- The company receives orders from its clients and transmits them to MiFID compliant order execution firms which execute them. As a consequence, under E.U. accepted procedures, the company can justifiably assume that these executing firms are observant and compliant with MiFID regulations. The company attempts to select order executing companies on the basis of ten criteria.
Nearly all orders are entered by the clients themselves via the different electronic order platforms (99,95%). The company operates according to the following rules regarding the reception and transmission of orders:
Each individual order is labeled (numbered) and time-stamped. The complete order entry details are registered step-by-step and are visible to the client in the order platform.
All orders are immediately routed to the point of execution. There is:
- no internal matching of orders,
- no delaying of orders,
- no changing of order sequences, and
- no bundling of orders.
All orders are thus received and transmitted immediately on an individual basis.
Telephone orders are accepted by the support desk. These orders are entered into the system, executed and confirmed while the client waits on the telephone. Telephone orders are entered into the same order platforms and follow the same stages as orders entered by the clients directly. All telephone orders are electronically saved and stored.
Given that the company only serves retail clients and only deals in very liquid financial instruments the orders are of a size which cannot influence the market price. As a consequence the orders do not offer any opportunities for front-running.
For all OTC financial instruments the company executes "fill time" tests and "reasonable price" tests.