This is a working template prepared for review by qualified counsel in the United States, India, the United Kingdom and the European Union. It is not yet in force and creates no rights or obligations until a final version is published.
- This policy will apply once AlgoNexus is authorised in the UK or EU to transmit client orders. Until then, live execution is disabled.
- For retail clients, best execution means the best total result: price plus all costs of executing.
- Your broker executes your orders. We monitor the results and act when quality falls short.
The summary helps you navigate; the sections below are the document.
1Scope
This policy sets out how [UK entity] and [EU entity] will meet their obligations under FCA COBS 11.2A and Article 24(1) and Article 27 of MiFID II (Directive 2014/65/EU) when receiving and transmitting orders for retail clients in shares and ETFs. It applies only once the relevant authorisation is held.
2Execution factors
We take all sufficient steps to obtain the best possible result, considering price, costs, speed, likelihood of execution and settlement, size, nature and any other relevant consideration. For retail clients, the best result is determined by total consideration: the price of the instrument and all costs related to execution, including broker commission, venue and clearing fees, taxes such as UK SDRT or EU financial-transaction taxes, and FX costs.
3Entities we transmit to
Orders are transmitted to the broker you select and connect. Before supporting a broker for live orders in the UK or EU, we assess its order-execution policy, venues, cost schedule and historical execution quality. The current list is on our brokers page. Where you choose the broker, your choice is a specific instruction; we still apply the order-handling protections in our Order Execution policy.
4Specific instructions
If you give a specific instruction — for example a limit price or extended-hours trading — we follow it, which may prevent us from taking the steps in this policy for the elements covered by that instruction.
5Monitoring and review
- We measure every fill against the arrival price and the prevailing best bid and offer, and track slippage, fill rates, rejection rates and latency per broker and venue.
- Material deterioration triggers review and may lead us to warn users, change default order types, or stop supporting a broker for live orders.
- The policy and arrangements are reviewed at least annually and whenever a material change occurs. A summary of our monitoring will be published annually.
6Your consent
We will ask for your consent to this policy before your first live order. You can ask us to demonstrate that your orders were handled in line with it.