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Order execution policy

Last modification 28 Jul 2022

  1. Introduction

    1. 1.1. Eurotrade Investments RGB Ltd (‘’Gratis app’’ , ‘’us’’ , ‘’we’’ , ‘’company’’) is regulated by the Cyprus securities and exchange commission (‘’CySEC’’) and is required to take all sufficient steps to act in the best interest of our clients when executing client orders. This means that when we execute transactions for you, we are required to do so in a way which achieves the best possible result for you. This is known as 'best execution', and this Best Execution and Order Handling Policy (the "Policy") describes how we seek to do this.

  2. Best execution factors & Criteria

    1. 2.1. In considering how to handle an order we take into account the range of execution factors listed below. When handling orders for retail clients, price and cost are the execution factors we prioritise in determining the quality of execution and deciding how to handle the order to get the best result available to us.

      • Price - This is the factor we place highest priority on when handling an order. We look to obtain the best possible market price available to us at the time of trading and aim to avoid executing an order at a price that is worse than the price available on the primary venue of the instrument.
      • Cost - We do not pass on any direct execution costs to customers therefore this factor is unlikely to impact our customer orders, however in considering the execution venues we select to execute customer orders we take into account any execution costs that may be incurred by us or passed on to our customers.
      • Speed - As an app focused on longer term investing, low latency execution is not the main focus but we consider and monitor the time it takes from a customer place an order with us, to executing it.
      • Likelihood of execution and settlement - We consider how likely orders are to execute and settle, for example by checking the liquidity levels of the instruments on the execution venues we use.
      • Size, nature and any other factors - We may also consider the size of an order, and any other characteristics when determining how to get the best possible result.
  3. Order in US listed instruments

    1. Orders for the majority of US-listed instruments are transmitted to our third-party US-based broker-dealer (“ US Broker”). For orders in US listed instruments transmitted to Our US Broker we allow fractional share quantities of less than one full share.

      • Orders of Fractional & full shares of a security will mostly be executed by our US Broker, as an agent. This means that our US broker will route the orders direct to the market.
      • Some tickers exist on an older framework, which may be executed as principle but are still filled by executing in the market.
      • They never deal out of their inventory.
      • All orders (including fractional) are routed through their best execution framework, which monitors and optimizes execution quality.
  4. Orders

    1. Market Orders: During the available trading hours for a security, we facilitate commission free market orders. Market orders are sent for execution immediately after being placed through our app. You should be aware of the following risks when placing Market orders.

      • A Market order is an order to buy or sell at the best price available to us in the market at that time.
      • You may only place a Market order when the respective market is open. For example, in the US this will ordinarily be from 14:30 until 21:00 local time during every normal trading day. Other markets will vary.
      • You cannot cancel a Market order on account of it being executed as fast as possible after instruction.
      • Due to the inherent nature of a moving market and any delays in displaying information through our mobile application, it is likely that the actual execution price will differ from that shown on screen before the order is made.
    2. You should be conscious to accept the risks associated with this type of instruction. Gratis app will not be liable for losses incurred due to the selection of the Market order type, save any assessment made by us that we have fallen short of our best execution obligations.

  5. Order allocation

    1. We send orders for execution in the sequence in which they are received. We do not prioritise one customer’s order over another. It is only in exceptional circumstances that we may prioritise orders - for example, during an external or internal outage, we may prioritise sell orders over buy orders, in order to minimise potential harm to our customers.

  6. Specific instructions

    1. Acting on specific instruction from you in relation to an order you place with us may prevent us from taking the steps we have designed and implemented in this policy to obtain the best possible result for the execution of those orders. However, as our orders are automatically executed or queued for execution when placed through our app, we do not envisage situations where we will be in a position to act on specific instructions.

  7. Monitoring and review

    1. We monitor execution performance for compliance with this policy, as well as periodically reviewing the policy itself to ensure that we are delivering the best execution results for our clients. We will let you know about any important changes being made here.