Email: info@xmtrading.com | Web: www.xmtrading.com
Address(es): F20, 1st Floor, Eden Plaza, Eden Island, Seychelles (Tradexfin Limited) c/o Amicorp (Mauritius) Limited,
6th Floor, NeXTeracom Building, Ebene, Mauritius (Fintrade Limited)ORDER EXECUTION POLICY
1. Introduction
XMTrading operating by Tradexfin Limited, a Security Dealer Licensee, regulated and authorised by theFinancial Services Authority (“FSA”) in Seychelles with licence number SD010, and Fintrade Limited, an
Investment Dealer (Full Service Dealer excluding Underwriting) Licensee, regulated and authorised by theFinancial Services Commission in Mauritius (“FSC”) under the license number GB20025835 (hereinafterreferred to as the “Companies” and/or “XMTrading”).
The Companies, as regulated entities, are required to take reasonable steps to find and deal on the terms
which are the best available to the client when dealing with or for a client (“best execution”). In order tocomply with this requirement, XMTrading has established and provides its clients and potential clients with
its Order Execution Policy (hereinafter the “Policy”).
This Policy forms part of the Terms and Conditions of Business/Client Agreement and by agreeing withour Terms and Conditions of Business, which is a contractually binding agreement between you and theXMTrading, you are also agreeing to the terms of the Policy set forth in this document.
2. Scope and services
This Policy applies when executing transactions with you for the Securities provided by the XMTrading. It
is up to the XMTrading’s discretion to decide which types of Securities to make available and to publish
the prices at which these can be traded. XMTrading is always the counterparty (or principal) to every trade;
therefore, if the Client decides to open a position in a Security with XMTrading, then that open position can
only be closed with XMTrading.
The Client is given the option to place with XMTrading the following orders for execution in the following
ways:
a. The Client places a “Market Order” which is an order instantly executed against a price that XMTrading
has provided. The client may attach to a market order a Stop Loss and/or Take Profit. Stop Loss is anorder to limit Client’s loss, whereas Take Profit is an order to limit Client’s profit.
b. The Client places a “Pending Order”, which is an order to be executed at a later time at the price that
the Client specifies. XMTrading will monitor the pending order and when the price provided by
XMTrading reaches the price specified by the Client, the order will be executed at that price. The
following types of pending orders are available: ‘Buy Limit’ (an order to purchase a Security at or below
a specified price), ‘Buy Stop’ (an order to buy a Security, which is entered at a price above the current
offering price; it is triggered when the market price touches or goes through the buy stop price), ‘SellLimit’ (an order to sell a Security at a specified price or better), and ‘Sell Stop’ (an order to sell aSecurity when it reaches a certain price). You may attach to any ‘Pending Order’ a ‘Stop Loss’ and/or‘Take Profit’.
c.

You may hold up to 200 positions simultaneously (considered as summary of “Market” and “PendingOrders” per “Client”).

The Client may modify an order before it is executed. The Client has no right to change or remove StopLoss, Take Profit and Pending Orders if the price has reached the level of the order execution.
3. Best execution factors
XMTrading shall take all reasonable steps to obtain the best possible result for its Clients taking into
account the following factors when executing Clients orders against its quoted prices:a. Priceb. Costsc. Speed of Execution

Email: info@xmtrading.com | Web: www.xmtrading.com
Address(es): F20, 1st Floor, Eden Plaza, Eden Island, Seychelles (Tradexfin Limited) c/o Amicorp (Mauritius) Limited,
6th Floor, NeXTeracom Building, Ebene, Mauritius (Fintrade Limited)

d.
e.
f.
g.

Likelihood of Execution
Likelihood of settlement
Size of orderMarket Impact

XMTrading does not consider the above list exhaustive and the order in which the above factors arepresented shall not be taken as priority factor. Nevertheless, whenever there is a specific instruction fromthe Client, XMTrading shall make sure that the Client’s order shall be executed following the specificinstruction.
4. Best execution criteria
XMTrading will determine the relative importance of the above factors by using its commercial judgment
and experience in the light of the information available on the market and taking into account the criteria
described below:
a.
b.
c.
d.

the characteristics of the client;
the characteristics of the order;
the characteristics of Securities that are the subject of that order;
the characteristics of the execution venues to which that order can be directed.

5. Execution venue(s)For the purposes of orders for the Security provided by XMTrading, the latter acts as principal and not as
agent on the Client’s behalf; therefore, XMTrading is the sole Execution Venue for the execution of theClient’s orders. XMTrading does not transmit the Client’s order in the external market if the order is for theSecurity provided by XMTrading.
Best Execution: It is XMTrading’s policy to maintain such internal procedures and principles in order to act
for the best interest of its Clients and provide them the best possible result (including “Best Execution”)
when dealing with them.
Off-exchange transactions: The Client acknowledges that the transactions entered in Securities with
XMTrading are not undertaken on a recognized exchange, rather they are undertaken through
XMTrading’s Trading Platform and, accordingly, they may expose the Client to greater risks than regulated
exchange transactions. Therefore, XMTrading may not execute an order, or it may change the opening(closing) price of an order in case of any technical failure of the trading platform or quote feeds. The terms
and conditions and trading rules are established solely by the counterparty which in this case is XMTrading.
The Client is obliged to close an open position of any given Security during the opening hours of theXMTrading’s Trading Platform. The Client also has to close any position with the same counterparty withwhom it was originally entered into (i.e. with XMTrading).
6. Monitor and review
XMTrading will monitor on a regular basis the effectiveness of this Policy and, in particular, the execution
quality of the procedures explained in the Policy and, where appropriate, reserves the right to correct any
deficiencies.
In addition, XMTrading will review the Policy at least annually. A review will also be carried out whenevera material change occurs that affects the ability of XMTrading to continue to the best possible result for theexecution of its client orders on a consistent basis using the venues included in this Policy. XMTrading will
notify its affected clients on any material changes in its Policy.
7. Client consent
XMTrading may obtain the above consents in the form of a general agreement where the Client is informedthat for any orders placed with XMTrading for the Securities offered by the latter, XMTrading acts as theprincipal and the sole Execution Venue.

Email: info@xmtrading.com | Web: www.xmtrading.com
Address(es): F20, 1st Floor, Eden Plaza, Eden Island, Seychelles (Tradexfin Limited) c/o Amicorp (Mauritius) Limited,
6th Floor, NeXTeracom Building, Ebene, Mauritius (Fintrade Limited)XMTrading reserves the right to review and/or amend its Policy and arrangements, at its sole discretion,
whenever it deems fit or appropriate.

Email: info@xmtrading.com | Web: www.xmtrading.com
Address(es): F20, 1st Floor, Eden Plaza, Eden Island, Seychelles (Tradexfin Limited) c/o Amicorp (Mauritius) Limited,
6th Floor, NeXTeracom Building, Ebene, Mauritius (Fintrade Limited)