Overview of Best Execution requirement  

This Order Execution Policy shall be read together with the Client Agreement.

ZFX is obliged to act in our Clients’ best interests and, other than in certain circumstances described below, where we execute or arrange the execution of orders, we are required to take all reasonable steps to obtain the best possible result for our Clients (known as delivering “best execution’’) and to establish and implement an order execution policy and related procedures to allow us to do so.

We have internal policies and procedures governing how we will act when we execute orders for our Clients. We continually strive to provide the best possible level of service to all of our Clients. Consequently, our policies and procedures are under constant review and may be revised at any time without prior notice.   

Execution Venues 

We deal with Clients as principal and not as agent. This means that we are the execution venue and so Clients transact directly with us and not on an exchange or another external market. Trades that Clients undertake with us are non-transferable, which means that if a Client opens a position with us, they must close the position with us.   

Execution Factors 

We apply the following execution factors:

  1. The Price – While we always aim to act in the best interest of our Clients we cannot guarantee that the price at which we permit Clients to execute a trade will be better than elsewhere. Prices on Contract for Difference (CFD) products are sourced from independent third party providers who supply liquidity to the OTC market.
  1. The Cost – We add a mark-up to the prices from our liquidity providers and publish the ‘’marked-up’’ prices that include our income. We will base the closing price of the relevant currency for the purposes of margin requirements and any balance credits/debits.
  1. Speed and Likelihood of Execution – Trades may be executed on our platform or by telephone or other forms of communication. Screen and telephone trades are subject to liquidity and market conditions and so we cannot guarantee that a Client’s trade will be open or closed instantaneously. The speed and likelihood of execution is also subject to software, hardware and telecom/data line use and we cannot guarantee that this will not be free of interruption of suspension.
  1. Quantity – We set the minimum and maximum quantity that Clients may place on a trade. This is influenced by market conditions and firm policy and changes from time to time. Price and cost are the predominant Execution Factors used by ZFX.  

Execution Criteria 

When arranging a transaction or executing a Client’s order, we will take into account the following criteria for determining the relative importance of the execution factors referred to above:

  1. The characteristics of the Client including the categorisation of the Client,
  1. The characteristics of the Client’s order, and
  1. The characteristics of the financial instruments that are the subject of that order.  

Dealing with Client’s Orders 

Subject to market conditions a Client’s order will be executed at our price or very close to our price. The price Clients receive at execution is not guaranteed as the market may widen, become very volatile or even gap. There is no guarantee that a Client’s order will be executed. 

We are under no obligation to honour and may cancel Client order under the circumstance which we reasonably believe that any form of market abuse, regulatory breach, or the Client order was transacted at an incorrect price may have taken place.    

Specific Instructions 

If Clients have any particular requirements as to how we act when dealing with them, then they must let us know and we will do our best to accommodate them. However, Clients should be aware that where they give us specific instructions that are incompatible with our normal order execution policies and procedures, their specific instructions will take precedence. This may result in a different outcome that would have been achieved had our normal policies and procedures been followed and, we will not be required to deliver best execution in respect of the aspects of a Client’s order which are covered by their specific instructions.

Our normal policies and procedures take account of the costs that we would incur in transacting business. Transactions may be subject to additional charges. Where this applies, we will notify Clients of the applicable charges before their order is executed.  

Our Duty of Best Execution - When executing orders OTC financial derivative products, we will take all reasonable steps to achieve the best possible outcome taking into account our Order Execution Policy and any specific instructions received from our Clients. 

Achieving Best Execution - To achieve the best possible result, we will take a number of factors into account, including price, costs, speed of execution, likelihood of execution and settlement, size, nature of the order or any other factors relevant to the execution of that order. We will use our own commercial experience and judgment in determining the relative importance of these factors, however, we have rated prices as the most important factor for obtaining the best possible result.

If we have classified a Client as a Professional Client, we will consider relevant guidance to determine whether they are relying on us to deliver best execution. We understand that Clients may be relying upon us to deliver best execution, but the importance of execution may take precedence over price.

If we have classified a Client as an Eligible Counterparty, there is no requirement for us to deliver best execution to them. However, we will comply with this policy in relation to Eligible Counterparty business and maintain records of data which are used to set our prices. We will review this policy at regular intervals and will monitor and review external pricing sources. We will give Clients 14 days written notice where we make any change to this policy and the Client disclosure relating to this policy on our website.

Refusal to Transmit Orders

Without prejudice to any other provisions herein, the Client agrees and understands that we have the right, at any time, without giving any notice and/or explanation, to refuse, at our discretion, to transmit any order for execution, and that the Client has no right to claim any damages, specific performance or compensation whatsoever from us, in any of the following cases but not limited to:

  1. Whenever we deem that the transmission of the order for execution affects or may affect in any manner the reliability or smooth operation of the Trading System,
  1. Whenever there are no available cleared funds deposited in the Client’s account to pay all the charges and required margin relating to the said order,
  1. There is absence of essential detail of the order,
  1. It is impossible to proceed with an order regarding the size or price,
  1. the Client’s order has more than one interpretation or is unclear,
  1. It is impossible for the order to be executed due to condition of the market, customs, or a trading volume,
  1. We received from the Client the notice on cancellation of the contract,
  1. Forwarding of the notice on termination of the Client Agreement by us to the Client,
  1. If any doubt arises as to the genuineness of the order,
  1. Where we suspect that the Client is engaged in money laundering activities or terrorist financing,
  1. In consequence of lawful claims or requirements of corresponding organized trading platforms, affiliates as well as in consequence of lawful claims of third parties,
  1. Where the legality of the order is under doubt,
  1. In consequence of request of a court order,
  1. In the circumstances mentioned in any of the ZFX’s policies,
  1. Where the order is placed in a manner and form not compliant with our normal operations of business, or
  1. When the underlying market is closed and we do not receive liquidity from its execution venues,
  1. If the Client’s account is under investigation or has been terminated,
  1. If the Client’s account is, or we suspect it to be, in breach of the Client’s Agreement.  

Assurances, Guarantees

Before the Client places an order, the Client shall state, affirm, warrant and guarantee the following:

  1. The Client is placing the order and entering the transaction as principal, (that is on the Client’s own behalf and not for any third person), unless The Client has submitted a document and/or Powers of Attorney enabling the Client to act as representative and/or trustee of any third person and relevant identification documents for such third party. 
  1. Each transaction carried out by the Client does not breach, conflict with or constitute a default under any law, regulation, rule, judgment, contract or other instrument binding on the Client or any of the Client’s funds or assets. 
  1. The Client is not subject to any restrictions on placing the order or entering the transaction related to the order. 
  1. The Client has taken such advice in respect to the transaction related to the order and have not relied on any representation or information provided by us in reaching the Client’s decision to enter the transaction. 
  1. All the information disclosed otherwise is true and accurate and that the Client undertakes to inform us in writing should there be any changes to the information provided. 
  1. The documents submitted to us are valid and authentic and to the best of the Client’s knowledge and belief, the information provided in the applicable application form and any other documentation supplied in connection with the application is correct, complete and not misleading and the Client will inform us if any changes to such details or information. 
  1. The Client’s funds are not in any direct or indirect way the proceeds of any illegal activity or used or intended to be used for terrorist financing. 
  1. The Client is over 18 years old and of sound mind, having no legal or other obstacle prohibiting the Client from entering into the Client Agreement and any other agreements. 
  1. The Client has provided us with the Client’s investment objectives which are relevant to our services for example whether there are any restrictions on the markets or instruments in which any Transactions will be sent for execution for the Client, depending on The Client’s nationality or religion.  

Third Party Authorisation to Trade

The Client has the right to authorise a third person (“Authorised Party”) to give instructions and/or orders to us provided the Client has notified us in writing of exercising such a right and that this person is approved by us in writing, fulfilling all our specifications for this arrangement.

Unless we receive a written notification from the Client for the termination of the Authorised Party’s authorisation, we will continue accepting instructions and/or orders given by the Authorised Party on the Client’s behalf and the Client will recognize such Orders as valid and committing to the Client. 

The written notification for the termination of the authorisation to a third party must be received by us with at least 5 days’ notice prior the termination date and with our written acknowledgement.


If for MAMM account management the Client authorise a third party to act on the Client’s behalf as an agent or otherwise, then such a party may instruct us and send requests concerning any transaction, or proposed transaction, or any other matter on the Client’s behalf to which we shall be bound. 

The Client authorises us to rely and act on any request, instruction, or other communication received by us which purports to have been given by the Client or on the Client’s behalf without further enquiry on the part of ZFX as to the authenticity, genuineness, authority or identity of the person giving or purporting to make such a request, instruction, or other communication. 

The Client will be responsible for, and will be bound by, all obligations entered or assumed by us on the Client’s behalf as a consequence of or in connection to such requests, instructions, or other communications. 

If The Client has expressly authorised a third party to act on the Client’s behalf, references to ‘Client’ or ‘the Client’ throughout the Agreement shall also include references to the Client’s authorised third party delegate.