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BEST EXECUTION POLICY

Introduction

Overview

The purpose of this document is to provide clients of SVS Securities Plc with information in relation to our Order Execution Policy and to seek your consent to such policy.

The Markets in Financial Instruments Directive (MiFID) requires that we put in place an Order Execution Policy and to take all reasonable steps to obtain the best possible result (or “Best Execution”) on your behalf and to provide you with information concerning our execution policies in respect of transactions we undertake on your behalf.

If you provide us with a specific instruction to deal for you it may prevent us from following our Order Execution Policy, which is designed to obtain the best possible result for you on a consistent basis, taking into account the factors outlined below. This means that you may receive a worse outcome on your order than if we had acted in compliance with our Order Execution Policy, which will be at your own risk. Where your instructions relate to only part of the order, we shall continue to apply our Order Execution policy to those aspects of the order not covered by your specific instructions.

You should be aware that providing specific instructions to us in relation to the execution of a particular order may prevent us from taking the steps set out in our Order Execution Policy to obtain the best possible result in respect of the elements covered by those instructions.

Please note that if our Order Execution Policy is designed to ensure that, on a consistent basis, we deliver the best possible outcome to you through the course of our relationship. This does not necessarily mean that the best possible outcome or price will be obtained in all circumstances.

Our commitment to provide you with the best possible outcome does not mean that we owe you any fiduciary responsibilities over and above the specific regulatory obligations placed upon us or as may be otherwise contracted between us.

Scope

This Execution Policy applies to Retail and Professional Clients only. The obligation to provide clients with best execution does not apply to clients categorised as Eligible Counterparties. This Execution Policy should be read in conjunction with our Terms of Business. By agreeing to our Terms of Business, You are also agreeing to the terms of this Execution Policy.

Execution Factors

Unless you give us specific instructions, the execution factors that we shall take into account in determining the manner in which your order will be executed are the price, cost, speed, likelihood of execution and settlement, size of your order, nature and any other consideration relevant to the execution of your order.

Price will ordinarily merit a high relative importance in obtaining the best possible result. However, in some circumstances for some clients, orders, financial instruments or markets, we may appropriately determine that other execution factors are more important than price in obtaining the best possible execution result.

The weighting of these factors may also differ between Retail and Professional clients and will be judged on an order-by-order basis. In executing orders for Retail clients, in the absence of any specific instructions, we generally give precedence to the factors that allow us to deliver the best possible result in terms of total cost to the client.

When dealing for you we will consider your client categorisation, the characteristics of the financial instrument concerned and of your order and where such orders can be effected.

List of Venues

SVSFX deals with You as Principal in all transactions; and such transactions are undertaken on an OTC, or Over-The-counter basis and not on a regulated exchange. OTC transactions may expose you to greater risks than on exchange transactions.

Specific Instructions

Should a client attach a specific instruction to an order, SVSFX will undertake to execute such order in accordance with such instruction. This specific instruction may prevent SVSFX from taking steps as outlined in this policy to obtain the best possible result for the execution of orders. Should your instructions be incomplete we shall endeavour to follow our execution policy for the parts or aspects of the order not covered by your instructions.

Speed of Execution

All orders executed through one of our dealing platforms are executed automatically so long as you have enough margin on your account. Although SVSFX aims to ensure the fastest execution possible, it is possible that in volatile or unusual market conditions or at other certain times delays may occur.

Size

On our dealing platforms we set a minimum and maximum size for specific instruments; which can be viewed on our website at www.svsfx.com. We seek execution venues likely to provide the greatest liquidity and therefore potential for execution.

Volatile Markets

Clients should be aware that there are risks associated with volatile markets, whether this be at times close to the release of Economic Data or the beginning and end of trading sessions. These risks include, but are not limited to:

  • Execution at a substantially different price from the quoted price or the last dealt price
  • Opening pricing that differs substantially from the previous close
  • Delays in executing orders due to lack of liquidity
Price Improvement and Overall Costs

SVSFX may charge their clients by way of spreads, commissions or daily financing charges. Spread conditions and commissions are available on our website at www.svsfx.com for each of our platforms. Financing charges are defined as the interest cost of holding a position. We apply such financing charges based upon the costs passed to us by our execution venues.

All transactions made by You or for your account are executed as market orders; therefore at trigger of the order the order is passed to the execution venue as a buy or sell order with no price attached to the request. As such the final execution price may be at a price better or worse than that requested. This concept also applies to holiday and weekend execution.

Aggregation

SVSFX may at its discretion aggregate client orders with its own orders, or any of its associates or other clients. Aggregation will only occur if it is unlikely that any such aggregation will work against the client whose order is to be aggregated. On certain occasions such aggregation may work to your disadvantage.

Review

We will monitor our execution venues from time to time in order to ensure compliance with this Order Execution Policy and with our regulatory obligations. Should this monitoring highlight a necessity to affect a material change to this policy then we will notify You of such a chance.

Monitoring

SVS will monitor compliance with its order execution policy and, at least annually, review the effectiveness of the execution arrangements in place. SVS may add to or remove the venues where we execute our trades. Full details of the execution venues currently employed by us will be made available upon request.

SVS will notify its Clients of material changes to its Order Execution Policy via our website at www.svsfx.com

Clients should monitor this site on a regular basis for any changes to the policy. A hard copy of the policy is available on request.

SVS Securities Plc is authorised and regulated by the Financial Conduct Authority (Reg.220929) and is a member of the London Stock Exchange.
© 2017 SVS Securities - All rights reserved.

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