Introduction
Delivering best execution is fundamental to market integrity and to the delivery of good outcomes for clients, and is something we are fully committed to. As the holder of an Australian Financial Services Licence (AFSL), we are required under the Corporations Act 2001 (Cth) to provide financial services efficiently, honestly and fairly, and to act in your best interests where applicable.
Providing best execution under our AFSL requires that when we deal with you, we must take all sufficient steps to obtain the best result for you in accordance with our Trade and Order Execution Policy. This does not mean we must achieve the best possible result on every single occasion. However, it does require us to review and monitor our execution arrangements on an ongoing basis to ensure they are functioning effectively across all stages of the trade lifecycle.
This document sets out the general principles of our execution policy. The full version of our execution policy is available upon request. Unless separately defined, words and expressions herein shall have the meanings given to them in the General Terms. This document does not form part of the contractual agreement between us. If there is any inconsistency between this summary and the full policy, the terms of the full policy prevail.
We deal with you as principal, but we do not make a market. We source pricing externally from third-party liquidity providers and apply a markup in accordance with our AFSL authorisations. You transact directly with us, and we are the sole counterparty to your trade. Any Trades with us are non-transferable. If you create an Open Position with us, you must close it with us.
Execution Policy
In providing best execution, we are obliged to take into account certain execution factors. We must disclose what these factors are and the relative importance we assign to each. If you are a Retail Client, we determine whether we have provided best execution primarily by reference to the total consideration you pay (i.e. price and costs of execution). However, we may also consider other relevant factors such as any instructions regarding price, with the aim of obtaining the best overall result.
The execution factors that we consider and their relative importance are as follows:
Price
Our Price for a given Market is based on pricing obtained from one or more external liquidity providers. We apply a markup to this price, as disclosed in our Market Information and in accordance with our licence conditions. This pricing may vary from that of the underlying reference markets.
Our Price will often differ from the price of the Underlying Instrument. For some Markets we add Our Spread to the externally sourced price. We may also adjust Our Price for any Market to take into account factors such as liquidity in external markets, dividend amounts, financing charges or other relevant conditions. You must pay Daily Financing Fees, commission and other charges in addition to Our Price for some Products and Markets – see under “Costs” below.
During periods of high volatility or rapid market movement, not every price change in the Underlying Instrument will be reflected in Our Price. While we aim to update Our Price as frequently as reasonably possible, our ability to do so may be impacted by technological factors such as software, data feeds and communication infrastructure.
We may quote Our Price outside of trading hours for the Underlying Instrument. In such cases, Our Price is derived from one or more alternative reference instruments or synthetic prices and may be adjusted based on client demand. In such cases, Our Spread may be wider and our maximum tradable Quantity may be reduced.
We execute all Trades at Our Price and in accordance with the General Terms.
Costs
In many Markets, Our Price includes Our Spread, with no additional commission. In other Markets, we may charge a separate commission per Trade.
We may also pass on charges related to the Underlying Instrument, such as borrowing costs or stamp duty, where applicable.
Additionally, for many Markets, you are required to pay Daily Financing Fees on the full notional value of an Open Position. These fees are disclosed on our Website.
We charge a premium for Guaranteed Stop Loss Orders. Full details of all charges are available in the Market Information.
Speed and Likelihood of Execution
You may execute Trades via our Trading Platform or by calling our dealers.
When trading on the platform, if your requested Quantity is below our maximum Quantity, execution will typically occur instantly at Our Price as shown in the Deal Ticket. Trades will be executed in accordance with the General Terms.
If trading by phone, you will typically be quoted the same Our Price as on the platform for permitted Quantities, and execution generally follows your confirmation without delay.
Trades will be executed as soon as reasonably possible. However, delays may occur due to market illiquidity or other unusual order characteristics.
Quantity
We normally guarantee execution for Quantities within our defined minimum and maximum thresholds.
These thresholds vary by Market and may be adjusted based on current market conditions. These values are listed in the Market Information or can be obtained from Client Management.
For Orders exceeding our maximum Quantity, we may quote a different Our Price. Alternatively, and only if agreed with our dealer, we may work the Order through external sources on your behalf.
Working an Order in the Market
The Our Price at which a worked Order is executed will reflect the average price obtained from our external liquidity providers or execution counterparties. Such Trades may be subject to additional charges, as set out in the Market Information.
A Trade becomes effective after we have confirmed pricing from our providers and you have accepted the quote. Once we have commenced execution on your behalf, cancellation of the Order is generally not permitted, although we may agree to cancel any unexecuted portion.
Dealing with your Orders
In most cases, Orders will be executed at or very close to your specified Order Price. However, for all Orders except Guaranteed Stop Loss Orders, execution price is not guaranteed.
Due to rapid market movements (‘gapping’), Our Price may move from below to above your specified Order Price (or vice versa) without passing through the intermediate level. In such instances, the execution price may be significantly different from your Order Price.
If the Order Quantity is less than our maximum Quantity, execution will generally occur at or near the specified price.
If you place multiple Orders in the same Market at the same price, and their combined Quantity exceeds our maximum, each Order may be filled at different prices depending on liquidity. Earlier Trades may affect pricing for later ones.
All Orders are executed in accordance with the General Terms.
Specific Instructions
You may provide us with specific instructions on how to execute an Order.
Following these instructions may prevent us from taking the steps outlined in this document to achieve the best possible outcome for that element of the Order.
Our Obligations
We will comply with our Trade and Order Execution Policy when executing or transmitting client Orders.
We are required to exercise judgment to achieve the best possible outcome for our clients, within the context of our execution arrangements.
As an ASIC-licensed intermediary, we have an overriding obligation to provide financial services efficiently, honestly and fairly. We do not make a market or hold proprietary positions. Instead, we source pricing from external providers and apply a disclosed markup.
We maintain internal policies and procedures, including a Code of Conduct for our staff. Any breaches or suspected breaches of this Code must be reported to the Head of Compliance or General Manager.
Monitoring and Review of Our Policy
We monitor compliance with our policy and retain records of data used to set Our Price.
We review this policy periodically and assess
- The sources of external pricing used for Underlying Instruments;
- The consistency of Our Price relative to reference markets;
- The fees and charges we apply.
Material changes to this policy will be communicated via email or published on our Website or Trading Platform.