Best Execution Policy

1. Purpose of Policy

This Best Execution Policy sets out information relating to how Millennium Global Treasury Services (MGTS or the Firm) seeks to provide best execution as required by the Markets in Financial Instruments Directive 2014/65/EU (“MiFID II”) and the Financial Conduct Authority’s Conduct of Business Sourcebook (“COBS”), when executing orders on behalf of clients.

'Best execution' is the term used to denote the duty we have to take all sufficient steps to obtain the best possible result given certain market conditions when executing transactions on clients’ behalf.

2. Scope of the Policy

This policy covers trading by MGTS in the following financial instruments:

  • FX Spot
  • FX Forwards
  • FX Swap
  • FX Non-Deliverable Forwards
  • FX Vanilla Option
  • FX Exotic Option

It is worth highlighting that the best execution requirements under MIFID II do not apply to FX spot transactions.

However, MGTS applies its Best Execution Policy to OTC FX spot trades as well as it makes all efforts to treat clients fairly and to manage any conflicts of interest that may arise in respect of such transactions.

3. Clients

As of the date of this policy, MGTS only provides its services to clients categorised as Professional Clients. Therefore, the information provided within this policy addresses the Firms obligations in respect to Professional clients only.

4. Order Handling

MGTS handles client orders on a first-in-first-out basis under each of the following scenario:

  • Trades executed on the MillTechFX Platform
  • Order submitted to MGTS under its outsourced execution services

When MGTS routes orders to Millennium Global Investments Limited (MGIL) for execution, in order to avoid conflicts of interests as MGIL is considered as a connected party to MGTS, orders are sent directly to MGIL’s execution team. MGIL’s execution team executes all orders based on the time stamp the order arrives at its Order Management System (OMS).

Where execution is undertaken electronically (both via platform or voice execution), in order to reduce potential for significant market impact and impact to counterparty banks, MGTS executes client orders in full size.

5. Execution Factors Summary

The Firm will endeavour to take all sufficient steps to obtain the best possible results for its clients taking into account the following Execution Factors:

  • The execution price and costs: MGTS considers that generally price merits a high importance, however, the nature of financial instrument will determine if MGTS shall give precedence of other factors such as speed or likelihood depending on the financial instruments characteristics. MGTS will always pay due regard to the costs related to any execution to ensure that the costs will not jeopardise the final execution outcome.

  • Speed: MGTS considers that for the foreign exchange market, speed is paramount taking into account of the fact that markets tend to move quickly, i.e. the price of the financial instrument may vary significantly.

  • Likelihood of execution and settlement: MGTS considers that for less liquid financial instruments, likelihood of execution may take precedence over price and speed. Whilst settlement risks are paramount when unwinding trades.

  • Size of order: MGTS considers that the size of the transaction and how it may impact the price of execution needs to be taken into account especially in case of large orders to minimise the market impact when executing orders or parts of an order.

  • Availability of price improvements: MGTS will take into consideration the opportunity to execute an order at a better price than what is quoted publicly.

  • Credit Risk and counterparty limits: MGTS will take into consideration the counterparty credit risk or any other counterparty limits (such as NOP) when routing client orders.

Relative importance of Execution Factors

In most circumstances, the Firm would typically expect that the price to be paid or received would be the most heavily weighted execution factor in respect to all OTC FX instruments. However, there will be occasions when other factors may be more important or relevant and the Firm may use its judgement and experience to give greater weight to other execution factors other than price based on the following types of criteria:

Voice Execution:

  • The Client’s regulatory categorisation and ‘type’ (i.e. ERISA)
  • Specific Client’s instructions
  • The liquidity providers to which that order can be directed
  • The market conditions which may dictate how the order is directed.

Electronic Execution:

  • Specific Client’s instructions
  • The liquidity providers to which that order can be directed
  • The market conditions which may dictate how the order is directed

6. Authorised counterparties banks (Liquidity Providers)

Authorised counterparty banks are the liquidity providers selected based on their ability to ensure that MGTS meets on a continuous basis the best possible results when applying the execution strategies specified above.

Following review and a due diligence process, MGTS has selected and entered into an agreement with Millennium Global Investments Limited (MGIL) to ensure that MGTS client orders are exclusively routed towards those authorised counterparties for execution and that only those counterparties are selected when MGTS execute orders on matched principal basis.

The list of authorised liquidity providers include: Australia and New Zealand Banking Group Limited, BNP Paribas, Citibank N.A., HSBC Bank Plc, Merrill Lynch International (Bank of America), Morgan Stanley & Co. International Limited, NatWest Market, Jefferies Financial Services, Inc. , Standard Chartered Bank, State Street Bank and Trust Company, UBS AG, Investec Bank Plc.

7. Client Specific Instructions

If a client provides MGTS with specific instructions relating to a transaction, MGTS will follow that instruction so far as is reasonably possible when executing the trade. By following client’s specific instructions, MGTS has satisfied the obligation to provide client with best execution in relation to that transaction or in relation to the part or aspect of the order to which your instructions relate.

8. Liquidity Providers Review and On-Going Monitoring

MGTS has set out the arrangement that currently Best Execution will be reviewed at the firm’s monthly risk committee meeting, comprising of Head of Risk and other senior members of the firm. The monthly risk committee meeting reviews the authorised third party providers and list of counterparty banks on a quarterly basis to ensure that it is still up to date and will enable MGTS to obtain the best possible results for its clients on a consistent basis.

9. Record Keeping

MGTS records and retains all data relating to its order execution policy including the venue selection process. Records are retained for five years in a durable medium and will be made available to the competent authorities upon request. All communications which relate to reception, transmission and execution of orders, and/or which will or may result in orders will be recorded and maintained for a period of 5 years or any other periods specified by the relevant regulator or government authority.

10. Data Usage

MGTS may need to use data reporting service providers and, in this regard, will transmit data relating to transactions to third parties. Clients are informed within the investment services agreements that client data relating to order execution provided to MGTS may be sent to the competent authorities, its affiliated entities and, where relevant, to service providers or subcontractors of the Institution or of its affiliated entities, which may not be located in the UK, in accordance with the General Data Protection Regulation.

11. Complaints

Any complaint concerning this execution policy may be addressed to:

Email: Compliance@milltechfx.com