Under the rules of the Financial Conduct Authority, Kerford Investments UK Limited (The Firm) is obligated to take reasonable steps to obtain the best possible result when executing orders on the client’s behalf, taking into account a range of factors. This process is referred to as providing the client with “Best Execution” and our policy governing this process is termed as Our Order Execution Policy.

Kerford Investments UK Limited’s Order Execution Policy describes:

  1. The Firm’s execution approach for carrying out orders from origination to execution
  2. The venue used by the Firm
  3. An explanation of how the different factors influence the firm’s execution approach and
  4. Why that approach is considered to deliver the best possible result.

This Policy, together with the documents set out below, as amended from time to time, form our agreement with you:

Client Agreement

Terms of Business

Conflicts of Interest

Risk Warning

The current version of this Policy (and also the current versions of the documents referred to above) can be found on our Website. Upon opening an account for each customer, the Firm will provide the customer with direct access to the prices on its trading platform (Kerford Trader) and the Firm’s Multi Trading facility (MTF). The prices on which any customer trades with the Firm will be the prices obtained through the Multi Trading Facility (MTF). These prices may differ from the prices that are displayed on the trading platform at the time that a customer places an order to trade with Kerford Investments UK Limited.

Kerford Investments UK Limited facilitates each order a customer places with the Firm by placing an identical order (“Back to Back Order”) on the MTF. Upon the Back to Back Order being matched or filled in whole on the MTF, the Firm shall open or close a trade on the customer’s account (“a Back to Back Trade”) at the same price and in the same size as the Firm’s Back to Back Order. This means that the Firm acts as principal on a matched basis only to every trade opened or closed on a customer’s account and is the sole execution venue for a customer’s orders.

If a customer has provided the Firm with specific instructions on how to execute his orders, as would be the case with contingent orders, the Firm will comply with its obligation to take all reasonable steps to obtain the best possible result when executing the customer’s order by following his instructions. To the extent that the customer’s instructions are incomplete, as would be the case with market orders, the Firm will follow this Policy for those parts or aspects of the order not covered by the customer’s instructions.

For orders that are not wholly covered by a customer’s specific instructions, the Firm shall take account of the following execution factors to deliver the best possible result when executing orders on the customer’s behalf. The Firm is also required to tell you the relative importance attached to each factor.

Best Execution Criteria

Kerford Investments (UK) Limited will determine the relative importance of the above Best Execution Factors by using its commercial judgment and experience in the light of the information available on the market and also taking into account the criteria described below:

  1. The characteristics of the Client, including the Client’s categorization either as Professional Client or Eligible Counterparty
  2. The characteristics of the Client’s Order;
  3. The characteristics of the financial instruments that are the subject of that Order;
  4. The characteristics of the execution venues to which that Order can be directed.

Execution Venues

Execution Venues are the entities with which the Orders are placed. For the purposes of Orders execution for different Financial Instruments, a third-party Financial Institution may be the Execution Venue and not the Firm itself. A list of these financial institution(s) will be made known to Clients in a durable medium upon request. The list may be changed at the firm’s discretion. The Client acknowledges that transactions entered in different financial instruments with the Firm are not undertaken on a recognised exchange, rather they are undertaken over the counter (OTC) and as such they may expose the Client to greater risks than regulated exchange transactions. Therefore the Company may not manage to have an Order executed, or it may change the opening (closing) price of an Order in case of any technical failure of the trading platform or quote feeds.

We will review this Policy at regular intervals to ensure we are continuing to comply with our regulatory obligations. If at any time we identify any deficiencies we shall take appropriate remedial action and where necessary shall amend this Policy to give effect to the action we have carried out. Amendments to this Policy shall be effective immediately. We shall wherever possible endeavour to give you advance notice of any changes we make to this Policy, but this may not always be possible. You can always find the latest published version of this Policy on our website.

By commencing trading with Kerford Investments UK Limited, you will be taken as having agreed to the contents of this Policy.