Introduction

The Company is required to provide its clients and potential clients with a summary of its Order Execution Policy (hereinafter the “Policy”).

Under the above legislation, The company is required to take all reasonable steps to obtain the best possible result (or “best execution”) on behalf of its clients either when executing client orders or receiving and transmitting orders for execution. These rules require firms to put in place an execution policy which sets out how it will obtain best execution for its clients and to provide appropriate information to its Clients on its order execution policy.

This Policy forms part of the Client Agreement. Therefore, by entering into the Client Agreement with The company, you are also agreeing to the terms of our Order Execution Policy relating to financial instruments provided by The company, the contract specifications of which are available online at www.ETInvest.com, as set out in this document.

The Policy is effective from October 2014 and applies to retail and professional clients.

This Policy applies when executing transactions with you for the FX, Commodities and Indices CFD (or “Financial Instruments”) provided by The company. The Financial Instruments provided by The company are Contracts for Difference; it is up to The company discretion to decide which types of Financial Instruments to make available and to publish the prices at which these can be investd. The company, through its investing platform, provides the client with live streaming prices, “Quotes”, as received from its third party liquidity providers.

This Policy applies to retail and professional clients only. The obligation to provide clients with best execution does not apply to clients categorised as Eligible Counterparties.

Execution Venue

When executing your orders, we deal with You as Principal (on a matched principal basis). We are therefore your sole execution venue. Your transactions with us are undertaken over-the-counter (“OTC”) rather than on a regulated exchange or multilateral investing facility (“MTF”). As such, You may be exposed to greater risks than transactions on regulated exchanges or MTFs.

Execution Factors and Criteria

When receiving orders we take into consideration the following factors to decide how to achieve the best possible result for clients:

  • Price;
  • Costs;
  • Liquidity of the underlying market (e.g. for orders outside the normal investing size);
  • Nature of the order;
  • Speed and likelihood of execution and settlement;
  • Any other consideration relevant to the execution of an order.

When executing an order we will generally treat price as the highest priority for ensuring best execution. In applying this Execution Policy, we will strive to obtain the best price for all clients. However, in certain circumstances, other factors will require greater importance than price or costs when obtaining the best possible result.

Price

The prices in which transactions may be executed are provided to You via our platforms. In order to provide the best possible price, we will take all reasonable steps to obtain firm price quotes for execution, representing the price of underlying financial instruments and the costs related to execution.

Once the market price is established, The company will create and insert a “spread”. The rules of specifying the prices are set out in the Agreement and the Spreads Table which are displayed on our website. We reserve the right to amend the spread quoted from time to time.

This Execution Policy does not guarantee that execution at the prices quoted by us will always be executed at a price which is as good as, or better than, one which might have been available elsewhere.

Costs

The company may charge the following costs:

  • Spreads – these are indicated in the Specification Tables which can be located via our website.
  • Commissions – These may be charged on the opening and closing of positions with prior information of the client.
  • Financing Charges – These will generally be charged on FX, Commodities and Indices CFD positions and represent the interest cost of holding the position. The amount charged depends on whether the position is long or short and is based on Libor or any other federal interest rate.
  • Withdrawal fee – A flat fee in value of 25 USD due for withdrawal operations of Client’s funds will be deducted from Client’s funds when processing the payment by wire transfer.

Size

The size of an order also carries a high degree of importance. We set a minimum and maximum size for instruments. The investment will be executed at the discretion of The company.

Nature of the Order

Where clients submit specific instructions, i.e. specifying the price at which an investment is to be closed, those instructions take precedence over other any aspects of this policy. However, where special instructions that are submitted by a client results in us having to use a different process than what is specified in this policy, we will pass on to the client any direct costs incurred. The available type of orders and instructions are specified in the Agreement. You should specifically acquaint with the type of orders and instructions available before investing with The company.

Speed of Execution

We consider speed to be important to our dealing culture, which is why a majority of orders are automated provided You hold enough margin on your account. However, there may be circumstances, such as unusual or volatile market conditions, or even the size of an order, which may result in it being manually quoted. This may cause a delay in processing the order which may affect the price at which your order may be executed.

Specific Instructions

Where You provide us with specific instructions as to the execution of an order, we will execute your order in accordance with your instructions. You should be aware that this may prevent us from following, in whole or in part, our execution policy.

Investing hours

The client acknowledges and agrees that The company will carry out its investing business 24 hours a day, 5 days a week, from Sunday at 10 pm GMT through to Friday at 10 pm GMT or during such other investing hours as are disclosed on the Website, as applicable in relation to each Underlying or market.

Subject to the terms of the Client Agreement, generally, The company will only quote prices and accept Orders or instructions in respect of any Contract during those hours.

Monitoring and Review

We will monitor the effectiveness of our order execution arrangements and this Execution Policy in order to identify any deficiencies, and where appropriate, to incorporate amendments. This Execution Policy will be reviewed at least every 12 months.

We will notify You of any material changes to this Execution Policy or to our execution arrangements.

No Fiduciary Relationship

Our commitment to provide You with best execution does not mean we owe You or assume any fiduciary responsibilities other than those imposed by any applicable rules and regulations or as agreed in our Customer Agreement.