Crowd Tech Ltd. (“Crowd Tech” or the “Company”) is a Cypriot Investment Firm incorporated and registered under the laws of the Republic of Cyprus, with registration No. HE 297365. The Company is authorised and regulated by the Cyprus Securities and Exchange Commission (“CySEC”) under the license No. 202/13.
The CySEC’s Law L.87 (I)/2017 regarding the provision of investment services, the exercise of investment activities and the operation of regulated markets 2017, including all its amendments, the Directives issued by CySEC (the “Regulations”) and the Markets in Financial Instruments Directive II (MiFID II) are the regulatory framework that governs Trading in Financial Instruments.
In accordance with the CySEC’s Law L.87/2017 regarding the provision of investment services, the exercise of investment activities and the operation of regulated markets of 2017 ( the “Law”), Cyprus Investment Firms (“CIFs”) must take all reasonable steps to obtain the best possible result for their clients when executing client orders or receiving and transmitting client orders for execution. Under the above legislation, the Company requires to put in place and implement an Order Execution Policy that provides appropriate information to its clients on the execution of their orders. Crowd Tech applies this Policy on acceptance of an order from a client and/or when a client provides no specific instruction for transmission/execution of the order.
Paragraphs 24 and 25 of Directive DI144-2007-02 on the Professional Competence of Investment Firms provide guidance on the duties of CIFs to act in the best interest of the client, and on the contents and scope of the best execution policy, respectively.
The purpose of this Policy is that in compliance to the Law the Company must establish and implement effective arrangements for obtaining the best possible results for its clients, taking into consideration price, costs, speed, likelihood of execution and settlement, size, nature, as well as the clients’ ability, needs and trading policies, where applicable and possible. Nevertheless, whenever there is a specific instruction from the client the Company shall execute the order following the specific instruction. Clients must note that best execution is a process, which considers various factors, and not the outcome of their transactions.
The Company will act in the capacity of an agent and not as a principal when receiving and transmitting client orders for execution.
This Policy applies to retail and professional clients, and does not apply to clients that the Company classifies as Eligible Counterparties. By entering into an agreement with the Company you are accepting the terms of this Policy.
Details of the financial instruments available to clients via the Company’s trading platform can be found through the Company’s website www.trade360.com or on the Company’s Terms and Conditions (“Agreement”).
When the Company executes an order in absence of any specific instructions from the Client, taking all reasonable steps to obtain the best possible result for their clients, the Company will take into account the following execution criteria:
- Characteristics of the client, including the categorisation of the client as retail or professional;
- Characteristics of the client order;
- Characteristics of the financial instrument that are the subject of that order;
- Characteristics of execution venues where that order can be directed.
When executing client’s orders, the Company is required to take into account various execution factors, provided that there are no specific instructions from the client to the Company about the way of execution of the orders. The execution factors the Company will consider, but not limited to, include:
The Company’s prices for each financial instrument on its trading platform are obtained through its liquidity provider. The Company provides clients with continuous price quotations in the form of BID and ASK. Where BID is the price referenced for short order (sell order) and ASK is the price referenced for long order (buy order). The difference between BID and ASK will be the SPREAD. To ensure the Company’s clients receive best execution, the Company on a daily basis monitors and compares its prices and spreads against a range of third party price providers and data sources as reference to ensure competitive and reliable prices. Depending on the position the client wishes to enter into, the Company will offer a BID or ASK price.
Once the client has decided on the position then he will send a request to the Company asking for a confirmation on the requested price. In order to comply with the “best execution policy” the Company will make best effort to execute the requests at the price the client is soliciting.
We strive to provide the best pricing for all clients, however, under certain market conditions the price requested by the client may not be available, and when this situation arises the order will be executed at the next best available price without prior confirmation. The client acknowledges that such deviations from the client’s declared price may be against the client (negative deviation) or to the client’s benefit (positive deviation).
Speed and Likelihood of Execution
The Company seeks to execute client orders with the fastest execution as reasonably possible. The frequency with which the Company offers the best possible speed of execution relies on various market conditions that can affect the prices of different financial instruments; for example, but not limited to, where there is a fast moving market, low liquidity, and/or at the beginning of trading sessions, around fundamental news announcements, it may not be possible to guarantee the execution of any or all market orders / pending orders at the declared price.
Costs or Commissions
The Company may charge a commission or Swap when the client opens transactions in certain financial instruments. The details of such costs are available on the Company’s website www.trade360.com.
Size of the Order
The Company will endeavour to provide the best possible execution for orders of all sizes; however, in certain circumstances the price given to the client may be different from the declared price due to the effects of market liquidity at the time of the clients’ order. The Company reserves the right not to accept a clients’ order in cases where the size of the order is large and cannot be filled by the Company due to certain market conditions at the time of the order.
Nature of Orders
i. Market Order
ii. Pending Order
The Company provides the following types of transaction:
“Market order”: this is an order to buy or sell immediately against a price that the Client sees on the Company’s trading platform. Market orders are executed on BID/ASK prices offered by the Company. In particular, an order to buy is executed at the current market Ask Price and an Order to sell is executed at the current market Bid Price.
“Pending Order”: this is an order to buy or sell a financial instrument at a desired and specified price at a later time. In this case, the Company will monitor the order and if the market price for the relevant financial instrument rises or falls to the price specified in the order, it will be executed at the desired price. However, under certain market conditions the price requested by the client may not be available. When this situation arises, the pending order will be voided and the Company will execute the order at the next available price. Best execution may apply in these circumstances. Such orders can be characterised on the Company’s trading platform as follows:
1. Buy Limit Order: an order to buy, provided that the future “ASK” price is equal to the pre-defined value. The current price level is higher than the price of the placed order. Orders of this type are usually placed in anticipation that the price of a financial instrument, having fallen to a certain level, will increase;
2. Sell Limit Order: an order to sell, provided the future “BID” price is equal to the pre-defined value. The current price level is lower than the price of the placed order. Orders of this type are usually placed in anticipation that the price of the financial instrument, having increased to a certain level, will fall;
3. Stop Loss: this order is placed to minimise losses if the price of the financial instrument has started to move in an unprofitable direction to the Clients’ order;
4. Take Profit: this order is placed to set an intended profit level for when the price of the financial instrument has reached a certain level.
Specific Order Instructions from clients on how to execute an order received over the phone by the Company, will only be executed once the Company has verified the identity of the caller.
Nevertheless, whenever there is a specific instruction from the client, the Company shall execute the order following acceptance of such instruction. It is noted however that when executing an order following a specific client instruction, the Company will execute the order in line with those instructions and will consider that it has discharged its best execution obligations. This may result in the Company being unable to follow the Company’s best execution policy for that particular order.
An execution venue is the entity to which the orders are placed or to which the Company transmits orders for execution. The Company shall act as the agent of the Client (the principal) when receiving and transmitting orders. In circumstances where there is a sole execution venue for client orders, best execution is achieved by execution on that venue.
The Company is the agent for all trades and the Company’s Liquidity Providers – “Saxo Bank A/S” and “HOTSPOT FX (PTY) Ltd”– are the execution venues. HOTSPOT FX (PTY) Ltd is regulated by the Financial Sector Conduct Authority (South Africa), Saxo Bank A/S is regulated by the Danish Financial Supervisory Authority. Our liquidity providers may be transmitting the orders received by us to other liquidity providers.
Broker(s) and Liquidity Provider(s) are not necessarily operating in regulated markets.
Adequate information is provided to the clients through this Policy in relation to the factors that are taken into consideration by Crowd Tech when handling clients’ orders.
When a client commences trading with the Company, that client has already provided his/her consent to the contents of this Best Execution Policy via the client’s acceptance of the Company’s Terms and Conditions (“Agreement”).
The Company has the right to amend the current Policy at its discretion and at any time it considers is suitable and appropriate; the Company shall review and amend the current Policy at least on an annual basis, and whenever a material change occurs that may affect the Company’s best execution offering. The Policy is available for review by clients upon request and it is uploaded on the Company’s website.
If there is anything in this Policy you do not understand or if you have any further queries, contact us at email@example.com.