This document is a template prepared for review. It must be reviewed, completed and approved by qualified legal and compliance professionals for each jurisdiction in which services are offered before publication. Bracketed items are placeholders.
1. Purpose and Scope
This Order Execution Policy (the "Policy") describes the arrangements [LEGAL ENTITY NAME], trading as JDGlobalFX ("we", "us", "our"), has established to obtain the best possible result for clients when executing orders in CFDs and related products. It applies to retail and professional clients and forms part of the Client Agreement.
2. Execution Model
We act as principal and are the counterparty to every transaction. Our execution model is [EXECUTION MODEL DESCRIPTION]. We may hedge our exposure with [HEDGING COUNTERPARTIES / LIQUIDITY PROVIDERS] or manage it internally; whether we hedge a particular transaction does not affect the price or execution you receive. We are the sole execution venue for your orders, which are not transmitted to a regulated market or multilateral trading facility.
3. Pricing
Our prices are derived from [PRICING SOURCES], to which we apply a spread and, where applicable, a mark-up. Spreads may be fixed or variable by instrument and can widen during low liquidity, high volatility or scheduled news events. We take reasonable steps to ensure our prices fairly reflect the underlying market. Prices on our website may be delayed or indicative; the tradable price is that shown on the platform at the moment of execution.
4. Execution Factors
| Factor | Description |
|---|---|
| Price | The price at which the order is executed |
| Costs | Spread, commission, financing and other charges |
| Speed | The time taken to execute the order |
| Likelihood of execution and settlement | The probability that the order is filled in full |
| Size | The order volume relative to available liquidity |
| Nature of the order | Market, limit, stop or other order type |
For retail clients the best possible result is determined in terms of total consideration (price plus execution costs). Speed and likelihood of execution take precedence only where instrumental in delivering the best total consideration.
5. Order Types and Handling
5.1 Market execution
Market orders are executed at the best available price when they reach our system. Because prices can move between submission and execution, the fill price may differ from the price displayed; we do not guarantee execution at the requested price.
5.2 Slippage
Slippage is the difference between the requested and executed price. Our systems apply slippage symmetrically: where the market has moved in your favour between submission and execution you receive the improved price, and where it has moved against you the order is filled at the less favourable price. We do not apply asymmetric settings that systematically disadvantage clients. Slippage is most likely during news releases, market open and thin liquidity.
5.3 Requotes
Under market execution, requotes are not used; orders are filled at the available price or rejected. Under instant execution, where offered, we may return a requote if the price has moved beyond [MAXIMUM DEVIATION SETTING], which you may accept or decline. Requotes are never used selectively to disadvantage particular clients.
5.4 Pending orders
Limit, stop, stop-loss and take-profit orders are held on our systems and triggered when our price reaches the specified level, on the [BID / ASK / MID] price for the relevant side as set out in [ORDER TRIGGERING RULES]. Once triggered, stop orders become market orders and are filled at the next available price, which may be worse than the stop level. Limit orders are filled at the specified price or better; if insufficient liquidity exists the order may remain pending.
5.5 Partial fills and size limits
Orders exceeding the liquidity available at a given price may be filled in parts at successive prices, or at a volume-weighted average price. Where partial fills are not permitted for an order type, the order is rejected. Order-size and position limits per instrument are published on the platform and may change without notice.
6. Abnormal Market Conditions
Abnormal conditions include extreme volatility, suspension of an underlying market, failure of a pricing source, market gaps, and any circumstance in which a fair price cannot reliably be established. In such conditions we may:
- widen spreads or increase margin requirements;
- switch instruments to close-only or suspend trading;
- delay, reject or execute orders at a price different from that requested;
- adjust or void transactions executed at manifestly erroneous prices.
We will act reasonably and in good faith when exercising these rights.
7. Specific Instructions
If you give a specific instruction regarding an order, we will follow it. Doing so may prevent us from taking the steps in this Policy to obtain the best possible result for the elements covered by the instruction.
8. Aggregation
We do not aggregate client orders with our own or other clients' orders unless permitted under [AGGREGATION RULES].
9. Monitoring and Review
We monitor execution quality on an ongoing basis by comparing executed prices against [BENCHMARK SOURCES], reviewing slippage, rejection rates and latency, and investigating outliers. Monitoring is carried out by [RESPONSIBLE FUNCTION] and reported to senior management at least [REVIEW FREQUENCY]. We review this Policy at least annually and whenever a material change affects our ability to obtain the best possible result; material changes are published on our website. Where required, we publish [EXECUTION QUALITY REPORT DESCRIPTION]. You may request information about how a particular order was executed from [SUPPORT EMAIL].
10. Consent
By accepting the Client Agreement you consent to this Policy and to the execution of your orders outside a trading venue, with us acting as principal.