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Order Execution Policy

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"Spotoption Exchange Ltd , a Cyprus Investment Firm located in Limassol Cyprus, is the first company in the EU to be granted a financial services license (CySEC License No. 170/12)"

ORDER EXECUTION POLICY

1. Purpose
The purpose of this policy is to establish effective arrangements for obtaining, when Spotoption Exchange Ltd Limited, hereafter the “Company”, is executing clients’ orders, the best possible result for its clients.
This document aims to set out those arrangements and to ensure compliance with legislative requirements and the departmental and general procedures, which are set within its Internal Procedures Manual.
This policy shall be read in conjunction with Dealing on Own Account Manual of the Company’s Internal Procedures Manual.

2. Legal Framework
In accordance with the Investment Services and Activities and Regulated Markets Law of 2007, Cypriot Investment Firms (hereafter the “CIFs”) must take all reasonable steps to obtain, when executing orders, the best possible result for their clients taking into account price, costs, speed, likelihood of execution, size, nature or any other consideration relevant to the execution of the order. Nevertheless, whenever there is a specific instruction from the client, the CIFs shall execute the order following the specific instruction.
In addition, CIFs must establish and implement an order execution policy to allow the CIF to obtain, for its clients’ orders, the best possible result.

3. Policy

Senior Management reviews the policy on an annual basis or / and whenever a material change occurs that impacts the Company’s ability to continue offering best execution of its clients’ orders using the Company’s trading platform.

The Company proceeded to the establishment and maintenance of an Order Execution Policy, in order to ensure compliance with the obligation to execute orders on terms most favourable to the clients and to achieve the best possible results for its clients, taking into consideration its clients’ ability, needs and trading policies, where applicable and possible.
The policy outlines the process that the Company follows in executing trades and assure taking all reasonable steps to consistently obtain the best possible result for clients through its order execution policy. It is noted however that when executing an order following a specific client instruction, the Company will execute the order in line with those instructions and will consider that it has discharged its best execution obligations. The Company operates as the counterparty to every customer’s trade, so if a customer chooses to deal with the Company to open position in a market the position can only be closed by dealing again with the Company. 3.1.Execution of transaction The Company offers the following binary option trading products: 1. Standard Binary Options
The Trading platform will be providing the clients with various options to trade and will also provide option conditions and pay out. The client will be able select the underlying asset and expiry time. The client can submit a trade by clicking the CALL or PUT button and select the amount she/he wish to trade. The applicable pay-out is paid to the client if the option expires in-the-money.
2. One Touch Binary Option
With One Touch options, the clients need to forecast if any asset will touch any set strike at its expiration. In the event the clients forecast correctly, as well as the price of the actual asset touches the particular strike price at the time of termination, the client will end up in-the-money and additionally get a pre-determined pay-out, generally somewhere between 250-400%.
3. Tailor Made Binary Options
The clients can create their own binary options by using the Options Builder function of the trading platform. The clients can select the underlying asset, expiration time, pay-out ratio, investment amount and submit a trade by clicking the CALL or PUT button. The applicable pay-out is paid to the client if the option expires in-the-money.

4. 60 Seconds Binary Option
60 Seconds Binary Options are options that have fixed expiry time of 60 seconds and payout ratio. The clients select the underlying asset and submit a trade by clicking the CALL or PUT button. The applicable pay-out is paid to the client if the option expires in-the-money.
For all binary options described above, the balance of the client will be checked automatically by the platform and will proceed to accept or reject the trade accordingly. Moreover, the clients will have the choice to cancel the trade for a period of at least 2 seconds after clicking the CALL or PUT button (cancelling the trade will not affect the client’s trading balance and the funds will be returned to the trading account).
3.2.Execution Factors
The Company, when managing client’s orders takes into account various execution factors, provided that there are no specific instructions from the client to the Company about the way of execution of the orders. The execution factors include:
 Price
 Speed and likelihood of execution
 Costs or commissions
 Size and nature of the order
 The current liquidity for the relevant instrument
 Market conditions and variations
 Execution capability
 Any other direct consideration relevant to the execution of the order
3.3.Execution Venues
The Company shall be the sole execution venue for the execution of its clients’ orders.
3.4.Financial Instruments
The financial instruments offered to clients are only binary options. The details of these financial instruments are available to the clients through the Company’s website or upon their request.
3.5.Pricing
The Company sets the prices to be used in binary options trading. The pricing rules set by the Company are:
 Pricing is allowed only before option purchasing, no manipulation on the option offering is allowed when the trade is being executed or after.
 The automated risk software should not act in any case against the customer in trade execution regardless of the pricing status.
 All traders will be offered the same price for any given option.

 Pricing should affect entry price only and not the expiry price.
3.6.Conclusion
Appropriate information is provided to the client on the content of the execution policy. The prior consent of the clients is obtained regarding the documented order execution policy to be followed. In addition, a clear and prominent warning is disclosed to the Company’s clients (within the Client Agreement) that any specific instruction from a client may prevent the Company from taking the steps that is has designed and implemented in its execution policy for obtaining the best possible result for the execution of those orders in respect to the elements covered by those instructions.
Adequate information is provided to the clients through this policy in relation to the factors that are taken into consideration by the management when handling clients’ orders. Also, the policy is reviewed periodically by the Company and the clients are informed accordingly in relation to any material changes.
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