4T S.A.L. Execution Policy

1. Purpose

• 1.1. In this policy, 4T S.A.L (also referred to as ‘we’, ‘us’, ‘4T’ and ‘Company’), is licensed and regulated by the Capital Markets Authority (CMA) in Lebanon.
• 1.2. 4T recognizes its duty to take reasonable steps to obtain the best outcome for handling and executing the orders of the client. Therefore, 4T S.A.L has put in place a policy in addition to procedures designed to obtain the best outcome for clients when executing orders on their behalf. The police and procedures take into account, and are subject to, , any specific instructions from the client, the nature of the particular orders and the nature of the markets concerned, but do not guarantee such results in all transactions. This policy should be read in conjunction with 4T’s Terms of Business as applicable from time to time, which is available on the website.
• 1.3. The company has established and implemented arrangements, including this Policy. The arrangements are designed to meet the regulatory requirement that obtain the best possible result according to the orders of the Clients. The process of obtaining such best possible result shall be referred to as “Best Execution”.
• 1.4. Other factors, not mentioned in this policy, could affect the execution; either because of their irrelevance, at this point in time, or because they are more related to technology faults, errors or bugs in systems and configurations. If an error is denied execution due to these circumstances, the Client must contact the company immediately and execute the order by means other than the trading platform.

2. Execution

• 2.1. 4T offers to retail and professional clients Contracts for Difference (CFDs) across a range of asset classes: Foreign Exchange (FX), Indices, Commodities, Equity and Cryptocurrencies.
• 2.2. We act as principle on behalf of contracts and trades you enter with us, and we therefore act as sole execution venue for the execution of your contracts. This means that we will act as market maker and you will be dealing with us.
• 2.3. We ensure you obtain best execution by ensuring that in the calculation of our bid and offer prices used to execute your Contracts, we take into regard the market price and liquidity available for the underlying reference product to which your Contract relates. We have access to top tier liquidity providers and data sources to ascertain the market price.
• 2.4. Whilst we act as principal in respect of your orders, we assess the venues available to us for the pricing and hedging of your Contracts and the execution of your transactions. We view that, price and costs are the most important factors in our choice of venue, but we will also take into account how each of the other execution factors are affected, for example; speed of processing and likelihood of order acceptance in a variety of markets and order types. The financial soundness and order execution policies of any counterparty or venue are also considered.
• 2.5. 4T will seek to manage our risk as market maker and may choose whether to hedge part or all of your Contracts in the underlying market. We believe this approach is likely to result in reducing the execution of costs and of market price impact for our clients overall. Hedging in the underlying market may affect the price of the Contract that 4T enters with you, considering the prevailing market prices and liquidity available to us.
• 2.6. When executing your orders, we will take all necessary steps to achieve the best possible outcome by executing orders according to this Policy and any specific instructions received from you. This Policy comprises a set of procedures that are designed to obtain the best possible execution result, subject to and taking into account, the nature of your orders and the specific instruction you have identified regarding those orders. The client acknowledges that our price may differ from any price which is or might have been available elsewhere.
• 2.7. In regard of some financial instruments, at the time at which you give us an order there may be no functioning or open market or exchange on which the reference product is traded. In such cases, we set out to determine a fair underlying two-way price based on several factors such as price movements on associated markets, other market influences and client trading flow.

3. Execution Factors

Many factors could affect providing best execution. The client should consider these factors prior to making the trading decision and send the orders for execution. In the absence of a specific instruction from the client, 4T may consider the impact of one or a combination of factors to determine the way a client order will be executed. These factors are:

• • Price
• • Speed and Likelihood of Execution
• • Size and Nature of Order
• • Specific Instructions
• • Costs
• • Technology
• • Any Other Factor Relevant to the Execution of the Order

• 3.1 Price

  • a) The price of a given instrument or contract that we provide for trading is calculated in reference to the exchange or the interbank price of the relevant underlying financial instrument. However, the client must understand that our products, though they are priced to reflect the underlying market, are mostly over-the-counter ‘OTC’ contracts for difference, where the client enters into a position with us and is therefore required to exit the position with us in exchange for the cash amount equivalent of the profit or loss realized on the position. There will be no delivery or transfer of positions to third party financial institutions.
  • b) The price is obtained by independent third-party financial institutions that may or may not act as our execution venue. We aggregate these prices to show the client the most favorable bid and ask after including our mark-up/down into the spread or commissions.
  • c) The prices that appear on the trading platform and applications are indicative and may at times not be executable. The reasons include, but are not limited to, the demand and supply of liquidity at this specific price. Also, it could be that the client is viewing only bid side, ask side, mid-price, stale price, non-tradable price, or raw price.
  • d) In the absence of a price quotation from our third parties for any reason, we will calculate the most probable price and display it on the system to prevent issues related to margin stop/out. These prices are provided temporary to give you an estimated value of your positions, however they may be deemed stale or non-tradable.
  • e) The prices on the charts are for indication purposes only. The charts are provided for the sole purpose of illustration of the historical price movement. They do not necessarily reflect execution prices and could occasionally have off-quotes or incorrect prices that we will clean-up, filter-out and amend accordingly.
  • f) In the rare occasion an order is executed on a stale, non-tradable or generally incorrect price, 4T reserves the right to cancel, offset and/or reverse the trade without prior notice.

• 3.2. Speed and Likelihood of Execution

  • a) In almost all circumstances, under normal market conditions and as long as the client has sufficient margin available on their account for the trade, and as long as the trade size requested is equal to or under the maximum size permissible, the trade will be executed immediately at the market prevailing price.
  • b) In certain specific circumstances, for example: speed of Internet communications and market volatility; where the quoted price is no longer representative of the ‘underlying market’ price, but within a predetermined permitted tolerance level, the client’s trade will be executed at the best price available at that time, regardless of whether the market movement is in a beneficial or detrimental direction.
  • c) The likelihood of execution of the Clients’ orders may depend on the availability of the underlying prevailing price. In some cases, it may not be possible to arrange an order for execution during abnormal market conditions, for example but not limited to the following cases: overnight, during news times, trading session start moments, during volatile markets where prices may move significantly up or down and away from declared prices, where there is a fast price movement, where there is insufficient liquidity for the execution of the specific volume at the declared price and/or a force majeure event.
  • d) Slippage can occur at any time, but is most likely to occur during periods of high volatility, overnight and at the opening of the market. It usually occurs when the market moves suddenly in any direction and during the time taken for a client’s acceptance of a price to be received, that price is no longer available and the client’s trade is executed at the best price available at that time.
    • I. Slippage is the difference between the expected price of a trade, and the price at which the trade was executed. This can be either in favor or against the client.
    • II. Slippage occurs when there is not enough supply or demand on either side of the quotation. This leads a market order to be executed relatively far from the desired price. It also occurs when the market price moves suddenly in any direction triggering a large number of orders to be sent through the networks causing latency which, in turn, leads to execution at the next available price. The price is then said to have ‘slipped’ from one level to another, as the market has ‘gapped’ from one level to another.
    • III. If the market ‘gaps’ overnight, it will open at the start of the trading day at a price different from the closing price of the previous trading session.
    • IV. Any order which activation price is between the market’s closing quote of the previous trading session and their opening quote of the new trading session, will be filled at the first price 4T can reasonably obtain in reference to the ‘underlying market’.
    • V. Should there be any market gaps from one quoted price to another due to any market sensitive piece of information (such as a profit warning or an economic data release), then any order placed between these prices will be activated.
    • VI. the speed of execution depends largely on the speed of networks, servers, and devices. We take all necessary steps to ensure our servers and networks are speedy and up to date. However, we have no control over the speed and performance of your own network and devices.
    • VII. 4T does not accept any orders outside the market hours of the relevant underlying financial instrument, and futures are traded in accordance with the trading hours of the exchange upon which the underlying financial instrument is traded.

• 3.3 Size and Nature of Order

  • a) When the order is sent to the market for execution, it is only triggered by the price. However, the prices are not assigned to infinite liquidity. Prices displayed on the system, only present a limited layer of the market depth, hence, large orders will tend to be executed partially and at different prices down the order book. In this case, the client will receive a weighted average price.
  • b) If the size of the order exceeds the available liquidity we may (or not) accept the order for partial execution.
  • c) Market Orders are when the client sends instructions to buy or sell any instrument at whatever price available at the time of execution.
  • d) Buy Stop orders are instructions to buy an instrument at a price higher than the current market price.
  • e) Sell Stop orders are instructions to sell an instrument at a price lower than the current market price.
  • f) Stop Loss Orders are instructions related to existing positions to close them when the market price is moving in the opposite direction to the positions of the client. Stop Orders are generally sent for execution as market orders. The designated price merely acts as a trigger to activate the order but the execution will be done at the first available market price.
  • g) Buy Limit Orders are instructions to buy an instrument at a price lower than the current market price.
  • h) Sell Limit Orders are instructions to sell an instrument at a price higher than the current market price.
  • i) Limit or T/P Orders are instructions related to existing positions to close them when the market price is moving in a direction favorable to the position of the client.
  • j) Entry limit and T/P orders are sent to execution with an attached price. They can only be executed if the price is linked to enough liquidity. They might continue to be executed partially until completely filled at the requested price or better.

• 3.4 Specific Instructions

  • a) As outlined in the policy, 4T takes into consideration any specific instructions that may prevent executing the orders in accordance with the terms of this policy. Examples of this include, but are not limited to: Executing, specifically, a limit order as market or specifically instructing 4T to break a large order into smaller size orders prior to sending for execution.

• 3.5 Cost

  • a) The difference between the Bid and Ask (selling and buying price) is known as the ‘spread’ and is, typically, the cost of trading. Spreads can be fixed or dynamic and can widen and shortened according to market volatility and available liquidity and instrument.
  • b) The price is transmitted to the platform of the client and includes the spread cost and therefore, both the bid and the offer price may be slightly different from the market or the exchange price of the underlying financial instrument.
  • c) A limit or even stop orders can be triggered at a price that is higher or lower than the market or traded price of the underlying financial instrument due to the spread cost.
  • d) An order can be rejected if the trading platform calculates that the client does not have enough balance to cover the cost of execution.
  • e) In other circumstances, clients may be charged overnight funding for holding positions overnight, and for adjustments made in respect of dividend payments and other corporate actions.
  • f) FX instrument overnight financing charges will be applied three times on Wednesday.

• 3.6 Technology

  • a) There are other factors that could affect execution that are not mentioned in this policy, either because of their irrelevance at this point or because they are related to technology, including but not limited to, set-up errors, connectivity issues, programming code breaks or ‘bugs’ in the configuration of instruments. If an error denies execution due to a bug or a configuration error, the client must contact 4T immediately and execute the order by means other than the trading platforms.
  • b) 4T does not and will not owe the client execution at a price that is no longer available in the current market.

• 3.7 Other Factors Relevant to the Execution of the Order

  • a) Available Margins The trading system may allow you to place working orders that would require a currently non-available minimum margin amount If the working order is triggered by a price movement, and the account does not have enough free margin available to meet the margin requirement, the working order will be cancelled and void..
  • b) Trading Platform There are several methods of trading with us, Desktop, Web trader, Mobile application or phone instruction. Each method may be different and can be affected by a different set of factors such as, Internet speed, accuracy and ease of use.
  • c) Market Impact The liquidity of any financial product is limited no matter how much of it is available at any time. The trades and orders of market participants have an impact on this liquidity which could quickly disappear, especially during volatile and extraordinary market conditions where the price movement could translate into a huge number of orders sent at the same time and looking to be executed at any price available. We always aim to provide our clients with best execution, but prevailing underlying market conditions may, at times, result in unfavorable execution.
  • d) Market Hours Aside from those markets defined as being quoted ‘out of hours’, no order will be filled outside of our specified quoting hours. Please note that some markets continue to trade outside our quoting hours and, in these cases, there is significant potential of some gapping from one 4T trading session to the next.. All orders in these markets will be subject to this gap in prices. Orders activated in ‘out of hours markets’ quoted by 4T are treated as though the underlying instrument were open and trading at that level require to activate the order.
  • e) The Execution Venue, If Any, to Which the Order Will Be Routed On the occasion where we have routed your order to an execution venue, we are bound by the venue’s business terms and conditions and execution policy which can differ from ours. Your order might, therefore, be affected as we pass to the execution.

4. 4T’s Conflict of Interest and Liabilities

• 4.1. 4T’s commitment to provide “best execution” does not mean that it owes any of its clients any fiduciary responsibilities over and above any specific regulatory obligations, unless it is specifically agreed in writing. 4T will not provide the client with any recommendation or any other information with the intention to incite the buying or selling of any instrument or the engagement of any other trading activities. The client must make their own trading decisions independently and seek help by a financial consultant before taking any trading decision. Each client remains responsible for their own investment decisions and 4T will not be responsible for any market or trading loss that a client might suffer because of those decisions.

5. Monitoring & Review

• 5.1. 4T will evaluate, on a regular basis, whether the execution venues and pricing mentioned in this Policy provide the best possible outcome for its clients or whether it needs to make changes to its execution process.
• 5.2. 4T will review its order execution arrangements and this Policy at least annually or whenever a material change arises and affects its ability to continue to obtain the best outcome for the execution of the orders of the client on a consistent basis using the venues included in this Policy.
• 5.3. 4T will notify the clients of any material changes to its order execution arrangements or Best Execution Policy as described above by posting the information on its website or by email.