Order Execution Policy

This Policy forms an integral part of the Client Agreement. By opening an account and placing orders with the Company, you acknowledge that you have read, understood, and accepted the terms of this Order Execution Policy. This document should be read in conjunction with the Client Agreement, Risk Disclosure Statement, and all other applicable policies published by the Company.

1. Introduction

Definitecom Financial Brokerage Services LLC (the 'Company') is committed to acting honestly, fairly, and professionally in the best interests of its clients when executing orders. The Company is authorised and regulated by the Capital Markets Authority of the United Arab Emirates ('CMA').

This Order Execution Policy (the 'Policy') sets out the approach the Company takes to executing client orders and the steps it takes to achieve the best possible result for clients. It covers the execution factors the Company considers, the execution model it employs, and the circumstances in which execution conditions may vary.

This Policy should be read together with the Client Agreement, Risk Disclosure Statement, Fee Schedule, Commission & Charges Disclosure, and other relevant legal documents published by the Company. In the event of any conflict between this Policy and the Client Agreement, the Client Agreement shall prevail, subject always to Applicable Regulations.

By opening an account and placing orders with the Company, clients acknowledge and accept the terms of this Policy. The Company reserves the right to amend this Policy from time to time in accordance with applicable regulatory requirements.

2. Execution model

The Company offers trading in over-the-counter ('OTC') derivative products, including Contracts for Difference ('CFDs') and other financial instruments that may be offered from time to time under the Company’s regulatory licence.

Client orders are executed on an OTC basis through electronic trading systems. The Company serves as the execution venue for client transactions and is responsible for the receipt, processing and execution of client orders in accordance with its Order Execution Policy.

As the Company acts as principal and sole execution venue, clients should be aware that:

The Company sets its own bid and ask prices based on underlying market data obtained from external sources.
There is no exchange or regulated trading venue involved in the execution of client orders.
The Company’s interests may, in certain circumstances, conflict with those of the client. Such conflicts are managed in accordance with the Company’s Conflicts of Interest Policy.
Clients do not acquire ownership rights, voting rights, or any other interest in the underlying asset of a CFD transaction.

3. Best execution commitment

The Company takes all reasonable steps to obtain the best possible result for clients when executing orders, taking into account the execution factors set out below. For retail clients, the Company generally considers total consideration—being price and all associated costs—as the most important factor in achieving best execution.

The relative importance of each execution factor may vary depending on market conditions, the type of order, and the financial instrument being traded. The following table sets out the key execution factors considered by the Company:

Price: the best available bid/ask price derived from underlying market data, adjusted for spread.
Costs: all transaction costs including spreads, commissions, and financing charges applicable to the order.
Speed of execution: orders are processed electronically with minimal latency through the Company’s trading systems.
Likelihood of execution: the probability that an order will be executed at the requested price or the best price available considering market depth and liquidity.
Order size: larger orders may have a greater market impact and may be subject to wider spread / slippage or partial execution.
Nature of the order: the type of order (market, limit, stop) and any specific client instructions attached to the order.
Market conditions: prevailing volatility, liquidity, and other real-time market factors affecting pricing and execution quality.

The Company’s best execution obligation does not require it to achieve the best possible outcome on every individual transaction. Rather, it requires the Company to maintain and consistently apply arrangements designed to deliver the best overall result for clients over time.

4. Pricing and quotes

The Company derives its prices from underlying market data obtained from external liquidity providers and market data sources. For each instrument, the Company provides a Bid Price (the price at which clients may sell) and an Ask Price (the price at which clients may buy). The difference between the Bid and Ask price is the spread.

Clients should be aware of the following in relation to pricing:

Prices displayed on the trading platform may change rapidly due to market movements and conditions. The Company does not guarantee that a displayed price will be available at the time an order is submitted.
The Company may adjust pricing and spreads at any time to reflect market liquidity, volatility, trading conditions, and other relevant factors.
During periods of low liquidity, high volatility, or market disruption, spreads may widen significantly and prices may be less favourable than under normal market conditions.
Quotes, charts, and graphs provided on the trading platform may be indicative or tradable depending on the product and platform functionality. Charts and graphs are provided for informational and analytical purposes only and do not constitute an offer to transact at any displayed price. The Company is not obliged to execute any order at an indicative price.
A transaction is only formed when the Company accepts and executes a client’s order. The execution price may differ from the price displayed at the time the order was placed.

5. Order types

The Company may offer the following order types through its trading platforms. The availability of specific order types may vary depending on the instrument, platform, and prevailing market conditions. Clients should refer to the relevant product specifications for further details.

Market order: an instruction to buy or sell an instrument at the best available price at the time the order is executed. The execution price may differ from the price visible on the platform at the time of submission.
Limit order: an instruction to execute a trade at a specified price or better. Execution of a Limit Order is not guaranteed and depends on market conditions and price availability.
Stop-loss order: designed to limit potential losses by automatically closing a position when a specified price level is reached. Subject to market conditions and may be subject to slippage.
Stop order: a Stop Order is an instruction to execute a Market Order when the specified Stop Level is reached, with the order executed at the best available price, which may be better or worse than the Stop Level depending on market conditions, liquidity, and order size, and may be used to open or close a position with optional Take Profit and Stop Loss Orders attached.
Take-profit order: automatically closes a position when a specified profit target is reached. Subject to price availability and prevailing market conditions at time of execution.
Trailing-stop order: automatically adjusts the stop level as the market moves in the client’s favour. All stop-related orders remain subject to market conditions and may be executed at the next available market price.

Where a client provides specific instructions regarding the execution of an order, the Company will execute the order in accordance with those instructions where reasonably practicable. Clients acknowledge that specific instructions may prevent the Company from taking all steps necessary to achieve the best possible result in respect of the elements covered by those instructions.

6. Slippage, market volatility and price gaps

The Company does not guarantee that an order will be executed at the exact price requested by the client. Market prices may change between the time an order is placed and the time it is executed—this difference is known as slippage. Slippage may be either positive (execution at a more favourable price) or negative (execution at a less favourable price).

Slippage is most likely to occur during the following conditions:

periods of high market volatility
major economic data releases or news announcements
market opening and closing periods
conditions of low market liquidity
fast-moving markets with rapidly changing prices

Clients should also be aware that price gaps may occur when prices move significantly between two consecutive market quotations, for example, over weekends or during market closures. In such circumstances, orders (including stop-loss orders) may be executed at the next available market price, which may be significantly different from the requested or trigger price.

7. Market disruptions and exceptional circumstances

Certain events may affect the Company’s ability to execute orders under normal conditions. In such circumstances, the Company may take reasonable measures to maintain orderly trading conditions and to protect the interests of clients and the Company.

Events that may affect normal execution conditions include, but are not limited to:

extreme market volatility or abnormal market conditions
significantly reduced liquidity in relevant markets
trading halts or suspensions by underlying exchanges or markets
technical disruptions affecting the Company’s trading systems
connectivity failures affecting the Company’s access to liquidity providers
force majeure events as defined in the Client Agreement.

In such circumstances, the Company may take the following actions:

delay the execution of orders pending restoration of normal conditions
execute orders at the next available market price
reject orders that cannot be executed under prevailing conditions
widen spreads to reflect increased risk or reduced liquidity
suspend trading in specific instruments
Remove or cancel erroneous or wrongly executed trades from client accounts where the Company determines that such transactions resulted from a manifest error, system malfunction, or any other technical or operational failure, and reverse any related positions or credits applied to the client’s account as a result of such incorrect execution.

Where the Company takes any of the above actions, it will do so in accordance with the Client Agreement and applicable regulations, and will endeavour to notify affected clients where reasonably practicable.

7. Market disruptions and exceptional circumstances

Events that may affect normal execution conditions include, but are not limited to:

extreme market volatility or abnormal market conditions
significantly reduced liquidity in relevant markets
trading halts or suspensions by underlying exchanges or markets
technical disruptions affecting the Company’s trading systems
connectivity failures affecting the Company’s access to liquidity providers
force majeure events as defined in the Client Agreement.

In such circumstances, the Company may take the following actions:

delay the execution of orders pending restoration of normal conditions
execute orders at the next available market price
reject orders that cannot be executed under prevailing conditions
widen spreads to reflect increased risk or reduced liquidity
suspend trading in specific instruments
Remove or cancel erroneous or wrongly executed trades from client accounts where the Company determines that such transactions resulted from a manifest error, system malfunction, or any other technical or operational failure, and reverse any related positions or credits applied to the client’s account as a result of such incorrect execution.

8. Margin requirements and position liquidation

Clients are responsible for maintaining sufficient margin in their trading accounts at all times to support their open positions. The Company may reject orders where sufficient margin is not available.

If account equity falls below the applicable margin requirements, the following may occur:

The Company may issue a margin call requesting the client to deposit additional funds. The Company is not obliged to issue a margin call prior to taking any other action.
The Company may automatically close one or more open positions without prior notice to the client in order to reduce the Company’s risk exposure.
Positions may be closed in any order the Company deems appropriate, including in circumstances involving market disruption or pricing anomalies.

Current Margin Call and Stop-Out levels are available through the Company’s trading platform and website and may be amended from time to time in accordance with applicable regulations and the Company’s risk management policies.

9. Settlement and no physical delivery

All transactions offered by the Company are cash-settled. The Company does not provide physical delivery of any underlying asset. Clients should be aware of the following:

Clients do not acquire ownership rights, voting rights, dividends (except where cash adjustments are made), or any other proprietary interest in the underlying asset of a CFD or other derivative transaction.
Profits and losses are calculated by reference to the change in price of the underlying instrument and are reflected in the client’s trading account upon closure of the relevant position.
Overnight positions may be subject to financing charges or credits (swap/rollover charges), as set out in the Fee Schedule, Commission & Charges Disclosure.
All cash settlements are processed in accordance with the Company’s standard operational procedures and the Client Agreement.

10. Monitoring and review

The Company regularly reviews its execution arrangements and this Policy to ensure that it continues to achieve fair and consistent execution outcomes for clients. The Company monitors execution quality on an ongoing basis, including:

regular review of pricing sources and liquidity provider arrangements
analysis of execution quality metrics including slippage, fill rates, and order rejection rates
assessment of whether execution arrangements remain appropriate in light of changing market conditions and regulatory requirements
review of client complaints relating to order execution.

The Company may amend this Policy from time to time to reflect changes in market conditions, regulatory requirements, technology, or business operations. Any material changes will be communicated to clients in accordance with applicable regulations and the Client Agreement. Clients are encouraged to review this Policy periodically.

11. Conflicts of interest

As the Company acts as principal and counterparty to client transactions, potential conflicts of interest may arise. For example, the Company may benefit financially in circumstances where a client incurs a trading loss. The Company manages such conflicts in accordance with its Conflict of Interest Policy, which is available on the Company’s Website.

The existence of a conflict of interest does not, in itself, mean that the Company has failed to achieve best execution. The Company is committed to treating all clients fairly and to managing conflicts of interest transparently and in accordance with applicable regulatory requirements.

12. Client responsibilities

Clients are responsible for understanding the terms of this Policy and the risks associated with trading in OTC derivative products. In particular, clients should:

Ensure they maintain sufficient margin in their accounts at all times to support open positions.
Monitor their open positions and account equity on a continuous basis.
Ensure that their contact details and communication preferences remain up to date so that they can receive time-sensitive notifications from the Company.
Review confirmations and account statements promptly and notify the Company of any errors or discrepancies within five (5) business days of receipt.
Seek independent financial and legal advice if they are uncertain about any aspect of this Policy or their trading activity.

13. Contact and further information

Clients who have any questions regarding this Order Execution Policy or the execution of their orders may contact the Company through the contact details published on the Company’s Website or through the Account.

Complaints relating to order execution should be submitted in accordance with the Company’s Complaints Handling Procedure, which is available on the Company’s Website and within the Account.

This Order Execution Policy is issued by Definitecom Financial Brokerage Services LLC, a company regulated by the Capital Markets Authority of the United Arab Emirates. This document is intended for informational purposes and does not constitute investment advice. The Company reserves the right to amend this Policy at any time in accordance with applicable regulatory requirements.