Order Execution Policy

FxPro Financial Services Ltd.

Order Execution Policy

CONTENTS
SCOPE OF THE POLICY ................................................................................................................................... 4
EXPRESS CONSENT ........................................................................................................................................ 4
TRADE EXECUTION MODEL ........................................................................................................................... 4
ORDER TYPES ................................................................................................................................................ 5
Instant Execution Orders .......................................................................................................................... 5
Market Execution Orders.......................................................................................................................... 6
Pending Orders ......................................................................................................................................... 7
Buy Limit ............................................................................................................................................... 7
Sell Limit ............................................................................................................................................... 7
Buy Stop ............................................................................................................................................... 7
Sell Stop ................................................................................................................................................ 7
Stop-Limit order ................................................................................................................................... 7
Stop Loss............................................................................................................................................... 8
Take Profit ............................................................................................................................................ 8
Good till Date (‘GTD’) ............................................................................................................................... 8
Good till Cancel ......................................................................................................................................... 8

Pending Order Modifications/ Cancellations ........................................................................................... 9
MetaTrader 4 and MetaTrader ............................................................................................................ 9
cTrader and FxPro Markets .................................................................................................................. 9
MARGIN AND LEVERAGE............................................................................................................................. 11
MetaTrader 4 (Instant and Market Execution)....................................................................................... 11
MetaTrader 5 .......................................................................................................................................... 11
cTrader and FxPro Markets .................................................................................................................... 11
BEST EXECUTION ......................................................................................................................................... 12
Prices ...................................................................................................................................................... 12
Size, Speed and Likelihood of Execution ................................................................................................ 14
Cost ......................................................................................................................................................... 16
Commission ........................................................................................................................................ 16
Mark-up .............................................................................................................................................. 16
Financing/ Overnight fee .................................................................................................................... 16
Currency Conversion .............................................................................................................................. 17
Likelihood of Settlement ........................................................................................................................ 17
EXECUTION VENUES.................................................................................................................................... 17
INSTRUCTIONS ............................................................................................................................................ 18
REFUSAL TO EXECUTE AND TERMINATION OF THE AGREEMENT .............................................................. 19

FxPro Financial Services Ltd. │Order Execution Policy

Page 2 of 26

CORPORATE ACTIONS ................................................................................................................................. 20
Long Positions ......................................................................................................................................... 21
Short Positions ........................................................................................................................................ 21
Stock Splits, Rights Issues and other Corporate Actions ........................................................................ 21
Fractional Share Adjustments ................................................................................................................ 21
Delisting .................................................................................................................................................. 21
GENERAL MATTERS ..................................................................................................................................... 22
MONITORING AND REVIEW ........................................................................................................................ 22
SCHEDULE A: GLOSSARY ............................................................................................................................. 23
SCHEDULE B: ORDER EXECUTION POLICY SUMMARY ................................................................................ 24

FxPro Financial Services Ltd. │Order Execution Policy

Page 3 of 26

1.

SCOPE OF THE POLICY

1.1

FxPro Financial Services Ltd. (referred to as ‘FxPro’, the ‘Firm’, ‘us’, ‘we’ and ‘our’) is required
to take all reasonable steps to obtain the best possible result (or ‘best execution’) for its Clients
either when receiving and transmitting orders for execution or executing Client orders. This
‘Order Execution Policy’ (the ‘Policy’) summarises the process by which our trading platforms
execute the Client (referred to as the ‘Client’, ‘you’, ‘your’ and ‘yourself’) orders.

1.2

You understand that it is up to the Firm’s discretion to decide which types of CFDs to make
available on its trading platforms; the Policy will apply accordingly.

1.3

For your convenience, an ‘Order Execution Policy’ Summary is available in Schedule B of the
Policy.

1.4

The Policy is subject to our ‘Client Agreement’ or any other agreement which governs, from
time to time, the relationship between the Client and the Firm.

1.5

For any capitalised term, which has not been defined in the Policy, please refer to Schedule A
(‘Glossary’) of the ‘Client Agreement’.

2.

EXPRESS CONSENT

2.1

By opening an Account with FxPro and accepting the ‘Client Agreement’, you provide your
express consent that all orders will be executed on a non-regulated market since the Firm is the
sole execution venue and the only principal to the transactions.

2.2

When opening an Account with us you consent to your orders being executed in accordance
with the Policy in force, from time to time.

2.3

There are instances where a Client may request that certain orders be executed in accordance
with specific instructions; to the extent that we are able to accommodate such request, we will
endeavour to do so. If there are additional charges, the Client will be charged accordingly.

3.

TRADE EXECUTION MODEL

3.1

FxPro places reliance on recognised external liquidity/ price providers when deriving its prices.
FxPro developed internally its price aggregation engine, which allows us to discover the best

bid/ask prices and provide continuous and reliable pricing to our Clients throughout our trading
platforms. FxPro applies symmetrical and/ consistent mark-ups to raw spreads (where

FxPro Financial Services Ltd. │Order Execution Policy

Page 4 of 26

applicable) to ensure our average spreads are highly competitive within the marketplace.
During liquid trading hours (for example, the EU/US trading session) our spreads are lower to
our average daily spread displayed on our Website. Continuous (in milliseconds) price
presentation of the flow of the bid/ask prices in addition to high liquidity compliments our
prices ensuring our Clients’ trades are executed at the best available prices. Notwithstanding
instances referred to in the Policy, the Firm’s fill ratio of our Client orders is close to 100%.
Under standard market conditions it typically takes 50-60ms, from the moment a Client’s order
is first registered in our system, to when execution is confirmed. By way of example, as at 31st
December 2015, 99% + of orders were executed within 50ms. Clients situated away from our
servers’ location or with poor internet connection will experience a delay of 100-300ms
reaching our servers from, which in effect might result in clients receiving a requote (if instant
execution) or slippage (if market execution) if market moved away from the clients requested
price. Execution statistics (including slippage and re-quote ratios) demonstrate symmetricity.

4.

ORDER TYPES

4.1

The Client may send instructions to the Firm for:
(i)
an instant execution order *
(ii)
market execution order **
(iii)
a pending order**.
* Available on MetaTrader 4 only.
** Available on MetaTrader 4, MetaTrader 5, cTrader and FxPro Markets.

Instant Execution Orders
4.2

Instant order is an order to either buy or sell at the ask price or bid price (respectively) as it

appears in the trading platforms at the time the Client presents the order for execution.
Example:
Client X requests to buy 60 Lots EURUSD (i.e. 6 million Euro) at 1.0560. The current prices are:
Bid price
1.0559

Ask price
1.0560

FxPro will execute the requested volume of 60 Lots, in its entirety, at the requested price of
1.0560.
NOTE: if at the time of receiving the order in our system, the market price changed then a
requote would be given to the Client; the Client may either accept or reject the requote.

FxPro Financial Services Ltd. │Order Execution Policy

Page 5 of 26

4.3

It should be noted that a stop loss and/or take profit may be attached to an instant execution
order.

4.4

MetaTrader 4 (Instant Execution) order is both size specific and price specific.

Market Execution Orders
4.5

Market order is the intention to either buy or sell at the current market price, subject to the
liquidity available. In the event there is not enough liquidity at the top of the book to fill a
Client’s market order, the system will automatically aggregate the volume received from third
party liquidity/ price provider(s) and execute the market order at the ‘Volume-Weighted
Average Price’ (‘VWAP’), subject to the liquidity available at the time of the execution.
Example:
Client X requests to buy 60 Lots EURUSD (i.e. 6 million Euro). The available liquidity at the time
is:
Quantity available at Bid Bid price
Ask price

Quantity available at Ask
price
price
1,000,000
1.05590
1.05600
1,000,000
500,000
1.05580
1.05610
2,000,000
3,000,000
1.05570
1.05620
3,000,000
FxPro will execute Clients order as follows:
• Buy 10 Lots (i.e. 1,000,000 Euro) at 1.05600,
• Buy 20 Lots (i.e. 2,000,000 Euro) at 1.05610, and
• Buy 30 Lots (i.e. 3,000,000 Euro) at 1.05620.
VWAP for the 60 Lots EURUSD (i.e. 6 million Euro) will be 1.056133.

NOTE: if there had not been enough liquidity available to fill the order in its entirety, the order
would have been partially filled.

4.6

Market execution orders are size specific but not price specific.

4.7

The Client understands that there are instances where we might not execute an order as per
your instructions. For example, we may treat an instant order as a market order executed at
VWAP at times of high volatility, or low liquidity or when we receive multiple trade requests for
the same symbol, direction and price range or request from the same signal provider or same
EA via multiple Accounts or similar.

FxPro Financial Services Ltd. │Order Execution Policy

Page 6 of 26

Pending Orders
4.8

A pending order is either a buy stop, or sell stop, or buy limit, sell limit order or a stop-limit
order*. It should be noted that stop loss and take profit instructions are a type of pending order
and are treated as described below.
*Not available on MetaTrader 4.

4.8.1

4.8.2

4.8.3

4.8.4

4.9

Buy Limit
Buy limit is an order to buy a CFD at a specified price lower than the current market price. A
buy limit order will be triggered when the market reaches or passes the specified price, namely
the limit price and executed at the limit price or better.

Sell Limit
Sell limit is an order to sell a CFD at a specified price higher than the current market price. A sell
limit order will be triggered when the market reaches or passes the specified price, namely the
limit price and executed at the limit price or better.

Buy Stop
Buy stop is an order to buy a CFD; the price is set above the current market price and is triggered
when the market price reaches or passes the specified price, namely the stop price. A buy stop
order is then executed as a market order i.e. at the declared, better or worse price which means
that the set buy stop price may not necessarily be the requested price of the order.

Sell Stop
Sell stop is an order to sell a CFD; the price is set lower than the current market price and is
triggered when the market price reaches or passes the specified price, namely the stop price.
A sell stop order is then executed as a market order i.e. at the declared, better or worse price,
which means that the set sell stop price may not necessarily be the requested price of the order.

Stop-Limit order
Stop-limit order is an order that combines the features of stop order with those of a limit order.
A stop-limit order will be triggered at a specified price (or better) after a given stop price has
been reached or passed. Once the stop price is reached, the stop-limit order becomes a limit
order to buy (or sell) at the limit price or better.

FxPro Financial Services Ltd. │Order Execution Policy

Page 7 of 26

4.10

4.11

4.12

Stop Loss
Stop loss is an instruction that is attached to either an instant execution/ market execution
order or a pending order and may be used to minimise losses. Once the market reaches or
passes the stop loss price the order is triggered and treated as a market order i.e. filled at the
declared, better or worse price, which means that the set sell stop price may not necessarily be
the close price of the order. If the stop loss is not triggered it shall remain in the system until a
later date.

Take Profit
Take profit is an instruction that may be attached to an already open position to close a position
at a specified price (namely, the take profit price) to secure profits. Once the market reaches
the take profit price the order is triggered and treated as a limit order; filled at declared or
better price. If the take profit is not triggered it shall remain in the system until a later date or
amended/ modified by the Client.
GENERAL NOTE:
In terms of CFDs traded through MetaTrader 4 and MetaTrader 5, pending orders as well as
stop loss and take profit should be placed a minimum number of pips away from the current
market price; for further information, please check our Website/ trading platforms.

Good till Date (‘GTD’)
4.13

Good till Date (‘GTD’) is a time setting that applies to pending orders traded through
MetaTrader 4 and MetaTrader 5. The Client may choose a specific date in the future until which
the order will remain ‘live’ and pending execution; if the order is not triggered during this predetermined timeframe it shall be deleted from the system.
Please note that this functionality is available on MetaTrader 5 as ‘Good till Today’ and ‘Good
till Specify’.

Good till Cancel
4.14

Good till Cancel (‘GTC’) (= Expiry) is an execution setting that the Client may apply to pending
orders. The order may remain ‘live’ and pending execution until such time as the order is
triggered and treated as a market order or cancelled by the Client.
Please note that GTC may become redundant in cases where a CFD on futures reaches its
maturity/ expiry date.

FxPro Financial Services Ltd. │Order Execution Policy

Page 8 of 26

Pending Order Modifications/ Cancellations

4.15

4.16

MetaTrader 4 and MetaTrader 5
The Client may modify/ cancel a pending order if the market did not reach the level of the price
specified by the Client.
cTrader and FxPro Markets
With regards to cTrader and FxPro Markets, a pending order will be cancelled in the event any
of the following occurs:
(a) if a Client manually cancels an order prior to the market reaching the price level
specified by the client; or
(b) if the requested price is more than 50,000 pips from the market price; or
(c) if a Client places an expiration time frame and this is reached; or
(d) after 2000 unsuccessful attempts to execute the order.

4.17

The Client accepts that once a pending order is triggered, the Client may not modify such order.

4.18

It should be noted that the status of an order is available, at all times, through the trading
platforms. If the Client is unable to access the trading platforms he/she can be notified of the
status of an order by contacting the Dealing Department by telephone on +357 25 969 238/9.

4.19

A pending order that is not triggered, at the close of a specific trading session, will remain valid
and will be executed accordingly in the future unless the Client deletes the order before it is
triggered.

4.20

The Client accepts that pending orders are triggered at the declared price on the first current
price touch but filled as per the specific order type. Limit orders may be filled at declared or
better price whereas stop orders may be filled at declared, better or worse price.

4.21

The Client accepts that under certain trading conditions (including but not limited to situations
of high market volatility or illiquidity and market gaps) it may be impossible for FxPro to execute
pending orders at the Declared Price; under such conditions, the Firm reserves the right to
execute the order or modify the opening and/or closing price to provide the next best price. In
instances where pending orders with stop loss/ take profit attached and the first available price
triggers both the opening price and the stop loss/ take profit simultaneously will result in stop
loss/ take profit being removed and position being opened at market price and the Client will
have to manage the position accordingly.

Examples:

FxPro Financial Services Ltd. │Order Execution Policy

Page 9 of 26

•

Buy Stop with Take Profit
o If both buy stop and take profit attached, are triggered at the same time/price,
FxPro will execute the entry order at the available market price and remove the
take profit if the trigger bid price is higher or equal to take profit level.
o Example:
 EURUSD now trades at 1.06775/1.06790,
 Buy stop order on EURUSD @ 1.06800 with take profit at 1.06820,
 and next tick/price jumps to 1.06830/1.06845
 Buy stop order will be filled at 1.06845 and take profit will be removed (client will
need to reapply a take profit)

•

Sell Stop with Take Profit
o If both sell stop and take profit attached, are triggered at the same time/price,
FxPro will execute the entry order at the available market price and remove the
take profit if the trigger ask price is lower or equal to the take profit level.
o Example:
 EURUSD now trades at 1.06775/1.06790,
 Sell stop order on EURUSD @ 1.06750 with a take profit at 1.06730,
 and next tick/price drops to 1.06700/1.06715
 Sell stop order will be filled at 1.06700 and take profit will be removed (client will
need to reapply a take profit).
•

Buy Limit with Stop Loss
o If both buy limit and stop loss attached are triggered at the same time/price;
FxPro will execute the entry order at the available market price and remove the
stop loss if the trigger bid price is lower or equal to stop loss level.
o Example,
 EURUSD now trades at 1.06755/1.06770,
 Buy limit order on EURUSD @ 1.06750 with stop loss at 1.06720,
 and next tick/price drops to 1.06700/1.06715
 buy limit order will be filled at 1.06715 and stop loss will be removed (client will need
to reapply a stop loss).
•

Sell Limit with Stop Loss
o If both sell limit and stop loss attached are triggered at the same time/price;
FxPro will execute the entry order at the available market price and remove the
stop loss if the trigger ask price is higher or equal to the stop loss level.
o Example,
 EURUSD now trades at 1.06755/1.06770,
 Sell limit order on EURUSD @ 1.06780 with SL at 1.06800,
 and next tick/price drops to 1.06820/1.06835

FxPro Financial Services Ltd. │Order Execution Policy

Page 10 of 26

 sell limit order will be filled at 1.06820 and stop loss will be removed (client will need
to reapply a stop loss).
5.

MARGIN AND LEVERAGE

5.1

The Client understands that during the account opening process the default leverage is set at
1:50; the Client reserves the right to request a higher leverage but this will be at the discretion
of the Firm and subject to the appropriateness assessment of the Client.

5.2

For margin calculation purposes, the leverage level used will be the lower of: (i) the Account or
(ii) symbol traded. This logic applies on all our trading platforms.

5.3

Any changes made to your leverage on an Account that is already traded can immediately affect
your open positions and may result in a stop-out.
MetaTrader 4 (Instant and Market Execution)

5.4

The Firm, at Margin Level of less than 25% (twenty-five), has the discretion to begin closing
positions starting from most the unprofitable one. The Firm, at Margin Level of less than 20%
(twenty), is automatically closing positions at market price.

MetaTrader 5
5.5

The Firm, at Margin Level of less than 40% (forty), has the discretion to begin closing positions
starting from the one that requires greater margin. The Firm, at Margin Level of less than 30%
(thirty), is automatically closing positions at market price.

cTrader and FxPro Markets
5.6

The Firm, at Margin Level of less than 40% (forty), has the discretion to begin closing positions
using the ‘Smart Stop-out’. The Firm, at Margin Level of less than 30% (thirty), is automatically
closing positions at market price.

5.7

Smart Stop Out: if Margin Level, falls below Smart Stop Out Level then trades will start being
closed until Margin Level reaches above Smart Stop Out Level. The logic of Smart Stop Out will
only close what is absolutely necessary from the largest trade in order to safely restore Margin
Level and protect the trade itself, the position entry point and the trading account for as long
as possible.

5.8

IMPORTANT:

FxPro Financial Services Ltd. │Order Execution Policy

Page 11 of 26

1. FxPro reserves the right to amend, at any time, the specifications of CFDs and/or the
‘Leverage Policy’, available on our Website, in order to respond to a number of
situations including but not limited to specific market conditions. Even though the
Client is liable for ensuring that he/she remains informed, at all times, regarding the
latest specifications, FxPro will -where reasonably possible- notify the Client in writing
of the amendment(s).
2. Specific leverage restrictions may apply on certain CFDs and/or platforms and/or
jurisdictions as indicated on our Website. The Firm may, in its sole discretion, amend the
margin requirements, on a case by case basis, on all or any transaction(s) of the Client,
by providing the Client-where reasonable- with notice.
6.

BEST EXECUTION

6.1

The Firm acts as principal and not as agent on the Client’s behalf; therefore, the Firm is the sole
execution venue for the execution of the Client’s orders for CFDs provided by the Firm. The
Firm shall take all reasonable steps to obtain the best possible result for its Clients taking into
account the following factors when executing Client orders using the Firm’s quoted prices.

6.2

The Firm considers various factors mentioned in the Policy (including the price, order size,
speed and likelihood of execution, cost, currency conversion, market impact as well as
likelihood of settlement) when executing Client orders and their respective importance. It is the
Firm’s policy to maintain such internal procedures and principles in order to determine the
importance of these factors and to act in the best interest of its Clients and provide them with
the best possible result (or ‘best execution’) when dealing with them.

Prices
This section provides you with information about prices, which are given the highest
importance in relation to the operation of our Platform.
6.3

The Firm’s price for a given CFD is derived through reference to the price of the relevant
underlying financial instrument, which the Firm obtains from third party liquidity/ price
providers so that at any point in time the prices are accurate and competitive. The Firm will not
quote any price outside the Firm’s operations time (see execution venue below) therefore no
orders can be placed by the Client during that time.

6.4

FxPro receives price feeds from some of the world’s leading liquidity/ price providers. Our prices
are generated electronically from our systems by aggregating market data from a variety of
liquidity/ price providers, consequently, the prices you may see on our trading platforms might

FxPro Financial Services Ltd. │Order Execution Policy

Page 12 of 26

not be the same as the prices you see on other platform(s)/ system(s) or in the market. Having
multiple liquidity providers is important especially during abnormal market conditions such as
times of extreme volatility the Firm is still able to provide Clients with competitive prices.
6.5

FxPro will, at all times, subject to events outside the control of the Firm, transmit bid and ask
prices through the trading platforms that are executable according to the Client’s instructions
and the Policy.

6.6

For cTrader and MetaTrader 5, prices are obtained directly from the liquidity/ price providers
through an electronic system. In conjunction with the price, the Firm streams available liquidity
at different price levels, (or ‘market depth’), which is used by the company to calculate the
VWAP price in the case that there is not enough liquidity at the top of the book to fill a market
order.

6.7

FxPro shall determine, at its discretion, the prices that are executable and appear through the
trading platforms. The Client accepts that he/she shall disregard any bid and/or ask prices
quoted by a financial product provider other than FxPro.

6.8

The Client accepts that FxPro is solely responsible for determining the validity of the prices at
any given time; therefore, the Firm reserves the right to send the Client a requote (applicable
to instant execution orders only), including but not limited to situations of high market
volatility, if the company deems that to be necessary. Under the above mentioned
circumstances, the Client may either accept or reject the requote.

6.9

We try to generate prices continuously but there are instances where this is not possible; for
example, instances of poor telecommunication/ internet connectivity, system errors and
outages severe volatility and/or illiquidity and/or other factors. There are also other factors
that may affect the price of the underlying instruments/ products from which the Firm derives its prices.
The above may cause prices to change between the time an order is placed and the time the order has
been received by the Firm.

6.10

In general, if such a change occurs, the order will be executed depending on the trading
platform and account type specifications. There are other instances where the price at which a
trade is executed may be less favourable than the price that was quoted on our trading platform
at the time the order was placed for reasons including but not limited to market movements.
For further details on this, please see below.

6.11

Requoting is the practice of providing a new quote (i.e. the current available price) to the Client
after an instant order has been submitted; the Client must agree to this price before the order
is executed. FxPro will requote instant orders if the requested price originally specified by the
Client is no longer available. The new quote provided to the Client is the price available for
execution at the time the order has been received from the Client and may differ significantly

FxPro Financial Services Ltd. │Order Execution Policy

Page 13 of 26

from the Client’s requested price. FxPro does not requote pending orders. The Client will not be
receiving a requote where certain orders will be executed as market orders (i.e. executed at VWAP)
instead of being executed as instant orders.

6.12

It should be noted that the price at which a trade is executed may vary significantly from the
original requested price during abnormal market conditions. This may occur, for example, at
the following cases:
(a) during the market opening;
(b) during news times;
(c) during volatile markets where prices may move significantly up or down and away from
declared price;
(d) where there is rapid price movement, 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;
(e) if there is insufficient liquidity for the execution of the specific volume at the declared price.

6.13

At the time that an order is received for execution, the specific price requested by 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. If the execution price is better than the price requested by
the Client this is referred to as positive slippage. In contrast, if the execution 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 market practice and a regular feature when trading CFDs under conditions
including but not limited to illiquidity and volatility due to news announcements, economic
events and market openings/ closings as well as order size. The FxPro automated execution
software does not operate based on any individual parameters related to the execution of
orders through any specific Client accounts.

6.14

The Firm strives to provide the best possible price to its Clients irrespective of the order type,
and makes every effort and necessary arrangements to do so.

Size, Speed and Likelihood of Execution
This section provides you with information about the size, speed and likelihood of execution,
all of which are given very high importance.
6.15

The Client should bear in mind that in terms of volume, financial instruments traded through
the trading platforms, are measured in lots and the minimum volume of a trade is available on
our Website. There is no maximum size of an order where the Client can place with the Firm,
with the exception of the Fixed Spread Account (where a maximum of 10 lots per trade applies
only for CFDs with a fixed spread).

FxPro Financial Services Ltd. │Order Execution Policy

Page 14 of 26

6.16

The Firm reserves the right to decline an order as explained in the Client Agreement, this Policy
or entered contrary to the policies and procedures in place by the Firm. Notwithstanding the
above, the Firm makes every effort to fill the order of the Client irrespective of the volume at a
best available price, as the market liquidity allows at the time of execution.

6.17

FxPro reserves the right to place a cap on the number of trades and/or limit on the total net
position value per profile for a specific instrument. In such an event, the Firm will undertake all
possible efforts to notify Clients prior to such an event.

6.18

In addition, FxPro reserves the right to cumulatively execute instant orders, having the same
symbol, direction and price, at VWAP without notifying Clients in advance. In such instances,
the Client may also experience delay and slippage.

6.19

Under standard market conditions it typically takes 50-60ms, from the moment a Client’s order
is first registered in our system, to when execution is confirmed. Clients situated away from our
servers’ location or with poor internet connection will experience a delay of 100-300ms
reaching our servers from, which in effect might result in clients receiving a requote (if instant
execution) or slippage (if market execution) if market moved away from the clients requested
price.

6.20

When low levels of liquidity are experienced this may result in FxPro receiving infrequent price
updates from its liquidity/ price providers. Under such circumstances, the last bid and ask prices
quoted on the platform are deemed off-market prices (at the discretion of the Firm). It should
be noted that when you attempt to open or close an order at an off-market (or stale) price,
your orders may be executed with a delay or may be rejected and the platform will display an
‘off market’ message confirming such an instance.

6.21

FxPro executes orders during trading hours only, as indicated on our Website.

6.22

Placing an order does not guarantee that such an order will be executed or that it will be
executed in accordance with the parameters set out by the Client.

6.23

The Firm relies on third party liquidity/ price providers for prices and available volume,
therefore execution of the Client’s orders will depend on the pricing and available liquidity of
the providers. Although the Firm executes all orders placed by the Clients, it reserves the right
to decline an order of any type.

6.24

The Firm executes most orders automatically, with minimal manual intervention. In addition to
the provisions referred to in the ’Events Outside our Control’ section of the 'Client Agreement’,
FxPro may execute an order manually and/or at VWAP, without notifying Clients in advance;
this may occur in instances where, for example, increased market volatility is experienced, at

FxPro Financial Services Ltd. │Order Execution Policy

Page 15 of 26

times of illiquidity and infrequent price updates, the order size is significant* in size, at times of
illiquidity and infrequent price updates as well as times where the system identifies a Client/
trading activity as abusive and/or trades from multiple Client profiles bearing the same
characteristics (i.e. same software, symbol, time and price requested).
* Note that the ‘significance’ is determined at the discretion of the Firm.
6.25

It is possible that a Client order is partially filled; this is the practice of executing an order in
parts if there is not enough liquidity in the market at the time in order to fill-in the full order at
a specific/ requested price. Partial fills may be executed at different prices.

6.26

The Firm strives to provide the best possible price to its Clients, and makes every effort and
necessary arrangements to do so.

Cost
This section provides you with information about the cost of execution which is given high
importance.
6.27

6.28

6.29

6.30

For opening a position in some types of financial instruments the Client may be required to pay
commission or other fees; these are described in detail on our Website. For all type of CFDs
offered by the Firm, the commission (if applicable) and financing/ overnight fees are not
incorporated into the Firm’s quoted prices and are instead charged explicitly to the Client
Account(s).

Commission
The Client shall be charged commission, as a fixed amount per USD million traded, when trading
CFDs on forex and metals through cTrader; further information is available on our Website.

Mark-up
The prices on which Clients are trading include a mark-up; this means that the spreads on offer
by the Firm comprise of (i) the raw spreads received from liquidity/ price provider(s) and (ii) any
mark-up, where applicable). Please see the ‘Order Execution Policy Summary’ (Schedule B of
the Policy) for further details.

Financing/ Overnight fee
In the case of financing/ overnight fees, the value of opened positions in some types of financial
instruments is increased or reduced by a daily financing fee ‘swap’ throughout the life of the

FxPro Financial Services Ltd. │Order Execution Policy

Page 16 of 26

trade. The financing fees are based on prevailing market interest rates; details of daily
financing/ overnight fees applied, are available on our Website.

Currency Conversion
This section provides you with information about the currency conversion which is given the
appropriate importance.
6.31

Any currency conversion calculations are provided by the Firm to the Client in the currency in
which the trading account is denominated and the currency of the relevant CFD, using the cross
spot rate.
Example:
Client X has an Account that is denominate in EUR currency. Client X trades GBPJPY (Base
currency being the GBP with Variable currency being the JPY). In this instance, the Firm’s trading
platforms will always display the trade Profit & Loss in EUR, using the EURJPY ‘live’ rate from
our trading platforms.

Likelihood of Settlement
6.32

All the financial instruments on offer by the Firm do not involve any physical delivery of the
underlying asset or assets. Therefore, no settlement occurs.

7.

EXECUTION VENUES

7.1

FxPro is, without exception, the execution venue for all orders and acts as principal and not as
agent on the Client’s behalf; contractually the Firm is the sole counterparty to the Client’s trades
and any execution of orders is done in the Firm’s name.

7.2

The Client acknowledges that the orders entered with the Firm are not undertaken on a
regulated exchange; rather, they are undertaken through the Firm’s trading platforms.
Therefore, the Firm may not execute an order, or it may change the opening or closing price of
an order in certain cases including but not limited to instances of a technical failure of the
trading platform. In addition, the Firm may not execute an order at all if such an order is based
on an erroneous and/or off-market price and/or the Client and/or the Client order(s) fall outside
the Firm’s risk limits. The trading conditions are solely established by the counterparty, which
in this case is the Firm. The Client is obliged to close an open position of any given CFD during
the opening hours of the Firm’s trading platform. The Client also has to close any position with
the same counterparty with whom it was originally entered into, i.e. the Firm.

FxPro Financial Services Ltd. │Order Execution Policy

Page 17 of 26

8.

INSTRUCTIONS

8.1

FxPro shall accept instructions that have been transmitted by the Client through the trading
platforms or other means determined in the Policy. If, for any reason, the Client is unable to
access the trading platforms in order to send an instruction for the purposes of trading CFDs
he/she may contact the Dealing Department by telephone on +357 25 969 238/9 to place a
verbal instruction, subject to the restrictions referred to in the ‘Recordings and Monitoring of
Communication’ section of the ‘Client Agreement’.

8.2

It should be noted that the Firm reserves the right to reject such verbal instruction when the
operator of the Dealing Department is not satisfied with the Client’s identify or clarity of
instructions; under such circumstances, FxPro reserves the right to request from the Client to
transmit an instruction through another mean. The Client accepts that at times of excessive
transaction flow there might be delay in connecting over the telephone with an operator of the
Dealing Department, especially when there are important market announcements.

8.3

It should be noted that if you were to provide us with instructions on how to execute your
order(s), complying with those instructions may prevent us from taking the steps set out in the
Policy to obtain the best possible result for the execution of your order(s). Under such
circumstances, our execution in accordance with your instructions will be deemed best execution.

8.4

In the absence of specific instructions from the Client, FxPro will balance the above factors
based on our judgment as well as professional experience, in light of the available market
information and market conditions at the appropriate time, and considering the following
criteria:
8.4.1 characteristics of the client including the categorization of the client as retail or
professional,
8.4.2 characteristics of the client’s order,
8.4.3 characteristics of the financial instrument that is the subject of that order,
8.4.4 characteristics of execution venues where that order can be covered.

8.5

The Client accepts that the Firm bears no responsibility for any instructions that may be
misinterpreted due to a technical or other error.

8.6

The client accepts that unless he/she informs in writing FxPro regarding the termination of the
Authorised Representative (as defined in the ‘Glossary’ section of the Client Agreement), the
Firm shall continue accepting instructions from the latter; such instructions shall be (a) valid
and (b) fully commit the Client. In case the Client needs to terminate the Authorised
Representative, the former shall provide the Firm with a written notice of at least 2 (two) days.

FxPro Financial Services Ltd. │Order Execution Policy

Page 18 of 26

8.7

The Client accepts that once FxPro receives instruction(s) for trading CFDs such instructions are
final and cannot be cancelled or deleted, except where the Firm expressly agrees to such
cancellation or deletion.

9.

REFUSAL TO EXECUTE AND TERMINATION OF THE AGREEMENT

9.1

In addition to any other provision of the Policy and/or the ‘Client Agreement’, the Client accepts
that FxPro shall have the right, at any time, to refuse at its discretion, the provision of any
investment or ancillary service, including but not limited to the execution of orders, without
providing notice to the Client.

9.2

This section might come in effect in under certain circumstances, including but not limited to
situations when FxPro has reasonable grounds to believe that the execution of a Client’s order
may:
(a) affect the orderly function of the market;
(b) constitutes an abusive exploitation of privileged confidential information;
(c) contributes to the laundering of illegal funds;
(d) affects in any manner the reliability or orderly operation of the trading platforms; and
(e) the Client’s order relates to the purchase of a financial instrument but there is
insufficient free margin in the relevant trading account to cover such purchase and any
applicable charges.

9.3

FxPro reserves the right to refuse the execution of a pending order and/or modify the opening/
closing price of an order if a technical or other issue arises.

9.4

The Client accepts that the Firm may refuse to execute an instruction for trading financial
instruments, if conditions described above, are triggered.

9.5

The Client accepts that FxPro reserves the right to immediately terminate the Client’s access to
the trading platform(s) or Account(s) or refuse or cancel any order of the Client, in the event
the Client voluntarily and/or involuntarily partakes in arbitrage unrelated to market
inefficiencies, including but not limited to, latency arbitrage and swap arbitrage and/or contrary
to good faith; under such circumstances, FxPro may, at its discretion, close any of the Client’s
Account(s) and recover any losses incurred from such practices, in accordance with the terms
of the ‘Client Agreement’, the Policy or FxPro’s policies and procedures.

9.6

In addition, the Client accepts that FxPro reserves the right to immediately terminate the
Client’s access to the trading platforms and/or recover any losses incurred from a Client’s
Account(s) in the event the Firm determines in its sole discretion that the Client voluntarily
and/or involuntarily undertakes to abuse the negative balance protection (the ‘NBP’) offered
by the Firm (or in any way which is contrary to good faith or the terms of the ‘Client Agreement’)

FxPro Financial Services Ltd. │Order Execution Policy

Page 19 of 26

either on an individual Account, or multiple Account(s) or multiple profiles and/or between one
or more Client(s) of the Firm in accordance with the ‘Client Agreement’. For instance, a Client
hedging his/her exposure utilising his/her accounts under the same or different Client profile
would constitute an abuse of the NBP as well as a Client requesting a withdrawal of his/her
Client Money -notwithstanding any of the provisions of the ‘Client Agreement’- when the
symbol he/she is trading is not available for trading at FxPro during that specific timeframe.
Another example would be an instance where a Client transfers fund from his/her Account to
the Vault before opening or while having open positions, in a manner which indicates an
attempt to abuse the NBP policy; it should be noted that this is not an exhaustive list. Where
the Firm has determined, in its sole discretion, that a Client or Client(s) have abused the NBP,
FxPro may take any action it deems fit, including but not limited to transfer any amount(s) from
any Account(s) under any profile, in order to cover the NBP loss.
9.7

The Client accepts that if FxPro were to refuse the execution of a Client’s order, under this
section or this Policy, the obligations of the Client under the ‘Client Agreement’ shall remain
unaffected.

10.

CORPORATE ACTIONS

10.1

Corporate actions mean, any actions taken by an issuer, whose listed securities are associated
with the CFDs traded through our trading platforms, including but not limited to instances of:
(i) stock split, (ii) consolidation, (iii) rights issue, (iv) merger and takeover, (v) dividends and (vi)
earnings report.

10.2

Margin requirements for shares and/or indices, with an upcoming earnings report and/or
corporate and/or other action (collectively, the ‘Corporate actions’), may increase up to no
more than 5 times the normal percentage, 5 days prior to the Corporate Action, and may remain
in effect after the Corporate Event at FxPro’s sole discretion. During the affected period, new
margin requirements will apply for all existing and new trades. FxPro Clients remain fully
responsible for monitoring both the required margin of their Account(s) and free margin prior,
during and post the affected period. As a result of the above, FxPro Clients understand and
accept that this may result in their Account(s) incurring a margin call and/or stop out.

10.3

When a corporate action occurs, the Client accepts that FxPro reserves the right to make
appropriate adjustments to the value and/or the size of a transaction and/or number of any
related transactions; any such adjustment aims in preserving the economic equivalent of the
rights and obligations of both the Client and the Firm immediately prior to a corporate action.
It should be noted that these adjustments are conclusive and binding upon the Client; the Client
will be informed accordingly by the Firm as soon as reasonably practicable.

FxPro Financial Services Ltd. │Order Execution Policy

Page 20 of 26

10.4

When a corporate action occurs, the Client accepts that FxPro shall take reasonable steps to
replicate the market conditions. If FxPro, in its sole discretion, warrants it is unable to fairly
value a corporate action, the Firm shall reserve the right to close a Client’s position.

10.5

Further information regarding ‘Corporate Actions’ can also be found on our Website.

Long Positions
10.6

A Client holding a long position for the applicable symbol and/or spot index, which
encompasses the symbol on the ex- dividend date will receive the applicable dividend in the
form of a cash adjustment, credited to the relevant Account.

Short Positions
10.7

A Client holding a short position for the applicable symbol and/or spot index which
encompasses the symbol on the ex- dividend date will be charged the applicable dividend in
the form of a reverse cash adjustment, debited from the relevant Account’s free equity.

10.8

In the event a Client maintains a short position for the applicable symbol and/or spot index,
which encompasses the symbol on t