ORDER EXECUTION POLICY
1.1. This Summary Best Interest and Order Execution Policy (“the Policy”) is provided to you (our Client or prospective Client) in accordance with the Provision of Investment Services, the exercise of Investment Activities, the Operation of Regulated Markets and Other Related Matters Law 144(I)/2007, as subsequently amended from time to time (“the Law”). Pursuant to the Law Herdos (“the Company”) is required to take all reasonable steps to act in the best interest of its Clients when receive (as defined in the Company’s Client Classification Policy). If the Company classifies a Client as an Eligible Counterparty, this Policy does not apply to such an Eligible Counterparty.
2.2. This Policy applies when receiving and transmitting Client Orders or executing Client Orders for the Client for all the types of Cryptocurrencies offered by the Company.
3. Best Execution Factors
3.1. The Company shall take all reasonable steps to obtain the best possible results for its Clients considering the following factors when executing Clients’ orders against the Company’s quoted prices:
• (a) Price: The Company’s price for a given type of Cryptocurrencies is calculated by reference to the price of the relevant underlying asset, which the Company obtains from third party external reference sources. The Company’s prices can be found on the Company’s online trading Platform. The Company updates its prices as frequently as the limitations of technology and communications links allow. The Company reviews its third party external reference sources from time to time to ensure that the data obtained continues to remain competitive. The Company will not quote any price outside the Company’s operations time therefore no orders can be placed by the Client during that time.
• (b) Costs
• (c) Speed of Execution: The Company does not execute the Client Order in Cryptocurrencies as a principal to principal against the Client, i.e. the Company is not the Execution Venue (as defined in Commission Directive 2006/73/EC implementing MiFID) for the execution of the Client’s order. The Company transmits Client Orders or arranges for their execution with a third party(ies). However, the Company places a significant importance when executing Client’s orders and strives to offer high speed of execution within the limitations of technology and communications links.
• (d) Likelihood of Execution: When the Company transmits Orders for Execution or executes it with another party, execution may be more difficult. The likelihood of execution depends on the availability of prices of other market makers/financial institutions. In some case it may not be possible to arrange an Order for execution, for example but not limited in the following cases: during news times, trading session start moments, during volatile markets where prices may move significantly up or down and away from declared prices, where there is rapid price movement, where there is insufficient liquidity for the execution of the specific volume at the declared price, a force major event has occurred. If the Company is unable to proceed with an Order regarding price or size or other reason, the Order will not be executed. In addition, the Company is entitled, at any time and at its discretion, without giving any notice or explanation to the Client, to decline or refuse to transmit or arrange for the execution of any Order or Request or Instruction of the Client in circumstances explained in the Client Agreement/General Terms and Conditions.
• (e) Likelihood of settlement.
• (f) Size of order
• (g) Market Impact: Some factors may rapidly affect the price of the underlying assets from which the Company’s quoted price is derived and may also affect other factors listed herein. The Company will take all reasonable steps to obtain the best possible result for its Clients.
3.2. The Company does not consider the above list exhaustive and the order in which the above factors are presented shall not be taken as priority factor. Nevertheless, whenever there is a specific instruction from the Client, the Company shall make sure that the Client’s order shall be executed following the specific instruction.
4. Best Execution Criteria
4.1. The Company will determine the relative importance of the above Best Execution Factors (of paragraph 3 above) by using its commercial judgment and experience in the light of the information available on the market and considering:
• (a) The characteristics of the Client order.
• (b) The characteristics of the Forex that are the subject of that order.
• (c) The characteristics of the execution venue to which that order is directed
4.2. For Retail Clients, the best possible result shall be determined in terms of the total consideration, representing the price of the Cryptocurrencies and the costs related to execution, which shall include all expenses incurred by the Client which are directly related to the execution of the order, including execution venue fees, clearing and settlement fees and any other fees paid to third parties involved in the execution of the order.
5. Client’s Specific Instruction
5.1. Whenever there is a specific instruction from or on behalf of a Client (e.g. fills in the required parts on the Company’s trading platform when placing an Order), the Company shall arrange – to the extent possible – for the execution of the Client order strictly in accordance with the specific instruction. It is noted that the specific instruction may prevent the Company from taking the steps in the Policy to obtain the best possible result for the Client.
5.2. Trading rules for specific markets or market conditions may prevent the Company from following certain of the Client’s instructions.
6. Execution on Client Orders
6.1. The Company shall satisfy the following conditions when carrying out Client Orders:
• (a) Ensures that orders executed on behalf of Clients are promptly and accurately recorded and allocated;
• (b) Carries out otherwise comparable Client orders sequentially and promptly unless the characteristics of the order or prevailing market conditions make this impracticable;
• (c) Informs a retail Client about any material difficulty relevant to the proper carrying out of orders promptly upon becoming aware of the difficulty.
7. Execution Venues
7.1. Execution Venues are the entities with which the Orders are placed. For the purposes of Orders for the Cryptocurrencies, some third Financial Institution(s) will be the Execution Venue and not the Company. A list of these financial institution(s) will be made known to Clients in a durable medium or may be publicized on the main website of the Company. The list may be changed at the Company’s discretion by giving at least one business day prior notice to the Clients.
7.2. The Client acknowledges that the transactions entered in Cryptocurrencies with the Company are not undertaken on a recognized exchange, rather they are undertaken over the counter (OTC) and as such they may expose the Client to greater risks than regulated exchange transactions.
8. Client’s Consent
8.1. By entering into an Agreement with the Company for the provision of Investment Services, the Client is consenting to an application of this Policy on him.
9. Amendment of the Policy and Additional Information
9.1. The Company reserves the right to review and/or amend its Policy and arrangements whenever it deems this appropriate without notice to the Client.
Should you require any further information and/or have any questions about conflicts of interest please direct your request and/or questions to firstname.lastname@example.org
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