Last updated: 21 October 2026
1. Purpose and scope
A conflict of interest arises when a person's personal, financial or professional interests, or the interests of GFCRS as an organisation, could influence, or could reasonably be seen to influence, a decision they take for GFCRS.
This policy applies to the Board of Directors, members of the Independent Review Committee, all employees and contractors, and anyone acting on behalf of GFCRS. Compliance is a condition of appointment.
2. Organisational structure and separation of functions
GFCRS is organised into separate functions with distinct responsibilities:
- Board of Directors: sets strategy and policies, appoints the Independent Review Committee and oversees compliance with this policy. The Board does not decide individual complaints.
- Independent Review Committee: reviews disputed complaint outcomes and oversees the quality and consistency of decisions. Its members have no role in membership sales, fee setting or fee collection.
- Claims & Resolution Department: investigates complaints and works towards resolutions. Its staff are not involved in admitting firms, setting their fees or collecting payments.
- Membership & Compliance Department: evaluates applications, conducts annual reviews, issues certificates and manages membership status.
- Investor Support: helps investors use the complaint process and track their cases. It does not decide complaints.
3. Separation of membership fees from complaint decisions
- Membership fees are set and published in principle in advance, are the same for all firms in the same category, and are never linked to the number or outcome of complaints.
- No person who decides or reviews a complaint is rewarded, assessed or paid by reference to membership income, the retention of a member, or the outcome of any case.
- Case handlers do not have access to a firm's fee or payment records, and the membership function has no say in the outcome of complaints.
- A firm cannot avoid or influence a complaint by paying, offering to pay, or threatening to withhold fees. Any such attempt is reported to the Board and may lead to membership action.
- Complaint outcomes are recorded with reasons and are subject to review by the Independent Review Committee, which provides a check on consistency.
4. Identifying conflicts
Conflicts include, but are not limited to, situations where a person:
- holds shares, bonds or other financial interests in a firm that is a member, an applicant or the subject of a complaint (other than through collective investment funds they do not control);
- is, or has in the past three years been, employed by, a director of, or an adviser to such a firm;
- has a close family member or personal relationship with someone at such a firm, or with a complainant;
- holds a trading account with a firm involved in a matter they are handling;
- has received gifts, hospitality or other benefits from a party to a matter;
- has previously expressed a view on the matter that could suggest they have prejudged it.
5. Declarations and the register of interests
Every director, committee member and employee completes a declaration of interests when appointed, updates it whenever their circumstances change, and confirms it at least once a year. Declarations are recorded in a register of interests maintained by the Board.
Before working on a membership application, an annual review or a complaint, the person assigned must confirm that they have no conflict with the firm or the complainant concerned.
6. Managing conflicts: recusal
Where a conflict exists, the person concerned must not take part in the matter. They must not attend discussions, see confidential papers, vote or try to influence anyone who is handling it. The matter is reassigned to someone without a conflict.
If a conflict is identified after work has started, the person stops immediately and reports it. The matter is reassigned and any decision already taken is reviewed by someone independent of it. Parties may also raise a concern that a person handling their matter has a conflict; such concerns are considered promptly and the outcome is recorded.
7. Gifts, hospitality and other benefits
- Staff and committee members must not accept money, gifts, hospitality or any other benefit from a member firm, an applicant firm, a complainant or anyone acting for them, other than modest refreshments in the normal course of a meeting.
- Any offer of a gift or benefit must be declined and recorded in the register.
- GFCRS does not accept sponsorship, donations or payments from firms other than published membership fees.
8. Personal dealing and outside activities
- Staff and committee members must not open or hold trading accounts with member or applicant firms without prior written approval, and must never use confidential information obtained through GFCRS for personal benefit.
- Outside employment, directorships or consultancy work in the forex and CFD industry require prior written approval from the Board and are recorded in the register.
- Former employees of member firms do not handle complaints about, or evaluate, their former employer for at least three years after leaving.
9. Organisational conflicts
GFCRS does not provide consultancy, advice, marketing or any paid service to firms beyond membership itself, and it does not promote or recommend member firms. Where GFCRS as an organisation could have an interest in the outcome of a matter, for example a complaint involving a firm whose membership is under review, the Independent Review Committee is informed and may oversee the matter.
10. Breaches of this policy
Failure to declare a conflict, or acting despite a conflict, is a serious matter. It may lead to disciplinary action, including dismissal, or removal from the Board or Committee. Decisions affected by an undeclared conflict are reviewed and, where necessary, taken again.
Anyone, inside or outside GFCRS, can report a suspected breach through our contact page. Reports are passed to the Board and handled confidentially. Staff who raise concerns in good faith will not suffer any detriment.
11. Oversight and review
The Board receives a report on the register of interests and on any conflicts and breaches at least once a year, and reviews this policy annually or sooner if needed. Our governance arrangements are described on the Governance & Independence page.