1. Purpose and scope
This Policy explains how we handle and execute your orders, the factors we take into account, and the arrangements we maintain to obtain a good result for you consistently.
It forms part of, and must be read together with, the Client Agreement (Terms of Business). Where this Policy and the Client Agreement conflict, the Client Agreement prevails. It applies to every order you place on any Instrument we quote.
2. Two separate processes
The single most important thing to understand about how we work:
How your order is executed, and how we manage the risk that results from it, are two separate processes. The first is automated and happens at the price the market gives. The second happens afterwards, on our own book, and cannot reach back into the price you received.
Sections 3 and 4 describe them in turn.
3. How your order is executed
3.1 Execution is automatic. Your orders are executed automatically by our systems against our quoted price. No person approves, rejects, delays, withholds or intervenes in the execution of your order.
3.2 We do not requote. You are not asked to accept a new price because the market moved, or because of what your order would mean for us.
3.3 We do not filter by client or by profitability. Execution does not vary according to who you are, how profitable your trading has been, or the direction of your order. There is no separate handling for clients who trade well.
3.4 Slippage is symmetric. Your order executes at the next price available to us, which may be better or worse than the price you saw. We do not apply positive and negative slippage on different terms, and we do not withhold price improvement.
3.5 Speed — typical, never guaranteed. We maintain low-latency infrastructure, and order execution typically completes within 25 to 50 milliseconds.
That is a typical range and not a guarantee, and we do not undertake to achieve it. We depend on our liquidity providers, and conditions affecting them affect us. Execution time, order rejections, spread widening and available depth are all influenced by factors outside our control — market volatility, news events, thin liquidity, and the performance or withdrawal of one or more liquidity providers — as well as by your own connection and by load on our systems. In such conditions execution may take materially longer, spreads may widen substantially, and orders may be rejected.
3.6 The commitments in Clauses 3.1 to 3.4 apply to every order, without exception, regardless of anything in Section 4.
4. How we manage the resulting risk
4.1 We deal as principal. Every Position you open is a contract between you and your Contracting Entity — we are your counterparty, not your agent, and your order is not executed on an exchange in your name. Our prices are our own, derived from the underlying market but not identical to it. Clause 6 of the Client Agreement sets this out in full.
4.2 Our primary model is to hedge. Our ordinary practice is to pass the risk arising from client trading to our liquidity providers. We seek to avoid holding a directional position against our clients, and that is how the substantial majority of client trading is handled.
4.3 What our dealing desk does. We operate a dealing desk. Its role is to monitor market conditions and the performance of our liquidity providers, to manage our own risk, and to support clients with deposits, withdrawals and order requests. It does not intervene in the execution of your orders — see Section 3.
4.4 We are authorised to deal on our own account, and in limited cases we do. Our Investment Dealer Licence permits it and we retain that right. In practice it applies to a small proportion of accounts and positions, at our discretion.
4.5 The conflict, and how we manage it. Where we retain risk, your loss on that Position is our gain and your profit is our loss. That is a conflict of interest and we disclose it rather than deny it. It is contained by the separation in Section 2: the decision about our own risk is made after execution, and the commitments in Clauses 3.1 to 3.4 apply to your order either way.
4.6 We are not obliged to tell you, for any particular Position, how we have managed the risk arising from it.
5. Execution factors
| Factor | Weight |
|---|---|
| Price | Generally the most important factor for a retail client |
| Costs | Spread, commission and any applicable financing |
| Speed of execution | High importance in fast-moving markets |
| Likelihood of execution and settlement | High importance in thin liquidity |
| Size of the order | Relevant where size exceeds readily available liquidity |
| Nature of the order | Market, pending, or attached order |
| Any other relevant consideration | Including prevailing market conditions |
Price and cost are ordinarily the most important factors for a retail client. We may prioritise another factor where circumstances require — for example prioritising likelihood of execution over price in a fast or illiquid market, where an order that does not fill at all is the worse outcome.
6. Pricing and liquidity
6.1 We construct our own quote from pricing obtained across a range of liquidity sources, which may include tier-one banks, non-bank electronic market makers and liquidity aggregators. We select and review those sources on pricing quality, depth, consistency, reliability and settlement capability.
6.2 Spreads are floating. We do not offer fixed spreads. They vary with market conditions and widen — sometimes substantially — during volatility, around economic releases, at market open and close, and in thin liquidity. We maintain our liquidity relationships in order to obtain the best pricing, stability and depth we reasonably can, and we pass that through.
6.3 Our quote is valid for the size and the moment for which it is given.
6.4 You have no direct relationship with any liquidity provider, and no order of yours is executed in your name on any venue. Your Position is with your Contracting Entity.
6.5 All Positions are off-exchange. They are not traded on a regulated exchange and are not cleared through a clearing house. By placing an order you consent to execution outside a trading venue.
7. Order handling
7.1 Order types. Those made available on the Trading Platform and described in the Contract Specifications — which may include market orders, pending orders, and orders attached to a Position such as stop-loss and take-profit orders. Orders may carry an immediate-or-cancel (IOC) fill condition, so any part that cannot be filled immediately is cancelled rather than held.
7.2 Sequence. Orders are handled promptly and in the sequence in which they reach us, unless an order's characteristics or market conditions make that impracticable.
7.3 Partial fills and multiple prices. Where liquidity at a single price is insufficient for your order, it may be filled in part, or across several prices, and your confirmation will show the result. Clause 8.5 of the Client Agreement applies.
7.4 Gapping. Where a market gaps — over a weekend, on a news event, or on a suspension — the next available price may be far from the last traded price, and orders including stop-loss orders execute at that price. A stop-loss order is not a guarantee of the level at which your Position will close.
7.5 Outside quoting hours. Orders placed outside an Instrument's quoting hours execute, if at all, when quoting resumes, at the price then available.
8. Monitoring and review
8.1 We monitor execution quality on an ongoing basis — including fill rates, rejection rates, slippage symmetry and latency — and review our liquidity providers against those measures.
8.2 We review this Policy at least annually, and whenever there is a material change to our execution arrangements. We will notify you of any material change.
9. Questions
If you have a question about how a particular order was executed, contact us using the details on our website. We can review the order and execution record for your Account and explain the outcome. If you remain dissatisfied, our Complaint Handling Policy sets out how to take it further.