Best Execution Policy. Version: July 2018

Transcription

1 Best Executin Plicy Versin: July 2018 Next Review Date: 1 Octber 2018

2 Cntents 1 Intrductin Review f plicy Best Executin Summary f Best Executin Delivery f Best Executin Scpe Financial instruments Clients Retail Clients Ttal Cnsideratin Prfessinal Clients Eligible cunterparties Activities Cntract fr Differences Order Types Best Executin Obligatins Order executin arrangements & client infrmatin Infrmatin n rder executin plicy Demnstrating cmpliance with the rder executin plicy Inducements Client cnsent Executin Factrs Executin strategies Executin Venues Executing rders utside a trading venue Executing rders via cnnected parties r internalising Client instructins Verifying the fairness f the price Quarterly publicatin n quality f executin f Transactins Annual infrmatin n the identity f executin venues and n the quality f executin Mnitring Material Changes Valutrades Limited is a limited liability cmpany registered in England and Wales with its registered ffice at 1 Primrse Street, Lndn, EC2A 2EX, United Kingdm. Cmpany Number Valutrades Limited is authrised and regulated by the Financial Cnduct Authrity. Financial Services Register Number Page 2 f 13

3 8 N Fiduciary Relatinship Breaches f Order Executin Plicy Valutrades Limited is a limited liability cmpany registered in England and Wales with its registered ffice at 1 Primrse Street, Lndn, EC2A 2EX, United Kingdm. Cmpany Number Valutrades Limited is authrised and regulated by the Financial Cnduct Authrity. Financial Services Register Number Page 3 f 13

4 1 Intrductin This plicy details hw Valutrades Limited (the Firm) will cmply with its verarching regulatry requirement f taking all sufficient steps t btain, when executing rders, the best pssible results fr its clients, taking int accunt prescribed and apprpriate executin criteria and any specific instructins received frm the client. The Firm is authrised by the Financial Cnduct Authrity (FCA) and, as such, will at all times act in accrdance with the rules as defined in the FCA Handbk, which will take precedence in case f any cnflict with the terms f this plicy which, fr the avidance f dubt, cmprise part f ur Terms f Business with clients (please see clause 1.2 f ur Terms f Business fr cnfirmatin), and any capitalised terms used in this plicy shall have the same meanings (if any) attached t them in the Terms f Business. 2 Review f plicy This plicy, and the Firm s rder executin arrangements, will be reviewed regularly, at least nce a year, and amended as cnsidered necessary by the Firm s Management Bdy in the event f changing circumstances r regulatins. 3 Best Executin 3.1 Summary f Best Executin Best executin is the verarching requirement fr firms t take all sufficient steps t prvide the client with the best pssible verall results n a cnsistent basis, and nt just by prviding the best price fr an individual trade. T d this, the Firm shall take int accunt executin factrs (see further at sectin 5.3 belw) such as: (i) the nature f the rder t be executed; (ii) the relevant market and its prevailing practices; (iii) the pririties the client identifies in respect f the relevant Transactin; (iv) price; (v) csts; (vi) speed; (vii) likelihd f executin and settlement; (viii) size f the relevant rder; and (ix) any ther factrs cnsidered t be relevant t the executin f the client s rders, Where there is a specific instructin frm the client, the Firm shall execute the rder fllwing the specific instructin. If the client s specific instructin cncerns sme but nt all aspects f the rder, the Firm will fllw its executin plicy fr the ther aspects with the aim f achieving fr the client the best pssible verall results, taking int accunt Valutrades Limited is a limited liability cmpany registered in England and Wales with its registered ffice at 1 Primrse Street, Lndn, EC2A 2EX, United Kingdm. Cmpany Number Valutrades Limited is authrised and regulated by the Financial Cnduct Authrity. Financial Services Register Number Page 4 f 13

5 and weighing in crrect balance factrs that may smetimes cnflict, s as t ensure Best Executin, ( Best Executin ). 3.2 Delivery f Best Executin The Firm is respnsible fr executing client rders and as such is respnsible fr prviding Best Executin fr thse rders. 4 Scpe 4.1 Financial instruments Best Executin requirements apply t all financial instruments as listed in the Annex I f MiFID II, sectin C. The Firm transacts in the fllwing classes f financial instruments: Currency derivatives Futures and ptins admitted t trading n a trading venue Swaps, frwards, and ther currency derivatives (f) Structured finance instruments Equity Derivatives Optins and Futures admitted t trading n a trading venue Swaps and ther equity derivatives Cmmdities derivatives and emissin allwances Derivatives Optins and Futures admitted t trading n a trading venue Other cmmdities derivatives and emissin allwances derivatives Cntracts fr difference Other instruments 4.2 Clients This plicy applies t Retail Clients and Prfessinal Clients. In accrdance with the Firm s bligatins t the client, it has ntified the client f the client classificatin that applies t it Retail Clients When dealing with Retail Clients, there is a regulatry assumptin that the client can rely n the Firm t prtect its interests, and the Firm will apply Best Executin t all trades that the client places thrugh it, which will be assessed n the basis f Ttal Cnsideratin in respect f all instruments: Valutrades Limited is a limited liability cmpany registered in England and Wales with its registered ffice at 1 Primrse Street, Lndn, EC2A 2EX, United Kingdm. Cmpany Number Valutrades Limited is authrised and regulated by the Financial Cnduct Authrity. Financial Services Register Number Page 5 f 13

6 Ttal Cnsideratin Ttal Cnsideratin represents the sum f the price f the financial instrument and all csts assciated with the executin f client s rder including executin venue fees, clearing and settlement fees, and any ther fees paid t third parties invlved in the executin f the rder. The Firm will evaluate regularly the fferings frm varius liquidity prviders and make an initial assessment f suitability based upn stability, quality f technlgy and market reputatin. Thse liquidity prviders deemed suitable will be added t the Firm s pl f liquidity prviders and per prduct, and the Firm will rute each rder t the liquidity prvider that ffers the best spreads, csts and chance f executin Prfessinal Clients What Best Executin means fr Prfessinal Clients may differ t an extent frm what it means fr Retail Clients. Certain executin factrs may carry different weight, fr example price and likelihd f executin. When dealing with Prfessinal Clients, the Firm des nt differentiate between elective Prfessinal Clients and per se Prfessinal Clients. It will apply Best Executin t all transactins undertaken fr its Prfessinal Clients where it has an agency r cntractual bligatin t thse clients and where it can be demnstrated that the client is legitimately relying n the Firm in relatin t the executin f its rder, and the Firm will always cnsider the FCA s and the Eurpean Securities and Markets Authrity s guidance t determine if this can be demnstrated including as set ut in the fllwing paragraph. In relatin t qute driven markets the Firm will determine if it wes Best Executin t Prfessinal Clients by determining t what extent the Firm acts n behalf f the client and whether the client legitimately relies n the Firm by carrying ut the fur-fld cumulative test by assessing the fllwing pints: Which party has initiated the transactin? Market practice & the existence f a cnventin t shp arund The relative levels f price transparency within the market The infrmatin prvided by the Firm and any agreement reached Eligible cunterparties This plicy des nt apply t Eligible Cunterparties where carrying ut Eligible cunterparty business and as such, the Firm des nt we Best Executin t transactins undertaken by clients classified as such. Valutrades Limited is a limited liability cmpany registered in England and Wales with its registered ffice at 1 Primrse Street, Lndn, EC2A 2EX, United Kingdm. Cmpany Number Valutrades Limited is authrised and regulated by the Financial Cnduct Authrity. Financial Services Register Number Page 6 f 13

7 4.3 Activities The Firm is a frex, CFD and cmmdity brker based in the City f Lndn and regulated under the FCA. The Firm aims t prvide a cmpetitively priced service with ur fcus being n prviding infrmative cntent and extremely high levels f custmer service as a way t enhance ur custmer s financial and trading experience and t differentiate us frm ther brkers. The Firm has permissin t carry ut the fllwing regulated activities: Hld and cntrl client mney Arranging deals in investments Arranging safeguarding and administratin f assets Dealing in investments as agent Dealing in investments as principal Making arrangements with a view t transactins in investments Cvering the fllwing prducts: Cmmdity Future Cmmdity ptin and ptin n cmmdity future Cntracts fr Difference Futures Optins Rights t ur interests in investments Rlling spt frex Spread bet This means that the Firm will be executing client rders in these instruments in accrdance with this plicy Cntract fr Differences The Firm recgnises that when clsing ut an pen psitin, the client must clse ut the cntract with the firm that sld it t them, even if there is a better price elsewhere. T ensure that in thse circumstances the Firm will cmply with its Best Executin bligatins, it will take all sufficient steps t btain the best pssible results in relatin t the instrument underlying the CFD and by disclsing hw they calculate their internal fees and charges. Valutrades Limited is a limited liability cmpany registered in England and Wales with its registered ffice at 1 Primrse Street, Lndn, EC2A 2EX, United Kingdm. Cmpany Number Valutrades Limited is authrised and regulated by the Financial Cnduct Authrity. Financial Services Register Number Page 7 f 13

8 The Firm cnsiders the csts f clsing ut psitins and vernight financing charges as part f ur liquidity prvider review and rder ruting prir t pening a psitin. This ensures trades will nt initially be pened with a liquidity prvider that will result in harmful charges fr maintaining r clsing that psitin. 4.4 Order Types Regardless f the type f rder that the client transacts with the Firm, Best Executin will apply. This will nrmally include rder types cmmnly used n an executin venue, as defined by MiFID. 5 Best Executin Obligatins 5.1 Order executin arrangements & client infrmatin The Firm has designed and implemented specific arrangement t take all sufficient steps t btain, when executing client rders, the best pssible results fr its clients taking int accunt the executin factrs including: A specific venue selectin prcess The ranking f the executin factrs in accrdance with the characteristics f the client, the rder, the financial instrument and the executin venue t which that rder may be directed The design f efficient executin strategies The verificatin f the fairness f the price when dealing in OTC prducts Infrmatin n rder executin plicy In accrdance with its regulatry requirements the Firm has prepared a cmprehensive dcument summarising thse arrangements and explaining clearly hw the rders will be executed by the Firm entitled: Infrmatin n the rder executin plicy. This dcument is available n the Firm web-site fr all clients befre entering int an agreement t prvide investment services. This infrmatin includes a link t the mst recent executin quality data published by the executin venues listed in this rder executin plicy Demnstrating cmpliance with the rder executin plicy Where a client makes reasnable and prprtinate requests fr infrmatin abut the Firm s plicies r arrangements fr Best Executin and hw they are reviewed and mnitred, the Firm will answer clearly and within a reasnable time. The Cmpliance Valutrades Limited is a limited liability cmpany registered in England and Wales with its registered ffice at 1 Primrse Street, Lndn, EC2A 2EX, United Kingdm. Cmpany Number Valutrades Limited is authrised and regulated by the Financial Cnduct Authrity. Financial Services Register Number Page 8 f 13

9 functin is in charge f this prcess. It may include demnstrating that the client rders were executed in accrdance with this plicy Inducements The Firm des nt receive any payments r nn-mnetary benefits frm third parties. 5.2 Client cnsent In accrdance with its regulatry requirements, the Firm will btain a client s cnsent n and agreement t its rder executin plicy as part f the accunt applicatin prcess. 5.3 Executin Factrs In the absence f express instructins frm the client, the Firm will exercise its wn discretin and cmmercial judgement in determining the relative imprtance and pririty it assigns t the executin factrs (r the prcess by which it determines their relative imprtance) that it needs t take int accunt fr the purpses f prviding the client with Best Executin. These executin factrs have been listed in default rder f pririty* and will include, but are nt restricted t, the: Likelihd f executin and settlement: the Firm cnsiders that fr illiquid securities, likelihd f executin may take precedence ver price and speed. Size f rder: the Firm cnsiders the size f the Transactin in the cntext f the liquidity f the market in that instrument and hw it may impact the price f executin. Price: the Firm will generally cnsider that price merits a high imprtance, hwever, the nature f the relevant securities will determine if the Firm shall give precedence t ther factrs such as speed r likelihd f executin depending n the security s characteristics. We will at all times pay due regard t the market prices f relevant underlying reference prducts t which a client s trades relate. Speed: the Firm cnsiders that fr liquid securities, speed is paramunt taking int accunt the fact that markets tend t mve quickly, i.e. the price f the security may vary significantly. Csts: the Firm will always pay due regards t the csts related t any executin t ensure that the csts will nt jepardise the end result. Ttal Cnsideratin: the Firm will always bear in mind and seek t determine where the balance lies as between factrs with a ptential impact n the Ttal Cnsideratin. Valutrades Limited is a limited liability cmpany registered in England and Wales with its registered ffice at 1 Primrse Street, Lndn, EC2A 2EX, United Kingdm. Cmpany Number Valutrades Limited is authrised and regulated by the Financial Cnduct Authrity. Financial Services Register Number Page 9 f 13

10 Nature f rder: the Firm will cnsider hw the characteristics f the Transactin can impact hw Best Executin is achieved. Any previus issues with similar rders: smetimes the Firm wuld have received issues with previus rders f similar characteristics and will avid ruting rders t a venue where issues have ccurred with that venue. *prvided always that the Firm will exercise its discretin in determining the pririty t be given frm time t time t these criteria t ensure Best Executin. 5.4 Executin strategies In the absence f express instructins frm the client, the Firm will exercise its wn discretin in determining the executin strategy it needs t apply t btain the best pssible results where executing a client rder. All executins are handled autmatically frm pint f request frm clients t ensure fastest pssible speed f executin. The Firm s main rder ruting system will make realtime algrithmic decisins based n the factrs listed in 5.2 t ensure Best Executin. 5.5 Executin Venues The Firm acts as principal in respect f client rders, and will assess available venues (including itself) t achieve the best pssible results fr the client including, withut limitatin, cnsideratin f the fllwing criteria: Ttal Cnsideratin (Price and csts) will, in the absence f a specific client instructin t the cntrary, be cnsidered the mst imprtant factr in the Firm s chice f venue; The Firm will als take int accunt the impact f the chice f venue n each f the ther executin factrs fr example, speed f prcessing and likelihd f rder acceptance in a variety f markets and rder types. The financial sundness and rder executin plicies f any cunterparty r venue will als be relevant cnsideratins; In respect f CFDs and spread bets fr which the Firm des nt match with an external liquidity prvider, it will seek t manage its risk as market maker and may chse whether t hedge part r all f a client s Transactins in the underlying market, t reduce executin csts and market price impact fr the client. Such hedging in the underlying market may, where necessary, affect price, taking int accunt the prevailing market prices available t the Firm. The Firm will execute Transactins and rders utside a regulated market s as t cnsistently surce the best price fr client rders, albeit acknwledging the Valutrades Limited is a limited liability cmpany registered in England and Wales with its registered ffice at 1 Primrse Street, Lndn, EC2A 2EX, United Kingdm. Cmpany Number Valutrades Limited is authrised and regulated by the Financial Cnduct Authrity. Financial Services Register Number Page 10 f 13

11 greater cunterparty and settlement risk arising frm such venues cmpared t trading n a recgnised exchange. 5.6 Executing rders utside a trading venue The Firm may execute client rders utside a trading venue. In such circumstances the Firm will seek t btain the client s express prir cnsent befre prceeding with the executin. The Firm has implemented a specific prcedure whereby the client will be infrmed f an intent t execute its Transactins utside a trading venue. The client will be issued a frmal cnsent frm t sign t acknwledge its agreement. The Firm will maintain the recrds f the cnsents btained and will verify at least annually if the client maintains its cnsent. 5.7 Executing rders via cnnected parties r internalising Where the Firm internalises the executin f client rders, t ensure that it cmplies with its verarching Best Executin requirements it has designed a rbust prcedure t prevent any ptential cnflicts f interest frm damaging client interests by clsely mnitring csts and applying the same selectin prcedure it applies t ther venues. Any cnflicts identified are lgged in the Firm Cnflict f Interest register Where the Firm executes a client s rders via cnnected parties, t ensure that it cmplies with its verarching Best Executin requirements, it has designed a rbust prcedure t prevent any ptential cnflicts f interest frm damaging client interests by clsely mnitring csts and applying the same selectin prcedure t thse venues that it applies t uncnnected venues. Any cnflicts identified are lgged in the Firm Cnflict f Interest register 5.8 Client instructins Where the client prvides the Firm with a specific instructin in relatin t an rder, r any particular aspect f that rder, including an instructin fr the trade t be executed n a particular venue, the Firm will execute the rder in accrdance with the client s instructin. The Firm will take all the steps it has designed in this plicy t btain the best pssible results fr the client in respect f the rder, r aspect f the rder, nt cvered by the specific instructin. It is hwever pssible that the specific instructin may prevent the Firm t take all the steps it has designed in its rder executin plicy t btain the best pssible results in respect f the elements f the rder nt cvered by the specific instructin. Valutrades Limited is a limited liability cmpany registered in England and Wales with its registered ffice at 1 Primrse Street, Lndn, EC2A 2EX, United Kingdm. Cmpany Number Valutrades Limited is authrised and regulated by the Financial Cnduct Authrity. Financial Services Register Number Page 11 f 13

12 Where the client prvides the Firm with a specific instructin in relatin t an rder, the Firm will als transmit the specific instructin t the entity t which the rder is transmitted in rder t ensure that the ther entity will execute the rder in accrdance with the client s instructin. It is hwever pssible that the specific instructin may prevent the ther entity t take all the steps it has designed in its wn rder executin plicy t btain the best pssible results in respect f the elements nt cvered by the specific instructin. 5.9 Verifying the fairness f the price Fr each financial instrument that is traded OTC, the Firm will check the fairness f the price befre prpsing it t the client and/r executing the rder by cmparing the price t external market data r reference prices in the same financial instrument r a cmparable financial instrument if n reference price is available in the same financial instrument Quarterly publicatin n quality f executin f Transactins The Firm will n a quarterly basis and free f charge publish data relating t the quality f executin, including details abut price, csts, speed and likelihd f executin and settlement fr individual financial instruments Annual infrmatin n the identity f executin venues and n the quality f executin The Firm will summarise and make public n an annual basis, fr each class f financial instrument, the tp five executin venues in terms f trading vlumes, where it has executed client rders in the preceding year, tgether with infrmatin n the quality f executin btained. 6 Mnitring The Firm will mnitr the effectiveness f its rder executin arrangements and rder executin plicy in rder t identify and, where apprpriate, incrprate any amendments t prcedures. The Firm will mnitr the prices available in the wider market t make sure that its executing parties are ffering fair prices and that they cntinue t prvide the best results fr clients. All rders are cmpared t a benchmark mid price fr the relevant prduct at the time f executin. Where the executin significantly varies frm this mid price this will be summarized and passed t management t allw them t cnsider any required changes t liquidity prviders r Best Executin prcedures. Valutrades Limited is a limited liability cmpany registered in England and Wales with its registered ffice at 1 Primrse Street, Lndn, EC2A 2EX, United Kingdm. Cmpany Number Valutrades Limited is authrised and regulated by the Financial Cnduct Authrity. Financial Services Register Number Page 12 f 13

13 The Firm will assess, n a regular basis, whether the executin venues included in the rder executin plicy prvide fr the best pssible result fr clients r whether it need t make changes t its arrangements. The Firm will review its rder executin arrangements and rder executin plicy at least annually r whenever a material change ccurs that affects its ability t cntinue t btain the best pssible result fr the executin f client rders n a cnsistent basis using the venues included in its rder executin plicy. 7 Material Changes The Firm will ntify clients f any material changes t its rder executin arrangements r this rder executin plicy arising frm mnitring and review as described abve by psting the infrmatin n its website. 8 N Fiduciary Relatinship The Firm s cmmitment t prvide clients with Best Executin des nt mean that it wes clients any fiduciary respnsibilities ver and abve the specific regulatry bligatins placed upn it r as may be therwise cntracted between the Firm and clients. Clients remain respnsible fr their wn investment decisins and the Firm will nt be respnsible fr any market trading lss clients suffer as a result f thse decisins. 9 Breaches f Order Executin Plicy Any breaches f the Order Executin Plicy will be recrded n the Firm s breach lg in cnjunctin with its regulatry breach plicy. Valutrades Limited is a limited liability cmpany registered in England and Wales with its registered ffice at 1 Primrse Street, Lndn, EC2A 2EX, United Kingdm. Cmpany Number Valutrades Limited is authrised and regulated by the Financial Cnduct Authrity. Financial Services Register Number Page 13 f 13