• Regulatory Status

The Investment Firms Prudential Regulations came into force on 1 January 2022, and require all UK MiFID investment firms to make a public disclosure concerning their adherence to the regulations. The required disclosure is intended to increase transparency and provide an insight into how HCFX is operated and governed. For the purposes of this disclosure HCFX is categorised as a non-SNI MIFIDPRU firm by reference to a series of permission-based and quantitative thresholds. The IFPR disclosures have been reviewed and approved by the Board of Directors of HCFX.

The EU adopted a new harmonised prudential regime which has applied to all investment firms authorised in the EU since June. The new Investment Firm Regulation and Directive (IFR/IFD) requires HCFX SIM to meet certain disclosure requirements which are intended to impose market discipline on the firm to ensure it remains well capitalised.

HCFX is obligated to ensure that, when clients place an order with our dealing team, we take all sufficient steps to provide you with the best possible overall result on a consistent basis. This is not solely about achieving the best price for an individual trade, there are additional factors which our dealing team must take into account when executing an order such as costs, speed, likelihood of execution and settlement, and any other considerations which are relevant to client orders. This regulatory requirement is known as ‘best execution’ and arises as a result of HCFX’s MIFIDPRU status and business activities. Our Order Execution policy details how we strive to meet this requirement.

HCFX SIM is obliged to ensure that, when clients place an order with our dealing team, we take all sufficient steps to provide them with the best possible overall result on a consistent basis. This is not solely about achieving the best price for an individual trade, there are additional factors which our dealing team must take into account when executing an order such as costs, speed, likelihood of execution and settlement, and any other considerations which are relevant to client orders. This regulatory requirement is known as “best execution” and arises as a result of HCFX SIM’s MIFID status and business activities. Our Order Execution policy details how we strive to meet this requirement.

As a regulated investment firm, HCFX is required to take appropriate steps to identity, prevent, and manage actual and perceived conflicts of interest which may arise in the course of HCFX providing services to clients. Conflicts of interest can arise in different forms, including between HCFX and clients, between clients of HCFX, and between employees of HCFX and our clients. Our Conflicts of Interest policy applies to all HCFX employees, and our Compliance team monitors adherence on an ongoing basis.

HCFX SIM is required to take appropriate steps to identify, prevent and manage actual and perceived conflicts of interest which may arise in the course of HCFX SIM providing services to clients. Conflicts of interest can arise in different forms, including between HCFX SIM and clients, between clients of HCFX SIM and between employees of HCFX SIM and our clients. Our Conflicts of Interest Policy applies to all HCFX SIM employees and Compliance Team monitors adherence on an ongoing basis.

The recast Markets in Financial Instruments Directive (2014/65/EU) (MiFID II) and new Markets in Financial Instruments Regulation (EU) 600/2014 (MiFIR) were published in the Official Journal of the European Union (EU) on 12 June 2014 and came into effect on 3 January 2018. Among the main objectives pursued by the new legislation, which has largely replaced the previous one, are those of strengthening investor protection and transparency, through the provision of stringent requirements on the organisation and conduct of business rules for financial intermediaries as well as on the transparency and supervision of financial markets. In order to provide an understanding of the impacts, the main drivers brought about by the new regulations are outlined below: - specific statement containing the reasons why a service or financial instrument is appropriate for the client; - periodic assessment of the suitability of the portfolio held by clients; - stricter procedural rules on the realisation, selection and distribution of financial products in relation to the type of client (so-called Target Market); - broadening of the scope of application of the obligation to report to the Supervisory Authorities the transactions arranged by customers, together with the relevant identification data, on the financial instruments subject to this obligation; - more information on costs and charges as well as on the incentives associated with the actual provision of investment services; - reporting of financial instruments held by clients; - recording of telephone conversations or communications which will or may give rise to transactions.

As an authorised firm, HCFX takes complaints seriously and ensures that they are investigated thoroughly and resolved fairly in line with the rules and regulations issued by the Financial Conduct Authority (FCA). Whilst HCFX endeavours to resolve complaints through our established policy and procedure, if HCFX fails to resolve the issue, certain clients may also have additional redress options through a third party. HCFX Investment Services - We will provide a final response to complainants within 8 weeks of receiving any such complaint. HCFX Payments Services - We will provide a response to eligible complainants within 15 business days.

HCFX takes complaints seriously and ensures that they are investigated thoroughly and resolved fairly in line with the rules and regulations issued by Banca d’Italia. Complaints handling for HCFX Payments Services are subject to Transparency Disclosure and additional guide issued by the Financial banking Arbitrator.