BEST INTEREST AND ORDER EXECUTION POLICY

1. Introduction

1.1. This Best Interest and Order Execution Policy (“the Policy”) is provided to the reader (our existing Client or prospective Client) in accordance with the Provision of Investment Services, the Exercise of Investment Activities, the Operation of Regulated Markets and Other Related Matters Law 144(I)/2007, as subsequently amended from time to time (“the Law”). Pursuant to the Law, Deray Options (“the Company”) is required to take all reasonable steps to act in the best interest of its Clients when receiving and transmitting Client Orders and to achieve the best execution results when executing Client Orders. The Company must also comply, in particular, with the principles set out in the Law when providing investment services.

2. Scope

2.1. This Policy applies to both Retail and Institutional Clients (as defined in the Company’s Client Classification Policy). If the Company classifies a Client as an Eligible Counterparty, this Policy will therefore not apply to such an Eligible Counterparty.

2.2. This Policy is applicable when receiving and transmitting Client Orders or executing Client Orders for the Client for every type of Binary Options offered by the Company.

3. Best Execution Factors

3.1. The Company shall undertake all reasonable measures to obtain the best possible results for its Clients taking into consideration the following factors when executing Clients’ orders against the Company’s quoted prices:

(a) Price: The price for a certain type of Binary Option is calculated in reference to the price of the relevant underlying asset, which the Company obtains from third-party external reference sources. The prices can be found on the Company’s online trading Platform. The Company updates the prices as frequently as the limitations of technology and communications links allow. The Company will review its third party external reference sources from time to time to ensure the continual competitiveness of the data obtained. The Company will not quote any price outside the Company’s operations time, meaning that no orders can be placed by the Client during that time.

(b) Costs.

(c) Speed of Execution: The Company does not execute the Client Order in Binary Options as a principal to principal against the Client, i.e. the Company is not the Execution Venue (as defined in Commission Directive 2006/73/EC implementing MiFID) for the execution of the Client’s order. The Company transmits Client Orders or arranges for their execution with a third party(ies). However, the Company places a significant importance when executing Client’s orders and strives to offer high speed of execution within the realm of limitations of technology and communications links.

(d) Likelihood of Execution: When the Company transmits Orders for Execution or executes it with another party, it is possible that execution may sometimes be difficult. The likelihood of execution depends on the availability of prices of other market makers/financial institutions. It may not be possible to arrange an Order for execution in certain cases. In case the Company is unable to proceed with an Order due to an issue with the price or size or any other reason, the Order will not be executed. Furthermore, the Company is entitled, at any time and at its total discretion, without giving any notice or explanation to the Client, to decline or refuse to transmit or arrange for the execution of any Order or Request or Instruction of the Client in circumstances explained in the Client Agreement/General Terms and Conditions.

(e) Likelihood of settlement.

(f) Size of order.

(g) Market Impact: The price of the underlying assets from which the Company’s quoted price is derived could rapidly be affected and may also affect other factors listed herein. The Company will take all reasonable steps in order to obtain the best possible result for its Clients.

3.2. The Company does not consider the above list exhaustive and the order of the presentation of the above factors shall not be taken as priority factor. Nonetheless, the Company shall ascertain to accurately follow the Client’s specific instructions regarding an order, should the client provide the company with said specific instructions.

4. Best Execution Criteria

4.1. The relative importance of the above Best Execution Factors (of paragraph 3 above) will be determined by the Company through its use of its commercial judgment and experience in the light of the information available on the market and taking into account:
(a) The characteristics of the Client order.
(b) The characteristics of the Binary Options that are the subject of that order.
(c) The characteristics of the execution venue to which that order is directed.

4.2. For Retail Clients, the best possible result will be decided in terms of the total consideration, representing the price of the Binary Options and the total 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.

5. Client’s Specific Instruction

5.1. Whenever the Company receives a specific instruction from or on behalf of a Client (e.g. fills in the required parts on the Company’s trading platform when placing an Order), the Company shall endeavour to – to the fullest possible extent – carry out the execution of the Client order strictly according to the Client’s specific instruction. It is noted that the Company may be prevented from taking the steps in the Policy to obtain the best possible result for the Client, due to the specific instruction.

5.2. Trading rules for specific markets or market conditions may prevent the Company from following certain of the Client’s instructions.

6. Execution of Client Orders

6.1. The Company shall meet the following conditions when carrying out Client Orders:
(a) ensure that orders executed on behalf of Clients are instantly and accurately recorded and allocated;
(b) carry out otherwise comparable Client orders sequentially and instantly unless the characteristics of the order or prevailing market conditions make this impracticable;
(c) inform a retail Client about any material difficulty relevant to the proper carrying out of orders immediately upon becoming aware of the difficulty.

7. Execution Venues

7.1. Execution Venues are hereby defined as the entities with which the Orders are placed. For the purposes of Orders for the Binary Options, some third party Financial Institution(s) will be the Execution Venue and not the Company. A list of these financial institution(s) will be made known to Clients in a durable medium or may be publicised on the main website of the Company. The list may be changed at the Company’s discretion by giving at least one business day prior notice to the Clients.

7.2. The Client acknowledges that the transactions entered in Binary Options with the Company are not undertaken on a recognised exchange, rather they are undertaken over the counter (OTC) and as such they may expose the Client to greater risks than regulated exchange transactions.

8. Client’s Consent

8.1. By entering into an Agreement with the Company for the provision of Investment Services, the Client is consenting to an application of this Policy on him/her.

9. Amendment of the Policy and Additional Information

9.1. The Company reserves the right to review and/or amend its Policy and arrangements whenever it deems this appropriate without notice to the Client.

Should you require any further information and/or have any questions about conflicts of interest please direct your request and/or questions to info@derayoptions.com