Introduction
PROFITTO is committed to treat our clients fairly by executing orders on terms most favourable to our clients.
As such, PROFITTO has implemented this Order Execution Policy (hereinafter referred to as the ‘Policy’) aimed to obtain the best possible result for our clients, taking into account factors listed below.
The Policy is aimed to provide our clients with a general overview on the how trade orders are executed and the various factors that can affect the execution of the financial instruments offered by PROFITTO.
Scope and Application
PROFITTO will always act as principle when executing transactions for the clients. The Policy will apply whenever PROFITTO execute transactions on behalf of professional and retail clients.
PROFITTO will take all reasonable steps to obtain the best possible result for the clients as accordance to the Policy. The Policy considers factors such as the size of the order, liquidity of the underlying market, and the priorities of the client with the purpose to provide the best outcome in the interest of the client.
PROFITTO does not however guarantee that execution at our price will be more favourable than one which might have been available elsewhere.
By agreeing to the terms of our Customer Agreement, clients are also agreeing to the terms of PROFITTO Order Execution Policy.
Best Execution Criteria and Relevant Elements
Price
PROFITTO is committed to treat our clients fairly by executing orders on terms most favourable to our clients.
As such, PROFITTO has implemented this Order Execution Policy (hereinafter referred to as the ‘Policy’) aimed to obtain the best possible result for our clients, taking into account factors listed below.
The Policy is aimed to provide our clients with a general overview on the how trade orders are executed and the various factors that can affect the execution of the financial instruments offered by PROFITTO.
Costs
Opening a position in some types of Financial Instruments provided by PROFITTO may require the client to pay commission and/or other fees if applicable. These charges are disclosed in Terms of Business.
Trade Order Execution and Price Confirmation
A. Trade and Order Confirmation
1. All orders submitted by the clients to PROFITTO are subjected to size consideration. The minimum size of an order is 1000 units of base currency. Although there is no maximum size for an order which can be submitted by the client, PROFITTO reserves the right to decline an order if the requested size is larger than PROFITTO is able to trade in the underlying market, at the requested price, at that particular point of time. Greater liquidity may be offered to the client by PROFITTO at its own discretion.
2. Confirmations for all transactions that have been executed in your Trading Account on any trading day will be available via your online account through the online trading platform as soon as the transaction is executed. It is your responsibility to notify the us, if any confirmations are incorrect. Confirmations shall, in the absence of manifest error, be conclusive and binding on you, unless you place your objection in writing within 14 (fourteen) Business Days. You may request to receive the account statement monthly or quarterly via email, by providing such a request to us, but the Company is not obliged to provide you with the paper account statement. The Account statement may be provided at the expense of the Client.
3. If there is any manifest error in the statement or information provided by us, we, acting reasonably and in good faith, void any transaction or decline to accept any orders and/or reserve the effect of any transaction or amend any trade so that the relevant trade is affected as if the error did not incur.
B. Price Order Confirmation
1. PROFITTO provides Market Execution on all trading instruments. The Company applies ECN/STP model to orders’ execution, that is, all the Client’s positions are offset to the interbank liquidity providers. In some cases, the orders may fail to be offset, or the Company may solely decide not to offset an order or a group of orders.
2. As a result of the nature of Market Execution, slippage during orders opening or closure may occur. The Client agrees that such possible occasional slippage is a natural consequence and feature of Market Execution, and the Company is not responsible for it in any way.
3. Any possible open or close price deviation is subject to the available liquidity. When the Company quotes a price, market conditions may move between our sending of the quote and the time your order is executed. Such movement may be either in your favour or against it. Prices that may be quoted and/or traded upon, from time to time, by other market makers or third parties shall not apply to trades between the Company and you. For example, in times of high volatility (i.e. daily rollover price feed, major news announcements, central bankers’ speeches, etc.) as well as low liquidity in the market, your orders may not be executed at declared prices but instead on the next best available price The Company bears no responsibility for the consequences of such deviations and/or price differences from the price requested by the Client.
4. The Client can cancel a sent order only while it is in the queue with the “Order is accepted” status. In this case, the Client should press the “Cancel order” button. In this case, due to the specifics of the Client Terminal, the order cancellation cannot be guaranteed.
5. The Client’s request to open, modify, or close an order can be declined in the following cases:
a. During the market opening, when the order is sent before the first quote has been received by the Trading Platform. (Depend on volume availability during the execution time)
b. In exceptional market conditions. Exceptional market condition can be referred to the daily price feed that has been received from the liquidity provider which usually happen during market opening and closing daily rollover.
c. In case the Client doesn’t have sufficient margin. In this case, ‘Not enough money’ or ‘Insufficient funds’ message is displayed by the Trading Platform
d. In case the Client uses Auto trading Software performing over thirty requests per minute, the Company reserves the right to ban such Expert Advisors or cBots.
6. The use of the same IP address by different clients can be a reason to consider all the orders in all the accounts performed from this IP address as those performed by the same Client
7. The use of arbitrage strategies is prohibited. Arbitrage is a strategy aimed at profiting by exploiting the difference in prices of identical or similar financial instruments in different markets or in different forms, including but not limited to latency abuse, price manipulation, or time manipulation. If the Company reasonably suspects that the Client uses arbitrage in an explicit or hidden way, the Company reserves the right to do the following:
a. Cancel all orders of the Client
b. Cancel the Client’s profit associated with all closed orders
c. Close all trading accounts of the Client and refuse further provision of the service to the Client.
8. The Company reserves the right to close the Client’s opened orders by the market quotes in the following cases:
• The Client is underage;
• The Client is from a country to which the Company does not provide its services;
• The Client uses any arbitrage strategies as considered by the Company at its sole discretion;
• The Client conducts any other violation of this Agreement or any of the Company’s policies.
• The Company reserves the right to cancel the Client’s orders in case they do not comply with this Agreement.
Speed and likelihood of execution
PROFITTO will act as the principle for all orders submitted by the client. PROFITTO is committed to offer our client the best possible execution speed and strives to improve within the limitations of information and communication technology. Under all normal circumstance’s orders will be filled at the requested price within seconds. If the price requested is not available in the market, the order will not be filled. However, the use of any form of unstable or slow internet connection at the client’s end may result in interrupted and/or delayed connectivity to our platforms.
In certain circumstances due to poor connection speed, abnormal market volatility or in the case of intentional manipulation of our quoted price or other related data, the client’s order may be declined by PROFITTO if the price requested by the client is not representative of the market price received by PROFITTO. Internet, connectivity delays, and price feed errors sometimes create a situation where the price displayed on the Trading Platform does not accurately reflect the market rates. The concept of latency arbitrage, or taking advantage of these internet delays, cannot exist in an OTC market where the Client is buying or selling directly from the principal.
The Company does not permit the practice of arbitrage on the Trading Platform. Transactions that rely on price latency arbitrage opportunities shall be revoked, without prior notice. Please, consult the “Allowed Trading Methods” Paragraph for more information!
Aggregation
The client’s orders may at the discretion of PROFITTO be aggregated/split with PROFITTO own orders, orders of any of PROFITTO associates and/or other clients. Orders will only be aggregated or split where PROFITTO reasonably believes it to be unlikely that the aggregation or split generally will be unfavourable to any client. However, such aggregation may in abnormal circumstances work to the client’s disadvantage.
Monitor and Review
PROFITTO will monitor on a regular basis the effectiveness of our order execution arrangements and execution policy to deliver the most favourable result to our clients and to identify and correct any problem. PROFITTO reserves the right to correct any deficiencies in the policy and to make improvement to its execution arrangements wherever deemed necessary by PROFITTO.
Force majeure events
PROFITTO not responsible for financial losses arising from force majeure events. These events are extreme and irresistible circumstances that are independent of the will and actions of the agreement participants, that cannot be foreseen, prevented, or eliminated, including but not limited to natural disasters, fires, man-made accidents and disasters, emergencies at utility works and on utility lines, bankruptcy of Liquidity Provider, DDOS attacks, riots, military actions, terrorist attacks, uprisings, civil unrest, strikes, and the regulatory acts of state- and local government authorities.
Allowed Trading Methods
PROFITTO allows all types of trading methods and styles.
The Company reserves the right, however, to close, suspend or recoup any closed profit and loss from an account it deems is engaging in unethical or questionable trading styles including, but not limited to, Picking and Snipping, Flooding, Scalping, Pip-hunting, Hedging, placing “buy stop” or “sell stop” orders prior to the release of financial data, arbitrage, use of robots, a combination of faster/slower feeds, manipulation fresh data feed on daily rollover and the act of “flooding” of our servers with an excessive amount of pending orders and / or pending order modification requests, excessive logins, or the use of certain automated trading systems or Expert Advisors, without notice.
PROFITTO will usually (but is not obligated to always) attempt to initially express its concern to Customer or associated parties via email or telephone in the form of a formal warning. If the Customer or associated party does not modify trading style within a reasonable amount of time following the warning, PROFITTO reserves the right to liquidate all or some open positions, close, suspend or recoup any closed profit or loss from account, and return any remaining proceeds to Customer according to Company account closing procedures or any combination thereof. If the Company reasonably suspects that the Client uses arbitrage in an explicit or hidden way, the Company reserves the right to do the following:
- Cancel all orders of the Client
- Cancel the Client’s profit associated with all closed orders
- Close all trading accounts of the Client and refuse further provision of the service to the Client.
Pending Orders
PROFITTO reserve the rights to disable pending order function on major news release without prior notice.
Misquotes / Mispricing
It is possible that a transaction may be performed on a wrong price due a miss-quote price feed from any of PROFITTO third party liquidity providers or through an unexpected technical fault. Equally, there may be delays due to internet connection or occasions where a position is opened or closed based on latent prices that do not reflect the correct market prices at the time of transaction, resulting in an inaccurate profit or inaccurate loss.
Such events may affect client transactions. In this case, PROFITTO will take all the necessary measures, immediately, to remedy and rectify the situation, as it is fair and suited to each case. Remedies include correcting deal entry prices or exit prices according to the correct market rates at the time of transaction. PROFITTO may need to cancel any transaction(s) which are executed wrongly due to the ‘price misquote’, for example from pre-set limit/pending orders been triggered due to mispricing. PROFITTO will make the best efforts to contact and inform client for PROFITTO’s actions, by telephone or by e-mail.
Slippage
PROFITTO aims to provide clients with the best execution available and to fill our client’s orders at the requested price. However, there are times when, due to abnormal increase in market volatility, orders may be subject to slippage or rejected on LP level.
PROFITTO hereby advise our clients that slippage is a normal market practice in the industry and a common feature of the foreign exchange market under conditions such as lack of liquidity and abnormal volatility due to economic events, news announcements, and market opening. PROFITTO shall not be held liable for losses suffered by the client caused by slippage.
PROFITTO reserve the rights to void any positions opened and subsequently closed within 3 minutes. PROFITTO do not recognize trades under 3 minutes if trades rejected by LP. Any profit, loss, and/or commission fees made through these transactions may be deemed invalid.
Reduction of Maximum Leverage
As protection against over exposure on news, PROFITTO will apply reduction of maximum leverage on every major economic news, included but not limited to FOMC, NFP and ECB news. The maximum leverage for all account types will be reduced to 1:50 at 5(five) hours before until 5(five) hours after the news announcement. Higher leverage creates additional risk and loss exposure, which may cause negative equity on client accounts.
Hence, PROFITTO reserves the right to reduce the leverage to 1:50 in event of big news to avoid the risk similar to crisis.
Legal notice
This policy supersedes any prior written or verbal communication or understanding. PROFITTO may change the terms of this policy at any time. Any later version of this document shall supersede all previous versions.
Language Discrepancies
This Policy has been drafted in the English language.
In the event of any discrepancy between the meanings of any translated versions of this Agreement and the English language version, the meaning of the English language version shall prevail.
@PROFITTO reserves all right.