Order Execution Policy

 

1.      Introduction

Amius Limited (“Amius”) is required to take all sufficient steps to obtain the best possible result for its clients when executing orders for them (“Best Execution”). This means taking into account a range of sometimes conflicting execution factors to achieve the best possible outcome on a consistent basis rather than for every individual client order.

This Order Execution Policy (“Policy”) sets out the execution factors that Amius considers in order to achieve Best Execution of its client orders on a consistent basis. Clients are deemed to have consented to their transactions being handled in accordance with this Policy by signing the Terms of Business with us, or continuing to trade with Amius.

This Policy replaces and supersedes all previous versions and may be subject to periodic updates which will be published on our website.

2.     Scope

Amius will apply this Policy to Professional Clients[1] who “legitimately rely” on Amius to protect its interests in relation to the execution of the financial instrument which include:

This includes all instructions to buy or sell financial instruments which give rise to contractual or agency obligations to our clients or where Amius act as agent or principal on a client’s behalf.

3.     When does best execution apply

Amius will consider the following factors to determine whether a Professional Client is “legitimately relying” on Amius to protect its interests:

Neither this Policy nor best execution obligations apply to Eligible Counterparties.

4.     Execution Factors

When executing a client order (to which best execution applies), Amius will consider a number of execution factors as appropriate which include:

Amius will consider the differences in the client’s objectives when determining the applicability and weighted importance of these execution factors including:

The variety of financial instruments and client orders that Amius receives means that different execution factors could apply to each order. Please see section VII for further details.

5.     Limited Application of Best Execution

There are circumstances when the Best Execution obligation applies on a limited basis, or at all:

6.     Execution Venues

When Amius deal as principal in bespoke OTC transactions it will be the only execution venue. However, when Amius provide execution only services, it will typically use one of the following venues to execute transactions:

Amius may execute all or part of your order outside of a Regulated Market or MTF. However we require your consent to do so and we refer you to our Terms of Business in which we seek this from you. In the absence of your express consent, we shall consider your deemed acceptance when you place an order with us.

Amius will take sufficient steps to ensure that its commissions are not structured or charged in such a way so as to discriminate unfairly between execution venues. Subject to any specific client instruction, Amius will choose an execution venue where it judges this will give the best outcome for the particular client order. Amius also undertake periodic reviews to determine that brokers it uses are able to provide the appropriate level of expertise and experience when executing in that market.

 7.     Execution by Asset Class

This section provides further details about how we apply best execution to the various asset classes and, subject to specific instructions or market volatility, the execution factors we consider.

OTC derivatives

Amius trade OTC derivatives on a request for quote (RFQ) principal to principal basis without using a regulated market, MTF, OTF or other platform to facilitate the transaction. Amius are therefore the only execution venue in relation to the OTC derivatives we enter into.

The nature of the OTC derivatives orders are bespoke and highly customised to a particular client. Accordingly it will not always be possible to compare prices for this transaction or consider suitable alternative venues for executing the OTC transaction. It cannot also be assumed that clients have price transparency or can “shop around” for the best possible price. Amius will therefore assess the nature of the transaction and the client’s instructions to determine the relevant execution factors to be taken into account when executing the order.

In view of the nature of these OTC derivatives that Amius and its clients enter into, Amius consider cost and price to be important execution factors.

Price is sometimes referred to as the “basis” and is usually determined by the client (either specifically or by reference to an “at market” or “limit” order). Otherwise Amius will check the fairness of the price proposed to the client using market data and comparable or similar products where this information is available. Cost is disclosed to you in your ex-ante and ex-post reports.

Another key factor is speed of execution and Amius will always endeavour to execute your order in full as expeditiously as possible. However, for larger orders or in highly volatile market conditions, this may take a little longer and/or result in partial fills being obtained.

Exchange traded futures and options

Amius deal as agent when executing these transactions and rarely exercise their own discretion when executing exchange traded futures and options, instead acting on specific client instruction. In the rare circumstances where Amius do have discretion, our decision to deal on a particular trading venue may be driven by the fact that there are no alternative sources of dealing in the products traded. For example, if a client wishes to trade London Cocoa, ICE Futures Europe is currently the only venue for that product.

Where there is only one execution venue then speed of execution will be the highest ranked execution factor. Where there is a choice of execution venue, price remains the primary factor, but Amius will, unless market conditions dictate, consider that time of execution, costs, order size, and likelihood of execution are also important execution factors.

Where possible, Amius will use a number of global exchanges to execute your order including but not limited to:

Amius will also use other brokers as well as its own internal liquidity sources only where, applying the same factors as we apply to other execution venues, we have concluded that the internalisation of the order provides you with best execution.

FX (forwards, swaps and options)

Amius deal as agent when executing FX transactions on your behalf and rarely exercise their own discretion. However, in the rare circumstances where there is no specific client instruction, price remains the primary factor and Amius will use its access to all available liquidity channels to achieve the best possible price for the client.

Amius will use other brokers, dealers and market makers to execute your order and price therefore remains the primary factor. However Amius will, unless market conditions dictate, consider the size of the transaction and how this may affect the price of execution, cost and speed of execution as important factors.

8.     Order Handling

Clients’ orders are generally placed over phone, instant messaging or email and will be confirmed to you in writing. Amius do not accept orders via any other electronic means or DMA.

All orders are promptly and accurately recorded and allocated. Amius will always carry out comparable orders sequentially unless the characteristics of a particular order or the market conditions make this impractical or not in the best interests of the client.

9.     Monitoring and Review

Amius has set out a governance framework to monitor the effectiveness of its order execution arrangements as set out in this Policy and to correct any deficiencies identified. Amius will review the arrangement, including this Policy, at least annually or whenever a material change occurs. Amius will publish any material changes on its website. Amius will also publish the following best execution reports on its website:

If you have any questions on this Policy, please feel free to contact your Relationship Manager or Amius Compliance – compliance@amius.com.

 


[1] Please refer to your Client Categorisation letter which states the categorisation we have afforded you in accordance with the Financial Conduct Authority regulations