In accordance with IBR-Global Markets Ltd internal policy
IBR-Global Markets Ltd. trading as IBR-Global is required to put in place an order execution policy to comply with its internal policy. The account IBR-Global trades on your behalf is with your designated broker(s). Trading as IBR-Global and therefore trades are only executed on the account by IBR-Global. Your authority to trade limits IBR-Global to trading only with your registered broker(s). Trading as IBR-Global and therefore IBR-Global does not owe best execution when selecting a venue to trade on instead meeting this requirement by following your instruction to trade with your designated broker(s). Trading as IBR-Global. In providing authority to IBR-Global to trade on your behalf, you are instructing IBR-Global that you accept the Order Execution Policy of both IBR-Global and your designated broker(s), and the pricing/conflicts of interest involved.
Orders are placed on accounts via software which seeks to eliminate the potential for issues when placing a trade with no human involvement in the order such trades are placed. Product specifications will vary to those linked below, please speak to your broker (s), account manager for further information and review the individual product details.
Please find below a copy of IBR-Global Order Execution Policy as of 15 May 2019. If this has been amended the latest version can be found here.
Based on the directive of the Board of Directors of IBR-Global Markets Ltd. (“IBR”, “we”, “us”, “our”) trading as IBR-Global (IBR) is required to put in place an order execution policy and take all reasonable steps to obtain the best possible result for its clients either when executing client orders dealing on own account (but not when dealing “on quotes”) or when receiving and transmitting orders for execution. This requirement is on top of the general duty to carry out our business with you fairly, honestly and professionally. The purpose of this document is to provide information on the Order Execution Policy of IBR and obtain the consent of the client (the “client” or “you”) to it, where we are obliged to do so. This policy should be read in conjunction with our Terms of Business however the Order Execution Policy itself does not form part of the agreement between you and us. Our commitment to follow the regulatory requirements does not provide any additional fiduciary responsibilities over and above that required by the regulators.
Our Order Execution Policy applies when we execute orders on behalf of our clients. However, save different written agreements with our clients, we always deal on behalf of our clients, and act as the relevant execution venue for the clients’ orders, which will be executed on an OTC basis rather than on a regulated market or multilateral trading facility.
If you provide IBR with specific instructions as to how to execute your order, we will have complied with our obligation to take all reasonable steps to obtain the best possible result when executing that order by following your instructions. Please note that this may prevent us from following our Order Execution Policy. To the extent that your instructions are incomplete, we will usually follow our Order Execution Policy for those parts or aspects of the order not covered by your instructions. In the absence of specific instructions from you, IBR will usually take into account the various execution factors and criteria set out below in order to determine how to obtain the best possible result when executing orders on your behalf.
Subject to any specific instructions that IBR accepts from you, IBR will take into account a range of factors in deciding where and when to execute your order. These include price, costs, speed, likelihood of execution and settlement together with any other consideration relevant to the execution of the order. In determining the relative importance of these factors IBR will take into account your status as a retail or professional client, together with the nature of your order, the characteristics of the financial instruments to which the order relates and the characteristics of the execution venues to which the order can be directed. IBR will generally give the highest priority to total consideration, representing the price of the relevant financial instruments and the costs related to execution. However, we may at our discretion, prioritise other factors, including the impact on market prices of displaying and executing your order, the speed and likelihood of execution and the availability of price improvement. We may prioritise such other factors where there is insufficient immediately available equity on the relevant execution time to execute your order in full, where you instruct us to work your order over a period of time or by reference to a benchmark calculated over a period of time or where we determine that there are other circumstances such that obtaining the best immediately available price may not be the best possible result for you.
In determining what is the best possible result for you, we will not compare the results that can be achieved for you on the basis of our Order Execution Policy and fees with results that might be achieved for you by another investment firm on the basis of that firm’s execution policy or a different structure of commission or fees, nor will we compare the differences in our own commissions or fees which are attributable to the nature of the services that we provide to you.
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 may 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. However, we are not required to quote a price when the market is closed, suspended or in extreme market conditions.
IBR prices for index CFDs will be referenced to the level of the relevant underlying index futures price. IBR will base the closing price for index CFDs on the closing price of the relevant index for the purpose of margin requirements and any balance credits/debits.
IBR has access to at least one relevant underlying derivative exchange per commodity in respect of which IBR offers trading in commodity CFD products. By reference to the underlying instruments IBR will determine a price, taking into account cost of carry etc. where relevant. Where the underlying bid and offer reference prices are not available, IBR will reference the last actual trade of the underlying instrument and then apply a trading strategy.
IBR prices for the individual share CFDs will be referenced to the price at which the individual share is currently trading on the appropriate exchange. IBR will base the closing price for the Share CFDs on the closing price of the relevant Share for the purpose of margin requirements and any balance credits/debits.
IBR prices for the Bond CFD will be referenced to the price of the relevant underlying Bond futures price. IBR will base the closing price for the Bond CFDs on the closing price of the relevant Bond for the purpose of margin requirements and any balance credits/debits.
IBR prices on Forex/currency products are sourced from independent price providing banks providing liquidity to the OTC Forex market. By reference, IBR will access the prices of a market maker in Forex/currency products who from our experience usually provides a consistent service, taking into account factors such as frequency of updates and reliability, from which we will then determine our prices. IBR will base the closing price on Forex/currency positions on the closing price of the relevant currency for the purpose of margin requirements and any balance credits/debits.
Effect of Other Factors on the Execution of Your Order. Your designated broker(s) reserves the right to modify its spreads, and you may experience widened spreads and slippage under certain market conditions (for example, when the trading desk is closed, around fundamental announcements, where there is a fast moving market or low liquidity). Most trades will be automatically priced and executed by your broker’s automated internal trading systems. However, depending on factors such as for example unusual market conditions or the size and nature of your order an instrument may be wholly or partly manually priced and/or an order may be manually executed.
During times of high demand manual pricing and/or execution may cause delays in processing your order which in turn can have an impact on the price at which your order is executed. IBR is committed to providing the most competitive trading strategy and has put dealing procedures in place to minimize the risk of delays.
CFDs are not traded up until the exact expiration date of the underlying instrument. Any Rollover will usually take effect the weekend preceding the maturity date of the underlying asset (except for commodities where rollover usually takes place two weekends prior to the expiration date) unless notified by email to the contrary with at least seven days’ notice by email. For open positions of CFD instruments a certain amount of swap is either credited or debited, calculated on the basis between the maturity price of the underlying asset and the price of the next contract maturity date. The trading price of the CFD is derived directly from the underlying asset contract with the new maturity date when the market reopens. IBR strategically cancel stop/limit orders near the day of the rollover. Alternatively, the system will automatically cancel the orders.
There may be occasions where we are unable to place orders where we are going short due to regulatory requirements or that we are not offering the opportunity to go short on that particular product e.g. on an individual share.
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 meet our obligations 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 meet our obligations. Should there be any material changes to our order execution arrangements or Order Execution Policy, we will notify you.