advanced COMPLIANCE
ORDER EXECUTION POLICY
Advanced Markets (UK) Limited outlines its execution standards and procedures to ensure clients receive the best possible results.
THIS POLICY IS SUBJECT TO PERIODIC REVIEW AND UPDATES IN LINE WITH FCA AND MiFID II REQUIREMENTS.
INTRODUCTION
Advanced Markets (UK) Limited (the “Company”) is authorised and regulated by the Financial Conduct Authority (“FCA”). The Company operates this Order Execution Policy (the “Policy”) in accordance with the requirements of the Markets in Financial Instruments Directive 2014/65/EU (“MiFID II”) and the applicable FCA Rules.
The Company has a general obligation to conduct its business with clients honestly, fairly, and professionally and to act in their best interests when executing transactions. In accordance with this duty, the Company must take all sufficient steps to obtain the best possible result (“best execution”) for its clients when executing orders on their behalf.
This Policy explains the arrangements through which the Company seeks to meet its best execution obligations. It does not create or extend any fiduciary duties or responsibilities beyond those required by regulation or by contract between the Company and its clients.
The Company acts as a matched principal broker, executing client orders across a range of financial instruments it offers, including but not limited to futures, options, forward contracts, contracts for difference (CFDs), and other derivative contracts relating to securities, currencies, commodities, interest rates, or yields. All trades are immediately matched through a panel of carefully selected liquidity providers. The Company does not trade for its own account and will only execute transactions on the basis of a clear and firm client order.
Subject to any specific client instructions, the Company will take all sufficient steps to achieve the best possible result for clients, taking into account the relevant Execution Factors described below. The relative importance of each Execution Factor will be determined using the Company’s commercial judgment and experience in light of prevailing market information.
EXEMPTION FROM THE PROVISION OF BEST EXECUTION
Notwithstanding the general principles set out above, the Company is not obliged to provide best execution in respect of transactions with clients who fall within certain regulatory exemptions.
In particular, where a client is classified as an Eligible Counterparty, the Company’s best execution obligations under the FCA Rules and MiFID II do not apply. Such clients are not entitled to best execution in respect of any services or transactions carried out with or for them.
CATEGORISATION OF CLIENTS
The Company conducts business only with per se and elective Professional Clients and with Eligible Counterparties, as defined under MiFID II and the FCA Rules.
The Company seeks to treat all clients equitably and to handle orders in a consistent manner. Once a client has been categorised for a particular type of instrument, that classification will generally remain in place for all transactions of that type. A client may, however, request a change to their categorisation for all business relationships with the Company.
Any such re-categorisation will be considered at the Company’s sole discretion and only in exceptional circumstances, subject to the Company’s consent. The Company reserves the right to decline to provide services where a re-categorisation request is made.
EXECUTION FACTORS AND CRITERIA
When executing client orders, the Company will take into account the following Execution Factors:
Price
Costs
Speed of execution
Likelihood of execution and settlement (liquidity)
Size of order
Nature of order
Type and characteristics of the financial instrument
Characteristics of the possible execution venues
Any other consideration relevant to executing the order
For most liquid instruments, total consideration (price and costs) will normally be the primary factor in determining best execution. However, the relative importance of other factors may vary depending on the circumstances of each transaction.
In particular, the relative weighting of each Execution Factor will depend on:
The categorisation of the client
Any special aims of the client in relation to executing the order
The characteristics of the order
The characteristics of the financial instruments
The characteristics of the venues (if more than one)
SPEED OF EXECUTION AND ORDER HANDLING
The Company places significant importance on the timely execution of client orders. It aims to process and execute orders immediately and, in most cases, instantaneously, subject to prevailing market conditions.
Factors outside the Company’s control, such as insufficient market liquidity or technical disruptions, may occasionally prevent immediate execution. The Company’s policy is to fulfil client instructions as promptly as possible whenever market conditions permit.
EXECUTION VENUES
The Company acts as the client’s primary venue of execution and does not operate as a market maker.
Subject to specific client instructions, the Company may transmit an order to a third-party broker, dealer, or entity (including affiliates) for execution at one or more of the following Execution Venues:
A Regulated Market
A Multilateral Trading Facility (MTF)
A Systematic Internaliser
Third-party investment firms or liquidity providers
Credit institutions
Non-EU entities performing equivalent functions
When selecting venues, the Company acts in the best interests of its clients, considering Execution Factors and Criteria. The Company’s list of liquidity providers is available upon request and is reviewed periodically.
TRADING OUTSIDE A REGULATED MARKET (RM) OR MULTILATERAL TRADING FACILITY (MTF)
Under FCA rules, the Company must obtain a client’s prior consent before executing orders outside an RM or MTF. By trading through the Company’s platform, clients provide this consent.
SPECIFIC CLIENT INSTRUCTIONS
Where a client provides specific execution instructions, the Company will execute the order accordingly. If the instructions apply only to part of an order, the Policy will apply to all elements not covered.
Clients should note that providing specific instructions may prevent the Company from taking steps that would otherwise achieve the best possible result.
CONFLICTS OF INTEREST
The Company takes reasonable steps to identify, prevent, and manage conflicts of interest.
Orders are sourced from multiple liquidity providers to ensure fair pricing. Client orders may be matched with orders from another Company client only where it is in the client’s best interest.
The Company does not direct orders to specific liquidity providers unless it is clearly beneficial to the client. Internal systems and controls are maintained to prevent and manage both potential and actual conflicts.
DETAILS OF EXECUTION
The Company maintains comprehensive records of all activities and actions related to client order execution. Upon request, it will demonstrate that an order has been executed in accordance with this Policy and regulatory requirements.
CONSENT
Clients should review this Policy alongside the Company’s Terms of Business, Client Classification Letter, and any other governing documents.
By executing the Company’s Terms of Business, the client is deemed to have read, understood, and consented to this Policy.
ANNEX – DEFINITIONS
Execution Venue means a Regulated Market (RM), a Multilateral Trading Facility (MTF), a Systematic Internaliser (SI), or any market maker or liquidity provider performing an equivalent function.
Multilateral Trading Facility (MTF) means a multilateral system operated by an investment firm or market operator which brings together multiple third-party buying and selling interests in financial instruments in a non-discretionary way.
Regulated Market (RM) means a multilateral system operated by a market operator which brings together multiple third-party buying and selling interests in financial instruments under non-discretionary rules, resulting in a contract.
Systematic Internaliser (SI) means an investment firm which, on an organised, frequent, and systematic basis, deals on its own account by executing client orders outside a regulated market or MTF.
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1, Unit 5, The Warehouse, Woolyard, 52-56 Bermondsey Street, London SE1 3UD
Phone Number
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