Novox Capital Ltd. BEST EXECUTION POLICY

Transcription

1 Novox Capital Ltd. BEST EXECUTION POLICY

2 Table of Contents 1. Introduction Scope and Application Best Execution Criteria Best Execution Factors Specific Instructions Execution of Client Orders Execution Venues Monitoring Clients Consent... 5

3 1. Introduction This policy summarizes the arrangements Novox Capital Ltd (hereinafter referred to as the Company ) has undertaken in accordance with Markets in Financial Instruments Directive ( MIFID ), Law 144(I)/2007(hereinafter referred to as the Law ) and CYSEC Directives to meet the company s obligations and take all reasonable steps to obtain the best possible result for its clients when receiving and transmitting orders for execution in relations to financial instruments. All clients are advised that trading Binary Options can carry a high level of risk and may be not suitable for all investors. Clients could lose all their initial investment. The risks must be understood prior to trading. The Company is authorized and regulated by the Cyprus Securities and Exchange Commission ( CYSEC ) under authorization number CIF 224/ Scope and Application The Purpose of this policy is to ensure that appropriate policies or arrangements are effectively implemented by Novox Capital Ltd when receiving and transmitting or executing client orders for all financial assets offered by the company. According to the Investments Services and Activities and Regulated Markets Law of 2007 (Law 144(1)/2007) the company should take all reasonable steps to obtain the best possible result for its clients, taking into consideration account price, costs, speed, likelihood of execution and settlement, size, nature or any other information relevant to order execution. The company provides a number of online financial trading instruments such as Binary Options Contracts ( BOC ), Forex ( FX ), and Contract for Difference ( CFD s) trading through its platforms. This policy applies to both Retail and Professional clients. In case that a client is classified as an Eligible Counterparty, this policy does not apply to that client. 3. Best Execution Criteria The Company will take into account the following criteria when determining the relative importance of the best execution factors: The characteristics of the client including whether the client is retail or professional. The characteristics of the client order. The characteristics of the financial instrument that is the subject of that order. The characteristics of the execution venues to which that order can be directed. For Retail clients The Company will determine the best possible result in terms of the total consideration by taking into account the price of the financial instrument and the costs directly related to execution, including clearing and settlement fees and any other fees paid to third parties involved in the execution of the order. 4. Best Execution Factors The Company has in place a policy and procedures which are designed to obtain the best possible execution result on a consistent basis, subject to and taking into account the following factors: a) Pricing The Company considers pricing as a matter of highest importance for best execution, and receives its raw prices from 2 to 3 well-known and reliable independent price providers (including but not limited to Reuters). The prices of all underlying assets relating to BOC are calculated by using the bid+ask/2 model, as a core formula, while factoring in external variable factors e.g. market conditions, volatility, liquidity, amongst

4 others. The Company consider this approach as the standard formula for binary options pricing purposes. The prices of all the instruments relating to FX and CFDs are calculated by reference to the price of the relevant underlying financial instrument, which the firm obtains from its liquidity providers. Clients are trading on the direct quotes that the company is receiving from its liquidity providers. Clients are offered consistently low fixed spreads in all market conditions without any commission. All the trading prices are presented electronically through the company s online trading platform. The company takes all the appropriate measures to ensure that its prices are accurate and competitive enough and it evaluates its pricing providers on a yearly basis. The Company provides its clients with more than 200 assets and expiries for a period of 15 seconds up to 1 year for BOC. b) Costs Clients are not charged any commissions or fees by the Company for any Transaction executed unless agreed otherwise by the Parties hereto. Leverage is not offered to any clients. There is also a $10/ 10/ 10 a month inactivity fee which will be charged to each client whose account is inactive for a period greater than 3 months. Activity, in this sense, is a client logging in to their trading account. The fee will be deducted directly from each client s trading account, from their available balance. To avoid this $10 inactivity fee a client must log in to their trading account at least once every three (3) months. c) Speed of Execution When a client opens a position, the order is received by The Company and is automatically routed to its execution venue. The company will ensure that the third party execution venue is contracted to providing clients with best execution. Speed of execution is dependent on market conditions and communications links. i.e. a poor internet connection or dial up connection could have an effect on the speed of pricing updating and may delay the execution of an order. d) Likelihood of Execution There could be specific cases where the execution of order may not be possible. This could happen when there is high volatility in the market or when there is a lack of available prices, or during a system failure. Moreover the company will not execute any client s order who try to abuse or manipulate the system, and the company has sole discretion to take any measures it deems fit and appropriate under the said circumstances. e) Likelihood of Settlement It is possible a contract is closed prior to expiration or the time of expiration. The Company carries on with the settlement of all transactions. f) Order Size The size of each order is dependent on that client s available balance, and price availability. In case that a client attempts to open an order that needs more capital than the available equity in their account, the system will automatically reject the order. g) Abnormal Market Conditions It is possible for factors other than the above to affect trading prices. The company will undertake all the appropriate measures to obtain the best possible executions results for its clients. 5. Specific Instructions In cases when there is a specific instruction from a client, the company must execute the order in accordance with those instructions and does not need to apply the best execution provisions in relation to those matters

5 that the instruction specifies. However the best execution requirements must still be applied to those parts of an order not covered by the specific instruction. 6. Execution of Client Orders Clients enter their Orders via the internet by using the web-platform or the mobile application. The Company when carrying out Clients Orders tries to satisfy the following conditions: a) Ensures that orders executed on behalf of clients are promptly and accurately recorded and allocated. b) 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. c) Informs a retail client about any material difficulty relevant to the proper carrying out of orders promptly upon becoming aware of the difficulty. 7. Execution Venues The Company is a market maker which uses from time to time independent third party execution venues, and risk-mitigation counter parties. The Company reserves the right at any point to change or add additional execution venues and/or riskmitagation counter parties. Clients should be aware that they are exposed to higher risk as all BOC are traded on the OTC markets, as opposed to regulated exchanges. 8. Monitoring The Company will review its order execution arrangements regularly in order to identify any inadequacies and ensure that The Company achieves execution on a consistent basis in relation to this policy. As part of the dealing/brokerage desk The Company creates and monitor risk management parameters to ensure that traders own risk is rather limited, and traders risk to other traders is limited as well. This Best Execution Policy is reviewed annually and every time a material change occurs that could affect its ability to obtain the best possible result for the execution of orders. The company reserves the right to review or amend its policy and arrangements without notice to the client. 9. Clients Consent Novox Capital Ltd is required to obtain clients consent to its execution policy. By accepting the T&C, Clients acknowledge and accept that they have read and understood the Best Execution Policy of the Company, which is available for examination on the Company s website under the heading LEGAL. For any additional information concerning the best execution policy, clients should contact The Company by at info@novoxcapital.com