Delivering best execution is fundamental to market integrity and to the delivery of good outcomes for clients, and is something we are fully committed to. Under the rules of the Australian Securities & Investments Commission(“ASIC Rules”) we have a duty to conduct our business with you honestly fairly and professionally and to act in your best interests in dealing with you. More specifically, we are required to provide you with the best possible execution when we deal with you.
Providing best execution under ASFL requires even greater levels of compliance than before and means that when we deal with you we must take all sufficient steps to obtain the best result for you in accordance with our trade and order execution policy. It does not mean that we must obtain the best possible results for you on every single occasion. However, it does require us to verify on an on-going basis that our execution arrangements are working well throughout the different stages of the order execution process.
This document sets out the general terms of our trade and order execution policy and our actual policy is available upon request. Unless separately defined, words and expressions herein shall have the meanings given to them in the General Terms. However this is not part of our Agreement and it does not form part of the contract between us. In the event of any conflict between this document and our actual policy, the terms of that policy will prevail.
We deal with you as principal and not as agent. 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. Any Trades with us are non-transferable. If you create an Open Position with us you must close it with us.
In providing best execution we are obliged to take into account certain execution factors. We must tell you what these are and the relative importance we give to each. If you are a Retail Client, we must determine whether we have provided you with best execution by reference to the total consideration you pay (that is price and costs of execution) though we will also use our judgement and take into account other relevant factors (such as any instructions regarding price) with the aim of providing you with the best result.
The execution factors that we consider and their relative importance are as follows:
Price: The relative importance we attach is high. Our Price for a given Market is calculated by reference to the price of the relevant Underlying Instrument. We obtain this price from third party external reference sources. For some kinds of instruments, e.g. equities, there will be a third party securities exchange from which we will obtain this price. For other kinds of instruments, e.g. foreign exchange, we will collect price data from nominated wholesale market participants.
Our Price will often differ from the price of the Underlying Instrument. For some Markets we add Our Spread to the price of the Underlying Instrument. We may also adjust Our Price for any Market to take into account factors such as liquidity in external markets for the Underlying Instrument, dividend amounts, financing charges in an external market or other relevant factors. You must pay Daily Financing Fees, commission and other charges in addition to Our Price for some Products and Markets – see under “Costs” below.
When trading in the Underlying Instrument is very active and the price of the Underlying Instrument changes quickly, there is no guarantee that every price movement in the Underlying Instrument will result in a change to Our Price. We aim to update Our Price as frequently as we reasonably can but our ability to do so may be limited by technological factors including current hardware, software and data and communications links.
For some Markets we will quote Our Price outside of trading hours for the Underlying Instrument. In such circumstances Our Price is set by us by reference to one or more related alternative Underlying Instruments that are then traded, and may be adjusted in response to supply and demand from our clients. This means that outside normal Exchange Hours we exercise a greater degree of discretion in the setting of Our Price. In addition, Our Spread is generally wider and our maximum Quantity is generally smaller than during normal trading hours for the Underlying Instrument.
We execute all Trades at Our Price and in accordance with the General Terms.
Costs: The relative importance we attach is high. For many Markets, Our Price includes Our Spread and no additional charges or commissions are payable by you. For other Markets you will be required to pay a separate commission charge for each Trade to open or close an Open Position.
We may pass on some charges to you arising from the Underlying Instrument traded. These include borrowing charges where an Underlying Instrument becomes expensive to borrow or stamp duty in some circumstances.
Additionally for many Markets you will be required to pay Daily Financing Fees on the full amount of an Open Position. Generally:
Details of the Daily Financing Fees are set out on our Website.
We will also charge a premium for Guaranteed Stop Loss Orders.
Details of charges we make in respect of particular Markets are set out in the Market Information.
Speed and Likelihood of Execution: The relative importance we attach is high. You may execute Trades either using our Trading Platform or by phoning one of our dealers.
When you execute through the Trading Platform you will receive immediate execution capability: if you see an Our Price on the screen and the Quantity you want to trade is less than our maximum Quantity for that Market, then the Trade will, under almost all circumstances, be executed at the Our Price quoted on the Deal Ticket. We will execute all Trades in accordance with the General Terms.
When executing by phone in a Quantity above our minimum Quantity but below our maximum Quantity, you will be quoted the same Our Price you will receive if you use the Trading Platform. In such circumstances, the dealer will generally confirm execution of your Trade immediately after you indicate that you wish to trade at the quoted Our Price.
Trades will be executed as soon as reasonably possible and in most circumstances almost instantaneously. However, there may be circumstances where Trades cannot be executed almost instantaneously, for example, due to illiquidity in the Underlying Instrument or if there is something unusual about the nature of the Order.
Quantity: The relative importance we attach is high. We normally provide certainty of execution for Trades you wish to place for a Quantity which is greater than our minimum Quantity and lower than our maximum Quantity.
Our minimum and maximum Quantities are set by us for each Market and may vary depending on current market conditions for the Underlying Instrument. Our minimum and maximum Quantities can be found in the Market Information or you may contact Client Management.
Where you wish to execute a Trade whose size exceeds our maximum Quantity, you may be quoted a different Our Price for the requested Quantity. Alternatively, if you agree with one of our dealers by phone, we may work the Order in an external market on your behalf.
The Our Price at which a worked Order is executed will be based upon the average price we receive for our transactions on an External Execution Venue. In such circumstances, our Trade with you may be subject to any applicable charges as described in the Market Information.
Our Trade or Trades with you only become effective after we have executed our hedge transactions on an External Execution Venue and you have confirmed Our Price. Please note if we have agreed to work an Order in the market for you and have started to execute transactions on an External Execution Venue then you cannot cancel the Order. However, we may agree to cancel any unfilled part of the Order.
In most cases when the condition or event specified in your Order occurs it will be executed at or very close to the specified Order Price. However, please note that for all Orders other than Guaranteed Stop Loss Orders, the price you receive at execution is not guaranteed. Our Price may move from a price which is less than your specified Order price to a price which is greater than your specified Order price without a quote at any intermediate price. This will be due to rapid price changes in the Underlying Instrument (called ‘gapping’), for example following a profits warning or the release of financial statistics different from those expected. In such a case, Our Price at the time of execution may be markedly different to the specified Order price.
If, when an Order is executed, the Quantity is less than our maximum Quantity for that particular Market, the Order will be executed at or near the specified Order price.
Note that if you have placed multiple Orders in the same Market, with the same specified Order price and with a Quantity greater than our maximum Quantity, there is no guarantee that they will all be executed at the same price, since each Order must be executed as a different Trade. The execution prices will depend on the liquidity in the external market for the Underlying Instrument and the execution of the first Trade may affect the liquidity available for the execution of the second and any subsequent Trades.
We will execute all Orders in accordance with the General Terms.
You may give us a specific instruction for the execution of a Trade or an Order.
Following your specific instructions may prevent us from taking the steps set out herein to obtain the best possible result for the element of the Trade or Order included in your instructions.
We will comply with our Trade and Order Execution Policy when
We are required to exercise our judgement in obtaining the best outcome for the execution of clients’ Trades and Orders.
We have an overriding obligation as an ASIC licensee to provide financial services efficiently, honestly and fairly. In adhering to these obligations, we maintain internal policies and procedures. We take all reasonable steps to obtain the best possible result when executing client orders or placing orders with (or transmitting orders to) other entities to execute. We consider a range of execution factors in order to deliver best execution including price, costs and speed. We maintain a Code of Conduct which sets out minimum standards for our employees when discharging their duties. Contraventions of the code, suspected contraventions or where have reasonable grounds to believe that the code may be contravened in some way in the future, must be escalated to the Head of Compliance or General Manager.
We will monitor compliance with our policy and maintain records of the data which is used to set Our Price.
We will review our policy at appropriate intervals. As part of that process, we will review:
- the sources of external pricing in Underlying Instruments;
- Our Price in relation to the external pricing of an Underlying Instrument; and
- any fees or charges.
If we make any material changes to our policy, we will notify you by email or by posting such information on our Website or the Trading Platform.
