1 Overview

4T Markets Limited (“4T Markets”, or “the Firm”) is committed to providing the best possible outcome to its clients and dealing with them honestly and in a transparent manner. Best execution is a requirement of both the EU Markets in Financial Instruments Directive 2014/65EU (“MiFiD”) and the Financial Conduct Authority (FCA) and applies to all firms regulated in here in the UK & Europe who execute orders on behalf of retail and professional clients. Best execution refers to our obligation to take all sufficient steps to obtain the best possible result when executing orders on our clients’ behalf, considering all relevant execution factors. We exercise our judgement in obtaining the best outcome for the execution of trades for our clients, and consider the following factors when executing clients’ orders:

• • total consideration (the sum of the price of the financial instrument and the costs related to execution)
• • speed and likelihood of execution and settlement.
• • the type and size of the order and transaction and its market impact; and
• • other factors that we believe to have significance for the execution of the order such as price, speed and likelihood of execution, and settlement size and nature

4T Markets Limited is authorised and regulated by the Financial Conduct Authority under firm reference number 624225.

This Execution Policy should be read in conjunction with the Firm’s standard Terms and Conditions. If you proceed to place an order with us, we will assume that as your consent to 4T Markets executing that order in accordance with this Policy. By accepting our Terms and Conditions, a client accepts that the execution of orders may take place outside a regulated market, a Multilateral Trading Facility (“MTF”) or an Organised Trading Facility (“OTF”).

1.1 Introduction

4T Markets’ business is providing liquidity to professional, institutional (small funds and FX retail brokers) and retail clients in Rolling Spot FX. Your trades will be executed on the Firm’s MT4 or MT5 trading platforms. Trades placed on the platform will be immediately hedged by 4T Markets with liquidity providers utilising their straight-through processing model.

When providing a brokerage service to you in relation to Rolling Spot FX the Firm will take all sufficient steps to achieve the best possible result for you. This means that the Firm will aim to provide “best execution” subject to and taking into account the nature of your orders, the prices available in the market, the nature of the market in question and a reasonable assessment of the sometimes overlapping and conflicting execution factors (which are detailed below).

The Firm’s intention is, so far as possible, to exercise consistent standards and operate the same processes across all markets, clients, and financial instruments in which the Firm operates.

The Firm also intends to provide you and other market participants with access to (where possible) tradable prices on a non-discriminatory basis. However, the diversity in those markets and instruments, and the kind of orders that you may place, mean that different factors will have to be considered in relation to any particular transaction.

1.2 Total Consideration

The best possible result is determined in terms of the total consideration for clients. Total consideration is the sum of the price and all relevant costs of the execution of the financial instrument. The main way in which we seek to provide this is by looking at the calculation of our bid/offer prices used to execute a client’s order to ensure there is due regard paid to the market price for the underlying reference product to which the order relates. Further expenses directly related to the execution of an order such as trading venue fees, clearing and settlement fees, and any other fees paid to third parties involved in the execution of the order, form part of the total consideration.

For professional clients, the best possible result is also determined in terms of the total consideration. If, arising from a specific order, we have reason to believe or the client declares that, due to the nature of the order or factors pertaining to the client, other factors, such as the likelihood and speed of execution and settlement, have greater significance, we may consider such factors in the execution. In such a case we will assess whether executing the transaction based on total consideration would ensure fast and full execution of the transaction. If it is not ensured, we will assess whether partial execution of the Order based on total consideration would be more beneficial for the client than full execution of the order based on the criterion of likelihood of execution and settlement. If not, we will use the criterion of execution of transaction and settlement. We will also assess the potential negative impact of the execution time (speed) for the client and the extent of the associated risk of damage. If such damage exceeds the gains achievable based on total consideration, the criterion of speed will be used.

2 Exemptions from the provision of Best Execution

Notwithstanding the intentions expressed above, the Firm does not undertake to provide “best execution” if you fall within any of the following exemptions:

2.1 Eligible Counterparties

If you are classified as an Eligible Counterparty, you will not be entitled to best execution under the UK Financial Conduct Authority (“FCA”) or equivalent EU rules (pursuant to Article 30 of MiFID II, which disapplies the best execution obligation under Article 27 of MiFID II for Eligible Counterparties).

2.2 Market Practice

In the wholesale OTC derivatives markets in which the Firm operates it is normal market practice for buyers and sellers to “shop around” by approaching several brokers/dealers for a quote.

If these circumstances apply, there is no expectation between the parties that the broker/dealer chosen will owe best execution.

2.3 Client Instructions

Where you provide the Firm with specific instruction in relation to your order, or any particular aspect of your order, including an instruction for your trade to be executed on a particular venue, the Firm will endevour to execute the order in accordance with your instructions.

However, please note that in following your instructions, in certain circumstances it may prevent us from following some or all of the steps outlined in our Order Execution Policy which is designed to obtain the best possible results for you on a consistent basis. In such circumstances, the Firm will be deemed to have taken all sufficient steps to provide the best possible result for you in respect of the order, or aspect of the order, covered by your specific instructions.

3 Clients

The Firm deals with Retail Clients, Professional Clients and Eligible Counterparties as defined in MiFID II and by the FCA.

Because the Firm always intends to handle orders and expressions of interest in an equitable and consistent manner, once a client is classified, for the purposes of a particular instrument, that client may not then elect to be re-classified for the purposes of one transaction of a type it customarily undertakes.

Exceptional circumstances may be considered at the time, with the consent of the Firm (the Firm may decline to provide a service should a reclassification be requested).

4 Execution Venues

For the avoidance of doubt, the only Financial Instruments provided by the Firm is Rolling Spot FX. As 4T Markets operates on a matched-principal basis, client orders are placed with execution venues and liquidity providers. Execution Venues are the entities with which the orders are placed or to which the Firm transmits orders for execution.

As principal to the trade (albeit as matched principal) we are the execution venue and other ‘venues’ have been identified to provide price feeds which drive the bid/offer and provide the cover for the matched principal trade offset, taking into account the factors detailed below.

Based on its assessment of the Execution Factors and the Execution Criteria, 4T Markets will select one or more venue(s) for the execution of the clients order. Venues used might include:

• a. Liquidity providers.
• b. Regulated Markets.
• c. Multilateral Trading Facilities.
• d. Market Makers.
• e. Systematic Internalisers and
• f. Non-EEA Firm that perform a similar function to the Firms above.

4T Markets will take reasonable care not to discriminate between execution venues other than on the basis of the Execution Factors relevant to the order concerned.

The Firm places significant reliance on the Execution Venue based on the execution factors set out above and their relative importance. It is the Firm’s policy to maintain such internal procedures and principles in order to determine the relative importance of these factors and to act for the best interest of its clients and provide them the best possible result ( “Best Execution”).

The selection process for execution venues used is based on the Firm’s assessment of execution strategies employed by those venues, the quality of execution obtained, and the best execution policies and processes adopted by those venues. Management has carried out due diligence on the Venue and its performance will be continually monitored to ensure clients continue to receive excellent service primarily on the bases of prices offered, total consideration to the client, speed of execution and reliability of trading infrastructure.

When selecting the execution venue, the Firm takes reasonable measures to ensure that it could obtain the best possible trading result for its clients, subject to the following factors:

• • The venue gives the Firm an indemnity vis-à-vis any negative balance protection the Firm gives its clients.
• • In the markets in which the Firm operates, the platform will give clients visibility to prices that have been communicated to the Firm.
• • The platform will provide details of all tradable bids and offers (subject to the other matters referred to below).
• • Time availability of prices – in many markets there are lulls and spikes in trading as negotiations align trading interests at different times and different parts of the curve, accordingly the “last traded” price may not always be available or act as a reliable indicator of current price;
• • 4T Markets cannot allow clients to trade unless it is reasonably satisfied that the venue can honour the relevant hedge trade with 4T Markets.
• • Fees may vary between venues and clients, based on agreements and levels of activity.

The execution venues used may evolve and 4T Markets reserves the right to include/exclude execution venues at its own discretion. An up to date list of execution venues can be found in Annex I of this policy.

5 Execution Factors

The Firm shall take all sufficient steps to obtain the best possible result (Best Execution) on behalf of clients either when receiving and transmitting orders for execution considering the following factors:

• • Price - The Firm will quote two prices: the higher price (ASK) at which the Client can buy (go long), and the lower price (BID) at which the Client can sell (go short). Collectively, the ASK and BID prices are referred to as the Firm’s price. The difference between the lower and the higher price of is the spread.
  Such orders as Buy Limit, Buy Stop and Stop Loss, Take profit for opened short position are executed at ASK price. Such orders as Sell Limit, Sell Stop and Stop Loss, Take profit for opened long position are executed at BID price.
  The Firm’s price for is calculated by reference to the price of the relevant underlying asset, which the Firm obtains from third party external reference sources. The Firm’s prices can be found on the Firm’s website or trading platforms. The Firm updates its prices as frequently as the limitations of technology and communication links allow. The Firm reviews its third-party external reference sources from time to time to ensure that the data obtained continues to remain competitive. The Firm will not quote any price outside the Firm’s operations time therefore no orders can be placed by the Client during that time.
  According to the MiFID II requirements in respect of best execution when trading in over-the-counter derivatives, 4T Markets will check the fairness of the price proposed to the client by gathering external market data used in the estimation of the traded instrument.
  If the price reaches an order such as: Stop Loss, Take Profit, Buy Limit, Buy Stop, Sell Limit or Sell Stop, these orders are instantly executed. However, under certain trading conditions it may be impossible to execute orders (Stop Loss, Take Profit, Buy Limit, Buy Stop, Sell Limit or Sell Stop) at the client's requested price. In this case, the Firm has the right to execute the order at the first available price. This may occur, for example, at times of rapid price fluctuations 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, or this may occur at the opening of trading sessions. The minimum level for placing Stop Loss, Take Profit, Buy Limit, Buy Stop, Sell Limit and Sell Stop orders, is specified under the Client Agreement.
• • Cost – details of commissions, fees, and charges for the execution of orders are available in the client agreement.
• • Speed - The Firm places a significant importance when executing or receiving and transmitting client’s orders for execution and strives to offer high speed of execution within the limitations of technology and communications links.
  For instance, in cases where clients use a wireless connection or a dial up connection or any other communication link that can cause a poor internet connection can cause unstable connectivity with the Firm's trading platform resulting to the client placing his orders at a delay and the orders to be executed at better or worst prevailing price offered by the Firm;
• • Likelihood of execution and Settlement – In some cases it may not be possible to arrange an order for execution, for example, but not limited to, in the following cases: during news times, trading session start moments, volatile markets where prices may move significantly up or down and away from declared prices, where there is rapid price movement, where there is insufficient liquidity for the execution of the specific volume at the declared price, or a force majeure event has occurred. If the Firm is unable to proceed with an order about price or size or other reason, the order will not be executed. In addition, the Firm is entitled, at any time and at its discretion, without giving notice or explanation to the Client, to decline or refuse to transmit or execute any order, request or instruction for the client in circumstances explained in the Client Agreement.
  The Financial Instruments offered by the Firm do not involve the delivery of the underlying asset, so there is no settlement. Size of order:
  A lot is a unit measuring the transaction amount and it is different for each type of derivative. Please refer to the Firm’s trading platform for the value of minimum size of an order and each lot for a given derivative type. The Firm reserves the right to decline an order as explained in the agreement entered with the client. Please refer to the Firm’s trading platform for the value of the maximum volume of the single transaction.
• • Size - order sizes that an execution venue typically accepts.
• • Market impact - Some factors may rapidly affect the price of the underlying instruments/products from which the Firm’s quoted price is derived and may also affect other factors listed herein. The Firm will take all sufficient steps to obtain the best possible result for its clients; and
• • Any other consideration relevant to the execution of the order, as applicable.

The Firm does not consider the above list exhaustive and the order in which the above factors are presented shall not be taken as a priority factor.

5.1 Best Execution Criteria

The Firm will determine the relative importance of the above Best Execution Factors by using its commercial judgment and experience in the light of the information available on the market and considering:

• • The characteristics of the client (client categorisation and appropriateness)
• • The characteristics of the client order.
• • The characteristics of financial instruments that are the subject of that order; and
• • The characteristics of the execution venues to which a client order may be directed.

4T Markets regards price as being one of the most important considerations when seeking to obtain the best possible result for clients. In addition, the Financial Instrument to which the order relates dictates to a large extent the determination and ranking of the relative importance of the Execution Criteria.

For Retail and Professional clients, the best possible result shall be determined in terms of the total consideration (unless the objective of the execution of the order dictates otherwise), represented by 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 any execution venue fees (as applicable).

5.2 Price Slippage

It is acknowledged that in rare circumstances, price slippage may occur despite the automated nature of the platform. Several factors may lead to price slippage, for example, market data latency, the speed of a client’s internet connection or high market volatility. You should be aware that when price slippage occurs, it can be to your disadvantage.

5.3 Trades outside Market Hours

In some cases, the Firm will obtain a quote outside of market hours and these may be subject to discretion. It may be necessary to reduce the maximum size of the trade or widen the spread or take any other steps required to obtain a fair price wherever possible in those circumstances.

5.4 Other Factors

Aside from the Best Execution obligations 4T Markets has, it is subject to the FCA’s Principles for Businesses which require us to:

• • conduct our business with integrity, due skill, care, and diligence.
• • observe proper standards of market conduct; and
• • pay due regard to the interests of our customers and treat them fairly.

4T Markets considers and continuously monitors for manifest errors. All instruments have reasonable price filtering conditions which prevent most of the manifest errors such as price spikes.

Price improvement and slippage symmetry is considered and continually monitored; we will not accept a liquidity provider that that does not provide price improvement. Liquidity providers that have persistent issues with asymmetric slippage that cannot be resolved within reasonable time will no longer be used.

The system uptime is an important factor for instruments with a single liquidity provider. It is carefully considered and monitored and where there are persistent issues that can impact on pricing availability caused by external factors such as system outages, remedial steps will be taken.

Our best execution obligation applies to all financial instruments that we offer. We therefore carry out detailed monitoring of the quality of execution obtained on the execution venues where client orders have been executed for 4T Markets. We have access to several different data sources to ascertain the market price, which is our objective view of the bids and offers available to arms’ length traders.

We will not normally differentiate between orders received from professional clients and retail clients, although in some circumstances our determination of the relative importance of the execution factors may differ for professional clients, e.g., where the likelihood of execution may take precedence over the price.

6 Fees and Costs

The Firm does not charge different fees or costs depending on the venues used in order to ensure that costs are transparent and fully disclosed to you, the client. For some markets, you may be liable to pay commission charges for opening and closing trades however these costs will be disclosed to you where required.

The Firm will agree on a charging structure with you at the outset and the charging structure will not vary depending on the financial instrument being traded however you should be aware that the spread can differ and that this is beyond our control. All implicit and explicit costs will be disclosed to you.

6.1 Payment for Order Flow

The Firm does not receive ‘Payment for Order Flow’, meaning that we do not receive commission or fees for arranging transactions with market makers or liquidity providers, thereby ensuring that there is no conflict created by fees in our execution arrangements.

7 Conflicts of Interest

The Firm recognises that conflicts may exist between the interests of the Firm and its clients including that the Firm may use an intra-group liquidity provider. The platform on which orders are transmitted will, though, display the best available prices from its selected liquidity providers, thereby reducing the scope for conflicts.

The Firm will take steps to manage, mitigate and avoid potential and actual conflicts and internal systems are in place to ensure that otherwise comparable client orders are carried out sequentially and promptly unless the characteristics of the order or prevailing market conditions make this impractical or it is not in the best interests of the client.

8 Monitoring and Review

The Firm will monitor the effectiveness of its order execution arrangements and order execution policy in order to identify and, where appropriate, incorporate any amendments to procedures.

Using a risk-based approach, the Firm will assess, on a regular basis, whether the execution venues included in the order execution policy provide for the best possible result for its clients or whether the Firm needs to make changes to its execution arrangements. The Firm will summarise and make public on an annual basis, for each class of financial instrument in this Policy, the top five execution venues in terms of trading volumes for the preceding year and information on the quality of the execution obtained. Additionally, the Firm will publish quarterly reports on the quality of execution of transactions about price, costs, speed and likelihood of execution for individual financial instruments. The following reports will be found on the Firm’s website.

The Firm will review its order execution arrangements and order execution policy at least annually or whenever a material change occurs, that affects its ability to continue to obtain the best possible result for the execution of client orders on a consistent basis using the venues included in its order execution policy.

The Firm will notify clients of any material changes to its order execution arrangements or order execution policy as described above by posting the information on the Firm’s website.

Should a client require any further information and/or have any questions about this policy, they should direct their request and/or questions to [email protected]

9 No Fiduciary Relationship

The Firm’s commitment to providing “best execution” does not mean that it owes a client any fiduciary responsibilities over and above the specific regulatory obligations placed upon it or as may be otherwise contracted between the Firm and its clients.

Clients remain responsible for their own investment decisions and the Firm will not be responsible for any market trading loss a client suffers because of those decisions.

Annex I – Execution Venues