Order execution policy

1. Introduction

We have a duty to treat clients fairly, to conduct our business in an open, honest and professional manner and to act in the best interests of our clients.

We provide financial products and services (examples: trading in contracts for differences and foreign exchange) covering a wide variety of Underlying Markets. This Policy determines the reasonable steps that we will take to provide our retail and professional clients with trading services.

In this Policy:

Bid Offer Spread (also known as Bid-Ask Price) means the difference between the price at which you can sell and the price at which you can buy.

Limit Order means an order to buy or sell a Market when it hits a certain price. This is an instruction to trade at a more favourable price than is currently available.

Market means a unique set of products based on the price movement of an Underlying Market.

Order means an instruction to open or close a Trade in a specific Market.

Trade means an Order that is executed.

Trading Agreement means the agreement that governs your relationship with us with respect to your trading in our products and using our services.

Stop Loss Order means an instruction to deal in a particular Market if our price in that Market becomes less favourable to you. (These Orders are commonly used to provide some risk protection, but are not guaranteed).

Underlying Market means the relevant financial instrument, index, currency pair or other instrument, whose price or value provides the basis for us to establish the price we quote you for a Market.

This Policy does not form part of the contractual terms of the Trading Agreement. In the event of a conflict between this Policy and the terms and conditions of the Trading Agreement, the Trading Agreement shall prevail.

If you require more information or further explanation about any aspect of this Policy, please do not hesitate to contact Client Support at info@gsimarkets.com or telephone +44 207 048 7224.

2. Order Execution

All your Trades are with GSI Markets as counterparty. Trading parameters as to any minimum and maximum sizes that are accepted and our hours of normal trading, together with other key information (example: margin requirements), are detailed for all Markets on our trading platform or upon request to Client Support.

Our trading systems and procedures ensure that our Market prices reflect, at all times, prevailing Underlying Market conditions and are as competitive as possible. Subject to an Underlying Market being closed or suspended, within normal Market hours we make such prices available for Trades within defined Trade size parameters and outside those parameters as we may determine from time to time (where our clients are so permitted with reference to the terms and conditions).

At our sole discretion we may choose to execute a transaction on our own account in order to hedge any particular or residual Market position accruing as a result of your trading. Even where such a transaction may be related to your particular Trade, at no time will we be acting as your agent or owe you a fiduciary duty in respect of your Trade or our hedge.

In providing you with financial products and services we, as your counterparty, act as a principal only and therefore represent the sole execution venue to which you have access and only at a price set by us. Orders are executed on an 'over the counter' (OTC) basis rather than on an exchange or other regulated market.

If you make an Order larger than a size limit specified by us, or in an illiquid Underlying Market, or with a specific request attached, we will proceed to 'work the Order' on a fully disclosed basis. This is where we will make Trades in our own name in the Underlying Market as a hedge against your prospective Trade. Once we have obtained our hedge we may execute your Order as a single Trade or series of Trades.

3.Execution Criteria

In providing trading services, we determine the most advantageous execution for our retail clients and professional clients by taking into account a range of (sometimes competing) factors and criteria. This Policy defines our prioritisation and approach adopted in reflecting those factors and criteria in executing Orders.

3.1 Price

We view the relative importance of the price in the execution of an Order to be of high.

For any given Market we may quote one or two prices: our offer price (the higher one at which you can buy the Market from us) and/or the bid price (the lower price at which you can sell the Market to us).

The calculation of a Market's bid or offer price pays due consideration to the price of the Underlying Market. Where necessary this may then be adjusted to allow for the effect of interest over the period of the Market contract, to take into account any corporate actions and other relevant factors and to include a commission. Prices on our trading platform take into account data from various sources and not directly from one source; they may not match the prices you see elsewhere.

If you choose to make an Order for immediate execution on a bid or offer price shown on our trading platform, execution will be at the latest price as calculated by our pricing system. In some cases this might be more, or less, advantageous than the price originally shown. In volatile Markets, where such an Order has not been rejected for failing our tolerance checks, the divergence in price might be greater. In such cases we view the speed and certainty of execution to be an overriding factor in giving you the most advantageous execution.

We undertake periodic reviews to ensure that the Underlying Market price data we receive represents competitive executable prices.

Some Markets we offer are quoted outside the normal trading hours of the exchange or other regulated market where the Underlying Market is traded. To execute Orders outside such normal trading hours we determine the price at our sole discretion, acting in good faith, and by reference to one or more alternative Underlying Market instruments that are trading, the standing of world market prices at that time and/or to the supply and demand of other clients. At such times our prices may reflect a wider Bid Offer Spread and might be restricted to reduced Trade sizes.

When the Underlying Market is volatile and its price is changing rapidly, we are not able to guarantee that every such price movement will result in a change to the calculated price of the Market. The frequency of updates of our Market price is subject to the technical limitations of computer hardware, software and data and communication links. If you specify a price for an Order (such as with a Stop Loss Order or a Limit Order), where the Underlying Market is moving so rapidly as to 'gap through' the specified price, we will execute the Order for you at the fairest price as possible.

Once a Stop Loss Order price is reached we will attempt to fill your Order at the next price available within a reasonable time. The level at which we fill your Order may be the same, or worse, than the price you specify. Your Order is triggered by our price during our trading hours, not the price of the Underlying Market during its normal trading hours.

We do not guarantee that when we open or close a Trade with you the price will be as good as or better than one you might have obtained elsewhere.

3.2 Costs

We view the relative importance of the costs of execution of an Order to be high.

For most Markets, a commission as well as a Bid Offer Spread is charged. This will only be charged on the execution of an Order which opens a new or closes an open Trade.

The Bid Offer Spread that we charge during and outside normal trading hours for Markets is set out in the 'Market Information Sheets' available on our website or by request. Additional charges or spreads may be charged where this is negotiated with you in advance.

3.3 Total Consideration

We view the relative importance of total consideration in the execution of an Order to be high.

In determining the various priorities and weights of all the different factors and criteria that we will take into account in the execution of Orders for clients, we will usually attach the highest relative importance to total consideration. This will usually comprise the price and costs related to execution, although in some circumstances we may determine that other execution factors (in particular: speed and certainty of execution) are more important than price and/or cost in obtaining the best overall outcome for you.

3.4 Size of Orders

We view the relative importance of the size of Orders in the execution of an Order to be high in circumstances where it might influence the choice of our hedging execution venue, and the overall price of execution might inevitably be affected at the expense of achieving the requested size.

Execution will not generally be affected by Trade sizes where the Order is within any pre-defined minimum and maximum limits. Such Orders will be executed automatically by our trading platform. Larger maximum size restrictions will generally apply to Orders executed by telephone where we have agreed to provide you with this service.

Where your Order size is greater than our predefined limit, it will become an important factor in the execution of your Order. With the exception of foreign exchange products, if your Order is of a particularly large size we may work the Order in tranches in order to be able to achieve complete execution and to do so for the most advantageous price outcome. Such orders will usually be executed in tranches up to or equal to the normal Market size. In such circumstances, the price may vary between tranches. Depending on our arrangement with you those individual tranches may be passed on to you as obtained, or be converted into a single Trade at the aggregate average price.

Where execution of a client Order requires us to work our hedge in tranches in the Underlying Markets, this is done by placing our Orders in the particular execution venue on a first-in-first-filled basis (i.e. in the same sequence we receive your and other client Orders), unless the particular specifics of an Order or the market conditions mean that this is either impractical to do so or risks a potential negative impact.

For foreign exchange products we will generally not work large Orders in tranches and will deal with such Orders on 'fill or cancel' basis.

Whilst your Stop Loss Order, Limit Order or opening Order may be of a size that might be executed automatically within normal trading hours, it might exceed the maximum size limit when out of normal trading hours. In such circumstances, execution may be carried out in tranches where the price may vary considerably for each tranche.

3.5 Speed of Execution

We view the relative importance of the speed of execution of an Order to be high.

Should Market circumstances result in unusually high demand, then automatic Market pricing might be temporarily superseded wholly or in part by manual pricing and execution. During such times this might cause delays in speed of execution which itself may impact on the price at which Orders are executed. We have procedures in place to minimise the risk and impact of such delays.

3.6 Likelihood of Execution

We view relative importance of the likelihood of execution and the minimisation of uncertainty to be of high.

When executing through our trading platform, we provide you with screens showing continuously updating prices for Markets offered and, subject to trading times and trading size limits, you have the ability to trade immediately and with a very high degree of certainty.

In order to increase the likelihood of execution for larger Orders and Orders of clients trading by telephone, we ensure that we have the necessary access to trading venues and third-party market makers likely to have the required liquidity to enable us to hedge prior to executing the Order.

3.7 Nature of the Order

The type of Order, including whether it is a Stop Loss Order, Limit Order or opening Order, can be an important factor in relation to execution where this might determine whether the Order is priced and executed manually rather than automatically.

3.8 Market Circumstances

In certain circumstances, the nature of the Market traded (particularly when involving equities) may become an important determinant in the execution of the Order. Where circumstances relating to an Underlying Market might affect the future price and the value of the Order going forward, we will take reasonable efforts to achieve a fair execution for you.

3.9 Specific Instructions

If you give us specific Order instructions, those instructions will take priority over other determinants as set out in this Policy. Where such instructions are not comprehensive we will revert to this Policy as and when necessary. However, in general, we will still exercise our judgement in balancing the various factors in order to obtain the most advantageous outcome for you on a consistent basis.

Where execution under your specific instructions results in us having to use a different process than that specified in this Policy, we may have to pass the direct costs incurred on to you in accordance with the terms of your Trading Agreement.

4 Aggregation of Orders

4.1 Client Orders

We may sometimes combine two or more Orders from different clients in order to execute a single transaction. This will be where we believe reasonably that it is in your overall best interest and is unlikely overall to be to your disadvantage.

4.2 Aggregation of Client Orders with our own Orders

Where our risk requirements dictate that we must execute an Order in an Underlying Market related to the Market of a client's Order and we receive more than one client Order for that Market, then we will execute the Orders on a first-in-time basis, unless the client Orders can be combined to obtain a better execution outcome for our clients.

5 Fiduciary Duty

Although we aim to operate in accordance with this Policy, this Policy does not create any legal obligation or duty, fiduciary or otherwise, over and above our duties to you under the Trading Agreement or any regulatory obligations.

6 Monitoring and Review of this Policy

We will, on a regular basis, monitor our operations in relation to this Policy. A periodic review will be made of the execution venues and data sources we rely upon to provide pricing information. Where we identify the need to make any material change to either this Policy or to our Order execution arrangements, such changes will be fully disclosed to you.