This Order Execution Policy forms part of the Agreement as defined in the Terms of Business
1.1. We have a general duty to conduct business with you honestly, fairly and professionally and to act in your best interests when executing orders. More specifically, when we execute orders on your behalf, we will provide you with “best execution”, meaning that we will operate according to procedures established in order to take reasonable steps to obtain the best possible result for our clients on a consistent basis.
1.2. This Policy is provided to you (our Client or prospective Client) in accordance with the relevant regulations.
1.3. By agreeing to the Terms of Business, you are also agreeing to the terms of this Order Execution Policy (“the Policy”).
2.1. FXmeridian.com (referred hereinafter as “the company”, “we’, “us” or “our”) provides only the execution of orders for trading with contracts for difference (“CFDs”) in stocks, FOREX, ETFs, futures of indices, futures of commodities and exchange traded options.
3.1. When executing your orders, we will take all reasonable steps to achieve the best possible outcome for you by executing those orders according to this Policy and subject to any specific instructions received from you. This Policy comprises a set of procedures that are designed to obtain the best possible execution result, subject to and taking into account the nature of your orders, the priorities you have identified for us in relation to execution of those orders and the practices relating to the market in question. All this aims to produce a result which provides, in our view, the best balance across a range of sometimes conflicting factors. Our Policy cannot provide a guarantee that, when executing an order, our price will always be better than one which is or might have been available elsewhere.
4.1. We act as principal in all dealings and as the sole execution venue for your orders, which are not executed on a regulated exchange or multilateral trading facility. We are required to take a number of factors into account when considering how to deliver best execution. We have rated price as the most important followed by:
4.1.1. cost;
4.1.2. size;
4.1.3. liquidity of the underlying market;
4.1.4. speed; and
4.1.5. likelihood of execution and settlement.
4.2. We provide best execution by ensuring that in arriving at our CFD bid/ask prices, we use the market price for the underlying product to which your order relates. We have access to a number of different data sources in order to generate our market price, our objective view of the bids and offers available to arms’ length traders. We do not consider the above list exhaustive and the order in which the above factors are presented shall not be taken as a priority factor.
4.3. We will determine the relative importance of the above best execution factors by using our commercial judgment and experience in the light of the information available on the market and taking into account the criteria described below:
4.4. For all CFDs we take into account factors such as liquidity, volatility, carry interest, expected dividends and any variations in the underlying contract for the reference date of the expiry. As a result of all these varying factors, our bid/offer prices will generally not be the same as the cash price for the underlying product.
4.5. At the time we receive your order, there may be no functioning market or Exchange which is open for trading of the underlying product. Then the market may be illiquid, trade halted or suspended and other influences may affect the price and we reserve the right not to execute your order under such conditions.
5.1. Slippage: You are warned that Slippage may occur when trading in Financial Instruments. This is the situation when at the time that an Order is presented for execution, the specific price showed to the Client may not be available; therefore the Order will be executed close to or a number of pips away from the Client’s requested price. So, Slippage is the difference between the expected price of an Order, and the price the Order is actually executed at. If the execution price is better than the price requested by the Client, this is referred to as positive slippage. If the executed price is worse than the price requested by the Client, this is referred to as negative slippage. Please be advised that Slippage is a normal element when trading in financial instruments. Slippage more often occurs during periods of illiquidity or higher volatility (for example due to news announcements, economic events and market openings and other factors) making an Order at a specific price impossible to execute. In other words, your Orders may not be executed at declared prices. Slippage may appear in all types of accounts we offer.
There must be noted that the slippage can also occur when we execute a ‘stop loss’, ‘take profit’ or ‘trailing stop’ position at the opening time of the specific market for the underlying asset. When a certain market is open, we would execute any ‘stop loss’, ‘take profit’, ‘trailing stop’ orders: at the price requested by the Client. In the case with ‘stop loss’ and ‘trailing stop’ orders, we cover the difference between the price at which the order was submitted and the market price at which this order could be executed. Pending orders for opening a position are not guaranteed and can be executed at a different price during news or high instability. We do not guarantee the performance of your pending orders at that price, but confirm that your order will be executed at the next best possible market price compared to the price that you have specified in your pending order.
6.1. Under our regulations, the Company will determine the relative importance of the above Best Execution Factors by using its commercial judgment and experience in the light of the information available on the market and taking into account:
7.1. Generally, CFDs based on equity instruments have no expiry date, however, should a transformation event be announced based on a takeover or a re-organisation, the date of the event may be used as the expiry date. All pending orders applied to CFDs on equity instruments based on cum-dividend prices will be valid for the ex-dividend price (and vice versa) unless specifically cancelled by the Client. The above is also valid if the CFD is on futures and the Client has a pending order submitted before the roll-over. Hence, the order will be valid after the roll-over towards the next futures contract.
8.1. The Company shall satisfy the following conditions when carrying out Client’s Orders:
9.1. We will not combine your order with those of other clients for execution as a single order.
10.1. 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 them.
11.1. We will monitor the effectiveness of our order execution arrangements and this Policy. We will assess from time to time whether the venues relied upon by us in pricing our transactions allow us to meet our regulatory obligations on a consistent basis or whether we need to make changes to our execution arrangements or this Policy. Should there be any material changes to our order execution arrangements or this Policy, we will notify you.
12.1. Full details of the trading conditions, including trading hours, for particular products are available on our website www.FXmeridian.com.
12.2. Should you require any further information and/or have any questions, please, direct your request and/or questions to [email protected].
13.1. We provide you with access to our Trading Platform and are not acting in any other capacity including as a fiduciary.
13.2. Our commitment to provide you with “best execution” does not mean that we owe you any fiduciary responsibilities beyond the specific regulatory obligations placed upon us or as may be otherwise agreed between us.