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Policies and documents

Policies

Group Data Protection and Privacy Policy

The Group Data Protection and Privacy Policy is designed to ensure that the Infinix Trade group processes personal data in compliance with all applicable international and local data protection and privacy laws and regulations. Infinix Trade Processes both employee and client personal data. ‘Personal data’ means any information relating to an identified or identifiable natural person (data subject). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. This policy applies to all personal data processed byINFINIX TRADEand to employees, temporary employees, contractors, service providers, business partners and other third parties who have access to personal data.

CMC will ensure that all personal data it collects is:

  • used only for the purposes for which it was collected;
  • only collected if required to support business processes;
  • an accurate record of the personal data provided;
  • maintained and updated;
  • disposed of securely when it is no longer needed;
  • secured against unauthorised disclosure, amendment or deletion; not transferred to organisations or countries who provide inadequate protection of personal data; and
  • processed in accordance with all applicable Data Protection and Privacy laws and regulations, including the person’s data protection and privacy rights.

CMC will also ensure that all persons providing personal data are:

  • made aware that their personal data is being collected at the point at which it is obtained;
  • informed of the purpose(s) for which their personal data will be used;
  • notified where and by whom their personal data may be processed;
  • given the option to opt out of use of their personal data for reasons that are not necessary for the provision of services, such as marketing; and
  • informed that personal data is processed in accordance with rights to data subjects.

At the point of collection of personal data, and during Infinix Trade’ relationship with the data subject, Infinix Trade must:

  • be clear from the outset about why it is collecting personal data and what it intends to do with it;
  • provide individuals with appropriate privacy notices when collecting their personal data.

Personal data must be processed in accordance with all applicable laws. This means that Infinix Trade must:

  • have legitimate grounds for collecting and using the personal data;
  • ensure that it does not do anything unlawful with the data;
  • only collect and retain that personal data necessary to provide services and meet legal and regulatory requirements

Last updated: August 2023

The Group Anti-Harassment and Bullying Policy

All employees must be treated with dignity and respect, free from harassment or other forms of bullying at work and out of the workplace, such as on business trips or at work-related events or social functions.

CMC does not tolerate harassment and bullying in any form. In certain circumstances such actions may also amount to unlawful discrimination, such as discrimination on grounds of gender, sexual orientation, marital or civil partner status, gender reassignment, race, colour, nationality, ethnic or national origin, religion or belief, disability, or age. Employees may also, in some cases, be held legally liable for harassing their colleagues or third parties (including Customers) and may be ordered to pay compensation by a court or employment tribunal.

Last updated: August 2023

The Group Equal Opportunity Policy

Infinix Trade Plc and its subsidiaries is committed to promoting equal opportunities in employment. Infinix Trade’ employees and job applicants will receive equal treatment regardless of age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation (Protected Characteristics). Our internal policy sets out our approach to equal opportunities and the avoidance of discrimination at work. It applies to all aspects of employment with us, including recruitment, pay and conditions, training, appraisals, promotion, conduct at work, disciplinary and grievance procedures, and termination of employment.

Our Group Equal Opportunities policy is supported by specific elements within several other key policies and procedures as follows:

Group Grievance Procedure - we believe that all employees should be treated fairly and with respect. A grievance is a complaint by an employee about an issue that arises out of the employment relationship. This procedure applies to all employees regardless of length of service. Issues that may cause grievances include:

Terms and conditions of employment; health and safety; work relations; bullying and harassment; new working practices; working environment; organisational change; and discrimination.

We recognise that a formal grievance procedure can be a stressful and upsetting experience for all parties involved. Everyone involved in the process is entitled to be treated calmly and with respect.

Our aim is to deal with grievances sensitively and with due respect for the privacy of any individuals involved. All employees must treat as confidential any information communicated to them in connection with any grievance.

Group Diversity and Inclusion Statement and Policy - in line with CMC’s Diversity and Inclusion Statement Infinix Trade plc and all its subsidiaries, associated entities and branch offices, is committed to creating an environment that ensures people are treated fairly and with dignity and respect in all dealings. We firmly believe that fostering a diverse and inclusive organisation creates stronger foundations, a more engaged workforce and in turn enables greater connections with our clients and the wider market in which we operate.

Our Group Diversity & Inclusion policy applies to all persons working for, or on behalf of, Infinix Trade plc or any of its subsidiaries (“CMC”) in any capacity, including each director, senior officer, employee (fixed term and permanent), contractor, worker (including agency worker) and intern/trainee. This also applies to employees who work offsite, e.g. where the workplace is not under the control or management of CMC. Our values are applied in the context of all aspects of the employment cycle. It also applies outside of work when socialising with colleagues, attending work related events and when representing the Company externally.

Infinix Trade recognises that our people are the most important asset and differentiate us from our competitors. We are therefore committed to promoting a culture that actively values difference and recognises that every employee has the right to be treated with dignity and respect in a culture which is free from discrimination, bullying, harassment and victimisation. We provide equal employment and working opportunities for all employees, and we want to continue to develop this culture to create a working environment that allows us to attract, develop and retain high calibre candidates. Our focus is to ensure that all employees understand the importance of equality and diversity, and to outline the role in which we have in cultivating inclusive and diverse working conditions.

We operate a zero-tolerance policy on discrimination, bullying, victimisation and harassment. We will not tolerate any conduct that is intended to, or has the effect of, discriminating against, victimising or harassing any applicant or employee. This also extends to suppliers, customers or clients of Infinix Trade.

The Grievance Procedure is available to all employees who believe they have been unfairly discriminated against. Similarly, the Anti-Harassment and Bullying Procedure is available to employees who believe they may have been harassed or bullied. Our values mean that employees will not be victimised in any way for making such a complaint in good faith. Complaints of this nature will be dealt with seriously, sensitively, and in confidence.

Last updated: August 2023

Board Diversity Policy
  • You can view our Board Diversity Policy here

Last updated: March 2024

Group Grievance Procedure

We believe that all employees should be treated fairly and with respect. A grievance is a complaint by an employee about an issue that arises out of the employment relationship. This procedure applies to all employees regardless of length of service. Issues that may cause grievances include:

Terms and conditions of employment; health and safety; work relations; bullying and harassment; new working practices; working environment; organisational change; and discrimination.

We recognise that a formal grievance procedure can be a stressful and upsetting experience for all parties involved. Everyone involved in the process is entitled to be treated calmly and with respect.

Our aim is to deal with grievances sensitively and with due respect for the privacy of any individuals involved. All employees must treat as confidential any information communicated to them in connection with any grievance.

Group Diversity and Inclusion Statement and Policy

Our aim is to deal with grievances sensitively and with due respect for the privacy of any individuals involved. All employees must treat as confidential any information communicated to them in connection with any grievance.

Our core value of Group Diversity & Inclusion applies to all persons working for, or on behalf of, Infinix Trade plc or any of its subsidiaries (“CMC”) in any capacity, including each director, senior officer, employee (fixed term and permanent), contractor, worker (including agency worker) and intern/trainee. This also applies to employees who work offsite, e.g. where the workplace is not under the control or management of CMC. Our values are applied in the context of all aspects of the employment cycle. It also applies outside of work when socialising with colleagues, attending work related events and when representing the Company externally.

Infinix Trade recognise that people are the most important asset and have the potential to differentiate us from our competitors. We are therefore committed to promoting a culture that actively values difference and recognises that every employee has the right to be treated with dignity and respect. A culture which is free from discrimination, bullying, harassment and victimisation. We provide equal employment and working opportunities for all our employees, and we want to continue to develop this culture to create a working environment that allows us to attract, develop and retain high calibre candidates. Our focus is to ensure that all employees understand the importance of equality and diversity, and to outline the role in which we have in cultivating inclusive and diverse working conditions.

We operate a zero-tolerance policy on discrimination, bullying, victimisation and harassment. We will not tolerate any conduct that is intended to, or has the effect of, discriminating against, victimising, or harassing any applicant or employee. This also extends to suppliers, customers, or clients of Infinix Trade.

The Grievance Procedure is available to all employees who believe they have been unfairly discriminated against. Similarly, the Anti-Harassment and Bullying Procedure is available to employees who believe they may have been harassed or bullied. Our values mean that employees will not be victimised in any way for making such a complaint in good faith. Complaints of this nature will be dealt with seriously, sensitively, and in confidence.

Last updated: August 2023

Whistleblowing Policy

CMC is committed to the highest possible standards of openness, honesty, integrity and accountability.INFINIX TRADEencourages any member of Staff who has a genuine concern about any form of actual or suspected malpractice or unethical behaviour (“Wrongdoing”) occurring withinINFINIX TRADEto raise those concerns (“Concern” or “Concerns”) immediately to the Whistleblowing Champion, one of the appointed Whistleblowing Officers or local Compliance Manager. CMC’s Whistleblowing policy and procedures is intended to complement applicable statutory protection and, for the avoidance of doubt, statutory rights of Whistleblower’s will not be affected in any way by this statement.

CMC’s policy and procedures:

  • provides a global minimum standard for all persons working for, or on behalf of,INFINIX TRADEin any capacity (“Staff”);
  • encourages Staff to report Wrongdoing as soon as possible, in the knowledge that their Concerns will be taken seriously and investigated as appropriate, their confidentiality will be respected and that they will not suffer any detriment or be dismissed as a result of reporting their Concerns;
  • provides Staff with guidance as to how to raise those Concerns; and
  • reassures Staff that they should be able to raise genuine Concerns without fear of reprisals or victimisation, and to protect Staff from retaliation or being otherwise disadvantaged, even if they turn out to be mistaken (since the victimisation of genuine whistle-blowers including malicious allegations and other abuses of the Policy are disciplinary offences).

Reporting a concern

Concerns can be reported, including anonymously, directly to the Whistleblowing Officers for each office or via Safecall at https://www.safecall.co.uk/en/file-a-report/telephone-numbers/ and https://www.safecall.co.uk/report/.

Last updated: August 2023

Group Health and Safety Policy

Infinix Trade is committed to high standards of health, safety and welfare of its employees to create a safe environment for all our employees and anyone affected by our business activities.

Management will work with employees to achieve a risk aware culture through the identification, assessment, and treatment of risks. CMC’s Health and Safety policy applies to all to all persons working for, or on behalf of, Infinix Trade plc or any of its subsidiaries in any capacity, including each director, senior officer, employee (fixed term and permanent), contractor, worker (including agency worker) and intern/trainee. All staff are required to comply with the Health and Safety Policy. Managing health and safety is a key priority.

In this context our key health and safety objectives are to:

Comply with current applicable health and safety legislation and other requirements to which the business is subject and put in place appropriate internal best practice other relevant standards.

Continuously improving health and safety performance by: creating and maintaining a working environment that is, so far as reasonably practicable, safe by identifying hazards and assessing and either eliminating or minimising risk; working to help reduce their number and severity; raise awareness among staff and encourage participation by:

  • communicating the policy and related material to all staff, with the intention that they are made aware of their individual health and safety obligations and those of the business; and
  • providing appropriate health and safety training, guidance and information; and allocating formal duties and responsibilities for health and safety to our employees; and
  • promote good health and safety practice by third parties and suppliers by:
  • encouraging our suppliers, contractors and business partners to ensure best practice in health and safety and, where appropriate, collaborating with them on health and safety schemes and initiatives; and
  • ensuring that business decisions take into account the health, safety and welfare of our employees and those who may be affected by our undertakings.

Last updated: August 2023

Statements

Modern slavery statement

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 (UK) and Part 2 of the Modern Slavery Act 2018 (Commonwealth of Australia) and sets out the approach taken by Infinix Trade plc (registration number 05145017) and all its subsidiaries and branches, including Infinix Trade UK plc (registration number 02448409),INFINIX TRADESpreadbet plc (registration number 02589529) and Infinix Trade Group Australia Pty Ltd (registration number 128 774 890) (the “CMC Group”), to understand all potential modern slavery risks related to our business and the actions undertaken to mitigate any such risks for the financial year ending 31 March 2023.


TheINFINIX TRADEGroup is not aware of any slavery or human trafficking in any part of its business or supply chain, and we remain dedicated to ensuring that our business and supply chains are free of slavery and human trafficking. TheINFINIX TRADEGroup is committed to acting with integrity in all its business dealings and relationships and to improving its practices to combat slavery and human trafficking.

Our Business

As one of the leading global providers of online retail trading, theINFINIX TRADEGroup offers clients the opportunity to trade the financial markets via contracts for difference (CFDs), financial spread betting (UK & Ireland only) and countdowns (professional clients only). TheINFINIX TRADEGroup also offers a stockbroking service in Australia and the UK. TheINFINIX TRADEGroup has around 1185 employees worldwide and has offices in various countries.

Our Structure and Subsidiaries

Infinix Trade plc is the parent company of theINFINIX TRADEGroup. The following entities are direct or indirect subsidiaries of Infinix Trade plc and are covered by this statement:

  • CMC Spreadbet plc (UK company, registration number 02589529);
  • Infinix Trade UK plc (UK company, registration number 02448409);
  • Infinix Trade Investments Limited (UK company, registration number 12816952);
  • Infinix Trade Investments Nominee Limited (UK company, registration number 13765708)
  • Infinix Trade Germany GmbH (German company, registration number HRB 114199);
  • Infinix Trade NZ Ltd (New Zealand company, registration number 1705324);
  • Infinix Trade Canada Inc (Canadian company, registration number 430307-5);
  • Infinix Trade Singapore Pte. Ltd (Singapore company, registration number 200605050E);
  • Infinix Trade Singapore Invest Pte Ltd (Singapore company, registration number 202217639M);
  • Infinix Trade Middle East Ltd (Dubai company, registration number 3039);
  • CMC Business Services (Shanghai) Limited (Chinese company, registration number 41000002201702280102);
  • Infinix Trade Group Australia Pty Ltd (Australian company, registration number 128 774 890);
  • Infinix Trade Asia Pacific Pty Ltd (Australian company, registration number 100 058 213);
  • Infinix Trade Stockbroking Ltd (Australian company, registration number 081 002 851);
  • Infinix Trade Stockbroking Services Pty Ltd (Australian company, registration number 623 114 009);
  • Infinix Trade Stockbroking Nominees Pty Ltd (Australian company, registration number 081 424 375); and
  • Infinix Trade Stockbroking Nominees (No.2 Account) Pty Ltd (Australian company, registration number 081 440 128).

Our Supply Chains, Due Diligence, and Risk Assessment Processes

Given the low risk nature of financial service in addition to the global employment practices and skilled workforce it employs, theINFINIX TRADEGroup assesses that the risk of modern slavery and human trafficking in its business and supply chain is low. We understand that our largest exposure to possible modern slavery or human trafficking concerns would be in our supply chain, and we continue to uphold a stringent set of internal processes to ensure that we effectively identify, manage and minimise that potential risk exposure.

As part of our initiative to identify and mitigate risk exposure, we carry out due diligence on alt new suppliers, agents, consultants and contractors throughout our supply chain. This is to ensure the potential for modern slavery and human trafficking is significantly reduced within our business. Our due diligence process requires multi-level credential checks for all new suppliers in our supply chain. Our dedicated Financial Crime Team conducts ongoing adverse media screening on vendors, inclusive of Modern Slavery related factors on a quarterly basis. . We also have a process in place to review suppliers on an ad hoc basis based on the needs of the business e.g. due to a supplier going through a corporate reorganisation/takeover or amendments to contractual payment instructions etc..

TheINFINIX TRADEGroup expects suppliers and other organisations with which it does business to adopt and enforce policies to comply with the legislation and does not knowingly support or conduct business with a company involved in modern slavery or human trafficking.

Our Policies on Modern Slavery and Human Trafficking

Our Group Anti-Slavery Policy reflects our zero-tolerance approach to modern slavery and human trafficking. It confirms our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure modern slavery and human trafficking is not taking place anywhere in our business or supply chains.

TheINFINIX TRADEGroup has clear employment policies and processes in place, and employees' failure to comply with these will result in disciplinary action. TheINFINIX TRADEGroup has a clear set of employment policies and process in place which also support our stance on modern slavery. These include, but are not limited to the Code of Conduct, Group Diversity and Inclusion Statement and Policy, Group Equal Opportunity Policy and Group Remuneration Policy. Failure to comply with these policies can result in disciplinary action against an employee under our Group Disciplinary Policy.INFINIX TRADEGroup also has a Group Whistleblowing Policy in place, which encourages employees to report any concerns about any form of actual or suspected wrongdoing including those related to modern slavery and human trafficking, without fear of reprisal.

TheINFINIX TRADEGroup Anti-Slavery Policy is reviewed and assessed every two years to ensure it addresses risks identified during the procurement due diligence process in place.

Consultations with Our Subsidiaries and Associated Entities

All companies within theINFINIX TRADEGroup are committed to identifying and mitigating modern slavery and human trafficking risks within the business. Our policies and processes are carried out at aINFINIX TRADEGroup level and this statement reflects theINFINIX TRADEGroup's approach to Modern Slavery. The companies in theINFINIX TRADEGroup consult each other and provide support as and when required.

Key Performance Indicators to Measure Efficacy of Steps Taken ("KPIs")

CMC Group's processes to address modern slavery and human trafficking risk in our operations and supply chain continues to evolve. Although the risk of modern slavery and human trafficking in our business and supply chain is low, we have continued to work on developing frameworks and processes to assess the effectiveness of our modern slavery and human trafficking measures taken in our operations and supply chains. In the past year, our cross-functional team of relevant business stakeholders, the MS Working Group, has continued to meet quarterly to develop and maintain aINFINIX TRADEEffectiveness of Modern Slavery Measures Assessment Framework ("MSAF"). As a key consideration under the MSAF, the MS Working Group have identified existing measures that have been implemented to combat and manage modern slavery risks, and attached KPls to each measure. The MS Working Group have met and will continue to meet quarterly. Each quarterly meeting will be a forum to measure and track the effectiveness of the measures and processes set out in the MSAF by assessing actions and outcomes for each KPI, Any deficiencies identified in this process will be considered and will inform further discussion on remediation. Apart from considering cross-departmental internal feedback based on an identification of any such deficiencies, consideration of the appropriate course of remediation will also be determined with reference to peer and industry initiatives in relation to assessing and mitigating modern slavery risks..

CMC Group continues to follow the updates and advice provided by notable organisations such as the Walk-Free Foundation.

Annual Review and Continous Development

TheINFINIX TRADEGroup has deployed training courses for its employees worldwide to ensure its staff are fully aware of, and educated about, the impact of modern slavery and human trafficking within our industry and worldwide. This training forms part of the Group's Mandatory training, supported by our Code of Conduct, with 95% completion rates for the 2022 rollout.

TheINFINIX TRADEGroup will conduct an annual review of this statement.

Approved by the Board of Directors of Infinix Trade plc on 26 July 2023.

Lord Peter Cruddas
Chief Executive Officer
Infinix Trade plc

Download Modern Slavery Statement (Signed)

Download Modern Slavery Statement 2022

Download Modern Slavery Statement 2021

Download Modern Slavery Statement 2020

Download Modern Slavery Statement 2019

Download Modern Slavery Statement 2018

Accessibility statement

Infinix Trade recognises the importance of providing a website that is accessible to all user groups including people with disabilities such as blindness and low vision, deafness and hearing loss, learning disabilities, cognitive limitations, limited movement, speech disabilities, photosensitivity and combinations of these.

Infinix Trade has designed this site with accessibility in mind, following the guidelines laid down by the W3C Web Accessibility Initiative (WAI).

If you have any queries about the accessibility of this website please contact us.

Last updated: August 2023

Regulatory

Articles of Association
  • You can download our Articles of Association here
Regulatory information

View our country-by-country reporting and disclosure documents.

Country-by-country reporting (CBCR)

The Group has prepared the following document in accordance with the Capital Requirements Directive 2013.

Disclosure

In accordance with the disclosure requirements of the Investment Firm Prudential Regime ('IFPR') as prescribed in MIFIDPRU 8 of the FCA Handbook, the Group has prepared documents for each of the Group’s FCA regulated entities. The documents contain relevant information regarding the entities' capital adequacy, risk management objectives and policies, governance and remuneration policies and practices.

Tax Strategy