Order Execution Policy

ORDER EXECUTION POLICY

Introduction

MEXEM LTD (hereinafter referred to as the "Company") is an Investment Firm incorporated and registered under the laws of the Republic of Cyprus, with registration number HE 351726. The Company is authorized and regulated in Cyprus by the Cyprus Securities and Exchange Commission (hereinafter referred to as "CySec") and subject to CySec rules, with CIF license number 325/17.
Subject to the provisions of the law which provides for the provision of investment services, the exercise of investment activities, regulated markets and other matters L144(I)/2007 as amended (the “Law”) the Company is required to set up this Policy and to take all reasonable steps to obtain the best possible result (or “Best Execution”) for its Clients either when receiving and transmitting orders in relation to financial instruments. The Policy sets out general overview on how orders are executed and to provide appropriate information to their Clients on their order execution policy.
The Company applies the Policy upon acceptance of an order and also when a client gives no specific instruction on the execution method. Nevertheless, when the client gives a specific instruction of an order, the Company shall execute the order following such instruction. If the Company receives a specific instruction of an order, this may prevent the Company from implementing the Policy to obtain the best possible result for the execution of the order.
Scope of Policy
The Policy applies whenever the Company is executing orders on behalf of its clients when trading through its trading website and/or platform. Every order which the Company may take is accepted and executed on the basis that the Company is acting in the best interests of the client. The Company does not guarantee that when receiving and transmitting for execution a transaction the client’s price will be more favourable than one which might be available elsewhere.
Best Execution Criteria and Factors
The Company shall take all reasonable steps to obtain the best possible results for its Clients taking into account the following factors when executing Clients orders against the Company’ quoted prices:
It is clarified that the Company does not hold clients’ funds.
1. Price
The Company, as part of its business operations, and the use of the execution venue, which is Interactive Brokers (please refer to the Company’s terms and conditions) shall provide Interactive Brokers’ tradable prices. The main way in which the Company will ensure that the client receives the best execution will be to ensure that the price provider to the client is made with reference and compared to a range of underlying price providers and data sources.
2. Costs
For opening a position in some types of financial instruments the Client may be required to pay commission or financing fees, the amount of which is disclosed on the Company Website.

8. Best Execution Criteria
The Company will determine the relative importance of the above Best Execution Factors by using its commercial judgment and experience in the light of the information available on the market and taking into account the criteria described below:
(a) The characteristics of the Client including the categorization of the Client as retail or professional;
(b) The characteristics of the Client order;
(c) The characteristics of financial instruments that are the subject of that order;
(d) The characteristics of the execution venues to which that order can be directed.
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 which 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.

11. Client Consent
When establishing a business relation with the Client, the Company is required to obtain the Client’s prior consent to this Policy.
The Company is also required to obtain the Client’s prior express consent before it executes or transmits its order for execution outside a regulated market or an MTF (Multilateral Trading Facility).

The Company may obtain the above consents in the form of a general agreement. The Company will treat clients who have either received the Policy or agreed to receive the Policy electronically or via the internet and have accepted the Terms and Condition of the Company, as clients who have given consent to the Policy as well as given consent to the Company to receive and transmit an order for execution outside a regulated market or an MTF.