Introduction

The purpose of this document is to provide information on Land-FX UK Ltd’ s policy on order execution and its approach to achieving the best possible result for you when executing your trades on a consistent basis. It is required under the EU Markets in Financial Services Directive (MiFID/MIFID II)), and will apply to all of Land-FX UK Ltd’ s retail clients and professional clients. This document forms part of Land-FX UK Ltd’ s Terms of Business. By accepting Land-FX UK Ltd’ s Terms of Business, you are deemed to also consent to the terms of Land-FX UK Ltd’ s Execution Policy, as summarised here.

Land-FXUK Ltd’ s Duty of Best Execution

When executing trades for Contracts for Difference, with you, Land-FX UK Ltd will take all sufficient steps to achieve the best possible outcome taking into account its Execution Policy and any specific instructions received from you. However, Land-FX UK Ltd’ s Execution Policy cannot guarantee that the price at which Land-FX UK Ltd permits you to execute a Trade will always be the best price available to you in the market at that point in time. Land-FX UK Ltd. is not a market maker and does not execute any of your trades. All trade flow is sent through to Land-FX UK Ltd.’s liquidity providers.

How Land-FX UK Ltd Applies its Best Execution Obligation

Land-FX UK Ltd will take into account the following factors to decide how to achieve the best possible result for you when executing your trades:
1. price
2. costs
3. liquidity of the underlying market (e.g. for trades outside the normal trading size)
4. nature of the Trades
5. speed and likelihood of execution and settlement.
Land-FX UK Ltd will generally apply its best execution obligation to retail clients and professional clients by prioritising obtaining the best possible price for you (for this purpose, price includes the price of the financial instrument to which your trade relates and its execution costs). However, in some circumstances, other factors will be given greater importance than price or costs in obtaining the best possible execution result.

In order to determine the relative importance of the Execution Factors above, we will take into account:
- the characteristics of the client (including your classification as Retail or Professional);
- the characteristics of the transaction (order type, size, likely market impact);
- the characteristics of the Financial Instrument to which the transaction relates;
- the characteristics of the Execution Venues to which an order can be directed; and
- any other circumstances that we deem to be relevant to the execution of that transaction.

What Your Specific Instructions Mean

Where you provide Land-FX UK Ltd with specific instructions as to how you wish to execute a trade, for example, by specifying (a) the price that you wish to execute a trade with Land-FX UK Ltd ; or (b) the price at which a trade is to be closed if the market moves against you (for example, a Limited Risk Trade), you should be aware that these instructions may prevent Land-FX UK Ltd from applying its Execution Policy. Your instructions will take precedence over Land-FX UK Ltd’ s Execution Policy and will mean that Land-FX UK Ltd will have satisfied its obligations to take all reasonable steps to achieve the best possible result for you when executing that Trade.

How do you determine the commission or mark-up I pay on a transaction?

We will provide you with a single “all-in” price that includes:
- the price of the financial instrument (including any bid/offer spread);
- the execution costs (including venue fees, clearing and settlement fees and other fees paid to third parties involved in the execution of the transaction); and
- any commission or mark-up charged by Land-FX UK Ltd.
The commission or mark-up charged by Land-FX UK Ltd. may take into account any of the following factors:
- the type of client (institutional, producer, consumer);
- the level of service required;
- the frequency of trading;
- the source and type of trade flow;
- the client’s credit line requirements
- the client’s margin requirements.
- the client’s pricing requirements; and
- the technology required.

Monitoring and Review

Land-FX UK Ltd will frequently monitor the effectiveness of its order execution arrangements and Execution Policy on a regular basis and implement enhancements and improvements as necessary. Additionally, upon request, Land-FX UK Ltd will make available to you details of how your trades were executed. Land-FX UK Ltd will notify you of any material changes to its Execution Policy, and the latest summary of it will be accessible at all times via the Land-FX UK Ltd website at http://landfx.co.uk/.

How do I know that my order was dealt with in accordance with this Best Execution Policy?

How do I know that my order was dealt with in accordance with this Best Execution policy? We monitor the performance of our Execution Venues on a periodic basis to ensure they are continuing to provide us with Best Execution for our client orders. We also monitor your trades to ensure they are executed in accordance with this policy.

Does this policy apply to all clients?

Land-FX UK Ltd. will apply Best Execution to transactions with Retail Clients dealing in Financial Instruments unless otherwise agreed. Land-FX UK Ltd. will apply Best Execution to transactions with Professional Clients dealing in Financial Instruments where it accepts an order or where it has expressly agreed to provide Best Execution. This policy will not apply to transactions with Eligible Counterparties. However, this does not diminish Land-FX UK Ltd.’s obligation to act honestly, fairly and professionally and to communicate in a way that is fair, clear and not misleading when dealing with Eligible Counterparties.

How often is your Best Execution Policy Reviewed?

We will review this policy annually, or whenever there is a Material Change that affects our ability to achieve Best Execution for you or adhere to any other aspect of this policy. A change is material where its disclosure is necessary to enable you to make a properly informed decision about whether to continue utilising the services of the firm. Examples of a Material Change would include, but are not limited to:
(i) a change to Land-FX UK Ltd.’s business model;
(ii) the introduction of a new product range;
(iii) the introduction or withdrawal of a trading desk;
(iv) the implementation of a new trading platform.

Exchanges used for Land-FX UK Ltd.

• LMAX Exchange FX Trading
• CFH
• Swiss Quotes
• ADS (2017)
• Saxo

Further Details – MIFID II Reporting Requirements

Further details of how Land-FX UK Ltd executes your orders are available on Land-FX UK Ltd’ s website and in its Terms of Business. As per the 4th April 2018 Land FX is required publish the top five execution venues in terms of trading volumes for all executed client orders per class of financial instruments. Information regarding retail clients shall be published in the format set out in Table 1 of Annex I and information regarding professional clients shall be published in the format set out in Table format of Annex I. The publication shall exclude orders in Securities Financing Transactions (SFTs) and shall contain the following information:
(a) class of financial instruments;
(b) venue name and identifier;
(c) volume of client orders executed on that execution venue expressed as a percentage of total executed volume;
(d) number of client orders executed on that execution venue expressed as a percentage of total executed orders;
(e) percentage of the executed orders referred to in point (d) that were passive and aggressive orders;
(f) percentage of orders referred to in point (d) that were directed orders;
(g) confirmation of whether it has executed an average of less than one trade per business day in the previous year in that class of financial instruments

Land FX will also publish for each class of financial instruments, a summary of the analysis and conclusions they draw from their detailed monitoring of the quality of execution obtained on the execution venues where they executed all client orders in the previous year. The information shall include:
(a) an explanation of the relative importance the firm gave to the execution factors of price, costs, speed, likelihood of execution or any other consideration including qualitative factors when assessing the quality of execution;
(b) a description of any close links, conflicts of interests, and common ownerships with respect to any execution venues used to execute orders;
(c) a description of any specific arrangements with any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits received;
(d) an explanation of the factors that led to a change in the list of execution venues listed in the firm’s execution policy, if such a change occurred;
(e) an explanation of how order execution differs according to client categorisation, where the firm treats categories of clients differently and where it may affect the order execution arrangements; This information will be publicly available on Land-FX’s website.

Significant Instructions

Best Execution is the term used to describe the obligation to ensure that all reasonable steps are taken to achieve the most favourable terms for the client, when either executing trades or passing orders to be executed.
Eligible Counterparties means investment firms, credit institutions, insurance companies, UCITS and their management companies, pension funds and their management companies, and other financial institutions authorised or regulated under Community legislation or the national law of a Member State as described in Article 24 of MiFID.
Execution Venue is the term used to describe the Regulated Market, MTF, Systematic Internaliser, OTF or any other Liquidity Provider where SFL executes an order on behalf of a client.
Financial Instruments means the instruments listed in Appendix 1. Material Change means a change where its disclosure is necessary to enable the client to make a properly informed decision about whether to continue utilising the services of the firm.
MTF means a multilateral system, operated by an investment firm or a market operator, and which brings together multiple third-party buying and selling interests in financial instruments - in the system and in accordance with non-discretionary rules - in a way that results in a contract.
Professional Clients means any natural or legal person that meets the criteria laid down in either Section I or Section II of Annex II of MiFID.
Regulated Market a multilateral system operated by and/or managed by a market operator, which brings together or facilitates the bringing together of multiple third-party buying and selling interests in financial instruments – in the system and in accordance with its nondiscretionary rules – in a way that results in a contract, in respect of the financial instruments admitted to trading under its rules and/or systems, and which is authorised and functions regularly and in accordance with the provisions of Title III of MiFID II.
Retail Clients means a client who is not a Professional Client or an Eligible Counterparty.
Specific Instructions means an instruction in relation to an entire order, or any particular aspect of an order, including selecting to execute on a particular venue.
Systematic Internaliser means an investment firm which, on an organised, frequent and systematic basis, deals on its own account by executing client orders outside a regulated market or MTF.

ANNEX I: Classes of financial instruments
(a) Equities – Shares & Depositary Receipts
(i) Tick size liquidity bands 5 and 6 (from 2000 trades per day)
(ii) Tick size liquidity bands 3 and 4 (from 80 to 1999 trades per day)
(iii) Tick size liquidity band 1 and 2 (from 0 to 79 trades per day)
(b) Debt instruments
(i) Bonds
(ii) Money markets instruments
(c) Interest rates derivatives
(i) Futures and options admitted to trading on a trading venue
(ii) Swaps, forwards, and other interest rates derivatives
(d) credit derivatives
(i) Futures and options admitted to trading on a trading venue
(ii) Other credit derivatives
(e) currency derivatives
(i) Futures and options admitted to trading on a trading venue
(ii) Swaps, forwards, and other currency derivatives
(f) Structured finance instruments
(g) Equity Derivatives
(i) Options and Futures admitted to trading on a trading venue
(ii) Swaps and other equity derivatives EN 3 EN
(h) Securitized Derivatives
(i) Warrants and Certificate Derivatives
(ii) Other securitized derivatives
(I) Commodities derivatives and emission allowances Derivatives
(i) Options and Futures admitted to trading on a trading venue
(ii) Other commodities derivatives and emission allowances derivatives
(j) Contracts for difference
(k) Exchange traded products (Exchange traded funds, exchange traded notes and exchange traded commodities)
(l) Emission allowances
(m) Other instruments

LandFX UK LTD 2017 Execution Data by Class of Instruments/Client Type/Liquidity Providers

Top Five Execution Venues - Proportion of Volume Traded as a percentage of total in that class	FX-Professional	Indices-Professional	Commodities-Professional
Swissquote	65.14%	88.88%	25.63%
Saxo	34.85%	0.00%	74.37%
ADS	0.01%	11.12%	0.00%
CFH	0.00%	0.00%	0.00%
LMAX	0.00%	0.00%	0.00%

Top Five Execution Venues - Proportion of Volume Traded as a percentage of total in that class	FX-Retail	Indices-Retail	Commodities-Retail
Swissquote	83.37%	92.59%	25.63%
Saxo	15.37%	0.00%	74.37%
LMAX	0.03%	11.12%	0.00%
ADS	0.03%	0.00%	0.00%
CFH	1.19%	0.00%	0.00%