Order Execution Policy
1. Purpose
This Policy explains the principles Montrock applies when executing or arranging client orders. It is intended to promote fair and consistent execution and should be read with the Client Agreement.
2. Execution Factors
Depending on the product and circumstances, the Company may consider:
- price;
- total cost;
- speed;
- likelihood of execution;
- likelihood of settlement;
- order size and nature;
- liquidity and market depth;
- execution venue or counterparty quality;
- market conditions;
- client classification and specific instructions.
The relative importance of factors can change in volatile or illiquid markets.
3. Execution Venues and Counterparties
Orders may be executed through approved exchanges, brokers, liquidity providers, banks, market makers or other counterparties within the Company’s permitted operating model.
4. Acting as Principal or Agent
The Company’s capacity for a transaction will be determined by the applicable product and execution model and must remain within the Company’s regulatory permissions. Where the Company acts as principal, potential conflicts are managed under the Conflicts of Interest Policy.
5. Price Formation
Prices may be derived from one or more external market, venue or liquidity sources and may incorporate applicable spreads, mark-ups, financing or other disclosed charges. Indicative website prices are not necessarily executable prices.
6. Specific Instructions
Where a Client gives a specific instruction, the Company will seek to follow it where accepted. A specific instruction may prevent the Company from applying its normal execution process to the relevant element of the order.
7. Slippage and Gapping
The execution price can differ from the requested price. Slippage can be positive or negative. During market gaps or severe volatility, the first available executable price may be materially different.
8. Partial Fills and Rejections
Orders may be partially filled, delayed or rejected where liquidity is insufficient, venue/counterparty controls apply, market conditions are disorderly, or execution would breach legal or risk limits.
9. Aggregation and Allocation
Where legally and operationally permitted, orders may be aggregated if the Company reasonably considers aggregation unlikely to work to the overall disadvantage of clients. Allocation must be fair, documented and not designed to favour the Company or particular clients.
10. Monitoring
The Company monitors execution arrangements using available data and risk/compliance controls. Material deficiencies are escalated and remedied.
11. Review
The Policy is reviewed at least annually and whenever there is a material change affecting the Company’s ability to obtain appropriate execution outcomes.
12. No Fiduciary Relationship
The Company’s commitment to provide best execution does not mean that the Company owes the Client any fiduciary responsibilities over and above the specific regulatory obligations placed upon it, or as may otherwise be agreed between the Client and the Company. The Client remains responsible for their own investment decisions and the Company will not be responsible for any market trading loss suffered as a result of those decisions.
Contact and Regulatory Information
Montrock Ltd is incorporated in Mauritius under Company No. 231276 GBC and is regulated by the Financial Services Commission, Mauritius (FSC) as an Investment Dealer (Full Service Dealer, Excluding Underwriting), FSC Licence No. GB25205688. Registered office: Suite 201, Level 2, The Catalyst, 40 Silicon Avenue, Cybercity, Ebene 72201, Mauritius.
Compliance enquiries: compliance@mont-rock.com
Website: https://mont-rock.com
Risk warning: Transactions in financial instruments, particularly leveraged or derivative instruments where offered, involve significant risk and may result in substantial loss. Nothing on the website constitutes a guarantee of profit or investment performance.