1. General Information

IBR-Global Markets Ltd is a registered trading name of IBR-Global Markets Ltd. A company registered by the Corporate Affairs Commission under number 1322846. IBR-Global Markets Ltd has established this policy along with other arrangements to meet our overarching obligation to take all reasonable steps to obtain the best possible result for our Clients.

IBR-Global Markets Ltd has an obligation to provide its Clients with appropriate information on this Policy. In order to comply with this obligation, the firm will make this Policy available to Clients upon written request. IBR-Global Markets Ltd.’s Execution Policy forms part of our Client Agreement and as such, by agreeing to the Client Agreement, you are agreeing to the terms of our Order Execution Policy.

This policy applies equally to trades executed for both Individual and Corporate Customers. When IBR-Global Markets Ltd makes a decision to deal, we will carry out the trade by executing the order directly in the market ourselves.

The price feed streamed on the trading platform consists of liquidity from various bank and non-bank providers to ensure the Client has the best execution possible.

2. IBR-Global Markets Ltd’s Best Execution Obligations

IBR-Global Markets Ltd provides Portfolio Management on leveraged (margin) trading, on an execution-only basis for its Client’s in Forex and CFD trading.

It is IBR-Global Markets Ltd’s decision as to what markets (“Trading Instrument”) to offer its clients and we will deal with you as principal, trading on client behalf with two-way price quotes.

As such, every dealing executed by IBR-Global Markets Ltd is quoted as a derivative of the underlying market and we are the only execution venue to which you have access through us.

Under the OXO (Orders-Crossing-Orders) ECN model, certain Brokerage (“Your Designated Broker”) Qualified Participants are able to provide liquidity in competition within the interbank pricing pool. Such Qualified Participants hold collateral directly with your broker (and not vice versa) to ensure that funds are protected under strict client funds procedures. To qualify, Qualified Participants must be financial institutions that have met the necessary capital requirements and have the sophisticated technological means to provide the required streaming pricing.

IBR-Global Markets Ltd will act in accordance with the best interests of our Clients when placing orders with other entities for execution. In complying with this duty IBR-Global Markets Ltd must take all reasonable steps to obtain the best possible result for its Clients taking into account the execution factors.

The execution factors are: price, costs, speed, likelihood of execution and settlement, size, nature, and any other consideration relevant to the order.

The relative importance of these factors must be determined by reference to the “execution criteria” and, for clients, the requirement to determine the best possible result in terms of the total consideration (see below). The execution criteria are as follows:

(i) the characteristics of the Client including their categorization based on risk tolerance;

(ii) the characteristics of the Client order;

(iii) the characteristics of the financial instrument that are the subject of that order;

(iv) the characteristics of the execution venues to which that order can be directed.

When IBR-Global Markets Ltd executes an order on behalf of a Retail Client, the best possible result must be determined in terms of the total consideration, representing the price of the financial instrument and the costs related to execution, which must include all expenses incurred by the Client which are directly related to the execution of the order. These will include the execution venue fees, clearing and settlement fees and any other fees paid to third parties involved in the execution of the order.

While IBR-Global Markets Ltd will seek to ensure that the prices displayed are competitive at the time of market execution, we are not able to give a warranty, express or implied, that the bid and offer prices displayed on brokers trading systems always represent the best prevailing market prices for investors. Brokers quoted prices may reflect market volatility or additional costs and charges which may result in an increase in the spread as well as per transaction.

a) Price: IBR-Global Markets Ltd takes the underlying market price of the derivative it is quoting and then applies an algorithm to this price to achieve its own market price. The underlying feed that IBR-Global Markets Ltd uses may be from one source in the case of FX from several feeds. Where several feeds are used the best bid and offer combinations are used to maintain tight spreads at all times.

b) Costs: Our market price will often be different to the underlying as it may also include commissions or financing.

c) Liquidity: The price made by IBR-Global Markets Ltd, similar to the underlying market, is usually good in up to a certain size. In order to maintain additional liquidity, a different spread may be applied to the price provided in the underlying market.

d) Speed of execution: In order to facilitate the speed of execution IBR-Global Markets Ltd has imposed a maximum deal size on every market. This limit is regularly monitored and takes into consideration many factors including liquidity and volatility to determine an amount that we are confident to execute without referral to speed up execution.

Other Factors: While the above four factors are considered by IBR-Global Markets Ltd to be the most important in our best execution policy, there are many other situations which can arise leading to price variations.

a) Some markets which are executed by IBR-Global Markets Ltd are done so outside of normal market hours, and as such are known as ‘grey markets’. In these situations, while every effort is made to keep prices and spreads consistent, this may not always be possible during particular volatile periods or during periods of illiquidity in corresponding markets.

b) Financing charges made by IBR-Global Markets Ltd are fair, competitive and transparent. These may include fees required to roll over open positions, and shall be disclosed to you on our website.

c) There may be situations, through third party introductions or through partnership deals with affiliated companies that a commission or other income generated from investors trade is shared with third parties. In such circumstances this will be made abundantly clear to the client by the party concerned and this information is available on request.

3. IBR-Global Markets Ltd’s Strategy

Monitoring:

IBR-Global Markets Ltd will monitor the effectiveness of its order execution arrangements, including this Order Execution Policy to identify and, where appropriate, correct any deficiencies.

Review:

We will review our order execution arrangements and this Order Execution Policy at least annually or whenever a material change occurs that affects our ability to obtain the best result for the execution of orders on a consistent basis using the venues included in this Order Execution Policy.

Consent:

IBR-Global Markets Ltd is required to obtain your prior consent to our order execution policy. You will be deemed to provide such prior consent prior to dealing with us.

4. Execution Venue

Execution Venue means the firm directly executing the orders. In this instance IBR-Global Markets Ltd is the Execution Venue who is quoting prices which are provided to IBR-Global Markets Ltd by: (i) top tier global banks, (ii) non-bank liquidity providers in the wholesale foreign exchange markets, and (iii) OXO ECN Qualified Participants, that the firm believes will provide the best available prices to its clients on a consistent basis.

IBR-Global Markets Ltd provides execution-only trading and services for its Clients in Foreign Exchange, and CFD trading. IBR-Global Markets Ltd does not offer any advice and does not offer equity share trading in its CFD offerings. It is the decision of IBR-Global Markets Ltd’s as to what markets it offers its clients and it does so, as a broker. As such, every execution offered by IBR-Global Markets Ltd is quoted as a derivative of the underlying market and we are the only execution venue to which you have access through us.

5. Monitoring & Review

This policy along with all effective arrangements will be reviewed annually or whenever a material change occurs that affects the firm’s ability to continue to obtain the best possible result for our Clients.

On a regular and ongoing basis, IBR-Global Markets Ltd shall monitor the effectiveness of this policy and assess the quality of the best order execution and ensure we are providing the best possible result for our Clients. Any deficiencies in our arrangements or within this policy will be corrected and Clients will be notified of any material changes.