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Order Execution Policy
Introduction
We have a general duty to conduct our business with you honestly, fairly, and professionally and to act in your best interests when executing orders. More specifically, when we are executing orders on your behalf we will provide you with “best execution”, that is, we will operate according to a policy which we have established in order to take reasonable steps to obtain the best possible result for our clients.
This document provides a summary of that policy. It applies from 1 July 2009. This disclosure statement forms part of our terms of business. Therefore, by agreeing to the terms of our Customer Agreement, you are also agreeing to the terms of our execution policy, as summarized in this document.

Duty to give you best execution
When executing Transactions with you, we will take all reasonable steps to achieve the best possible result for you by executing those Transactions according to our Order Execution Policy and subject to any specific instructions received from you. Our Order Execution 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, the priorities you have identified to us in relation to filling of those orders and the practices relating to the market in question with the aim of producing a result which provides, in our view, the best balance across a range of sometimes conflicting factors. Our policy cannot provide a guarantee, however, that when executing a Transaction with you our price will always be better than one which is or might have been available elsewhere.

Determining whether we obtain best execution for you
In dealings between us we act as principal and not as agent on your behalf and we therefore act as the sole execution venue for the execution of your orders. We are required to take a number of factors into account when considering how to give you best execution. We have rated price as the most important followed by: costs, size, liquidity of the underlying market, speed and likelihood of execution and settlement. The main way in which we will ensure that you obtain best execution is by ensuring that in our calculation of our CFD bid/offer prices we use the market price for the underlying reference product to which your Transaction relates. We have access to a number of different data sources in order to generate our market price, that is, our objective view of the bids and offers available to arms’ length traders.
For All of our CFDs we take into account factors such as interest, expected dividends and variations in the underlying contract for the reference date of the expiry of the CFD. To this we add a Plus500 Spread. The Plus500 Spread will not be greater than the range published in the Plus500 Spread tables on our website in the online version of the Contract Details. As a result of all these varying factors our bid/offer prices will generally not be the same as the cash price for the underlying.
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.

Specific instructions
Where you give us specific instructions, including specifying the price of a CFD Transaction with us
, or the price at which a Transaction is to be closed if the market moves against you, or, for us to “work” an order; those instructions take precedence over other aspects of our policy. A Transaction for which a Controlled Risk Stop has been set will be closed at the level of the Stop if the limit price is reached.

No Aggregation
We do not combine your instruction to close with those of other clients of ours for execution as a single order.

We do not owe you a fiduciary duty
Our commitment to provide you with “best execution” does not mean that we owe you any fiduciary responsibilities over and above the specific regulatory obligations placed upon us or as may be otherwise contracted between us.

Monitoring and review of our Order Execution Policy
We will 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. We will 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.

Contract details
Full details of the trading conditions for particular products are available through the “contract details” pages of our website.
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