ORDER EXECUTION POLICY

Introduction

In order to comply with the requirements of the Second Markets in Financial Instruments Directive (MiFID II) this document sets out the steps that InterTrader Limited will follow in order to obtain the best possible result when executing your orders. It should be read in conjunction with our Customer Agreement, Conflicts of Interest Policy and Risk Warning Notice. We have a general duty to conduct our business with you honestly, fairly and professionally. This policy forms part of our Terms and Conditions, and as such acceptance of our Customer Agreement constitutes acceptance of our Order Execution Policy as summarised in this document.

Scope

The Execution Policy applies when orders are executed by InterTrader on your behalf relating to financial CFDs and Spread Betting transactions. Where you execute your order through our online trading platform, we shall assume that you have provided us with specific instructions and in these circumstances InterTrader Limited will have complied with our obligation to take all reasonable steps to obtain the best possible result when executing an order on your behalf.

How we execute your orders

InterTrader deals with you as principal (and not as agent) when executing your orders. We are therefore your only “execution venue”. In dealing with us, you transact directly with us and not on any exchange or other external market or venue.

We have entered into arrangements with different execution parties (liquidity providers) which allow us to create back to back transactions. The client is provided with indicative quotes from our liquidity providers. When a client sends an execution request, this request is transmitted immediately by us as an identical request to the designated liquidity provider (who has been determined on the basis of regular assessments of the quality of available execution data, to offer the best prices for the relevant underlying instrument traded).

Although you are provided with only indicative quotes, we pass on to you any price improvement over and above the quoted indicative price (although we absorb any price slippage from the indicative quote). Our charges are in the form of the bid-offer spread. There is zero mark-up applied by us to the exchange traded execution to you.

The majority of your instructions are executed by us on an over the counter (‘OTC’) basis but we may direct some of the trades through a regulated market or multilateral trading facility (MTF). You consent to our executing your orders outside regulated markets and MTFs.

Execution Venues

An execution venue is a regulated market, Multilateral Trading Facilities (MTFs), or systematic- internaliser or other liquidity provider (i.e. an off-exchange dealer). As we act as principal (and not as agent) in relation to contracts that you enter into with us, we are acting as the only execution venue in connection with your transactions. While we are your execution venue, an identical order will be executed by us with liquidity providers selected by Intertrader and through whom Intertrader transmits the order. Venues other than regulated markets and MTFs (e.g. off exchange dealers) may be used as execution venues.

We ensure best execution for you by reference to the market prices of the underlying reference prices for your transaction. We regularly compare competing liquidity providers for the best prices from which to derive indicative quotes for you. Although we operate as a single execution venue, we are able to obtain best execution for our clients on a consistent basis – compared with outcomes which could reasonably be expected from using alternative execution venues.

Execution factors and criteria

The execution factors and criteria are an important aspect of the process to ensure that the best possible result is obtained. These factors and criteria have been considered in order of the relevant importance we place on them as part of the decision making process and are as follows:

Price and cost

The relative importance we attached to these factors is very high.

There are two components of the price of a financial spread bet / CFD:

  • the price of the underlying instrument derived from our liquidity providers; and
  • our charges in the form of the bid-offer spread (a mark-up or mark-down to the price of the underlying) – the Spread Charge.

The execution price is determined by the price we are able to obtain for the underlying instrument from our liquidity providers and the ‘Spread Charge’, which is defined as the spread which is added to the underlying market price, resulting in the spread bet price. We ensure complete transparency by providing you with access to both the spread bet price and the underlying market price when executing your orders.

Whilst we understand that price is a key factor, we may decide that in certain circumstances other execution factors (see below) are more important in determining the best possible result for you, for retail clients, the best possible result will generally be determined only by reference to the total consideration (price) of the transaction.

OTHER EXECUTION FACTORS

Size of the order and likelihood of execution

The relative importance we attach to these factors is high.
When we accept an instruction from you regarding a spread bet or CFD, we will only accept the instruction on the basis that we would be able to fill at least the equivalent hedge as a proprietary trade in the underlying market.

Speed of execution

The relative importance we attach to this factor is medium.
In most circumstances, spread bets and CFDs requested by you will be processed immediately. However, occasionally situations may occur that prevent immediate execution. For example, there may be a delay in execution should lack of liquidity in the underlying market prevent instant execution of our hedge, against your spread bet or CFD. InterTrader will endeavour to fulfil your instructions within a timely manner wherever the market conditions permit.

Dealing with your orders

Your exposure to our products becomes effective as soon as you receive confirmation from us that your CFD or spread bet has been ‘filled’. It is important to note that we cannot guarantee the execution price of orders. We do, of course, make every effort to execute orders at or very close to the specified order. However, due to movements in the underlying price, it is possible that our price may move quickly or erratically causing market slippage when we execute your orders on your behalf – the price that you obtain at the time of execution may be markedly different to the order price.

With our discretion, it is possible to execute trades through the trading platform outside our trading hours but during the relevant exchange’s opening period. Your orders will not be monitored outside our trading hours and consequently the maximum margin available during this period is equivalent to 100% of our margin requirement.

You may request for your position to be altered on certain triggers such as an adverse market move to prevent significant losses or if our offer price exceeds a specified order price to consolidate profits. In most cases when a ‘stop order’ is triggered, it will be executed at the specified price or at the next available price governed by the underlying instruments price and depth. However, this is not guaranteed. In extreme market conditions where our price may need to change quickly due to changes in the underlying investment, the ‘stop order’ would be filled as soon as possible but in these circumstances you would only be eligible for our price obtainable at the time the order was filled.

Risks

Clients should be aware that in fast moving and volatile markets, whilst we take all reasonable steps to ensure the best possible price, the prevailing conditions may result in a trade price that is no longer the best market price.

Furthermore, during a period of volatile markets, an order may be executed at a substantially different price(s) from the quoted price or may only be executed in part.

Execution quality

When executing orders or taking decisions to deal we check the fairness of the price proposed to you by periodically gathering underlying market data used in the estimation of the price and, where possible, by comparing with similar or comparable products. You can find further information about our execution quality on request.

Review

This policy will be reviewed at least annually and whenever a material change occurs that affects Intertrader Limited’s ability to continue to obtain the best possible result for you. As part of that process we will review the external execution venues we use when proprietary trading which also provide our external reference for pricing purposes. Should we decide to change this policy, we will provide you with at least fourteen days’ notice.

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