Order Execution Policy
Order Execution Policy
1 Background
1.1 Introduction
Under the rules of the Financial Conduct Authority, Tradeslide Trading Tech LTD (“The Firm”, “we”, “us”, “our” and, “ours”) are required to take all sufficient steps to obtain the best possible result when executing Orders on your behalf, taking into account a range of factors.
This is referred to as providing you with "best execution". This policy sets out our approach for carrying out Orders from origination to execution, the venues we use and an explanation of how the different factors influence our execution approach, so that we can obtain the best possible result when executing your Orders.
1.2 Purpose and scope
The Policy forms part of our Agreement, and shall govern your relationship with The Firm, including any Orders you place with us in respect of leveraged derivatives instruments we offer. It is intended to be read alongside our Terms & Conditions and the other documents that form our Agreement. If there is any inconsistency between this Policy and our Terms & Conditions, this Policy will prevail. Unless separately defined in this document, words and expressions have the meanings given to them in our Terms & Conditions.
Some of the instruments we offer - FX Contracts (rolling cash settled spot FX and NDFs), Commodities Contracts (rolling cash settled bullion, base metals or energy spot or forward contracts) and CFDs - are leveraged products traded over-the-counter (OTC) that carry a high degree of risk. They are not suitable for everyone.
You should not trade with us unless you understand the nature of the transaction you are entering into and the extent of your potential loss from a trade. You must satisfy yourself that it is suitable for you in the light of your circumstances, financial resources and investment objectives. If you are in any doubt you should seek independent advice. You trade entirely at your own risk
2 Execution Venues
We execute some of the orders in OTC-traded assets you place with us by placing an order identical on LMAX Exchange or in other Liquidity Pools (the “Execution Venues”), while other orders in OTC-traded assets are internalized if there is room in our risk limit book.
2.1 LMAX Exchange
We may place your orders on LMAX Exchange. The Firm is an indirect client of LMAX MTF Services for the purposes of trading CFDs and accesses the LMAX MTF Services for trading NDFs and LMAX Exchange Services for other Instruments as an indirect client of a Bank Member.
The Firm has selected LMAX Exchange as they are fully committed to the FX Global Code and is committed to conducting its FX market activities in a manner consistent with the principles of the Code. It has sought to align its activities with the principles of the Code and has gone beyond the minimum standard set out in the Code by prohibiting last look.
2.2 Other Liquidity Pools
We may execute orders on other Liquidity Pools, via our Prime Brokerage providers. In doing so, where possible we will reference other available market prices and demonstrate that we have satisfied our best execution obligations to you.
The Firm gives priority to Prime Brokerage providers that are committed to the FX Global Code and conduct its FX market activities in a manner consistent with the principles of the Code.
2.3 Interactive Brokers
For the execution of orders in Exchange-traded assets we have partnered with Interactive Brokers. Prior to placing such orders you will be required to open an Interactive Brokers Sub-Account with us. We will provide you with a mechanism to submit such orders yourself electronically directly to Interactive.
3 Execution of Orders
3.1 Execution of orders
We execute some of the OTC orders you place with us by placing an order identical in all respects apart from settlement (a Back to Back Order) on the Execution Venues. Note that the OTC-traded instruments we offer you are cash settled. We place orders as principal and not as an agent on your behalf; we are the sole counterparty to your trades. Other orders are internalized if there is room in our risk limit book.
For Exchange-traded assets, Interactive Brokers shall receive and execute orders directly or by transmitting them to a market center for execution. Interactive shall execute orders as agent, unless otherwise confirmed. Interactive is authorized to execute orders as principal. Interactive may utilize another executing broker to execute orders.
3.2 Prices
The prices on which you trade OTC-traded assets with us will generally be the prices available to us on the Execution Venues, although we reserve the right to add an additional spread at times. Notwithstanding, the prices of such Orders may differ from the prices that are displayed at the time that you place your Order to trade with us due to factors such as quantities on the order book, speed of execution and your choice of connectivity.
3.3 Specific instructions
If you provide us with specific instructions on how to execute your Orders, as is the case with FIX based Limit Orders submitted via our Software Bridges, we will have complied with our obligation to take all sufficient steps to obtain the best possible result when executing your Order by following your instructions.
If you give us specific instructions on how to execute your Orders, our resulting compliance with these instructions may prevent us from following the execution factors set out below. These factors are intended to provide you with best execution. Notwithstanding, where there is a specific instruction from you to execute a particular Order, we shall execute the Order following such specific instruction. Accordingly, this Policy shall not apply. We will deem Orders received via direct market access systems as specific instructions.
4 Best Execution Factors
It is our regulatory obligation to take all sufficient steps to obtain, when executing Orders, the best possible result for our clients taking into account price, costs, speed, likelihood of execution, size, nature or any other consideration relevant to the execution of the Order.
Therefore for Orders that are not wholly covered by your specific instructions, we shall determine the best possible result by taking into consideration the factors outlined below. The execution factors which we take into account when we execute your Orders and their relative importance are as follows:
4.1 Price - highest importance
The prices we display are described in our Terms & Conditions. Our prices generally mirror those of our Execution Venues and may differ from those on other venues for assets traded over the counter. An Order placed with us for a specific size can result in a number of partial fills being executed on different execution venues to fill that Order in whole or in part. If that occurs, the prices you receive from us will depend on the liquidity on the Execution Venues at the time that the corresponding part of our trade is executed and the prices may differ for each of the trades executed.
4.2 Speed, consistency and likelihood of execution - high importance
You may place Orders with us online via our Trading Platforms or a Software Bridge. We are under no obligation to accept an Order from you. However, we shall normally do so if you have sufficient funds in your Account with us, you are not otherwise in breach of the Terms & Conditions and it is possible to execute such Order.
Factors such as the size of your Order and liquidity available in the Instrument you wish to trade will impact whether and when it is possible to execute your Order. The times at which you are able to submit Orders to us are restricted. Please refer to our Execution Conditions section for further details.
It is important that you familiarise yourself with the restrictions on the submission of Orders before you commence trading with us, for these restrictions may affect your trading strategy. In order to provide protection against the potential adverse consequences of erroneous Orders we may reject any Orders that lie outside of a defined range. The ranges are, through necessity, constantly changing due to the volatile nature of financial markets. We may be unable to execute all or part of your Order if there is insufficient liquidity in the Instrument you wish to trade. If this occurs, the part of the Order that did not execute would be cancelled.
4.3 Quantity available to trade - medium importance
We have restrictions in place in terms of the minimum and maximum size of position you may hold in an Instrument at any one time. Any opening Order you place with us will be subject to these restrictions. Our minimum and maximum position sizes are set by us for each Instrument and may vary depending on current market conditions. Our minimum and maximum position sizes as they apply from time to time can be found on the Graphical User Interfaces we supply.
4.4 Cost - low importance
We will levy a separate commission charge for each trade that is opened or closed on your Account. You may incur an additional ‘spread’ charge with us as your trade is executed by us. You will pay the same commission regardless of which Execution Venue fills your order. Because we pay very similar – if not outright identical – commission to hedge your orders with either of the venues available to us, neither the commission you pay us, nor the commission we pay the venue is a factor for choosing whether to fill Orders on either of the venues available to us. Financing charges or adjustments may apply to your trades. If applicable, these charges or adjustments will result in a debit or credit being made to your Account at the time the charge or adjustment becomes effective. This will usually occur whilst the affected trade(s) is open on your Account but may occur after that trade(s) has been closed.
We shall wherever possible seek to comply with this Policy when we are required to exercise our judgement in obtaining the best outcome for the execution of your Orders.
5 Review, Ongoing Monitoring and Records
5.1 Review of Policy and Order Execution arrangements.
The Firm will review this Policy and our order execution arrangements annually and whenever there is a material change that could impact parameters of best execution. During the review of this Policy and our order execution arrangements, we endeavour to ensure its effectiveness, to ensure that we continue to comply with our regulatory obligations and that intended best execution outcomes can be successfully achieved on an on-going basis.
The Firm uses a number of methods to monitor best execution for its clients.
We monitor the Best Execution by comparing our executions against an industry benchmark.
We monitor the execution quality of clients and by instrument on a continuous basis using metrics such as slippage, execution time, "rejections", etc.
We specifically measure the execution quality of investors distinguishing between latency due to execution or due to the risk manager.
We have developed a proprietary tool to monitor the price feed of the different Prime Brokers that enables us to offer our clients the best available Prime Broker based on parameters such as the spread and liquidity of the feed.
If at any time we identify any deficiencies we shall take appropriate remedial action and where necessary we shall amend this Policy to give effect to the action we have carried out. Amendments to this Policy shall be effective immediately. You can always find the latest published version of this Policy on our Website.
5.2 Customer communications
We will notify you of any material changes to our order execution arrangements or this Policy in a durable medium or by updating our website. We will also provide you within a reasonable time, should you request, documented evidence which demonstrates clearly that we have executed your orders in accordance with this Policy.
We provide transparent brokerage service – with special focus on order execution quality. This is why we offer you an Order Execution Quality section on our platform where you may cross-check, for every fill of an OTC trade, the Requested vs. Fill Price and the Round-trip latency.
5.3 Record keeping
For the purpose of this Policy, we will maintain records of the prices for individual financial instruments traded over the counter as streamed via our Graphical User Interfaces for a minimum period of 6 months including details about costs, speed and likelihood of execution. We will also keep records which evidence our ongoing monitoring of best execution, and which demonstrate our compliance with best execution obligations to any competent authority as and when required.
Such records shall be kept for a minimum of 2 years. By trading with us, you will be taken as having agreed to the contents of this Policy.
This Policy was last reviewed and approved by the Company Board on 21 July 2021.