Order Execution Policy

Introduction

Investa Markets Ltd (“IML”, the “Firm”, “we”, “our” or “us”) are authorised and regulated by the Financial Conduct Authority (“FCA”) in the United Kingdom (FRN: 1037289).

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IML is required to put in place arrangements to enable it to execute trades in compliance with MiFID and the FCA rules. This is the Firm’s Order Execution Policy (the “Policy”) which applies to both retail and professional clients.

For the purposes of the Policy, a client is defined as any individual account that has been established with IML and that is authorised to trade as an on-boarded client. An order for the purposes of the Policy is an instruction from a client to buy or sell a financial instrument on an execution-only basis. IML always acts as agent for the purposes of the Policy and does not trade for its own principal account.

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Obligation for best execution

The best execution regime requires investment firms to take all sufficient steps to obtain the best possible result for their clients when transacting in financial instruments. The extent of these obligations will vary depending upon the firm’s role in the execution of the transaction. IML is an app-based trading platform which receives and transmits orders directly from clients for execution at the client’s custodian.

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As IML only passes orders in financial instruments directly to the relevant custodian for execution, the Firm is required to operate in the client’s “best interests”. IML does not advise, take decisions, nor use external brokers to execute orders to the requirement to provide “best execution” does not lie directly with IML.

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Execution factors considered by the Firm

Whilst IML will endeavour to obtain the best available result in carrying out each client order, this does not mean obtaining the best possible result for each individual order on a transaction-by transaction basis. 

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As part of IML’s Terms of Business, all clients give express consent for their orders to be executed on their behalf outside a regulated market or multi-lateral trading venue (“MTF”) / Organised Trading Facility (“OTF”) where it is reasonably believed to be in the clients’ best interests to do so. IML will direct transactions to the client’s custodian as the primary trading venue for all asset types. 

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Order handling, including aggregation and allocation

Client orders will be executed in a prompt, fair, and expeditious manner, with prompt and accurate records. IML does not aggregate orders of clients, nor does it allocate securities for partial fills. IML does not trade on a principal basis or “work” client orders.

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Execution venues

IML will send orders directly to the client’s custodian for ALL transactions. Interactive Brokers UK is the only custodian utilised by IML and all orders will be executed through that firm.

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Monitoring arrangements

IML will monitor the effectiveness of its order execution arrangements and the Policy on an ongoing basis. Where IML passes orders to third parties for execution, without taking steps that affect execution quality, it is not the Firm’s role to duplicate the monitoring efforts of the executing entities. Consequently, the monitoring will focus upon the third party’s regulatory (or contractual) obligations and the arrangements that they have in place including, as appropriate, their own Order Execution Policy, to obtain best execution.

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IML’s responsibility is to monitor the venue’s execution quality not less than annually via their publicly available reports alongside the above ongoing monitoring and issue our own statement annually to our website covering the top five venues we have dealt with and how they have been assessed for providing best execution.

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Appendix 1 - Execution venues

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INTERACTIVE BROKERS (U.K.) LIMITED (FCA FRN: 2081590) 

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• 100% of Client Orders
• Types of Securities
  
  • Transferrable Securities
  • Options

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