1.1. In this policy, 4T S.A.L (also referred to as ‘we’, ‘us’, ‘4T’ and ‘Company’), is licensed
and regulated by the Capital Markets Authority (CMA) in Lebanon.
1.2. 4T recognizes its duty to take reasonable steps to obtain the best outcome for handling and
executing the orders of the client. Therefore, 4T S.A.L has put in place a policy in addition to
procedures designed to obtain the best outcome for clients when executing orders on their behalf.
The police and procedures take into account, and are subject to, , any specific instructions from
the client, the nature of the particular orders and the nature of the markets concerned, but do not
guarantee such results in all transactions. This policy should be read in conjunction with 4T’s
Terms of Business as applicable from time to time, which is available on the website.
1.3. The company has established and implemented arrangements, including this Policy. The
arrangements are designed to meet the regulatory requirement that obtain the best possible result
according to the orders of the Clients. The process of obtaining such best possible result shall be
referred to as “Best Execution”.
1.4. Other factors, not mentioned in this policy, could affect the execution; either because of
their irrelevance, at this point in time, or because they are more related to technology faults,
errors or bugs in systems and configurations. If an error is denied execution due to these
circumstances, the Client must contact the company immediately and execute the order by means other
than the trading platform.
2.1. 4T offers to retail and professional clients Contracts for Difference (CFDs) across a range of
asset classes: Foreign Exchange (FX), Indices, Commodities, Equity and Cryptocurrencies.
2.2. We act as principle on behalf of contracts and trades you enter with us, and we therefore act
as sole execution venue for the execution of your contracts. This means that we will act as market
maker and you will be dealing with us.
2.3. We ensure you obtain best execution by ensuring that in the calculation of our bid and offer
prices used to execute your Contracts, we take into regard the market price and liquidity available
for the underlying reference product to which your Contract relates. We have access to top tier
liquidity providers and data sources to ascertain the market price.
2.4. Whilst we act as principal in respect of your orders, we assess the venues available to us for
the pricing and hedging of your Contracts and the execution of your transactions. We view that,
price and costs are the most important factors in our choice of venue, but we will also take into
account how each of the other execution factors are affected, for example; speed of processing and
likelihood of order acceptance in a variety of markets and order types. The financial soundness and
order execution policies of any counterparty or venue are also considered.
2.5. 4T will seek to manage our risk as market maker and may choose whether to hedge part or all of
your Contracts in the underlying market. We believe this approach is likely to result in reducing
the execution of costs and of market price impact for our clients overall. Hedging in the underlying
market may affect the price of the Contract that 4T enters with you, considering the prevailing
market prices and liquidity available to us.
2.6. When executing your orders, we will take all necessary steps to achieve the best possible
outcome by executing orders according to this Policy and any specific instructions received from
you. This Policy comprises a set of procedures that are designed to obtain the best
possible execution result, subject to and taking into account, the nature of your orders and the
specific instruction you have identified regarding those orders. The client acknowledges that our
price may differ from any price which is or might have been available elsewhere.
2.7. In regard of some financial instruments, at the time at which you give us an order there may be
no functioning or open market or exchange on which the reference product is traded. In such cases,
we set out to determine a fair underlying two-way price based on several factors such as price
movements on associated markets, other market influences and client trading flow.
3. Execution Factors
Many factors could affect providing best execution. The client should consider these factors prior to
making the trading decision and send the orders for execution. In the absence of a specific instruction
from the client, 4T may consider the impact of one or a combination of factors to determine the way a
client order will be executed. These factors are:
• Speed and Likelihood of Execution
• Size and Nature of Order
• Specific Instructions
• Any Other Factor Relevant to the Execution of the Order
a) The price of a given instrument or contract that we provide for trading is calculated in
reference to the exchange or the interbank price of the relevant underlying financial
instrument. However, the client must understand that our products, though they are priced to
reflect the underlying market, are mostly over-the-counter ‘OTC’ contracts for difference,
the client enters into a position with us and is therefore required to exit the position
in exchange for the cash amount equivalent of the profit or loss realized on the position.
will be no delivery or transfer of positions to third party financial institutions.
b) The price is obtained by independent third-party financial institutions that may or may
not act as our execution venue. We aggregate these prices to show the client the most
favorable bid and ask after including our mark-up/down into the spread or commissions.
c) The prices that appear on the trading platform and applications are indicative and may at
times not be executable. The reasons include, but are not limited to, the demand and supply
of liquidity at this specific price. Also, it could be that the client is viewing only bid
side, ask side, mid-price, stale price, non-tradable price, or raw price.
d) In the absence of a price quotation from our third parties for any reason, we will
calculate the most probable price and display it on the system to prevent issues related to
margin stop/out. These prices are provided temporary to give you an estimated value of your
positions, however they may be deemed stale or non-tradable.
e) The prices on the charts are for indication purposes only. The charts are provided for
the sole purpose of illustration of the historical price movement. They do not necessarily
execution prices and could occasionally have off-quotes or incorrect prices that we will
clean-up, filter-out and amend accordingly.
f) In the rare occasion an order is executed on a stale, non-tradable or generally incorrect
price, 4T reserves the right to cancel, offset and/or reverse the trade without prior
3.2. Speed and Likelihood of Execution
a) In almost all circumstances, under normal market conditions and as long as the client has
sufficient margin available on their account for the trade, and as long as the trade size
requested is equal to or under the maximum size permissible, the trade will be executed
immediately at the market prevailing price.
b) In certain specific circumstances, for example: speed of Internet communications and
market volatility; where the quoted price is no longer representative of the ‘underlying
market’ price, but within a predetermined permitted tolerance level, the client’s trade will
be executed at the best price available at that time, regardless of whether the market
movement is in a beneficial or detrimental direction.
c) The likelihood of execution of the Clients’ orders may depend on the availability of the
underlying prevailing price. In some cases, it may not be possible to arrange an order for
execution during abnormal market conditions, for example but not limited to the following
cases: overnight, during news times, trading session start moments, during volatile markets
where prices may move significantly up or down and away from declared prices, where there is
a fast price movement, where there is insufficient liquidity for the execution of the
specific volume at the declared price and/or a force majeure event.
d) Slippage can occur at any time, but is most likely to occur during periods of high
volatility, overnight and at the opening of the market. It usually occurs when the market
moves suddenly in any direction and during the time taken for a client’s acceptance of a
price to be received, that price is no longer available and the client’s trade is executed
at the best price available at that time.
I. Slippage is the difference between the expected price of a trade, and the price
at which the trade was executed. This can be either in favor or against the client.
II. Slippage occurs when there is not enough supply or demand on either side of the
quotation. This leads a market order to be executed relatively far from the desired
price. It also occurs when the market price moves suddenly in any direction
triggering a large number of orders to be sent through the networks causing latency
which, in turn, leads to execution at the next available price. The price is then
said to have ‘slipped’ from one level to another, as the market has ‘gapped’ from
one level to another.
III. If the market ‘gaps’ overnight, it will open at the start of the trading day at
a price different from the closing price of the previous trading session.
IV. Any order which activation price is between the market’s closing quote of the
previous trading session and their opening quote of the new trading session, will be
filled at the first price 4T can reasonably obtain in reference to the ‘underlying
V. Should there be any market gaps from one quoted price to another due to any
market sensitive piece of information (such as a profit warning or an economic data
release), then any order placed between these prices will be activated.
VI. the speed of execution depends largely on the speed of networks, servers, and
devices. We take all necessary steps to ensure our servers and networks are speedy
and up to date. However, we have no control over the speed and performance of your
own network and devices.
VII. 4T does not accept any orders outside the market hours of the relevant
underlying financial instrument, and futures are traded in accordance with the
trading hours of the exchange upon which the underlying financial instrument is
3.3 Size and Nature of Order
a) When the order is sent to the market for execution, it is only triggered by the price.
However, the prices are not assigned to infinite liquidity. Prices displayed on the system,
only present a limited layer of the market depth, hence, large orders will tend to be
executed partially and at different prices down the order book. In this case, the client
will receive a weighted average price.
b) If the size of the order exceeds the available liquidity we may (or not) accept the order
for partial execution.
c) Market Orders are when the client sends instructions to buy or sell any instrument at
whatever price available at the time of execution.
d) Buy Stop orders are instructions to buy an instrument at a price higher than the current
e) Sell Stop orders are instructions to sell an instrument at a price lower than the current
f) Stop Loss Orders are instructions related to existing positions to close them when the
market price is moving in the opposite direction to the positions of the client. Stop Orders
are generally sent for execution as market orders. The designated price merely acts as a
trigger to activate the order but the execution will be done at the first available market
g) Buy Limit Orders are instructions to buy an instrument at a price lower than the current
h) Sell Limit Orders are instructions to sell an instrument at a price higher than the
current market price.
i) Limit or T/P Orders are instructions related to existing positions to close them when the
market price is moving in a direction favorable to the position of the client.
j) Entry limit and T/P orders are sent to execution with an attached price. They can only be
executed if the price is linked to enough liquidity. They might continue to be executed
partially until completely filled at the requested price or better.
3.4 Specific Instructions
a) As outlined in the policy, 4T takes into consideration any specific instructions that may
prevent executing the orders in accordance with the terms of this policy. Examples of this
include, but are not limited to: Executing, specifically, a limit order as market or
specifically instructing 4T to break a large order into smaller size orders prior to sending
a) The difference between the Bid and Ask (selling and buying price) is known as the
‘spread’ and is, typically, the cost of trading. Spreads can be fixed or dynamic and can
widen and shortened according to market volatility and available liquidity and instrument.
b) The price is transmitted to the platform of the client and includes the spread cost and
therefore, both the bid and the offer price may be slightly different from the market or the
exchange price of the underlying financial instrument.
c) A limit or even stop orders can be triggered at a price that is higher or lower than the
market or traded price of the underlying financial instrument due to the spread cost.
d) An order can be rejected if the trading platform calculates that the client does not have
enough balance to cover the cost of execution.
e) In other circumstances, clients may be charged overnight funding for holding positions
overnight, and for adjustments made in respect of dividend payments and other corporate
f) FX instrument overnight financing charges will be applied three times on Wednesday.
a) There are other factors that could affect execution that are not mentioned in this
policy, either because of their irrelevance at this point or because they are related to
technology, including but not limited to, set-up errors, connectivity issues, programming
code breaks or ‘bugs’ in the configuration of instruments. If an error denies execution due
to a bug or a configuration error, the client must contact 4T immediately and execute the
order by means other than the trading platforms.
b) 4T does not and will not owe the client execution at a price that is no longer available
in the current market.
3.7 Other Factors Relevant to the Execution of the Order
a) Available Margins
The trading system may allow you to place working orders that would require a currently
non-available minimum margin amount If the working order is triggered by a price movement,
and the account does not have enough free margin available to meet the margin requirement,
the working order will be cancelled and void..
b) Trading Platform
There are several methods of trading with us, Desktop, Web trader, Mobile application or
phone instruction. Each method may be different and can be affected by a different set of
factors such as, Internet speed, accuracy and ease of use.
c) Market Impact
The liquidity of any financial product is limited no matter how much of it is available at
any time. The trades and orders of market participants have an impact on this liquidity
which could quickly disappear, especially during volatile and extraordinary market
conditions where the price movement could translate into a huge number of orders sent at the
same time and looking to be executed at any price available. We always aim to provide our
clients with best execution, but prevailing underlying market conditions may, at times,
result in unfavorable execution.
d) Market Hours
Aside from those markets defined as being quoted ‘out of hours’, no order will be filled
outside of our specified quoting hours. Please note that some markets continue to trade
outside our quoting hours and, in these cases, there is significant potential of some
gapping from one 4T trading session to the next.. All orders in these markets will be
subject to this gap in prices. Orders activated in ‘out of hours markets’ quoted by 4T are
treated as though the underlying instrument were open and trading at that level require to
activate the order.
e) The Execution Venue, If Any, to Which the Order Will Be Routed
On the occasion where we have routed your order to an execution venue, we are bound by the
venue’s business terms and conditions and execution policy which can differ from ours. Your
order might, therefore, be affected as we pass to the execution.
4. 4T’s Conflict of Interest and Liabilities
4.1. 4T’s commitment to provide “best execution” does not mean that it owes any of its clients any
fiduciary responsibilities over and above any specific regulatory obligations, unless it is
specifically agreed in writing. 4T will not provide the client with any recommendation or any other
information with the intention to incite the buying or selling of any instrument or the engagement
of any other trading activities. The client must make their own trading decisions independently and
seek help by a financial consultant before taking any trading decision. Each client remains
responsible for their own investment decisions and 4T will not be responsible for any market or
trading loss that a client might suffer because of those decisions.
5. Monitoring & Review
5.1. 4T will evaluate, on a regular basis, whether the execution venues and pricing mentioned in this
Policy provide the best possible outcome for its clients or whether it needs to make changes to its
5.2. 4T will review its order execution arrangements and this Policy at least annually or whenever a
material change arises and affects its ability to continue to obtain the best outcome for the execution
of the orders of the client on a consistent basis using the venues included in this Policy.
5.3. 4T will notify the clients of any material changes to its order execution arrangements or Best
Execution Policy as described above by posting the information on its website or by email.
Contracts for Difference (CFDs) are a leveraged product and can result in losses that exceed deposits.
CFD trading carries a high level of risk and may not be suitable for everyone, so please ensure you fully
understand the risks involved before trading.