ORDER EXECUTION POLICY

Introduction

In order to comply with the requirements of the Second Markets in Financial Instruments Directive (MiFID II) this document sets out the steps that Alvar Financial will follow in order to obtain the best possible result when executing your orders. It should be read in conjunction with our Customer Agreement, Conflicts of Interest Policy and Risk Warning Notice. We have a general duty to conduct our business with you honestly, fairly and professionally. This policy forms part of our Terms and Conditions, and as such acceptance of our Customer Agreement constitutes acceptance of our Order Execution Policy as summarised in this document.

Scope

The Execution Policy applies when orders are executed by Alvar Financial in financial CFDs and Spread Betting transactions. Where you execute your order through our online trading platform, we shall assume that you have provided us with specific instructions and in these circumstances Alvar Financial will have complied with our obligation to take all reasonable steps to obtain the best possible result when executing an order on your behalf.

How we execute your orders

Alvar Financial deals with you as principal (and not as agent) when executing your orders. We are therefore your only “execution venue”. In dealing with us, you transact directly with us and not on any exchange or other external market or venue.

Where you give us specific instructions then those instructions take precedence over other aspects of our policy. We will continue to apply the policy for the aspects of an order not affected by the specific instructions.

Execution Venues

An execution venue is a regulated market, Multilateral Trading Facilities (MTFs), or systematic internaliser or other liquidity provider (i.e. an off-exchange dealer). As we act as principal (and not as agent) in relation to contracts that you enter into with us, we are acting as the only execution venue in connection with your transactions. While we are your execution venue, Alvar or an affiliate will transact with liquidity providers selected by Alvar Financial and through whom Alvar Financial transmits the order. Venues other than regulated markets and MTFs (e.g. off-exchange dealers) may be used as execution venues.

We ensure best execution for you by reference to the market prices of the underlying reference prices for your transaction. We regularly compare competing liquidity providers for the best prices from which to derive indicative quotes for you. Although we operate as a single execution venue, we are able to obtain best execution for our clients on a consistent basis – compared with outcomes which could reasonably be expected from using alternative execution venues.

Execution factors and criteria

The execution factors and criteria are an important aspect of the process to ensure that the best possible result is obtained. These factors and criteria have been considered in order of the relevant importance we place on them as part of the decision making process and are as follows:

Price and cost

The relative importance we attached to these factors is very high.

There are two components of the price of a financial spread bet / CFD:

• the price of the underlying instrument derived from our liquidity providers; and
• our charges in the form of the bid-offer spread (a mark-up or mark-down to the price of the underlying) – the Spread Charge.

The execution price is determined by the price we are able to obtain for the underlying instrument from our liquidity providers and the ‘Spread Charge’, which is defined as the spread which is added to the underlying market price, resulting in the spread bet price. We ensure complete transparency by providing you with access to both the spread bet price and the underlying market price when executing your orders.

Whilst we understand that price is a key factor, we may decide that in certain circumstances other execution factors (see below) are more important in determining the best possible result for you.

OTHER EXECUTION FACTORS

Size of the order and likelihood of execution

The relative importance we attach to these factors is high. Liquidity may be sourced from a variety of market participants.

Speed of execution

The relative importance we attach to this factor is medium.

In most circumstances, spread bets and CFDs requested by you will be processed immediately. However, occasionally situations may occur that prevent immediate execution. For example, there may be a delay in execution should lack of liquidity in the underlying market prevent instant execution of our hedge, against your spread bet or CFD. Alvar Financial will endeavour to fulfil your instructions within a timely manner wherever the market conditions permit.

Dealing with your orders

Your exposure to our products becomes effective as soon as you receive confirmation from us that your CFD or spread bet has been ‘filled’. It is important to note that we cannot guarantee the execution price of orders. We do, of course, make every effort to execute orders at or very close to the specified order. However, due to movements in the underlying price, it is possible that our price may move quickly or erratically causing market slippage when we execute your orders on your behalf – the price that you obtain at the time of execution may be markedly different to the order price.

With our discretion, it is possible to execute trades through the trading platform outside our trading hours but during the relevant exchange’s opening period.

Risks

Clients should be aware that in fast moving and volatile markets, whilst we take all reasonable steps to ensure the best possible price, the prevailing conditions may result in a trade price that is no longer the best market price.

Furthermore, during a period of volatile markets, an order may be executed at a substantially different price(s) from the quoted price or may only be executed in part.

Execution quality

When executing orders or taking decisions to deal we check the fairness of the price proposed to you by periodically checking the processes in which orders are executed and liquidity sought.

Review

This policy will be reviewed at least annually and whenever a material change occurs that affects Alvar Financial’s ability to continue to obtain the best possible result for you. As part of that process we will review the external execution venues we use which also provide our external reference for pricing purposes.