The target market for our CFDs include the following classes of Consumers:

Consumers who satisfy each of the following criteria:

• Consumers above the age of 18 and below the age of 70;
• Consumers who have the requisite knowledge for the purposes of trading in CFDs;
• Consumers who can accept losses that can be as great as the sum of their deposits
• Consumers who have high investment risk appetites; and
• Consumers with a short-term investment horizon.

For those Consumers who satisfy the above criteria:

Those Consumers who satisfy the above criteria and wish to trade CFDs for investment purposes, including for one or more of the following purposes:

• Speculative trading;
• Hedging (including hedging exposure to underlying assets and hedging positions taken in relation to other CFDs); and
• Gaining exposure to price movements of the underlying assets including where exposure to such underlying assets may not be otherwise as readily available, or where such exposure is required at short notice,

Target market – criteria, scope and key attributes

Further details regarding BCR’s target market for CFDs trading is set out below.

Our products are not compatible with the needs of clients who:

• are seeking capital protection or stability;
• are risk-averse;
• are seeking regular or otherwise predictable returns on their investments;
• cannot afford to bear losses;
• are vulnerable clients as described below.

Consumers who fall into any of the categories set out immediately above, are not in the target market for CFDs.

Consumers for whom CFDs are unsuitable

CFDs are generally unsuitable for the following classes of Consumers:

• Consumers below the age of 18;
• Consumers who reside in a country which restricts or prohibits trading in CFDs;
• Consumers who are in financial hardship or going through bankruptcy;
• Consumers who do not have the requisite knowledge for trading in CFDs;
• Consumers who have a low tolerance to risk;
• Consumers who do not have the ability and willingness to lose the sum of their deposits;
• Consumers who have low levels of literacy or numeracy, financial literacy and technological literacy;
• Consumers who wish to trade using their retirement savings, income, or cash that the Consumer relies on for living expenses or personal savings;
• vulnerable Consumers, including Consumers who are vulnerable for any of the following reasons:
  > elderly or suffering an age-related impairment;
  > suffering from elder or financial abuse;
  > job loss;
  > suffering from mental or other forms of serious illness affecting capacity;
  > suffering from any form of addiction; or
  > any other personal or financial circumstances causing significant detriment.
  

Consumers who are in any of the above categories are not in the target market for CFDs.

Distribution conditions

Our CFDs are distributed by:

• BCR; and
• various third parties are also involved in the distribution of our CFDs, including authorised representatives and referrers (each a Distributor, and together, the Distributors).

We will take reasonable steps to ensure that both we and any Distributors distribute the financial product to the identified target market.

To ensure that the distribution strategy is consistent with the identified target market, we have several processes in place to ensure that the Consumers who are potential clients fall within the identified target market. For instance, BCR will verify whether potential clients fall within the identified target market during the onboarding process, before approving them and allowing them to trade CFDs on the trading platform. Also, BCR will provide appropriate training and scripts to staff who communicate information to clients.

We will also take reasonable steps to ensure that our marketing strategy and the marketing strategy of Distributors is targeting potential clients who fall within the identified target market. No Distributor may release marketing materials without obtaining our prior written consent. As above, any new marketing campaign shall be reviewed and approved by the product issuer prior to its publication, to check that it does not contain elements which may attract potential clients outside of the intended target market.

Monitoring and reviewing the TMD

Periodic reviews

We will perform periodic reviews of this TMD.

The first review of this TMD occurred on 5 October 2022. Subsequent reviews of the TMD will occur at the very least on each anniversary of the first review date, or if a review triggers occurs.

Review triggers – additional reviews

We will also review the TMD where the following review triggers occur

• where there are significant dealings (issuing of CFDs) in BCR’s CFDs, which are not consistent with the target market or this TMD. This trigger occurs where significant distribution is occurring outside the target market, and does not refer to any one particular dealing in CFDs
• where a Distributor has reported a significant number of complaints or noted any relevant complaint trends;
• where we have received a significant number of complaints or noted any relevant complaints trends;
• where we have detected significant issues with the distribution of our CFDs through our monitoring of our own day-today activities, or the monitoring and supervision of our Distributors.

Distributors – information collecting and reporting requirements

As part of the process of monitoring and reviewing the TMD to determine whether it is still appropriate, each Distributor must provide the following to us on a quarterly basis (subject to where no reporting is required, based on the particular reporting requirements and conditions set out below), within 10 business days of the end of each calendar quarter – 31 March, 30 June, 30 September and 31 December, each year:

Complaints data

• complaints data – information about the complaints received, including the number of complaints received (but only where the Distributor received complaints in relation to the product during the reporting period);

Other Data

• Consumer feedback, including regarding performance of the product (but only where such feedback was received during the reporting period);
• requests for information that the Distributor has received from clients (but only where such requests were received during the reporting period);
• percentage of sales to clients who are not in the target market (but only where such sales occurred during the reporting period); and
• volume of sales (but only where such sales occurred during the reporting period).

Further reporting requirements

Each Distributor must report

• Any significant dealing outside the TMD, as soon as practicable and in any event within 10 business days of such dealing.

No party may engage in the distribution of our CFDs unless they have entered into an agreement with us.

Please contact us for further information and for a copy of our prescribed reporting template, if you wish to become a Distributor of our CFDs.

We reserve the right to amend the TMD at any time if such amendment is needed as a result of any changes to the law or regulations, regulatory guidance, or for any reason we consider as a proper reason to amend the TMD.