GFX ORDER EXECUTION POLICY

Introduction

GoldFX Investment Co, Ltd (referred as “GFX”) is committed to treat our clients fairly by executing orders on terms most favourable to our clients. As such, GFX has implemented this Order Execution Policy (hereinafter referred to as the ‘Policy’) aimed to obtain the best possible result for our clients, taking into account factors listed below.
The Policy is aimed to provide our clients with a general overview on the how trade orders are executed and the various factors that can affect the execution of the financial instruments offered by GFX.

Scope and Application

GFX will always act as principle when executing transactions for the clients. The Policy will apply whenever GFX execute transactions on behalf of professional and retail clients.

GFX will take all reasonable steps to obtain the best possible result for the clients as accordance to the Policy. The Policy takes into account factors such as the size of the order, liquidity of the underlying market, and the priorities of the client with the purpose to provide the best outcome in the interest of the client.

GFX does not however guarantee that execution at our price will be more favourable than one which might have been available elsewhere.

The Policy forms part of our terms of business and is effective from the 1st of June 2015. By agreeing to the terms of our Customer Agreement, clients are also agreeing to the terms of GFX Order Execution Policy.

Best Execution Criteria and Relevant Elements

Price

GFX receive price feeds from some of the world’s leading liquidity providers to ensure our clients receive the best possible price quotes. Trade orders accepted by GFX will be executed at the price requested by the client and at no other price, assuming there are no “slippage” and that the required price is still available.

Costs

Opening a position in some types of Financial Instruments provided by GFX may require the client to pay commission and/or other fees if applicable. These charges are disclosed in Terms of Business.

Liquidity

All orders submitted by the clients to GFX are subjected to size consideration. The minimum size of an order is 10,000 units of base currency. Although there is no maximum size for an order which can be submitted by the client, GFX reserves the right to decline an order if the requested size is larger than GFX is able to put into the underlying market, at the requested price, at that particular point of time. Greater liquidity may be offered to the client by GFX at its own discretion.

Speed and likelihood of execution

GFX will act as the principle for all orders submitted by the client. GFX is committed to offer our client the best possible execution speed and strives to improve within the limitations of information and communication technology. Under all normal circumstances orders will be filled at the requested price within seconds. If the price requested is not available in the market, the order will not be filled. However, the use of any form of unstable or slow internet connection at the client’s end may result in interrupted and/or delayed connectivity to our platforms; as a result, re-quoting may occur from the delayed or interrupted data transmission between the client and GFX.

In certain circumstances due to poor connection speed, abnormal market volatility or in the case of intentional manipulation of our quoted price or other related data, the client’s order may be declined by GFX if the price requested by the client is not representative of the market price received by GFX.

Internet, connectivity delays, and price feed errors sometimes create a situation where the price displayed on the Trading Platform does not accurately reflect the market rates. The concept of latency arbitrage, or taking advantage of these internet delays, cannot exist in an OTC market where the Client is buying or selling directly from the principal. The Company does not permit the practice of arbitrage on the Trading Platform. Transactions that rely on price latency arbitrage opportunities shall be revoked, without prior notice. Please, consult the “Allowed Trading Methods” Paragraph for more information!

Aggregation

The client’s orders may at the discretion of GFX be aggregated/split with GFX own orders, orders of any of GFX associates and/or other clients. Orders will only be aggregated or split where GFX reasonably believes it to be unlikely that the aggregation or split generally will be unfavourable to any client. However, such aggregation may in abnormal circumstances work to the client’s disadvantage.

Allowed Trading Methods (EA)

Generally speaking, GFX allows all types of trading methods and styles. The Company reserves the right, however, to close, suspend or recoup any closed profit and loss from an account it deems is engaging in unethical or questionable trading styles including, but not limited to, latency arbitrage, the act of “flooding” of our servers with an excessive amount of pending orders and / or pending order modification requests, excessive logins, or the use of certain automated trading systems or Expert Advisors, without notice. GFX will usually (but is not obligated to always) attempt to initially express its concern to Customer or associated parties via email or telephone in the form of a formal warning. If the Customer or associated party does not modify trading style within a reasonable amount of time following the warning, GFX reserves the right to liquidate all or some open positions, close, suspend or recoup any closed profit or loss from account, and return any remaining proceeds to Customer according to Company account closing procedures or any combination thereof.

Slippage

GFX aims to provide clients with the best execution available and to fill our client’s orders at the requested price. However, there are times when, due to abnormal increase in market volatility, orders may be subject to slippage. GFX hereby advise our clients that slippage is a normal market practice in the industry and a common feature of the foreign exchange market under conditions such as lack of liquidity and abnormal volatility due to economic events, news announcements, and market opening. GFX shall not be held liable for losses suffered by the client caused by slippage.

GFX reserve the rights to void any positions opened and was subsequently closed within 1-2 minutes. Any profit, loss, and/or commission fees made through these transactions may be deemed invalid.

Contract Expiration

Energies

The CFDs of Oil and Gas products of GFX do not expire. GFX does not require clients to provide rollover instructions. The underlying assets of the said instruments offered by GFX, however, have an expiration date and/or delivery date. The Company will not automatically close client positions when the underlying asset of the traded instrument is expiring. Instead the Company will rollover the trading instrument from the price feed of the expired underlying forward/future contract to the price feed of the following forward/future contract. Open client positions will be carried forward by the Company as well. GFX reserves the right to decline opening of new positions in the period of rollover from expired underlying asset to following underlying asset.

Indices

The Index trading instruments offered by GFX do have an expiration date. GFX does not require clients to provide rollover instructions. The Company reserves the right to close all client positions at the date of expiry of the traded instrument and where possible to re-open the said positions with the same size and type at the opening of the market on the following day.

INDEX EXPIRY
CAC 40 – France Third Friday of the contract month
DAX 30 – Germany Two days before third Friday in March, June, September, and December
Dow Jones – United States Third Friday in March, June, September, and December
FTSE 100 – United Kingdom Two days before third Friday in March, June, September, and December
Nasdaq 100 – United States Third Friday in March, June, September, and December
Nikkei 225 – Japan Two days before second Friday in March, June, September, and December
S&P 500 – United States Third Friday in March, June, September, and December

Re-quoting

GFX will provide our clients with a secondary quote (Re-quote) in the event that the price specified in the instant order submitted to GFX is not available. The secondary quote provided to our clients is the next best price given by our liquidity providers. The client must agree to accept the secondary quote in order for the re-quote to be executed.

Monitor and Review

GFX will monitor on a regular basis the effectiveness of our order execution arrangements and execution policy to deliver the most favourable result to our clients and to identify and correct any problem. GFX reserves the right to correct any deficiencies in the policy and to make improvement to its execution arrangements wherever deemed necessary by GFX

Pending Orders

GFX reserve the rights to disable pending order function on major news release without prior notice.