ORDER EXECUTION POLICY
This Order Execution Policy (the “Policy”) is available to both retail and professional clients upon request and is also made available on our Website. The Policy serves to enable clients to make a properly informed decision about whether to utilize the services offered by the Company.
Stocks Forex AF Ltd (the “Company”) is an Investment Firm regulated by the Cyprus Securities and Exchange Commission (“CySEC”) with authorization number 283/15. The purpose of this policy is to establish effective arrangements for obtaining, when the Company, is executing clients’ orders, the best possible result for its clients.
In accordance with the Provision of Investment Services, the Exercise of Investment Activities, the Operation of Regulated Markets and Other Related Matters Law 144(I)/2007, as subsequently amended from time to time (“the Law”), the purpose of this policy is to establish effective arrangements for the Company to obtain, the best possible result for its clients, in a consistent basis when executing orders, taking into account price, costs, speed, likelihood of execution, size, nature specific instructions received from the client or any other consideration relevant to the execution of an order.
The Company cannot guarantee that upon execution of an order the price at which the order is executed will always be better than a price which is or might has been available elsewhere.
In addition, this document aims to set out those arrangements and to ensure compliance with legislative requirements and the departmental and general procedures, and gives an overview on how trades and orders are executed, the factors that may affect the execution’s timing and the way in which market volatility determines the execution of an order.
This policy shall be read in conjunction with the Company’s Terms & Conditions.
The Company solely executes orders in relation to one or more financial instruments mainly on Contracts for Differences (CFDs).
1.3 Legal Framework
This Policy implements the requirements of the Law which Provides for the Provision of Investment Services, the Exercise of Investment Activities, the Operation of Regulated Markets and Other Related Matters Law 144(I)/2007, as this is subsequently amended from time to time. Additionally, the Policy further implements the relevant requirements of Part VI of Directive DI144-2007-02 for the Professional Competence of Investment Firms and the Natural Persons Employed by them as issued by CySEC.
Terms used in this Policy that are not interpreted differently shall have the meaning given to them by the Terms & Conditions of the Company.
2. Execution Policy
The Company satisfies the following conditions when carrying out client orders:
- ensures that orders executed on behalf of clients are promptly and accurately recorded and allocated;
- carries out otherwise comparable client orders sequentially and promptly unless the characteristics of the order or prevailing market conditions make this impracticable, or the interests of the client require otherwise;
- Informs a retail client about any material difficulty relevant to the proper carrying out of orders promptly upon becoming aware of the difficulty.
Dealing Room is the relevant department of the Company, to which the order execution policy mainly applies.
The Company proceeds with the establishment and maintenance of an Order Execution Policy, in order to ensure compliance with the obligation to execute orders on terms most favourable to the clients and to achieve the best possible results for its clients, taking into consideration its clients’ ability, needs and trading policies, where applicable and possible.
The policy outlines the process that the Company follows when executing trades, and assure taking all reasonable steps to consistently obtain the best possible result for clients through its order execution policy. It is noted however that when executing an order following a specific client instruction, the Company executes the order in line with those instructions and considers that it has discharged its best execution obligations.
Senior Management reviews the policy on an annual basis or / and whenever a material change occurs that impacts the Company’s ability to continue offering best execution of its clients’ orders using the Company’s trading platform.
The Company reserves the right to amend or supplement this Policy at any time. In such case the Company will inform clients should any material change takes place.
2.2 Execution Factors
In the absence of specific client instructions, when managing client orders through to execution or upon facilitation of reception and transmission of orders the Company takes all reasonable steps to achieve the best possible result for clients in a comprehensive and consistent way. The Company takes into consideration; inter alia, a combination of the following execution factors:
- Nature of the order
- Market conditions and variations
- Likelihood of Execution and Settlement
- Any other direct consideration relevant to the execution of the order
2.3 Best Execution Criteria
The Company will take into account the best execution criteria for determining the relative importance of the execution factors:
- The characteristics of the client order
- The characteristics of the financial instruments that are the subject of that order
- The characteristics of the execution venues to which that order can be directed.
The best possible result will be determined in terms of the total consideration, representing the price of the contract and the cost related to execution. The other execution factors of speed, likelihood of execution size, nature or any other relevant consideration will, in most case, be secondary to price and cost considerations, unless they would deliver the best possible result for the client in terms of total consideration.
3. Specific Instructions
In circumstances where the client provides the Company with a specific instruction as to how to execute an order and the Company has accepted this instruction, then the Company will execute the order in accordance with that specific instruction.
Nevertheless, if the client provides a specific instruction to carry out an order, then by executing that order the Company will be complying with the Company’s duty to provide the client with best execution. This may result in being unable to follow the Company’s order execution policy for that particular order and it is therefore noted that the specific instruction provided by the client may prevent the Company from obtaining the best possible result for the client as otherwise would be implemented according to this Policy.
4. Execution Venues
Execution venue is a regulated market, a multilateral trading facility, a systematic internaliser, or a market maker or another liquidity provider or an entity performing in a third country a function similar to any of the abovementioned. For the purposes of this execution policy, execution venue is the market maker with which all clients’ orders are executed. It is noted that the Company will be responsible against the clients for the execution of their orders, while the execution venue to all clients’ orders will be Magnasale Trading Ltd a duly authorized investment firm, authorized by Cyprus Securities and Exchange Commission with licence number 264/15. The Client deposits funds with the Company and places an order via a trading platform and the Company is responsible for safeguarding of clients’ funds. Upon receipt of the order, the Company opens an exactly identical order on the name of the client with the market maker, per order received or accumulatively. In this respect, the Company executes the client order by acting as a broker (STP Broker).
5. Analysis of Execution Factors
The Company provides prices as are obtained from the third party external providers. In this respect prices on financial instruments are calculated with respect to the underlying asset prices as provided from external sources. The Company ensures that the client receives the best execution mainly by ensuring that the price provision to the client is made with reference and compared to a range of underlying price providers and data sources. The Company reviews its independent price providers at least once a year to ensure that correct and competitive pricing is offered.
The provider, is continuously updating its prices, therefore last updated prices are displayed on Company’s trading platform.
Under certain trading conditions, the Company might not be in a position to execute the order placed by the client at the client’s requested price. Under this scenario, the Company maintains the right to execute the order at the first available price.
When the client opens a position in relation to some types of financial instruments a commission or a financing fee will apply. Commissions may be charged either in the form of a percentage of the overall value of the executed trade or as a fixed amount.
Overnight financing fees may apply for some types of financial instruments, and trades in these will be subject to ‘rolling fees’ if kept open overnight. Details on the daily financing fees are available for each financial instrument within the trading platform.
5.3 Size of order
All orders are placed in monetary value. The client will be able to place his order as long as he has enough available balance in his trading account. If the client wishes to execute a large size order, in some cases the price may become less favorable considering the feed obtained from its price provider. Minimum size of an order may depend on each type of Client Account.
Obviously, prices change over time. The frequency with which they do varies with different financial instruments and market conditions. Considering that the tradable prices which are distributed via the Company’s trading platform/terminal, technology used by the client to communicate with the Company plays a crucial role. For instance, the use of a wireless connection, or dial up connection, or any other communication link that can cause a poor internet connection can cause unstable connectivity to the Company’s trading platform/terminal. The result for the client is to place his orders at a delay and the order to be executed at better or worst prevailing market price offered by the Company via its platform/terminal. In general, the Company seeks to provide high speed of execution to its clients within the limitations of technology and communication links.
At the time of execution due to lack of liquidity or market volatility the execution of the order might be close or a number of pips away from the price at the time that the client requested the order. This is normal market practice and it can be both positive or negative, for the client, slippage depending on the prevailing market conditions.
5.5 Nature of order
The particular characterizing of an order depends on the instrument to be selected by the client. The value of the instrument is mainly depended on the volatility of the underlying instrument and the risk management to be selected by the client.
5.6 Market conditions and variations
The Company’s quoted prices which are derived from its independent price providers may be affected by various factors which could also affect the abovementioned factors affecting the price of the underlying instruments. The Company takes all reasonable factors to ensure the best possible result for its clients.
5.7 Likelihood of execution
The likelihood of execution depends on whether there are available prices from other market makers/financial institutions. However, in the event that the Company is unable to proceed with an order for any reason, including size and price, the order will not be executed. The Company is entitled, at any time and at its discretion to decline or refuse to transmit or execute any order or instruction received from the client as this is explained in the Client Agreement and General Terms & Conditions.
5.8 Likelihood of settlement
The Company shall proceed with the settlement of all transactions upon the execution and/or time of expiration of the specific transaction.
6. Aggregation and Allocation of Orders
The Company carries out a client order in aggregation with another client order unless the following conditions are met:
- it must be unlikely that the aggregation of orders and transactions will work overall to the disadvantage of any client whose order is to be aggregated;
- it is disclosed to each client whose order is to be aggregated that the effect of aggregation may work to its disadvantage in relation to a particular order;
- an order allocation policy is established and effectively implemented, providing in sufficiently precise terms for the fair allocation of aggregated orders and transactions, including how the volume and price of orders determines allocations and the treatment of partial executions.
7. Order Management
The Company ensures that, at all times, client orders are handled equitably and to client’s best advantage. Client orders are executed in a prompt and equitable manner, taking into account the nature of the order. Other similar orders may be processed or executed sequentially in parity with the time of receipt and may be aggregated or pro-rated accordingly, unless the characteristics of the order or prevailing market conditions make this impracticable or the interests of the client, require otherwise. The Company undertakes to manage all client orders in accordance with the following principles:
- Order execution shall be prompt, fair and expeditious and processed sequentially
- Aggregation of comparable orders shall be undertaken to the client’s best interests
- Allocation or reallocation shall be equitable and seek to protect from client detriment
8. Partial Execution
Where partial execution takes place on an aggregated order, the Company remains at liberty to pro rata the allocation with the client order. In such an event, the Company will be in a position to reasonably demonstrate, that without its own participation, execution could not have taken place at all or on such favorable terms.
The Company assesses on a regular basis, of particular transactions in order to determine whether it has complied with its execution policy and/or arrangements, and whether the resulting transaction has delivered the best possible result for the client.
Appropriate information is provided to the client on the content of the execution policy. The prior consent of the clients is obtained regarding the documented order execution policy to be followed. In addition, a clear and prominent warning is disclosed to the Company’s clients (within the Terms & Conditions) that any specific instruction from a client may prevent the Company from taking the steps that is has designed and implemented in its execution policy for obtaining the best possible result for the execution of those orders in respect to the elements covered by those instructions.
Adequate information is provided to the clients through this policy in relation to the factors that are taken into consideration by the management when handling clients’ orders. Also, the policy is reviewed periodically by the Company and the clients are informed accordingly in relation to any material changes.