Within the framework of MiFID, Global Capital is required to draw up an order execution policy and to take all reasonable steps to obtain the best possible result for its Retail and Professional Clients either when executing or receiving and transmitting Client Orders for execution in relation to financial instruments or when handling transaction Orders under its portfolio management services. 

Within this context, Global Capital is required to provide appropriate information to its Clients on its Order Execution Policy. 

2. Scope of Application 

Global Capital applies its Order Execution Policy, taking all reasonable measures for the achievement of the best possible result, when it conducts the following services on behalf of its Retail and Professional clients: 

• Receiving & executing orders; 
• Receiving & transmitting orders to 3rd cooperating companies; 
• Managing orders in the context of portfolio management 

Global Capital is not obliged to provide best order execution in the following cases; 

• When it is dealing on own account providing or publicizing quotes and the Client transacts on the basis of these quotes; 
• When it negotiates the terms of the transaction with a Client. 

If the Client gives specific instructions for the execution of an order accepted by Global Capital, the latter will follow such instructions irrespectively of whether by doing so it can achieve the best possible result from the execution of the specific client order.

3. Order Execution - Obtaining the Best Possible Result 

Subject to any specific instruction from the Client, when global Capital executes Orders on behalf of Clients, it takes all reasonable measures to obtain the best possible result for its Clients, taking into account the following Best Execution Factors: 

Best Execution Factors 

• Price 
• Volume 
• Cost 
• Speed 
• Likelihood of execution and settlement (liquidity), and 
• Any other consideration relevant to the execution of the Order. 

The relative importance of the Execution Factors varies between different financial instruments. In most circumstances, price will be the most important Execution Factor; however, in certain circumstances Global Capital may appropriately determine that other Execution Factors have greater importance in achieving the best possible result for the Client. Global Capital will determine the relative importance of the Execution Factors by using its commercial judgement and experience in the light of the information available on the market and taking into account the Execution Criteria outlined below: 

Execution Criteria 

• Characteristics of the Client including his/her categorization; 
• Characteristics of the Client’s Order; 
• Characteristics of the financial instruments related to the Client’s Order; 
• Characteristics of the Execution Venues to which the Client’s Order can be transmitted for execution; and 
• Technical means at the disposal of global Capital or in operation for the transmission of the Client’s Order 

Demonstrating best execution does not necessarily involve a transaction-by-transaction analysis, but rather involves an assessment of a record of transactions over a period, indicating that overall the best result is achieved by executing Orders on the Client’s behalf on the Execution Venues and in the manner described in the Order Execution Policy. 

For Retail Clients, the best possible result shall be determined in terms of the total consideration, representing the price of the financial instrument and the costs related to execution, which shall include all expenses incurred by the Client that are directly related to the execution of the Order, including execution venue fees, clearing and settlement fees and any other fees paid to third parties involved in the execution of the Order. 

4. Execution Venues 

Order Execution Venues cover the markets in a wider context, i.e. Regulated Markets, Multilateral Trading Facilities, Systematic Internalisers or special brokers performing a similar operation in a 3rd country, in which transactions in financial instruments are executed. 

Global Capital is presently dealing with financial instruments traded in Regulated Markets only and does not use other Execution Venues. Global Capital reserves the right to use other Execution Venues where deemed appropriate in the future.

5. Client’s Specific Instructions 

Whenever a Client gives a specific instruction as to the execution of an Order or a part of it, global Capital shall execute the Order following the specific instruction. The specific instruction may prevent global Capital from taking the steps that it has designed and implemented in its Order Execution Policy in order to obtain the best possible result for the execution of that Order in respect of the elements covered by the specific instruction. Where the Client’s instruction relates to only a part of the Order, Global Capital will continue to apply its order execution policy to those aspects of the Order not covered by the specific instruction. 

6. Reception and Transmission of Orders 

Subject to any specific instruction from the Client, Global Capital may transmit an Order it receives from the Client to an external entity, such as a third party broker, for execution. In doing so, Global Capital will act in the Client’s best interests and will comply with Section 3 above. 

Global Capital will review periodically its choice of third party brokers to ensure that the third party broker has execution arrangements and execution policy that enable Global Capital to comply with all its best execution requirements.

7. Monitoring / Reviewing 

Global Capital will monitor the effectiveness of its order execution arrangements and execution policy, making any changes where appropriate. In particular, Global Capital shall assess on a regular basis whether the Execution Venues included in the order execution policy provide for the best result for the Client or whether it needs to make changes to its execution arrangements. 

Furthermore, Global Capital will review its Order Execution Policy at least once a year and will notify its Clients of any material changes to its order execution arrangements or execution policy (including changes to the selected Execution Venues), by posting an updated version of this document on www.globalcapital.com.cy/client-info. Global Capital will not notify its Clients individually of these changes. Upon request, Global Capital will demonstrate to its Clients that it has executed their Orders in accordance with its Order Execution Policy. 

8. Clients Consent 

Global Capital is required to obtain the Client’s prior consent to its Order Execution Policy. The Client will be deemed to have provided such consent when giving an Order after 1 November 2007 or, in the case of discretionary portfolio management, when the Client has not stated otherwise in writing to his/her service provider by the aforementioned date. 

9. Additional Information