GRM European best execution policy

1 Introduction

Global Reach Group – Europe is formed of four Netherlands-domiciled entities: Global Reach FX BV (GRF), an authorised Payment Institution, Global Reach Markets BV (“GRM”), an authorized investment firm and 2 customer accounts foundations, Global Reach FX Stichting and Global Reach Markets Stichting whose objectives are to receive, manage and pay or transfer funds for and to entitled parties. Under the Markets in Financial Instruments Directive II (‘MiFID II’) GRM are required to put in place a Best Execution policy and to take sufficient steps to obtain the best possible result (or ‘best execution’) on behalf of our clients, either when executing Orders for clients or when receiving and transmitting Orders for execution. We are also required to provide appropriate information to our clients in our Best Execution Policy. Our commitment to provide clients with ‘best execution’ does not mean that we owe clients any fiduciary responsibilities or duties over and above the specific regulatory obligations placed upon us, or as may be otherwise contracted between us. The purpose of this document is to provide our clients with information on our best execution policy.

2 Scope

GRM’s Best Execution Policy (‘policy’) applies only to clients trading in Financial Instruments. It applies to orders executed in circumstances where our client has issued explicit trading instructions but does not apply where a contract arises following a client’s request for GRM to quote for foreign exchange business. GRM executes all Orders by dealing as matched principal on behalf of our client.

3 Best Execution – obtaining the best result

Subject to any specific instructions that may be provided by you, the client (see Section 7), when executing Orders on your behalf, we will take all sufficient steps to obtain the best possible result taking into account the Execution Factors listed in Section 4. We will determine the relative importance of the Execution Factors by using our commercial judgement and experience, considering the market information available and taking into account the Execution Criteria described in Section 5.

4 Execution Factors

The Execution Factors that will be taken into account are: • Price of the financial instruments • Costs relating to financing the transaction throughout its life cycle • Speed of executing the order including settlement • Size of the order • Product offering by counterparty • Tenor of product • Client categorisation • Nature or any other consideration relevant to the execution of the Order. Price and cost will usually merit a high relative importance in obtaining the best possible result. However, when executing on behalf of a retail customer total consideration of, price, costs expenses and fees will be accounted for when determining the best possible execution result. It should be noted that when considering the price and cost we look at the balance of our existing trades across our counterparties as a more balanced portfolio results in a lower net cost to our clients.

5 Execution Criteria

The Execution Criteria that will be taken into account are the characteristics of: • The client (and the client’s categorisation). • The Order. • The Financial Instruments that are the subject of that Order; and • the Execution Venues to which the Order can be directed.

6 Execution Venues

When trading Financial Instruments, we leverage the relationships of other firms within Global Reach Group to access multiple Execution Venues. GRM’s execution venue is its 100% affiliated company Global Reach Partners Limited that is authorized and regulated by the FCA in United Kingdom. We reserve the right to use other Execution Venues in order to obtain the best overall result for you. Not all products are available at each Execution Venue. 

Subject to any specific instructions that may be provided by you (see Section 7), to select an Execution Venue for an Order, we will use the following methodology:

• We will select the Execution Venue that we consider the most appropriate subject to proper consideration of the Execution Criteria and Execution Factors.
• We will not structure or charge our commissions in such a way as to discriminate unfairly between Execution Venues.
• We will regularly assess the Execution Venues available in respect of any products that we trade to identify those that will enable us, on a consistent basis, to obtain the best possible result when executing Orders.

The list of Execution Venues will then be updated, where necessary, following such assessment. A customer may request an up-to-date Execution Venue list can at any time. GRM will not unfairly discriminate between Execution Venues or types but will make a decision based on a consideration of the execution factors.

7 Client Instruction

Where you give us a specific instruction as to the execution of an Order, we will execute the Order in accordance with those specific instructions, even if contrary to this policy. Where your instructions relate to only part of the Order, we will continue to apply our best execution policy to those aspects of the Order not covered by your specific instructions. If you provide specific instructions to us in relation to the execution of a particular Order, it may prevent us from taking the steps set out in this policy to obtain the best possible result, in respect of the elements covered by those instructions.

8 Execution Cost

Where a transaction is subject to Best Execution, and the selection of an execution venue is relevant, we will choose the execution venue (or venues) that we consider to be the most appropriate to meet our obligation to obtain the best possible results for our clients on a consistent basis.

9 Monitoring

We will monitor compliance with this policy.

10 Review

We will regularly review our order execution arrangements. We will also review the Best Execution Policy annually and whenever a material change occurs that affects our ability to continue to obtain the best possible results for our clients. We will notify you of any material changes to our execution arrangements or our Best Execution policy by posting an update of this document on our website. You will not be notified separately of any changes to our Execution Venues. You should therefore refer to the current list of Execution Venues that are available on our website.

11 Consent

We are required to obtain your consent to our Best Execution Policy prior to executing any order. We understand that, by the act of agreeing to trade with us, you are effectively affirming your consent to it. Alternatively, should you have any questions then please contact us at: [email protected]

12 Definitions

‘Client’ means any natural or legal person to whom an investment firm (GRM) provides investment and/or ancillary services. ‘Execution Criteria’ means those factors listed in Section 5 of this document. ‘Execution Factors’ means those factors listed in Section 4 of this document. ‘Execution Venue’ means a third-party market maker. ‘Financial Instruments’ means a foreign exchange contract which is not a Spot contract, or a MiFID exempt forward contract. ‘Order’ means an instruction to buy or sell a Financial Instrument which is accepted by us for execution or transmission to a third party.

13 Disclosure to Clients

This Policy does not form part of our general business terms and is not intended to be contractually binding. It does not impose or seek to impose any obligations on GRM which we would not otherwise have – whether under our general business terms, or the AFM rules, had this Policy not been disclosed to you.