SPREADEX

ORDER EXECUTION POLICY

Spreadex Limited is Authorised and Regulated by the Financial Conduct Authority in respect of its spread betting and CFD business. In accordance with the requirements of our regulator, we have implemented a number of steps designed to enable our clients to get the best possible outcome when they enter into financial spread bets and CFDs with us.

Financial Spread Bets and CFDs

We have established and implemented arrangements that we believe will provide you with the best result when you execute transactions with us.

Spread bets and CFDs are bilateral contracts between two principals. When you carry out transactions in spread bets and CFDs with us, we will be the only execution venue available to you, our price will be the only price, and you will not be dealing within or on the underlying market. We have therefore made arrangements for our prices, as far as possible, to reflect prices available in the underlying market and we take all sufficient steps to achieve the best possible result for you when executing a transaction according to this Order Execution Policy and subject to any specific instructions received from you.

RETAIL AND PROFESSIONAL CUSTOMERS

The majority of our clients are categorised as Retail clients, however, we also carry out transactions for clients categorised as Professional clients.

When we execute client orders, we follow the same process irrespective of the categorisation of the client.

Execution Factors

We consider a number of factors in deciding how to execute client orders, and unless we agree otherwise, we will proceed on the basis that the most important factor to our clients is determined by the total overall cost of a transaction, Total Consideration, which includes the price of the financial instrument as well as the costs relating to execution.
 
We seek to base our bid and offer prices on the underlying market. We have access to a number of different data sources from which we determine our prices. These prices may not match prices that you see elsewhere, including those quoted on trading venues or by other providers. Further details can be found in the Execution Venues below.

Other execution factors that we consider are:

•    speed of execution,
•    likelihood of execution,
•    size of the transaction, and 
•    nature of the transaction.

Unless we agree otherwise with you, we will as far as practical, execute orders following receipt. We will not delay execution of an order in the hope of a change in market conditions. The speed of internet connections, and the performance of third-party software or applications may all impact on the size of any potential price change between the time an order is requested and the time it is received, processed, and executed by us. We base our prices only on the prices which are immediately available to us at the point of execution.

We generally only execute orders during market hours and dependent on prices being available in the underlying market or with other providers, the likelihood of execution can therefore be affected by liquidity in underlying market(s).
 
Spreadex operates tiered spreads, under which spreads increase proportionately to the size of the requested order. This aims to reflect the underlying liquidity of the market and is intended to maximise the chance of your order being accepted.

The size and nature of your order may impact the price and likelihood of execution, it may not always be possible to execute an order where there is insufficient liquidity or price availability in the underlying market.

Execution Venues

We seek to manage our risk as a market maker, and in doing so, we may choose to hedge all or part of your order(s) in the underlying market(s). It is our belief that this approach is likely to result in reduced execution costs and better prices for our clients overall. 
Where Spreadex determine that hedging in the underlying market is required to execute your order, the price of the contract that Spreadex enters into with you may be affected, due to it taking into account the prevailing market prices available to Spreadex. 

Spreadex’s key Execution Venues are:

•    Morgan Stanley
•    Cantor Fitzgerald
•    IG Index
•    ADM
•    Killik & Co
•    Maybank
•    Patronus Partners

Details of our selected price source for each contract can be found on our market information pages.

Specific Instructions

Where we accept specific instructions from you in relation to an order, we will give priority to those instructions when executing the order. On executing an order in line with specific instructions we will have satisfied our best execution obligations, in respect of the part or aspect of the order to which the instructions relate. 

You should also note the costs disclosed on the market information pages reflect the costs we incur in managing risk at our selected venue. If you give specific instructions that require the risk on a particular order to be managed in a different way, the applicable costs may vary. We will provide you with any relevant details before accepting your order.

You can adjust tolerance thresholds when placing an order, which will dictate the likelihood of an order being successfully executed or rejected. Spreadex shall only ever partially fill an order as an alternative to an outright rejection. You are also able to adjust your preferences on whether you wish to accept partial fills for an order. 

trading outside market hours

If at the time you give us an order there is no functioning or open market or exchange on which the reference product is traded, we may, and where possible, set out to determine a fair underlying two-way price. This can be based on a number of factors including but not limited to, price movements on associated markets, other market influences and client trading flow.

Limitation

We act as true principal for our own account at all times. Our commitment to provide best execution will not result in us owing any fiduciary responsibilities beyond what is required under the rules of our regulator or as may otherwise be contracted between us.

CONFLICTS OF INTEREST

Spreadex will not receive any remuneration, discount or non-monetary benefit for routing client orders to a particular trading venue or execution venue which would infringe the requirements on conflicts of interests or inducements.  

The Spreadex Conflicts of Interest Policy can be found at Conflict Of Interest Policy | Terms and Agreements | Spreadex

MONITORING OUR EXECUTION

As part of Spreadex’s governance process, execution data is regularly reviewed and assessed to monitor the effectiveness of our Order Execution Policy.

We maintain relationships with leading pricing providers and data vendors to deliver our prices to our platform, as well as using global execution venues to provide liquidity. We regularly review and assess all such relationships to determine whether they permit us to achieve best execution on a consistent basis or if changes are needed to these arrangements.