Order Execution Policy

1. Introduction

ZenGuard Markets Ltd ("we", "us", "our") is committed to achieving the best possible result when executing client orders, subject to the execution factors set out in this policy. This Order Execution Policy describes how we execute orders on behalf of our clients, the execution venues we use, and the factors we consider when determining the best execution outcome.

This policy is provided to you in accordance with the UK Financial Conduct Authority (FCA) Conduct of Business Sourcebook (COBS) and the Markets in Financial Instruments Directive (MiFID II) framework. It applies to all orders in financial instruments that we execute for you as an execution-only client. By opening an account and trading with ZenGuard Markets, you acknowledge that you have read, understood, and accepted this policy.

2. Scope

This Order Execution Policy applies to all retail and professional clients of ZenGuard Markets who trade financial instruments through our platform, including contracts for difference (CFDs) on forex, indices, commodities, shares, and cryptocurrencies. The policy covers both single orders and orders that form part of a larger transaction.

This policy does not apply to orders where you have given us a specific instruction that limits our ability to obtain the best execution (for example, an instruction to execute only on a particular venue or at a specific price). In such cases, we will execute your order in accordance with your instructions but may not be able to achieve the best possible result.

3. Execution Venues

ZenGuard Markets executes client orders through a combination of execution venues to achieve the best possible result. Our primary execution model involves acting as principal, meaning we are the counterparty to your trades. We hedge our exposure by executing offsetting transactions with our liquidity providers, including tier-one banks, institutional market makers, and regulated exchanges.

We maintain relationships with multiple liquidity providers and may route orders to different venues depending on the instrument, order size, market conditions, and the execution factors described in this policy. We do not maintain a formal list of execution venues for OTC products such as CFDs, as liquidity is sourced dynamically from our provider network. For exchange-traded instruments, we execute on regulated exchanges and multilateral trading facilities as appropriate.

4. Order Types

Market Orders: A market order is an instruction to buy or sell at the best available price immediately. We will execute market orders as soon as practicable at the prevailing market price. During periods of high volatility or low liquidity, the execution price may differ from the price displayed at the time the order was placed.

Limit Orders: A limit order specifies the maximum price (for buy orders) or minimum price (for sell orders) at which you are willing to trade. The order will only be executed if the market reaches your specified price or better. Limit orders may remain unfilled if the market does not reach your price.

Stop Orders: A stop order (stop-loss) becomes a market order when the market price reaches a specified trigger level. Once triggered, execution is attempted at the best available price, which may be less favorable than the trigger price in fast-moving markets.

Stop-Limit Orders: A stop-limit order combines a stop trigger with a limit price. When the trigger is reached, the order becomes a limit order and will only execute at the limit price or better. There is a risk that the order may not be filled if the market moves away from the limit price.

Trailing Stop Orders: A trailing stop order dynamically adjusts the stop level as the market moves in your favor, locking in profits while limiting downside. The stop level trails the market price by a specified distance. When triggered, execution is attempted at the best available price.

5. Execution Factors

When executing orders, we take into account the following factors, which may conflict with each other. The relative importance of each factor depends on the characteristics of the order, the instrument, the client, and the market conditions.

Price: We aim to obtain the best price for you, considering both the execution price and the total cost of the transaction, including spreads, commissions, and financing charges. For many instruments, price is the most important factor.

Cost: We consider all costs related to execution, including explicit costs (commissions, fees) and implicit costs (spreads, market impact). We seek to minimize total cost where consistent with other execution factors.

Speed: The speed of execution can be important, particularly for market orders and in volatile markets. We balance speed against the potential for price improvement through additional price discovery.

Likelihood of Execution: For limit orders and larger orders, the probability of full execution may take precedence over achieving a marginally better price. We may use execution strategies that prioritize fill certainty where appropriate.

6. Slippage

Slippage occurs when an order is executed at a price different from the price displayed or requested at the time the order was placed. Slippage can work in your favor (positive slippage) or against you (negative slippage). It is most common during periods of high market volatility, low liquidity, around major economic announcements, or when placing large orders.

ZenGuard Markets does not guarantee that orders will be executed at the requested or displayed price. For market orders and stop orders, we will execute at the best available price at the time of execution. We implement measures to minimize slippage, including robust pricing feeds, multiple liquidity sources, and appropriate order handling procedures. However, in volatile conditions, significant slippage may occur. You should consider using limit orders where price certainty is important to you.

7. Price Improvement

Price improvement occurs when an order is executed at a better price than the price displayed or requested. We may be able to achieve price improvement when our liquidity providers offer prices that are more favorable than our quoted prices, when we can aggregate orders to achieve better pricing, or when market conditions allow for execution at improved levels.

We pass on price improvement to clients where practicable and where it does not conflict with our obligations under this policy. However, we do not guarantee that price improvement will be achieved on any order. The possibility of price improvement is one of the factors we consider when determining execution strategy.

8. Requotes

A requote occurs when the price at which you requested to execute has moved before we can process your order, and we present you with a new price. Requotes typically occur during volatile market conditions, when there is a delay between your order submission and our ability to confirm execution, or when the order size exceeds available liquidity at the quoted price.

When a requote occurs, you may choose to accept the new price, reject it and cancel the order, or modify your order. We aim to minimize requotes through our technology and liquidity arrangements, but they may be necessary to ensure fair and accurate execution. We will not execute orders at prices that are no longer available in the market.

9. Order Aggregation

We may aggregate your orders with orders of other clients or with our own orders when we reasonably believe that aggregation is in the best interests of the clients concerned. Order aggregation can result in more favorable execution by accessing better prices or liquidity than would be available for individual orders.

When we aggregate orders, we allocate the execution results fairly among the aggregated orders. Our allocation methodology takes into account the size and timing of each order and aims to ensure that no client is systematically disadvantaged. We maintain records of aggregated orders and allocations for regulatory and audit purposes.

10. Monitoring and Review

We regularly monitor the quality of execution we obtain for our clients. Our compliance and execution teams review execution data, analyze execution quality across different instruments and market conditions, and assess the performance of our liquidity providers. We use this analysis to improve our execution arrangements and to ensure continued compliance with our best execution obligations.

We review this Order Execution Policy at least annually, or more frequently when there are material changes to our execution arrangements, market structure, or regulatory requirements. Any material changes to this policy will be communicated to you in advance, and you will have the opportunity to accept the updated policy or close your account.

11. Client Consent

By opening an account with ZenGuard Markets and placing orders through our platform, you confirm that you have read and understood this Order Execution Policy. You consent to us executing your orders in accordance with this policy and acknowledge that we may act as principal and may aggregate your orders as described herein.

If you have any questions about this policy or how we execute your orders, please contact our client support team or compliance department. We are committed to transparency and will provide you with such information about our execution practices as we are reasonably able to disclose.