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Disclaimer

We have provided the information available on this website for your general guidance. We take great care in ensuring that the information is accurate; however we accept no liability in this respect. You should be aware that the content is subject to change without notice.

The information on this web site is not targeted at the general public of any particular country. It is not intended for distribution to residents in any country where such distribution or use would contravene any local law or regulatory requirement.

The services offered on this web site are only available following successful completion of our account opening requirements. We have made every effort to describe the benefits and risks associated with these services which you should ensure you understand before contemplating an application.

In the ordinary course of its business, we may hold positions in one or more financial instruments which feature on this web site.

You acknowledge and agree that any instruction given by you or on your behalf via our website is made at your own risk. You will be responsible for keeping your account number and password confidential and acknowledge that we shall be entitled to rely upon these details to identify you.

All copyright, trademarks and other intellectual property rights in the content of this website belong to us or our licensors. No information on this website may be reproduced, adapted, uploaded to a third party distributed or transmitted in any form by any process without our specific written consent.

From time to time, our website may contain links to other sites and/or resources provided by third parties. These links and/or resources are provided for your information only and we have no control over the contents of those materials, and in no way endorse their content. Any analysis, opinion, commentary or research-based material on our website is for information and educational purposes only and is not, in any circumstances, intended to be an offer, recommendation or solicitation to buy or sell. You should always seek independent advice as to your suitability to speculate in any related markets and your ability to assume the associated risks, if you are at all unsure. No representation or warranty is made, express or implied, that the materials on our website are complete or accurate. We are not under any obligation to update any such material.

As such, we (and/or our associated companies) will not be responsible or liable for any loss or damage incurred by you or any third party arising out of, or in connection with, any use of the information on our website (other than with regards to any duty or liability that we are unable to limit or exclude by law or under the applicable regulatory system) and any such liability is hereby expressly disclaimed.

Forex Trading
Terms and Policies

This includes General Terms, Supplemental Terms, Regulatory Notices and Policies.

Terms and Policies (FX, CFD and Spread Betting)

Further information regarding:

Pricing and Fees (formerly known as Key Service Features)

Market Information

This provides the commercial details of each market, including market hours, margin factors and other requirements for dealing in each market. The Market Information is available on the trading platform.

Important Information
1. Your cancellation rights

There is no minimum duration for this agreement. Should you decide to cancel your account with Macrogm, You can send us an email via your registered email: [email protected],If you have any open trades with us, your account will remain open until they are closed, filled or cancelled in accordance with the general terms.

2. Complaints

We aim to provide a high standard of service to all our clients on every occasion.

However, If you wish to raise a complaint about any aspect of our service, you can contact our Client Management Team on +61 0280280188, [email protected] or send a copy of your complaint to:

Client Management Team

Suite 1 Level 26,25 Bligh Street,SYDNEY NSW 2000

3. Complaints Procedure

We have established an internal complaints procedure to ensure that your complaint is dealt with efficiently and by the correct person. We usually aim to resolve issues within 3 business days following receipt of the complaint.

To help us investigate and resolve your complaint as quickly as possible and with minimum inconvenience to you, please make sure you give us as much information as possible, including:

  • Your name, address and client reference number
  • A clear description of your complaint
  • Details of what you would like us to do to put it right
  • Copies of any relevant documents, such as letters
  • A daytime telephone number where we can contact you

If the Client Management Team are unable to resolve the matter to your satisfaction, your complaint may be referred to our Compliance Department who will:

  • Send you a prompt written acknowledgement
  • Issue you a final response within eight weeks of the complaint logged date setting out our view and your options

    If you are not satisfied with the outcome of your complaint you can request a review from the Financial Ombudsman Service. The Financial Ombudsman Service has been established to review eligible complaints which firms are unable to resolve.

In our final response, we will confirm your eligibility to refer your complaint to the Financial Ombudsman Service which must take place within six months of our final response. The Financial Ombudsman Service’s contact details are outlined below:

Australian Financial Complaints Authority

GPO Box 3 Melbourne VIC 3001

Email: [email protected]

FAX: (03)9613 6399

Web: www.afca.org.au

4. Compensation arrangements

As an ASIC regulated firm, we are required to take out compulsory Professional Indemnity Insurance (PI Insurance) for our clients which will be provided by Lloyds Bank and if you are an eligible claimant under the scheme you may be liable if we are unable to meet our obligations. are entitled to compensation from the program. For most types of investments, you may receive up to AUD$. The latest information about the program is available from

5. Compensation arrangements

The contract and all future correspondence will be in English. Without agreement to the contrary, English Law will apply.

6. Tax and Charges

Foreign exchange contracts trading is exempt from AU stamp duty. Legislation and tax laws change. You take the risk that your foreign exchange contracts trading may become subject to AU stamp duty in the future. We do not represent or warrant that no tax or stamp duty will be payable. You will be responsible for all taxes and stamp duty in respect of your trading and will indemnify us against them. If in doubt, you should obtain legal and/or independent financial advice.

Privacy Policy
Who we are

Macro Global Markets Pty Ltd of Suite 1 Level 26,25 Bligh Street,SYDNEY NSW 2000 ("we", "us", "our") is subject to data protection legislation in the Australia.

We are committed to protecting your privacy and maintaining the security of any personal information that we receive from you.

If our privacy policy changes, we will place an updated version on our website.

The purpose of this policy

The purpose of this policy is to explain to you what personal information we collect and how we and our associated companies may use it. Companies are associated with us if they are our subsidiaries or we are both subsidiaries of the same corporate entity.

We are the controller of any personal information which you provide to us which means that we decide the purposes and means of the processing of that personal information.

How we obtain and store your information

We obtain your information through applications, emails, letters, telephone calls, SMS messages, cookies and conversations when registering for our services and during the course of our relationship (including information gained when you use our learning tools, demo accounts and trading simulators)./p>

We may monitor or record phone calls with you and monitor (and maintain a record of) all emails and electronic communications sent by or to us.

We follow strict security procedures in the storage and disclosure of information that you have given us to prevent unauthorised access.

What types of personal information we process

We may process the following types of personal information:

  • name;
  • contact details including email details and phone numbers;
  • age or date of birth;
  • gender;
  • occupation;
  • income;
  • trading knowledge and experience;
  • user names and passwords;
  • information relating to your account including your account history, activity and order;
  • IP address;
  • National insurance number or other MiFIR national identifier;
  • ASIC approved reference number;
  • Transaction reporting reference;
  • Power of attorney / agent details;
  • Phone device type;
  • Operating system;
  • Device ID;
  • Cookie ID;
  • Google 360 ID;
  • GUID;
  • information about your use of our services, products and facilities (including information gained when you use our learning tools, demo accounts and trading simulators);
  • Bank Account Number;
  • Sort Code;
  • Passport Number;
  • Marital Status;
  • Additional information to determine if you are potentially a vulnerable client, which may include special category data – please see “Vulnerable Clients” below;
Vulnerable Clients

We follow ASIC guidance on the fair treatment of vulnerable clients. In order to follow this guidance we may need to collect additional personal information from you. The ASIC has identified four drivers of vulnerability which are: health; life events; financial resilience; and capability (meaning financial literacy). These drivers are broad and could mean the collection from you of a variety of types of personal information such as physical disability, illness, mental health conditions, bereavement, retirement, domestic abuse, literacy skills, access to support, indebtedness, and savings. If you do not provide the information requested we may not be able to continue providing services to you.

We process this personal information as we have a legal and regulatory obligation to do so and because it is necessary for our legitimate interest in treating our clients fairly. Some of this personal information will also be “special category data” (for instance, information regarding health). We use your special category data because it is necessary for a substantial public interest, specifically the safeguarding of economic well-being of certain individuals. We are not able to rely solely on your consent to use this information as in some circumstances we may be unable to lawfully offer you services without this information, and providing this information is a condition of using our services. However you still have rights in respect of this information, which you can find at the bottom of this privacy policy.

When we use this information we do so to determine whether or not you are vulnerable and, if you are, what actions we can take to treat you fairly and protect you from economic harm.

How we check your identity

To comply with money laundering regulations we need to confirm the name and address of our customers and certain third parties. We may ask you to provide physical forms of identity verification when you open your account. Alternatively, we may use a credit reference agency to verify your identity. Our search is not seen or used by lenders to assess your ability to obtain credit.

Using your personal information

As well as checking your identity, the personal information we hold may be used for:

  • considering any of your applications;
  • carrying out risk assessments;
  • complying with our legal and regulatory obligations;
  • performing our obligations under any contract we have with you;
  • administering our relationship with you including resolving queries or issues;
  • establishing and managing your account;
  • reviewing your ongoing needs;
  • providing you with the information, products and services that you request from us;
  • checking your instructions to us;
  • investigating any complaint you may make;
  • providing evidence in any dispute or anticipated dispute between you and us;
  • recovering amounts payable;
  • training our staff;
  • enhancing our customer service and products;
  • undertaking product development and analysis;
  • detecting or preventing fraud or other crimes; and
  • to determine if you are potentially a vulnerable client – please see “Vulnerable Clients” above.

Where you have consented to direct marketing, we may send you marketing material from time to time by post, email, telephone, SMS or other electronic messaging services.

We also use technology to make decisions automatically or to build profiles about you. This technology uses logic that assesses whether our products are suitable for a potential customer, which helps us to determine whether or not it is appropriate for a potential customer to open an account with us. This means that you may not be able to open an account with us if our technology determines that it would not be appropriate for you to do so based on your financial knowledge and trading experience. If you ever think our machines have got it wrong, you can ask for a human to look into it. (See “Your Rights - Rights in relation to automated decision making and profiling”.)

When we may share your information

We may share your personal information with:

  • the ASIC and any other regulatory or tax authority;
  • such third parties as we reasonably consider necessary in order to prevent crime, e.g. the police;
  • our associated companies;
  • third-party service providers and advisers who provide us with administrative, financial, research or other services in connection with the services we provide to you;
  • our introducing brokers and other commercial partners;
  • our professional advisers;
  • our auditors for the purposes of carrying out financial and regulatory audits;
  • our agents, including credit reference agencies, acting on our behalf, carrying out such credit and identity checks, including money laundering checks, compliance regulatory reporting and fraud prevention checks, as we may reasonably consider necessary or desirable, including requesting a reference from your bank or any credit reference agency. Any third party referred to in this clause may share any personal information concerning you with us and other organisations involved in credit reference, the prevention of fraud and/or crime and/or money laundering or for similar purposes or to recover debts involved;
  • courts, tribunals, regulatory or tax authorities and government agencies to enable us to enforce our agreement with you or to comply with the requirements of a court, regulator, tax authority or government agency;
  • the purchaser or potential purchaser of one or more of our businesses or product/service lines and their professional advisers; and
  • our trade repository.

Please also note that disclosure to the trade repository or regulators may also result in certain anonymous transaction and pricing data becoming available to the public.

Generally, we require that organisations outside our associated companies with whom we share your personal information acknowledge the confidentiality of your data, undertake to respect your right to privacy and comply with the data protection principles and this policy.

Information, which we obtain indirectly

We also gather information relating to you and your online behaviour:

  • to help optimise our website, to give you a good user experience and to personalise your use and our communications to you;/span>
  • to help us monitor, support and improve the performance of our site (by analysing your use and experience of our site);
  • to help us understand more about you and the products and services you use and are interested in; and
  • to tailor the online advertising you receive.

Knowing more about you helps us to understand our customers better, and means we can give you recommendations about products and services you may be interested in, and provide you with relevant advertising and customised communications that are of interest to you.

Our website uses cookies to operate, personalise and enhance our site performance and to distinguish you from other users. Please see our cookie policy for further details.

Joint applicants

You should only give us personal information about someone else (such as a joint applicant) with their permission. Where information is provided by you about someone else, or someone discloses information about you, it may be added to any personal information that is already held by us and it will be used in the ways described in this privacy notice. Sometimes, when you open a joint account or product, this may mean that your personal information will be shared with the other applicant. For example, transactions made by you will be seen by your joint account holder and vice versa.

The legal basis for our processing of personal information

The legal basis for our processing of personal information will depend on why we process your information.

Where you wish to enter into or have signed a contract to receive services from us, we will process your personal information to enable us to enter into and perform our contract with you. If you don’t provide the personal information requested then we may not be able to provide some or all of those services to you.

Where you use our website, we will process your personal information collected by using cookies in accordance with our cookie policy. Please click here to view our cookie policy.

We may also need to process your personal information to comply with our legal and regulatory obligations including in relation to:

  • performing anti-money laundering, terrorism prevention and sanctions screening checks, complaints and investigations or litigation;
  • obtaining information about your relevant investment knowledge and experience as required by the ASIC so that we can assess whether a service is appropriate for you;
  • obtaining information about your other investment activities in order to ascertain your status for the purposes of regulations which apply to trading in over-the-counter derivatives; and
  • submitting and disclosing reportable data to our trade repository.

We also have a legitimate interest to process your personal information for:

  • performing the services or supplying the products or information you have agreed to receive from us;
  • ongoing management of our relationship with you and to maintain contact with you;
  • our internal business purposes which may include business and disaster recovery, document retention/storage, IT service continuity (e.g. back-ups and helpdesk assistance) to ensure the quality of the services we provide to you;
  • corporate transactions;
  • marketing analytics including marketing campaign optimisation and web analytics to enable us to develop and target the marketing of our products and services;
  • keeping our records updated and studying how customers use our products/services;
  • developing our products and services, growing our business and informing our marketing strategy;
  • defining the types of customers for our products and services and keeping our website(s) and platform(s) updated and relevant; and
  • defining the types of customers for our products and services and keeping our website(s) and platform(s) updated and relevant; and

If you have consented to direct marketing, we will use relevant personal information to enable us to provide you with personal information about products, news and services that may be of interest to you.

Using companies to process your information outside the Australia

The personal information that we collect from you may be transferred, and stored, outside the Australia. It may also be processed by staff operating outside the Australia who work for us. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. Where we transfer personal information or share it with others outside the Australia, we will ensure that a similar degree of protection is afforded to it by use of model clauses approved by the Australia , by transferring to countries that have been deemed to provide an adequate level of protection for personal data or by such other legally approved method.

How long will we keep it?

We shall hold information about you on electronic and/or paper files whilst you are a customer and typically for seven years after you cease to be a customer. In some circumstances, it may be necessary to keep your information for longer than this period, in order to fulfil the purposes we collected it for, or for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.

How to get more help

If you want help with our Privacy Policy or have questions about it, please contact us.

If you are unhappy about any aspect of the way we collect, share or use your personal information, we would like you to tell us. You can contact us using the details above.

If you are not satisfied with our response, you have the right to file a complaint with the information specialist at GPO Box 5288 Sydney NSW 2001. Phone: 1300 363 992 or visit its website https://www.oaic.gov.au/.

Governing law

This privacy policy is governed by Australia law.

Your privacy rights

This section explains your rights in relation to your personal information in more detail. The various rights are not absolute and are subject to certain exceptions or qualifications.

Further personal information and advice about your rights can be obtained from the Information Commissioner at GPO Box 5288 Sydney NSW 2001. Phone: 1300 363 992 or visit its website https://www.oaic.gov.au.

You are entitled to receive personal information free of charge except in the following circumstances where we may charge a reasonable fee to cover our administrative costs of providing the personal information for:

  • manifestly unfounded or excessive/repeated requests, or
  • further copies of the same information.

Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll let you know.

In order to exercise any of the rights described below please contact us.

Accessing your information
When can you request access?

You have the right to:

  • confirmation that your personal information is being processed
  • access to your information, and
  • other certain information (most of which should be in our privacy policy anyway).

You can request copies of paper and electric records about you that we hold, share or use. To deal with your request, we can request proof of identity and enough personal information to enable us to locate the personal information you request.

When will access not be provided ?

We can only provide you with your information, not personal information about another person. Also, where access would adversely affect another person’s rights, we’re not required to provide this. Due to legal privilege, we may not be able to show you anything that we learned in connection with a claim or legal proceeding.

Please clearly set out in your access request the personal information that you’re requesting. If this is not clear, we may come back to you to ask for further personal information by way of clarification.

Correcting your information

You have the right to obtain from us without undue delay the rectification of inaccurate personal information concerning you.

If you tell us that the personal information we hold on you is incorrect, we will review it and if we agree with you, we will correct our records. If we do not agree with you we will let you know. If you wish, you can tell us in writing that you believe our records still to be incorrect and we will include your statement when we give your personal information to anyone outside the Macro of companies. You can contact us using the details in the section above in the main body of the privacy notice headed ‘Obtaining further personal information from us’.

You may also have the right to have incomplete personal information completed, including by means of providing a supplementary statement. Whether or not this is appropriate in any particular case depending on the purposes for which your personal information is being processed.

We need to notify any third parties with whom we’ve shared your personal information that you’ve made a rectification request. We’ll take reasonable steps to do this, but if it is not possible or may involve disproportionate effort we may not be able to do this or ensure they rectify the personal information they hold.

How you can see and correct your information ?

let you see the personal information that we hold about you, or take steps to correct any inaccurate information, if you ask us in writing.

Due to legal privilege, we may not be able to show you anything that we learned in connection with a claim or legal proceeding.

Erasing your information
When can you request erasure?

You have a right to have your personal information erased, and to prevent processing, where:

  • the personal information is no longer necessary for the purpose it was originally collected/processed;
  • you withdraw consent (where previously provided);
  • you object to the processing and our legitimate interests in being able to keep processing your personal information don’t take priority;
  • we’ve been processing your personal information in breach of data protection laws; or
  • the personal information has to be erased in order to comply with a legal obligation.
When can we refuse erasure requests?

The right to erasure does not apply where we are required to retain it for legal or regulatory purposes or where your information is processed for certain specified reasons, including for the exercise or defence of legal claims.

More importantly, if we have to erase your data we may not be able to provide you with our services.

Do we have to tell other recipients of your personal information about your erasure request?

Where we have provided the personal information you want to be erased to third parties, we need to inform them about your erasure request, so they can erase the personal information in question. We’ll take reasonable steps to do this, but this may not always be possible or may involve disproportionate effort.

It may also be that the recipient is not required/able to erase your personal information because one of the exemptions above applies.

Restricting processing of your information
When is restriction available?

You have the right to restrict the processing of your personal information:

  • where you disagree with the accuracy of the information, we need to restrict the processing until we’ve verified the accuracy of the information;
  • when processing is unlawful and you oppose erasure and request restriction instead;
  • if we no longer need the personal information but you need this to establish, exercise or defend a legal claim; or
  • where you’ve objected to the processing in the circumstances detailed in paragraph (a) of “Objecting to processing”, and we’re considering whether those interests should take priority.
Do we have to tell other recipients of your personal information about the restriction?

Where we’ve disclosed your relevant personal information to third parties, we need to inform them about the restriction on the processing of your information, so that they don’t continue to process this.

We’ll take reasonable steps to do this, but this may not always be possible or may involve disproportionate effort.

We’ll also let you know if we decide to lift a restriction on processing.

Taking your personal information with you
When does the right to data portability apply?

The right to data portability only applies:

  • to personal information you’ve provided to us (i.e. not any other information)
  • where the processing is based on your consent or for the performance of a contract ,and
  • when processing is carried out by automated means.
When can we refuse requests for data portability?

We can refuse your data portability request if the processing does not satisfy the above criteria. Also, if the personal information concerns more than one individual, we may not be able to transfer this to you if doing so would prejudice that person’s rights.

Objecting to processing

You can object to processing in the following circumstances:

Legitimate interests

You’ve the right to object, on grounds relating to your particular situation, at any time to processing of personal information concerning you which is based on legitimate interests.

If we can show compelling legitimate grounds for processing your personal information which override your interests, rights and freedoms, or we need your personal information to establish, exercise or defend legal claims, we can continue to process it. Otherwise, we must stop using the relevant information.

Direct marketing

You can object at any time to your personal information being used for direct marketing purposes (including profiling related to such direct marketing).

If you sign up to receive newsletters or other e-mail messages from us, you can opt-out at any time free of charge by clicking the unsubscribe link at the bottom of the message. You may also choose to opt-out from receiving marketing materials from us through MyAccount or by contacting us.

Automated decision making and profiling

You’ve the right not to be subject to a decision based solely on automated processing, including profiling, which has legal consequences for you or similarly significant effects.

As explained in the main part of our Privacy Policy, we use technology that does this. We only do so where:

this is necessary for entering into, or performance of, a contract between us;

this is authorised by applicable law; or

we’ve obtained your explicit consent to do so for these purposes.

While we’re confident that the technology works, we understand that not everyone is comfortable with decisions being left entirely up to machines. That is why you can request human intervention - let us know your concerns and contest the decision if you think our technology has got it wrong.

Last updated: January 2024

Trade and Order Execution Policy
1. Introduction

Delivering best execution is fundamental to market integrity and to the delivery of good outcomes for clients, and is something we are fully committed to. Under the rules of the Australian Securities & Investments Commission(“ASIC Rules”) we have a duty to conduct our business with you honestly fairly and professionally and to act in your best interests in dealing with you. More specifically, we are required to provide you with the best possible execution when we deal with you.

Providing best execution under ASFL requires even greater levels of compliance than before and means that when we deal with you we must take all sufficient steps to obtain the best result for you in accordance with our trade and order execution policy. It does not mean that we must obtain the best possible results for you on every single occasion. However, it does require us to verify on an on-going basis that our execution arrangements are working well throughout the different stages of the order execution process.

This document sets out the general terms of our trade and order execution policy and our actual policy is available upon request. Unless separately defined, words and expressions herein shall have the meanings given to them in the General Terms. However this overview is not part of our Agreement and it does not form part of the contract between us. In the event of any conflict between this document and our actual policy, the terms of that policy will prevail.

We deal with you as principal and not as agent. We are therefore your only “execution venue”. In dealing with us, you transact directly with us and not on any exchange or other external market or venue. Any Trades with us are non-transferable. If you create an Open Position with us you must close it with us.

2. Execution policy

In providing best execution we are obliged to take into account certain execution factors. We must tell you what these are and the relative importance we give to each. If you are a Retail Client, we must determine whether we have provided you with best execution by reference to the total consideration you pay (that is price and costs of execution) though we will also use our judgement and take into account other relevant factors (such as any instructions regarding price) with the aim of providing you with the best result.

The execution factors that we consider and their relative importance are as follows:

Price: The relative importance we attach is high. Our Price for a given Market is calculated by reference to the price of the relevant Underlying Instrument. We obtain this price from third party external reference sources. For some kinds of instruments, e.g. equities, there will be a third party securities exchange from which we will obtain this price. For other kinds of instruments, e.g. foreign exchange, we will collect price data from nominated wholesale market participants.

Our Price will often differ from the price of the Underlying Instrument. For some Markets we add Our Spread to the price of the Underlying Instrument. We may also adjust Our Price for any Market to take into account factors such as liquidity in external markets for the Underlying Instrument, dividend amounts, financing charges in an external market or other relevant factors. You must pay Daily Financing Fees, commission and other charges in addition to Our Price for some Products and Markets – see under “Costs” below.

When trading in the Underlying Instrument is very active and the price of the Underlying Instrument changes quickly, there is no guarantee that every price movement in the Underlying Instrument will result in a change to Our Price. We aim to update Our Price as frequently as we reasonably can but our ability to do so may be limited by technological factors including current hardware, software and data and communications links.

For some Markets we will quote Our Price outside of trading hours for the Underlying Instrument. In such circumstances Our Price is set by us by reference to one or more related alternative Underlying Instruments that are then traded, and may be adjusted in response to supply and demand from our clients. This means that outside normal Exchange Hours we exercise a greater degree of discretion in the setting of Our Price. In addition, Our Spread is generally wider and our maximum Quantity is generally smaller than during normal trading hours for the Underlying Instrument.

We execute all Trades at Our Price and in accordance with the General Terms.

Costs: The relative importance we attach is high. For many Markets, Our Price includes Our Spread and no additional charges or commissions are payable by you. For other Markets you will be required to pay a separate commission charge for each Trade to open or close an Open Position.

We may pass on some charges to you arising from the Underlying Instrument traded. These include borrowing charges where an Underlying Instrument becomes expensive to borrow or stamp duty in some circumstances.

Additionally for many Markets you will be required to pay Daily Financing Fees on the full amount of an Open Position. Generally:

Details of the Daily Financing Fees are set out on our Website.

We will also charge a premium for Guaranteed Stop Loss Orders.

Details of charges we make in respect of particular Markets are set out in the Market Information.

Speed and Likelihood of Execution: The relative importance we attach is high. You may execute Trades either using our Trading Platform or by phoning one of our dealers.

When you execute through the Trading Platform you will receive immediate execution capability: if you see an Our Price on the screen and the Quantity you want to trade is less than our maximum Quantity for that Market, then the Trade will, under almost all circumstances, be executed at the Our Price quoted on the Deal Ticket. We will execute all Trades in accordance with the General Terms.

When executing by phone in a Quantity above our minimum Quantity but below our maximum Quantity, you will be quoted the same Our Price you will receive if you use the Trading Platform. In such circumstances, the dealer will generally confirm execution of your Trade immediately after you indicate that you wish to trade at the quoted Our Price.

Trades will be executed as soon as reasonably possible and in most circumstances almost instantaneously. However, there may be circumstances where Trades cannot be executed almost instantaneously, for example, due to illiquidity in the Underlying Instrument or if there is something unusual about the nature of the Order.

Quantity: The relative importance we attach is high. We normally provide certainty of execution for Trades you wish to place for a Quantity which is greater than our minimum Quantity and lower than our maximum Quantity.

Our minimum and maximum Quantities are set by us for each Market and may vary depending on current market conditions for the Underlying Instrument. Our minimum and maximum Quantities can be found in the Market Information or you may contact Client Management.

Where you wish to execute a Trade whose size exceeds our maximum Quantity, you may be quoted a different Our Price for the requested Quantity. Alternatively, if you agree with one of our dealers by phone, we may work the Order in an external market on your behalf.

3. Working an Order in the Market

The Our Price at which a worked Order is executed will be based upon the average price we receive for our transactions on an External Execution Venue. In such circumstances, our Trade with you may be subject to any applicable charges as described in the Market Information.

Our Trade or Trades with you only become effective after we have executed our hedge transactions on an External Execution Venue and you have confirmed Our Price. Please note if we have agreed to work an Order in the market for you and have started to execute transactions on an External Execution Venue then you cannot cancel the Order. However, we may agree to cancel any unfilled part of the Order.

4. Dealing with your Orders

In most cases when the condition or event specified in your Order occurs it will be executed at or very close to the specified Order Price. However, please note that for all Orders other than Guaranteed Stop Loss Orders, the price you receive at execution is not guaranteed. Our Price may move from a price which is less than your specified Order price to a price which is greater than your specified Order price without a quote at any intermediate price. This will be due to rapid price changes in the Underlying Instrument (called ‘gapping’), for example following a profits warning or the release of financial statistics different from those expected. In such a case, Our Price at the time of execution may be markedly different to the specified Order price.

If, when an Order is executed, the Quantity is less than our maximum Quantity for that particular Market, the Order will be executed at or near the specified Order price.

Note that if you have placed multiple Orders in the same Market, with the same specified Order price and with a Quantity greater than our maximum Quantity, there is no guarantee that they will all be executed at the same price, since each Order must be executed as a different Trade. The execution prices will depend on the liquidity in the external market for the Underlying Instrument and the execution of the first Trade may affect the liquidity available for the execution of the second and any subsequent Trades.

We will execute all Orders in accordance with the General Terms.

5. Specific instructions

You may give us a specific instruction for the execution of a Trade or an Order.

Following your specific instructions may prevent us from taking the steps set out herein to obtain the best possible result for the element of the Trade or Order included in your instructions.

6. Our obligations

We will comply with our Trade and Order Execution Policy when

We are required to exercise our judgement in obtaining the best outcome for the execution of clients’ Trades and Orders.

We have an overriding obligation as an ASIC licensee to provide financial services efficiently, honestly and fairly. In adhering to these obligations, we maintain internal policies and procedures. We take all reasonable steps to obtain the best possible result when executing client orders or placing orders with (or transmitting orders to) other entities to execute. We consider a range of execution factors in order to deliver best execution including price, costs and speed. We maintain a Code of Conduct which sets out minimum standards for our employees when discharging their duties. Contraventions of the code, suspected contraventions or where have reasonable grounds to believe that the code may be contravened in some way in the future, must be escalated to the Head of Compliance or General Manager.

7. Monitoring and review of our policy

We will monitor compliance with our policy and maintain records of the data which is used to set Our Price.

We will review our policy at appropriate intervals. As part of that process, we will review:

  • the sources of external pricing in Underlying Instruments;
  • Our Price in relation to the external pricing of an Underlying Instrument; and
  • any fees or charges.

If we make any material changes to our policy, we will notify you by email or by posting such information on our Website or the Trading Platform.