Order execution policy April 2016

Similar documents
RP Martin EXECUTION POLICY

PVM Execution and Order Handling Policy

Order Execution Policy Disclosure

PVM Execution Policy. Part of TP ICAP group. PVM Oil Associates Ltd. PVM Oil Futures Ltd. London

Best Execution Policy Customer Distribution

Order Execution Policy

B E S T E X E C U T I O N P O L I C Y

Order Execution Policy. January 2018 v1

Order Execution Policy Purpose and Scope

Order Execution Policy

Best Execution Policy. 1 Overview

Summary of the Best Execution Policy

Order Execution Policy - Corporate & Investment Bank Division - EEA

Order Execution Policy

TULLETT PREBON EXECUTION POLICY

Best Execution Policy

INTL FCSTONE LTD INFORMATION ON ORDER EXECUTION POLICY. April 2018

BEST EXECUTION AGGREGATION AND ALLOCATION POLICY. Green Street Advisors (UK) Ltd (GSA)

Jefferies International Limited

Marex Financial Limited: Order Execution Policy

Instruction for execution, handling and transmission of orders in financial instruments on behalf of clients for SEB Fund Services S.A.

AxiCorp Limited FCA # Leaden h all Street London EC 3 A 1AT UNITED KINGDOM. Issued: May 1st 2018

Order Handling and Execution Policy. January 2018

C. EXECUTION POLICY TERMS OF BUSINESS

By giving SEB an Order the client agrees to the transaction being executed in accordance with this Policy.

ING Wholesale Banking Best Execution and Order Handling Policy

Nordea Execution Policy

Best Execution and Client Order Handling Policy

BEST EXECUTION POLICY

Information on the RBCCM Europe Best Execution Policy

A CYPRUS INVESTMENT FIRM REGULATED BY THE CYPRUS SECURITIES AND EXCHANGE COMMISSION

Order Execution Policy MiFID Firms

Order Execution Policy financial instruments

saranac partners limited Saranac Partners Limited is authorised and regulated by the Financial Conduct Authority

BEST EXECUTION AND ORDER HANDLING DISCLOSURE STATEMENT BANK JULIUS BAER & CO. LTD.

ORDER EXECUTION POLICY. ABG Sundal Collier Group

Order Execution Policy

Execution Policy. 1 Purpose. to and taking into account the execution factors (see paragraph 4).

Jefferies International Limited

Best Execution Policy

Best Execution Client Disclosure Statement

Best Execution Policy Summary For Receipt, Transmission and Execution of orders Business. Fideuram Asset Management (Ireland) Limited ( Fideuram )

Order Execution Policy Cantor Fitzgerald Europe ( CFE ) For Professional Clients

INFINOX Capital Ltd Best Execution Policy

Canaccord Genuity Limited Order Execution Policy

EXANE EXECUTION POLICY

ARCHITAS ORDER EXECUTION POLICY: SUMMARY STATEMENT. October 2017 INTRODUCTION

Nordea Execution Policy

Best Execution & Order Handling Policy

Order Handling and Best Execution Policy

Order Execution Policy

SKANESTAS INVESTMENTS LIMITED BEST EXECUTION AND ORDER HANDLING POLICY

Mega Equity Securities & Financial Services Public Ltd

2.1 Liquidnet agency trading business: (i) operator of Multilateral Trading Facilities; (ii) agency trading desk

TMS BROKERS EUROPE BEST EXECUTION POLICY

Best Execution & Order Handling Policy

Best Execution Client Disclosure Statement HSBC UK Bank Plc Global Markets. Dated 1 July 2018 PUBLIC

Downing LLP. Best Execution Policy

Order Execution Policy STP/ECN

CITI SECURITIES SERVICES EXECUTION POLICY

Order Execution Policy Instant Execution

Order Execution Policy Macquarie Investment Management EMEA

Order Execution Policy Instant Execution

STIFEL NICOLAUS EUROPE LIMITED ORDER EXECUTION POLICY

Order Execution Policy

State Street Global Advisors Ireland Limited. Best Execution Policy

Information on the RBC I&TS (UK) Best Execution Policy

ORDER EXECUTION POLICY FOR PROFESSIONAL CLIENTS Applicable to ENGIE GLOBAL MARKETS head office and branches in the European Economic Area

Client Order Execution Policy

ORDER EXECUTION POLICY

Best Execution and Order Handling Policy

Your Order Execution Policy

POLICY TO ACT IN THE BEST INTEREST OF THE CLIENT AND ORDER EXECUTION POLICY

139 Makarios Avenue, Zavos Business Center, 3 rd Floor 3021 Limassol, Cyprus Investments Ltd Tel: , F:

BEST EXECUTION AND CLIENT ORDER HANDLING POLICY FOR PROFESSIONAL AND RETAIL CLIENTS

MEDIOBANCA MANAGEMENT COMPANY S.A. BEST EXECUTION POLICY

January ABN AMRO Global Markets Order Execution Policy Professional Clients

APPLICABLE AS FROM

William Blair: Client Order Execution Policy

Liquidnet Order Execution Policy

Order Execution Policy for Retail Clients Settling Through Pilling Cantor Fitzgerald Europe ( CFE )

Order Execution Policy January 2018

CLIENT ORDER EXECUTION POLICY

INFORMATION ON THE ORDER EXECUTION POLICY OF PATRIA FINANCE FOR PROFESSIONAL CLIENTS

ORDER AND BEST EXECUTION POLICY

Order Execution Policy Disclosure. Effective as at 3 January 2018.

FXBFI Broker Financial Invest Ltd (Regulated by the Cyprus Securities & Exchange Commission) SUMMARY BEST INTEREST AND ORDER EXECUTION POLICY

Order Execution Policy. 12 September 2017

Summary of Scotiabank London Best Execution Policy

SCOTIABANK SCOTIABANK ORDER EXECUTION POLICY DISCLOSURE STATEMENT WITH EFFECT FROM 30 JANUARY 2012

BMI Order Execution Policy

Bank of China Limited, Luxembourg Branch Bank of China (Luxembourg) S.A. 37/39, Boulevard Prince Henri L-1724 Luxembourg

ORDER EXECUTION POLICY

BEST EXECUTION POLICY

Citco Bank Nederland N.V. Order Execution Policy

SUMMARY BEST INTEREST AND ORDER EXECUTION POLICY

Act No. 108/2007 on Securities Transactions

Order Transmission and Execution Policy

Sberbank CIB (UK) Limited

BEST INTEREST AND ORDER EXECUTION POLICY

Transcription:

Order execution policy April 2016 1. Introduction 1.1 Under the rules of the Financial Conduct Authority ( FCA ), Marex Spectron is required to take all reasonable steps to obtain the best possible result for our clients when executing orders, or when transmitting an order to another entity for execution, taking into account various factors and criteria. 1.2 Marex Spectron is committed to providing a high quality execution service on a consistent basis across all markets, clients and financial instruments in which Marex Spectron operate. The purpose of this document is to provide clients with appropriate information on our order execution policy in order to enable clients to make a properly informed decision about our services. 2. Scope 2.1 This policy applies to the receipt, transmission and execution by any Marex Spectron entity resident in the European Economic Area of client orders which: (i) satisfy the criteria in paragraph 2.3 below; and (ii) do not fall within any of the exceptions in paragraph 5 below. 2.2 The relevant Marex Spectron entities (collectively and individually Marex Spectron or we ) are: Marex Spectron entity FCA Firm reference number Marex Financial Limited 442767 Marex Spectron International Limited 193027 2.3 The criteria required to be satisfied for this policy to apply are as follows: The order is for a Financial Instrument as defined under the Markets in Financial Instruments Directive 2004/39/EC ( MiFID ). A list of Financial Instruments under MiFID can be found at http://fshandbook.info/fs/glossary-html/handbook/glossary/f?definition=g1519; The order is from a client which has been categorised in writing by us as Professional. The best execution obligation under FCA rules does not apply to orders from clients classified as Eligible Counterparties ; and The order is received by us when dealing as your agent or when dealing as a matched principal on your behalf. 3. Methodology of execution 3.1 In the absence of other express instructions from a client, Marex Spectron has arrangements in place to execute orders (or transmit orders to another entity for execution) which are subject to this policy, in a manner designed reasonably to obtain the best possible result for our clients on a consistent basis. In this respect Marex Spectron takes into account a number of different execution factors and execution criteria. 1

3.2 Whilst Marex Spectron s execution arrangements are designed to obtain the best result on a consistent basis, we cannot guarantee that we will always be able to achieve best execution of every order. Execution Factors 3.3 Price will normally merit a high relative importance in obtaining the best possible result for our clients. However, we may take into account other factors (and at our discretion decide that one or more of them are more important than price) such as: The liquidity of the market; The need for timely execution; The size of the order; The nature of the order; The ability of a venue to manage complex orders; The trading technology capabilities of the venue; Market conditions at the time of the order; Market impact; Historical trading data; The likelihood of execution or settlement; The cost of the transaction; The quality of any related clearing and settlement facilities; Internal or external systems or communications failure; and Any other factor relevant to the execution of the order. Execution Criteria 3.4 Marex Spectron will consider the relative importance of the execution factors above with reference to the characteristics of: The client; The order; The Financial Instrument; and The relevant execution venue(s). 4. Execution Venues 4.1 For each Financial Instrument in which Marex Spectron executes orders we shall select execution venues which enable us to obtain the best possible results on a consistent basis. When executing client orders, Marex Spectron may use one or more of the following venue types: Regulated Markets; Third party firms acting as brokers, market makers or other liquidity providers; Multilateral Trading Facilities ( MTFs ), including a MTF operated by Marex Spectron; Systematic Internalisers; For wholesale energy and commodities orders, our OTC customer base, or A Marex Spectron entity. 4.2 A list of execution venues most regularly used by Marex Spectron to execute orders can be found at www.marexspectron.com. This list of venues is regularly updated. This list is not exhaustive and Marex 2

Spectron reserves the right to use other execution venues where it is deemed to be appropriate in order to comply with our obligations under this policy. 4.3 In selecting execution venues we take into account the execution factors and the execution criteria referred to above. Marex Spectron will monitor the effectiveness of our order execution arrangements and this policy in order to identify and, where appropriate, incorporate any amendments to procedures. In particular, we assess on a regular basis whether the execution venues we use provide for the best possible result for clients on a continuing basis or whether any changes to execution arrangements are necessary. 4.4 In some circumstances, we may trade on our own account with a client on a (unmatched) principal to principal basis (including where a client elects to use our Internalisation Facility) and in such circumstances we will therefore be the counterparty to a client. In such circumstances, the client orders and resulting transactions will fall outside the scope of our best execution obligations. 4.5 Client orders may be executed outside a Regulated Market or MTF where we have obtained a client s express prior consent (or where a Financial Instrument is not admitted to trading on a Regulated Market or MTF). 4.6 In relation to some Financial Instruments, there may only be one possible execution venue. If so, Marex Spectron will assume that executing an order through such venue on a timely basis or otherwise in accordance with the terms of the order will satisfy our order execution policy obligations. 4.7 For certain Financial Instruments, and in the absence of a client specifying a particular execution venue, Marex Spectron may use a Smart Order Routing facility either provided by a Marex Spectron entity or a third party (which will determine the execution venue used). 4.8 In the wholesale energy and commodities markets in which Marex Spectron operates, selection of an execution venue and obtaining the best possible result for clients will be subject to the following additional factors: We can only give clients visibility to prices that have been communicated to us by other clients that operate in the same relevant market, and the best possible result for a client will be solely within this limitation; We will provide details of all tradable bids and offers; Time availability of prices in many markets there are lulls and spikes in trading as negotiations align trading interests at different times and on different parts of the curve. Accordingly the last traded price may not always be available or act as a reliable indicator of price; We cannot allow a client to trade in a market unless we are reasonably satisfied that a client (via an agent or otherwise) is operationally capable of settling the relevant trade; We cannot control either the cost of credit (credit premium) or credit acceptance between our clients; and Rates of brokerage will differ between clients, based on agreements and levels of activity. 5. Exceptions from best execution requirements The following exceptions apply to our provision of best execution under this policy: 3

Where a specific instruction is given by a client relating to the execution of all or part of an order, or a specific aspect of an order, we will execute the relevant part or aspect of the order in accordance with those instructions; Where a client approaches us on a request for quote basis; Where a systems or other failure or problem means that in order to execute an order, we decide to use an alternative method to that which we would normally select under this policy; Where a client executes an order themselves through an order routing/direct Market Access interface provided by us to an execution venue or we provide sponsored access; Where a client executes an order themselves and elects to execute the order through a Systematic Internaliser. Block trades effected in accordance with the rules of an exchange; Unless a client advises us to the contrary, in the wholesale energy and commodities markets in which we operate, where it is normal market practice for buyers and sellers to shop around by approaching several broker dealers for a quote; Where we are acting in a name passing capacity and we take on an arranging role in a transaction between two or more counterparties; and Where we enter into transactions to unwind a defaulting client s position in accordance with our rights under our agreed terms of business with such client, we will not owe that client a duty of best execution in relation to such transactions. We may take into account any factors in executing such transactions as we determine, in our absolute discretion, to be appropriate. 6. Order handling 6.1 Marex Spectron shall execute client orders promptly, fairly and expeditiously relative to other client orders. Comparable orders will be executed sequentially in accordance with the time of their reception unless the characteristics of an order or prevailing market conditions make this impossible or impractical. Orders on behalf of clients shall be promptly and accurately recorded and, if appropriate, allocated. 6.2 Depending upon the circumstances and the prevailing market conditions, Marex Spectron may decide to aggregate a client s order with orders of other clients if the order is executed on a venue where order aggregation is permitted and we consider that the aggregation of orders is unlikely to work to the overall disadvantage of any client whose order is to be aggregated. 6.3 As a result of an order being aggregated, it may be executed in the form of a block trade. 7. Limit Orders Applicable rules may require Marex Spectron to publish any limit order placed by a client should we not be in a position to immediately execute it, subject to a client s agreement that we may exercise our discretion to not publish an order which is not immediately executable to a Regulated Market of MTF. 8. Monitoring and Amendment 4

This policy is kept under review and accordingly we may change this policy from time to time to ensure compliance with changes to the FCA Rules in force and, if appropriate, to correct any deficiencies or disclose changes in our order execution arrangements. An up-to-date policy may be reviewed at www.marexspectron.com. 9. Consent We are required to obtain each client s prior consent to our order execution policy. A copy of this policy is made available to each client and a client will be deemed to provide such prior consent when giving us an order. 10. Policy Status This policy does not form part of our standard terms of business with clients and is not intended to be contractually binding. Marex Spectron s commitment to provide a client with best execution under this policy does not mean that we owe any fiduciary responsibilities over and above our specific regulatory responsibilities or any other responsibilities as may otherwise be specifically agreed in writing with clients on an individual basis. 5