Order Execution Policy

Tradenext Limited (“Tradenext”, “We”, “Our” or “Us”) is a Contract for Differences (“CFD”), Financial (“FSB”) and Foreign Exchange (“Forex”) broker authorised and regulated by the Financial Conduct Authority (“FCA”) under firm reference number 573464. Tradenext’s registered office address is Lower Ground, 3 Copthall Avenue, London, EC2R 7BH.

The address of the FCA is 25 The North Colonnade, Canary Wharf, London, E14 5HS.

Tradecrowd Technology Ltd is an Appointed Representative of Tradenext Limited under firm reference number 607527. Tradecrowd’s registered office address is 9th floor, 107 Cheapside, London, EC2V 6DN.

1. Introduction

1.1 We aim to treat Our clients fairly at all times, to conduct Our business in an open, honest and professional manner and to act in the best interests of Our clients, in accordance with the Markets in Financial Instruments Directive (MiFID) and the FCA Handbook of Rules and Guidance. We provide financial products and services (including trading in contracts for differences and foreign exchange) which covers a wide variety of Underlying Markets. This Policy describes steps that We shall take to provide Our retail and professional clients with trading services.

1.2 In this Policy:

Bid Offer Spreadmeans the difference between the price at which you can sell and the price at which you can buy.

Limit Order means an order to buy or sell when a Market hits a certain price. This is an instruction to trade at a more favourable price than is currently available.

Market means a distinctive set of products based on the price movement of an Underlying Market.

Order means an instruction to open or close a Trade at a specific Market level.

Stop Loss Order means an instruction to deal in a particular Market at Our price in that Market to avoid or restrict you incurring further losses (these Orders are not guaranteed).

Trade means an executed Order.

Trading Agreementmeans the agreement that covers Our relationship with you regarding your trading in Our products using Our services.

Underlying Market means the relevant financial instrument, index, currency pair or other instrument, whose price or value provides the basis for Us to establish the price We quote you for a Market.

1.3 In the event of a conflict between this Policy and the terms and conditions of the Trading Agreement, the Trading Agreement shall prevail.

1.4 If you require more information or further explanations concerning any aspect of this Policy, please feel free to contact Our traders at dealers@tradenext.co.uk or Our customer services department at customerservices@tradenext.co.uk.

2. Order Execution

2.1 Tradenext is your counterparty in all Trades. Any trading restrictions concerning Our minimum and maximum sizes or Our hours of normal trading, together with other key information (such as margin required), are detailed for all Markets on Our trading platform or upon request to Client Support.

2.2 We aim to ensure that the Market prices available on Our trading systems and procedures at all times are as competitive as possible. Subject to an Underlying Market being closed or suspended, within normal Market hours, We make such prices available for Trades within defined Trade size parameters and outside those parameters as We may determine from time to time (where Our clients are so permitted with reference to the terms and conditions).

2.3 We may choose to execute a transaction on Our own account in order to hedge any particular or residual Market position accruing as a result of your trading. Even where such a transaction may be related to your particular Trade, We will not be acting as your agent nor owe you a fiduciary duty in respect of your Trade or Our hedge.

2.4 We will act as your counterparty as principal when We provide you with financial products and services and thus represent the sole execution venue to which you have access and only at a price set by Us. Orders are executed on an 'over the counter' (OTC) basis rather than on an exchange or any other regulated market.

2.5 Should you make an Order that is larger than a size limit specified by Us, or in an illiquid Underlying Market, or with a specific request attached, We may, at Our own discretion, 'work the Order' on a fully disclosed basis (where We trade in Our own name in the Underlying Market as a hedge against your prospective Trade). As soon as We obtain Our hedge, We may execute your Order as a single Trade or series of Trades.

3. Execution Criteria

In providing Our trading services, We shall determine the most advantageous execution for Our retail clients and professional clients by taking into account a range of competing factors and criteria. This Policy defines Our approach and prioritisation adopted in reflecting those factors and criteria in Our execution of Client Orders.

4. Price

4.1 We regard the price of the execution of an Order to be of relative high importance.

4.2 We may quote one or two Market prices: Our offer price (you can buy the Market from Us at the higher price) and/or the bid price (you can sell the Market to Us at the lower price).

4.3 The Market's bid calculation (or offer price) takes the price of the Underlying Market into consideration. This might be adjusted (where applicable) to allow for the effect of interest over the period of the Market contract, to take into account any corporate actions and other relevant factors and include a commission. Our trading platform prices take into consideration, data from various sources and not directly from one source; they might not necessarily match the prices offered by Our competitors.

4.4 When you choose to make an Order (trade) for immediate execution on the bid or offer price shown on Our trading platform, execution will be at the latest price as calculated by Our pricing system. This might be more, or less, advantageous than the price shown originally. In volatile Markets, where such an Order has not been rejected for failing Our tolerance checks, the variation in price might be even greater. In these circumstances We will regard the speed and certainty of execution to be an overriding factor in giving you the most advantageous execution.

4.5 In order to ensure that the Underlying Market price data We receive represents competitive executable prices, We shall undertake periodic reviews. Several Markets that We offer are quoted outside the normal trading hours of the exchange or other regulated market where the Underlying Market is traded. When executing such Orders outside normal trading hours, We will determine the price at Our sole discretion, acting in good faith, and by reference to one or more alternative Underlying Market instruments that are trading, the standing of world market prices at that time and/or to the supply and demand of other clients. At such times Our prices are likely to reflect a wider Bid Offer Spread and might include restrictions to reduced Trade sizes.

4.6 When the Underlying Market is volatile causing the market price to change rapidly, We will not be able to guarantee that every such price movement will result in a proportional change to the calculated Market price. The frequency of updates of Our Market price is subject to the technical limitations of computer hardware, software and data and communication links. If you specify a price for an Order (such as with a Stop Loss Order or a Limit Order), where the Underlying Market is moving so rapidly as to 'gap through' the specified price, We will execute the Order for you at the fairest price as possible. This will normally be the next available price that We are able to achieve. (For example, where the client places a stop on a market to sell at 610 market price and there is an announcement which causes the price to go through the level of stop without trading, the client will receive Our next available quote – so in this example if We were quoting 612 – 614 prior to the announcement, and Our next quote after the announcement was 608 – 610, you would receive Our sell price of 608, because Our bid price did not trade at 610 or 609).

4.7 During such conditions, underlying market trades are executed ahead of Tradenext’s stop loss orders and so it may be possible that underlying exchanges or Tradenext’s tick data show a traded price in between these two levels. Tradenext will then fill the order at the best price available to Tradenext following the Stop Loss Order’s activation.

4.8 Once a Stop Loss Order price is reached, We will attempt to fill your Order at the next price available within a reasonable time. The level at which We fill your Order may therefore be the same, or worse, than the price you specify.

4.9 Remember that your Order is triggered by Our price during Our trading hours, not the price of the Underlying Market during its normal trading hours. We do not guarantee that when you open or close a Trade with Tradenext, the price will be the same as or better than one you might have obtained from another Firm.

5. Costs

We view the costs of execution of an Order to be of relative high importance. A commission as well as a Bid Offer Spread is charged for most Markets. This will only be charged on the execution of an Order which opens a new or closes an open Trade. Our Bid Offer Spread during and outside normal trading hours for Markets is set out in the 'Market Information Sheets' available on www.tradecrowd.co.uk or by request. Any additional charges or spreads will be negotiated with you in advance.

6. Total Consideration

We regard the total consideration in the execution of an Order to be of relatively high importance. We will usually attach the highest relative importance to the total consideration, in the execution of Orders for clients when determining the various priorities and weights of all the different factors and criteria. This will normally encompass the costs and price connected to execution. However in certain situations, We may determine that other execution factors (such as speed and certainty of execution) are more important than price and/or cost in obtaining the best overall outcome for you.

7. Size of Orders

7.1 We regard the size of Orders in the execution of an Order to be of relative high importance, where it could influence the choice of Our hedging execution venue if the overall price of execution is affected at the expense of achieving the requested size. Where the Order is within any pre-defined minimum and maximum limits, the trade sizes will not generally affect the Execution. Assuming the minimum amount of funds is in place on the account, those Orders will be executed automatically by Our trading platform. Larger maximum size restrictions will generally apply to Orders executed by telephone where the Firm has agreed to provide you with this service.

7.2 Your Order size will become an important factor in the execution of your Order where it is greater than Our predefined limit. Where your Order is large than Our standard maximum size, We may work the Order in tranches to enable Us to achieve complete execution at the most advantageous price outcome. Those orders will usually be executed in tranches up to or equal to the normal Market size. In such circumstances, the price may vary between tranches. Those individual tranches may be passed on to you as obtained, or be converted into a single Trade at the aggregate average price but will depend on your arrangement with Us.

7.3 If your Order requires Us to work Our hedge in tranches in the Underlying Markets, this will be done by placing Our Orders in the particular execution venue on a first-in-first-filled basis (i.e. in the same sequence that We receive client Orders), unless the particular specifics of an Order or the market conditions mean that this is either impractical to do so or risks a potential negative impact.

7.4 We will generally not work large foreign exchange Orders in tranches but will deal with such Orders on a 'fill or cancel' basis. Stop Loss Order, Limit Order or opening Order might exceed the maximum size limit when out of normal trading hours. In those circumstances, execution might be carried out in tranches where the price may vary considerably for each tranche.

8. Speed of Execution

We regard the speed of execution of an Order as relatively high importance. If there is an unusually high demand in that Market, automatic Market pricing might be temporarily superseded wholly or in part by manual pricing and execution. This might cause delays in speed of execution which itself may impact on the price at which Orders are executed. Our procedures aim to minimise the risk and impact of such delays.

9. Likelihood of Execution

9.1 We regard likelihood of execution and the minimisation of uncertainty to be of relative high importance. We normally provide you with screens showing continuously updating two way prices for Markets when executing through Our trading platform. You have the ability (subject to trading times and trading size limits) to trade immediately with a very high degree of certainty.

9.2 We ensure that We have the necessary access to trading venues and third-party market makers likely to have the required liquidity to enable Us to hedge prior to executing the Order. This enables Us to increase the likelihood of execution for larger Orders and telephone.

10. Nature of the Order

We offer Stop Loss Order, Limit Order or opening Orders. The type of Order can be an important factor in relation to execution where this might determine whether the Order is priced and executed manually rather than automatically.

11. Market Circumstances

The nature of the Market traded (such as equities) may in certain circumstances, become an important determinant in the execution of the Order. If an Underlying Market might affect the future price and the value of the Order, We will take reasonable efforts to achieve a fair execution for you.

12. Specific Instructions

12.1 Specific instructions will take priority over other determinants as set out in this Policy. We will revert to this Policy where such instructions are not comprehensive. We will generally still exercise Our judgment in balancing the various factors in order to obtain the most advantageous outcome for you on a consistent basis.

12.2 If We incur any direct costs or charges in executing your specific instructions resulting in Us having to use a different process than that specified in this Policy, We may pass the direct costs incurred on to you in accordance with the terms of your Trading Agreement.

13. Aggregation of Orders Client Orders

In order to execute a single transaction We may sometimes combine two or more Orders from different clients. This will generally occur where We reasonably believe that it is in your overall best interest and thus unlikely overall to be to your disadvantage.

14. Aggregation of Client Orders with Our own Orders

Where We receive more than one client Order for that Market and Our risk requirements dictate that We must execute an Order in an Underlying Market related to the Market of a client's Order, We will execute the Orders on a first-in-time basis, unless the client Orders can be combined to obtain a better execution outcome for Our clients.

15. Margin Close Out

As Tradenext offers an ‘execution only’ policy, it is your responsibility to monitor your own positions and ensure that you have sufficient funds on your account to cover your initial and variation margin (deposit requirement and any open position profits or losses). We therefore advise you to keep a surplus of funds on your account to cover any sudden adverse movements in the market. Where a client appears on margin call, Tradenext will normally attempt to contact the client via email. Please ensure that you have provided Us with up to date contact details. However where there is a sudden sizeable adverse movement in the market or you fail to meet your margin call promptly, Tradenext might close part or all of your open position in order to bring you off margin call. Where the client has more than one position open, Tradenext will decide on which positions it closes. Tradenext will normally close out your open positions starting with those showing the largest open loss.

16. Fiduciary Duty

We shall endeavor to operate in accordance with this Policy. However, this Policy does not create any legal obligation or duty, fiduciary or otherwise, over and above Our duties to you under the Trading Agreement or any regulatory obligations placed on Us by the FCA.

17. Monitoring and Review of this Policy

We will monitor Our operations in relation to this Policy on a regular basis and make a periodic review of the execution venues and data sources We rely upon in providing pricing information. Any material changes to either this Policy or to Our Order execution arrangements will be fully disclosed to you.

18. Questions or Comments

If you have any question or comments regarding this policy please contact dealers at dealers@tradenext.co.uk