Terms of Service

Last Updated on 25 April 2017

Please read these Terms of Service carefully before using the website.

1. General

1.1. These Terms of Business (the “Terms”) together with your completed and signed Confidential Client Fact Find (the “CCFF”, collectively with the Terms referred to as “the Agreement”) govern the legal relationship between you (hereinafter, the “Client”) and MZ Investment Services Ltd (hereafter referred to as the “MZI”) in respect of the services MZI provides to the Client.

1.2. The Client should read the Terms, and any document referred to herein very carefully. If there is anything that the Client does not understand the Client should discuss this matter with his/ her contact within MZI and seek the necessary clarification.

1.3. MZI’s registered office is at 61 St. Rita Street Rabat RBT 1523 Malta MZI’s business office is located at 55 MZ House St Rita Street Rabat RBT 1523 Malta and may be contacted on +356 2145 3739 or +356 2145 9058.

1.4. MZI may communicate with the Client by electronic mail unless otherwise instructed by the Client. Documents sent by electronic mail (whether or not containing confidential information) will not be encrypted unless specifically requested by the Client in writing. Following such request, MZI and the Client may agree and implement mutually acceptable encryption standards and protocols. MZI’s ‘E-mail Consent Form’ outlines the risks related to use of e-mail for communication purposes. 

1.5. MZI reserves the right to monitor or access any or all e-mails sent to it.

1.6. Communication between Clients and MZI will be made in the English language, unless agreed by mutual agreement between both parties. In the event of discrepancy between the terms of this agreement and any other communication, the terms of these Terms will prevail.

1.7. The Terms cover the provision by MZI of the following services: 

• Investment Advisory Services; 

• Portfolio Management Services;

• Reception and Transmission of orders; 

• Execution of Orders; 

• Placement of instruments without a firm commitment basis; and

• Nominee Services.

• (each “a Service” and collectively referred to as “the Services”)

1.8. The Terms contain important information regarding the way in which MZI will provide the Services to the Client and the Client’s legal position. 

1.9. MZI will provide the Client with a copy of these Terms and the most recent CCFF upon request.

2. Representations and Warranties

2.1. The Client represents and warrants to MZI that:

• the Client has authority to enter into the Agreement; and

• any information which the Client has provided or may provide to MZI is complete, up-to date and correct in all respects; 

• in the event that any of the information supplied by the Client ceases to remain complete, up-to date and correct in any respect, the Client shall provide MZI with such revised and updated information without delay; and

• the Client is the beneficial owner (or if the Client is a trustee, the legal owner) of any investment and cash subject to these Terms and will indemnify MZI against all claims or demands made by any person in relation thereto. 

2.2. The Client confirms that whenever the Client instructs MZI to buy, sell or hold investments, the Client shall not grant, without prior written agreement with MZI, a charge, hypothec, pledge or create any security interest whatsoever over such investments.

2.3. By agreeing to these Terms the Client is authorising MZI to deduct or withhold any sum, which MZI is required or liable to deduct or withhold under the law or practice of any revenue authority in any relevant jurisdiction. 

2.4. The Client represents and warrants that he/she is in compliance with and shall comply at all times with any applicable law including Maltese tax and exchange control laws and regulations. The Client further represents and warrants that any foreign currency which forms the subject of the Agreement is money which has lawfully been invested out of Malta and that any necessary authorisations in this respect have been obtained.

3. Taxation and Other Legal Matters

3.1. MZI shall not be responsible and shall not assume any liability for the provision of any Tax or Legal advice in respect of the products and services it offers. It shall also be the Clients’ responsibility to seek advice about and observe any applicable laws relating to the purchase, sale, dealing or any transaction of any instrument. Clients are strongly advised to seek their own independent professional advice on tax and legal matters since the implications will depend on the clients’ individual circumstances.

3.2. When investment income meets the requirements as per the Income Tax Act, this income will be subject to the current final withholding tax of 15% and the client has the option of being taxed at source on the individual investments.

4. Regulation

4.1. MZI’s is regulated by the Malta Financial Services Authority (the “MFSA”). 

4.2. MZI is licensed by the MFSA under the Investment Services Act 1994 and holds a Category 2 Investment Services Licence. MZI provides investment services business in accordance with its licence.

4.3. MZI will provide the Services in accordance with applicable laws, regulations, bye-laws, licence conditions, guidelines, exchange requirements, customs, usages and other provisions or market practices (the “Rules”) to which MZI may be subject from time to time.

4.4. If any conflict arises between the Terms and the Rules, the latter shall prevail. 

4.5. MZI may provide other services which are not regulated and which do not require a licence by the MFSA to its clients.

5. Client Categorization

5.1. MZI shall categorise Clients into one of the following three categories: -

• Retail Clients; 

• Professional Clients; or 

• Eligible Counterparties. 

5.2. The level of protection offered and due to each Client depends on the category assigned to each Client. The Client’s categorisation will be identified in the CCFF.  Should the Client classification change, MZI will inform the Client accordingly.

5.3. The Client may also request (in writing) MZI to change the category in which he/she has been classified. This change may have an effect on the level of protection afforded to the Client. MZI reserves the right to accept or refuse any such request for change in classification.

5.4. The Client agrees to advise MZI in writing of any material changes in the information provided to MZI which may effect Client categorisation or advice given to the Client.

6. Types of Services

6.1. Discretionary Management

6.1.1. MZI shall, where applicable, provide discretionary portfolio management services to the Client for the investment and reinvestment of Client’s money and instruments. MZI shall manage the assets of the Client with a view to achieving the Client’s stated investment objective.

6.1.2. The MZI shall maintain full and detailed records of all assets and transactions carried out on the Client’s behalf. 

6.1.3. The investment management service will be provided in terms of an investment management agreement between MZI and the Client. 

6.2. Advisory Services 

6.2.1. MZI shall, where applicable, provide investment advisory services to its Clients suitable to them to achieve their investment objectives. This is only possible if the Client commits to provide the Company with full information regarding his / her investment objectives, financial situation, knowledge and expertise. The Company is not obliged to periodically assess, monitor or review the Client’s holdings through the term of the Investments. 

6.2.2. MZI will retain a record of all investment advice given to the specific clients. 

6.3. Reception and Transmission of Orders / Execution of orders 

6.3.1. MZI shall, where applicable, (i) receive orders from the Client and transmit the orders to a third party for execution or (ii) execute the orders on behalf of the Client, without giving any investment advice as to the suitability of that investment. MZI shall be under no duty to monitor, review or advise the Client on any investment made. MZI shall however keep records of the transactions made and inform the Client in accordance with the Rules on the transaction executed on the Client’s behalf. 

6.4. Placement of instruments without a firm commitment basis

6.4.1. MZI may, where applicable, market newly-issued securities or securities which are already in issue but not listed to its Clients. 

6.4.2. The offering of securities to the Clients will be made without a firm commitment basis and MZI shall at no point in time assume any risk of guaranteeing the sale of a certain number of shares by buying the relevant securities from the issuer.

6.5. Nominee Services 

6.5.1. Most instruments acquired by MZI for and on behalf of the Client may be held in the name of MZI as nominee for and on behalf of the Client. MZI offers this service in order to expedite and facilitate Clients’ acquisitions and/or subscriptions to instruments, consequently the Client should note that in the event that he opts out of this service in relation to a particular transaction the order might take longer to process. In the event that the Client opts out of this service the Client will be responsible for the custody arrangements and MZI will accept no liability for the negligence or other default of such third party nominee or custodian as applicable.

7. Client Profile Requirements

7.1. Appropriateness Test

7.1.1. When providing investment services other than discretionary portfolio management services and investment advice, MZI shall conduct an appropriateness test. Based on the information provided by the Client, MZI shall determine whether the product or service requested by the Client is appropriate. Where the product or service requested by the Client is deemed inappropriate, MZI shall issue a warning to the Client. Such warning shall be issued in writing.

7.1.2. If based on the information provided, MZI believes it has insufficient information to assess the appropriateness of the product/ service for the Client, MZI shall inform the Client that MZI is not in a position to assess appropriateness. 

7.1.3. Should the client request, at his/her own initiative, an execution only transaction, which transaction is in relation to non-complex instruments, MZI is not required to assess the appropriateness of the investment service or product requested by the Client.

7.2. Suitability Test

7.2.1. When providing discretionary portfolio management services and investment advisory services, MZI shall conduct a suitability test. MZI needs to establish that the product / service requested: (a) meets the objectives of the Client; (b) is such that the Client is able to financially bear any related investment risks consistent with his/ her investment objectives; and (c) is such that the Client has the necessary experience and knowledge to understand the risks involved.  

7.2.2. Where the Client has been classified as a Professional Client, MZI is only obliged to ensure that the product/ service requested meets the Client’s investment objectives and whether the Client is able to financially bear any related investment risks consistent with his investment objective.

7.2.3. In order to be in a position to evaluate such suitability, the Client agrees to provide MZI with information regarding his/her investment objectives, financial situation, knowledge and experience in relation to specific investment services and products.

7.2.4. If MZI determines that, from the information provided by the Client, it does not possess sufficient information to be able to provide the relevant service to such Client, MZI shall refrain from providing such service.

7.2.5. In case where MZI is providing investment advice to a Client which has been categorised as a professional client, MZI shall be entitled to assume that such Client is able financially to bear any related investment risks consistent with his investment objectives.

8. Transactions and Instructions

8.1. Both the Client and MZI acknowledge that an investment transaction facilitated by MZI is not deemed to be a loan and the Client’s money and Client’s assets have not been given on the sole condition of returning as much of the same kind and quality.

8.2. All settlement with clients in respect of investment income, sale proceeds or any account related transactions will be made payable to the clients directly jointly or individually according to the signing instructions of the account holder/s. 

8.3. The Client may give instructions to undertake transactions either in writing, over the telephone, by e-mail (subject to completion of MZI ‘E-Mail Consent Form) or facsimile. Transactions, orders or queries undertaken through the telephone. E-Mail and facsimile will be effected in a prompt and timely fashion and to the extent possible, in the order in which they were received. 

8.4. MZI recommends that telephone orders are followed up with written instructions via email or by facsimile. In giving written instruction, the Client is authorising MZI to draw up an order confirmation form based on the transaction communicated over the telephone or facsimile. MZI will not assume liability for any errors if the client fails to provide written instructions via email or by facsimile.

8.5. MZI shall be indemnified by the Client against all actions, proceedings or claims which may be incurred or sustained from the execution of the order/s taken over the telephone or by facsimile irrespective of the whether the official confirmation order relevant to that transaction was signed or otherwise by the Client.

8.6. The Client or any other person whose authority has previously been notified by the Client to the Company in writing, may at any time give Client instructions to alter, modify, amend or revoke Client instructions previously given to the Company by or on behalf of the Client. The Attorney’s authority shall remain in full force until written notice of the revocation is given by the client and acknowledged by MZI.  

8.7. MZI shall send the Client a contract note or confirmation in respect of each trade effected on behalf of the Client. The Client agrees to review each contract note or confirmation received and to notify MZI of any errors, omissions or objections within fifteen (15) days from the date of the contract note or confirmation. Following the lapse of fifteen (15) days from the date of the contract note or confirmation MZI shall treat any entries or balances therein as final, conclusive and binding.

8.8. The Client agrees that payments made for any transactions executed by MZI are to be settled within the period stipulated in the contract note or relevant documentation. Any failure to meet these obligations within the allowed time frame shall not to be borne as a liability by MZI. MZI bears the right to immediately dispose of any unpaid investments of which any differences emanating from this are to be paid up by the Client.

8.9. The Client has the right to inspect the contract notes, vouchers and entries in MZI’s books or computerised records relating to his/ her transactions. These records are retained for a period of at least ten (10) years.

8.10. MZI may combine the Client’s order(s) with order(s) of other Client(s) provided that such aggregation does not operate to the disadvantage of the Client.

8.11. The Client agrees that MZI may, at its discretion, record any telephone communications between the Client and MZI.

8.12. MZI shall not incur any liability whatsoever by reason of acting on any such client instructions or for any error in such client’s instructions and the Client shall indemnify and hold harmless MZI from any loss, cost, damage or expense it may suffer or incur by relying on such client instructions, whether received by letter, telephone, facsimile or other electronic transmission (including electronic mail) or in such other manner as MZI may determine from time to time, and which MZI, in its absolute discretion, has reason to believe to be genuine.

8.13. The Client understands that MZI shall not be held liable as a result of any change in market conditions between the date of the Client’s instructions and the execution thereof by MZI.

8.14. Where the processing of Client’s instructions are affected by a trading halt in the relative RIE or for any other reason not within the control of MZI, MZI shall complete the Client’s instructions as soon as reasonably possible. MZI shall not be held responsible for any loss the Client suffers as a result of such circumstances beyond its control.

9. Best Execution Policy

9.1. Subject to any specific instructions which may be given by the Client, when executing orders on the Client’s behalf, MZI will take all reasonable steps to obtain the best possible result for its Client which shall be determined in terms of total consideration (represented by the price of the financial instrument and the costs related to the execution of the transaction). 

9.2. Other best execution factors such as speed, the likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of the order may also be applied by MZI but only in so far as they are relevant to provide the Client with the best result in terms of total consideration.

9.3. Please refer to MZI’s full best execution policy.

10. Clients Money and Assets

10.1. Where investments are held under Nominee with a third party, MZI shall inform the Client of this fact and shall adequately warn the Client of any potential resulting risks.

10.2. MZI may also hold monies belonging to the Client in a “Clients’ Bank Account” opened with various credit institutions/securities depository. The Client agrees that MZI shall have no responsibility to credit interest on the Clients’ monies held with MZI.

10.3. MZI has in place adequate arrangements for handling and accounting for the Client’s monies and that such monies will at all times be separated from MZI’s monies. MZI shall, upon receipt, promptly place any Client’s monies with a credit institution/ securities depository. 

10.4. MZI declares that it has in place adequate arrangements for the segregation of the Clients’ Bank Accounts from its own accounts. 

10.5. MZI will monitor and act in the best manner it deems fit as regards to voting in respect of any investments held by MZI as nominee as regards any subscription, conversion or other rights in respect thereof or as regards any merger, consolidation, reorganization, receivership, bankruptcy or insolvency proceedings, compromise or arrangement or the deposit of any Instruments in connection therewith or otherwise, or as regards any take-over bids, issuer bids, rights offerings or similar events. MZI shall when feasible and practical investigate or participate therein or take any affirmative action in connection therewith. MZI shall act in the clients’ best interest upon such indemnity and provision for expenses as MZI may require.

11. Reporting to Clients

11.1. MZI shall send the Client at least every twelve (12) months a statement of the Client’s portfolio, including any clients’ money held by MZI (if applicable) and a valuation thereof. 

11.2. The Client agrees to promptly examine all statements and valuations received from MZI and each entry and balance recorded therein and to notify MZI of any errors, omissions or objections to any entries and balances in such statements or valuations, within thirty (30) days from each statement or valuation date (as the case may be), failing which MZI shall be entitled to treat such statements and valuations and any entries and balances therein as final, conclusive and binding.

12. Joint Accounts

12.1. If the Client’s account is held jointly by more than one person then the obligations of each of the joint account holders, under these Terms shall be joint and several. 

12.2. Unless MZI receives notice in writing to the contrary from any one of such joint account holders MZI is hereby authorised to communicate with and act on client instructions of, any one of the joint account holders and MZI shall have authority to act on any such client instructions, without notice to any one or more of the other joint account holders.

12.3. MZI is hereby authorised to send notices, confirmations, statements and communications of any kind to any one of the joint account holders and service of any demand, notice, confirmation, statement or any other communication of any kind shall be deemed to have been duly served on all joint account holders if served on any one joint account holder to the most recent address as appears on the records of MZI.

12.4. In the event of the death of one of the joint account holders, the surviving joint account holders agree to immediately provide MZI with written notice thereof. The death of any joint account holder will affect the rights and obligations of the surviving joint account holders which will be governed by the Civil Code (Chapter 16) of the Laws of Malta. MZI is authorised, prior to or after receipt of written notice of the death of one of the joint account holders, to take such steps or require such documentation or restrict trades or transactions relating to the joint account as MZI may deem prudent or advisable, at its absolute discretion.

12.5. The estate of any deceased joint account holder shall continue to be liable to MZI jointly and severally for any indebtedness or other liabilities in connection with the joint account.

13. Conflicts of Interest

13.1. It is understood that MZI or any director, officer or employee thereof may have an interest, relationship or arrangement that is material in relation to any trade effected on behalf of the Client and it is hereby agreed that any person so interested shall be entitled to retain any benefit or profit received and shall not be liable to account therefore to the Client by reason only of such conflict. MZI declares that it has in place adequate internal procedures to ensure that the Client is in all cases treated fairly and that risks of damage to client interests will be prevented.

13.2. MZI undertakes to bring to the Client’s attention the conflicts of interest referred above and any other conflicts of interest which may arise with regards to products promoted by MZI or the services provided by its related companies. In the provision of its services, MZI will seek to ensure that it always acts in the Client’s best interests. 

13.3. Please refer to MZI’s full conflicts of interest policy.

14. Prevention of Money Laundering - Cient Identification and Source of Funds

14.1. MZI is subject to the Prevention of Money Laundering laws and regulations in force in Malta. 

14.2. The Client is required to produce satisfactory evidence of identity and the source of funds to be invested. MZI reserves the right to request further documentation as it deems necessary from the client during the course of the relationship. 

14.3. The Client represents and warrants that the monies and investments which form the subject of the Agreement and any future additions thereto have not originated and will not originate from activities or transactions which are a criminal offence in Malta or which, if carried out in Malta, would constitute such an offence or comprise property the receipt ownership or control of which would be such an offence.

15. Risks

15.1. Investment Risks

15.1.1. The price of all investments can go up as well as down and an investor may not get back the amount invested and selling an investment in an inopportune moment may result in a loss. 

15.1.2. Past performance is not indicative of fu¬ture performance. Investment markets are volatile in nature and it is important that any investment is viewed as long term in nature.  

15.2. Currency Risk

15.2.1. An investment may have a base currency other than the Clients’ base currency and thus carries with it an element of currency risk which can affect the value of any investment and the income generated therefrom, positively or negatively, including interest or dividend payments. In addition, upon the sale or maturity of the Client’s investment, the realisable value might be less than the initial outlay when exchanged in the Clients’ domestic currency. 

15.3. Credit Risk

15.3.1. An issuer of a debt instrument such as a bond may be unable to meet interest and/or principal payments in the future and consequently default on its principal or interest repayments. The longer the term to repayment of principal (maturity), the greater the credit risk. 

15.4. Interest Rate Risk

15.4.1. The market value of a bond or other debt instrument may go up or down as a result of a variation in the interest rates 

15.5. Other risks

15.5.1. Investments in certain assets may be subject to specific risks which may or may not effect a par¬ticular investment. These risks may include Liquidity risk, Country risk, Political risk and Counterparty risk. The exposure to these risks may change over the course of the investment period, and may affect the value of the Client’s investment.

15.5.2. The Client acknowledges that the risks involved and related to an investment are various and the risks referred to in the Terms constitute a non- exhaustive list.

16. Complaints

16.1. In the circumstance were a complaint arises, the Client shall inform MZI by visiting our offices or write to the attention of “The Compliance Officer, MZI Investment Services Ltd, [address]”. The Compliance Officer of MZI shall deal with Client’s complaints reasonably and promptly and in accordance with MZI’s internal complaint handling procedures. MZI commits that all complaints with be acknowledged and replied to within reasonable time.

16.2. If your complaint is not ultimately handled to your satisfaction after being dealt with according with MZI’s internal complaint handling procedures, then you may subsequently refer your complaint: The Office of the Arbiter for Financial Services, First Floor, Pjazza San Kalċidonju, Floriana - FRN 1530.

16.3. Further information may be obtained through the official website: www.financialarbiter.org.mt, Freephone (local calls): 8007 2366 and Telephone: (356) 2124 9245

17. Investor Compensation Scheme

17.1. The MZI is a member of the Investor Compensation Scheme in Malta. The Investor Compensation Scheme pays compensation, subject to certain limits, to eligible consumers if an authorised investment firm fails. 

17.2. Further information may be obtained from http://www.compensationschemes.org.mt

18. Charges

18.1. The Client agrees to pay MZI, on demand, its applicable commissions and other fees (including, without limitation to the generality of the aforesaid, any performance and/or incentive fees) due in respect of the provision by MZI of any of the Services. MZI undertakes that all commissions and other fees payable to / charged by MZI shall be provided to the Client by means of a durable medium. Current “Schedule of Commissions and Fees” is hereby being attached. In instances where the amount of the fee / charge cannot be ascertained, the method / rate used in calculating that amount will be clearly disclosed prior to providing the Service. MZI shall, in so far as practicable, notify the Client of any proposed changes in commissions and other fees in good time.

18.2. The Client also agrees to pay MZI, on demand, in addition to its commissions and/or fees, any duty, VAT or other tax whatsoever arising in respect of any of the Services provided. MZI shall not be required to give the Client prior notice of the imposition of, or variation in, any duty, VAT or other tax arising in respect of any of the Services.

18.3. MZI’s commission and/or fees may be shared between MZI, any associated entity and/or any other third party. In addition MZI may receive remuneration from any other party in connection with transactions entered into for and on behalf of the Client and MZI shall be entitled to retain any remuneration so received.  Details of any such remuneration is as per Schedule of Commission and Fees, forming part of these Terms.

19. Data Protection and Confidentiality

19.1. MZI shall respect and protect the confidentiality of all information concerning the Client and shall not, without the Client’s prior consent, disclose any such information to a third party except in the proper performance of these Terms or as required by law.

19.2. MZI maintains strict information security policies designed to prevent unauthorised access to the Client’s information. However the Client’s personal information may be shared with third parties in the course of providing a Service to the Client and for the prevention and detection of any criminal activity which MZI is bound to report.

19.3. The Client shall have the right to require access to his/her personal data. In certain circumstances, the Client may request the revision of any inaccurate, incomplete or immaterial personal data.

20. Marketing Material

20.1. The Client agrees to receive direct marketing material related to financial products. 

20.2. The Client’s has a right to request MZI to refrain from sending any marketing material by informing MZI in writing.

21. Amendment and Termination

21.1. MZI may amend any provision of the Terms provided that any material change which might give rise to an obligation on the part of MZI shall be notified to the Client in good time.

21.2. The Agreement may be terminated at any time by either party with immediate effect upon giving written notice to the other.

21.3. The termination of the Agreement shall be without prejudice to any other rights or remedies MZI may be entitled to hereunder or at law and shall not affect the coming into or the continuance in force of any provision of the Agreement which is expressly or by implication to come into effect or to continue in effect after such termination.

22. Governing Law and Jurisdiction

22.1. The Agreement shall be governed by and construed in accordance with Maltese law and the parties hereto agree to submit to the non-exclusive jurisdiction of the Maltese courts.

Best Execution Policy

This policy has been drafted in line with the Markets in Financial Instruments Directive (MiFID) and this document is meant to provide you with the relevant information about MZI’s Order Execution Policy.

Orders shall be executed according to the Company’s Order Execution Policy in order to obtain the best possible results or “Best Execution” when executing orders for the client. The best possible results takes into account:

• price 

• costs 

• speed 

• likelihood of execution and settlement 

• size and nature of the order

• market impact 

• any other consideration directly related to the execution of the order or the transaction.

1. Execution Venues – MZI will execute the Client’s orders:

• Directly on a regulated market or a Recognised Investment Exchange 

• Through third party / parties with whom an agreement is in place. MZI will satisfy itself that the best execution obligation is satisfied.

• Through Fund Management Companies with whom an agreement is in place. MZI will satisfy itself that the best execution obligation is satisfied.

MZI will endeavour to place orders with the third party that is most appropriate for the transaction in question, keeping in mind the commitment to obtain the best possible result when executing orders.

MZI may transmit an Order to a third party for execution on the client’s behalf, acting in the best interest of the client.

In circumstances where the client provides MZI with specific instruction on how an order may be executed, and if MZI has accepted, then that order will be executed in accordance to the instructions of the client. This circumstance may result in MZI not obtaining the best possible result in the execution of the order.

2. Execution of Client’s Order

Client orders must be executed fairly and promptly and in accordance with the time of their reception. 

All orders relative to instruments of the same characteristics must be carried out sequentially, in the order that they were received by the MZI. Clients’ Money or Clients Instruments, if these are available, must be promptly and correctly delivered in settlement as promptly as possible. On sales/redemption of instruments, Clients Money must be made available to the client as promptly as possible, dependent on the day of settlement of the trade.

Client orders can only be aggregated if the client is not disadvantaged, in any way, by the aggregation. 

For the purpose of executing orders on behalf of the Client in accordance with Terms of Business, the company is empowered to affect any trade or transaction in its own name and on its own behalf and that unless the Company shall be in receipt of cleared funds by settlement date the company shall not be required to transfer any instruments in the name and for the benefit of the Client.

Due to circumstances beyond control, MZI may execute orders in a method that differs from this policy but commits to execute orders on the best terms available to the company at the time, acting for the best interest of the clients. 

MZI shall review this policy on a regular basis and keep clients updated of any material changes.

Conflicts of Interest Policy

MZI shall avoid Conflicts of Interests where this is possible. MZI, any connected entity, its directors and employees shall avoid placing themselves in a position whereby a conflict of interest with a client may arise. Directors and all officers are bound to inform the Compliance Officer if they feel a situation may give rise to a conflict of interest. 

The Services provided by the Company to the Client in this Agreement are not to be deemed exclusive and the Company shall be free to render Services to other clients and to retain any benefit or profit received thereby.

MZI hereby brings to the clients’ attention that the company has been a Sponsor and Representative in Malta for Lloyds Investment Funds Limited, Lloyds Gilt Fund Limited and Lloyds Money Fund Limited since 1st July 2006.

MZI, its directors and employees shall avoid placing themselves in a situation where a conflict of interest arises. However it is understood that MZI or any director, officer or employee thereof may have an interest, relationship or arrangement that is material in relation to any trade effected on behalf of the Client and it is hereby agreed that any person so interested shall be entitled to retain any benefit or profit received and shall not be liable to account therefore to the Client by reason only of such conflict. MZI declares that it has in place adequate internal procedures to ensure that the Client is in all cases treated fairly and that risks of damage to client interests will be prevented.

The Company, any entity connected with MZI, its directors and employees may:

(i) trade as principal for the account of the Company or any connected company by selling or buying Instruments; or

(ii) have or hold a dealing position in the investment concerned or a related investment; or

(iii) receive payments or any other benefits for giving business to the form with which the clients’ order is placed; or

(iv) buy or sell units in a collective investment scheme on behalf of the Client when the Company, any entity within the MZI, any director, or employee thereof is the promoter, manager or advisor of the scheme (or a director, officer or employee of the promoter, manager, adviser or the scheme); or

(v) Trade or effect any transaction whatsoever in Instruments on behalf of the Client when the Company or any entity within MZI is involved in a new issue, rights issue, takeover or similar transaction concerning the said Instruments.

MZI hereby brings to the Client’s attention the conflicts of interest referred above and commits to disclose any other conflicts of interest which may arise with regards to products promoted by MZI or the services provided by its related companies. In the provision of its services, MZI will seek to ensure that it always acts in the Client’s best interests.