1. Introduction
1.1 This Summary of the Best Interest and Order Execution Policy (“the Policy”) is
provided to you (our Client or prospective Client) in accordance with the Law as
subsequently amended from time to time. Pursuant to the Law, “the Company” is required
to take all sufficient steps to obtain the best possible result (best execution) on behalf of its
Clients either when executing Client orders or receiving and transmitting orders for
execution.
By opening a Trading Account you agree/consent to the fact that your Orders will be
executed outside a Regulated Market (e.g. Licensed European Stock Exchange) or a
Multilateral Trading Facility (e.g. European Financial Trading System) or Organised
Trading Facility “OTF”.

2. Scope
2.1. This Policy applies when executing Client Orders for the Client for all types of
Contracts for Difference (“CFDs”) offered by the Company.
2.2. This policy is also applicable when providing the service of Portfolio Management.

3. Best Execution Factors
3.1. When executing Orders, we take all sufficient steps to obtain the best possible result
(“Best Execution”) for our Clients, taking into account price, costs, speed, likelihood of
execution and settlement, size, market impact or any other consideration relevant to the
execution of the Order (“Best Execution Factors”).
Where the Company executes an order on behalf of a Client, the best possible result shall
be determined in terms of the total consideration, representing the price of the financial
instrument and the costs relating to execution, which shall include all expenses incurred
by the Client which directly relate to the execution of the order. For determining the
relative importance of the execution factors, the following criteria are taken into account:
1. The characteristics of the Client
2. The characteristics of the Client order;
3. The characteristics of Financial Instruments that are the subject of that order;
4. The characteristics of the Execution Venues to which that order can be directed.
The Company considers price and costs as the most important execution factors, followed
by speed, likelihood of execution and settlement, size and nature, and market impact. The
relative importance attached to these execution factors does not differ across the asset
classes traded by the Company.
(a) Price – Highest Importance:
For any given CFD, the Company will quote two prices: the higher price (ASK) at which
the Client can buy (go long) that CFD, and the lower price (BID) at which the Client can
sell (go short) that CFD. Collectively, the ASK and BID prices are referred to as the
Company’s prices. The difference between the lower and the higher price of a given CFD
is the spread.
Company’s Prices: The Company will quote to Clients the prices provided by the Execution
Venue (see Section 7 below). The Execution Venue calculates and provides its own tradable
prices for a given CFD by reference to the prices of the relevant underlying asset, which
the Execution Venue obtains from third party reputable external reference sources (i.e. price
feeders). The Company’s prices can be found on the Company’s trading platforms. The Company
updates its prices as frequently as the limitations of technology and
communications links allow.
The main way in which the Company will ensure that the Client receives the best price will
be to ensure that the calculation of the bid/ask spread is made with reference and compared
to a range of underlying price providers and data sources. The Company reviews regularly
or at least once a year its Execution Venue to ensure that relevant and competitive pricing
is offered.
Despite the fact that the Company takes every sufficient step to obtain the best possible
result for its Clients, it does not guarantee that when executing an Order its price will be
more favourable than one which might be available elsewhere.
Pending Orders: Such Orders as Buy Limit, Buy Stop and Stop Loss, Take profit for opened
short position are executed at the ASK price. Such Orders as Sell Limit, Sell Stop and Stop
Loss, Take profit for opened long position are executed at the BID price.
Certain ex-ante and ex-post quality checks are conducted by the Company to ensure that
prices obtained and subsequently passed on to Clients remain competitive. Such checks
include, but not limited to, reviewing system settings/parameters, comparing prices with
reputable price sources, ensuring symmetry of spread and checking the speed of price
updating.
If the price reaches an Order set by you such as: Stop Loss, Take Profit, Buy Limit, Buy
Stop, Sell Limit or Sell Stop, then these Orders are automatically executed. However, under
certain trading conditions it may be impossible to execute Orders (Stop Loss, Take Profit,
Buy Limit, Buy Stop, Sell Limit or Sell Stop) at the Client’s requested price. In this case,
the Company has the right to execute the Order at the first available price. This may occur,
for example, at times of rapid price fluctuations if the price rises or falls in one trading
session to such an extent that, under the rules of the relevant exchange trading is suspended
or restricted, or this may occur at the opening of trading sessions. The minimum level for
placing Stop Loss, Take Profit, Buy Limit, Buy Stop, Sell Limit and Sell Stop orders, for a
given CFD, is specified in the Client Agreement and/or the Company’s website.

(b) Costs – Highest Importance:
For opening a position in some types of CFDs the Client may be required to pay
commission or financing fees, the amount of which is disclosed on the Company’s website.
Commissions: Commissions may be charged either in the form of a percentage of the
overall value of the trade or as fixed amounts. More information on commissions can be
found on the Company’s website.
Financing Fee: In the case of financing fees, the value of opened positions in some types
of CFDs is increased or reduced by a daily financing fee “swap rate” throughout the life of
the CFD (i.e. until the position is closed). Financing fees are based on prevailing market
interest rates, which may vary over time. Details of daily financing fees applied are
available on the Company’s website.
For all types of CFDs that the Company offers, the commission and financing fees are not
incorporated into the Company’s quoted prices and are instead charged explicitly to the
Client account.
In addition, where the Company transmits orders for execution to another third party, the Client may be required to pay additional costs (whether Execution Venue fees or other fees
paid to a third party involved in the transaction), the amount of which is disclosed on the
Company’s website.
Note that the Company nevertheless may obtain a commission/inducement from its
Liquidity Provider in consideration for the transmission of Clients Orders for execution to
the Liquidity Provider. The Client has the right to contact the Company for more
clarifications in relation to these commissions.
Should the Company at any period of time decide not to charge such costs, it shall not be
construed as a waiver of its rights to apply them in the future, with prior notice to the Client
as explained in the Client Agreement found on the Company’s website. Such notice may
be sent personally to the Client and/or posted on the Company’s website.

(c) Speed of Execution – Highest Importance:
The Company places a significant importance when executing Client Orders and strives to
offer high speed of execution within the limitations of technology and communications
links. For instance, in cases where Clients are using a wireless connection or a dial up
connection or any other communication link that can cause a poor internet connection then
this may cause unstable connectivity with the Company’s trading platform resulting to the
Client placing his Orders at a delay and hence the Orders to be executed at better or worst
prevailing price offered by the Company.
(d) Likelihood of Execution – Medium Importance:
The Company arranges for the execution of Client Orders with third party (ies) (i.e.
Execution Venue); hence, execution may sometimes be difficult. The likelihood of
execution depends on the availability of prices of the Execution Venue(s). In some cases it
may not be possible to arrange an order for execution, for example, but not limited to, in
the following cases: during news times, trading session start moments, volatile markets
where prices may move significantly up or down and away from declared prices,
where there is rapid price movement, where there is insufficient liquidity for the execution
of the specific volume at the declared price, a force majeure event has occurred. In the event
that the Company is unable to proceed with an order with regard to price or size or other
reason, the order will not be executed. In addition, the Company is entitled, at any time and
at its discretion, without giving any notice or explanation to the Client, to decline or refuse
to transmit or arrange for the execution of any order or request or instruction of the Client
in circumstances explained in the Client Agreement found at the company’s website.
Since the Company transmits orders for execution to a third party (another Execution
Venue), the likelihood of execution depends on the pricing and available liquidity of
such other third party.
In order to improve speed and likelihood of execution the Company carries out certain exante and ex-post quality checks. Such checks include, but not limited to, symmetric slippage
checks, number of trades subject to slippage and comparing our average speed of execution
with industry standards.

(e) Likelihood of settlement – Low Importance:
The Company shall proceed to a settlement of all transactions upon execution of such
transactions. The Financial Instruments of CFDs offered by the Company do not involve
the physical delivery of the underlying asset, so they are not settled physically as there
would be for example if the Client had bought shares. All CFDs are cash settled.

(f) Size of Order – Low Importance: 

The actual minimum size of an order may be different for each type of Client Account. A
lot is a unit measuring the transaction amount and it is different for each type of CFD.
Please refer to the Company’s website for the value of minimum size of an order and each
lot for a given CFD type. If the Client wished to execute a large size order, in some cases
the price may become less favourable. The Company reserves the right to decline an Order
in case the size of the Order is large and cannot be filled by the Company or for any other
reason as explained in the Client Agreement found at the company’s website.
(g) Market Impact – Medium Importance:
Some factors may rapidly affect the price of the underlying instruments/products from
which the Company’s quoted price is derived and may also affect other factors listed herein.
The Company will take all sufficient steps to obtain the best possible result for its Clients.
The Company does not consider the above list exhaustive and the order in which the above
factors are presented shall not be taken as priority factor. Nevertheless, whenever there is
a specific instruction from the Client, the Company shall make sure that the Client’s order
shall be executed following the specific instructions.

3.2. Types of Order(s) in Trading in CFDs:
The particular characterizing of an Order may affect the execution of the Client’s Order.
Please see below the different types of Orders that a Client can be placed:
Market Order(s)
A Market Order is an Order to buy or sell a CFD as promptly as possible at the prevailing
market price. Execution of this Order results in opening a trade position. CFDs are bought
at ASK price and sold at BID price. Stop Loss and Take Profit Orders can be attached to a
Market Order. Market Orders are offered for all type of accounts.
Pending Order(s)
This is an Order to buy or sell a CFD in the future at the best available price once a certain
price is reached. The Company offers the following types of Pending Orders: Buy Limit,
Buy Stop, Sell Limit or Sell Stop Orders to trading accounts for CFDs.
A Pending order is an Order that allows the user to buy or sell a CFD at a pre-defined price
in the future. These Pending Orders are executed once the price reaches the requested level.
However, it is noted that under certain trading conditions it may be impossible to execute
these Orders at the Client’s requested price. In this case, the Company has the right to
execute the Order at the first available price. This may occur, for example, at times of rapid
price fluctuations of the price, rises or falls in one trading session to such an extent that,
under the rules of the relevant exchange, trading is suspended or restricted, or there is lack
of liquidity, or this may occur at the opening of trading sessions.
It is noted that Stop Loss and Take Profit may be attached to a Pending Order. Also, pending
orders are good till cancel. Pending Orders are offered for all type of accounts.
Take Profit
Take Profit Order is intended for gaining the profit when the CFD’s price has reached a
certain level. Execution of this Order results in complete closing of the whole position. It
is always connected to an open, market or a pending Order. Under this type of order, the
Company’s trading platform checks long positions with Bid price for meeting of this order
provisions (order is always set above the current Bid price), and it does with Ask price for
short positions (the order is always set below the current Ask price).

Stop Loss
Stop Loss Order is used for minimising of losses if the CFD’s price has started to move in
an unprofitable direction. If the CFD’s price reaches this stop loss level, the whole position
will be closed automatically. Such Orders are always connected to an open, market or a
pending order. Under this type of orders, the Company’s trading platform checks long
positions with Bid price for meeting of this order provisions (the order is always set below
the current Bid price), and it does with Ask price for short positions (the order is always set
above the current Ask price).
3.3. Execution Practices in CFDs
Slippage
You are warned that Slippage may occur when trading in CFDs. This is the situation when
at the time that an Order is presented for execution, the specific price showed to the Client
may not be available; therefore the Order will be executed close to or a number of pips
away from the Client’s requested price. So, Slippage is the difference between the expected
price of an Order, and the price the Order is actually executed at. If the execution price is
better than the price requested by the Client, this is referred to as positive slippage. If the
executed price is worse than the price requested by the Client, this is referred to as negative
slippage. Please be advised that Slippage is a normal element when trading in CFDs.
Slippage more often occurs during periods of illiquidity or higher volatility (for example
due to news announcements, economic events and market openings and other factors)
making an Order at a specific price impossible to execute. In other words, your Orders may
not be executed at declared prices.
Slippage may appear in all types of accounts we offer. It is noted that Slippage can occur
also during Stop Loss, Take Profit and other types of Orders (see Section 3.3.1. above). We
do not guarantee the execution of your Orders at the price specified. However, we confirm
that your Order will be executed at the next best available price from the price you have
specified under your Order.
3.4. Different Types of Trading Accounts in CFDs
The Company offers different types of Trading Account. In this respect, the initial
minimum deposit, the spreads, costs, size commissions, if any etc. may differ according to
each type of Trading Account. Further information regarding the different type of Trading
Accounts offered can be found on the Company’s website.

4. Best Execution Criteria
4.1. When executing Client orders, the Company takes into account the following criteria
for determining the relative importance of the Best Execution Factors referred in
paragraph 3 above:
(a) The characteristics of the Client
(b) The characteristics of the Client Order;
(c) The characteristics of the Financial Instruments that are the subject of that Order;
(d) The characteristics of the Execution Venue to which that Order is directed;
The Company determines the relative importance it assigns, in accordance with the
abovementioned criteria, to the Best Execution Factors by using its commercial judgment
and experience in light of the information available on the market and taking into account
the remarks included in paragraph 3. The Company assigns the following importance level For the purposes of delivering best execution and in cases where there is more than one
competing Execution Venue to execute an Order, in order to assess and compare the results
for the Client that would be achieved by executing the Order on each of the execution
venues (see Paragraph 7 below) that is capable of executing that Order, the Company’s own
commissions and costs for executing the order on each of the eligible execution venues
shall be taken into account in that assessment. The Company shall not structure or charge
commissions in such a way as to discriminate unfairly between execution venues.

5. Client’s Specific Instruction
5.1. Whenever there is a specific instruction from or on behalf of a Client (e.g. fills in the
required parts on the Company’s trading platform when placing an Order), relating to the
Order or the specific aspect of the Order the Company shall arrange – to the extent
possible – for the execution of the Client Order strictly in accordance with the specific
instruction.
WARNING: It is noted that any specific instructions from a Client may prevent the
Company from taking the steps that it has designed and implemented in this Policy to obtain
the best possible result for the execution of those Orders in respect of the elements covered
by those instructions. However, it shall be considered that the Company satisfies its
obligation to take all sufficient steps to obtain the best possible result for the Client.
5.2. Trading rules for specific markets or market conditions may prevent the Company from
following certain of the Client’s instructions.  6. Execution on Client Orders
6.1. The Company shall satisfy the following conditions when carrying out Client Orders:
(a) ensures that Orders executed on behalf of Clients are promptly and accurately
recorded and allocated;
(b) carries out otherwise comparable Client Orders sequentially and promptly unless
the characteristics of the Order or prevailing market conditions make this
impracticable, or the interests of the Client require otherwise;

7. Execution Venues
7.1. Execution Venues are the entities with which the orders are placed and executed.
Financial Institutions acting as Execution Venues are First Prudential Markets Pty Limited.
The list may be changed at the Company’s discretion by giving at least one business day
prior notice to the Clients. The Company evaluates and selects the Execution Venues based
on a number of criteria including such as (but not limited to) the following:
(a) the regulatory status of the institution
(b) the ability to deal with large volumes of Orders
(c) the speed of execution
(d) the competitiveness of commission rates and spreads
(e) the reputation of the institution
(f) the ease of doing business
(g) the legal terms of the business relationship
(h) the financial status of the institution
(i) various qualitative criteria such as clearing schemes, circuit breakers and scheduled
actions.
The Company places different relative importance on each of the criteria mentioned
above by using its commercial judgment and experience in the light of the information
available on the market.
The Company selects to work with those third party venues that enable the Company to
obtain on a consistent basis the best possible result for the execution of Client orders. Where
there is only one possible Execution Venue, best execution is achieved by execution on that
venue. Best execution is a process, which considers various factors, not an outcome. This
means that, when the Company is executing an order for a Client, the Company must
execute it in accordance with its execution policy.
The Company does not guarantee that the exact price requested will be obtained in all
circumstances and, in any event, the factors may lead to a different result in a particular
transaction.
7.2. The Client acknowledges that the transactions entered in Financial Instruments with
the Company are not undertaken on a recognized exchange/regulated market, rather they
are undertaken over the counter (OTC) and as such they may expose the Client to greater
risks than regulated exchange transactions/Orders.
7.3. The Company, before deciding which Execution Venues to use for Client orders, it
compares different Liquidity Providers and performs due diligence of them. Some of the
parameters that the Company evaluates, include the following:
 Pricing frequency – how many ticks per second does the Liquidity Provider
provides.

 Speed of communication/execution – How fast are the prices received/orders
executed.
 Occurrence of price freezes and frequency.
 Depth of liquidity – What is the liquidity provided by the Liquidity Provider.
 If dealing back-to-back is the overall cost (i.e. total consideration paid by Clients)
competitive compared to the industry.
 If dealing back-to-back symmetry of slippage should be evaluated in detail for every
order type.
In general, the Company places great significance on the choice of its Liquidity Providers
as it strives to offer, on a consistent basis, best execution to its Clients.
7.4. The Company randomly selects a sufficiently large sample of trades to ensure, with a
high statistical confidence level, that it constantly obtains and will obtain the best possible
results for the Clients. This is verified by selecting samples from different periods of time,
for different instruments and different types of CFDs. Also, the sample checks include
trades under irregular market events.

8. Client’s Consent
8.1. By entering into a Client Agreement with the Company for the provision of Investment
Services, the Client is consenting to an application of this Policy on the business
relationship between the Company and the Client (i.e. this Policy forms part of the Client
Agreement found at the company’s website.

9. Amendment of the Policy and Additional Information
9.1. The Company reserves the right to review and/or amend its Policy and arrangements
whenever it deems this appropriate according to the terms of the Client Agreement. It
should be noted that the Company will not notify Client separately of changes, other than
substantial material changes to the Policy, and Clients should therefore refer from time to
time to the website of the Company for the most up to date version of the Policy.
9.2. Should you require any further information and/or have any questions about this policy
please direct your request and/or questions to our support team. 

Should you have any questions or enquiries, please don’t hesitate to contact Orlan Capital