Order Execution Policy

1. INTRODUCTION & SCOPE

Under the rules of the Financial Conduct Authority (“FCA”) and the requirements of the Markets in Financial Instruments Directive 2014/65/EU (“MiFID II”), JVA Brokers Limited (“JVA”) is required to take all sufficient steps to obtain the best possible result for Professional Clients taking into account various factors and criteria, “Best Execution”. This document provides JVA’s Professional Clients with appropriate information on its order execution policy for LME contracts. This policy applies to the receipt, transmission and execution of client orders where:

  • The order is for a “Financial Instrument” as defined under the Markets in Financial Instruments Directive 2004/39/EC (“MiFID”).

The order is from a client which has been categorised in writing by JVA as a “Professional Client”. Best Execution obligations do not apply to transactions effected for or with “Eligible Counterparties”

2. WHEN IS BEST EXECUTION OWED

2.1. Determining legitimate reliance

In determining legitimate reliance, JVA will consider all circumstances surrounding the transaction including the following factors:

  • Which party initiates the transaction?

Where JVA approaches a client about a transaction, this may be a consideration in determining whether the client is more likely to be placing reliance on JVA

  • Questions of market practice

JVA clients trade LME contracts so they can go to other brokers then it is less likely that they will be placing reliance on JVA:

  • The relative levels of price transparency within the LME

JVA’s clients have access to LME data so it is less likely that they will be placing reliance on JVA;

  • The information provided by JVA and any agreement reached

JVA is providing execution-only services so there is clearly a reliance

2.2. General exceptions from Best Execution requirements

The following exceptions apply to Best Execution:

  • Where a specific instruction is given by you relating to the execution of all or part of an order, or a specific aspect of an order. See section 3.3 below;
  • Where a systems or other failure or problem means that to execute an order, JVA may decide to use an alternative method to usual method;

2.3. Specific instructions

Where a client provides JVA with a specific instruction in relation to its order, or any particular aspect of its order, JVA will execute the order in accordance with those instructions which means JVA will be deemed to have taken all reasonable steps to provide the best possible result for the client. In the absence of any specific instructions from a client, JVA will consider these factors:

  • The liquidity of the market, market conditions and impact
  • The need for timely execution;
  • The size and nature of the order;
  • Historical trading data;
  • The likelihood of execution

3 COSTS, CHARGES AND THIRD-PARTY PAYMENTS

Should JVA obtain any price improvement in the execution of a transaction subject to this policy, this will be offered to the client.

4 MONITORING AND REVIEW

JVA will monitor the effectiveness of this policy and its implementation to identify and correct any deficiencies in its execution arrangements.

5 CONSENT

The Policy is on JVA’s website

6 ANNUAL SUMMARY

RTS 28 requires JVA to set out the top five trading venues used to execute client orders. All JVA client orders are executed on the LME. JVA’s brokers have the appropriate knowledge and competency to enable them to prioritise the execution factors set out section 2 above. JVA’s client relationships are long standing which means its brokers have extensive knowledge of client trading. Execution does not differ based upon client classification. JVA does not take any remuneration, discount or non-monetary benefit from routing client orders to the LME and has no close links ,conflicts of interest and common ownership with the LME. All JVA client orders are passive.