Best interest and order execution policy
1.1. This Directive Realization and Best Interest Policy (“the Policy”) is provided to you (our Client or prospective Client) by Seymour Marketing Ltd (“the Firm”). The Firm is required to take all reasonable steps in order to act in the best interest of its Clients when receiving and conducting Client Directives and to achieve the best realization outcomes when executing Client Directives and to comply, in particular, with the principles set out in the Law when providing investment services.
2.1. This Policy applies to both Retail and Professional Clients (as defined in the Firm’s Client Classification Policy). If the Firm files a Client as an Eligible Counterparty, this Policy does not apply to such an Eligible Counterparty.
2.2. This Policy applies when receiving and conducting Client Directives or executing Client Directives for the Client for all the types of Binary Options offered by the Firm.
3. Best Realization Factors
3.1. The Firm shall take all reasonable steps to obtain the best possible outcomes for its Clients taking into account the following factors when executing Clients’ directives against the Firm’s quoted prices:
(a) Price: The Firm’s price for a given sort of Binary Option is calculated by reference to the price of the relevant underlying asset, which the Firm obtains from third party external reference sources. The Firm’s prices can be found on the Firm’s online trading Platform. The Firm updates its prices as often as the restrictions of technology and communications links allow. The Firm reviews its third party external reference sources from time to time to ensure that the data obtained continues to remain competitive. The Firm will not quote any price outside the Firm’s operations time therefore no directives can be placed by the Client during that time.
(b) Costs – eXbino doesn’t charges any commissions from investments.
(c) Probability of Realization: When the Firm conducts Directives for Realization or realizes it with another party, realization may be more difficult. The probability of realization depends on the availability of prices of other market makers/financial institutions. In some case it may not be possible to arrange an Directive for realization, for example but not limited in the following cases: trading session start moments, during news times, during volatile markets where prices may move significantly up or down and away from declared prices, where there is rapid price movement, where there is insufficient liquidity for the realization of the specific volume at the declared price, a force majeure event has occurred. In the event that the Firm is unable to proceed with an Directive with regard to price or size or other reason, the Directive will not be realized. Moreover, the Firm is entitled, at any time and at its discretion, without giving any notice or explanation to the Client, to decline or refuse to conduct or arrange for the realization of any Directive or Claim or Demand of the Client in circumstances explained in the Client Agreement/General Terms and Conditions.
(d) Speed of Realization: The Firm does not realize the Client Directive in Binary Options as a principal to principal against the Client, i.e. the Firm is not the Realization Spot for the realization of the Client’s directive. The Firm conducts Client Directives or arranges for their realization with a third party(ies). However, the Firm places a significant importance when executing Client’s directives and strives to offer high speed of realization within the restrictions of technology and communications links.
(e) Market Impact: Some factors may quickly influence the price of the underlying assets from which the Firm’s quoted price is derived and may also influence other factors listed herein. The Firm will take all reasonable steps to obtain the best possible outcome for its Clients.
(f) Size of directive.
(g) Probability of settlement.
3.2. The Firm does not consider the above list complete and the directive in which the above factors are presented shall not be taken as priority factor. Nevertheless, whenever there is a specific direction from the Client, the Firm shall make sure that the Client’s directive shall be realized following the specific instruction.
4. Best Realization Standards
4.1. The Firm will determine the relative importance of the above Best Realization Factors (of paragraph 3 above) by using its commercial judgment and experience in the light of the information available on the market and taking into account:
(a) The characteristics of the Client directive.
(b) The characteristics of the Binary Options that are the subject of that directive.
(c) The characteristics of the realization spot to which that directive is directed.
4.2. For Retail Clients, the best possible outcome shall be determined in terms of the total consideration, representing the price of the Binary Option and the costs related to realization, which shall include all expenses incurred by the Client which are directly related to the realization of the directive, including realization spot fees, clearing and settlement fees and any other fees paid to third parties involved in the realization of the directive.
5. Client’s Specific Instruction
5.1. Whenever there is a specific instruction from or on behalf of a Client (e.g. fills in the required parts on the Firm’s trading platform when placing a Directive), the Firm shall organize – to the extent possible – the realization of the Client directive strictly in accordance with the specific instruction. It is noted that the specific instruction may prevent the Firm from taking the steps in the Policy to obtain the best possible outcome for the Client.
5.2. Trading Regulations for specific markets or market conditions may prevent the Firm from following certain of the Client’s instructions.
6. Realization on Client Directives
6.1. The Firm shall satisfy the following conditions when carrying out Client Directives:
(a) carries out otherwise comparable Client directives sequentially and promptly if the characteristics of the directive or prevailing market conditions do not make this impracticable;
(b) ensures that directives realized on behalf of Clients are promptly and accurately recorded and assigned;
(c) informs a retail Client about any material problem relevant to the proper carrying out of directives promptly upon becoming aware of the problem.
7. Realization Spots
7.1. Realization Spots are the entities with which the Directives are placed. For the purposes of Directives for the Binary Options, some third Financial Institution(s) will be the Realization Spot and not the Firm. A register of these financial institution(s) will be made known to Clients in a durable medium or may be publicized on the main website of the Firm. The register may be changed at the Firm’s discretion by giving at least one business day prior notice to the Clients.
7.2. The Client admits that the transactions entered in Binary Options with the Firm are not undertaken on a recognized exchange, rather they are undertaken over the counter (OTC) and therefore, the Client may subjected to greater risks than regulated exchange transactions.
8. Client’s Approval
8.1. By entering into an Agreement with the Firm for the provision of Investment Services, the Client is approving an application of this Policy on him.
9. Amendment of the Policy and Additional Information
9.1. The Firm reserves the right to review and/or amend its Policy and arrangements whenever it deems it appropriate without notice to the Client.
Should you require any further information and/or have any questions about conflicts of interest please contact us at support (at) exbino.com