Best Execution

Acetop Financial Limited — Best Execution Policy

 

1. Introduction

The Markets in Financial Instruments Directive II (“MiFID II”) and the corresponding rules of the Financial Conduct Authority (“FCA”) require investment firms to establish, implement, and maintain an Order Execution Policy. This policy must set out the firm’s arrangements for ensuring the best possible execution results for client orders and be made available to clients prior to the provision of investment services.

This document constitutes Acetop Financial Limited’s (“Acetop”) Order Execution Policy (“the Policy”). It explains how we execute client orders, the factors we consider when executing those orders, and how we strive to comply with our regulatory obligation to act honestly, fairly, and professionally in the best interests of our clients.

The objective of this Policy is to ensure that Acetop takes all sufficient steps to achieve the best possible result for clients when executing orders or transmitting them for execution, taking into account the relevant execution factors as prescribed by MiFID II and the FCA Handbook (COBS 11.2A).

This Policy should be read together with our Client Agreement (“Terms”), as it forms an integral part of those Terms.

While Acetop is committed to achieving best execution, it should be noted that this commitment does not create any fiduciary obligation beyond those specifically imposed by applicable laws, regulations, or contractual arrangements between Acetop and the client.

 

2. Scope and Purpose

This Policy applies to the execution of client orders in Contracts for Difference (“CFDs”) and Spread Betting (“SB”) products offered by Acetop Financial Limited. It outlines the principles, execution arrangements, and monitoring processes that Acetop employs to achieve the best execution outcome on a consistent basis.

Acetop acts as principal in all transactions with clients. As such, Acetop is the sole execution venue available to clients, and all transactions are executed at prices quoted by Acetop. Clients therefore transact directly with Acetop, rather than on an exchange or through a third-party venue.

 

3. Regulatory Framework and Obligations

Under MiFID II and FCA COBS 11.2A, Acetop must:

• Take all sufficient steps to obtain the best possible result for clients.
• Establish and implement effective execution arrangements.
• Monitor the effectiveness of its execution policy and arrangements.
• Review and update this Policy at least annually or when a material change occurs.
• Obtain prior consent from clients to the execution arrangements described herein.

4. Execution Factors

When executing client orders, Acetop considers a range of factors to determine the best possible result. These include, but are not limited to:

1. Price – The price at which a transaction is executed.
2. Costs – All associated costs directly related to execution.
3. Speed – The time taken to execute the order.
4. Likelihood of Execution and Settlement – The probability that an order will be successfully executed and settled.
5. Size and Nature of the Order – The volume and specific characteristics of the transaction.
6. Market Impact and Liquidity – The availability of liquidity and potential influence of the order on market conditions.
7. Other Considerations – Any other relevant circumstances necessary to ensure fair and efficient execution.

The relative importance of these factors may vary depending on the client classification (Retail or Professional), the financial instrument concerned, and prevailing market conditions.

 

5. Execution Criteria

When determining the relative importance of the execution factors, Acetop takes into account the following criteria:

• The client’s classification (Retail or Professional).
• The characteristics of the client order (e.g., size, type, and purpose).
• The characteristics of the financial instrument.
• The characteristics of the execution venue or counterparty to which the order is directed.

 

6. Execution Venues

Acetop acts as the sole execution venue for client transactions in CFDs and Spread Betting instruments. In certain circumstances, Acetop may hedge positions or offset risk exposures with selected liquidity providers. These liquidity providers are subject to periodic review to ensure that they continue to meet Acetop’s standards for price competitiveness, execution speed, and financial soundness.

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

 

Acetop publishes its RTS 28 report annually, which details the top five execution venues used in the preceding year and provides a summary of the quality of execution achieved.

 

7. Price Formation and Costs

7.1 Price Determination

Acetop aggregates prices from multiple liquidity providers to derive a composite reference price for each instrument. Adjustments may be applied to reflect internal risk management considerations, resulting in Acetop’s quoted bid, mid, and offer prices.

These quoted prices may differ slightly from the underlying market due to factors such as liquidity, volatility, and operational costs.

7.2 Transaction Costs

Acetop maintains transparency regarding spreads, commissions, and overnight financing charges. Detailed product cost disclosures are available on our website:

https://www.acetop.uk/trading/costs.html

 

8. Likelihood, Speed, and Quality of Execution

Under normal market conditions, Acetop provides high-speed execution with prices updating continuously on our trading platform. However, during periods of high volatility or limited liquidity, execution times may increase, and slippage may occur.

Acetop continuously monitors execution speed and performance metrics, including average execution time (in milliseconds), and publishes these in our RTS 27 quarterly reports.

 

9. Order Handling and Types

Acetop executes 100% of active client orders automatically without manual intervention, in accordance with the following order types:

• Market Orders: Executed immediately at the prevailing market price.
• Limit/Stop Orders: Executed at or near the specified price; however, execution may vary in volatile conditions.
• Take Profit Orders: Triggered once the specified profit level is reached, functioning as a limit order thereafter.

Where multiple orders are received simultaneously, Acetop may aggregate them to improve overall execution efficiency. Partial fills may occur depending on available liquidity.

Orders placed via telephone are executed at the confirmed quoted price, provided no pricing error occurs.

 

 

10. Slippage

Slippage may occur when there is a difference between the requested order price and the executed price due to rapid market movements.

• Positive Slippage: Execution at a better price than requested.
• Negative Slippage: Execution at a worse price than requested.

Acetop neither benefits from nor manipulates slippage outcomes and does not guarantee execution at the exact requested price.

 

11. Specific Instructions

If a client provides specific instructions regarding the execution of an order, Acetop will execute the order in accordance with those instructions. However, such instructions may prevent Acetop from applying its standard procedures designed to achieve the best possible execution result.

Clients should be aware that specific instructions (e.g., a fixed execution price) may limit the ability of Acetop to obtain best execution.

 

12. Monitoring and Review

Acetop monitors its order execution arrangements on an ongoing basis to ensure their effectiveness. This includes:

• Regular reviews of execution quality and price competitiveness.
• Assessment of liquidity providers and counterparties.
• Identification and rectification of deficiencies in execution performance.

This Policy is reviewed at least annually, and any material changes will be communicated to clients via an updated publication on Acetop’s website.

 

13. Consent

By continuing to use Acetop’s trading services, clients are deemed to have read, understood, and consented to this Order Execution Policy in its most current form.

 

14. Force Majeure and Exceptional Circumstances

In the event of force majeure or abnormal market conditions — such as system failures, extreme volatility, or regulatory restrictions — Acetop may be unable to execute orders in accordance with this Policy. Under such circumstances, Acetop will act reasonably and take all feasible steps to execute orders on the best available terms at that time.

 

 

15. Professional Clients

Professional clients are presumed to have a higher level of market knowledge and experience. While Acetop remains committed to providing best execution, it may, where appropriate, apply different execution priorities or rely on the client’s judgment regarding execution preferences.

 

16. Reporting and Transparency

In compliance with MiFID II requirements, Acetop publishes the following reports annually:

• RTS 27 Reports: Detailing quantitative data on execution quality.
• RTS 28 Reports: Listing the top five execution venues by trading volume and summarising execution performance.

These reports are available on Acetop’s website.

Acetop Financial Limited RTS 28 - 2024

Quality of Execution Report 2024