Order Execution Policy

Transcription

1 Order Execution Policy Version 1.2. Date of Edition: November 2015 Date of Last Modification:

2 Contents Introduction.3 Scope 3 Best Execution Factors Execution Venues...5 Monitor and Review..5 Client Consent... 6 Order Definitions

3 Introduction K-DNA Financial Services Ltd, hereinafter referred to as the Company, IF or K-DNA is an investment firm that operates a global broker. It is incorporated in the Republic of Cyprus under registration number HE through the Registrar of Companies and Official Receiver. K-DNA is authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) with license No. 273/15 and operates under the Markets and Financial Instruments Directive (EU Directive 2004/39/EC)(MiFID). Following the implementation of MiFID and the Investment Services and Activities and regulated Markets Law of 2007 (Law 144(I)/2007), the Company has established its Order Execution Policy, hereinafter also referred to as the Policy. K-DNA is required to set up this Policy and to take all reasonable steps to obtain the best possible results for its clients ( Best Execution ) either when executing clients orders or receiving and transmitting orders for execution in relation to financial instruments. This Policy forms part of the Client Agreement. Therefore, by entering into the Client Agreement with the Firm, the client agrees to the terms of the Company s Order Execution Policy relating to financial instruments provided by the Company. Scope This Policy applies when executing transactions in the Financial Instruments provided by the Company on behalf of all its clients (retail and professional). The Company will always act as principal (counterparty) when executing clients orders. The Company takes every reasonable step to obtain the best possible result for its clients. Nevertheless, it does not guarantee that when executing a transaction the client s price will be more favorable than one which might be available elsewhere. Best Execution Factors The Company shall take all reasonable steps to obtain the best possible results for its Clients taking into account the following factors when executing Clients orders against the Company s quoted prices: Prices: The Company generates its tradable prices from information sourced through independent price providers that generally provide liquidity to the global market. The Company 3

4 will ensure that its clients will be receiving the best execution by ensuring that the calculation of the spread between the BID price (the highest price that the seller is offering for the particular instrument at the moment) and the ASK price (the lowest price acceptable to the buyer for the specific instrument at the moment) is made with reference to a range of underlying price providers and data sources. The Company s prices can be found on the Company s website. The Company updates its prices as frequently as the limitations of technology and communications links allow. Costs: The Company will take all necessary steps to ensure that the clients are informed of any costs before they elect to trade. Details of the costs are available on the Company s website and/or on the trading platform. In addition, the value of opened positions in some types of instruments is increased or reduced by a daily swap rate throughout the life of the contract. Swap rates are based on prevailing market interest rates, which may vary over time. Speed of Execution: The Company is not the Execution Venue (as defined in Commission Directive 2006/73/EC implementing MiFID) for the execution of the clients order. The Company transmits clients orders or arranges for their execution with a third party/ies. However, the Company places a significant importance when executing clients orders and strives to offer high speed of execution within the limitations of technology and communications links. Prices change over time and the frequency with which they do varies with different financial instruments and market conditions. Moreover, speed of execution can be affected by factors which may include poor internet connection, or any other link to the Company s servers and platforms which may affect execution of the clients orders. In cases where a client s order is placed on old prices the Company might decline them and/or provide the client with another quote (re-quote). Likelihood of Execution: When the Company transmits orders for execution or executes it with another party, execution may sometimes be difficult. The likelihood of execution depends on the availability of prices of other market makers/financial institutions, as the volatility in the market affects both price and volume. Under certain market conditions, orders may not be filled at the exact price requested but instead at the best available price. This may occur during periods of volatile market conditions, news announcements, on opening gaps when a trading session starts or other factors that can affect the market. Likelihood of Settlement: The Company shall proceed to a settlement of all transactions upon execution of such transactions. Size of Orders: A lot is a unit measuring the transaction amount and it is different for each instrument. Please refer to the Company s website for the value of minimum size of an order and each lot for a given instrument. 4

5 Market Impact: Some factors may rapidly affect the price of the underlying assets from which the Company s quoted price is derived and may also affect other factors listed herein. The Company will take all reasonable steps to obtain the best possible result for its clients. The Company does not consider the above list exhaustive and the order in which the above factors are presented shall not be taken as priority factor. Nevertheless, whenever there is a specific instruction from a client, the Company shall make sure that the client s order shall be executed following the specific instruction. Best Execution Criteria: K-DNA will determine the relative importance of the execution factors, following the best execution criteria listed below: 1. The characteristics of the Client order 2. The characteristics of financial instruments that are the subject of that order 3. The characteristics of the execution venue to which that order is directed 4. The Characteristics of the client. The best possible result is determined in terms of the total consideration, represented by the prices and the costs related to execution as the main factors. Other execution factors such as speed and likelihood of execution, nature or any other relevant consideration will in most cases be secondary to prices and costs considerations. Execution Venues Execution Venues are the entities with which the orders are placed or to which the Firm transmits orders for execution. The Company will enter into transactions with its clients as principal (counterparty), and not as agent, and act as the sole execution venue for all client orders at all times. The clients are required to open and close their position(s) of any financial instrument with the Company via its trading platform. The Company places significant reliance to the above Execution Venue based on the above mentioned factors and their relative importance. It is the Company s policy to maintain such internal procedures and principles in order to determine the relative importance of these factors and to act for the best interest of its clients and provide them the best possible result (or best execution ) when dealing with them. The client acknowledges that the transactions entered with K-DNA are not undertaken on a recognized exchange, rather they are undertaken through the Company s Trading Platform and, accordingly, they may expose the client to greater risks than regulated exchange transactions. Thus, the Company may not execute an order, or it may change the opening or closing price of an order in certain cases including but not limited to instances of a technical failure of the trading platform. 5

6 Monitor and Review K-DNA will monitor and assess on a regular basis the effectiveness of this Policy and the order of its order execution arrangements and, in particular, the execution quality of the procedures explained in the Policy in order to deliver the best possible result for the client, and, where appropriate, the Company reserves the right to correct any deficiencies in this Policy and make improvements to its execution arrangements. Moreover, the Company will review the Policy as well as its order execution arrangements at least annually. A review will also be carried out whenever a material change occurs that affects the ability of the Company to continue to the best possible result for the execution of its client orders on a consistent basis using the venues included in this Policy. Clients should be aware that the Company will not notify clients separately of changes and they should therefor refer to the Company s website for the most up to date version of this Policy. Client Consent By entering into a Client Agreement with the Company for the provision of Investment Services, the client is consenting to an application of this Policy on him/her. The Company is required to obtain the client s prior consent to this Policy. When establishing a business relationship with K-DNA, the client is informed that the Company always acts as a principal and is the sole execution venue, which is not a regulated market or a multi-lateral trading facility (MTF). List of Banned Countries Banned countries Belgium Bulgaria Canada (Residence only) Democratic People's Republic of Korea (DPRK) Myanmar Iran Turkey (Residence only & North Cyprus residence) USA (Citizens and Residents) 6