Under the FCA rules FCI is required to implement an Order Execution Policy and a Best Execution Policy in order to obtain the best results for its clients. The aim of this document is to provide our client with the appropriate details of these policies in accordance with the Financial Conduct Authority’s rules requirements and in order to extend to our clients a transparent overview to our business practices. FCI has put in place Order Execution Policy and Best Execution Policy with a view to provide the best possible results to our clients depending upon the circumstances and market conditions on a best endeavour basis. These policies take into consideration the relevant execution factors with due diligence paid to their comparative importance. The disclosure schedule forms part of our terms of business. Therefore, by agreeing to the terms of our Client Agreement, you are also agreeing to the terms of our execution policy, as summarised in this document.

1. SCOPE

FCI understands there is to be a duty of Best Execution owed to the client when orders are executed having arisen from either contractual or agency obligations, on the client’s behalf. The duty is not owed when FCI offers prices at which it will be prepared to buy or sell, nor when FCI provides a quote in an answer to such a request.

2. OUR SERVICE

In dealings between us FCI act as principle and not as agent on your behalf and we therefore act as the sole execution venue on the provided trading platform for the execution of your orders.

3. DISCRETION

The general market understanding is that the best possible results for a client would be determined by the price and/or the liquidity of the market. However, FCI may decide, in their absolute discretion, that in certain circumstances, other factors e.g. the need for timely execution of the order is more important in determining the best possible results. This may depend on the type of order, the financial instrument or the market involved.

4. ORDER CAPTURE

FCI will endeavour to execute the order received in a prompt, fair and expeditious manner, ensuring that potential conflicts of interest between clients or between the client and FCI are managed effectively. Where there is a lapse of time between FCI’s first quote and the clients acceptance which causes delay or in the case that the market conditions have changed, FCI will still be within its rights to execute the order, provided the quote is not significantly out of date and that its still would have met the best execution requirements.

5. ORDER HANDLING

FCI records and executes otherwise comparable orders sequentially and timed to coincide with receipt of the order unless the characteristics of the order or market conditions make it impractical to do so; or if the client’s interests demand otherwise. Orders received in a different media cannot be termed otherwise comparable.

6. ORDER ALLOCATION

Depending upon the circumstances, market conditions and order size, FCI may aggregate the client order with those of other clients or transactions on behalf of FCI. This aggregation is not considered to compromise the client interest although some disadvantage, in relation to a particular order, may occur. In the case of such aggregated orders being partially executed, FCI will allocate the executed orders in terms of its Order Allocation Policy.

7. EXECUTION VENUES

FCI executes client orders at various execution venues. Selecting the execution venues provide the best execution for the client requires consideration of the relative importance of the execution factors depending upon the characteristics of:

• The client order
• The financial Instrument involved
• The execution venues and
• The client classification

The execution factors that FCI consider are:

• Price
• Costs
• Probability of execution and settlement
• Speed of Execution
• Size of order
• Nature of order and
• Other relevant consideration to the execution of the order

FCI will assess which venues within this list are likely to provide the best possible results for you on a product by product basis and depending on other considerations. FCI will monitor the execution venues and other execution arrangements regularly for their effectiveness and consistency in providing best results.

8. METHODS OF EXECUTION

Depending upon circumstances, FCI may execute orders outside Regulated Markets or Multilateral Trading Facilities (‘MTFs’). FCI believe restricting the execution of orders to Regulated Markets and MTF’s may adversely affect the quality of the execution and liquidity. By signing this agreement you expressly consent to our executing your orders outside Regulated Markets and MTF’s.

9. CLIENT LIMIT ORDERS

We are required to publish limits orders given by you should we not be able to execute your order immediately. Please sign and return the attached form to confirm that you agree that when you place a limit order with us that is not immediately executable, we are authorised to exercise our discretion to not publish such an order to a Regulated Market or MTF.

10. SPECIFIC CLIENT INSTRUCTIONS

Where you provide FCI with specific instructions in relation to your entire order, or any aspect of your order, for example a preferred execution venue, FCI may execute your order in accordance with your instructions, and to that extent FCI will not owe you a duty of best execution. To the extent that your specific instructions relate to only one or some aspects of the order, FCI will determine any unspecified aspects in accordance with its Order Execution Policy.

You should be aware that where you provide FCI with specific instructions in relation to the execution of your order, you may prevent FCI from following some or all of the steps in our Order Execution Policy to obtain the best possible result for you in respect to those aspects affected by your instructions.

While we take all reasonable steps based on the resources available to us and depending upon the market conditions and circumstance as then prevalent to enable us to provide best possible results for you, we can not guarantee that we will always be able to provide best execution to each and every order executed on your behalf particularly where you give us specific instructions as to all or part of your order.

11. FCI’S COMMITMENT

FCI’s commitment to provide you with Best Execution does not mean that we owe you any fiduciary responsibility over and above the specific regulatory obligations placed upon us or as may be otherwise contracted between us.

12. MONITORING AND REVIEWING OF OUR EXECUTION POLICY

We periodically monitor the effectiveness of our order execution arrangements and Order Execution Policy. We will assess from time to time whether the venues relied upon by us in pricing our Transactions allow us to achieve best execution on a consistent basis or whether we need to make changes to our execution arrangements. Will we also review our order execution arrangements and Order Execution Policy in respect of material changes either in respect of one of our chosen pricing venues or otherwise that affects our ability to continue to achieve best execution. Should there be any material changes to our Order Execution arrangements or Order Execution Policy, we will notify you as soon as it is practically possible.

13. CLIENT CONSENT

Under FCA Rules we are required to obtain your consent to our Best Execution Policy and other matters as outlined above. We will consider that you have consented to agreeing to such Best Execution Policy by your placing an order with us. We are however required to obtain your express consent for execution of your order outside Regulated Markets or MTF’s and for exercising our judgement in the matter of publishing your Limit Orders. We would request you to please provide such consent by signing this agreement.