1. Why we have this policy
A conflict of interest arises when what is good for Lumos, a partner or a member of staff could be different from what is good for you. This policy explains where that can happen and how we manage it. It applies to everyone who works for Lumos.
2. We sell, buy and set the price
2.1 When you buy, Lumos sells metal to you. When you sell, Lumos buys it back. We also set the buy and sell prices.
2.2 We earn from the difference between the buy price and the sell price, called the spread, plus the fees listed in the Key Facts. This means we earn more when spreads are wider and when customers trade more.
3. How we keep pricing fair
- Our prices follow a live world market price feed. Our spread on top of it is set in advance and published in the Key Facts.
- Every customer in the same channel sees the same price at the same moment. We do not change prices for one customer.
- Only a senior approver can change spreads, and every change is recorded.
- If the market feed is late or unreliable, buying and selling pause automatically, so no one trades on an old price.
- We do not trade against your orders or use them to gain an advantage for ourselves.
- We do not encourage you to trade more often than you want to. The app gives no buy or sell tips.
4. Partners
4.1 Some customers reach Lumos through another company's app. That partner receives an agreed share of the spread, and may set its own fee within limits we approve.
4.2 Partners set their own fees for their customers, but the underlying metal price follows the same market feed. Partners must show their customers the full price and fees before they confirm.
5. Our own metal
5.1 Lumos also holds its own stock of metal, so that it can fill orders quickly. Our own stock is recorded separately from customer holdings.
5.2 We check every day that the metal held for customers covers at least 100% of what all customers own. Customer metal is never used to cover Lumos's own needs.
6. Vault and suppliers
We choose the vault operator, refiners and metal suppliers on price, quality, security and reliability. Staff may not accept payments or benefits from them in return for business. Lumos has no ownership links with its vault operator or suppliers.
7. Our staff
- Staff may not use what they learn about customer orders to trade for themselves or anyone else.
- Staff who hold a Lumos account follow the same prices and rules as customers, and their accounts are monitored.
- Staff tell us about any outside interest that could conflict with their role.
8. Records and review
We keep a record of the conflicts we have identified and how we manage them. We review this policy at least once a year, and whenever our business changes in a way that could create a new conflict.
9. Raising a concern
If you think we have not handled a conflict fairly, tell us at [email protected]. We treat it as a complaint, as set out in the Terms and Conditions.