Trading Procedures & Best Execution Policy

Leads Capital inc.

March 15, 2017


Trading Procedures & Best Execution Policy


  1. General Policy


1.1. When dealing with Retail Clients and Professional Clients, Leads Capital inc. (the “Company”) will take all reasonable steps to obtain, when executing orders, the best possible result for the client taking into account price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of the order. Nevertheless, whenever there is a specific instruction from the client, the Company shall execute the order following such instruction.


1.2. All orders shall be transmitted to the Company’s system from the Client’s system (the “System“) by electronic means. The Company may also, at its sole discretion, receive client’s instructions regarding transaction execution via the following means: telephone, fax and/or electronic mail, subject to the terms of this policy. Such instructions will not impose any obligation upon the Company to execute these instructions.


1.3. Any order shall not take effect unless actually received by the Company. The Company shall be entitled to rely upon any instruction given or purporting to be given by client or any other Company pre-approved authorized person on client’s behalf without further enquiry as to the genuineness, authority or identity of any such person giving or purporting to give such instructions.


1.4. Orders can be placed, executed, changed or removed only during the period of time within a business week when the Company systems provides the opportunity for trading operations. The client’s order shall be valid in accordance with the type and time period of the given order, as specified. If the period of validity of the order is not specified, it shall be valid for an indefinite period and shall be executed accordingly under the Company’s sole discretion. The status of the orders is always shown using the client’s online access to the System. In the event that access to the System is not available, the client may contact the Company by telephone and request the status of any pending order(s) that the Client placed, but the Company does not guarantee that it will be able to furnish the status of such orders in every case.


1.5. The Company shall not be held responsible in the case of delays or other errors caused during the transmission of orders, instructions and/or communications via computer networks.


1.6. The Company reserves the right to change the opening/closing price (rate), size and/or number of the related transaction (and/or the level and size of any order) in case any financial instrument becomes subject to possible adjustment as the result of any Corporate Event (defined below). This operation is applied exclusively to transactions which relate to securities and has a meaning to preserve the economic equivalent of the rights and obligations of the parties under that Transaction immediately prior to that Corporate Event. All actions of the Company that implement such adjustments are conclusive and binding upon the client. The Company shall inform the client of any adjustment as soon as reasonably practicable.


1.7. While a client has any open positions on the ex-dividend day for any financial instrument, the Company reserves the right to close such positions at the last price of the previous trading day and open the equivalent volume of the financial instrument at the first available price on the ex-dividend day. In this case, information by internal mail in the trading terminal, or any other agreed means of communication, shall be posted about the possibility of such actions.


1.8. A “Corporate Event” is a declaration by the issuer of the financial instrument the terms of any of the following:


(a) a subdivision, consolidation or reclassification of shares, a share buy-back or cancellation, or a free distribution of shares to existing shareholders by way of a bonus, capitalization or similar issue;


(b) a distribution to existing holders of the underlying shares of additional shares, other share capital or securities granting the right to payment of dividends and/or proceeds of liquidation of the issuer equally proportionately with such payments to holders of the underlying shares, or securities, rights or warrants granting the right to a distribution of shares or to purchase, subscribe or receive shares, in any case for payment (in cash or otherwise) at less than the prevailing market price per share as determined by the Company; and/or


(c) any other event in respect of the shares analogous to any of the above events or otherwise having a diluting or concentrating effect on the market value of the shares.


1.9. Several order types (which may or may not be available to the client from time to time, according to the Company’s discretion with respect to the operation of its system(s) and the supply of Services: Stop Loss, Take Profit, Buy Limit, Buy Stop, Sell Limit, Sell Stop on financial instruments, when they are available for the client, are transmitted on the first current price touch. However, the actual execution of the order is dependent upon Liquidity Provider. The Company reserves the right not to execute the order, or to change the opening (closing) price of the transaction in case of any technical failure.


1.10. Under certain trading conditions it may be impossible to execute orders (including, when available, Stop Loss, Take Profit, Buy Limit, Buy Stop, Sell Limit, Sell Stop) on any financial instrument at the requested price. In this case the Company has the right to execute the order or change the opening (closing) price of the transaction at a first available price. This may occur, for example, at times of rapid price movement if the price rises or falls in one trading session to such an extent that under the rules of the relevant exchange, trading is suspended or restricted. Or this may occur in the trading session start moments. So as a result, placing a Stop Loss order will not necessarily limit client’s losses to the intended amounts, because market conditions may make it impossible to execute such an order at the stipulated price.


1.11. The client may submit to the Company in writing (by e-mail or delivery by hand), its objection(s) to the execution, non-execution or the mode of execution of a transaction and/or order concluded on its behalf within one (1) working day from the conclusion of the transaction. Otherwise the transaction will be considered valid and binding for the client.


1.12. The Client agrees and realizes that all conversations and other means of communications between the client and the Company can be recorded on magnetic, electronic and other carriers. The records are under the Company’s sole and exclusive ownership and the client further agrees that the Company has the right to use these records as evidence in any dispute that arises between the Company and the client.


1.13. The Company has the right to refuse the client in the execution of transactions placed not through the System if the instructions of the client are not clear and do or not include the following operations: opening position, closing position, changing or removing orders.


1.14. In case of any (i) force-majeure;(ii) hacker attacks and other illegal actions against the Company’s systems; and/or (iii) a suspension of trade in the financial markets concerning financial instruments of the Company, the Company may suspend, freeze or close the client’s positions and request from the Client the revision of the executed transactions.


1.15. Trading operations using additional functions of the System, such as any external system that may be connected to the System (whether by API or any other means of integration)are executed completely under the client’s sole responsibility and the Company bears no responsibility whatsoever therefor. The Company reserves the right to reverse any or all types of existing or previous transactions performed by the client in any of its accounts and terminate the agreement, in the event the client uses or delivers additional functions from/to the System such as usage of algorithmic trading capabilities (including “expert advisors” and similar mechanisms) etc., which might cause a manipulation on the execution process of the financial instrument as well as affect the smooth operations of the System.


1.16. The measurement units in relation to the services the Company provides are specified for each financial instrument traded in the System. The specifications appear at the Trading Terms Scheme, available to the Client at the Company’s office, and the Company reserves the right to change any specifications at any time depending on the market situation and risk management policy. The Client agrees to check the full specification of the financial instrument before placing any order. Several leverage rates are applicable, depending on the type of the account, type of financial instrument and the discretion of the Company with regard to the financial instrument. Upon opening of an account by the client, the leverage rate is predetermined according to the type of the account and the Client has to maintain the funds in his Account to support the sufficient margin level with regard. The client may request a lower leverage to be applied to the account by contacting the Company. The Company reserves the right to change the account leverage at its discretion, either for a limited time period or on a permanent basis, by informing the client by written notice sent by electronic means.


1.17. The Company has a discretionary right to begin closing the open positions when the Client reaches the relevant margin level. The Company will automatically close all positions at market price. The Company may change the margin level, from time to time, and notification shall be sent to the client by electronic means in the event that the margin level is increased accordingly.


1.18. The level of swap rates may vary in size and change depending on the level of interest rates. The Company reserves the right to change the swap rate applicable to the financial instruments on a daily basis and this information can be obtained from the Company upon written request. The client agrees to check the full specification of the financial instrument before placing any order. Current swap rates are available to the Client at the Trading Terms Scheme available at the Company’s office.


  1. Order Refusal


2.1. The Company may, in its sole discretion, refuse to accept any order from the Client but will notify client of any such refusal, without obligation to give any reasons, promptly following receipt of client’s instructions therefor.

2.2. Once an instruction has been given by or on behalf of the client, it cannot be rescinded, withdrawn or amended without the Company’s express consent. Where there is a contradiction between multiple instructions given to the Company, the last instruction in time which was not executed shall prevail.


  1. Execution of Client Order


3.1. All orders executed by the Company should be displayed on the System. Any failure or delay in any executed order being displayed shall not affect the validity of the order. It shall be solely the client’s responsibility to inquire with the Company, and obtain confirmation, regarding the  execution of the order, and Client’s failure to make such inquiry shall not affect the validity of the executed order.


3.2. In cases where a Liquidity Provider rejects an order made on a represented price, subject to the order parameters, the Company may attempt to execute transactions on or close to the prevailing market prices. This may or may not adversely affect client’s realized and unrealized gains and losses.


3.3. The Company may, in its sole discretion, alter transactions, not transmit, or execute or terminate transactions if: (a) the transactions were executed by arbitrage/explosion of market failures, or off the market rates; (b) a technical problem withheld the transaction from being executed as desired; (c) a Liquidity Provider has canceled or altered the transaction with the Company; and/or (d) the transaction covering was failed or partially executed with the Liquidity Provider.


3.4. If, after a client is notified by the Company that the client’s transaction was rejected by a Liquidity Provider, it is revealed that the transaction was subsequently approved, the Company shall be entitled to:


(a) Notify the Client by-mail or through Company’s systems, on the Account, about the execution of that transaction and about its outcome (loss/profit and its amount).

(b) Charge a fee, retroactively, for that transaction, and/or

(c) Pass on to Client any losses and/or profits gained by that transaction.