BEST INTEREST & ORDER EXECUTION
POLICY

Best Interest & Order
Execution Policy

TABLE OF CONTENTS
1.

INTRODUCTION ................................................................................................................................................................................52.

SCOPE....................................................................................................................................................................................................53.

TYPE OF ORDER EXECUTION .....................................................................................................................................................5

4.

ORDER EXECUTION ELEMENTS & RISKS ..............................................................................................................................6
A.

PRICES ..................................................................................................................................................................................................6

B.

SLIPPAGE .............................................................................................................................................................................................6a)Trade in low volatile and high liquidity markets ................................................................................. 7b)

Employ guaranteed stops and limit Orders ........................................................................................... 7

C.

PARTIAL FILLS .................................................................................................................................................................................... 7

D.

COMMISSIONS ................................................................................................................................................................................ 7

E.

MARK-UP ............................................................................................................................................................................................ 7F.

TRADE REJECTION .........................................................................................................................................................................8G.

VOLATILITY & GAPS ......................................................................................................................................................................8H.

TRADING SYSTEM OR INTERNET CONNECTIVITY EXECUTION DELAYS ...........................................................8I.

CANCELLATION OF TRADES AND/OR CLOSURE OF POSITIONS ........................................................................8

5.

ORDER TYPES FOR METATRADER 5 (MT5) .......................................................................................................................8
A.

MARKET ORDERS ............................................................................................................................................................................8B.

PENDING ORDERS ..........................................................................................................................................................................9C.

STOP ORDERS ..................................................................................................................................................................................9D.

LIMIT ORDERS ...................................................................................................................................................................................9E.

STOP-LIMIT ORDER .......................................................................................................................................................................9F.

STOP LOSS .........................................................................................................................................................................................9G.

TAKE PROFIT ......................................................................................................................................................................................9H.

GOOD 'TIL CANCELLED ('GTC') ............................................................................................................................................ 10‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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Best Interest & Order
Execution Policy
I.

GOOD 'TIL DATE ('GTD') ........................................................................................................................................................... 10J.

PENDING ORDER MODIFICATION/CANCELLATION .................................................................................................. 10

6.

MARGIN AND LEVERAGE .............................................................................................................................................................11A.

INITIAL MARGIN REQUIREMENT ..............................................................................................................................................11

B.

MAINTENANCE MARGIN REQUIREMENT & POSITIONS LIQUIDATION (‘STOP OUT’) ............................. 13

7.

CORPORATE ACTIONS ............................................................................................................................................................... 14A.

DIVIDENDS........................................................................................................................................................................................ 14

B.

FRACTIONAL SHARE ADJUSTMENTS................................................................................................................................. 14C.

OTHER CORPORATE ACTIONS (INCLUDING, BUT NOT LIMITED TO STOCK SPLITS AND RIGHTSISSUE) ............................................................................................................................................................................................................ 14D.

EARNINGS ANNOUNCEMENTS ............................................................................................................................................. 15E.

DE-LISTING....................................................................................................................................................................................... 16F.

CORPORATE ACTIONS WHICH ARE NOT MENTIONED IN THIS SECTION ................................................... 16

8.

BEST EXECUTION ........................................................................................................................................................................... 16
A.

PRICES ................................................................................................................................................................................................ 16

B.

COSTS ................................................................................................................................................................................................ 17

C.

SPEED OF EXECUTION ............................................................................................................................................................... 17

D.

LIKELIHOOD OF EXECUTION ................................................................................................................................................... 18

E.

LIKELIHOOD OF SETTLEMENT ................................................................................................................................................. 199.

OTHER EXECUTION CONSIDERATIONS ............................................................................................................................. 19A.

CURRENCY VALUATION ........................................................................................................................................................... 19

B.

SIZE OF ORDER .............................................................................................................................................................................. 19C.

UNEXPECTED AND UNFORESEEABLE MARKET EVENTS ........................................................................................... 19

D.

MANIFEST ERROR ........................................................................................................................................................................ 20

E.

PROHIBITED TRADING TECHNIQUES ................................................................................................................................. 21a)

Artificial Intelligence Software ......................................................................................................................... 21b)

Arbitrage......................................................................................................................................................................... 22c)

Algorithmic trading or high-frequency algorithmic trading techniques ...................... 23‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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Best Interest & Order
Execution Policyd)Specific Client Instructions ............................................................................................................................... 25

10.

AGGREGATION, SPLITTING AND ALLOCATION OF ORDERS ................................................................................ 26

11.

EXECUTION VENUES ................................................................................................................................................................... 26

12.

MONITORING AND REVIEW .................................................................................................................................................... 27

13.

RECORD KEEPING ......................................................................................................................................................................... 27

14.

NO FIDUCIARY RELATIONSHIP .............................................................................................................................................. 27

15.

YOUR CONSENT ............................................................................................................................................................................ 27

16.

IMPORTANT INFORMATION .................................................................................................................................................... 29

17.

CONTACT US .................................................................................................................................................................................. 29‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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Best Interest & Order
Execution Policy

BEST INTEREST & ORDEREXECUTION POLICY
1.

INTRODUCTION

1.1.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company
registered in Seychelles with company registration number: 8429300-1, having its
registered office at CT House, Office 9A, Providence, Mahé, Seychelles.

1.2.

‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles
as a Securities Dealer with License number: SD087

1.3.

A reference in this document to “we”, “us”, “FinPros”, “our”, “ours” and “ourselves” (asappropriate) is a reference to ‘FinPros Financial Ltd’.

1.4.

This Policy applies to all Clients of FinPros, both retail and professional, when executing
transactions in the financial instruments provided by us via Contracts for Differences(“CFDs”).

1.5.

This Policy is provided to you alongside our ‘Client Agreement – Terms & Conditions ofBusiness’ and contains further details on our services and the activities you may carry out
with us.

2.

SCOPE

2.1.

The Best Interest & Order Execution Policy of the Company applies to both retail andprofessional Clients.

3.

TYPE OF ORDER EXECUTION

3.1.

At FinPros, Clients’ Orders are executed following the ‘Market Execution’ model. Market
execution is a type of execution in which the Client places an Order and specifies only thevolume. The Bid/Ask price of a Financial Instrument is generated during the process of
execution.

3.2.

As opposed to ‘Instant Execution’, under the ‘Market Execution’ model, FinPros does not
reject a Client’s Order in the event of change in price, but fills the Order with the current
price. The final price is composed by taking the required volume by available prices from
the Market. In these circumstances, any variation between the executed price and theintended price is considered ‘slippage’ (see paragraph B further below). The slippage
may be zero, positive, or negative, and it depends on whether the Order is a buy or sell, or
whether the Order is for opening or closing a position, and on the direction of pricemovement. A positive slippage gets a Client a better price than expected, while a negative‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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Best Interest & Order
Execution Policy
slippage leads to a loss. Slippage may occur when a huge market Order is finalized, butthere is an insufficient volume at the selected price for maintaining the bid/ask spread.

4.

ORDER EXECUTION ELEMENTS & RISKS

4.1.

FinPros takes all sufficient steps to obtain the best possible result for its Clients when
executing Client Orders, taking into account a combination of the following best execution
factors. FinPros does not consider the below list of factors as an exhaustive list and theOrder in which these factors are presented are not on a priority basis.
A. PRICES

4.2.

We receive price feeds from some of the world’s leading liquidity and data providers(“LPs”). Having leading LPs is important especially during abnormal market conditions,such as times of extreme volatility, when some liquidity providers may decide to widen
the spreads or stop quoting prices at all. Having leading LPs enables us to provide youwith competitive prices, as the remaining liquidity providers shall continue competing toprovide us their best ‘Bid’ and ‘Ask’ prices.
B. SLIPPAGE

4.3.

This is the difference between the executed price and the Order price at the time the Orderis submitted for execution. Slippage is normal and expected cost of trading, particularly
for Orders of larger size and during times of thin liquidity and/or volatile markets.

4.4.

Slippage usually occurs in periods when the Market is highly volatile, or the Market liquidity
is low. Since the participants are fewer in markets with low liquidity, there is a wide time
gap between the placement and execution of an Order. The volatile markets experience
quick price movements, even quicker than filling an Order. Hence, the price of a Financial
Instrument may change during the time gap, which results in slippage.

4.5.

In forex trading, slippage normally occurs on less popular currency pairs – such as
AUD/JPY – since highly popular currency pairs come with low volatility and high liquidity.
Slippage often occurs during or around major events such as announcements regarding
interest rates and monetary policy, earnings report of a company, or changes in the
management positions. The events increase market volatility, which can increase thechances of investors experiencing slippage. When investors hold positions after markets
close, they can experience slippage when the market reopens. It happens because theprice may change due to any news event or announcement that could have happened
while the market was closed.

4.6.

FinPros takes sufficient steps so that the execution of the quoted prices will obtain the best
possible result for its Clients at the time the quote is provided. Nevertheless, rapidly‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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Best Interest & Order
Execution Policychanging markets might result in the execution of an Order at a price, which has ceased
to be the best market price.
4.7.

In addition, there are various ways in which Clients can minimize the consequences ofslippage. Some of these are as follows:a) Trade in low volatile and high liquidity markets

4.8.

The prices in low volatile markets usually do not change quickly, and high volatile markets
have many market participants on the other side of the trade. Hence, if investors trade inhighly liquid and low volatile markets, they can limit the risk of experiencing slippage.

4.9.

Moreover, the chances of slippage can be reduced by trading during the periods
experiencing the most activity since liquidity will be the highest during that time. It
increases the chances of the trade getting executed quickly at the requested price. For
example, the largest volume of trades is executed in the stock markets when the major
U.S. stock exchanges are open. The forex trading experiences the largest volume during
the open hours of the London Stock Exchange (LSE).

b) Employ guaranteed stops and limit Orders
4.10.

Since an Order with a guaranteed stop will be executed at the requested price, slippage
risk is prevented. However, a premium attached to the guaranteed stop will be incurred if
it is triggered. A ‘Limit Order’ can help lessen the risk of slippage when investors enter a
trade or seek to gain returns from a successful trade.

4.11.

When a ‘Limit Order’ is activated, the Order will be filled at the specified price or afavourable price. It implies that execution of a sell Order takes place at the desired priceor a higher price, whereas the execution of a buy Order takes place at the specified priceor a lower price.

C. PARTIAL FILLS
4.12.

This is the practice of executing an Order in parts, at a time where there is not enoughliquidity in the market. Partial fills may be executed at different prices than the requested
price.

D. COMMISSIONS
4.13.

Depending on the Account and instrument type, Clients may be charged commissions
when trading CFDs. Further information is available on our Website.

E. MARK-UP
4.14.

Clients shall be charged mark-up (instead of commission) when trading CFDs on specificAccount types under the MT5 platform. Further information is available on our Website.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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Best Interest & Order
Execution Policy
F. TRADE REJECTION
4.15.

A trade can be rejected for any of the following reasons: a) no liquidity in the market b)
trades submitted on the prices considered by the system as old or false c) not enoughfree Margin in the Account d) due any trading restrictions placed on the instrument c) andfor any reason we deem as a breach of our internal risk management.

G. VOLATILITY & GAPS
4.16.

During volatile markets, Orders may be executed at a substantially different price from thequoted Bid or Ask price, or the last reported trade price at the time of the Order entry, oran Order maybe only partially executed or maybe executed in several steps at different
prices and ‘market opening prices’ may differ significantly from the previous day’s close.

4.17.

Significant volatility and gaps are possible in case of news and unexpected events. In suchcase, Orders are executed at the first price after the gap. The first tick on the news releasehas to be confirmed by the second tick. Delays are possible in such cases, as the markets
need to calm down and supply the first quotes after the gap.

H. TRADING SYSTEM OR INTERNET CONNECTIVITY EXECUTION DELAYS
4.18.

I.
4.19.

If the Client undertakes transactions on an electronic system, the Client will be exposed torisks associated with the system including the failure of hardware and software (Internet/ Servers). The result of any system failure may result to Client Order is either not executed
according to Client instructions or it is not executed at all. FinPros does not accept any
liability in the case of such a failure.
CANCELLATION OF TRADES AND/OR CLOSURE OF POSITIONSFinPros might cancel the trade Order in circumstances where due to lack of liquidity in orsuspension of an asset or errors in feeds from LPs or quotes from Counterparties have
proved to be faulty. FinPros shall provide within a reasonable time a full explanation of thereason for the cancellation of a trade. FinPros may delete any ‘Pending Orders’ which are
older than 3 (three) months. FinPros may close, revoke, correct and/or adjust any tradesin circumstances where the Client is involved with arbitrage and/or prohibited trading
techniques. FinPros may close any trades which are deemed untrue or opened at a
fictitious price not existing on the market at the time of opening i.e. trades opened at old
prices.

5.

ORDER TYPES FOR METATRADER 5 (MT5)A. MARKET ORDERS

5.1.

These are Orders to buy or sell at the current market price that is available.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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Best Interest & Order
Execution Policy
B. PENDING ORDERS
5.2.

Pending Orders include:a) Buy Stop Orders: this are Orders to buy a specific quantity of the underlying
instrument with the triggering price (‘the stop price’) being higher than the current
market price (upon triggering the Order becomes Market Order).
b) Sell Stop Orders: these are Orders to sell a specific quantity of the underlying
instrument with the triggering price (‘the stop price’) being lower than the current
market price (upon triggering the Order becomes Market Order).
c) Buy Limit Orders: these are Orders to buy an instrument at a specified price (‘thelimit price’) that is lower than the current market price.
d) Sell Limit Orders: these are Orders to sell an instrument at a specified price (‘thelimit price’) that is higher than the current market price.
C. STOP ORDERS

5.3.

These are Orders to buy or sell once the price reaches a pre-set stop level (the 'stop price').
Once this Order is triggered, it is treated as a 'market Order'. If the 'stop Order' is not
triggered it shall remain in the system until a later date, subject to the conditions
described in the "Good 'til cancelled" section.

D. LIMIT ORDERS
5.4.

These are Orders to buy or sell once the price of an instrument reaches a pre-set level(the 'limit price'). It is used to execute trades at a pre-chosen level, rather than at theavailable market price at the time.

E. STOP-LIMIT ORDER
5.5.

Stop-limit Orders are Orders that combine the features of stop Order with those of a limit
Order. A stop-limit Order will be triggered at a specified price after a given stop price has
been reached or passed.

F. STOP LOSS
5.6.

These are ‘stop Orders' to control and minimise losses. They are used to close an open
position when the price of the instrument has moved contrary to the expected direction,
reaching a pre-set level.

G. TAKE PROFIT
5.7.

This is a ‘limit Order’ to secure profits. It is used to close an open position when the priceof the instrument has moved in the expected direction, reaching a pre-set target level.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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Best Interest & Order
Execution Policy
H. GOOD 'TIL CANCELLED ('GTC')
5.8.

This is an execution setting that Clients may apply to 'pending Orders'. The Order shallremain 'live' and pending for execution until it is triggered and treated as a market Orderor cancelled by the Client. Please note that GTC may become redundant in cases wherea CFD on futures reaches its maturity/expiry date. FinPros reserves the right to cancel GTC
Orders if they are not triggered within three (3) months.

I.
5.9.

GOOD 'TIL DATE ('GTD')
This is an execution setting that applies to 'pending Orders' traded through MetaTrader 5.
Clients may choose a specific date in the future until which the Order shall remain 'live'
and pending for execution. If the Order is not triggered during the pre-set timeframe, it will
be deleted by the system. Please note that GTD may become redundant in cases wherea CFD on futures reaches its maturity/expiry date and the date specified is after thematurity date. FinPros reserves the right to cancel GTD Orders if they are not triggered
within three (3) months.

J. PENDING ORDER MODIFICATION/CANCELLATION
5.10.

The Client places a “Pending Order”, which is an Order to be executed at a later time at
the price that the Client specifies. We will monitor the Pending Order and when the priceprovided by the Execution Venue reaches the price specified by the Client, the Pending
Order will automatically become a Market Order.

5.11.

The following types of Pending Orders are available: “Buy Limit”, “Buy Stop”, “Sell Limit” and“Sell Stop”. The Client may attach to any pending Order a “Stop Loss” and/or “Take Profit”.
The Client may modify an Order before it is executed. The Client has no right to change or
remove “Stop Loss”, “Take Profit” and “Pending Orders” if the price has reached the level of
the Order execution.

5.12.

An Order will be cancelled in the event of any of the following:a) If a Client manually cancels an Order prior to the market reaching the price levelspecified; orb) If a Client places an expiration timeframe and it is reached.
c) If an Order is triggered and there is not enough free Margin in the Account, the Orderwill be deleted.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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Best Interest & Order
Execution Policy
5.13.

Note: Please note that, as a general rule, we execute most Orders automatically, withminimal manual/human intervention. In addition to the provisions referred to in the 'Events
Outside our Control' section of the 'Account Terms ', we may execute an Order manually
without notifying Clients in advance.

5.14.

This may occur in instances where we experience, for example, increased market volatility,
illiquidity and infrequent price updates, a significant* Order size, as well as times where
the system identifies abusive trading behaviour and/or trades from multiple Client profiles
bearing the same characteristics (i.e. same software, symbol, time and price requested).
* the 'significance' is determined in our sole discretion.

6.

MARGIN AND LEVERAGE

6.1.

The Financial Instruments offered by FinPros are traded on ‘Margin’, which means that you
are required to put up only a fraction of the funds you would normally need in Order toopen a much larger position. This means rather than paying the full value of the position,
you only need to pay a percentage of the position, which is called the ‘Margin
Requirement’. Simply put, Margin is the amount of money required to open a position,
while leverage (or Margin ratio) is the multiple of exposure to your Account equity.

6.2.

Trading on Margin can be beneficial, but also entails high-risk, given the fact that you canpotentially lose your entire investment and that you may be required to deposit additional
funds to cover your losses. Please carefully read our ‘Risk Disclosures and Warning
Notices’. The relevant ‘Risk Disclosures and Warning Notices’ are included in our ‘Client
Agreement – Terms and Conditions of Business’, as well as a separate Risk DisclosureStatement that is published on our Website.

6.3.

The ‘Margin Requirement’ can be further broken down into ‘Initial Margin Requirement’and ‘Maintenance Margin Requirement’.

A. INITIAL MARGIN REQUIREMENT
6.4.

The ‘Initial Margin Requirement’ refers to the percentage of equity required when you
open a position and differs between each Financial Instrument, depending on market
volatility and liquidity in the underlying market. Different minimum ‘Initial Margin
Requirements’ may apply when trading CFDS on stocks, currencies, ETFs, commodities
and indices, and, in certain circumstances, cryptocurrencies. Each instrument has
maximum leverage limitations, which are published on our Website and are guided byindustry regulations, as well as FinPros’ own efforts to promote responsible trading andmitigate the risks of trading on Margin.

6.5.

For example, if you have $5,000 of equity in your Account and you would like to open a
position in a CFD that has a 50% ‘Initial Margin Requirement’, the size of the trades opened‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
Page 11 of 29

Best Interest & Order
Execution Policy
in your Account is multiplied by the applicable Margin percentage for each trade in thatparticular Financial Instrument. Then, the Margin used for all trades, i.e., the ‘Used Margin’,is subtracted from the equity in your Account, with the remaining Equity in your Accountthat is not tied up in Margin for current open positions being referred to as ‘Free Margin’
or ‘Usable Margin’. Please note that Margin requirements will be calculated solely in themain currency of your Account.
6.6.

Thus, if the ‘Initial Margin Requirement’ for the positions you wish to open is 50%, the sizeof the trades you are eligible to open on Margin in that particular Financial Instrument isthen calculated as follows:
Trading power * 50% >> is less than or equal to $5,000.
>> Buying power >> is less than or equal to $5,000 / 50% = $10,000>> You can open positions in that particular Financial Instrument up to $10,000
using your Margin buying power.

6.7.

The execution of Market Orders as well as Pending Orders is subject to ‘Free Margin’
availability, i.e. if the ‘Free Margin’ in the account (i.e., the remaining Equity in your Accountthat is not tied up in Margin for current open positions) does not exceed the ‘Initial Margin
Requirement’ to open the position, then the platform will automatically reject the Order.

6.8.

If the ‘Used Margin’ reaches 100% or more of the reaming equity in the Account, the Client
cannot open any new positions, as the Free Margin at such an occasion is either zero (at100% Margin Level) or negative (below 100% Margin Level).

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
Page 12 of 29

Best Interest & Order
Execution Policy
B. MAINTENANCE MARGIN REQUIREMENT & POSITIONS LIQUIDATION (‘STOP OUT’)
6.9.

When you hold open positions in Financial Instruments on Margin, in Order to allow somefluctuation in price, the minimum Margin requirement is lowered to 30%. This is called the‘Maintenance Margin Requirement’, i.e., the minimum amount of the remaining equity
that you must maintain in your Account after you have opened your trading positions.

6.10.

In Order to prevent the balance in your Account from going negative, when you are unable
to maintain the equity in your Account above the ‘Maintenance Margin Requirement’ andthe remaining equity in your Account falls below the 30% ‘Maintenance Margin’ threshold,we will automatically start closing your positions at the current market price, starting withthe position that carries the heaviest loss.

6.11.

For Example: You have $20,000 worth of CFDs open using $10,000 in cash and $10,000 on
Margin. If the total value of your holding drops to $14,000 and the amount you borrowed
on Margin remains $10,000, your equity worth will only be $4,000, which falls below the 30%
minimum margin requirement.

6.12.

If the ‘Maintenance Margin’ is still below the 30% ‘Maintenance Margin’ threshold, thesame procedure is repeated for the next applicable position. Positions will be closed untilthe ‘Maintenance Margin’ exceeds the 30% ‘Maintenance Margin’ threshold again.

6.13.

FinPros shall not be responsible for any losses and damages incurred to the Client due toclose out of his positions and all the expenses to close Client’s open positions shall be for
the Client’s account. For more details, please consult our ‘Leverage, Margin, Margin Call
& Margin Close-out Policy’.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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Best Interest & Order
Execution Policy
6.14.

Important: Please note that, in Order to protect FinPros and all of our Clients, FinPros may
modify Margin Requirements for any or all Clients for any open or new positions at any
time, in FinPros sole discretion to adjust for unprecedented volatility in financial markets.
The changes will promote reduction of leverage in Client portfolios and help ensure that
Clients' accounts are appropriately capitalized.

6.15.

If FinPros increases its Margin requirements, it may prevent a Client from increasing
positions size if the specific Client has insufficient equity.

6.16.

If you are unsure about the leverage that you are entitled to or the margin that is required,
FinPros strongly recommends that you contact us for these details. The information will be
provided for reference only. FinPros does not provide any investment advice or investment
recommendation and expects its Clients to have received independent investment
advice from an investment professional.

7.

CORPORATE ACTIONS
A. DIVIDENDSa) Clients holding long positions on the applicable share and/or spot index at the ex-div
date will receive a ‘net dividend’ (i.e. the dividend minus the applicable Withholding
Taxes) in the form of a cash adjustment (deposit, paid into their trading Account).
b) Clients holding short positions on the applicable share and/or spot index at the ex-div
date will be charged the dividend amount in the form of a cash adjustment(withdrawal, deducted from their trading Account).
c) We reserve the right to increase Margin requirements prior to the release of a dividend.
d) Stocks may be offered as a dividend. The dividend amount will be calculated using theshare price to determine the cash adjustment (see Fractional Share Adjustments).
B. FRACTIONAL SHARE ADJUSTMENTS

7.1.

In the event the corporate action results in a fractional position, the fractional component
may be represented as a cash adjustment independent of the handling for the nonfractional position.

7.2.

The adjustment value will equal the fractional position times the adjusted closing price on
the day prior to the ex-date.
C. OTHER CORPORATE ACTIONS (INCLUDING, BUT NOT LIMITED TO STOCK SPLITS AND RIGHTSISSUE)

7.3.

An appropriate adjustment on the Client’s position will be made to mirror the economic
impact of a corporate action.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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D. EARNINGS ANNOUNCEMENTS
7.4.

We may increase Margin requirements and limit maximum exposure on the relevant
symbols prior to earnings announcements.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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Best Interest & Order
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E. DE-LISTING
7.5.

In the event of a share being de-listed, the Client’s position will be closed at the last market
price traded.
F. CORPORATE ACTIONS WHICH ARE NOT MENTIONED IN THIS SECTION

7.6.

For certain corporate actions which are not mentioned in this section, including, but notlimited to Mergers, Acquisitions (together commonly referred to as ‘M&A’) and Leveraged
Buyouts (‘LBO’), we reserve the right to:a) increase Margin requirements.
b) suspend or halt trading in the relevant instrument.
c) limit the maximum exposure (Order size) to the relevant instrument.
d) close the positions in the event that the relevant instrument is no longer trading on
the relevant exchange.
e) take any other action as we deem necessary in the given circumstances.

8.

BEST EXECUTION

8.1.

We will take all sufficient steps to obtain the best possible result for our Clients, taking into
Account the price, costs, speed of execution, likelihood of execution and settlement, size,
nature or any other consideration relevant to the execution of the Order. The best possible
result is determined on the basis of the total consideration representing the price and thecosts associated with the execution, which include all expenses incurred by the Client,which are directly related to the execution of the Order.

8.2.

It should be noted that if the Client provided us with specific instructions on how to execute
his/her Order(s), complying with those instructions may prevent us from taking the steps
set out in this Policy. Under such circumstances, our execution in accordance with Client’s
instructions will be deemed best execution.
A. PRICES

8.3.

Price is the most important factor for ensuring best execution. As mentioned in paragraph
4.2 above, we contracted leading LPs providing us with their prices. Please note that theprices you will see on our trading platforms may differ from the prices you may see onother trading/charting platforms.
a) Bid-Ask Spread: For any given financial instrument, we quote two prices: the higher
price (Ask), at which the Client can buy (go long) a financial instrument, and thelower price (Bid) at which the Client can sell (go short); collectively referred to as
our prices. The difference between the Bid and the Ask price of a given financial‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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Best Interest & Order
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instrument is the spread, which includes our mark-up, wherever there is a mark-up
from our side.
b) Pending Orders: All ‘buy’ Market Orders open with the Ask Price and close with the
Bid Price. All ‘sell Market Orders open with the Bid Price and close with the Ask Price.
Please note that all Pending Orders turn into Market Orders when triggered.
c) Our price for a given financial instrument is calculated by referencing the price ofthe relevant underlying asset, which is obtained from third-party liquidity and data
providers. We update our prices as frequently as the limitations of technology andcommunication links allow. We will not quote any price outside of our operational
hours (see execution venues below).
d) We will at all times, subject to events outside of our control, transmit Bid and Ask
Prices through our trading platforms. We shall, in our sole discretion, determine theprices that are executable, and which appear through our trading platforms. The
Client accepts that FinPros is solely responsible for determining the validity of theseprices at any given time and that in some instances, where the market moves while
the Client is placing an Order, the Client may experience slippage (either positiveor negative), as described in paragraph 4.3 et Seq. above.
B. COSTS
8.4.

Execution venue costs are not a relevant factor, as FinPros is always the sole execution
venue and there are not third-party fees such as clearing, or settlement fees involved in
the execution of your Orders.

C. SPEED OF EXECUTION
8.5.

We place a significant importance in this factor when executing Client Orders and to thisend, we maintain high speed connections through multiple servers hosted globally. Our
execution is fully automated apart from minimal manual execution. However, the use of
any form of unstable connection at the Client’s end, whether wireless or dial-up, may
result in poor or interrupted connectivity, which may cause delays in the transmission ofdata between the Client and us.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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Best Interest & Order
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8.6.

In that regard, please note that of the use of electronic trading services through theInternet entails certain risks that may lead to undesirable losses. These risks may be
associated with the Internet network itself, software, or electronic trading system, in
addition to the misuse of the service by the Client.

8.7.

Thus, the speed of execution and any related slippage the Client may experience is heavily
dependent on the quality and stability of the Client’s internet connection, bandwidth,
technology used (3G, 4G, 5G, analogue, fiber etc.).

8.8.

Mobile and wireless devices, for instance, are not ideal for trading if speed of execution isimportant for the Client. Orders triggered from a mobile device or a device with low quality
and/or bandwidth connections are more likely to experience slower execution andslippage. The Client acknowledge that he/she is aware and accept these risks which
he/she might face while trading via the Internet. FinPros will not be responsible for any
failures of communication and/or any interruption or delay of trading via the Internet andwill not be liable for errors resulting in the Client’s Account balances as a result of any such
failures.

D. LIKELIHOOD OF EXECUTION
8.9.

We rely on third-party LPs for prices and available volume of the different financial
instruments we offer. Therefore, the execution of Client's Orders will depend on whether
there are prices and liquidity available at the time these Orders are received. By having
leading LPs, we enhance the likelihood of execution across the instruments we offer. Thisavailability may be subject to variation, especially during abnormal market conditions,such as:a) During market opening times.
b) During times of market news and events.
c) During periods of significant volatility.
d) Where there is a rapid price movement of a particular instrument, to such extent
that under the rules of a relevant exchange, trading on said instrument issuspended or restricted.
e) Where there is insufficient liquidity for the execution of a specific volume at a
specific declared price.
f) Where our internal risk limits no longer permit the acceptance of any further Orders
on a specific instrument.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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E. LIKELIHOOD OF SETTLEMENT
8.10.

All transactions are settled upon execution.

9.

OTHER EXECUTION CONSIDERATIONS
A. CURRENCY VALUATION

9.1.

We may provide a currency conversion quote from your Account’s base currency to thecurrency of the relevant financial instrument. This will not be reflected as an actual
currency conversion in your Account, but only serves the purpose of indicating thevaluation in the base currency.
B. SIZE OF ORDER

9.2.

The minimum size of an Order is 0.01 lots. We may place limits on maximum Order sizes
from time to time, and we reserve the right to decline an Order as per our ‘Client
Agreement – Terms & Conditions of Business’. We will make every effort to fill Orders
irrespective of the volumes. This however may be achieved at the ‘best available price’ as
per the available market liquidity at the time of execution (see ‘Likelihood of Execution’).

9.3.

In that regard, please note that FinPros reserves the right to raise the minimum Order size
to 0.1 for Accounts with an equity or balance above 10,000 units of currency.

9.4.

We reserve the right to place a cap on the number of contracts and/or a limit on the total
net position value per profile, for a given instrument. Where this occurs, we will make all
possible efforts within reason to provide Clients with prior notice.

C. UNEXPECTED AND UNFORESEEABLE MARKET EVENTS
9.5.

In Order to protect FinPros and all of our Clients against the potential adverse
consequences of certain unexpected and unforeseeable Market events, i.e., when themarket is highly volatile, FinPros might take any or all of the following steps, including but
not limited to:a. Restrict the opening of Orders;b. Decrease/Increase leverage;c. Widen/Narrow Spreads;
d. Decrease/Increase Margin Requirements;
e. Impose Volume Restrictions;
f.

9.6.

Suspend trading.

FinPros shall inform its Clients of the actions it is taking during such unexpected andunforeseeable Market events, which can cause the market to be highly volatile. FinPros‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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Best Interest & Order
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may do so via email to the Client’s registered email address provided by the Client during
the Account Opening procedure and/or through the Company’s website.
9.7.

Under these circumstances, the price of any Financial Instrument might be affectedmaking it impossible for the Company to execute any type of Order at the declared price.
In such circumstances, the ability to execute Orders on a timely basis will become theprimary factor.
D. MANIFEST ERROR

9.8.

We may, without your consent, at any time amend the terms of any Order or open Position
based on any error that we reasonably believe to be a Manifest Error.

9.9.

If, in our discretion, we choose to amend the terms of any such Order or open Position due
to a Manifest Error, the amended terms will equal those, which we reasonably believe
would have been fair at the time the Order was placed had the Manifest Error not occurred.

9.10.

In deciding whether an error is a Manifest Error we will act reasonably, and we may (butnot obliged to) take into account any relevant factors including, without limitation, thestate of the Market at the time of the Manifest Error or any error in, or lack of clarity of, any
information source or pronouncement upon which we base our quoted prices. Any
financial commitment that you have entered into or refrained from entering into inreliance on an Order placed with us will not be taken into account in deciding whether or
not there has been a Manifest Error.

9.11.

In the absence of our fraud, willful default or negligence, we will not be liable to you for any
Loss, cost, claim, demand or expense following a determination of a Manifest Error(including where the Manifest Error is made by any information source, commentator or
official on whom we reasonably rely) or any action (or omission) taken (or omitted) by asa result.

9.12.

If a Manifest Error has occurred and we choose to exercise any of our rights under thisclause, and if you have received any monies from us in connection with the Manifest Error,
you agree that those monies are due and payable to us on our written demand and you
agree to return an equal sum of those monies to us within the period stated in our written
demand.

9.13.

If a Transaction or Open Position is based on a Manifest Error, we may (in addition to ourother rights) without your consent do any or all of the following:a. amend the terms of a Transaction to reflect what we consider to have been the fairterms at the time the Transaction had been entered into had there been no
Manifest Error;b. Close Out the Transaction and any Open Positions resulting from it;‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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Best Interest & Order
Execution Policyc. adjust or suspend your Account;d. treat the Transaction as void from its inception;e. refrain from taking action to amend or void the Transaction; or
f.
9.14.

any other action that we believe is appropriate in the circumstances.

We will exercise our rights under the above clauses reasonably, in good faith and as soon
as reasonably practical after we become aware of the Manifest Error.

9.15.

To the extent reasonably practicable, we will give you prior notice of any action we takeunder the above clauses; but if it is not reasonably practicable, we will give you notice assoon as reasonably practicable afterwards.

9.16.

In the absence of fraud or gross negligence on our part, to the extent permitted by law weare not liable to you for any Loss, cost, claim, demand or expense that your incur or suffer(including loss of profits or indirect or consequential losses), arising from or connectedwith the Manifest Error including if the Manifest Error arises from an information service on
which we rely.

E. PROHIBITED TRADING TECHNIQUESa) Artificial Intelligence Software
9.17.

It is absolutely prohibited to use any software, which we determine, in our sole discretion,
to have as its purpose to apply any kind of artificial intelligence analysis to our trading
platform(s) and/or computer system(s) with an ultimate goal to gain unfair advantage
and exploit our trading platform(s); in the event that we determine, in our own discretion,that any such artificial intelligence software has been used, or is being used, we reserve
the right to take all action as we see fit, including, without limitation, completely blocking
access to our trading platform(s), blocking and/or revoking your Access Codes and/or
terminating your Account. Under these circumstances, we reserve the right to seize any
profits and/or revenues generated directly or indirectly by exercising any such prohibit
trading activity and or charge you with extra fees. In addition, we shall be entitled to informany Interested third parties of your breach of this clause; we have, and will continue todevelop any tools necessary to identify fraudulent and/or unlawful access and use of our
trading platform(s); any dispute arising from such fraudulent and/or or unlawful trading
activity will be resolved by us in our sole and absolute discretion, in the manner we deem
to be the fairest to all concerned; that decision shall be final and/or binding on allparticipants; no correspondence will be entered into.

9.18.

Moreover, it is absolutely prohibited to use any software in such a way, which can cause
serious negative impact on the performance of our servers and may prevent us fromachieving the best possible result for our Clients as regards the execution of their orders.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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Best Interest & Order
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In the event that we identify any such activity, we reserve the right to take all action as we
see fit, including, without limitation, completely blocking access to our trading platform(s),blocking and/or revoking your Access Codes and/or immediately terminating yourAccount. Moreover, you acknowledge that once your Account has been terminated we
may liquidate any outstanding contracts/positions you have with us. In view of the above,please note that you will be strictly prohibited from opening any new trading Account(s)and trade with us. Nonetheless, in cases where you may successfully open an Accountand trade with us due to any technical and/or human error, we reserve every right toimmediately close your Account upon identification, nullify any profit/loss generated andrefund the original amount of deposit, excluding any deposit and withdrawal charges.
b) Arbitrage
9.19.

Internet, connectivity delays, and price feed errors sometimes create a situation where
the price(s) displayed on our trading platform(s) do(es) not accurately reflect the market
rates. In that regard, we reserve the right, in our sole discretion, not to permit the use of
trading strategies aimed at exploiting errors in prices and/or concluding trades at offmarket prices and/or by taking advantage of internet delays (commonly known as“arbitrage”, “sniping” or “churning” hereinafter, collectively, referred to as “Arbitrage”) on
our trading platform(s) and/or in connection with our services.

9.20. Any indication or suspicion, in our sole discretion, of any form of Arbitrage (including but
not limited to risk free profiting), abuse (including but not limited to participant's trading
activity patterns that indicate that the participant solely aims to benefit financially without
being genuinely interested in trading in the markets and/or taking market risk), internal
hedging in coordination with other parties, abuse of our ‘no negative balance’ policy,
fraud, manipulation, cash-back arbitrage or any other forms of deceitful or fraudulent
activity, may, in our sole discretion, render all related Orders, transactions and/or
contracts void, without prior notice being required.
9.21.

Furthermore, in those instances, we reserve the right, in our sole discretion and without
prior notice being required: (a) to make the necessary corrections or adjustments on the
Account(s) involved (including, without limitation, adjusting the price spreads available
to the Client); (b) to restrict the Account(s) involved access to streaming, instantly
tradable quotes (including, without limitation, providing manual quotations only andsubmitting any Orders to our prior approval); (c) to retrieve from the Account(s) involved
any historic trading profits that we can document as having been gained through suchabuse of liquidity at any time during the Client relationship; (d) to terminate the Client
relationship and/or close all Accounts involved (including, without limitation all otherAccounts held by the same Account holder with us) immediately by giving written notice;
and/or (e) to inform any interested third parties.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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Best Interest & Order
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9.22.

Furthermore, in these circumstances, you will be strictly prohibited from opening any new
Account(s) and trade with us. Nonetheless, in cases where you may successfully open an
Account and attempt to trade with us due to any technical and/or human error, we
reserve every right to immediately close your Account upon identification, nullify any
profit/loss generated and refund the original amount of deposit, excluding any deposit
and withdrawal charges.

9.23. We have, and will continue to develop any tools necessary to identify fraudulent and/or
unlawful access and use of our trading platform(s); any dispute arising from such
fraudulent and/or or unlawful trading activity will be resolved by us in our sole andabsolute discretion, in the manner we deem to be the fairest to all concerned; thatdecision shall be final and/or binding on all participants; no correspondence will beentered into.
c) Algorithmic trading or high-frequency algorithmic trading techniques
9.24. We do not allow Clients to use ‘algorithmic trading’ or ‘high-frequency algorithmic trading’techniques when using our trading platform(s), without our prior written consent.
9.25. For the purposes hereof:a. ‘algorithmic trading’ is defined as ‘trading in financial instruments where acomputer algorithm automatically determines individual parameters of Orders
such as whether to initiate the Order, the timing, price or quantity of the Order or
how to manage the Order after its submission, with limited or no humanintervention, and does not include any system that is only used for the purpose ofrouting Orders to one or more trading venues or for the processing of Orders
involving no determination of any trading parameters or for the confirmation ofOrders or the post-trade processing of executed transactions’,
whereby, a system shall be considered as having no or limited human intervention
where, for any Order or quote generation process or any process to optimize Orderexecution, an automated system makes decisions at any of the stages of initiating,generating, routing or executing Orders or quotes according to pre-determinedparameters’;b. ‘high frequency algorithmic trading’ is defined as ‘an algorithmic trading
technique characterized by:(i) infrastructure intended to minimize network and other types of latencies,
including at least one of the following facilities for algorithmic Order entry:
co-location, proximity hosting or high-speed direct electronic access;‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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Best Interest & Order
Execution Policy(ii) system-determination of Order initiation, generation, routing or execution
without human intervention for individual trades or Orders; and(iii) high message intraday rates which constitute Orders, quotes orcancellations;”
whereby, a ‘high message intraday rate’ is understood as ‘the submission on
average of any of the following:(i) at least 2 messages per second with respect to any single financial
instrument traded on a trading venue;(ii) at least 4 messages per second with respect to all financial instruments
traded on a trading venue”; and(iii) where only messages concerning financial instruments for which there isa liquid market are to be included in the calculation.
9.26. Where we give Clients permission to use algorithmic trading and/or high-frequency
algorithmic trading techniques, we may disclose, without prior notice to the Client(s)involved being required, information on the computer algorithms to the FSA or othercompetent authorities, Trading Venues, Liquidity Providers and such other persons as are
required by the Applicable Laws, Rules and/or Regulations.
9.27.

Furthermore, in these circumstances, we reserve the right, in our sole discretion andwithout prior notice to the Client(s) involved being required, to take any action inconnection with such algorithmic trading and/or high-frequency algorithmic trading
techniques or any Orders generated by such algorithmic trading and/or high-frequency
algorithmic trading techniques, which we, in our sole discretion, deem necessary in Orderto ensure compliance with the Applicable Laws, Rules and/or Regulations.

9.28. In particular, any such actions which we may take in connection with such algorithmic
trading and/or high-frequency algorithmic trading techniques or any Orders generated
by such algorithmic trading and/or high-frequency algorithmic trading techniques, may
include, without limitation, any of the following:a. the implementation and maintenance of limitations on the ratio of unexecuted
Orders to transactions entered through such algorithmic trading and/or highfrequency algorithmic trading techniques;b. the implementation and maintenance of restrictions to limit, block, cancel orotherwise restrict the use of our trading platform(s) in relation to any aspect of suchuse (hereinafter ”Limits”), including, without limitation:(i) Instruments;(ii) Orders;‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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Best Interest & Order
Execution Policy(iii) positions and other risks taken;(iv) messages;(v) methods of trading (for example, using algorithmic trading and/or highfrequency algorithmic trading techniques);c. increasing or decreasing the rate of execution of Orders to transactions enteredthrough such algorithmic trading and/or high-frequency algorithmic trading
techniques;d. imposing additional ‘Pre-Trade Risk Controls’, consisting of any of the abovementioned Limits to all or certain ‘Orders’ placed via our trading platform(s) by acomputer algorithm, including controls filtering Order price and quantity;e. imposing additional ‘Post-Trade Risk Controls’, consisting of any of the abovementioned Limits to all or certain ‘trades, positions, strategies and Instruments
relating to Orders’ placed via our trading platform(s) by a computer algorithm,
including controls filtering Order price and quantity;f.

implement and maintain Limits on the minimum tick size that may be executed via
our trading platform(s) on the Trading Venue; and/or

g. take any other action as we deem fit in Order to maintain Orderly trading
conditions.
9.29. You hereby expressly acknowledge and agree that any such actions taken by us may
cause Orders to be delayed, executed, partially executed, amended or cancelled.
d) Specific Client Instructions
9.30. When FinPros receives specific Client instructions on how to execute an Order, it shall
execute the Order in line with the specific instructions provided by the Client. For the
purposes of this Policy, executing an Order following the Client’s specific instruction isdeemed as satisfying the ‘best execution’ obligation owed by FinPros to its Clients.
9.31.

For the purposes of this Policy under specific instruction will be meant any Order which
expressly includes the indication of execution venue and/or party for execution and/ortime limit for execution and/or other firm conditions including specific settlement terms.
When executing a specific instruction, FinPros will seek the best possible result for the
Client under the constraints imposed by the specific conditions provided in the Order, e.g.
price available on the execution venue, specified by the Client, at the time of transmissionof a market Order, price available on the execution venue at the time when it reaches thethreshold established by a limit Order, or the price offered by the third party, specified by
the Client, operating on a bilateral basis outside trading venues (OTC) within theparticular period of time.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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9.32. Given the possible constraints mentioned above, FinPros hereby informs its Clients thatany specific instruction may prevent FinPros from taking all the steps designed in thisPolicy to obtain the best possible result for the execution of such an Order. For example,
trading rules for specific markets or execution venues may prevent FinPros from strictly
following some of the Client's other instructions. By no means, FinPros encourages its
Clients to give FinPros specific instructions.

10.

AGGREGATION, SPLITTING AND ALLOCATION OF ORDERS

10.1.

Client Orders may at the discretion of FinPros be aggregated with Orders of any of FinPros’
associates and/or other Clients. Furthermore, FinPros may split the Client’s Orders as well
as aggregate Orders before executing such. Orders will only be aggregated or split where:a. the aggregation or split of Orders will be for the benefit of the Client; orb. it is unlikely that the aggregating of Orders and transactions will work overall to thedisadvantage of the Client.

10.2.

By entering into the ‘Client Agreement – Terms and Conditions of Business’ with FinPros
and giving consent to this Policy, the Client acknowledges that aggregation and split may
in single occasions result in the Client obtaining a less favourable price than if the Client’sOrders had been executed separately or together, as applicable.

10.3.

To ensure the fair allocation of aggregated Orders and transactions FinPros performs suchallocation in accordance with its ‘Order Allocation Policy’. The policy specifies, inter alia,
how the volume and price of Orders determines allocations and the treatment of partial
executions. The overriding principle is that FinPros must not unfairly discriminate Clients
when allocating Orders executed on an aggregated basis.

10.4.

Generally, the aggregated Orders executed first, in full or in part, will be allocated first to
the Clients who first placed the Orders included into such aggregated Orders. If FinPros
aggregates a Client Order with one or more other Orders and the aggregated Order ispartially executed, FinPros will allocate the related trades in accordance with its ‘Order
Allocation Policy’.

11.

EXECUTION VENUES

11.1.

Execution Venues are the entities with which the Orders are placed, or to which wetransmit Orders for execution. For the purposes of Orders for the financial instruments weprovide, we act as principal at all times and not as agent. Although we may transmit yourOrders for execution to third party liquidity providers, contractually, FinPros is the solecounterparty to your trades and any execution of Orders is done in our name. Therefore,
we are the sole Execution Venue for the execution of Clients’ Orders.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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Best Interest & Order
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11.2.

We operate round–the–clock five days a week, please refer to our website for further
information. Holidays will be announced through the internal mail of the trading terminal
supplied by us.

11.3.

The precise treading times for each Financial Instrument are published on our Website
and trading platform.

11.4.

In that regard, please note that, Financial Instruments, our LPs apply certain daily breaks
during which no pricing may be available.

12.

MONITORING AND REVIEW

12.1.

We have procedures and processes in place to analyse the quality of execution, as wellas to monitor best execution. We measure and monitor the competitiveness of our prices
against other major competitors and the speed of our execution. We also monitor thesymmetry of slippage and requotes.

12.2.

Our compliance department and internal audit perform additional independent reviewsof the above processes and provide assurance as to their effectiveness. These reviews
and assessments are conducted on a regular basis and at least annually. Where
necessary, they provide recommendations for improvements, which are thenimplemented with the aim of keeping the quality of execution to the highest standards. In
instances where a material change to our execution arrangements and policy occurs, wewill notify our Clients of such changes.

13.

RECORD KEEPING

13.1.

FinPros shall maintain records of all Client Orders placed, including the date and time a
Client Order was placed and any details, including, but not limited to, the type of Order,
the financial instrument involved and the price it was executed.

14.

NO FIDUCIARY RELATIONSHIP

14.1.

FinPros’ commitment of providing the Clients with "best execution" does not mean that
FinPros owes its Clients any fiduciary duty over and above the specific regulatory
obligations placed upon it, or as may be otherwise contracted between FinPros and theClient.

14.2.

The Client remains responsible for his own investment decisions and FinPros will not be
responsible for any market trading loss the Client suffers because of those decisions.

15.

YOUR CONSENT

15.1.

We are required to obtain your consent prior to establishing a business relationship withyou. By entering into our ‘Client Agreement – Terms & Conditions of Business’, you‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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Best Interest & Order
Execution Policy
consent and acknowledge that the transactions in financial instruments entered with us
are not undertaken on a recognised exchange, but rather through our trading platforms
and, accordingly, you may be exposed to greater risks than when conducting transactions
on a regulated exchange. Therefore, we may not execute an Order, or we may change theopening or closing price of an executed Order in certain cases, including, but not limited
to instances of a technical failure of the trading platform. The trading rules are establishedsolely by the counterparty to your transactions, which is, at all times, FinPros. You are then
only allowed to close an open position in any given financial instrument during ourplatforms’ working hours, as per paragraph 11.2 above, and you can only close any such
position(s) with us as your sole counterparty and thus you are subject to counterparty
risk.
15.2.

By entering into the ‘Client Agreement – Terms & Conditions of Business’, you consent that
FinPros is, without exception, the sole execution venue for all your Orders and acts as
principal and not as agent on the Client’s behalf; contractually FinPros is the solecounterparty to the Client’s trades and any execution of Orders is done in FinPros’ name.

15.3.

When opening an Account with us you consent to your Orders being executed inaccordance with this Order execution Policy, as it is in force, at the time. You consent that
FinPros reserves the right to terminate your access to the trading platform(s) or
Account(s) or refuse or cancel any Order, immediately in the event that you voluntarily
and/or involuntarily partake in arbitrage unrelated to market inefficiencies, including but
not limited to, latency arbitrage and swap arbitrage and/or engage in transactions withus contrary to good faith; under such circumstances, FinPros may, in its sole discretion,
close any of your Account(s) and recover any losses incurred from such practices. You
also accept that FinPros reserves the right to terminate your access to the trading
platforms and/or recover any losses incurred immediately, in the event that FinPros
determines in its sole discretion that you voluntarily and/or involuntarily undertook toabuse the negative balance protection offered by FinPros (or in any way which is contrary
to good faith or the terms of the ‘Client Agreement – Terms & Conditions of Business’)
either on an individual Account, or multiple Account(s) or multiple profiles and/or between
one or more Client(s) of FinPros in accordance with the ‘Client Agreement – Terms &Conditions of Business’. For instance, a Client hedging his/her exposure utilising his/her
Accounts under the same or different Client profile would constitute an abuse of the
Negative balance Protection, as well as a Client requesting a withdrawal of his/her Client
Money -notwithstanding any of the provisions of the ‘Client Agreement – Terms &Conditions of Business’ - when the symbol he/she is trading is not available for trading at
FinPros during that specific timeframe.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
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Best Interest & Order
Execution Policy
16.

IMPORTANT INFORMATION

16.1.

Specific leverage limits or restrictions on the instruments available may apply inaccordance with applicable legislation and/or FinPros’ policies.

16.2.

CFDs are not eligible for sale or distribution in certain jurisdictions or countries. This Policy
is not directed to any jurisdiction or country where its publication, availability or
distribution would be contrary to local laws or regulations, including, but not limited to theUnited States of America. Equally, this Policy does not constitute an offer, invitation orsolicitation to buy or sell leveraged products. It may not be reproduced or disclosed (inwhole or in part) to any other person without prior written permission. The Policy is notintended to constitute the sole basis for the evaluation of any Client’s decision to tradeleveraged products.

17.

CONTACT US

17.1.

Questions regarding this Policy should be addressed, in first instance, to our Customer
Support Department. You may contact our Customer Support Department via e-mail at
SupportPros@finpros.com, or via phone on the numbers you will find on the Contact
section of our Website.

17.2.

‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company
registered in Seychelles with company registration number: 8429300-1, having its
registered office at CT House, Office 9A, Providence, Mahé, Seychelles.

17.3.

The Company is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a
Securities Dealer with License number: SD087.

______________‘FinPros.com’ is a domain owned and operated by ‘FinPros Financial Ltd’, a company registered in Seychelles withcompany registration number: 8429300-1, having its registered office at CT House, Office 9A, Providence, Mahé,
Seychelles. ‘FinPros Financial Ltd’ is regulated by the Financial Services Authority (‘FSA’) of Seychelles as a Securities
Dealer with License number: SD087
Page 29 of 29