Best Execution

Introduction

The Markets in Financial Instruments Directive II (“MiFID II”) requires us to establish and implement an Order Execution Policy and to provide our clients with a copy of that policy detailing the execution arrangements that we use to comply with our duty to give our clients best execution.

This policy is issued pursuant to, and is in compliance with, the rules of the Financial Conduct Authority and MiFID II.

Best Execution refers to our obligation as a firm to execute orders on behalf of clients to ensure that the prices those orders receive reflect the optimal mix of price improvement, speed and likelihood of execution. This policy describes Acetop’s approach to best execution and describes the main factors that Acetop evaluates to determine the best way to execute an order on behalf of the client.  It should be read in conjunction with our general Terms and Conditions of Business (“Terms”), this Order Execution Policy forms part of our Terms.

Our commitment to provide you with ‘best execution’ does not mean that we owe you any fiduciary responsibilities in respect of order execution over and above the specific regulatory obligations placed upon us or as may be otherwise contracted between us.

Outline of the Policy

In accordance with regulatory requirements set out by the Financial Conduct Authority (“FCA”), we have a general duty to act honestly, fairly and professionally, taking into account your best interest. We are therefore required to provide you with details regarding the sufficient steps we take to achieve what is called “best execution” when executing orders on our client's behalf in relation to financial instruments. This means that we will have in place policies and procedures which are designed to obtain the best possible execution result, subject to and taking into account the nature of our client's orders, the priorities our client places upon us in filling those orders and the market in question and which provide, in our view, the best balance across a range of sometimes conflicting factors.

We will also take into account our client's dealing profile, the nature of the dealing service our client requires of us and the specific and general instructions given to us by our client which may prioritise how we are to fill our client orders.

Execution Service

We provide execution services in Contracts for Difference (“CFDs”) and Spread Betting (“SB”). In providing you with financial products and services we, as your counterparty, act as a principal only and therefore represent the sole execution venue to which you have access and only at a price set by us.

Execution Factors

In considering how we might achieve the best possible result for your order, we will take into consideration a range of different factors which include not just price, but also other elements such as the cost of the transaction, the need for timely execution, the liquidity of the market (which may make it difficult to execute an order), the size of the order and the nature of the financial transaction including whether it is executed on a regulated market or over-the-counter.

Price

Price is the most important factor in relation to achieving best execution for the client. Acetop have access to multiple venues (i.e. Liquidity provider) to ascertain the best price for the underlying instrument or reference contract.

Having determined a market price, we make adjustments to take into account our own risk management procedures to form the Acetop mid, bid and offer market price. As a result of this methodology, the Acetop mid, bid and offer market price may not be the same as the market price for the underlying instrument or reference contract but will be derived from those market prices. Acetop constantly review our venues and will try to add more liquid venues that improve our price and reduce client’s cost.

Cost

We attach high importance to costs in relation to achieving best execution. We are clear and transparent about our spreads and commissions for all our products, please note that you can see full product specifications on our website. https://www.acetop.uk/trading/costs.html

Likelihood of execution

When executing through our platform, our prices are continuously updating, clients have the ability to trade immediately and with a very high degree of certainly, however under extreme market conditions, there may be delays in speed of execution. In most circumstances, your transaction can be executed provided you have enough margin available on your account.

On rare occasions, Acetop may provide a partial fill of a transaction request as an alternative to an outright rejection. We will never partially fill your order as an alternative to filling it in its entirety.

Size & Nature of the order

Size of the order is also an important factor to determine our best execution. We set minimum and maximum sizes for instruments that we trade, which can be found on our website via products specification.

We normally provide certainty of execution for orders you place for a quantity that is greater than our minimum quantity and lower than our maximum quantity. Where clients wish to execute a trade where the size exceeds our maximum quantity size, they can contact our dealing desk to agree a trade with our dealers over the phone.

Slippage

Slippage is where the execution price is better (Positive Slippage) or worse (Negative Slippage) than the price requested by the client, depending on market conditions and volatility. Slippage can occur on Stop Loss orders, Take Profits and other types of Orders. Acetop does not benefit from slippage and does not guarantee the execution of Client orders at the price specified because of slippage.

Speed

All speeds of executed trades are recorded in milliseconds. Acetop uses this information to monitor the quality of execution on a monthly basis and includes mean and median times within table 8 of the RTS 27 quarterly reports.

Order handling

Acetop financial will process 100% of client active orders without any manual intervention.

Your order, when placed through the trading platform, will be executed in accordance to the order type below:

• Market Order - It will be filled at the prevailing market price once we have received your order
• Limit/Stop Order - The order will normally be filled at the price or very close to the price requested by you, however in the likely event that the price has moved, your order may be filled at a different price than that available at the time.
• Take Profit – This is an order to realise profit. Once the market reaches ‘take profit price,’ the order is triggered and treated as a ‘limit order’. If it is not triggered, it will remain in the system until a later date.

Should we receive multiple orders at the same time, we may aggregate the orders and allocate the resulting fills as the aggregate order is executed. This may mean that we will provide you with partial fills at different prices or a single fill at an average price.

If your order is made over the telephone, then assuming there is no ‘price error’, your transaction will be executed at the price quoted and confirmed by the dealers or as per the instructions left by you.

Specific Intructions

Where you give us specific instructions as to the execution of an order, those instructions will take precedence over this Order Execution Policy which may prevent us from taking the steps we would otherwise take to obtain the best possible result for you in respect of any element of the order covered by the instructions.

For most of the products/instruments that we provide, we may (subject to our Terms and Conditions) accept an order from you to execute a trade in an instrument at such time as the price on the relevant market has risen or fallen to an order price specified by you. Orders are often attached to open positions, either to be triggered in the event of an adverse market move, in which case they are known as stop-loss orders, or to be triggered by a favourable market move to allow profits to be taken. These orders are triggered for execution based upon our price.

In most cases, when an order is triggered it will be executed at or very close to the specified order price but this is not guaranteed and the execution price may be markedly different to the specified order price as a result of a price movement in the underlying instrument.

If any market gaps from one quoted price to another due to an announcement of market sensitive information (such as an economic data release), then your order will be filled at the next available price.

Please note that should you give specific instructions with your order, we will follow those instructions. However, you should be aware that this may prevent us from taking the steps we have put in place and implemented to obtain ‘best execution’ in relation to the matters covered by your instructions. We further recognise that there may from time to time be circumstances for some clients, instruments or markets where other factors may be deemed to have a higher priority.

In the absence of express instructions from the client, we will exercise our own discretion in determining the factors and their relative importance that we need to consider for the purpose of providing our client with “best execution”.

Professional Clients

If you have been categorised by Acetop as a Professional Client, we recognise that you will be replying on us to provide best execution in line with this policy. There may be certain circumstances where the execution factors will differ to retail clients.

Monitoring & Review

We will regularly monitor our order execution arrangements as well as the quality of both our execution and that of third parties to whom Acetop have commissioned to execute its orders. This will enable us to identify and implement changes to our policy and execution arrangements as necessary. In general, this Policy shall be reviewed annually and Acetop shall notify clients of any material changes to this policy and execution arrangements by posting an updated version of this policy on its website.

Consent

Regulations require that we obtain your prior consent to this Policy. By continuing to use Acetop’s services, Clients shall be deemed to have consented to the contents of this Policy which is in force at the moment the Client’s instructions are received by Acetop.

Force Majeure & Other events

Client’s orders may not be received, or may not be executed in accordance with the policy, due to situations beyond our reasonable control, including disaster, abnormal market conditions, regulatory requirements, etc. We will not be bound to provide best execution in such circumstances. During such circumstances, Acetop may execute orders in a method that differs from the method selected pursuant to the Order Execution Policy. In the event of such a case, Acetop endeavours to execute orders on the best terms available at that point.

Venues

Acetop Financial Limited acts as the execution venue for all CFD orders and the clients that are contracted with us on that basis. Acetop will take the sufficient steps to consider the execution factors upon which to consistently achieve the best possible result for the execution of orders. Though we view price and cost to the client as an important factor, we also consider how other execution factors are affected, such as likelihood of order acceptance, speed of processing, and financial soundness.

Acetop may seek to manage risk and choose to hedge part or all of your contracts, which is an approach that may result in reduced execution costs and market price impact for our clients. The below lists the venues which we may consider and which may be updated from time to time;

Our Products	Our Liquidity Providers
CFDs & Spread Betting	Swissquote Bank SA (H6IQ3SWWWBLDBI06ZX04) IG Markets Limited (21380017XKSVQ3LC3V75)

RTS 28

MiFID II oblige us to take all sufficient steps to achieve the best possible result on a consistent basis. On an annual basis, we publish the following top five execution venues that we relied on within the given years;

Acetop Financial Limited RTS 28 - 2024

Additionally, we assess the quality of execution that we provide each year, and make them publicly available;

Quality of Execution Report 2024