This Order Execution policy constitutes a legal requirement following the Company’s authorization and regulation by the Cyprus Securities and Exchange Commission (“CySEC”) under authorization number CIF 198/13, as detailed below:
The purpose of this policy is to establish effective arrangements for obtaining, when Hoch Capital Limited, hereafter the “Company”, is executing clients’ orders, to the best possible result for its clients.
This document aims to set out those arrangements and to ensure compliance with legislative requirements and the departmental and general procedures, which are set within this Internal Procedures Manual.
This policy shall be read in conjunction with the Dealing Room Manual of this Internal Procedures Manual.
In accordance with the Investment Services and Activities and Regulated Markets Law of 2007, CIFs must take all reasonable steps to obtain, when executing orders, the best possible result for their clients taking into account price, costs, speed, likelihood of execution, size, nature or any other consideration relevant to the execution of the order. Nevertheless, whenever there is a specific instruction from the client, the CIFs shall execute the order following the specific instruction.
In addition, CIFs must establish and implement an order execution policy to allow the CIF to obtain, for its clients’ orders, the best possible result.
The Dealing Room is the relevant department to which the order execution policy mainly applies. Senior Management reviews the policy on an annual basis or / and whenever a material change occurs that impacts the Company’s ability to continue offering best execution of its clients’ orders using the Company’s trading platform.
The Company must establish and maintain an Order Execution Policy, in order to ensure compliance with the obligation to execute orders on terms most favorable to clients and to achieve the best possible results for its clients, taking into consideration its clients’ ability, needs and trading policies, where applicable and possible.
The policy outlines the process that the Company follows in executing trades, and assures taking all reasonable steps to consistently obtain the best possible result for clients through its order execution policy. It is noted however that when executing an order following a specific client instruction, the Company will execute the order in line with those instructions and will consider that it has discharged its best execution obligations.
Best Execution Criteria
The Company will take into account the best execution criteria for determining the relative importance of the execution factors:
- The characteristics of the client
- The characteristics of the client order
- The characteristics of the financial instruments that are the subject of that order
- The characteristics of the execution venues to which that order can be directed.
The best possible result will be determined in terms of the total consideration, representing the price of the contract and the cost related to execution. The other execution factors of speed, likelihood of execution size, nature or any other relevant consideration will, in most case, be secondary to price and cost considerations, unless they would deliver the best possible result for the client in terms of total consideration.
The Company, when managing client’s orders takes into account various execution factors, provided that there are no specific instructions from the client to the Company about the way of execution of the orders. The execution factors include:
- Speed and likelihood of execution
- Costs or commissions
- Size and nature of the order
- Market conditions and variations
- Execution capability
- Any other direct consideration relevant to the execution of the order
In circumstances where the client provides the Company with a specific instruction as to how to execute an order and the Company has accepted this instruction, then the Company will execute the order in accordance with that specific instruction.
Nevertheless, if the client provides a specific instruction to carry out an order, then by executing that order the Company will be complying with the Company’s duty to provide the client with best execution. This may result in being unable to follow the Company’s order execution policy for that particular order.
Execution venues are the entities to which the orders are placed or to which the Company transmits orders for execution. The Company will enter into transactions with the client as principal (counterparty) and not as an agent; even though the Company may transmit the client’s order to the liquidity providers for execution, due to risk parameters (i.e. clients with high volume, big equity, etc.), the Company will still be the contractually counterparty to the client. Therefore, the Company will act as the sole Execution Venue for clients’ orders.
In particular, the Client deposits funds with the Company and places an order via a trading platform and the Company is responsible for safeguarding of clients’ funds. Upon receipt of the order, the Company opens an exactly identical order on its name with the market maker, per order received or accumulatively. In this respect, the Company executes the client order by acting as a riskless principal (i.e. enters into true back to back trades).
The Company will provide its own tradable prices which are derived from independent price providers. The main way in which the Company will ensure that the client receives the best execution will be to ensure that the price provided to the client is made with reference and compared to a range of underlying price providers and data sources. The Company reviews its independent price providers at least once a year to ensure that correct and competitive pricing is offered.
At an initial stage, the Company’s trading platform is integrated with the following price providers:
Bayline Trading Ltd
The provider, is continuously updating its prices, therefore the last updated prices are displayed on Company’s trading platform.
When the client opens a position in some types of financial instruments a commission or a financing fee will apply.
Size of order
All orders are placed in monetary value. The client will be able to place his order as long as he has enough balance in his trading account. If the client wishes to execute a large size order, in some cases the price may become less favorable considering the feed obtained from its price provider.
Obviously, prices change over time. The frequency with which they do varies with different financial instruments and market conditions. Considering that the tradable prices which are distributed via the Company’s trading platform/terminal, technology used by the client to communicate with the Company plays a crucial role. For instance, the use of a wireless connection, or dial up connection, or any other communication link that can cause a poor internet connection can cause unstable connectivity to the Company’s trading platform/terminal. The result for the client is to place his orders at a delay and the order to be executed at better or worst prevailing market price offered by the Company via its platform/terminal.
Nature of the order
The particular characterizing of an order depends on the digital option selected by the client. The value of the option is mainly depended on the volatility of the underlying instrument, the set time of option expiration and the risk management to be selected by the client.
Likelihood of execution
Due to the levels of volatility affecting the underlying instrument’s price, the Company seeks to provide client orders with the fastest execution reasonably possible.
Likelihood of settlement
The Company shall proceed with the settlement of all transactions upon the execution and/or time of expiration of the specific transaction.
The Company’s quoted prices which are derived from its independent price providers may be affected by various factors which could also affect the abovementioned factors. The Company will take all reasonable factors to ensure the best possible result for its clients.
Appropriate information is provided to the client on the content of the execution policy. The prior consent of the client is obtained regarding the documented order execution policy to be followed. In addition, a clear and prominent warning is disclosed to the Company’s clients (within the Client Agreement) that any specific instruction from a client may prevent the Company from taking the steps that is has designed and implemented in its execution policy for obtaining the best possible result for the execution of those orders in respect to the elements covered by those instructions.
Adequate information is provided to the clients through this policy in relation to the factors that are taken into consideration by the management when handling clients’ orders. Also, the policy is reviewed periodically by the Company and the clients are informed accordingly in relation to any material changes.