AgeFX - BEST INTEREST AND ORDER EXECUTION POLICY
1. Introduction
1.1. This Summary Best Interest and Order Execution Policy (“the Policy”) is provided to you (our
Client or prospective Client) in accordance with the Investment Services and Activities and
Regulated Markets Law of 2017 (L. 87(Ι)/2017), as subsequently amended from time to time (“the
Law”). Pursuant to the Law, AgeFX (“the Company”, “we”) is required to take all sufficient steps
to act in the best interest of its Clients when executing Client Orders and to achieve the best
execution results when executing Client Orders and to comply, in particular, with the principles
set out in the Law when providing investment services.
By opening a Trading Account, you provide your explicit consent to your Orders being executed
outside a Regulated Market (e.g. Licensed European Stock Exchange) or a Multilateral Trading
Facility (e.g. European Financial Trading System).
When opening an Account with us you consent to your orders being executed in accordance with
the Policy in force, from time to time.
The Company executes Client Orders in relation to Contracts for Differences (“CFDs”) across a
range of asset classes: stocks, commodities, indices, currency pairs (FX) and Virtual Currencies
(Cryptocurrencies). CFDs may be referred to as the Financial Instruments in this Policy.
2. Scope
2.1. This Policy applies to both Retail and Professional Clients (as defined in the Company’s
Client Categorisation Policy found on the Company’s website at (Click here). If the Company
classifies a Client as an Eligible Counterparty, this Policy does not apply to such Client.
2.2. This Policy applies when executing Client Orders for the Client for all the types of CFDs
offered by the Company.
3. Best Execution Factors:
3.1. When executing Orders, we will take all sufficient steps to achieve/obtain the best possible
outcome/result (“Best Execution”) for you, taking into account price, costs, speed, likelihood of
execution and settlement, size, nature or any other consideration relevant to the execution of the
Order (“Best Execution Factors”), as follows: (a) Price:
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BID - ASK Spread: For any given CFD, the Company will quote two prices: the higher price (ASK)
at which the Client can buy (go long) that CFD, and the lower price (BID) at which the Client can
sell (go short) that CFD. Collectively, the ASK and BID prices are referred to as the Company’s
prices. The difference between the lower and the higher price of a given CFD is the spread.
Company’s Prices: The Company will quote to Clients the prices provided by the Execution Venue
(see Section 7 below). The Execution Venue calculates and provides their own tradable prices for
a given CFD by reference to the prices of the relevant underlying asset, which the Execution Venue
obtains from third party reputable external reference sources (i.e. price feeders). The Company’s
prices can be found on the Company’s trading platforms. The Company updates its prices as
frequently as the limitations of technology and communications links allow.
The main way in which the Company ensures that the Client receives the best price is to ensure
that the calculation of the bid/ask spread is made with reference and compared to a range of
underlying price providers and data sources. As a result, price quotes are monitored
independently by the Company against other price quotes from other independent market data
providers in order to ensure the accuracy and consistency of the data, to provide a competitive
and fair reflection of the market price to clients and avoid the possibility of arbitrage. Moreover,
the Company reviews systematically its Execution Venue to ensure that relevant and competitive
pricing is offered.
Despite the fact that the Company takes every step the Company considers sufficient to obtain
the best possible result for its Clients, it does not guarantee that when executing an Order its price
will be more favourable than one which might be available elsewhere.
Pending Orders: 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.
If the price reaches an Order set by you such as: Stop Loss, Take Profit, Buy Limit, Buy Stop, Sell
Limit or Sell Stop, then these Orders are automatically 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 Company 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, for a given CFD, is specified in the Client Agreement and/or the
Company’s website at (Click Here).
(b) Costs:
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For opening a position in some types of CFDs the Client may be required to pay commission or
financing fees, the amount of which is disclosed on the Company's website and/or trading
platform.
Commissions: Commissions may be charged either in the form of a percentage of the overall value
of the trade or as fixed amounts. More information on commissions can be found on the
Company’s website and/or the General Fees document.
Financing Fee: In the case of financing fees, the value of opened positions in some types of CFDs
is increased or reduced by a daily financing fee “swap rate” throughout the life of the CFD (i.e.
until the position is closed). Financing fees are based on prevailing market interest rates, which
may vary over time. Details of daily financing fees applied are available on the Company’s trading
platform.
For all types of CFDs that the Company offers, the commission and financing fees are not
incorporated into the Company’s quoted prices and are instead charged explicitly to the Client
account.
Should the Company at any period of time decide not to charge such costs, it shall not be
construed as a waiver of its rights to apply them in the future, with prior notice to the Client as
explained in the Client greement found on the Company’s website. Such notice may be sent
personally to the Client and/or posted on the Company’s website.
(c) Speed of Execution:
The Company does not execute the Client Order in CFDs as a principal to principal against the
Client, i.e. the Company is not the Execution Venue (as defined in Commission Directive
2006/73/EC implementing MiFID) for the execution of the Client’s Order. The Company arranges
for the execution of Client Orders with the Execution Venue. The Company places a significant
importance when executing Client Orders and strives to offer high speed of execution within the
limitations of technology and communications links. For instance, in cases where Clients are using
a wireless connection or a dial up connection or any other communication link that can cause a
poor internet connection then this may cause unstable connectivity with the Company's trading
platform resulting to the Client placing his Orders at a delay and hence the Orders to be executed
at better or worst prevailing price offered by the Company.
(d) Likelihood of Execution:
The Company arranges for the execution of Client Orders with third party(ies) (i.e. Execution
Venue); hence, execution may sometimes be difficult. The likelihood of execution depends on the
availability of prices of the Execution Venue(s). In some case it may not be possible to arrange an
Order for execution, for example but not limited in the following cases: during news times, trading
session start moments, during volatile markets where prices may move significantly up or down
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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, a force majeure event has
occurred.
In the event that the Company is unable to proceed with an Order with regard to price or size or
other reason, the Order will not be executed. In addition, the Company is entitled, at any time
and at its discretion, without giving any notice or explanation to the Client, to decline or refuse to
transmit or arrange for the execution of any Order or Request or Instruction of the Client in
circumstances explained in the Client Agreement found at (Click here).
(e) Likelihood of settlement:
The Company shall proceed to a settlement of all transactions upon execution of such
transactions. The Financial Instruments of CFDs offered by the Company do not involve the
physical delivery of the underlying asset, so they are not settled physically as there would be for
example if the Client had bought shares. All CFDs are cash settled.
(f) Size of Order:
All Orders are placed in monetary values. The Client will be able to place Order(s) as long as he
has enough balance in his trading account. In general, the Company does not take into
consideration the size of your order in accepting, scheduling or prioritizing its execution. However,
order execution is subject to size considerations including a minimum deal size.
The minimum size of an Order is 0.01 lots. The maximum order size varies depending on the
underlying asset and can be found on the trading platform.
If you wish to execute a large size Order (above average order size), in some cases the price may
become less favourable. Without prejudice to the above, the Company reserves the right to
decline an Order in case the size of the Order is large and cannot be filled by the Company or for
any other reason as explained in the Client Agreement found at (Click here).
(g) Market Impact:
Some factors may rapidly affect the price of the underlying instruments/products from which the
Company’s quoted price is derived and may also affect other factors listed herein. The Company
will take all reasonable steps to obtain the best possible result for its Clients.
The Company does not consider the above list exhaustive and the order in which the above factors
are presented shall not be taken as priority factor.
3.2. Types of Order(s) available for CFDs trading:
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The particular characterizing of an Order may affect the execution of the Client’s Order. Please
see below the different types of Orders that a Client can place:
Market Execution Order(s)
A Market Order is an Order to buy or sell a CFD as promptly as possible at the prevailing market
price. Execution of this Order results in opening a trade position. CFDs are bought at ASK price
and sold at BID price. Stop Loss and Take Profit Orders can be attached to a Market Order. Market
Orders are offered for all type of accounts.
Please refer to the trading platform for the type of order available per underlying asset.
Instant Execution Order(s)
An instant Order is an Order to buy or sell at the price as it appears on the platform at the moment
the order is requested. If the price at the market has changed by the time the Company has
received it then a requote will be given to the client with the choice of accepting or rejecting it.
Please refer to the trading platform for the type of order available per underlying asset.
Pending Order(s)
This is an Order to buy or sell a CFD in the future at the best available price once a certain price is
reached. The Company offers the following types of Pending Orders: Buy Limit, Buy Stop, Sell Limit
or Sell Stop Orders to trading accounts for CFDs.
A Pending order is an Order that allows the user to buy or sell a CFD at a pre-defined price in the
future. These Pending Orders are executed once the price reaches the requested level. However,
it is noted that under certain trading conditions it may be impossible to execute these Orders at
the Client's requested price. In this case, the Company has the right to execute the Order at the
first available price. This may occur, for example, at times of rapid price fluctuations of 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 there is lack of liquidity, or this may occur at the
opening of trading sessions.
It is noted that Stop Loss and Take Profit may be attached to a Pending Order. Also, pending orders
are good till cancel. Pending Orders are offered for all type of accounts. Pending Orders are
executed as Market Orders.
Take Profit
Take Profit Order is intended for gaining the profit when the CFD’s price has reached a certain
level. Execution of this Order results in complete closing of the whole position. It is always
connected to an open, market or a pending Order. Under this type of order, the Company’s
trading platform checks long positions with Bid price for meeting of this order provisions (the
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order is always set above the current Bid price), and it does with Ask price for short positions (the
order is always set below the current Ask price).
Stop Loss
Stop Loss Order is used for minimising of losses if the CFD’s price has started to move in an
unprofitable direction. If the CFD’s price reaches this stop loss level, the whole position will be
closed automatically. Such Orders are always connected to an open, market or a pending order.
Under this type of orders, the Company’s trading platform checks long positions with Bid price
for meeting of this order provisions (the order is always set below the current Bid price), and it
does with Ask price for short positions (the order is always set above the current Ask price).
3.3. Execution Practices in CFDs
(a) Slippage
You are warned that Slippage may occur when trading in CFDs. This is the situation when at the
time that an Order is presented for execution, the specific price showed to the Client may not be
available; therefore, the Order will be executed close to or a number of pips away from the
Client’s requested price. So, Slippage is the difference between the expected price of an Order,
and the price the Order is actually executed at. If the execution price is better than the price
requested by the Client, this is referred to as positive slippage. If the executed 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 element when trading in CFDs. Slippage more often occurs during periods of
illiquidity or higher volatility (for example due to news announcements, economic events, during
volatile markets where prices may move significantly up or down and away from declared price,
where there is insufficient liquidity for the execution of the specific volume at the declared price,
during market openings and other factors) making an Order at a specific price impossible to
execute. In other words, your Orders may not be executed at declared prices.
Slippage may appear in all types of accounts we offer. It is noted that Slippage can occur also
during Stop Loss, Take Profit and other types of Orders (see Section 3.2 above). We do not
guarantee the execution of your Orders at the price specified. However, we confirm that your
Order will be executed at the next best available price from the price you have specified under
your Order.
3.4. Different Types of Trading Accounts in CFDs:
The Company offers different types of Trading Account. For example: Basic, Silver, Gold, Platinum,
Diamond account etc. In this respect, the initial minimum deposit, the spreads, swaps, costs, size
commissions, if any, available features etc. may differ according to each type of Trading Account.
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Further information regarding the different type of Trading Accounts offered can be found on the
Company’s website at (Click here).
4. Best Execution Criteria
4.1. When executing client orders, the Company takes into account the following criteria for
determining the relative importance of the Best Execution Factors referred in paragraph 3 above:
a) The characteristics of the Client including the categorization of the client as retail or
professional;
b) The characteristics of the Client Order;
c) The characteristics of the Financial Instruments that are the subject of that Order;
d) The characteristics of the Execution Venue to which that Order is directed;
The Company determines the relative importance it assigns, in accordance with the
abovementioned criteria, to the Best Execution Factors by using its commercial judgment and
experience in light of the information available on the market and taking into account the remarks
included in paragraph 3. The Company assigns the following importance level to the Best
Execution Factors:
FACTOR
IMPORTANCE
REMARKS
LEVEL
Price
High
We give strong emphasis on the quality and level of
the price data that we receive from external sources
(i.e. Execution Venue) in order to provide our Clients
with competitive price quotes.
Costs
High
We take all sufficient steps to keep the costs of your
transactions as low and competitive, to the extent
possible.
Speed of Execution
High
Execution speed and the opportunity for price
improvement are critical to every trader and we
repeatedly monitor this factor to ensure we maintain
our high execution standards
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Likelihood of
High
Even though we reserve the right to decline a Client
Execution
order we aim to execute all Client Orders, to the
extent possible.
Likelihood of
Medium
See relevant description in Best Execution Factors (See
Settlement
Section 3.3).
Size of Order
Medium
See relevant description in Best Execution Factors
(Section 3 for CFDs).
Market Impact
Medium
See relevant description in Best Execution Factors
(Section 3).
Nature of Order
Medium
See relevant description in Best Execution Factors
(Section 3).
Where the Company executes an order on behalf of a Retail Client, the best possible result shall
be determined in terms of the total consideration, representing 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 execution venue fees,
clearing and settlement fees and any other fees paid to third parties involved in the execution of
the Order.
For the purposes of delivering best execution where there is more than one competing Execution
Venue to execute an Order, in order to assess and compare the results for the Client that would
be achieved by executing the Order on each of the execution venue (see Paragraph 7 below) that
is capable of executing that Order, the Company's own commissions and costs for executing the
order on each of the eligible execution venue shall be taken into account in that assessment. The
Company shall not structure or charge commissions in such a way as to discriminate unfairly
between execution venue.
5.. Client’s Specific Instruction
5.1. Whenever there is a specific instruction from or on behalf of a Client (e.g. fills in the required
parts on the Company’s trading platform when placing an Order), relating to the Order or the
specific aspect of the Order the Company shall arrange - to the extent possible - for the execution
of the Client Order strictly in accordance with the specific instruction.
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WARNING: It is noted that any specific instructions from a Client may prevent the Company from
taking the steps that it has designed and implemented in this Policy to obtain the best possible
result for the execution of those Orders in respect of the elements covered by those instructions.
However, it shall be considered that the Company satisfies its obligation to take all sufficient steps
to obtain the best possible result for the Client.
5.2. Trading rules for specific markets or market conditions may prevent the Company from
following certain of the Client’s instructions.
6. Execution on Client Orders
6.1. The Company shall satisfy the following conditions when carrying out Client Orders:
a) ensures that Orders executed on behalf of Clients are promptly and accurately recorded
and allocated;
b) carries out otherwise comparable Client Orders sequentially and promptly unless the
characteristics of the Order or prevailing market conditions make this impracticable, or
the interests of the Client require otherwise; informs a Retail Client about any material
difficulty relevant to the proper carrying out of orders promptly upon becoming aware of
the difficulty.
7. Execution Venues
7.1. Execution Venues are the entities with which the Orders in Financial Instruments are placed
and executed. The Company does not execute Client Orders in Financial Instruments on an
own account basis, as principal to principal against the Client. The Company uses third party
Financial Institution(s) as Execution Venue. The Execution Venue currently used by the
Company is KTRADE (PTY) Limited.
The Company evaluates and selects the Execution Venue based on a number of criteria including
but not limited to the regulatory status of the institution, the ability to deal with large volume of
Orders, the speed of execution, the competitiveness of commission rates and spreads as well as
other business strategic reasons.
Where there is only one possible Execution Venue, best execution is achieved by execution on
that venue. Best execution is a process, which considers various factors, not an outcome. This
means that, when the Company is executing an order for a Client, the Company must execute it
in accordance with its execution policy. The Company does not guarantee that the exact price
requested will be obtained in all circumstances and, in any event, the factors may lead to a
different result in a particular transaction.
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The Execution Venue may be changed at the Company’s discretion by giving at least one (1)
business day prior notice to the Clients on the Website.
7.2. The Client acknowledges that the transactions entered in Financial Instruments with the
Company are not undertaken on a recognized exchange/regulated market, rather they are
undertaken over the counter (OTC) and as such they may expose the Client to greater risks
than regulated exchange transactions/Orders.
8. Client’s Consent
8.1. By entering into a Client Agreement with the Company for the provision of Investment
Services, the Client acknowledges and agrees that the present policy is binding (i.e. this Policy
forms part of the Client Agreement found at (Click here). This Policy is not intended to
constitute the sole basis for the evaluation of the Client’s decision to trade CFDs.
9. Amendment of the Policy and Additional Information
9.1. The Company reserves the right to review and/or amend its Policy and arrangements
whenever it deems this appropriate according to the terms of the Client Agreement. It should
be noted that the Company will not notify Client separately of changes, other than substantial
material changes to the Policy, and Clients should therefore refer from time to time to the
website of the Company at (Click here) for the most up to date version of the Policy.
9.2. Should you require any further information and/or have any questions about this policy
please direct your request and/or questions to mail to: support@agefx.io
AgeFX is licensed and regulated by CySEC, CIF License Number 317/17
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AgeFX is licensed and regulated by CySEC, CIF License Number 317/17
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