In order to comply with the requirements of the Markets in Financial Instruments Directive (MiFID) this document sets out the steps that InterTrader Limited will follow in order to obtain the best possible result as consistently as possible 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 also infers acceptance of our Order Execution Policy outlined in this document
The Execution Policy applies when orders are executed by InterTrader Limited on your behalf relating to financial CFDs and Spread Betting transactions. All orders will be mark-to-market via exchange counterparties, however in all circumstances, we will be acting as principal and, as such, we are your order execution venue. There will be zero mark up on the exchange traded execution to you, the client. The majority of your instructions are executed on an over the counter (‘OTC’) basis but we may direct some of the trades through a regulated market or multilateral trading facility (MTF). 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.
An execution venue is a regulated market, Multilateral Trading Facilities (MTFs), or systematic internaliser or other liquidity provider (i.e. an off-exchange dealer). We are your execution venue but an identical order will be executed on these execution venues by or through the entity selected by Intertrader Limited and to whom Intertrader Limited transmits the order. Venues other than regulated markets and MTFs (e.g. off exchange dealers) may also be used as execution venues in exceptional circumstances.
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 high.
The strike price is determined by the price we are able to obtain for the underlying instrument 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.
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.
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. 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.
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.