Introduction This document contains the most important and relevant elements of our Order Execution Policy and arrangements which enable clients to make a properly informed decision about the use of our execution services.

Application of Best Execution Obligation We are obliged to take all reasonable steps to obtain, when executing orders, the best possible result for our clients (“best execution”) taking into account the execution factors (noted below) where we act on behalf of a client.

In circumstances where we act as principal on own account and do not consider we act on a client’s behalf and do not assume responsibility to provide best execution, we will notify you so that you are properly informed.

Whenever there is a specific instruction from you, we shall execute the order following the specific instruction and compliance with that specific instruction will be treated as satisfaction of the best execution obligation.

Best Execution Factors and Criteria When executing a client order, we may take into account the following criteria for determining the relative importance of price, costs, speed, likelihood of execution and settlement, size and any other consideration relevant to order execution (the “execution factors”):

• (a) the characteristics of the client including its classification as retail or professional;
• (b) the characteristics of the client order;
• (c) the characteristics of the financial instruments that are the subject of that order; and
• (d) the characteristics of the execution venues to which that order can be directed.

Differences in market structure and the structure of financial instruments results in the satisfaction of our best execution obligations in different ways as further detailed below.

The Role of Price It is our general policy for all client transactions not to give execution factors other than price and costs precedence unless they are instrumental in delivering the best possible result in terms of total consideration to the client.

Execution Venues and Liquidity Providers The following applies to retail and professional clients. Subject to any specific instructions from a client, we may use one or more venues and basis of execution to enable us to obtain the best possible result on a consistent basis when executing an order on a client’s behalf.

Basis of Execution & Execution Venues



Order Execution Risks

Slippage

We take reasonable steps so that execution of our quoted prices will obtain the best possible result for clients at the time the quote is provided. However fast moving markets may result in execution of a transaction at a price which has ceased be the best market price.

Gapping/Volatility

There may be significant market movement after a news announcement or economic event or between the close and reopening of a market which will have a significant impact on the execution of a pending order. You should be aware of the following risks associated with volatile markets, especially at or near the close of the standard trading session:

• An order may be executed at a substantially different price from the quoted bid or offer, or the last reported trade price at the time of order entry, or an order may be only partially executed or may be executed in several shapes at different prices; and

• Opening prices may differ significantly from the previous day’s close.

Trading System or Internet Connectivity Execution Delays

Delays in execution beyond our control may occur as a result of technical failures or malfunctions in connection with use of the Trading System or internet connectivity or processing speed for which we do not accept responsibility.



Order Handling A client order is passed through a number of business logic components before hitting the external execution engine. These components deliver all pertinent order details, including the type of order, price, and Time in Force.

Order types


Limit Order Publication (if unexecuted)

If your give us a limit order in relation to shares admitted to trading on an EEA regulated market, we will be required to make public such limit orders to the extent they are not immediately executed under prevailing market conditions unless you consents to our exercising our discretion as to whether to make such limit orders public.

Aggregation

We may combine your order or instruction with those of other clients as a single order. This will be where we reasonably believe that this is in the overall best interests of our clients and is unlikely to work overall to your disadvantage. However such aggregation may work to your disadvantage in relation to a particular order.

Monitoring and Review

We will monitor the effectiveness of our order execution arrangements and this Policy and regularly assess whether or not the execution venues it accesses continue to provide the best possible results for orders it executes on behalf of clients.

Using a risk based approach we will review, at least annually or when a material change occurs, both our order execution arrangements and this Policy. Material changes to this Policy will be notified through our website and be available to actual and potential clients.

Client Consent to Execution Policy and Execution of Order: outside a Regulated Market or MTF

By entering into these Terms of Business or the SECURCAPFX Client Application Form, you consent to the SECURCAPFX execution policy and the execution of orders outside a regulated market or Multi-lateral Trading Facility (“MTF”).