Order Execution Policy

Ver 1.1 2023

ORDER EXECUTION POLICY

STP/ECN

 

  1. Introductory Provisions

TRAZE (PTY) LTD a Company duly registered in the Republic of South Africa with registration: 2016/164943/07; a Subsidiary wholly (100%) owned by Zeal Holdings Limited Incorporated and registered in British Virgin Islands with Company Registration: 2006432.

Traze (Pty) Ltd shall take reasonable steps to ensure that the financial services offered, and any advice given, or transaction entered, are appropriate for the client, and in harmony with any applicable laws, codes and standards in accordance with Act No. 37 of 2002: Financial Advisory and Intermediary Services Act, 2002. Traze (Pty) Ltd “must at all times render financial services honestly, fairly, with due skill, care and diligence, and in the interests of clients and the integrity of the financial services industry” as stipulated in section 2 of the General Code of Conduct for Authorised Financial Services Providers and Representatives [As amended by Board Notice 43 of 14 May 2008].

Traze (Pty) Ltd maintains policies, guidelines, procedures, records and strategies in respect of the overarching best execution obligations, requirements and factors encompassed in this document, to observe reasonable steps designed to offer the best possible result for Clients.

  1. Purpose

Traze (Pty) Ltd and its personnel have a direct interest in ensuring the best possible execution for its clients in observing our legal and regulatory duty. These obligations fall in line with the Company’s obligations in the FAIS Act, and any separate fiduciary duties or contractual obligations owed to the Client by the Company.

In respect of the Financial Advisory and Intermediary Act of 2002 (FAIS) Traze (Pty) Ltd is required to set up the Straight Through processing (STP)/ Electronic Communication Network Order Policy (the “Policy”) and to take all sufficient steps to obtain the best possible results for its clients (“best execution”) either when executing client orders or receiving and transmitting orders for execution in relation to financial instruments. The Policy sets out a general overview on how Traze (Pty) Ltd will obtain the best possible result when executing Clients’ orders by considering the criteria and factors outlined in this order execution Policy.

  1. Application

The policy shall apply whenever Traze (Pty) Ltd executes orders on behalf of its Clients through the STP/ECN model. Traze (Pty) Ltd Company registration 2016/164943/07 does not participate in any Principal (Counterparty) activities when executing client orders. Though Traze (Pty) Ltd takes all sufficient steps to obtain the best possible result for its clients, it does not guarantee that when executing a transaction, the client’s price will be more favourable than one which might be available elsewhere.

Traze (Pty) Ltd further applies the Policy upon acceptance of an order and when a Client gives no specific instruction on the execution method. Nevertheless, when the client gives a specific instruction on an order, Traze (Pty) Ltd will execute the order following such instruction. If Traze (Pty) Ltd receives a specific instruction on an order, this may prevent Traze (Pty) Ltd from implementing the Policy to obtain the best possible result for the execution of the order.

The type of Clients the order Policy applies to are “retail” and “professional” clients only while “eligible counterparties” are in no need of being safeguarded by these rules.

  1. Company Operating hours

The following are the Company’s:

  • Holidays are announced through the internal mail of the trading terminal provided by Traze (Pty) Ltd and may alternatively be provided via the Clients registered email from time to time.
  1. Financial Instruments Description.

In the event Traze (Pty) Ltd provides the investment services of reception and transmission of orders in relation one or more financial instruments and/or when executing orders on behalf of retail and professional clients, this Policy shall be applicable.

The financial instruments provided by Traze (Pty) Ltd are Over the Counter (“OTC”) Financial Contracts for Differences (CFDs). In particular:

5.1  Contracts for Difference (CFDs) on currency pairs,

5.2  CFDs on spot Shares,

5.3  CFDs on spot metals,

5.4  CFDs on spot commodities,

5.5  CFDs on spot indices,

5.6  CFDs on spot futures,

5.7  CFDs on spot Cryptocurrencies

For more details pertaining to contract specifications visit the Company’s website at www.traze.com

  1. Order Types

The Characteristics of an order can affect the Clients order execution. The Client trading platform (Terminal) allows to prepare requests and requisitions to the broker for execution of trading operations. The following are different types of orders available to the Client which can be executed:

6.1 MarketOrder(Instant)

This is a Client’s commitment to buy or sell a security or instrument at the current price available at a given time. The trading platform screen will display the price the order is usually filled at. If the market has shifted while the client was in the process of placing their order, the price may differ and the order will be assume the price which was available at the time the order was executed. A Stop Loss or a take Profit can be placed by the Client before or after the order is placed.

6.2 Pending Order.

This is a Client’s commitment to buy or sell a security or instrument at the current price available at a pre-defined price in the future. If the future price level or quotes reach the pre-defined price, then a trade position is opened with respect to these types of orders. A Stop Loss or a take Profit can be placed by the Client before or after the order is placed. The four pending orders available on the Company’s trading platform include: Buy Limit, Buy Stop, Sell Limit and Sell Stop

  1. Buy Limit: Buy provided the anticipated future “ASK” price is equal to the pre- defined price or value. The current price level is higher than the value of the placed order. Orders of this type are usually placed in anticipation of that the security price, having fallen to a certain level, will increase;
  2. Buy Stop: Buy provided the anticipated future “ASK” price is equal to the pre- defined price or value. The current price level is lower than the value of the placed order. Orders of this type are usually placed in anticipation of that the security price, having increased to a certain level, will fall;
  3. Sell Limit: Sell provided that the future “BID” price is equal to the pre-defined price or value. The current price level is lower than the value of the placed order. Orders of this type are usually placed in anticipation of that the security price, having increased to a certain level, will fall;
  4. Sell Stop: Sell provided that the future “BID” price is equal to the pre-defined price or value. The current price level is higher than the value of the placed order. Orders of this type are usually placed in anticipation of that the security price, having reached a certain level, will keeping falling.

6.3 Trailing Order.

A Trailing stop works only in the Client terminal and in the server as compared to a Stop Loss or the Take Profit. Therefore, the Trailing stop loss will only work when the terminal is on and not off as in the case of the above-mentioned orders. This order or feature permits the client to place a stop loss order on open positions in the client terminal, as the market moves to the clients advantage the profit is locked automatically.

7. Best Execution factors.

We take all sufficient steps to acquire the best possible result for our clients as part of our compliance and regulatory obligations, by considering the following relevant factors taken into account in the execution of the order:

In circumstances wherein your order is not wholly covered by the specific instructions of the Client, we shall determine the best possible result when executing Client Orders against the Company’s quoted prices by taking into consideration the execution factors and their relevant importance according to the latter table and in the order presented below:

7.1 Price-High Relative Importance.

Bid-Ask spread: Two prices are quoted for any financial instrument, the higher price (ASK), being the price the Client can buy (go long) a financial instrument, and the lower price (Bid), being the price the Client can sell (go short) a financial instrument; collectively, referred to as the Firm’s prices. The difference between the Bid and Ask price of a given financial instrument is termed the ‘spread’.

Pending Orders: Orders such as ‘Buy Limit’, ‘Buy Stop’ and ‘Stop Loss’/’Take Profit’ for the open short positions are executed at the Ask price. Orders such as ‘Sell Limit’, ‘Sell Stop’ and ‘Stop Loss’/’Take Profit’ for open long positions are executed at the Bid Price.

Prices are generated and provided from information sourced through independent price providers and banks that generally provide liquidity to the global market. Traze (Pty) Ltd Company registration 2016/164943/07 does not and provide any Principal activities. The main way in which the client receives the best execution will be to ensure due diligence in that the calculation of the bid/ask spread is made with reference to a range of underlying price providers and data sources. Additionally, that updates in prices as frequently as the limitations of the technology and communication links allow. Prices will not be quoted outside of our operational hours (Refer to execution venues below).

Reviewal of Traze (Pty) Ltd independent price providers to ensure that correct and competitive pricing is offered is regularly done at least once a year. For more information on the Company’s prices, visit the Company’s website at: https://traze.com/

The types of accounts offered by Traze (Pty) Ltd, can differ depending on the account to be selected by the Client in terms of pricing and its costs. The main account types or products are listed below, for more details refer: https://traze.com/

  • Cent Trading Account
  • Standard Trading Account
  • ECN Trading Account

7.2 Costs and Charges- high Relative Importance.

A commission or financing fee will apply where a client opens a position in some types of financial instruments. The details of these costs are available in the Contract Specification on the Traze (Pty) Ltd website. Appropriate steps will be taken to ensure the client is informed of the costs, (being the commission and spread rates) prior to the client electing or executing a trade. There shall be no other unknown variables to the Client and necessary disclosures shall be made.

 

The Table displays the varying forms of costs related to CFD trading.

Once-off entry or
Exit costs

Spread Costs

Applicable to all Instruments.

The cost is realised each time the Client opens and closes a trade.

A spread is the difference between the bid (buy) and the ask (sell) price on the specific instrument you trade.

Commission Costs

Applicable to CFD’s on futures and CFDs on shares only.

When the Client buys and sells an instrument, this is the Commission they pay.

Currency Conversion Costs

Applicable to all instruments.

This is the cost associated with converting realised profits and losses as well as any costs and charges that are denominated in a currency other than the base currency of your trading account.

Continuing Costs

Swap (Financing Fee)

Applicable to all instruments

The swap can either be positive or negative depending on the instrument to be traded.

This is the cost for keeping your position open overnight.

Information on Traze (Pty) Ltd’s Costs and charges can be found on the Company’s website at: https://traze.com/

7.3 Speed of Execution- Medium Relative Importance.

Traze (Pty) Ltd serves as an intermediary for the tradable prices, which are distributed via the Company’s trading platform, the technology used by the client to communicate with Traze (Pty) Ltd plays a crucial role.

Traze (Pty) Ltd strives to offer the highest possible speed of execution within the limitations of technology and communication links. Prices change over time and the frequency with which they do varies with different financial instruments and market conditions. Traze (Pty) Ltd places signification importance when executing Client’s orders to the speed of the execution of an order.

As an example, the use of wireless connection or dial up connection or any other communication link that may result in a poor internet connection can lead to an unstable connectivity on the Company’s trading platform resulting to the client orders being received at old prices, where the principal might decline and offer the Client a new quote (commonly referred to as re-quote).

7.4 Likelihood of execution- Medium Relative Importance.

The volatility levels in the financial market influence both price and volume. Traze (Pty) Ltd intends to provision its clients with the fastest execution reasonably possible. Client orders (Buy Limit, Buy Stop, Sell Limit, Sell Stop, Stop loss and/or Take Profit) are executed through Traze (Pty) Ltd at the requested price. Howbeit, under certain market conditions, orders may not be filled at the exact price requested but instead at the best available price. This usually occurs during news announcements (fundamentals), during periods or volatile market conditions, on opening gaps (When trading sessions starts) or on possible gaps where the underlying instrument has been suspended or restricted on a particular market.

Traze (Pty) Ltd strives to provide the best possible price to its clients by making an effort to ensure it has all necessary arrangements in place to do so, but it cannot guarantee the execution of any of the pending orders at the requested price.

7.5 Likelihood of Settlement- Low Relative Importance.

Traze (Pty) Ltd proceeds with the settlement of a clients transaction subject to the successful execution of the respective transaction.

7.6 Size of order- Low Relative Importance.

The quantity of an order is measured in lot sizes, the fraction of a lot size is commonly referred to as a micro lot. All orders are placed in lot sizes and a lot is considered as a unit measuring the transaction amount which differs in respect to the financial instrument. Contract specifications insofar as lot sizes are available on the Company’s website.

If the client wished to execute a large size order, in some cases the price may become less favourable considering the liquidity in the market. Traze (Pty) Ltd reserves the right not to accept a client order, in case the size of the order is large and cannot be filled by the Company.

7.7 Nature of Order- Low Relative Importance.

The characteristics of an order in so far as the underlying instrument, fee type applicable, type of order and distinguishing characteristics collectively sum the nature of an Order.

7.8 Market Impact- Low Relative Importance.

The quoted prices may be affected by several factors which could also be a result of the above-mentioned parameters. The Company’s takes an approach in consideration of the best possible result for its clients. As stated above, Traze (Pty) Ltd will always take all reasonable steps to ensure the best possible result for its clients.

Traze (Pty) Ltd does not consider the above list of parameters to be exhaustive. The order in which they are presented however, indicates their relative importance in the best execution process without excluding the possibility of derogation from the above-mentioned process in cases where the best interests of the client criterion justify such derogations.

  1. Best Execution Criteria.

Traze (Pty) Ltd will generally consider the following best execution criteria in order to determine the relative importance of the above-mentioned execution factors:

  • The characteristics of the client, which includes the categorisation of the client as retail or professional;
  • The characteristics of the client order;
  • The characteristics of the financial instruments that are subject to that order;
  • The characteristics of the execution venue to which that order can be and will be directed.

The total consideration of these characteristics will determine the best possible result, by factoring the price of the contract and the execution costs as the primary factors. Other execution factors like speed, likelihood of execution size, nature or any other relevant considerations will usually be secondary to price and cost considerations, unless they deliver the best possible result for the client in terms of total considerations.

  1. Effect of other facts on the execution of an order.

Client may experience widened spreads and execution at the best available price under certain market conditions (for example, fundamental or news announcements, where there is a fast-moving market or low liquidity). In such circumstances, the principal reserves the right to modify Traze (Pty) Ltd spread.

Some trades maybe automatically priced and executed by the principal’s automated internal trading systems. Nonetheless, depending on the factors like unusual market conditions, the size and nature of client orders, a financial instrument may be manually priced and/or an order may be manually executed.

Manual pricing and/or execution may result in the processing delays of an order during times of high demand, which in turn impacts the price and speed at which the order is executed. Traze (Pty) Ltd is committed to providing the most competitive trading technology as an intermediary passing through orders and is always striving to implement measures to minimize the risk delays.

In circumstances of any communication technical failure, as well as any incorrect reflection on the quotes fee, The principal reserves the right not to execute an order nor change the opening and/or closing price of a order.

Where the Principal transmits the clients order to the liquidity Providers for execution, the order may be executed against the Liquidity providers or executed within the ECN of the liquidity Provider(s).

  1. Specific Instructions.

The obligation to take all reasonable steps to obtain the best possible result for a client to the extent that it executes an order, or a specific aspect of an order, following specific instructions from the client relating to the order or the specific aspect of the order should be observed.

In circumstances where the client provides Traze (Pty) Ltd with a specific instruction as to how to execute an order and Traze (Pty) Ltd has accepted this instruction, then Traze (Pty) Ltd will pass through the order in accordance with that specific instruction. An order following specific instructions from the client, it should be treated as having satisfied its best execution obligations only in respect of the part or aspect of the order to which the client instructions relate.

Nevertheless, if the client provides a specific instruction to carry out an order, then by executing that order, Traze (Pty) Ltd will be complying with the Company’s duty to provide the client with best execution. This may result in being unable to apply this Policy in certain instances; howbeit specific instructions which cover one part or aspect of the order should not give prerogative to derogate from best execution obligations in respect of any other parts or aspects of the client order that are not covered by such specific instructions.

  1. Execution Venue.

Traze (Pty) Ltd Company registration 2016/164943/07 will not enter any transaction with the client as principal (Counterparty) and will not act as the execution venue for any client orders. The client is required to open and close a position of any financial instrument via the trading platform.

In the event where there is only one possible venue, best execution is achieved on that venue. The Best execution obligations is a process, which considers various factors, not only an outcome. This means, when Traze (Pty) Ltd is passing an order for a client, Traze (Pty) Ltd must execute it in accordance with its execution policy, but the principal does not guarantee that the exact price requested will be obtained in all circumstances and, in any event, the factors may lead to a different result in a particular transaction.

In certain circumstances this obligation will not apply, for example at a time of severe market turbulence or volatility, and/or internal or external system failure, where instead the ability to execute orders on a timely basis will become the primary factor.

Traze (Pty) Ltd has execution arrangements via its affiliated entities with several liquidity providers.

The Client acknowledges that all transactions entered in any particular financial instrument via Traze (Pty) Ltd are executed in a regulated Market, Organised Trading Facility (OTF), multi-lateral trading facility (MTF) or outside a regulated marketed and the Client maybe exposed to a greater risk of a possible default of the counterparty.

 

  1. ReviewandMonitoring.

Traze (Pty) Ltd shall implement measures to monitor the effectiveness of the Policy and relevant order execution arrangements on a continuous basis to identify and implement any appropriate augmentations. This will also include regularly reviewing (at least annually) the Policy and the relevant order execution arrangements with the objective to assess if they enable Traze (Pty) Ltd to provide and observe the best execution for its Clients.

The factors considered in deciding whether to execute a Clients order incorporate price, costs, speed together with any other consideration relevant to the execution of the order. In determining the relative importance of these factors Traze (Pty) Ltd will consider the client’s status, together with the nature of the order, the characteristics of the financial instruments to which order relates and the characteristic of the execution venues.

There is an assessment process prior the selection of an execution venue, considering both qualitative and quantitative criteria. In exact, the pricing and the costs in relation to the execution venue. Other factors are also taken into consideration, which include the speed of processing and likelihood of execution as well as the financial soundness and order execution policy of such venue.

An assessment and monitoring is conducted on continuous basis in respect to financial institutions used as hedging liquidity/price providers in order to ensure that the best possible result is provided to Clients. Traze (Pty) Ltd should also assess on a regular basis whether the execution venues included in its order execution policy provide the best possible result for Client orders. If there is a material change, a more frequent review may be appropriate.

From time to time it may be expedient to make changes to this Order Execution Policy. The Client is made aware that Traze (Pty) Ltd will not notify clients separately of changes, unless they are substantial material changes to the Policy, the client is encouraged from time to time to refer to the website of Traze (Pty) Ltd https://traze.com/ for the most up to date version of the Order Execution Policy. If and when requested by a Client, Traze (Pty) Ltd shall demonstrate that Client orders were executed in accordance with this Policy.

The following outlined is a non-exhaustive list of factors constituting a Material Change:

  • Changes as it relates to the relative importance of execution criteria and relevant factors;
  • Changes, additions or subtractions in Execution Venues;
  • Incorrect prices compared to the correct or average market price;
  • Significant increase in the daily number of requotes;
  • Significant delay in the execution of orders.
  1. Customer Communication.

Any material changes to the order execution arrangements shall be notified to you in a durable medium or by updating our website: www.traze.com

Should you request documented evidence or records which demonstrates that we have executed your orders in line with the same order execution policy and information pertaining to our arrangements in this regard, this will be provided to you within reasonable time.

  1. Record Keeping.

For this Policy, records on details about costs, speed, likelihood of execution, individual financial instruments and transactions passed through the Electronic Trading Platform shall be maintained for a minimum period of five (5) years and, where requested by the competent authorities, for a period of up to seven (7) years where relevant.

  1. Client’s Consent

When establishing a business relation with the client, Traze (Pty) Ltd is required to obtain the clients prior consent to this Policy. In addition, Traze (Pty) Ltd is required to obtain the clients prior consent before passing through clients’ orders or receiving and transmitting orders for execution in an Organised Trading Facility (OTF), Regulated Market, Multi-lateral Trading Facility (MTF) or outside a regulated market. The client is informed that Traze (Pty) Ltd does not act as principal (counterparty), in any manner.

Traze (Pty) Ltd will treat clients who have either received the policy or agreed to receive the Policy electronically or via the internet and have accepted the Trading Terms and Conditions of the Company, as clients who have given their consent to the Policy as well as given consent to Traze (Pty) Ltd to execute or receive and transmit an order in an Organised Trading Facility (OTF), Regulated Market, Multi- lateral Trading Facility (MTF) or outside a regulated market. Traze (Pty) Ltd may also obtain the above consents in the form of any other general agreement.

  1. Definitions and Construction.

Eligible Counterparties– means authorised financial service providers, investment funds, banks, credit institutions, insurance companies, a collective investment scheme and its management companies, pensions funds and their management companies, other financial institutions authorised.

Execution venue- means a regulated market, an MTF, a systematic internaliser, or market maker or other liquidity provider or an entity that performs a similar function in a third country to the functions performed by any of the forgoing.

FAIS– means the Financial Advisory and Intermediary Services Act of 2002.

MULTILATERAL TRADING FACILITY (MTF)- means a multi-lateral system, operated by an investment firm or a market operator, which bring together multiple third- party buying and selling interests in financial instruments.

Retail Client-means a client who is not a Professional Client or an Eligible Counterparty.

ORGANISED TRADING FACILITY (OTF)– means a type of multilateral trading facility (MTF) it is a regulated platform that allows trading in financial instruments which are not are not admitted to trading on a regulated market. OTFs are designed to offer a more transparent and efficient trading environment to market participants. They must comply with strict rules regarding pre- and post-trade transparency, risk management, and reporting requirements.

REGULATED MARKET– Means a multilateral system operated and/or managed by a market operator, which brings together or facilitates the bringing together of multiple third party buying and selling interests in financial instruments.

SYSTEMATIC INTERNALISER– means an investment firm which, on an organised, frequent and systematic basis, deal on own account by executing client order outside a regulated market or an MTF.

PENDING ORDER- pending order is the client’s commitment to the brokerage company to buy and sell a security at a pre-defined price in the future. This type of orders is used for opening of a trade position provided the future quotes reach the pre-defined level. There are four types of pending orders available in the terminal examples of which can be found in Appendix to this Policy:

  • Buy limit- Buy provided the future “ASK” price is equal to the pre-defined value. The current price level is higher than the value of the placed order. Orders of this type are usually placed in anticipation of that the security price, having fallen to a certain level, will increase;
  • Buy Stop- Buy provided the future “ASK” price is equal to the pre-defined value. The current price level is lower than the value of the placed order. Orders of this type ae usually placed in anticipation of that the security price, having reached a certain level, will keep on increasing;
  • Sell Limit- sell provided the future “BID” price is equal to the pre-defined value. The current price level is low than the value of the placed order. Orders of this type are usually placed in anticipation of that the security price, having reached a certain level, will keep falling.
  • Sell Stop- Sell provided the future “BID” price is equal to the pre-defined value. The current price level is higher than the value of the placed order. Orders of this type are usually placed in anticipation of that the security price, having reached a certain level, will keep on falling.

Stop Loss

Stop loss order is used for minimizing of losses if the security price has started to move in an unprofitable direction. If the security price reaches this level, the position will be closed automatically. Such orders are always connected to an open position or a pending order. The brokerage company can place them only together with a market or a pending order. Terminal checks long positions with BID price for meeting of this order provisions (the order is always set above the current ASK price).

To automate Stop Loss order following the price, one can use Trailing Stop.

Take Profit

Take Profit order is intended for gaining the profit when the security price has reached a certain level. Execution of this order results in closing of the position. It is always connected to an open position or a pending order. The order can be requested only together with a market or a pending order. Terminal checks long positions with BID price for meeting of this order provisions (the order is always set above the current BID price), and it dos with ASK price for short positions (the order is always set below the current ASK price).

Zeal Holdings Limited Incorporated and registered in British Virgin Islands with Company Registration: 2006432. Zeal Holdings Limited, as a Group is composed of Multiple Brands 100% (Wholly) owned, authorised and regulated in various jurisdictions through the following Subsidiaries:

Traze (Pty) Ltd Company Registration Number: 2016/164943/07 and registered address: Dock Road Junction Cnr Dock Road and Stanley Street V&A Waterfront Cape Town 8001, South Africa. Authorised by the Financial Services Conduct Authority with FSP (Financial Services Provider) Number: 48248. Traze (Pty) Ltd does not carry out any Principal activities and is not an ODP.

Zeal Capital Market (Seychelles) Limited, is regulated as a Securities Dealer by the Financial Services Authority of Seychelles, license number: SD027. Its principal office is at: Office 1, Unit 3, 1st Floor, Dekk Complex, Plaisance, Mahe, Seychelles.

Zeal Capital Market (Seychelles) Limited does not provide services for residents of certain countries such as the United States of America, Brazil, Canada, Egypt, Iran and North Korea (Democratic People’s Republic of Korea) and EU countries.

Official Website: www.traze.com | © 2024 Traze

Zeal Capital Market (UK) Limited is authorised for specific activities and product types including dealing in investments as agent, dealing in investments as principal, arranging (Bringing about) deals in investments and making arrangements with a view to transactions in investments by the Financial Conduct Authority, FCA Registration Number (FRN): 768451. Its principal office is at: No. 1 Royal Exchange, London, EC3V 3DG, United Kingdom.

Risk Warning: Contracts for Difference (CFDs) are complex instruments and come with a high risk of losing money rapidly due to leverage. You may be required to make further deposits in order to meet your margin requirements. You should consider whether you understand how CFDs work and whether you can afford to take the risk. The historical financial performance of any underlying instrument is no guarantee or indicator of future performance. Trading financial derivatives may not be suitable for all investors. Please ensure that you fully understand the risks involved, and seek independent advice if necessary.