Skilling Ltd - Order Execution Policy

This Policy is the property of Skilling Ltd. Reproduction in whole or in part in any way including the reproduction in summary form, the reissue in a different manner and any changes in the original Policy  (V.03) or any translated version is strictly forbidden and is only allowed with the prior written consent of Skilling Ltd. This Policy was last updated on 01 December 2021.

1. INTRODUCTION 

1.1. Skilling Ltd (hereafter the “Company”, “we”, “our”) is authorised and regulated by the Cyprus Securities and Exchange Commission under CIF licence number 357/18.

1.2. Skilling Ltd takes into account the price, costs, speed, likelihood of execution and settlement, size, nature and/or any other relevant order execution consideration, whether we are executing orders on behalf of clients (hereafter the “Client”, “You”, “Your”), providing reception and transmission of orders and execution of orders among services others. 

1.3. The Order Execution Policy (the ‘Policy’) is issued pursuant to, and in compliance with the following: the (EU)Directive 2014/65/EU (“MiFID II”); the the Investment Services and Activities and Regulated Markets Law 87(I)/2017 (the “Law”); the Investment Services and Activities and Regulated Markets Law No 144(Ι)/2007 to the extent it remains applicable after coming into force of MiFID II; and the relevant (EU) Commission Delegated Regulations. For the purpose of this Policy, any of the above legislation, regulation or guidelines will be referred to as ‘Law(s)’ and ‘Regulation(s)’.

1.4. Pursuant to the Laws and Regulations, the Company is obliged to take sufficient steps to obtain the best possible results (or “best execution”) when acting on behalf of its clients, either when executing clients’ orders or receiving and transmitting orders for execution. These Regulations also require the Company to establish an Order Execution Policy to allow it to achieve the best possible result for its clients orders.

1.5. The Policy sets out the execution procedures for the financial instruments offered by the Company. Clients must therefore ensure that they have read, understood and consent to the contents of this Policy before trading with the Company.The Policy applies to both retail and professional clients (as defined in the Company’s Client Categorisation Policy), but it does not apply to clients who have been classified as Eligible Counterparties.

1.6. In addition, the Client agrees that the Company while executing his/hers order, will always act as counterparty and does not guarantee that the price will be more favourable than one which might be available elsewhere.Where the Company executes orders for retail clients, it shall provide those clients with a summary of this Policy, focused on the total costs they incur.

2. BEST EXECUTION MODEL

2.1. This Policy applies to all Clients of Skilling Limited, retail and professional, when executing transactions in the financial instrument, Contracts for Differences (CFDs) offered by us.

2.2. The Company collaborates with regulated third-party liquidity and price providers where it derives its prices and uses a price aggregation engine to enable continued provision of reliable pricing (Bid/Ask) to Clients throughout the trading platforms. 

2.3. Where the Client places an order for execution, the Company provides symmetrical or/ consistent markups to raw spreads (obtained from its Liquidity providers) to ensure its average spreads are highly competitive within the market as well as ensure Clients’ trades are executed at the best available prices.  

2.4. DEFINITIONS

2.5. Execution elements

2.5.1. Slippage: This is the difference between the execution price and the order price at the time the order is submitted for execution. Slippage is a normal and expected cost of trading, particularly for orders of larger size and during times of thin liquidity or/and volatile market conditions.

2.5.2. Partial fills: This is the practice of executing an order in parts, at a time where there is not enough liquidity in the market in order to fill an order as a whole at a specific price. Partial fills may be executed at different prices.

2.5.3. Commission: Premium clients shall be charged commission when trading CFDs on forex.

2.5.4. Mark-up: Clients shall be charged a mark-up on spread when trading CFDs.

2.5.5. Trade Rejection: trades submitted on the prices considered by the system as invalid or/and old, are automatically rejected.

2.5.6. Execution Venues: are the locations (with or without a physical presence) such as Regulated markets (RM), Multilateral trading facilities (MTF), Organised trading facilities (OTF), Systematic internalises (SI), Market makers, Other liquidity providers or any other entity that performs a similar function in a third country to the functions performed by any of the foregoing.   

2.5.7. Market order: This is an order to buy or sell at the current market price that is available. The system automatically aggregates the volume received from third party LPs and executes the ‘market order’ at VWAP (‘Volume-Weighted Average Price’), that is, the average and best available price at the time of execution.    

2.5.8. Good ‘til Cancelled (‘GTC’) (= Expiry): This is an execution setting that the client may apply to ‘pending orders’. The order may remain ‘live’ and pending for execution until such time as the order is triggered and treated as a market order or cancelled by the client.

2.5.9. Market gap: This is the difference between the closing price of one period and the opening price of the next period. Market gaps are most often created between trading sessions, such as during the night or over the weekend.  

2.6. Pending orders (types of orders): 

2.6.1. Stop Orders: This is an order to buy or sell once the price reaches a pre-set level (the ‘stop price’). Once this order is triggered it is treated as a ‘market order’, therefore the order will be executed at the current market price that is available (VWAP). If the ‘stop order’ is not triggered it shall remain in the system at a later date, until the market reaches the pre-set level or it is removed by the client. ‘Stop orders placed within the current bid-ask spread will be invalid and the system won’t allow the placement of such an order, therefore, ‘stop orders’ must be placed a minimum number of pips away from the available market price at the time of placing the order so that these are valid.

2.6.2. Limit Orders: This is an order to buy or sell once the price of an instrument reaches a pre-set level (the ‘limit price’). It is used to enter trades at a pre-set level, rather than at the available market price at the time. Once the market reaches the ‘limit price’, the ‘limit order’ is triggered and executed at the requested ‘limit price’ or better.

2.6.3. Stop Loss: This is a ‘stop order’ to control and minimise losses. It is used to close an open position when the price of the instrument has moved contrary to the expected direction, reaching a pre-set level.

2.6.4. Take Profit: This is a ‘limit order’ to secure profits. It is used to close an open position when the price of the instrument has moved in the expected direction, reaching a pre-set target level.

2.6.5. Pending Order Modification / Cancellation: The Client may modify/cancel a ‘pending order’ if the market haven’t yet reached the price previously specified by the Client for as long as the order remains in the system. Stop Loss or Take Profit attached to a ‘pending order’ may be removed by the platform upon the pending order being triggered/filled. In such instances the Client is responsible for managing the open position accordingly. An order will be cancelled in the event any of the following occur:

2.6.5.1. The price requested is more than 50,000 pips away from the market price;

2.6.5.2. If a Client manually cancels an order prior to the market reaching the price level specified;

2.6.5.3. After 200 unsuccessful attempts to execute the order;

2.6.5.4. In case a pending order is triggered and there is not enough margin to be executed then the order is cancelled.

3. OVER-THE-COUNTER PRODUCTS (OTC) 

3.1. You acknowledge that transactions in financial instruments placed with the Company are not executed in recognised exchange and/or Trading Venue, rather these transactions are executed by us Over-the-Counter (OTC) through our online trading platform and as such they may expose the Client to greater risks 

3.2. The Company executes orders or takes decision to deal in OTC products including bespoke products and thus shall establish in an ex-ante assessment, appropriate procedures and arrangements, as well as appropriate evaluation systems, in order to check the fairness of the price proposed to the client, by gathering market data used in the estimation of the price of such product and, where possible, by comparing with similar or comparable products.. In addition, the Company shall maintain arrangements regarding the pre-trade checks as evidence for ongoing monitoring of best execution.  

4. BEST EXECUTION CRITERIA 

4.1. The Company is required to take several factors into consideration when executing an order for the client. The factors that the Company will consider are listed below:  

4.1.1. the characteristics of the client including the categorization of the client as retail or professional.

4.1.2. the characteristics of the client’s order.

4.1.3. the characteristics of financial instruments that are subject to that order.

4.1.4. the characteristics of the execution venues to which that order can be directed.

4.2. When the Company executes an order on behalf of a retail client, the best possible result shall be determined in terms of the total consideration, representing the price of the financial instrument 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. BEST EXECUTION FACTORS 

5.1. For the purposes of delivering best execution where there is more than one competing venues to execute an order for a financial instrument,  the Company shall take into consideration amongst other factors, the order execution policy that is capable of executing that order and the Company's own commissions and costs for executing the order on each of the eligible execution venues. .

5.2. When executing orders or receiving and transmitting orders for execution, the Company should at any time take all the sufficient steps to obtain the best possible result for its clients, by taking into account price, costs, speed, likelihood of execution and settlement, size, nature or any other factor relevant to the execution of the order. Important execution factors to be taken into consideration when obtaining best execution:

Factor	Importance Level	Remarks
Price	High	Strong emphasis on the quality and level of the price data that we receive from external sources (i.e. execution venue) in order to provide our Clients with competitive price quotes.
Costs	High	All reasonable steps to keep the costs of the tradable transactions as low and competitive, to the extent possible.
Speed of Execution	High	Execution speed and the opportunity for price improvement are critical to every trader and we repeatedly monitor this factor to ensure we maintain our high execution standards.
Likelihood of Execution	High	Even though we reserve the right to decline a Client order we aim to execute all Client orders, to the extent possible.
Likelihood of Settlement	Medium	Shall proceed to a settlement of all transactions upon execution of such transactions.
Size of order	Medium	The Client will be able to place Order (s) as long as he/she has enough balance in his/her trading account. A unit measuring the transaction amount and it is different for each type of CFD.
Market impact	Medium	The Company shall avoid any behaviour that may result in market impact or in market distortion.

6. CONTRACTS FOR DIFFERENCE (CFDS) AND PRICES

6.1. The Client acknowledges and accepts that, regardless of any information which may be offered by the Company, the value of investments may fluctuate downwards or upwards and it is even probable that the investment may become of no value due to the implied margining system due to the above, the client may either achieve  good profit or lose all the invested capital depending on the underlying market’s movement. So, the client must not invest unless he/she is willing to undertake the risks of losing all the capital invested.

6.2. The financial instruments available for trading with the Company are non-deliverable transactions giving an opportunity to make profit on changes in currency rates, commodities, CFD derivatives prices, called the underlying instrument. Derivative securities / Markets can be highly volatile. The prices of the security and the underlying instrument and CFD derivatives may fluctuate rapidly and over wide ranges and may reflect unforeseeable events or changes in conditions, none of which can be controlled by the client or the Company. As a result, it is worth noting that under certain market conditions it may be impossible for a client’s order to be executed at declared prices.

6.3. The Company must take all relevant steps to obtain the best possible results for its clients when executing orders. The application of and the relative importance of the relevant execution factors will vary depending on whether the client is a retail or professional client, as follows:

6.3.1. Where orders are executed on behalf of a retail client, total consideration must be the overriding factor in determining best execution. 

6.3.2. Where orders are executed on behalf of a professional client a range of factors may be considered in determining best execution, and the relevant importance given to each factor by the Company is indicated in the table above.

6.4. Trading CFDs are not eligible for distribution or sale in certain jurisdictions or countries. This Policy is not directed to any jurisdiction or country where its publication, availability or distribution would be contrary to local laws or regulations.  

7. EXECUTION OF ORDERS  

7.1. Client Order Handling

The Company must take in consideration the following factors when handling Client orders:

7.1.1. ensure that orders executed on behalf of a client are promptly and accurately recorded and allocated. They must carry out comparable Client orders sequentially and promptly unless the characteristics of the order or prevailing market conditions make this impracticable or the interests of the client require otherwise; 

7.1.2. inform a retail client about any material difficulty relevant to the proper carrying out of orders promptly upon becoming aware of the difficulty; 

7.1.3. ensure the correct and prompt delivery of settlement funds to a client’s account; and 

7.1.4. not misuse information and take all reasonable steps to prevent the misuse of information relating to pending Client orders.

7.2. Orders

7.2.1. Should the Company determine that a specific investment product or service is not appropriate or suitable, it shall undertake the measures that, at its discretion, it deems necessary in order to inform the account holder. In the absence of specific instruction from that account holder, the Company is required to execute the order at the best available resources offered by the Company at the time of the execution. The company is not responsible for any negative or positive impact that might be resulted due to technical failures in the online or remote systems of any party. In this context, the Company assumes no liability for damages that the account holder could incur as a result of the execution or non-execution of the instruction.

7.2.2. The Client should also be aware that checks regarding the appropriateness or suitability (where applicable) of a specific investment product or service could result in delays in the execution of orders regarding financial instruments. The Company cannot be held liable for any such delays resulting from the duties stipulated and governed by these provisions, except in the case of fraud or gross negligence on the part of the Company.

7.2.3. On some occasions, orders executed on the online trading system may get executed at wrong prices. The Company has the right to review the client’s order details in terms of price, time, volume and the validity of execution type whether they are in the form "pending" or "Market" orders through the online trading system, in case of any discrepancy, the company - without prior notice- will take the proper actions to correct the details of the given orders where and when possible. The Client acknowledges and accepts that seeing an order executed at a certain price on the system does not mean it was executed correctly and that the executed price may not be altered later if a mistake is detected. 

7.2.4. The Client acknowledges that the online trading system is an alternative solution for executing  the orders, the company maintains its trading system on real time bases during the trading hours of the financial instruments offered by the company to its clients, the client understands that the trading system may not be available for trading, any trades which have been wrongly confirmed in the client's account might be reversed or corrected, this can happen in particular in the event of totally or partiality illiquid markets, failure of electronic or telecommunications systems or any force action (majeure) which might be applied on certain instruments by company  during abnormal market conditions. 

7.2.5. For opening a position in some types of CFDs, the Client may be required to pay commission or financing fees, the amount of which is disclosed on the Company's website found under the Key Information Document. Commissions may be charged either in the form of a percentage of the overall value of the trade or as fixed amounts. In the case of financing fees, the value of open positions in some types of CFDs is increased or reduced by a daily financing fee “swap rate” throughout the life of the contract.  

7.2.6. For more information on trading conditions, including but not limited to Trading hours, Leverage, Spreads, Overnight rollover charges are made available to our clients on the Company’s Website.

8. LEVERAGE

8.1. The Company provides specific leverage limits or restrictions apply for retail clients. There may be specific leverage limits on the instruments available. For more information please visit our Website.

8.2. The Client acknowledges that the use of leverage can lead to loss of all the invested capital as well as gains and his/hers consent of the undertaken risk is required.. The client acknowledges and consents that any changes to leverage setting of the account that is already traded can affect open positions and may result in stop-out. 

9. MARGIN 

9.1. The Company’s transactions have a contingent liability, and the client should be aware of the implications of this, in particular the margin requirements of the Company. For margin calculation purposes, the leverage level used will be the lowest between the traded symbol and account. 

9.2. CFDs financial instruments are extremely volatile and the client should maintain an appropriate margin to cover the risk of losing the entire investments, the company has the right to maintain the account margin in the absence of prior intervention by the client.

9.3. For Retail clients, the Company has the right, at its own discretion, to start closing Clients positions when the margin used is at 50% (equivalent of 200% client’s usage) of the account balance. The Company will automatically close one or more positions at market price where stop out level is reached. Similarly, for Clients categorised as Elective professional clients, the Company has the right to implement the 50% margin close out rule.

9.4. The Margin close out is calculated and as shown in the trading platform: margin used/account balance = 200% stop out (equivalent, account balance/margin used = 50% stop out).

9.5. Specific leverage restrictions may apply on Retail clients’ accounts or/ Elective professional clients.We reserve the right to further increase/decrease the margin requirements at our  discretion at any time if such is considered necessary, subject to the initial margin requirements mentioned in our Leverage Policy. . The Company will always follow an efficient approach in order to protect its clients’ interests and to act according to the best execution policy. Any changes will be communicated to the clients who can always request further information 

10. NEGATIVE BALANCE PROTECTION 

10.1 The Company applies negative balance protection (NBP) to Retail clients’ accounts on trading CFDs, meaning that the limit of Retail client’s liability for all CFD trading accounts cannot exceed the deposit. 

11. ASSOCIATED RISK

11.1. The Client acknowledges that the Company acts as a principal counterparty to its client’s trades. Part or all of these trades are covered within the Company or related entities having same or similar shareholders. Some of these related entities may also act as a market maker for some instruments. This may entail additional risk of conflicts of interest. For transparency, the client is hereby made aware of this and accepts this risk when conducting business with the Company. 

12. EXECUTION VENUES

12.1. For the purposes of orders for the financial instrument provided by the Company, the Company acts as the sole principal as well as the sole Execution venue for the execution of the Client’s orders for the financial instruments provided by the Company. The Company endeavours to offer a high speed of execution within the technological and telecommunication limitations and it shall not be liable for poor performance of Client’s technology, internet connection or any other resources that might result in Client’s delay in the transmission of data between the Client and the Company. 

12.2. The Company relies on third-party liquidity providers for prices and available volume of the different financial instruments we provide our clients. The execution of clients’ orders depends on whether there are prices and liquidity available in the market at the time the orders are received by us. For this purpose, we use multiple liquidity providers to enhance the likelihood of execution across instruments we offer. We reserve the right to change the below Execution venues at our own discretion:

Stonex Financial Ltd (“StoneX”)	Incorporated in England & Wales under registration number 5616586, and its registered office at 1st Floor Moor House, 120 London Wall, London EC2Y 5ET
MTG Liquidity Ltd	Incorporated in Cyprus under CIF licence number 390/20 and its registered office at 3rd Floor, Office 32, 62 Athalassis Avenue, 2012, Strovolos, Nicosia
Broctagon Prime Ltd  (“Broctagon”)	Incorporated in Cyprus under registration number HE360194 and its registered office at 2 Christou Samara, 3 rd floor, 4001, Limassol, Cyprus

12.3. The Company reserves the right to decline the execution of an order, or to change the opening or closing price of an order in case of any technical failure of the trading platform, price feed or any other unforeseen event. The terms and conditions and trading rules are established solely by the counterparty which in this case is the Company. The Client is obliged to close an open position of any given financial instruments with the same counterparty with whom it was originally entered during the opening hours of the Company’s trading platform. 

12.4 For more information regarding top execution venues and quality of execution, please refer to RTS Reports that are available on our website.

13. SELECTION OF LIQUIDITY PROVIDERS

13.1. The Company will determine the relative importance of the above Best execution factors by using its commercial judgement and experience in the light of the information available on the market such as quality of services offered, quality of execution, technological equipment, third party’s market reputation and others. The weighting of the mentioned criteria mainly aims at achieving a safe, cost-efficient and high-quality service and/or order execution to the Company’s clients.  

13.2. The Company shall not structure or charge its commissions in such a way as to discriminate unfairly between execution venues. Where the Company applies different fees depending on the execution venue, the Company shall explain these differences in detail in order to allow the client to understand the advantages and the disadvantages of the choice of a single execution venue. 

14. QUALITY OF EXECUTION OF TRANSACTIONS 

14.1. When acting as a market maker, the Company shall be considered as “execution venue” and shall comply with the requirement to publish information on the quality of execution of transactions. The information shall be published in a machine-readable electronic format, available for downloading by the public.    

15. PRICE 

15.1. Price is an utmost important factor for the Company’s best execution obligations. The Company derives its prices from its liquidity providers and price providers using a price aggregation system to detect and quote the best Bid and Ask quote from its third-party liquidity providers to the trading platform. The Company will not quote any price outside Company’s operations time; thus, no orders can be placed by the Client during that time. 

15.2. It should be noted that the prices provided to Clients through our trading platform may vary from the prices of other trading platforms. We update our prices as frequently as the limitations of technology and communication links allows.  

16. ASSOCIATED COSTS 

16.1. The Client is charged financing fees such as swaps or rollover fee, and/or commissions.  

16.2. In the case of Financing Fees, the value of open positions in some types of Financial Instruments is either increased or reduced by a daily financing fee (‘swap’) until the open position is being closed. Financing fees are based on prevailing market interest rates, which may vary over time.  

17. COMMISSIONS 

17.1 Where a Client sign-up for Pro premium account type, commissions as a fixed amount is levied on trading Commodity CFDs and Forex CFDs, through cTrader, and the charges are available on our website.  

18. SWAPS/ FINANCING FEES

18.1. The Client’s value of opened trades on certain financial instruments or/asset class decrease or increase through daily swaps (long/short), such financing fees depend on the trade size or/PIP size  and derived from prevailing market interest rates as well as overnight fees levied on the trading accounts, which is available on our website.  

19. MARK-UPS

19.1. The Company provides prices on which Clients rely on to trade such as mark-up, which is the spreads offered regarding the raw spreads obtained from Liquidity providers or price feeds and; any mark-up displayed on the trading platform. The difference between the Bid and the Ask price of a given financial instrument is the spread, which includes Company's mark-up. 

20. CURRENCY CONVERSION 

20.1. The Company ensures currency conversion calculations are provided to the Clients based on the trading account denominated currency as chosen by the Client, through the trading platform.   

21. LIKELIHOOD OF EXECUTION 

21.1. The Company acts as the sole Execution venue for the execution of its Client’s orders. We reserve the right to decline or partly fill in any order or to execute the order at the first available market price without providing any justification to the Client. We rely on third-party liquidity and price providers for prices and available volume of the financial instruments we offer.  

21.2. For this purpose, the execution of Client's orders depends on whether there are prices and liquidity available at the time these orders are received. We optimise the use of third-party liquidity providers that lead to a high likelihood of execution across the instruments we offer Clients, especially during abnormal market conditions stated below:  

21.2.1. during market opening times.  

21.2.2. during times of market news and events.  

21.2.3. during periods of significant volatility.  

21.2.4. a rapid price movement of a particular instrument, to such an extent that under the rules of a relevant exchange, trading on said instrument is suspended or restricted.  

21.2.5. insufficient liquidity for the execution of a specific volume at a specific declared price.  

21.2.6. internal risk restricts the acceptance of any further orders on a specific instrument. 

22. CORPORATE ACTION

22.1. Corporate Actions are Corporate Action is an event carried out by a publicly traded company that subsequently has an effect on its shareholders. Bankruptcy and liquidation are examples of extreme financial corporate actions, which usually have a negative impact on shareholders. Dividends, stock splits, acquisitions, mergers, stock buybacks and re-branding are all common examples of corporate actions. Any long or short positions held on the relevant share at the ex-div date will receive a dividend (minus the withholding tax) or charged the dividend amount in the form of a cash adjustment (respectively). A withholding tax which is a levy deducted from dividends in most underlying markets, and such deduction may vary depending on the underlying market, but it's often reduced to 15%. 

22.2. More information is available on the Business terms and conditions. 

23. CLIENTS’ CONSENT 

23.1. The commercial terms of a particular service or transaction will be agreed at the time of dealing. This may occur over the phone or electronically. Once we reach an agreement, both the client and the Company are bound by the terms of the agreement. The Client is made aware that the online trading system may execute trades at wrong prices in some cases and the Client acknowledges and accepts that the Company may correct such orders later even if they are already confirmed on his account. 

24. OTHER EXECUTION CONSIDERATIONS 

24.1. At the Company, all Stop loss orders will be confirmed at the best available price for trading. In the event of market gaps, the requested price will be adjusted by the Company automatically by the trading system or manually. 

24.2. Provision of initial margin protection, negative balance protection and leverage limits on trading CFDs to retail clients in accordance with the Company’s Leverage Policy, and where the Company is required to provide protection for retail client to reduce the complexity of product and/ or risk warning associated for losing capital rapidly due to leverage, which is not applicable to a professional client. 

24.3. Where exchange restrictions do not allow physical delivery of currency, the Company provides a means of negating foreign exchange risk. 

24.4. The client will forego any benefit of a favourable exchange rate movement between the time he/she enters into a transaction and the maturity date. 

24.5. Cancellations or a new execution order from the client whether by telephone, fax or email or adjustments which may result in unavoidable additional cost  that may be communicated through our website.      

24.6. Some of the Company’s underlying instruments may not become immediately liquid as a result of reduced demand for the underlying instrument and the Client may not be able to obtain the information on the value of these or the extent of the associated risks. 

24.7. Reliability on Previous Performance Information of the previous performance of the Company does not guarantee its current and/or future performance as well as a performance of the underlying instrument. The use of the historical data does not constitute a safe forecast as to the corresponding future performance of the Company and underlying instrument to which the information refers. 

24.8. Provision of CFDs are not eligible for sale and distribution in certain jurisdictions or countries. This Policy is not directed to any jurisdiction or country where its publication and availability would be contrary to local laws or regulations, including, but not limited to the United State of America.  

24.9. This Policy does not constitute an offer, solicitation or invitation to buy or sell leveraged products.  

24.10. Any information regarding the quality of execution as shown in the RTS 27 and RTS 28 Reports, are accessible by all clients through the company’s official website, here. 

25. POLICY MONITORING PROCEDURE

25.1. The procedures shall be reviewed at least annually by the Dealing on Own Account Department, Brokerage Department, Back Office, Compliance Department and Risk Department and be approved from the Company’s Board of Directors. 

25.2. The Company shall monitor on a regular basis (at least annually) the effectiveness of the Best execution policy and in particular, the quality of execution, as well as to monitor best execution of the entities identified in the said policy and, where appropriate, correct any deficiencies.  Such monitor shall be also performed whenever a material change regarding the Company’s ability to offer the best results occurs. Material changes shall mean regarding the cost, price, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of the order. 

25.3. Such monitoring shall be conducted on an ex-ante basis and on an ex-post basis.  

25.4. In particular, the Company shall assess, on a regular basis, whether the execution venues included in this policy for order execution provide for the best possible result for the client or whether the Company needs to make changes to its execution arrangements. 

25.6. The Company shall notify clients with whom it has an ongoing client relationship of any material changes to its order execution arrangements and shall also obtain their explicit consent where deemed necessary. 

26. CONFLICT OF INTEREST

26.1. The Company shall ensure that any identified conflicts of interests are managed in accordance to its Policy which is available on the website.  It should be noted that no conflict of interest can arise from investment advice since that source is not within the scope of the Company's regulatory permissions.

26.2. Some circumstances which constitute or may give rise to a conflict of interest entailing a material risk of damage to the interests of one or more Clients, as a result of providing investment services,include but not limited to: (a) matching the client’s execution orders with that of another client by acting on such other client’s behalf as well as on the client’s behalf; (b) making a financial gain, or avoid a financial loss, at the expense of the client; (c) implementing legal arrangement with third parties related to the referral of new Clients; and other factors identified in our Conflict of Interest Policy.

27. POLICY REVIEW

27.1. The Company reserves the right to review and/or amend this Policy at its sole discretion, whenever it deems fit or appropriate by law, and the revised Policy will be uploaded on the Company’s Website.

27.2. Your continued use of our services, following any notification of such amendments, constitutes your acknowledgement and consent to such amendments to this Policy and your agreement to be bound by the terms of such amendments.