360T Compliance


As an authorised firm that operates across more than 90 countries, 360 Treasury Systems AG (360T) is committed to ensuring that it meets and complies with the fundamental principles of doing business in a regulated environment.

The purpose of this Compliance Statement is to provide 360T current and potential customers with a high level confirmation of how 360T commits to ensuring that it meets the rules and regulations that it subject to in so far as it carries out its day-to-day activities.

Access and Use
360T will not deny any customer access to its transactions network provided that customer meets the eligibility criteria set by 360T, is located in a jurisdiction in which 360T can do business and provided that that customer does not fail due diligence tests.

360T will endeavour to ensure that in so far as customers make use of our transactions network they will not be in breach of any local laws or regulatory obligations.

Approved and Authorised Persons
360T maintains a clear and appropriate apportionment of duties and responsibilities among its Directors and Senior Executives, and it is organised in such a way so that there are clear reporting lines and levels of accountability. 360T is committed to ensuring that all persons, both those holding senior positions and all other staff within the Company, would qualify as being ‘fit and proper’.

Business Continuity
360T has put in place appropriate arrangements to ensure that the Company can continue to operate and meet its regulatory obligations in the event of an unforeseen interruption.

Business Principles
360T staff will at all times endeavour to:


  • conduct their business with integrity,
  • conduct their business with due skill and care,
  • pay due regard to the interests of its clients and treat them fairly; and,
  • not put themselves in a position of conflict against a customer, nor knowingly allow a conflict of interest to arise between one customer and another.

Client Classification
360T will only provide its transaction capabilities and post trade services to those wholesale market participants that qualify as eligible counterparties or as professional investors as defined within the context of the EU Markets in Financial Instruments Directive: broadly speaking – Banks, Broker Dealers, Asset Managers, Hedge Funds, Corporate Treasuries and Commodity Trading Advisors. 360T does not provide its services to private investors.

Communications
360T will, in all mediums and in relation to all subjects, aim to communicate with its customers in a manner that is clear, fair and non-misleading.

Confidentiality
360T will at all times, other than for when mandated by a regulatory authority, endeavour to keep confidential any information it holds about a customer, or which it becomes party to in the course of day-to-day business.

Conflicts of Interest
360T endeavors to ensure that neither the Company, nor its staff or other persons linked with 360T, put themselves in such position so as to give rise to an unnecessary potential or actual conflict of interest. Should for any reason a potential or actual conflict be perceived to have arisen, then that conflict will be promptly managed in accordance with effective Company organizational and administrative controls. For example; in relation to any inducements received by 360T from third party suppliers in connection with the provision of investment services or ancillary investment services, we ensure that those are not in conflict with our clients´ interest but are dedicated to maintain and continue improving the quality of our services. Detail information of the conflict policy and inducements can be obtained under compliance@360t.com.

Complaints
360T aims to deliver a high quality service but we recognise that sometimes things can go wrong. When this happens, we will do our best to put matters right quickly. We will listen to your complaint and:


  • treat it seriously, and in confidence;
  • investigate it thoroughly and fairly;
  • resolve it promptly, and informally whenever possible;
  • wherever possible find a remedy and;
  • learn from complaints to improve our services.

Financial Crime
360T takes seriously the need to prevent financial crime and is therefore committed to ensuring that its transaction network is not subject to money laundering, market abuse or any other form of inappropriate conduct. In the event that a customer should be considered to have been acting inappropriately or suspiciously, 360T will issue a report on that customer to the relevant reporting authority.

Gifts and Entertainment
360T recognises that entertaining clients is important to building good business relationships and developing confidence and trust between parties. However, 360T is committed to ensuring that all such entertainment and gifts given or received are appropriate in the circumstances and that it they are not of a kind to call into question the integrity of the Company.

Prudential
360Taims to be prudently compliant at all times and will strive to ensure that it maintains sufficient financial and human resources.

Regulatory Relations
360T is committed to maintaining open and cooperative relationships with all regulatory authorities, and not just those authorities to whom it owes regulatory obligations.

Management
360T believes it has taken care to organise and control its affairs responsibly and effectively, and believes that it has put in place adequate processes and procedures to manage any risks that may from time to time arise.

Rules and Code of Conduct
360T will endeavour to comply will all laws, rules, and guidance to which it is exposed, whether they are contained in legislation, rulebooks or in industry codes of best practice.

System and Controls
360T has put in place systems and controls that it believes to be appropriate in relation to the scale and complexity of its business operations.

Training
360T is committing to ensuring that all its staff receive appropriate training in order to ensure that they have and maintain the skills, knowledge and expertise necessary to discharge the responsibilities that have been assigned to them.

Contact

If you are interested in more information on regulatory matters please contact

Global Head: Regulatory Affairs
regulation@360t.com
360 Trading Networks
Grüneburgweg 16-18/ Westend Carrée
60322 Frankfurt am Main
Phone: +49 69 900 289 0