1.1 This Order Execution Policy (“the Policy”) is provided you (our Client or prospective Client) in accordance with the applicable laws and it is required to take all reasonable steps to act in the best interest of its Clients. This Policy applies for all clients, excluding eligible counterparties.
This Policy applies to the Company’s execution of orders on behalf of retail Clients and professional Clients as defined by Markets in Financial Instruments Directive (MiFID II) 2014/65/EU. Upon acceptance of a Client order and when there is no specific client instruction regarding the execution method, the Company will execute an order in accordance with this Policy.
In our dealings with the Client, we have a general duty to act honestly, fairly and professionally, considering the Client best interest. In relation to order execution, the Company is required to take all sufficient steps to obtain the best possible result when executing Client orders or when placing orders with, or transmitting orders to, other entities to execute. The definition of best possible result will vary and the Company must consider a range of execution factors and determine their relative importance based on the characteristics of its Clients, the orders that we receive and the markets in which we operate. These factors are further described in this Policy.
When executing orders, the Company will take all sufficient steps to obtain the best possible result under the circumstances for the Client considering price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of the order.
When considering the best executing factors, the Company considers:
4.1 Whenever there is a specific instruction from or on behalf of a Client (e.g. fills in the required parts on the Company’s trading platform when placing an Order), the Company shall arrange – to the extent possible – for the execution of the Client order strictly in accordance with the specific instruction. It is noted that the specific instruction may prevent the Company from taking the steps in the Policy to obtain the best possible result for the Client.
4.2 Trading rules for specific markets or market conditions may prevent the Company from following certain of the Client’s instructions.
5.Execution on Client Orders
The Company shall satisfy the following conditions when carrying out Client Orders:
5.1 Ensures that orders executed on behalf of Clients are promptly and accurately recorded and allocated;
5.2 Carries out otherwise comparable Client orders sequentially and promptly unless the characteristics of the order or prevailing market conditions make this impracticable;
5.3 Informs a retail Client about any material difficulty relevant to the proper carrying out of orders promptly upon becoming aware of the difficulty.
6.1 By entering into an Agreement with the Company for the provision of Investment Services, the Client is consenting to an application of this Policy on him.
7.1 The Company reserves the right to review and/or amend its Policy and arrangements whenever it deems this appropriate without notice to the Client. Should you require any further information and/or have any questions about conflicts of interest please direct your request and/or questions to email@example.com.