Order Execution Policy

1.        Best Execution Obligation

When executing client orders or placing orders with other entities to execute, Amius Limited (Amius) has an overarching obligation to take reasonable steps to obtain the best possible result on a consistent basis (rather than in every case) by taking into account a range of execution factors in order to deliver best execution.  This is known as the Best Execution obligation.

2.        Scope

We will apply this Order Execution Policy to Professional Clients dealing in financial instruments[1] in the following circumstances:

This policy will be amended from time to time and all material changes to this policy will be made available on Amius’ website at www.amius.com.

This policy does not apply to Eligible Counterparties.

3.        Limited Application of Best Execution

There are circumstances when the Best Execution obligation applies on a limited basis.

3.1        Nature of the order

In some cases the application of the Best Execution obligation may be limited by the nature of the order given by you. Such cases include highly structured transactions. The Best Execution obligation applies only in very limited form, to highly structured off-exchange transactions where, due to the unique contractual structure entered into between you and Amius, it is not possible to provide any comparisons with other transactions or instruments where the transaction involves a customised OTC financial instrument tailored to your circumstances. Although Best Execution technically applies, there is little or nothing against which to compare the transaction. This applies if it is (i) a bespoke OTC transaction, which is (ii) highly structured/customised to the particular client and, therefore, (iii) is not one of a series of similar deals to which the firm is a counterparty, and (iv) there is nothing comparable in the market.

3.2        Specific Instructions

Where you provide Amius with a specific instruction as to the execution of an order, Amius executes the order in accordance with those specific instructions.  In doing so, Amius will be deemed to have taken all reasonable steps to achieve the best possible result in relation to that order, so far as those elements of the order to which the specific instructions relate are concerned.

The execution of an order in accordance with specific instructions may prevent Amius from taking the steps that it has designed and implemented in this Order Execution Policy to obtain the best possible result for the execution of orders.  This is particularly true in respect of complex or illiquid instruments, or limited execution venues, therefore it may be inappropriate to judge best execution against the price achieved.  In such instances Amius will use commercial judgement and at a price deemed appropriate by a trader.  In all the other circumstances, Amius will use its judgement to obtain the best possible result in relation to any elements of the order where specific instructions have not been given.

3.3        Single Venue Transactions

Certain transactions may only have one venue of execution (e.g. when Amius deals on own account as a matched principal, it will be the only venue of execution) and therefore, the key execution factor is time of execution.  Accordingly, it would not be possible to compare the prices for this type of transaction.

3.4        Access to Electronic Trading Systems

Where Amius has provided a client with access to prices displayed on third party crossing networks or other third party electronic systems and the client decides to deal at the prices displayed, the client is responsible for achieving their own best execution.

4.        Execution Factors

When executing orders on behalf of a client in relation to financial instruments, Amius will take into consideration a range of different execution factors. Amius generally considers the most important of the execution factors to be ranked as:

Additionally Amius relies on “other” factors when selecting best execution factors such as expertise, product and market knowledge, trading insights, value added service (research), reputation, the availability of the service and ability to deal when placing an order.

Amius will always use reasonable endeavours to act in accordance with this policy, but we do not guarantee that the best possible price will be obtained in all circumstances. There may be occasions when Amius changes the priorities given to the execution factors outlined above, where we deem that execution may not lead to the best possible result, for example in times of severe market disruption or in the event of a system outage.

5.        Execution Criteria

Amius considers the differences in investor’s objectives when determining the weighted importance of the execution factors set out above.  In such case, the following criteria will be taken into account:

6.        Execution Venue

Amius will typically execute transactions on the following venues when providing execution only brokerage services:

Amius will use reasonable endeavours not to discriminate unfairly between execution venues. Any decision to transmit or place an order to a third party or select an execution venue is determined based on their ability to meet the execution factors listed above. Amius chooses an execution venue where it judges this to be in your best interests in the circumstances of a particular order.  The methodology in selecting an appropriate execution venue may be varied by specific instructions by the client, or alternatively, at Amius’ discretion using commercial judgment and experience where this would not prejudice acting in the client’s best interest.  A list of the main execution venues upon which Amius places significant reliance are listed in Annex 1.

In respect of the OTC derivative business, Amius deals on own account as a matched principal.  In this case, Amius is the sole execution venue for each OTC derivative transaction which a client enters into with Amius.

Where Amius provides brokerage services in relation to futures and equities and unless a client has given a specific instruction in relation to an execution venue or a third party broker, Amius will select an execution venue based on a number of factors including liquidity, market share, tenure, breadth of market coverage and market impact of the order.

7.        Order handling

7.1        Carrying out orders

When carrying out orders for Professional Clients, Amius will generally execute comparable orders on a first-come first-served basis. We will handle all orders in a timely fashion unless the characteristics of the order, prevailing market conditions or the instructions or interests of the client require otherwise.

7.2        Market Volatility

Market volatility may result in the price of a financial instrument moving significantly from the time of receipt of a client order to the time of order execution. Amius will attempt to reflect such price movements, whether positive or negative, in the price provided to the client.

8.        Review and Monitoring

Amius has an obligation to monitor the effectiveness of its order execution arrangements and Order Execution Policy, and where appropriate, correct any deficiencies.

The Order Execution Policy is reviewed on a regular basis in order to determine whether the execution venues and liquidity sources included in the policy provide the best possible result on a consistent basis.

Amius will review this policy and its order execution arrangements periodically.

9.        Information on price and spreads

In relation to OTC derivative transactions, Amius will provide you a single “all-in” price, which is comprised of:

The price charged by Amius in relation to OTC derivative transactions are determined using discretion taking into consideration a variety of factors including:

In relation to futures and options, Amius will provide a fixed fee or a fixed premium (including all external costs such as execution venue fees, clearing and settlement fees and other fees paid to third parties involved in the execution of the transaction).

The price, costs and mark-up will vary depending on the client and a nature of the transaction.  Further information is available on request.

10.        Further Information

If you have any questions regarding our Order Execution Policy, please contact us by e-mail at compliance@amius.com or call us on +44 (0) 2072687700.  We would be happy to demonstrate how we provide best execution to a client transaction where applicable.

 

Annex 1

Best Execution by asset class

1.        OTC commodity derivatives (cash settled or EFRs)

1.1        Execution Factors:

The following factors are taken into account when executing a client order in OTC commodity derivatives:

Price. Amius will use its access to all available liquidity channels to achieve the best price for the client.

Size and Liquidity. Amius will use its access to all available liquidity channels to attempt to execute the full size of the client transaction given the prevailing market conditions and instructions of the client.  Amius will assume that partial fills are acceptable unless the client indicates otherwise.

Speed. Amius will endeavour to execute the transaction as soon as is practical given the prevailing market conditions and the instructions of the client.

The priority of any one of these factors over the others will depend upon the specific instructions from the client.  If no instructions are received, Amius will generally use the above order of priority.

1.2        Execution Venues:

Amius’ own internal sources of liquidity, where we will be your counterparty.

2.        Exchange traded futures and options (including commodity futures and single stock/equity)

2.1        Execution Factors

The following factors are taken into account when executing a client order in exchange traded futures and options:

Price. Amius will use its access to all available liquidity channels to achieve the best price for the client.

Size. Amius will use its access to all available liquidity channels to attempt to execute the full size of the client transaction given the prevailing market conditions and instructions of the client.  Amius will assume that partial fills are acceptable unless the client indicates otherwise.

Speed. Amius will endeavour to execute the transaction as soon as is practical given the prevailing market conditions and the instructions of the client.

The priority of any one of these factors over the others will depend upon the specific instructions from the client.  If no instructions are received, Amius will generally use the above order of priority.

2.2        Execution Venues:

Amius will use a number of global ETD exchanges as execution venues including, but not limited to:

Amius will also use:

3.        FX Forwards, FX Swaps and any other FX products (excluding FX Options)

3.1       Execution Factors

The following factors are taken into account when executing a client order in exchange traded futures and options:

Price. Amius will use its access to all available liquidity channels to achieve the best price for the client.

Size. Amius will use its access to all available liquidity channels to attempt to execute the full size of the client transaction given the prevailing market conditions and instructions of the client.  Amius will assume that partial fills are acceptable unless the client indicates otherwise.

Speed. Amius will endeavour to execute the transaction as soon as is practical given the prevailing market conditions and the instructions of the client.

The priority of any one of these factors over the others will depend upon the specific instructions from the client.  If no instructions are received, Amius will generally use the above order of priority.

3.2        Execution Venues

4.        FX Options

4.1        Execution Factors

The following factors are taken into account when executing a client order in exchange traded FX options:

Price. Amius will use its access to all available liquidity channels to achieve the best price for the client.

Size. Amius will use its access to all available liquidity channels to attempt to execute the full size of the client transaction given the prevailing market conditions and instructions of the client.  Amius will assume that partial fills are acceptable unless the client indicates otherwise.

Speed. Amius will endeavour to execute the transaction as soon as is practical given the prevailing market conditions and the instructions of the client.

The priority of any one of these factors over the others will depend upon the specific instructions from the client.  If no instructions are received, Amius will generally use the above order of priority.

4.2        Execution Venues

Amius’ own internal sources of liquidity, where we will be your counterparty

Other brokers, dealers and market makers

 


[1] The definition of a financial instrument can be found in Annex A of this policy.

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