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Order Execution Statement Quality of Execution When executing orders in financial instruments on your behalf, Knight Equity Markets International Ltd. (KEMIL) will take all reasonable steps to achieve the best possible result for executing those orders by following our Order Execution Policy in conjunction with your specific instructions. We will achieve this by following procedures which are subject to and taking into account the nature of your orders, the priorities you have identified to us in relation to filling those orders and the practices relating to the market in question. Our aim is to produce results which provide, in our view, the best balance across a range of sometimes conflicting factors. In each case where the relevant activities relate to "financial instruments" as defined in MiFID, KEMIL will be executing orders for you in the following circumstances:
If you provide us with specific instructions, including detailing the characteristics of a bespoke product, either relating to an order or a particular aspect of an order, we will execute the order in accordance with those instructions. This will mean that, in the context of this order or aspect, your instructions will supersede our Order Execution Policy. Factors We Take into Consideration in Seeking to Deliver Best Execution KEMIL will take into consideration a range of different factors which include not just price, but which may also include such other factors as the cost of the transaction, the need for timely execution, the liquidity of the relevant market (which may increase the difficulty to even 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. We will take into account specific instructions that you have provided to us which may determine how we prioritise your order. We may also take into account your understanding and experience of the market in question, your dealing profile and the nature of the dealing service you require from us. In the absence of express instructions from you, we will exercise our own discretion in determining the factors that we need to take into account for the purpose of providing you with best execution. Our commitment to provide you with best execution does not create any fiduciary responsibilities over and above the specific regulatory obligations placed upon us or as may be otherwise contracted between us. Finding liquidity and increasing the likelihood of execution are important for larger middle-market and institutional orders. KEMIL may use its own capital to enhance liquidity in individual stocks to improve the speed and likelihood of execution. For the avoidance of doubt, use of capital is entirely at KEMILs discretion and is not guaranteed for any individual client, stock or trading situation. For smaller middlemarket and broker-dealer orders, displayed liquidity on Regulated Markets and Multilateral Trading Facilities is typically available unless dealing in illiquid stocks. Order-size will be a key determining factor on how to achieve best execution. Order-size and market impact are directly correlated, subject to the relative liquidity of the stock in question. Orders in larger size and/or less liquid stocks are likely to be worked over a period of time to reduce market impact. In normal circumstances, orders in smaller size and in liquid stocks will be executed as quickly as possible after receipt. Price will always be important but not necessarily determinative in achieving the best outcome for the client. Price is a sub-set of other considerations such as timeliness, order size and market impact. Price assumes a higher priority for client orders where the transactions are low in size/value and have minimal market impact. Broker-dealer client orders will be executed as quickly as possible and where the best-available price is present. Institutional client orders will have less immediate emphasis on price and more on market impact. For example, by working the order, our emphasis will be minimising market impact to achieve the best possible outcome. The Basis on Which We Decide on Execution Venues Our Order Execution Policy includes venues that will allow us to obtain, on a consistent basis, best execution for each order in a financial instrument which we execute on your behalf. Those execution venues may include, as appropriate for each financial product, regulated markets, multilateral trading facilities, systematic internalisers, our own propriety trading desks and third party investment firms and/or affiliates acting as a market maker. The choice of execution venues is based on client demand, liquidity and displayed price. To obtain best execution for you, where we have your consent to do so (i.e. where you have signed and returned the Form of Agreement to us; specifically, item 4 on the consent form) we may execute orders on your behalf outside a regulated market or a multilateral trading facility. In relation to some financial instruments, there may be only one possible execution venue. In executing an order on your behalf under such circumstances it will be assumed that we have achieved best execution. Monitoring the Effectiveness of our Order Execution Policy and its Regular Review We will monitor the effectiveness of our order execution arrangements and Order Execution Policy. We will assess on a regular basis whether the execution venues included in our Order Execution Policy, and the brokers and dealers to whom we transmit orders, allow us to achieve best execution or whether we need to make changes to our execution arrangements. We will also review our order execution arrangements and Order Execution Policy regularly whenever a material change occurs either in respect of one of our chosen execution venues or otherwise impacts our ability to continue to achieve best execution. Should there be any material changes to our order execution arrangements or Order Execution Policy, those will be disclosed to you. Please note that specific instructions from you may prevent KEMIL from taking the steps that we have designed and implemented in our Order Execution Policy to obtain best execution. To provide further transparency regarding our execution capabilities, please click on Execution – A Business Overview. We hope you will use this to fully understand and maximise Knight’s commitment to superior execution quality and client service. To view the Terms of Business, please click here*. For further information on KEMIL’s services, please contact any of the following: John Holl – Managing Director, Sales & Trading jholl@knight.com - +44 (0)207 997 2029 PhilGough – Managing Director, Chief Operating & Compliance Officer pgough@knight.com - +44 (0)207 997 7878 KEMIL classifies all approved clients as Professional Clients in accordance with the Rules of the UK Financial Services Authority. * Attached you can find the required PDF-file of the Terms of Business, which will appear when clicking on the hyperlink. This section of the web site is targeted at existing clients of Knight Equity Markets International Ltd only. Knight Equity Markets International Ltd is Authorised and Regulated by the Financial Services Authority |
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