FxPro Financial Services Ltd.
SCOPE OF THE POLICY ... 4
EXPRESS CONSENT ... 4
TRADE EXECUTION MODEL ... 4
ORDER TYPES ... 5
Instant Execution Orders ... 5
Market Execution Orders... 6
Pending Orders ... 7
Pending Order Modifications/ Cancellations ... 9
MetaTrader 4 and MetaTrader ... 9
cTrader and FxPro Markets ... 9
MARGIN AND LEVERAGE ... 11
MetaTrader 4 (Instant and Market Execution) ... 11
MetaTrader 5 ... 11
cTrader and FxPro Markets ... 11
BEST EXECUTION ... 12
Prices ... 12
Size, Speed and Likelihood of Execution ... 14
Cost ... 16
Commission ... 16
Mark-up ... 16
Financing/ Overnight fee ... 16
Currency Conversion ... 17
Likelihood of Settlement ... 17
EXECUTION VENUES ... 17
INSTRUCTIONS ... 18
CORPORATE ACTIONS ... 20
Long Positions ... 21
Short Positions ... 21
Stock Splits, Rights Issues and other Corporate Actions ... 21
Fractional Share Adjustments ... 21
Delisting ... 21
GENERAL MATTERS ... 22
MONITORING AND REVIEW ... 22
SCHEDULE A: GLOSSARY ... 23
1. SCOPE OF THE POLICY
1.1 FxProFinancial Services Ltd. (referred to as ‘FxPro’, the ‘Firm’, ‘us’, ‘we’ and ‘our’) is required
to take all reasonable steps to obtain the best possible result (or ‘best execution’) for its Clients either when receiving and transmitting orders for execution or executing Client orders. This
‘Order Execution Policy’ (the ‘Policy’)summarises the process by which our trading platforms
execute the Client (referred to as the ‘Client’, ‘you’, ‘your’and ‘yourself’)orders.
1.2 You understand that it is up to the Firm’s discretion to decide which types of CFDs to make
available on its trading platforms; the Policy will apply accordingly.
1.3 For your convenience, an ‘Order Execution Policy’ Summary is available in Schedule B of the
Policy.
1.4 The Policy is subject to our ‘Client Agreement’ or any other agreement which governs, from
time to time, the relationship between the Client and the Firm.
1.5 For any capitalised term,which has not been defined in the Policy, please refer to Schedule A
(‘Glossary’) of the ‘Client Agreement’.
2. EXPRESS CONSENT
2.1 By opening an Account with FxPro and accepting the ‘Client Agreement’, you provide your
express consent that all orders will be executed on a non-regulatedmarketsince the Firm is the
sole execution venue and the only principal to the transactions.
2.2 When opening an Account with us you consent to your orders being executed in accordance
with the Policy in force, from time to time.
2.3 There are instances where a Client may request that certain orders be executed in accordance
with specific instructions; to the extent that we are able to accommodate such request, we will endeavour to do so. If there are additional charges, the Client will be charged accordingly.
3. TRADE EXECUTION MODEL
3.1 FxPro places reliance on recognised external liquidity/ price providers when deriving its prices.
FxPro developed internally its price aggregation engine, which allows us to discover the best
bid/ask pricesand provide continuous and reliable pricing to our Clients throughout our trading
applicable) to ensure our average spreads are highly competitive within the marketplace. During liquid trading hours (for example, the EU/US trading session) our spreads are lower to
our average daily spread displayed on our Website. Continuous (in milliseconds) price
presentation of the flow of the bid/ask prices in addition to high liquidity compliments our prices ensuring our Clients’ trades are executed at the best available prices. Notwithstanding instances referred to in the Policy, the Firm’s fill ratio of our Client orders is close to 100%.
Under standard market conditionsit typically takes 50-60ms, from the moment a Client’s order
is first registered in our system, to when execution is confirmed. By way of example, as at 31st
December 2015, 99%+ of orders were executed within 50ms. Clients situated away from our
servers’ location or with poor internet connection will experience a delay of 100-300ms
reaching our servers from,which in effect might result in clients receiving a requote (if instant
execution) or slippage (if market execution) if market moved away from the clients requested
price. Execution statistics (including slippage and re-quote ratios) demonstrate symmetricity.
4. ORDER TYPES
4.1 The Client may send instructions to the Firm for:
(i) an instantexecution order *
(ii) market execution order **
(iii) a pending order**.
* Available on MetaTrader 4 only.
** Available on MetaTrader 4, MetaTrader 5, cTrader and FxPro Markets.
Instant Execution Orders
4.2 Instant order is an order to either buy or sell at the ask price or bid price (respectively) as it
appears in the trading platformsat the time the Client presents the order for execution.
Example:
Client X requests to buy 60 Lots EURUSD (i.e. 6 million Euro) at 1.0560. The current prices are:
Bid price Ask price
1.0559 1.0560
FxPro will executethe requested volume of 60 Lots, in its entirety, at the requested price of
1.0560.
NOTE: if at the time of receiving the order in our system, the market price changed then a
4.3 It should be noted that a stop loss and/or take profit may be attached to an instant execution order.
4.4 MetaTrader 4 (Instant Execution)order is both size specific and price specific.
Market Execution Orders
4.5 Market order is the intention to either buy or sell at the current market price, subject to the
liquidity available. In the event there is not enough liquidity at the top of the book to fill a
Client’s market order, the system will automatically aggregate the volume received from third
party liquidity/ price provider(s) and execute the market order at the ‘Volume-Weighted
Average Price’ (‘VWAP’), subject to the liquidity available at the time of the execution.
Example:
Client X requests to buy 60 Lots EURUSD (i.e. 6 million Euro). The available liquidityat the time
is:
Quantity available at Bid price
Bid price Ask price Quantity available at Ask price
1,000,000 1.05590 1.05600 1,000,000
500,000 1.05580 1.05610 2,000,000
3,000,000 1.05570 1.05620 3,000,000
FxPro will execute Clients order as follows:
• Buy 10 Lots (i.e. 1,000,000 Euro) at 1.05600,
• Buy 20 Lots (i.e. 2,000,000 Euro) at 1.05610, and
• Buy 30 Lots (i.e. 3,000,000 Euro) at 1.05620.
VWAP for the 60 Lots EURUSD (i.e. 6 million Euro) will be 1.056133.
NOTE: if there had not been enough liquidity availableto fillthe order in its entirety, the order
would have been partially filled.
4.6 Market execution orders are size specific but notprice specific.
4.7 The Client understands that there are instances where we might not execute an order as per
your instructions. For example, we may treat an instant order as a market order executed at
VWAP at times of high volatility, or low liquidity or whenwe receive multiple trade requests for
the same symbol, direction and price range or request from the same signal provider or same
Pending Orders
4.8 A pending orderis either a buy stop, or sell stop, or buy limit, sell limit order or a stop-limit
order*. It should be noted that stop loss and take profit instructions are a type of pending order and are treated as described below.
*Not available on MetaTrader 4.
Buy Limit
4.8.1 Buy limit is an order to buy a CFD at a specified price lower than the current market price. A buy limit order will be triggered when the market reaches or passes the specified price, namely the limit price and executed at the limit price or better.
Sell Limit
4.8.2 Sell limit is an order to sell a CFD at a specified price higher than the current market price. A sell limit order will be triggered when the market reaches or passes the specified price, namely the
limit price and executed at thelimit price or better.
Buy Stop
4.8.3 Buy stop is an order to buy a CFD; the price is set above the current market price and is triggered when the market price reaches or passes the specified price, namely the stop price. A buy stop
order is then executed as a market order i.e. at the declared, better or worse pricewhich means
that the set buy stop price may not necessarily be the requestedprice of the order.
Sell Stop
4.8.4 Sell stop is an order to sell a CFD; the price is set lower than the current market price and is triggered when the market price reaches or passes the specified price, namely the stop price. A sell stop order is then executed as a market order i.e. at the declared, better or worse price,
which means that the set sell stop price may not necessarily be the requestedprice of the order.
Stop-Limit order
4.9 Stop-limit order is an order that combines the features of stop order with those of a limit order.
A stop-limit order will be triggered at a specified price (or better) after a given stop price has
been reached or passed. Once the stop price is reached, the stop-limit order becomes a limit
Stop Loss
4.10 Stop loss is an instruction that is attached to either an instant execution/ market execution
order or a pending order and may be used to minimise losses. Once the market reachesor
passesthe stop loss price the order is triggered and treated as a market orderi.e. filled at the
declared, better or worse price, which means that the set sell stop price may not necessarily be the close price of the order. If the stop loss is not triggered it shall remain in the system until a later date.
Take Profit
4.11 Take profit is an instruction that may be attached to an already open position to close a position
at a specified price (namely, the take profit price) to secure profits. Once the market reaches
the take profit price the order is triggered and treated as alimit order; filled at declared or
better price. If the take profit is not triggered it shall remain in the system until a later date or amended/ modified by the Client.
4.12 GENERAL NOTE:
In terms of CFDs traded through MetaTrader 4 and MetaTrader 5, pending orders as well as stop loss and take profit should be placed a minimum number of pips away from the current market price; for further information, please check our Website/ trading platforms.
Good till Date (‘GTD’)
4.13 Good till Date (‘GTD’) is a time setting that applies to pending orders traded through
MetaTrader 4 and MetaTrader5. The Client may choose a specific date in the future until which
the order will remain ‘live’ and pending execution; if the order is not triggered during this pre
-determined timeframe it shall be deleted from the system.
Please note that this functionality is available on MetaTrader 5as ‘Goodtill Today’and ‘Good
till Specify’.
Good till Cancel
4.14 Good till Cancel (‘GTC’) (= Expiry) is an execution setting that the Client may apply to pending
orders. The order may remain ‘live’ and pending execution until such time as the order is triggered and treated as a market order or cancelled by the Client.
Please note that GTC may become redundant in cases where a CFD on futures reaches its
Pending Order Modifications/ Cancellations
MetaTrader 4 and MetaTrader 5
4.15 The Client may modify/ cancel a pending order if the market did notreach the level of the price
specified by the Client.
cTrader and FxPro Markets
4.16 With regards to cTrader and FxPro Markets, a pending order will be cancelled in the event any
of the following occurs:
(a) if a Client manually cancels an order prior to the market reaching the price level
specified by the client; or
(b) if the requested price is more than 50,000 pips from the market price; or
(c) if a Client places an expiration time frame and this is reached; or
(d) after 2000 unsuccessful attempts to execute the order.
4.17 The Client accepts that once a pending order is triggered,the Client may not modify such order.
4.18 It should be noted that the status of an order is available, at all times, through the trading
platforms. If the Client is unable to access the trading platforms he/she can be notified of the status of an order by contacting the Dealing Department by telephone on +357 25 969 238/9.
4.19 A pending order that is not triggered, at the close of a specific trading session, will remain valid
and will beexecuted accordingly in the futureunless the Client deletes the order before it is
triggered.
4.20 The Client accepts that pending orders are triggered at the declared price on the first current
price touch but filled as per the specific order type.Limit ordersmay be filled at declaredor
better pricewhereas stop orders may befilled at declared, better or worse price.
4.21 The Client accepts that under certain trading conditions (including but not limited to situations
of high market volatility or illiquidity and market gaps) it may be impossible for FxPro to execute pending orders at the Declared Price; under such conditions, the Firm reserves the right to execute the order or modify the opening and/or closing price to provide the next best price. In instances where pending orders with stop loss/ take profit attached and the first available price triggers both the opening price and the stop loss/ take profit simultaneously will result in stop
loss/ take profit being removed and position being openedat market price and the Client will
have to manage the position accordingly.
• Buy Stop with Take Profit
o If both buy stop and take profit attached, are triggered at the same time/price,
FxPro will execute the entry order at the available market price and remove the
take profitif the trigger bidprice is higher or equal to take profit level.
o Example:
EURUSD now trades at 1.06775/1.06790,
Buystop order on EURUSD @ 1.06800with take profitat 1.06820,
and next tick/price jumps to 1.06830/1.06845
Buystop order will be filled at 1.06845and take profit will be removed (client will
need to reapply a take profit)
• Sell Stop with Take Profit
o If both sell stop and take profit attached, are triggered at the same time/price,
FxPro will execute the entry order at the available market price and remove the
take profitif the trigger askprice is lower or equal to the take profitlevel.
o Example:
EURUSD now trades at 1.06775/1.06790,
Sellstop order on EURUSD @ 1.06750with a take profitat 1.06730,
and next tick/price drops to 1.06700/1.06715
Sellstop order will be filled at 1.06700and take profitwill be removed (client will
need to reapply a take profit).
• Buy Limit with Stop Loss
o If both buy limit and stop loss attached are triggered at the same time/price;
FxPro will execute the entry order at the available market price and remove the
stop lossif the trigger bid price is lower or equal to stop losslevel.
o Example,
EURUSD now trades at 1.06755/1.06770,
Buylimit order on EURUSD @ 1.06750with stop lossat 1.06720,
and next tick/price drops to 1.06700/1.06715
buylimit order will be filled at 1.06715and stop losswill be removed (client will need
to reapply a stop loss).
• Sell Limit with Stop Loss
o If both sell limit and stop loss attached are triggered at the same time/price;
FxPro will execute the entry order at the available market price and remove the
stop lossif the trigger ask price is higher or equal to the stop losslevel.
o Example,
EURUSD now trades at 1.06755/1.06770,
Selllimit order on EURUSD @ 1.06780with SL at 1.06800,
selllimit order will be filled at 1.06820 and stop losswill be removed (client will need
to reapply a stop loss).
5. MARGIN AND LEVERAGE
5.1 The Client understands that during the account opening process the default leverage is set at
1:50; the Client reserves the right to request a higher leverage but this will be at the discretion
of the Firm and subject to the appropriateness assessment of the Client.
5.2 For margin calculation purposes, the leverage level used will be the lower of:(i) the Account or
(ii) symbol traded. This logic applies on all our trading platforms.
5.3 Any changes made to your leverage on an Account that is already traded can immediately affect
your open positions and may result ina stop-out.
MetaTrader 4 (Instant and Market Execution)
5.4 The Firm, at Margin Level of less than 25% (twenty-five), has the discretion to begin closing
positions starting from most the unprofitable one. The Firm, at Margin Level of less than 20% (twenty), is automatically closing positions at market price.
MetaTrader 5
5.5 The Firm, at Margin Level of less than 40% (forty), has the discretion to begin closing positions
starting from the one that requires greater margin. The Firm, at Margin Level of less than 30%
(thirty), is automatically closing positions at market price.
cTrader and FxPro Markets
5.6 The Firm, at Margin Level of less than 40% (forty), has the discretion to begin closing positions
using the ‘Smart Stop-out’. The Firm, at Margin Level of less than 30% (thirty), is automatically
closing positions at market price.
5.7 Smart Stop Out: if Margin Level, falls below Smart Stop Out Level then tradeswill start being
closed until Margin Level reaches above Smart Stop Out Level. The logic of Smart Stop Out will
only close what is absolutely necessary from the largest tradein order to safely restore Margin
Level and protect the tradeitself, the position entry point and the trading account for as long
as possible.
1. FxPro reserves the right to amend, at any time, the specifications of CFDs and/or the
‘Leverage Policy’, available on our Website, in order to respond to a number of
situations including but not limited to specific market conditions. Even though the
Client is liable for ensuring that he/she remains informed, at all times, regarding the
latest specifications, FxPro will -where reasonably possible- notify the Client in writing
of the amendment(s).
2. Specific leverage restrictions may apply on certain CFDs and/or platforms and/or
jurisdictions as indicated on our Website. The Firm may, in its sole discretion, amend the
margin requirements, on a case by case basis, on all or any transaction(s) of the Client,
by providing the Client-where reasonable- with notice.
6. BEST EXECUTION
6.1 The Firm acts as principal and not as agent on the Client’s behalf; therefore, the Firm is the sole
execution venue for the execution of the Client’s orders for CFDs provided by the Firm. The
Firm shall take all reasonable steps to obtain the best possibleresult for its Clients taking into
account the following factors when executing Client orders using the Firm’s quoted prices.
6.2 The Firm considers various factors mentioned in the Policy (including the price, order size,
speed and likelihood of execution, cost, currency conversion, market impact as well as
likelihood of settlement) when executing Client orders and their respective importance. It is the
Firm’s policy to maintain such internal procedures and principles in order to determine the
importance of these factors and to act in the best interest of its Clients and provide them with the best possible result (or ‘best execution’) when dealing with them.
Prices
This section provides you with information about prices, which are given the highest importance in relation to the operation of our Platform.
6.3 The Firm’s price for a given CFD is derived through reference to the price of the relevant
underlying financial instrument, which the Firm obtains from third party liquidity/ price
providersso that at any point in time the prices are accurate and competitive. The Firm will not
quote any price outside the Firm’s operations time (see execution venue below) therefore no orders can be placed by the Client during that time.
6.4 FxPro receives price feeds from some of the world’s leading liquidity/ price providers. Our prices
not be the same as the prices you see on other platform(s)/ system(s) or in the market. Having multiple liquidity providers is important especially during abnormal market conditions such as times of extreme volatility the Firm is still able to provide Clients with competitive prices.
6.5 FxPro will, at all times, subject to events outside the control of the Firm, transmit bid and ask
prices through the trading platforms that are executable according to the Client’s instructions and the Policy.
6.6 For cTrader and MetaTrader5, prices are obtained directly from the liquidity/ price providers
through an electronic system. In conjunction with the price, the Firm streams available liquidity
at different price levels, (or ‘market depth’), which is used by the company to calculatethe
VWAP price in the case that there is not enough liquidity at the top of the book to fill a market
order.
6.7 FxPro shall determine, at its discretion, the prices that are executable and appear through the
trading platforms. The Client accepts that he/she shall disregard any bid and/or ask prices
quoted by a financial product provider other than FxPro.
6.8 The Client accepts that FxPro is solely responsible for determining the validity of the prices at
any given time; therefore, the Firm reserves the right to send the Client a requote (applicable to instant execution orders only), including but not limited to situations of high market volatility, if the company deems that to be necessary. Under the above mentioned circumstances, the Client may either accept or reject the requote.
6.9 We try to generate prices continuously but there are instances where this is not possible; for
example, instances of poor telecommunication/ internet connectivity, system errors and
outages severe volatility and/orilliquidity and/or other factors. There are also other factors
that may affect the price of the underlying instruments/ products from which the Firm derives its prices.
The above may cause prices to change between the time an order is placed and the time the order has been received by the Firm.
6.10 In general, if such a change occurs, the order will be executed depending on the trading
platform and account type specifications. There are other instances where the price at which a trade is executed may be less favourable than the price that was quoted on our trading platform at the time the order was placed for reasons including but not limited to market movements. For further details on this, please see below.
6.11 Requoting is the practice of providing a new quote(i.e. the current available price)to the Client
from the Client’s requested price. FxPro does not requote pending orders. The Client will not be receiving a requote where certain orders will be executed as market orders (i.e. executed at VWAP) instead of being executed as instant orders.
6.12 It should be noted that the price at which a trade is executed may vary significantly from the
original requested price during abnormal market conditions. This may occur, for example, at the following cases:
(a) during the market opening;
(b) during news times;
(c) during volatile markets where prices may move significantly up or down and away from
declared price;
(d) where there is rapid price movement, if the price rises or falls in one trading session to such
an extent that under the rules of the relevant exchange, trading is suspended or restricted;
(e) if there is insufficient liquidity for the execution of the specific volume at the declared price.
6.13 At the time that an order is received for execution, the specific price requested by the Client
may not be available; therefore, the order will be executed close to or a number ofpips away
from the Client’s requested price. If the execution price is better than the price requested by the Client this is referred to as positive slippage. In contrast, if the execution price is worse than the price requested by the Client this is referred to as negative slippage. Please be advised that slippage is a normal market practice and a regular feature when trading CFDs under conditions including but not limited to illiquidity and volatility due to news announcements, economic
events and marketopenings/ closings as well as order size. The FxPro automated execution
software does not operate based on any individual parameters related to the execution of orders through any specific Client accounts.
6.14 The Firm strives to provide the best possible price to its Clientsirrespective of the order type,
and makes every effort and necessary arrangements to do so.
Size, Speed and Likelihood of Execution
This section provides you with information about thesize, speed andlikelihood of execution,
all of which are given veryhigh importance.
6.15 The Client should bear in mind that in terms of volume, financial instruments traded through
the trading platforms, are measured in lots and the minimum volume of a tradeis available on
6.16 The Firm reserves the right to decline an order as explained in the Client Agreement, this Policy or entered contrary to the policies and procedures in place by the Firm. Notwithstanding the above, the Firm makes every effort to fill the order of the Client irrespective of the volume at a best available price, as the market liquidity allows at the time of execution.
6.17 FxPro reserves the right to place a cap on the number of trades and/or limit on the total net
position value per profile for a specific instrument.In such an event, the Firm will undertake all
possible efforts to notify Clients prior to such an event.
6.18 In addition,FxPro reserves the right to cumulatively execute instant orders,having the same
symbol, direction and price,at VWAP without notifying Clients in advance. In such instances,
the Client may also experience delay and slippage.
6.19 Under standard market conditions it typically takes 50-60ms, from the moment a Client’s order
is first registered in our system, to when execution is confirmed. Clients situated away from our
servers’ location or with poor internet connection will experience a delay of 100-300ms
reaching our servers from, which in effect might result in clients receiving a requote (if instant execution) or slippage (if market execution) if market moved away from the clients requested price.
6.20 When low levels of liquidity are experienced this may result in FxPro receiving infrequent price
updates from its liquidity/ price providers. Under such circumstances, the last bid and ask prices
quoted on the platform are deemed off-market prices (at the discretion of the Firm). It should
be noted that when you attempt to open or close an order at an off-market (or stale) price,
your orders may be executed with a delay or may be rejectedand the platform will display an
‘off market’ message confirming such an instance.
6.21 FxPro executes orders during trading hours only, as indicated on our Website.
6.22 Placing an order does not guarantee that such an order will be executed or that it will be
executed in accordance with the parameters set out by the Client.
6.23 The Firm relies on third party liquidity/ price providers for prices and available volume,
therefore execution of the Client’s orders will depend on the pricing and available liquidity of the providers. Although the Firm executes all orders placed by the Clients, it reserves the right to decline an order of any type.
6.24 The Firm executes most orders automatically, with minimal manual intervention. In addition to
the provisions referred to in the ’Events Outside our Control’ sectionof the 'Client Agreement’,
FxPro may execute an order manually and/or at VWAP, without notifying Clients in advance;
times of illiquidity and infrequent price updates,the order size is significant*in size, at times of illiquidity and infrequent price updates as well as times where the system identifies a Client/ trading activity as abusive and/or trades from multiple Client profiles bearing the same
characteristics (i.e. same software,symbol,time and price requested).
* Note that the ‘significance’ is determined at the discretion of the Firm.
6.25 It is possible that a Client order is partially filled; thisis the practice of executing an order in
parts if there is not enough liquidity in the market at the time in order to fill-in the full order at
a specific/ requested price. Partial fills may be executed at different prices.
6.26 The Firm strives to provide the best possible price to its Clients, and makesevery effort and
necessary arrangements to do so.
Cost
This section provides you with information about the cost of execution which is given high
importance.
6.27 For opening a position in some types of financial instruments the Client may be required to pay
commission or other fees; these are described in detail on our Website. For all type of CFDs offered by the Firm, the commission (if applicable) and financing/ overnight fees are not incorporated into the Firm’s quoted prices and are instead charged explicitly to the Client Account(s).
Commission
6.28 The Client shall be charged commission, as a fixed amountper USD million traded, when trading
CFDs on forex and metals through cTrader; further information is available onour Website.
Mark-up
6.29 The prices on which Clients are trading include a mark-up; this means thatthe spreads on offer
by the Firm comprise of (i) the raw spreads received from liquidity/ price provider(s) and (ii) any
mark-up, where applicable). Please see the ‘Order Execution Policy Summary’ (Schedule B of
the Policy) for further details.
Financing/ Overnight fee
6.30 In the case of financing/ overnight fees, the value of opened positions in some types of financial
trade. The financing fees are based on prevailing market interest rates; details of daily financing/ overnight fees applied, are available on our Website.
Currency Conversion
This section provides you with information about the currency conversion which is given the
appropriateimportance.
6.31 Any currency conversion calculations are provided by the Firm to the Client in the currency in
which the trading account is denominated and the currency of the relevant CFD, using the cross spot rate.
Example:
Client X has an Account that is denominate in EUR currency. Client X trades GBPJPY (Base
currency being the GBP with Variable currency being the JPY).In this instance, the Firm’s trading
platforms will always displaythe trade Profit & Lossin EUR, using the EURJPY ‘live’rate from
our trading platforms.
Likelihood of Settlement
6.32 All the financial instruments on offer by the Firm do not involve any physical delivery of the
underlying asset or assets. Therefore, no settlement occurs.
7. EXECUTION VENUES
7.1 FxPro is, without exception, the execution venue for all orders and acts as principal and not as
agent on the Client’s behalf; contractually the Firm is the sole counterparty to the Client’s trades and any execution of orders is done in the Firm’s name.
7.2 The Client acknowledges that the orders entered with the Firm are not undertaken on a
regulated exchange; rather, they are undertaken through the Firm’s trading platforms. Therefore, the Firm may not execute an order, or it may change the opening or closing price of an order in certain cases including but not limited to instances of a technical failure of the
trading platform. In addition,the Firm may not execute an order at all if such an order is based
on anerroneous and/or off-market price and/or the Client and/or the Client order(s)falloutside
8. INSTRUCTIONS
8.1 FxPro shall accept instructions that have been transmitted by the Client through the trading
platforms or other means determined in the Policy. If, for any reason, the Client is unable to
access the trading platforms in order to send an instruction for thepurposes of trading CFDs
he/she may contact the Dealing Department by telephone on +357 25 969 238/9 to place a verbal instruction, subject to the restrictions referred to in the ‘Recordings and Monitoring of Communication’ section of the ‘Client Agreement’.
8.2 It should be noted that the Firm reserves the right to reject such verbal instruction when the
operator of the Dealing Department is not satisfied with the Client’s identify or clarity of
instructions; under such circumstances, FxPro reserves theright to request from the Client to
transmit an instruction through another mean. The Client accepts that at times of excessive transaction flow there might be delay in connecting over the telephone with an operator of the Dealing Department, especially when there are important market announcements.
8.3 It should be noted that if you were to provide us with instructions on how to execute your
order(s), complying with those instructions may prevent us from taking the steps set out in the
Policy to obtain the best possible result for the execution of your order(s). Under such
circumstances, our execution in accordance with your instructions will be deemed best execution.
8.4 In the absence of specific instructions from the Client, FxPro will balance the above factors
based on our judgment as well as professional experience, in light of the available market
information and market conditions at the appropriate time, and considering the following criteria:
8.4.1 characteristics of the client including the categorization of the client as retail or professional,
8.4.2 characteristics of the client’s order,
8.4.3 characteristics of the financial instrument that is the subject of that order, 8.4.4 characteristics of execution venues where that order can be covered.
8.5 The Client accepts that the Firm bears no responsibility for any instructions that may be
misinterpreted due to a technical or other error.
8.6 The client accepts that unless he/she informs in writing FxPro regarding the termination of the
Authorised Representative(as defined in the ‘Glossary’ section of the Client Agreement), the
8.7 The Client accepts that once FxPro receives instruction(s) for trading CFDs such instructions are final and cannot be cancelled or deleted, except where the Firm expressly agrees to such cancellation or deletion.
9. REFUSAL TO EXECUTE AND TERMINATION OF THE AGREEMENT
9.1 In addition to any other provision of the Policy and/or the ‘Client Agreement’, the Client accepts
that FxPro shall have the right, at any time, to refuse at its discretion, the provision of any
investment or ancillary service, including but not limited tothe execution of orders, without
providing notice to the Client.
9.2 This section might come in effect in under certain circumstances, including but not limited to
situations when FxPro has reasonable grounds to believe that the execution of a Client’s order may:
(a) affect the orderly function of the market;
(b) constitutes an abusive exploitation of privileged confidential information;
(c) contributes to the laundering of illegal funds;
(d) affects in any manner the reliability or orderly operation of the trading platforms; and
(e) the Client’s order relates to the purchase of a financial instrument but there is
insufficient free margin in the relevant trading account to cover such purchase and any applicable charges.
9.3 FxPro reserves the right to refuse the execution of a pending order and/or modify the opening/
closing price of an order if a technical or other issue arises.
9.4 The Client accepts that the Firm may refuse to execute an instruction for trading financial
instruments, if conditions described above, are triggered.
9.5 The Client accepts that FxPro reserves the right to immediately terminate the Client’s access to
the trading platform(s) or Account(s) or refuse or cancel any order of the Client, in the event the Client voluntarily and/or involuntarily partakes in arbitrage unrelated to market inefficiencies, including but not limited to, latency arbitrage and swap arbitrage and/or contrary to good faith; under such circumstances, FxPro may, at its discretion, close any of the Client’s
Account(s)and recover any losses incurred from such practices, in accordance with the terms
of the ‘Client Agreement’, the Policy or FxPro’s policies and procedures.
9.6 In addition, the Client accepts that FxPro reserves the right to immediately terminate the
Client’s access to the trading platforms and/or recover any losses incurred from a Client’s
Account(s) in the event the Firm determines in its sole discretion that the Client voluntarily
and/or involuntarily undertakes to abuse the negative balance protection (the ‘NBP’) offered
either on an individual Account, or multiple Account(s) or multiple profiles and/or between one or more Client(s) of the Firm in accordance with the ‘Client Agreement’. For instance, a Client hedging his/her exposure utilising his/her accounts under the same or different Client profile
would constitute an abuseof the NBP as well as a Client requesting a withdrawal of his/her
Client Money -notwithstanding any of the provisions of the ‘Client Agreement’- when the
symbol he/she is trading is not available for trading at FxPro during that specific timeframe. Another example would be an instance where a Client transfers fund from his/her Account to the Vault before opening or while having open positions, in a manner which indicates an attempt to abuse the NBP policy; it should be noted that this is not an exhaustive list. Where the Firm has determined, in its sole discretion, that a Client or Client(s) have abused the NBP, FxPro may take any action it deems fit, including but not limited to transfer any amount(s) from
any Account(s) under any profile, in order to cover the NBP loss.
9.7 The Client accepts that if FxPro were to refuse the execution of a Client’s order, under this
section or this Policy, the obligations of the Client under the ‘Client Agreement’ shall remain unaffected.
10. CORPORATEACTIONS
10.1 Corporate actionsmean, any actions taken by an issuer, whose listed securities are associated
with the CFDs traded through our trading platforms, including but not limited to instances of: (i) stock split, (ii) consolidation, (iii) rights issue, (iv) merger and takeover, (v) dividends and (vi) earnings report.
10.2 Margin requirements for shares and/or indices, with an upcoming earnings report and/or
corporate and/or other action (collectively, the ‘Corporate actions’), may increase up to no
more than 5 times the normal percentage, 5 days prior to the Corporate Action, and may remain in effect after the Corporate Event at FxPro’s sole discretion. During the affected period, new margin requirements will apply for all existing and new trades. FxPro Clients remain fully
responsible for monitoring both the required marginof their Account(s) and free margin prior,
during and post the affected period. As a result of the above, FxPro Clients understand and accept that this may result in their Account(s) incurring a margin call and/or stop out.
10.3 When a corporate action occurs, the Client accepts that FxPro reserves the right to make
10.4 Whena corporate action occurs, the Client accepts that FxPro shall take reasonable steps to replicate the market conditions. If FxPro, in its sole discretion, warrants it is unable to fairly value a corporate action, the Firm shall reserve the right to close a Client’s position.
10.5 Further information regarding ‘Corporate Actions’ can also be found on our Website.
Long Positions
10.6 A Client holding a long position for the applicable symbol and/or spot index, which
encompasses the symbol onthe ex- dividenddate will receive the applicable dividend in the
form of a cash adjustment, credited to the relevant Account.
Short Positions
10.7 A Client holding a short position for the applicable symbol and/or spot index which
encompasses the symbol on the ex- dividenddate will be charged the applicable dividend in
the form of a reverse cash adjustment, debited from the relevant Account’s free equity.
10.8 In the event a Client maintains a short position for the applicable symbol and/or spot index,
which encompasses the symbol on the ex- dividenddate and has insufficient free equity in their
Account to cover the reverse cash adjustment, FxPro reserves the right to close the open position. Under such circumstances, the reverse cash adjustment shall be deducted from the Account’s Balance.
10.9 The Client accepts that FxPro is not required to notify a Client in the event an Account maintains
insufficient free equity to cover a reverse cash adjustment for a short position.
Stock Splits, Rights Issues and other Corporate Actions
10.10 An appropriate adjustment on the Client’s position will be made to mirror the economic impact of an action.
Fractional Share Adjustments
10.11 In the event a corporate action results in a fractional position, FxPro reserves the right at its own discretion to credit the outstanding fractional component as a cash adjustment to be credited to the Client’s trading account; the adjustment will be subject to the closing price on
the last trading day prior to the ex-date.
10.12 In the event of a share being de-listed, the Client’s position will be closed at the last market price traded.
10.13 IMPORTANT:
FxPro bears no responsibility for notifying the Client regarding announcements of corporate actions.
11. GENERAL MATTERS
11.1 CFDs are not eligible for sale in certain jurisdictions or countries. The Policy is not directed to
any jurisdiction or country where its publication, availability or distribution would be contrary to local laws or regulations, including but not limited to the United States of America. The Policy does not constitute an offer, invitation or solicitation to buy or sell CFDs. It may not be reproduced or disclosed (in whole or in part) to any other person without prior written permission. The Policy is not intended to constitute the sole basis for the evaluation of the Client’s decision to trade CFDs.
11.2 Please contact us, if you are dissatisfied with ourservices, or if you have a query regarding your
account or activity with us. For further details, please refer to the ‘Complaints Handling
Procedure’ available on our Website.
11.3 We provide to our clients with periodic statements (in a durable medium) of their activities
carried on with us, unless such a statement is provided to the Client via another durable
medium i.e. via our trading platforms.
11.4 The Client shall regularly consult the ‘Help’ menu or UserGuideof the trading platforms; if a
conflict arises the ‘Client Agreement’ and/ or the Policy shall prevail unless FxPro determines, in its sole discretion, otherwise.
12. MONITORING AND REVIEW
12.1 The Firm will monitor and review the Policy as well as its order execution arrangements at least
annually and make improvements (where necessary). A review will also be carried out whenever a material change occurs that affects the ability of the Firm to continue provide the
best possible result for the execution of its Client orders as indicated in the Policy.
SCHEDULE A: GLOSSARY
NOTE: for any word that has been capitalised but has not been defined herein, please refer to
the ‘Glossary’ section of the Client Agreement.
1. Base Currency: means the first currency represented in a currency pair, for example in the
EURUSD currency pair the base currency is the EUR.
2. Contract for Difference (‘CFD’): CFDs, which are traded off-exchange (or Over-the-Counter
(‘OTC’)), are agreements to exchange the difference in value of a particular instrument or
currency between the time at which the agreement is entered into and the time at which it is closed, allow the Firm’s Clients to replicate the economic effect of trading in particular
currencies or other instruments without requiring actual ownership of those assets;a full list
of theCFDson offer by the Firm is available on our Website.
3. Declared Price:meansthe price that the Client requested for either an instant execution or
pending order.
4. Lot:is a standard trading term referring to an order of 100,000 units. Forex Currency pairs are
usually traded in units of 100,000 (standard lots), 10,000 units(mini lots) or 1,000 (micro lots)
meaning buying/ selling 100,000 of the Base Currency while selling/ buying the equivalent number
of units of the Variable Currency.
5. Margin Level: means the Equity to Margin ratio calculated as:
Margin Level = Equity / Required Margin
6. Variable Currency: Shall mean the second currency represented in a currency pair, for example
SCHEDULE B: ORDER EXECUTION POLICY SUMMARY
MetaTrader 5 cTrader FxPro Markets
Execution: Instant Order Market Order Market Order Market Order
Market Order
Requoting: Yes No No No No
Slippage: N/A Yes Yes Yes Yes
Partial fills: No Yes Yes Yes Yes
Level restrictions on ‘stop & limit’ orders:
Yes Yes Yes No No
Commission: N/A N/A N/A Yes N/A
Mark-up: Yes Yes Yes Where
Execution: Market Order Market Order Market Order Market Order
Market Order
Requoting: N/A N/A N/A N/A N/A
Slippage: (i) Yes
Partial fills: No Yes Yes Yes Yes
Level restrictions on ‘stop & limit’ orders:
Yes Yes Yes No No
Commission: N/A N/A N/A Yes N/A
Mark-up: Yes Yes Yes Where
Applicable Yes
LIMIT ORDERS**
Execution: Limit Order Limit Order Limit Order Limit Order Limit Order
Requoting: N/A N/A N/A N/A N/A
Slippage: (i) Yes,
Level restrictions on ‘stop & limit’ orders:
Yes Yes Yes No No
Commission: N/A N/A N/A Yes N/A
Mark-up: Yes Yes Yes Where
Applicable
Yes
* STOP ORDERS include buy stop, sell stop, stop loss and stop-outs.
FxPro Financial Services Ltd. Incorporated in the Republic of Cyprus (Registration no. HE 181344) Authorised and regulated by the Cyprus Securities and Exchange Commission (Licence no. 078/07)
Address: 1 Karyatidon, Limassol, CY-4180, Cyprus Telephone: +357 25 969 200 │Fax: +357 25 969 269 http://www.fxpro.com│ [email protected]
