, including Marketing Communication, in order to take reasonable steps to prevent
and/or mitigate possible conflicts of interest from adversely affecting the interests of the
Company’s Clients.

The main focus of this Policy is to ensure that marketing initiatives are aimed at the right
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Registered in the Financial Services Authority St. Vincent & the Grenadines.
Registration number 22747 IBC 2015
 HF Markets (SV) Ltd
Marketing Policy and Guidelines

audience and are conceived in such a manner as to be clear and easily understood by the
average member of the group to whom it is directed. In addition, this policy aims to ensure
the correct formulation of Marketing Communications and drastically reduce the possibility
of the latter being misinterpreted or misleading, as per the relevant legislative requirements.

2. Definitions

“Affiliate” is a natural or legal person who has completed the online Application Form, available
on the Company’s website to become an Affiliate of the Company and has been accepted by the
Company as its Affiliate and who shall obtain remuneration from the Company for the purpose of
introducing Clients to the Company, as per the provisions of the Affiliate Agreement.

“Client” is a natural or legal person who has completed the online Account Opening Application
form available on the Company’s website and has been accepted by the Company as its Client and
to whom the Company shall provide the services that is authorised to provide under the Law.

“Law” shall mean the International Business Companies (Amendment and Consolidation) Act, Chapter
149 of the Revised Laws of Saint Vincent and Grenadines, 2009 (herein the “Law”)., as amended from
time to time.

“Marketing Channels”: The Company uses several marketing channels in order to broaden the
visibility of its marketing material. The marketing channels used by the Company are as follows and
are related to both Clients and/or Prospective Clients:

1. Email Marketing

2. Social Media Marketing

3. Affiliate Marketing

4. Offline Marketing

“Marketing Communication” describes the method used by the Company to promote its
marketing material to its Clients and/or Prospective Clients i.e. through advertising, direct
marketing, branding, printed materials, messaging and any other form of communication the
Company might use from time to time to promote its marketing material.

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Registered in the Financial Services Authority St. Vincent & the Grenadines.
Registration number 22747 IBC 2015
 HF Markets (SV) Ltd
Marketing Policy and Guidelines

“Marketing Material” describes the materials used by the Company to present and promote its
business i.e. website content, e-books, educational videos, landing pages, banners, mailers, social
media, brochures, letterheads, newsletters, all forms of circulars, fact sheets, press
announcements, television, video channels (e.g. Youtube), or radio broadcasts, phone
applications, newspaper articles and periodicals. In particular, marketing material is any form of
information addressed to Clients and/or Prospective Clients, either off-line or online, and it is
considered as marketing communication, depending on whether it includes an invitation or
incentive for Clients and/or Prospective Clients to engage with the Company for the provision of
any investment and/or ancillary services which the Company is authorized to provide.

“Marketing Registry” means the Compliance Function’s online system where all Marketing
Material are reviewed by the Compliance Function and consequently approved or declined.

“Professional Client” is a Client who possesses the experience, knowledge and expertise to make
his own investment decisions and properly assess the risks that he incurs.

“Prospective Affiliate” is natural or legal person who has completed the online Application Form
found on the Company’s website to become an Affiliate of the Company and has not yet been
accepted by the Company as its Affiliate.

“Prospective Client” is a natural or legal person who does not have an account with the Company
and who has been introduced by the Affiliate for the purpose of concluding an agreement with the
Company. The definition of Prospective Client also includes any natural or legal person who does
not have an account with the Company and who has not been introduced by any Affiliates and
wishes to open a trading account with the Company.

“Prospective Retail Client” is a Prospective Client who at the time of the Account Opening
procedure is not considered by the Company as a Professional Client within the meaning of the
Law.

“Retail Client” is a Client who is not a Professional Client by default or an eligible counterparty.

“Stand-alone Compliant” is all promotional material must be stand-alone compliant meaning that
it must not be required to be issued in conjunction with further materials in order to be compliant.
Every promotion must meet all the relevant financial promotion rules, regardless of where or how
it appears. It is not acceptable to omit important information or a statement about risk just because
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Registered in the Financial Services Authority St. Vincent & the Grenadines.
Registration number 22747 IBC 2015
 HF Markets (SV) Ltd
Marketing Policy and Guidelines

you intend to give it later in the sales process.

Words denoting the singular include the plural and vice versa; words denoting any gender include
all genders; and words denoting persons include corporations, partnerships, other unincorporated
bodies and all other legal entities and vice versa.

3. Policy

The Policy outlines herein the procedure followed by the Company and/or its employees
and/or its Affiliates prior to the publishing of Marketing Materials on the Company’s and/or
the Affiliate’s website and/or in any other form which is used by the Company to
communicate with its Clients and/or Prospective Clients.

The Marketing Department is responsible for the preparation of the marketing materials
which are to be disseminated and/or addressed to the Company’s Clients and/or Prospective
Clients. The Compliance Function of the Company is responsible for reviewing and approving
the Marketing Material prepared prior to the dissemination of any Marketing Material to any
Client and/or Prospective Client, either prior or during the business relationship with a Client
and/or a Prospective Client.

The Company ensures that the following procedure is followed:

a) Marketing Material is being prepared by the Marketing Department upon request of the
Company’s Management;

b) The Company’s Management proceeds with the approval or refusal of the Marketing
Material proposal;

c) Upon approval of the marketing proposal, the Chief Marketing Officer assigns the relevant
task to the responsible Marketing Department officer who then proceeds with the
preparation of the Marketing Material;

d) The responsible Marketing Department officer for the preparation of the Marketing
Material proceeds with requesting the approval of the Marketing Material from the
Compliance Function;

e) The responsible person from the Compliance Function will proceed with reviewing the
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Registered in the Financial Services Authority St. Vincent & the Grenadines.
Registration number 22747 IBC 2015
 HF Markets (SV) Ltd
Marketing Policy and Guidelines

proposed Marketing Material and shall provide its approval or refusal whether the
proposed Marketing Material shall be made available to the Clients and/or Prospective
Clients;

f) In the event where the responsible person from the Compliance Function has any
comments in regard to the proposed Marketing Material, the comments are provided to
the responsible person from the Marketing Department through the relevant online
marketing tool;

g) Once the Marketing Department receives Compliance Function’s comments, it proceeds

with the update of the proposed Marketing Material in order to ensure consistency and
compliance with the relevant legislative requirements and the provision of the guidelines
included in this policy;

h) Upon approval of the Compliance Function, the Marketing Manager proceeds with
requesting the Company’s Management approval prior to publishing any Marketing
Material on the Company’s website or in any other form which is communicated to the
Clients and/or Prospective Clients;

i) Upon approval of the Company’s Management, the Marketing Manager is responsible for
making all necessary arrangements in order for the Marketing Material to be made
available to the Clients and/or Prospective Clients.

If the Compliance Function considers, during the review of the Marketing Material, that such
Marketing Material is not prepared in accordance with the requirements of the Law and the
Directive and/or the Policy, it will reject the proposed Marketing Material providing the
reasons for rejection and/or propose any amendments thereof. This procedure might be
followed by the Compliance Function several times prior to approving any proposed
Marketing Material.

In case the Compliance Function considers that such Marketing Material is wholly against the
requirements of the Law and/or this Policy and should not be made available to the Clients
and/or Prospective Clients under any circumstances, it shall inform the Chief Marketing
Officer accordingly and such Marketing Material shall be prohibited from being published in
any form to the Clients and/or Prospective Clients.
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Registered in the Financial Services Authority St. Vincent & the Grenadines.
Registration number 22747 IBC 2015
 HF Markets (SV) Ltd
Marketing Policy and Guidelines

The Company ensures that the Marketing Material, either approved or rejected are properly
recorded in the Marketing Registry maintained by the Company.

Any approved Marketing Material by the Compliance Function shall be made available by the
Marketing Department to the Company’s Affiliates, through their Affiliate/Client Area, for
the purpose of displaying promotional and advertising content on their website and/or social
network link, in order to promote the Company’s brand and direct web-traffic to the
Company’s authorized website, in accordance with the relevant legislative requirements.

Affiliates are able to automatically share any approved Marketing Material directly on their
website and/or social network link by clicking on the dedicated buttons on their
Affiliate/Client Area. It is noted that Affiliates do not have any access rights in order to tamper
with and/or alter in any way the Marketing Materials provided by the Company.

Upon termination of the Company’s Affiliates as per the terms and conditions of the Affiliate
Agreement, any marketing material used by Affiliates to promote and introduce clients to
the Company through their websites, will be automatically disabled by the Company and
shall not be visible to any person visiting the website of the Affiliates. For any marketing
material used by the Affiliate to promote and introduce clients to the Company through his
website which cannot be removed by the Company, the Affiliate has the obligation to remove
them upon termination of the Affiliate Agreement.

The Compliance Function shall be responsible to conduct regular checks on the Affiliates’
websites and/or social network links to ensure that the Affiliates are not uploading any
marketing material which was not provided by the Company and/or which has not been
approved by the Compliance Function prior to its publication. It is noted that the Affiliates
are prohibited from making any alterations to the Marketing Materials provided by the
Company, without the Company’s prior consent and the Company shall have the right to
terminate the business relationship with the Affiliate as per the terms and conditions of the
Affiliate Agreement.

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Registered in the Financial Services Authority St. Vincent & the Grenadines.
Registration number 22747 IBC 2015
 HF Markets (SV) Ltd
Marketing Policy and Guidelines

4. Continuous Monitoring

The Chief Marketing Officer is appointed by the Company and is responsible for the
establishment of the necessary procedures relevant to the continuous monitoring of any
marketing information to be addressed to Clients and/or Prospective Clients. The Compliance
Officer reviews at least on an annual basis any information which is sent to Clients and/or
Prospective Clients and ensures that they continue to be in line with the initial requests. A
relevant work plan is maintained, for the Company’s records.

The Compliance Function is performing the monitoring of all Marketing Material through the
Marketing Registry, as all the Marketing Material can be checked, approved or rejected and
also through the section, follow up, the material is re-checked on sample basis and if any
changes are deemed to be applied the relevant requests will be sent to Marketing
Department, to proceed accordingly, before the Marketing Material is available to
Prospective Clients and/or Clients.

The Marketing Registry includes records of the following data:

a) The employee who has uploaded the Marketing Material;

b) The title of the marketing material i.e. what type of Marketing Material is requested to be
reviewed;

c) The format of the Marketing Material;

d) The status of the Marketing Material i.e. whether it is approved, declined or pending,
along with comments stating the reasons where applicable;

e) The actions to be taken by the Compliance Function i.e. the Compliance Function selects
from the list whether it is approved or declined, and completes the section below with
the appropriate comments and actions to be taken;

f) The follow-up section i.e. the Compliance Function selects from the list whether the
Marketing Material is pending, checked or declined and completes the section below with
any comments if any;

g) The unique identification code to each approved Marketing Material.

In the event which the Compliance Function identifies any possible variations from the
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Registered in the Financial Services Authority St. Vincent & the Grenadines.
Registration number 22747 IBC 2015
 HF Markets (SV) Ltd
Marketing Policy and Guidelines

version which initially has been approved, it communicates it to the Marketing Department
for the rectification of the deficiencies identified. The monitoring of Marketing Material
published by the Company shall be documented within the Company’s Marketing Registry.

5. Websites Operated by the Company

In order for a new website to be launched, the Marketing Department responsible officer
must present the relevant website to the Chief Marketing Officer for his review and approval.
Upon confirmation of the Chief Marketing Officer, the website must be notified to the
Compliance Function in order to perform a review and provide their comments and
suggestions. As soon as the Compliance Function’s comments and suggestions are
implemented, the website should be notified to Board of Directors for review and approval
and upon their approval, it is released.

The Company operates a number of websites which may change from time to time. The
Company must ensure that at all times, the communication made to Clients through its
websites is fair and not misleading. In this respect and at least on a semi-annual basis, the
Company’s Executive Directors review the Company’s websites in order to ensure that the
material displayed on the websites is in accordance with the website’s approvals issued by
the Company.

Websites operated by the Company, have at the end of the website the relevant notification.

6. Principles on Marketing Material

This section of the policy analyzes the general principles to be followed by the Company and
its employees responsible for the preparation of any Marketing Material addressed to Clients
and/or Prospective Clients, so as to ensure compliance with the relevant legislative
requirements. The below principles are applicable to both the Company and its Affiliates.
General examples of adequate and insufficient practices as regards to Marketing
Communication addressed to Clients are available in Appendix 1.

Furthermore, advertising material shall not in any manner promote sexually explicit

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Registered in the Financial Services Authority St. Vincent & the Grenadines.
Registration number 22747 IBC 2015
 HF Markets (SV) Ltd
Marketing Policy and Guidelines

materials, violence, discrimination based on race, sex, religion, nationality, disability, sexual
orientation or age and/or any illegal activities or violate any intellectual property or other
proprietary rights of any third party.

As regards to information addressed to Clients and/or Prospective Clients, it is the Company’s

obligation that all information is fair, clear and not misleading. In particular, the Company
shall ensure that all information addressed to, or disseminated to Retail Clients or
Prospective Retail Clients is clear and easily understood and does not in any way lead the
Clients and/or Prospective Clients to false conclusions regarding the Company and its
products/services, nor be ambiguous in any way.

The Company is not allowed to make false, misleading statements such as:

a) promised returns/guarantee profits;

b) statements that mislead Clients and/or Prospective Clients to consider that trading in
Forex and CFDs carry little or no risk;

c) references that do not reflect the real opinion of Clients;

d) nor must any Marketing Material or communication be construed as giving advice or by

making any form of recommendation to any Client.

Promotions that fail to be fair, clear and not misleading can pose a risk as they could lead
Clients and/or Prospective Clients who are categorised as Retail, to trade with a financial
instrument that is not appropriate for them. The “fair, clear and not misleading” principle
implies the balance in how financial instruments and/or services are promoted, so that for
Clients and/or Prospective Clients to have an appreciation not only of the potential benefits
but also of any relevant risks associated with trading.

In addition to the Stand-alone Compliant rule, there is no such rule as a ‘one click- rule’. Being
one click away from the information does not necessarily make it compliant; the actual
promotion itself must be fair, clear and not misleading. This is known as being ‘Stand-alone
compliant’ and must be adhered to with all marketing material and communications. Roll-
over risk warnings are not sufficient to achieve stand-alone compliance on website banner
adverts. A roll-over risk warning is not considered appropriate as many people may still read

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Registered in the Financial Services Authority St. Vincent & the Grenadines.
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 HF Markets (SV) Ltd
Marketing Policy and Guidelines

the adverts without hovering over it or clicking through.

The Company ensures that Marketing Communication is used by its employees and/or its
Affiliates in a fair, clear and not misleading manner and in accordance with the requirements
of the Law.

Marketing Department is responsible for ensuring that Marketing Material, satisfies the
conditions laid down as follows:

i. The information should:

a. include the name of the Company

b. not include misleading statements or forecasts

c. be truthful in relation to any products or services provided by the Company

d. describe the nature of the products and services clearly

e. be current and up to date at the time that it is conveyed to the Clients

f. be accurate and in particular, shall not emphasize any potential benefits of an

investment service or financial instrument without also giving a fair and prominent
indication of any relevant risks in a balanced way;

g. be sufficient for, and presented in a way that is likely to be easily understood by, the
average member of the group to whom it is directed, or by whom it is likely to be
received;

h. not disguise, diminish, grey-out, shrink or obscure important items, statements or

warnings (these must be prominent).

ii. Where the information compares investment or ancillary services, financial instruments,
or persons providing investment or ancillary services, the following conditions need to be
satisfied:

a. the comparison must be meaningful and presented in a fair and balanced way;

b. the sources of the information used for the comparison must be specified;

c. the key facts and assumptions used to make the comparison must be included.

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 HF Markets (SV) Ltd
Marketing Policy and Guidelines

iii. Where the information contains an indication of past performance of a financial

instrument, a financial index or an investment service, the following conditions shall be
satisfied:

a. that indication must not be the most prominent feature of the communication;

b. the information must include appropriate performance information which covers the
immediately preceding 5 years, or the whole period for which the financial instrument
has been offered, the financial index has been established, or the investment service
has been provided if less than five years or such longer period as the firm may decide,
and in every case that performance information must be based on complete 12-month
periods;

c. the reference period and the source of information must be clearly stated;

d. the information must contain a prominent warning that the figures refer to the past
and that past performance is not a reliable indicator of future results;

e. where the indication relies on figures denominated in a currency other than that of the
country in which the Retail Client or Prospective Retail Client is resident, the currency
must be clearly stated, together with a warning that the return may increase or
decrease as a result of currency fluctuations;

f. Where the indication is based on gross performance, the effect of commissions, fees
or other charges must be disclosed.

iv. Where the information includes or refers to simulated past performance, it must relate to
a financial instrument or a financial index, and the following conditions shall be satisfied:

a. the simulated past performance must be based on the actual past performance of one
or more financial instruments or financial indices which are the same as, or underlie,
the financial instrument concerned;

b. in respect of the actual past performance referred to in point (a) above, the conditions
set out in sub-points (a) to (c), (e) and (f) of point (iii) above must be complied with;

c. the information must contain a prominent warning that the figures refer to simulated
past performance and that past performance is not a reliable indicator of future
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Registered in the Financial Services Authority St. Vincent & the Grenadines.
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 HF Markets (SV) Ltd
Marketing Policy and Guidelines

performance.

v. Where the information contains information on future performance, the following

conditions shall be satisfied:

a. the information must not be based on or refer to simulated past performance;

b. the information must be based on reasonable assumptions supported by objective

data;

c. where the information is based on gross performance, the effect of commissions, fees
or other;

d. charges must be disclosed;

e. the information must contain a prominent warning that such forecasts are not a
reliable indicator of future performance.

vi. Where the information refers to a particular tax treatment, it shall prominently state that
the tax treatment depends on the individual circumstances of each Client and may be
subject to change in the future.

vii. The information shall not use the name of any competent authority in such a way that
would indicate or suggest endorsement or approval by that authority of the products or
services of the Investment Firm.

Marketing Communication of any form shall not be permitted without the Client’s prior
consent. The Company ensures that employees who are associated with the Marketing
Communication of Clients and/or Prospective Clients apply the following principles:

a) disclosure of the content of the Marketing Communication in a clear, true and accurate
manner without promoting any false and/or untrue and/or misleading information;

b) clarifies from the beginning of the communication the purpose of the Marketing
Communication;

c) provides information regarding the Company and its identity;

d) If a Retail Client has consented to cold calling but has not himself determined the time
and the method of communication, the employee must consider whether or not the

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Registered in the Financial Services Authority St. Vincent & the Grenadines.
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 HF Markets (SV) Ltd
Marketing Policy and Guidelines

addressee wishes the communication to continue and, if not, he shall terminate it;

e) Employees do not proceed with undue pressure upon Clients and/or Prospective Clients
during their communications with any Client and/or Prospective Clients.

7. The Prominence of Risk Warnings

Risk Warnings must be:

• Be clear, fair and prominent to take into account the nature of the product, the risks involved
and the client’s commitment;

• Make it absolutely clear that a client’s capital is at risk;

• Be a prominent indication of any relevant risks;

• Prominently state that tax treatment depends on the individual circumstances of each client
and may be subject to change in the future (this only applies in situations where the client
receives some tax advantages).

8. Information addressed to Clients

Any other information i.e. legal documentation and the Company’s policies and procedures,
which is required to be disseminated to the Clients and/or Prospective Clients is properly
assessed prior to publishing.

The Company is required to provide Clients and/or Prospective Clients with specified legal
information. A Retail Client or Prospective Retail Client must receive the following
documents:

i. The Terms and Conditions which includes the following information:

a. Means of communication.

b. Company name and address.

c. The languages in which the Client and/or Prospective Client may communicate with the
Company and receive documents and other information.

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 HF Markets (SV) Ltd
Marketing Policy and Guidelines

d. Company’s contact details.

e. Communication method for receiving orders.

f. Information on costs and associated charges.

g. A general description of the nature and risks of financial instruments taking into
consideration the Client’s categorization either as Retail or Professional Client. That
description must explain the nature of the specific type of instrument concerned, as
well as the risks particular to that specific type of instrument in sufficient detail to
enable the client to take investment decisions on an informed basis.

ii. Conflicts of Interest Policy.

iii. Risk Disclosure Statement.

iv. Privacy Policy.

v. Trading Conditions, available instruments, expiry dates, information of spreads and

rollovers, as well as expiry rates as applicable for each product offered by the Company.

vi. Details of the complaints handling process.

vii. Order Execution Policy.

viii. Client Categorisation Policy.

The Marketing Department shall ensure that at least on annual basis the following section in
the Terms and Conditions are reviewed and updated list of payment service providers is
updated once a new collaboration is in place or when a termination has occurred.

The Company provides its Clients and/or Prospective Clients with the prescribed information
through the website which is accessible by all website users (Clients or Prospective Clients)
at specified times. In addition, Retail Clients are notified of the exact information location
through an email upon registration.

The Compliance Function is responsible for preparing all legal documentation which is made
available to the Clients and/or Prospective Clients through the Company’s website. The
Compliance Function is responsible for reviewing, updating and/or amending the Company’s
legal documentation on an annual basis or earlier if changes are required to be implemented

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 HF Markets (SV) Ltd
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prior to the annual review. These changes are approved by the Board of Directors in cases
are classified as material, otherwise, the final approval of the Senior Management is
obtained.

The Marketing Department is responsible for communicating any change, update and/or
amendment of any of the Company’s legal documentation to the Clients. The Compliance
Function is responsible for reviewing and approving the material which is to be
communicated to the Clients as per the procedure outlined in Section 3.3 of the Policy.

The Company ensures that any update and/or amendment in any of the Company’s legal
documentation and policies and procedures are acknowledged and read by the Client prior
to being effective and relevant records are kept in Company’s systems.

9. Marketing Department

The Marketing Department is responsible for the development and implementation of the
Company’s marketing strategies and marketing plans and the promotion of the Company and
its products and services.

The Marketing Department consists of the Chief Marketing Officer and additional staff who
are employed in the positions of (a) Online Marketing Manager, (b) Marketing Graphic/Web
Developer (c) Head of Web Masters (d) Web Developer (e) Online Marketing Coordinator (f)
Content Writer and (g) Social Media Executive.

10. Education and Training of Marketing Employees

The Compliance Function is responsible to inform the employees of the Marketing

Department for any updates of the applicable regulation is related to Marketing
Communication and/or Marketing Material.

Marketing Department’s personnel will attend, at least once a year and/or whenever a
change in the legal framework occurs, either internal or external seminar, which will be
related to their duties and responsibilities as well as the legislative requirements related to
information addressed to Clients and/or Prospective Clients, including Marketing
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Marketing Policy and Guidelines

Communication.

11. Investment Research

Investment research services, financial analysis and other forms of general

recommendations relating to transactions in financial instruments shall be aiming to provide
a professional service in accordance with the provisions of the Law as well as the Company’s
code of conduct and internal regulation. Investment Research Department shall be ensuring
the protection the customer’s interest, ensuring market stability, avoiding conflicts of
interest, and ensuring the fair and equal treatment of all customers.

Investment research means research or other information recommending or suggesting an

investment strategy, explicitly or implicitly, concerning one or several financial instruments
or the issuers of financial instruments, including any opinion as to the present or future value
or price of such instruments, intended for distribution channels or for the public, and in
relation to which the following conditions are met:

(a) it is labelled or described as investment research or in similar terms, or is otherwise

presented as an objective or independent explanation of the matters contained in the
recommendation;

(b) if the recommendation in question was made by an investment firm to a client, it would
not constitute the provision of investment advice for the purposes of the Law;

The relevant person who produces the substance of investment research is known as a
financial analyst. The services offered by the financial analyst can include: Investment
Research, Financial Analysis and other forms of General Recommendations.

The Company shall cover the cost of producing investment research from its own resources
and shall not pass it to its Clients either as a cost or charge for execution, research or other
advisory services.

Financial analysts and other relevant persons must not undertake personal transactions or
trade, other than as market makers acting in good faith and in the ordinary course of market
making or in the execution of an unsolicited client order, on behalf of any other person,

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including the Company, in financial instruments to which investment research relates, or in

any related financial instruments, with knowledge of the likely timing or content of that
investment research, which is not publicly available or available to clients and cannot readily
be inferred from information that is so available, until the recipients of the investment
research have had a reasonable opportunity to act on it.

The Company itself, financial analysts, and other relevant persons involved in the production
of the investment research must not promise issuers favorable research coverage.

The Company itself, financial analysts, and other relevant persons involved in the production
of the investment research must not accept inducements from those with a material interest
in the subject-matter of the investment research.

Where the Company shall disseminate investment research produced by another person to
the public or to clients is exempted from complying with above if the following criteria are
met:

(a) the person that produces the investment research is not a member of the group to which
the Company belongs;

(b) the Company does not substantially alter the recommendations within the investment
research;

(c) the Company does not present the investment research as having been produced by it;

General examples of adequate practices as regards to Investment Research addressed to

Clients are highlighted in Appendix 2.

12. Record Keeping Procedures

The Marketing Department is responsible for keeping all documents/data in electronic form.

The Company ensures that all Marketing Material as well as the process prior to been
released need to be kept in electronic form.

All documents and data related to Marketing Communication are kept by the Marketing
Department and are recorded in the Marketing Registry which is accessible to all the

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Registered in the Financial Services Authority St. Vincent & the Grenadines.
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 HF Markets (SV) Ltd
Marketing Policy and Guidelines

employees of the Marketing Department and Compliance Function.

13. Review and Amendment of the Policy

The Compliance Function with the assistance of the Marketing Department shall be
responsible for reviewing the Policy on an annual basis and propose any amendments
thereof.

Any amendments thereof are presented the Board of Directors for review and approval.
Once the Board has given its consent, the Policy is updated accordingly to give effect to the
proposed amendments. The Policy is uploaded on the Company’s internal manager and on
the Client/Affiliate Area in order for all of the Company’s employees and Affiliates to be
notified and informed accordingly.

This Policy is required to be acknowledged by all the Company’s employees as part of the
Company’s Internal Operations Manual. The Marketing Department employees are required
to specifically acknowledge the respective Policy by executing the relevant Acknowledgment
Form.

The Affiliates shall receive notifications in advance of the proposed changes in the Policy and
shall confirm their acceptance of the proposed changes in order to continue the business
relationship with the Company.

14. Applicability of the Policy

The Policy is available on the Client’s Affiliate/Client Area and has to be acknowledged by
every Affiliate who has been accepted by the Company as such.

Version: 2023/01

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Registered in the Financial Services Authority St. Vincent & the Grenadines.
Registration number 22747 IBC 2015
 HF Markets (SV) Ltd
Marketing Policy and Guidelines

15. Appendix 1 – Examples of good and poor practice

A. EXAMPLES OF GOOD PRACTICE

The following are considered as examples of good practice; although the list is not exhaustive:

▪ Important information, statements or warnings are prominent and presented using clear and
bold type styles.

▪ The size of important information such as risk warnings is proportionate, taking into
consideration the content, size and orientation of the Marketing Material as a whole.

▪ Both the benefits and drawbacks of a financial instrument and/or service are balanced
through equally prominent feature statements.

▪ Risk warnings are contained within their own distinct border, thus drawing the clients’ and/or
potential clients’ attention to them.

▪ Risk warnings are clearly stated within the main body of the banner/picture and/or
sign/invitation for account opening and ahead of a small print.

▪ Risk information appears on the website(s) landing page that the clients and/or potential
client first arrive at when following a promotional link.

B. EXAMPLES OF POOR PRACTICE

▪ Risk warnings are diminished through the use of small font sizes and unclear type styles and
due to their location being outside of the main advertisement border.

▪ Important information, statements are covered across coloured or patterned backgrounds

which diminish their visual impact.

▪ Important information is hidden and is only accessed through significant scrolling down
and/or multiple page links.

▪ References which refer to indicative information and/or to fictitious and/or non-existing

persons.

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Registered in the Financial Services Authority St. Vincent & the Grenadines.
Registration number 22747 IBC 2015
 HF Markets (SV) Ltd
Marketing Policy and Guidelines

16. Appendix 2 – General Guidelines for Investment Research

▪ The following terms used in this Policy have the following meaning:

“Major Currency Pairs” are the EURUSD, GBPUSD, USDJPY, AUDUSD, USDCAD, USDCHF, NZDUSD.

“Minor currency pairs” are other currency pairs than Major Currency pairs.

▪ Investment Research should be focused mainly on the currency market and most precisely on
the major currency pairs (The 7 USD pairs plus EURJPY, GBPJPY and EURGBP) and the major
commodities (Gold, Oil). A total of approximately 70% of the written or electronic material
should refer to the above. Naturally, in the case of important events the percentage could
vary.

▪ Indices, Equities and minor currency pairs should take up the remaining 30% of the analysis.
This percentage varies based on the relevance to current affairs (news, topical events or
client’s requests)

▪ Keeping the above in mind, it would be advisable to examine which currencies the recipients
mainly follow in order to tailor the posts to their needs.

▪ Analysts must ensure that the information within their Investment Research is clear, justified
and complete and in no way misleading or deceptive.

▪ Analysts are prohibited from providing personalized advice or being perceived as doing so
through a written or electronic communication to the general public.

▪ Written Material should be short and to the point. No need to exceed 500 words, unless the
post necessitates such elaboration.

▪ Usage of intriguing titles, such as: “scalping”, “trading”, “fundamentals”, and posts with lists
“ten things to look out for when trading” usually triggers more interest.

▪ Major economic events and announcements, as well as how these affect the markets in the
short term should be thoroughly examined and commented upon.

▪ In general, a shorter-term analysis is preferred. While it may not be easy to fit a 5M chart, as
the post may become obsolete by the time a reader sees it, the use of H1 and H4 charts (as a
maximum) is advised for intra-day analysis. In addition, when pointing to previous economic
___ ___ ___

Suite 305, Griffith Corporate Centre, P.O. Box 1510, T. +44-2030978571 support@hfm.com
Beachmont, Kingstown, St. Vincent and the Grenadines F. +44-2030978570 www.hfm.com
 HF Markets (SV) Ltd
Marketing Policy and Guidelines

events it would be advisable to use the M5 charts for illustration purposes.

▪ On occasion, due to adverse market conditions, there may be more longer-term opportunities
arising. Long-term analysis may range from daily to weekly basis.

▪ No specific recommendations can be offered regarding the path of any asset. However, the
outcome of the Technical Analysis for the specific parameters can be used, such as “Resistance
at XX”, “Support at XX”, “Pivot Point/Key Level / Psychological level at XX” and so on.

▪ High volatility events such as FOMC meetings, NFPs, and others should always be covered
within the day, with emphasis on how these have previously affected exchange rates based
on the facts. instead of personal positions. Again, the use of shorter timeframe charts is
advised.

▪ Observations of market research such as: “the US has been facing strong economic growth, in
contrast to the EU”, etc. should be clearly stated in the post, however no specific advice with
respect to such observation should be offered. Economic data could be used for such
observation, such as: “The retail data fell by 4%, the stock market continues to suffer, the
manufacturing sector continue falling, raised concerns about slowing European growth.”

▪ There should be no explicit proposed action in the article, such as: “USD issued a buy signal”
or “Euro provides a good sell opportunity” or suggesting that a client can “buy at XX” or “sell
at XX”. This refers to any kind of suggestions, tips or recommendations that could be
considered as investment advice.

▪ Market review should be always based on the facts obtained from reliable sources and never
on personal opinions or individual, subjective judgments or believes.

▪ Any kind of promises of estimated returns, guarantees of profit, misleading statements that
suggest that trading in Forex and CFDs carries little risk, and false advertising of services that
the company is authorized to provide, are not allowed.

▪ CFDs are considered to be complex investment products, therefore trading CFDs should never
be described as easy, simple or straight forward. The recipients should be aware that trading
CFDs requires specific knowledge, skills and experience.

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Registered in the Financial Services Authority St. Vincent & the Grenadines.
Registration number 22747 IBC 2015
 HF Markets (SV) Ltd
Marketing Policy and Guidelines

▪ In case there is a reference to the specific data or report it should be from reliable source only
and the name of that source should be quoted.

▪ Absolute statements should be avoided and replaced with balanced statements, which should
be clear, not misleading and present a balance between positive and negative aspects of
trading in complex financial instruments.

▪ When information addressed to clients contains an indication of past performance of a

financial instrument, financial index or an investment service, it should be clarified that the
past performance is not the most prominent feature of communication and it is not reliable
indicator of future results.

▪ Each post or article should always include relevant risk warning and the disclaimer.

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Registered in the Financial Services Authority St. Vincent & the Grenadines.
Registration number 22747 IBC 2015