1.6.1. Execution of Orders
When executing orders on behalf of clients the Company would be dealing as a riskless principal, meaning that the Company interposes itself between the buyer and the seller to the transaction in such a way that the Company never gets exposed to market risk throughout the execution of the transaction, with both sides executed simultaneously, and where the transaction is concluded at a price where the Company makes no profit or loss, other than a previously disclosed commission, fee or charge for the transaction. The Company would deal as principal with its client and at the same time, and on the same terms, enter into a transaction as a principal with a counterparty.

1.6.2. Dealing on Own Account
We may also deal as principal with the client (ie executing the order against the Company’s proprietary capital), for example where the client has accepted a quote provided by us. In those circumstances, whether we owe best execution will depend on whether the client is legitimately relying on us to protect his interests in relation to the pricing and other elements of the transaction.

The Company may choose to act as market maker in instruments by quoting prices at which it is prepared to deal with the Client. The prices quoted by the Company may be different to those available on a regulated market or MTF.

5.8. The Company may execute orders internally.
These orders will only be internalised when it is determined, in accordance with this Policy and taking into account potential conflicts of interest and the Execution Factors, that the Company is the appropriate Execution Venue in respect of the Client order. Therefore, orders will be internalised when, after due consideration of the above factors, the Company’s internal execution is expected to provide the best result for the Client.

ii. When the Company places a Client order with a liquidity provider for execution it remains the responsibility of the Company (achieved through careful selection and ongoing monitoring of the respective liquidity providers) to ensure that the Client obtains the best possible result on a consistent basis.

“SCALPING”: a financial transaction is considered as scalping when the purpose of the trade made by the customer, is not the investment on the considered financial product or taking a position on the financial market, but only a tentative to take advantage from an IT latency time or a technological inefficiency or a bug of the IT infrastructure of the licence holder.
The trading behaviour of scalping as defined above is considered a breach of the Company’s Terms of Business.