1. 4T Limited - Execution Policy

Scope and Services

• 1.1
  This Execution Policy (hereinafter referred to as the ‘Policy’) is made and entered by 4T Limited (hereinafter referred to as ‘we’, ‘us’, ‘4T’ or ‘Company’), licensed and regulated by the Financial Markets Authority (FSA), Seychelles as a securities dealer. This policy should be read in conjunction with 4T’s Terms and Conditions as applicable from time to time, which are available on the website.
• 1.2
  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”.
• 1.3
  It is to be noted that the factors highlighted in this policy is not exhaustive, therefore there are other factors not mentioned in this Policy which could affect the execution due to their irrelevance, at this point in time. Furthermore, third party or some matters that are beyond the Company’s control can arise that may affect this Policy e.g. possible technology faults, errors, or bugs in systems and configurations. The Company aims at giving the best execution solutions therefore the Client must contact the Company immediately and we would advise on the way forward.

2. Execution

• 2.1
  The Company 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
  The Company acts as principle on behalf of contracts and trades the Client enter with the Company, and we therefore at times act as sole execution venue for the execution of the Client’s contracts. This means that the Company will act as market maker and the Client will be dealing with us.
• 2.3
  The Company ensures the Client obtains best execution by ensuring that in the calculation of the Company’s bid and offer prices used to execute the Client’s Contracts, the Company takes into regard the market price and liquidity available for the underlying reference product to which the Client’s Contract relates. The Company also has access to top tier liquidity providers and data sources to ascertain the market price.
• 2.4
  Whilst the Company acts as principal in respect of the Client’s Orders, the Company assesses the venues available to it for the pricing and hedging of the Client’s Contracts and the execution of his Transactions. The Company views that, price and costs are the most important factors in its choice of venue, but the Company 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
  The Company will seek to manage its risk as market maker and may choose whether to hedge part or all of the Client’s Contracts in the underlying market. The Company believes this approach is likely to result in reducing the execution of costs and of market price impact for the Company’s Clients overall. Hedging in the underlying market may affect the price of the Contract that the Company enters with the Client, considering the prevailing market prices and liquidity available to the Company.
• 2.6
  When executing the Client’s Orders, the Company will take all necessary steps to achieve the best possible outcome by executing orders according to this Policy and any specific instructions received from the Client. 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 the Client’s Orders and the specific instruction he has identified regarding those orders. The Client acknowledges that he is aware that the Company’s 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 the Client gives the Company an Order, there may be no functioning or open market or exchange on which the reference product is traded. In such cases, the Company sets 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

• • Price
• • Speed and Likelihood of Execution
• • Size and Nature of Order
• • Specific Instructions
• • Cost
• • Technology
• • Other Factors Relevant to the Execution of the Order

3.1 Price

• i.
  The price of a given instrument or contract that the Company provides for trading is calculated in reference to the exchange, liquidity provider, or the interbank price of the relevant underlying financial instrument. However, the Client must understand that the Company’s products, though they are priced to reflect the underlying market, are mostly over-the-counter ‘OTC’ contracts for difference, where the Client enters into a position with us and is therefore required to exit the position with us in exchange for the cash amount equivalent of the profit or loss realized on the position. There will be no delivery or transfer of positions to third party financial institutions.
• ii.
  The price is obtained by independent third-party financial institutions that may or may not act as the Company’s execution venue. The Company aggregates these prices to show the Client the most favorable bid and ask after including the Company’s mark-up/down into the spread or commissions
• iii.
  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.
• iv.
  In the absence of a price quotation from the Company’s 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 the Client an estimated value of his positions, however they may be deemed stale or non-tradable.
• v.
  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 reflect execution prices and could occasionally have off-quotes or incorrect prices that the Company will clean-up, filter-out and amend accordingly.
• vi.
  In the rare occasion an order is executed on a stale, non-tradable or generally incorrect price, the Company reserves the right to cancel, offset, and/or reverse the trade without prior notice.

3.2 Speed and Likelihood of Execution

• i.
  In almost all circumstances, under normal market conditions, 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.
• ii.
  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.
• iii.
  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 economic data releases, news events, 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.
• iv.
  Slippage can occur at any time but is most likely to occur during periods of high volatility, economic data releases, event announcements, or 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.

  • • 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.
  • • 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.
  • • 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.
  • • 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 the Company can reasonably obtain in reference to the ‘underlying market’.
  • • 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.
  • • The speed of execution depends largely on the speed of networks, servers, and devices. The Company takes all necessary steps to ensure its servers and networks are speedy and up to date. However, the Company has no control over the speed and performance of the Client’s own network and devices.
  • • The Company 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 traded.

3.3 Size and Nature of Order

• i.
  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.
• ii.
  If the size of the order exceeds the available liquidity, the Company may (or not) accept the order for partial execution.
• iii.
  Market Orders are when the Client sends instructions to buy or sell any instrument at whatever price available at the time of execution.
• iv.
  Buy Stop orders are instructions to buy an instrument at a price higher than the current market price. They are executed when the offer/buy price reaches the specified price (not the bid/sell price)
• v.
  Sell Stop orders are instructions to sell an instrument at a price lower than the current market price. They are executed when the bid/sell price reaches the specified price (not the offer/buy price)
• vi.
  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 price.
• vii.
  Buy Limit Orders are instructions to buy an instrument at a price lower than the current market price. They are executed when the offer/buy price reaches the specified price (not the bid/sell price)
• viii.
  Sell Limit Orders are instructions to sell an instrument at a price higher than the current market price. They are executed when the bid/sell price reaches the specified price (not the offer/buy price)
• ix.
  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.
• x.
  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

• i.
  As outlined in the Policy, the Company 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 a limit order as market or specifically instructing the Company to break a large order into smaller size orders prior to sending for execution.

3.5 Cost

• i.
  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.
• ii.
  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.
• iii.
  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.
• iv.
  An Order can be rejected if the trading platform calculates that the client does not have enough balance to cover the cost of execution.
• v.
  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 actions.
• vi.
  FX instrument overnight financing charges will be applied three times on every Wednesday.
• vii.
  Equities, Indices, Commodities except Gold and Silver, and Crypto Currencies overnight financing charges will be applied three times on every Friday.

3.6 Technology

• i.
  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 the Company immediately and execute the order by means other than the trading platforms.
• ii. T
  he Company 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

• i.
  Available Margins: The trading system may allow the Client to place working Orders (to open new positions) 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.
• ii.
  Trading Platform: There are several methods of trading with the Company: Internet - Desktop, Web trader, Mobile, Tablet 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.
• iii.
  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. The Company always aims to provide its Clients with best execution, but prevailing underlying market conditions may, at times, result in unfavorable execution.
• iv.
  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 underlying markets continue to trade outside the Company’s quoting hours and, in these cases, there is significant potential of some gapping from one Company’s 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 us are treated as though the underlying instrument were open and trading at that level require to activate the order.
• v.
  The Execution Venue, If Any, to Which the Order Will Be Routed: On the occasion where the Company has routed the Client’s order to an execution venue, the Company is bound by the venue’s business terms and conditions and execution policy which can differ from the Company’s. The Client’s Order might, therefore, be affected as we pass the execution.