Order
Execution

1.2The Policy is issued in satisfaction of the Client Agreement, which provides that additional execution provisions, venues, price sources and review arrangements are set out in this Policy.

1.3This Policy describes arrangements and process. It does not create, extend or limit any contractual right, and it does not constitute a guarantee of any execution outcome. Where this Policy and the Client Agreement address the same matter, the Client Agreement prevails in accordance with the order of precedence stated in it.

1.4Nothing in this Policy removes or reduces a protection conferred on the Client by Applicable Law that cannot lawfully be excluded, and nothing in it excludes liability that cannot lawfully be excluded.

1.5Terms defined in the Client Agreement have the same meaning in this Policy.

1.6By placing an Order, the Client consents to this Policy and to the execution arrangements it describes, including execution outside a regulated market where permitted and disclosed.

2.2Each entity is separately licensed. The capacity in which each entity deals, and the execution arrangements available to it, differ, as summarised in the entity variation table above and set out in section 4.

2.3An obligation owed by one entity is not owed by the other. Nothing in this Policy makes one entity responsible for the acts, omissions or obligations of the other, of an affiliate, or of any third party.

2.4Authorisation does not guarantee an execution outcome. No regulator approves or guarantees any price, any execution or any result obtained by the Client.

3.2This Policy applies to the execution of Orders and to the receipt and transmission of Orders for execution.

3.3This Policy does not apply where the Client has not placed an Order with the Company, or where a Transaction is entered into under separate written transaction-specific terms that address execution.

3.4The Company owes the obligations described in this Policy in respect of the elements of an Order that it controls. It does not owe them in respect of matters outside its control, including the behaviour of an underlying market, the acts or omissions of an independent third party, or the Client's own decisions.

4.2Royce Capitals Ltd. acts as an intermediary. It does not act as principal, does not execute as principal and does not retain proprietary market risk. It routes or facilitates execution through one or more regulated principal brokers, liquidity providers or other counterparties in accordance with the arrangements described in this Policy.

4.3Royce Global Markets Limited may execute through one or more venues, liquidity providers, brokers, exchanges, market makers or counterparties, or outside a regulated market where permitted and disclosed. Its execution capacity and routing model for a Financial Instrument or Account are stated in the execution arrangements published through an Approved Medium and in the relevant confirmation.

4.4Where the Company or an affiliate deals as principal or as matched principal, it is the counterparty to the Client's Transaction and its economic interest may differ from the Client's. That circumstance is addressed in the Conflicts of Interest Policy and does not reduce the obligations in this Policy.

4.5The Company does not act as the Client's agent or fiduciary, and nothing in this Policy creates a fiduciary, trustee, partnership or agency duty in favour of the Client, except to the extent a specific duty is imposed by Applicable Law or expressly accepted by the Company in writing.

5.2A pending Order is an instruction that becomes executable only when a stated condition is met. Pending Order types may include buy limit, sell limit, buy stop, sell stop, stop-loss, take-profit and trailing stop, as made available for the relevant Financial Instrument.

5.3A limit Order becomes executable when the relevant side of the market reaches the limit price. It is then executed at the best price available, or rejected where no price is available.

5.4A stop Order becomes executable when the relevant side of the market reaches the stop level. It is then treated as a market Order and executed at the first price available, which may be materially different from the stop level.

5.5A trailing stop operates by reference to a stated distance from the prevailing price. Its behaviour depends on the platform implementation, and it may not function where the Client's platform connection is interrupted.

5.6Availability, minimum distance, expiry and behaviour of each Order type are stated in the Contract Specifications and may differ by Financial Instrument, Account and market condition.

6.2This is an obligation as to process, not as to outcome. The Company undertakes to apply its execution arrangements consistently; it does not undertake that any individual Order will achieve the best price available anywhere, or the fastest execution, or any particular result.

6.3Compliance is assessed across Orders over time and against the total consideration for an Order, and not by comparing a single execution against a price observed elsewhere after the event.

6.4A price observed on another venue, platform, data source or provider is not evidence that the same price, in the same size, was available to the Company at the relevant moment.

6.5The Company is not required to pass through the most favourable price visible on an unrelated venue where that price was not available to the Company for the relevant size and time.

7.2Total consideration, comprising the price of the Financial Instrument and the costs related to execution, is ordinarily the most important factor for the Client categories the Company serves.

7.3The Company may nonetheless give precedence to speed, to likelihood of execution and settlement, to size or market impact, or to another factor, where doing so is necessary to deliver the best possible result in terms of total consideration.

7.4Costs related to execution include the spread, commission, and any fee payable to a third party involved in executing the Order.

8.2For liquid Financial Instruments traded frequently in ordinary market conditions, price is generally the predominant factor.

8.3For an Order that is large relative to available liquidity, or in a Financial Instrument that is illiquid or subject to restricted trading, likelihood of execution and settlement may take precedence over price.

8.4In volatile or disorderly conditions, the Company may be unable to obtain the best price or the fastest execution. In those conditions all relevant factors are taken into account, and likelihood of execution and Order size in particular.

8.5The Company does not determine the relative importance of factors by reference to the identity of an individual Client, or to any benefit accruing to the Company from a particular routing decision.

9.2A specific instruction may prevent the Company from applying its usual execution arrangements. To the extent the instruction applies, the Company is treated as having satisfied its obligation to obtain the best possible result, and the Client accepts the outcome that follows from the instruction.

9.3Elements of an Order not covered by a specific instruction remain subject to this Policy.

9.4The Company may decline a specific instruction where it cannot be implemented lawfully or operationally, and is not obliged to explain the operational basis for declining.

9.5Selecting an Order type, a price level, a size, a time of submission, an automated tool or a trading strategy is a decision of the Client. The consequences of those decisions rest with the Client.

10.2A list or description of the principal execution arrangements in use for each entity is made available through an Approved Medium and is updated as those arrangements change.

10.3Where a single counterparty or arrangement is used for a Financial Instrument, the Company satisfies itself that the arrangement is capable of delivering the best possible result on a consistent basis. The Client acknowledges that in that case there is no alternative venue accessible through the Company.

10.4Counterparties and venues are selected and reviewed against execution quality, pricing, reliability, capacity, settlement performance, cost and regulatory standing.

10.5The Company may add, replace or cease to use a counterparty, venue or arrangement at any time, including where commercial terms change, where performance deteriorates, or where Applicable Law requires it.

10.6Executing outside a regulated market may expose the Client to counterparty risk and to the absence of exchange or clearing-house protections. Those risks are described in the Risk Disclosure Policy.

11.2A quote is firm or indicative according to its context. An indicative quote is not an executable offer. The Company will not publish a quote it has no intention of honouring, but availability of any price depends on market conditions at the moment of execution.

11.3An executed price may reflect external price sources, available liquidity, Order size, market impact, hedging cost, credit and operational factors.

11.4Prices displayed by the Company may differ from prices displayed on other venues, platforms or data sources, including because of differences in liquidity, timing, aggregation method and cost structure.

11.5Spreads are variable and may widen materially and without notice during volatility, at session opens and closes, around announcements and in thin conditions.

11.6Where a price feed from a source is delayed, suspended or unavailable, pricing for the affected Financial Instrument may be suspended, and Orders in it may be rejected until pricing resumes.

12.2Slippage is a normal characteristic of the markets in which the Company's Financial Instruments are traded and arises in particular from insufficient liquidity, volatility around announcements and economic events, and market openings and closings.

12.3The Company's execution systems do not apply asymmetric treatment to slippage as between Clients, and do not apply criteria specific to an individual Client Account.

12.4The Company does not accept responsibility for execution differences arising from ordinary market practice of this kind, which are outside its control, save to the extent that liability cannot lawfully be excluded or arises under clause 24.1 of the Client Agreement.

12.5Where price updates from a source are temporarily suspended during a significant event, an Order executed when pricing resumes may experience material slippage. The Client will receive the best price available to the Company at that time.

13.2Otherwise comparable Orders are executed in the sequence in which they are received, unless the characteristics of the Order, the prevailing market conditions or the Client's interests make that impracticable.

13.3The Company may aggregate an Order with another Order where it reasonably considers that aggregation is unlikely to disadvantage the Client overall. Aggregation may nonetheless work to the disadvantage of a particular Order.

13.4Where aggregated Orders are partially filled, allocation is performed using an approach intended to be fair and orderly, and is not applied so as to favour the Company, a Relevant Person or one Client over another.

13.5Where the Company obtains a price improvement before executing an Order, the improvement is passed to the Client.

13.6Information about a pending Client Order is not used by the Company, or by any person acting for it, to deal ahead of that Order.

14.2Where the requested size exceeds the size the Company is able to trade in the relevant market at the time, the Order may be rejected in whole or in part.

14.3An Order larger than the size available at the best price may be filled across several price levels, with the portion executed above the best available size obtained at a less favourable price.

14.4Where an Order is partially filled, each fill may occur at a different price, and the remaining quantity may stay pending, be cancelled or be rejected according to the Order type and market conditions.

14.5A large Order may itself move the market against the Client. The Company is not responsible for market impact arising from the size of an Order the Client chose to place.

15.2An underlying market may continue to trade outside the Company's quoting hours, which increases the likelihood of a price gap between one session and the next. Orders in such Financial Instruments are subject to that gap risk.

15.3Where a market opens at a price materially different from the previous close, an Order whose trigger level falls between those prices may be triggered and will be filled at the first price reasonably obtainable by the Company by reference to the underlying market.

15.4Where market-sensitive information causes a gap between quoted prices, any existing Order falling between those prices may be triggered.

15.5Where trading in a Financial Instrument or its underlying market is suspended, halted or restricted, Orders in that instrument may be rejected, cancelled or left pending, and Positions may be unable to be closed.

16.2The Company may reject an Order where the price at which the Client sought to trade does not represent the price of the underlying market at the time the Order was received, including where the discrepancy arises from communication latency or from deliberate manipulation of displayed prices.

16.3A request to amend or cancel an Order is effective only when it is accepted and processed. An Order may execute before the amendment or cancellation reaches the relevant system, and the Client remains bound by that execution.

16.4The Company is not obliged to accept every Order and is not obliged to give a reason for rejecting one, except where Applicable Law requires it.

17.2Certain platform functions are provided by an independent software vendor and operate outside the Company's control. Where such a function does not perform as the Client expects, the Client remains responsible for monitoring and managing open Positions and pending Orders.

17.3Where the Client experiences connectivity difficulty and needs to place, amend, cancel or close a Transaction, the Client must contact the Company through an alternative Approved Medium without delay. The Company does not guarantee that an alternative channel will be available or that an instruction can be executed before the market moves.

17.4The Company makes reasonable and continuing efforts to resolve technical issues affecting access to the Trading Platform. Unexpected failure or disruption may nonetheless occur.

17.5The Company is not responsible for loss arising from the failure, delay, interruption or malfunction of an independent system, network or provider, or of the Client's own equipment, software or connection, save to the extent that liability cannot lawfully be excluded or arises under clause 24.1 of the Client Agreement.

18.2The Company may review the details of an Order, including price, time, size and execution type, and where an error is identified may correct the price or terms to the level that would have applied absent the error, cancel the affected Transaction, or leave it unchanged, acting fairly and reasonably.

18.3The appearance of an executed price on the Trading Platform does not by itself establish that the Transaction was executed correctly. A price may be corrected after execution and after confirmation where an error is subsequently identified.

18.4A correction may be made without prior notice where prompt action is required, and the Company will notify the Client with a reasonable explanation afterwards.

18.5The Company will not cancel a legitimate profitable Transaction merely because it was profitable. A correction is made only on a documented ground under this Policy, the Client Agreement or Applicable Law.

18.6The relevant factors are those set out in the Manifest Error provisions of the Client Agreement, including whether the Client knew or should reasonably have known of the error.

19.2The Client is responsible for maintaining compatible equipment, reliable connectivity and appropriate security controls, and for monitoring the Account, the Trading Platform and the trading records on a continuing basis.

19.3Where the Client uses automated tools, Expert Advisors or application interfaces, the Client remains responsible for every Order they generate, including Orders generated by error, by unexpected behaviour or after loss of connectivity.

19.4The Client must notify the Company immediately on identifying an apparent error in an Order, a Transaction or a record.

19.5Duplicate instructions remain the Client's responsibility unless caused by a proven Company system error.

20.2Where no objection is made within that period, the records as shown on the Trading Platform and in the Company's trading records may be treated as accepted, save that this does not validate fraud, wilful misconduct, a Manifest Error or a liability that cannot lawfully be excluded.

20.3The Company's time-stamped platform, server, pricing, communication and transaction records are the primary evidence of what occurred. In the event of a discrepancy those records are considered together and constitute rebuttable evidence.

20.4The Client must preserve relevant device, platform and communication records while an objection or dispute is outstanding.

20.5The Company retains execution records for the period required by Applicable Law and makes them available to a regulator on request.

21.2The Company does not guarantee that an Order will be accepted, that it will be executed, that it will be executed at a requested or displayed price, that it will be executed within any period, or that a pending Order or conditional Order will be triggered or filled at its trigger level.

21.3The Company does not guarantee that any spread, price, liquidity or execution condition will be available, will remain available, or will match a price or condition observable elsewhere.

21.4Subject to the Client Agreement, the Company does not accept responsibility for loss arising from market movement; from ordinary execution risk including slippage, gaps, requotes, partial fills and rejections; from the acts, omissions, failure or insolvency of an independent venue, counterparty, liquidity provider, bank, payment provider, software vendor, network or other third party; from the Client's own instructions, decisions, strategies or automated tools; from the Client's equipment, software, connectivity or credential compromise; or from a Force Majeure Event.

21.5Any market commentary, research, signal, education, analysis, calculator or model output made available by the Company or by a third party through it is general information only, is not a personal recommendation, and is acted on at the Client's own risk.

21.6Nothing in this Policy limits the Company's responsibility for direct loss caused by its fraud, wilful misconduct, gross negligence or breach of a non-excludable legal duty, or excludes any liability that cannot lawfully be excluded, including a mandatory obligation concerning Client Money or a regulatory duty. The liability provisions of the Client Agreement govern, and this Policy is read subject to them.

22.2Monitoring includes review of execution quality against the arrangements in use, review of counterparty and venue performance, and periodic review by the compliance function with reporting to the Company's governing body.

22.3This Policy and the execution arrangements are reviewed at least annually, and in addition whenever a material change occurs that affects the Company's ability to continue obtaining the best possible result on a consistent basis using the arrangements covered by this Policy.

22.4Where a material change is made to this Policy or to the execution arrangements, Clients are notified through an Approved Medium.

22.5A Client may request further information about the Company's execution arrangements, and the Company will provide it within a reasonable period, subject to confidentiality obligations owed to counterparties and third parties.

23.2The current version of this Policy is made available through an Approved Medium. The Company maintains version control and records the effective date of each version.

23.3The governing language of this Policy is English. A translation is provided for convenience only and, in the event of conflict, the English version prevails to the extent permitted by Applicable Law.