NDD (No Dealing Desk) — client's orders are executed without dealer's intervention

The Company executes Client Orders in CFDs as a principal to principal towards the Client, i.e. the Company is the sole Execution Venue (as defined in Commission Directive 2006/73/EC implementing MiFID) for the execution of the Client’s Order. Hence, Client Trading Accounts offered by the Company may fall under a Dealing Desk Execution Model. When the Company executes Client Orders as a principal to principal, it faces market maker risk.

There are instances however, where the Company may decide at its own discretion to place an order for execution to a third party Execution Venue i.e. the Company is not the Execution Venue for the execution of the Client’s Orders. The Company transmits Client Orders or arranges for their execution with a third party (ies) known as Straight Trough Processing (STP). Such arrangement can be made to manage the Company’s risk and it shall not jeopardize the quality of execution of the Client’s order while all abovementioned best execution criteria/factors shall be followed/applied.

6.9. Model of Execution
In relation to each Transaction, the Company will execute the Client Orders on its own account basis. Under this model of execution, the Company is a counterparty against the Client in each Transaction and executes the Client Order as a principal to principal against the Client, i.e. the Company is itself the Execution Venue. The Company executes Client Orders according to the Summary Best Interest and Order Execution Policy, available on our Website.

Abusive Trading: Any of the following actions such as, but not limited to Sniping; placing “buy stop” or “sell stop” Orders prior to the release of financial data and news related to the Underlying Market/Asset; arbitrage;