This document provides a summary of the processes in place at Make Capital to provide ‘Best Execution’ to its clients.
Our Best Execution practice applies to Retail Clients. Best Execution means that we must take all reasonable steps to obtain the best possible result for you when executing an order with you or on your behalf, taking into account various Execution Criteria. Our Order Execution Policy applies when we execute orders on behalf of our clients. However, we always deal as principal, not on behalf of our clients, and act as the relevant execution venue for your orders, which will be executed on an OTC basis.
Subject to any specific instructions that we accept from you, we will take into account a range of factors in deciding where to execute your order. These include price, costs, speed, likelihood of execution and settlement, together with any other consideration relevant to the execution of the order. In determining the relative importance of these factors we will take into account the nature of your order, the characteristics of the financial instruments to which the order relates and the characteristics of the execution venues to which the order can be directed.
We will generally give the highest priority to total consideration of all the factors, representing the price of the relevant financial instruments and the costs related to execution. However, we may at our discretion prioritise other factors, including the impact on market prices of displaying and executing your order, the speed and likelihood of execution, and the availability of price improvement. We may prioritise such other factors where there is insufficient immediately available liquidity on the relevant execution venue(s) to execute your order in full, where you instruct us to work your order over a period of time or by reference to a benchmark calculated over a period of time or where we determine that there are other circumstances such that obtaining the best immediately available price may not be the best possible result for you.
In determining what is the best possible result for you, we will not compare the results that can be achieved for you on the basis of our Order Execution Policy and fees with results that might be achieved for you by another investment firm on the basis of that firm’s execution policy or a different structure of commission or fees, nor will we compare the differences in our own commissions or fees which are attributable to the nature of the services that we provide to you.
In relation to some financial instruments, at the time at which you give us an order there may be no functioning or no open market or exchange on which the reference product is traded. In such cases we set out to determine a fair underlying price based on a number of factors, for example price movements on associated markets and other market influences, including information about our clients’ own orders.
Upon acceptance of a client order and when there is no specific client instruction regarding the execution method, Make Capital will execute the order in accordance with this policy. Where there is a specific instruction from or on behalf of a client Make Capital will, to the extent possible, execute the order in accordance with the specific instruction though trading rules for some markets may prevent Make Capital from following certain parts of the instruction.
To the extent that we execute an order in accordance with a client’s specific instruction we consider that we have satisfied our best execution obligation in respect of those aspects of the order to which the specific instruction relates.
Although we aim to operate in accordance with this Policy, this Policy does not create any legal obligation or duty, fiduciary or otherwise, over and above our duties to you under the Terms of Business or any regulatory obligations.
We will, on a regular basis, monitor the effectiveness of this Order Execution Policy. A periodic review will be made of the execution venues and data sources we rely upon to provide pricing information. Where we identify the need to make any material change to either this Policy or to our Order execution arrangements, we will undertake to notify you prior to such change being implemented.