Best Execution Policy

1. Introduction

ZenGuard Markets Ltd ("we", "us", "our") is committed to acting in the best interests of our clients when executing orders on their behalf. This Best Execution Policy sets out the arrangements we have established to obtain the best possible result when executing client orders in respect of financial instruments, in accordance with our regulatory obligations under the Markets in Financial Instruments Directive II (MiFID II) and the rules of the Financial Conduct Authority (FCA).

This policy applies to all execution services we provide to retail and professional clients. We take our best execution obligations seriously and have implemented robust systems and controls to ensure that we consistently deliver on our commitment to obtain the best possible outcome for our clients.

2. Regulatory Framework

Our best execution obligations derive primarily from MiFID II (as implemented in the UK through the Financial Services and Markets Act 2000 and the FCA Handbook) and the Commission Delegated Regulation (EU) 2017/576. These requirements oblige us to take all sufficient steps to obtain the best possible result when executing client orders, taking into account the execution factors of price, costs, speed, likelihood of execution and settlement, size, nature, and any other consideration relevant to the execution of the order.

For retail clients, we are required to obtain the best possible result in terms of the total consideration, representing the price of the financial instrument and the costs related to execution. Where we determine that there are a number of venues that could deliver the best possible result, we take into account the likelihood of execution and settlement when ranking those venues. We review our execution arrangements and policy at least annually and whenever a material change occurs that could affect our ability to obtain the best possible result.

3. Scope

This policy applies to all orders in financial instruments executed by ZenGuard Markets Ltd on behalf of clients, including but not limited to foreign exchange (forex), contracts for difference (CFDs), spread bets, and other over-the-counter (OTC) derivative products. The policy covers both execution-only services and execution as part of advisory or portfolio management services.

This policy does not apply where a client gives us a specific instruction in relation to an order. In such cases, we will execute the order in accordance with the client's specific instruction, which may prevent us from following the steps set out in this policy to obtain the best possible result. We will inform clients of this consequence before they provide a specific instruction.

4. Execution Factors

When executing client orders, we consider the following factors, which we rank in order of importance for retail clients: Price. For retail clients, the price of the financial instrument is the predominant factor in achieving the best possible result. We obtain prices from multiple liquidity providers and route orders to the venue offering the most favourable price at the time of execution, subject to other execution factors.

Costs. We consider all costs related to execution, including spreads, commissions, and any other charges that may apply. Our pricing structure is designed to be transparent, and we disclose all material costs to clients before they place orders.

Speed. We strive to execute orders as quickly as possible, recognising that delays can result in price movement adverse to the client. Our trading infrastructure is optimised for low-latency execution.

Likelihood of Execution and Settlement. We consider the probability that an order will be executed and settled when selecting execution venues. We prioritise venues with high fill rates and reliable settlement.

Size. For larger orders, we consider the ability of a venue to execute the full order size without undue market impact. We may split large orders across multiple venues where this would achieve a better overall result.

Nature. We take into account the nature of the order, including whether it is a market order or a limit order, and any specific characteristics that may affect the best execution outcome.

5. Execution Venues

ZenGuard Markets Ltd executes client orders through a combination of execution venues, including regulated markets, multilateral trading facilities (MTFs), organised trading facilities (OTFs), and systematic internalisers. We also execute against our own book where we act as principal, and we have arrangements with multiple liquidity providers including major banks and institutional market makers.

We maintain a list of execution venues and liquidity providers that we use for each class of financial instrument. This list is reviewed regularly to ensure that we continue to use venues that enable us to obtain the best possible result for our clients. We assess execution quality through ongoing monitoring of fill rates, execution speeds, and price improvement.

6. Specific Instructions

Where a client provides a specific instruction in relation to an order, we will execute the order in accordance with that instruction. A specific instruction may relate to the execution venue, the timing of execution, or other aspects of how the order should be executed. When a client gives a specific instruction, we are not required to take the steps set out in this policy to obtain the best possible result in respect of the elements covered by the instruction.

We will inform clients before they provide a specific instruction that doing so may prevent us from obtaining the best possible result for them. Clients should consider carefully whether a specific instruction is appropriate for their circumstances.

7. Monitoring and Review

We monitor the effectiveness of our order execution arrangements on an ongoing basis. This includes analysing execution quality by instrument type, venue, and client segment. We assess whether we are obtaining the best possible result for our clients and whether our execution policy remains appropriate.

We conduct a formal review of this policy and our execution arrangements at least annually. The review considers whether the execution venues we use continue to provide the best possible result, whether we need to add or remove venues, and whether any changes to our business or the market require updates to our policy. Material changes to this policy will be communicated to clients in advance.

8. Order Handling

We have established procedures for the fair and expeditious handling of client orders. Orders are processed in accordance with our order management systems and are executed in a manner that is consistent with this policy. We do not engage in practices that could disadvantage clients, such as front-running or trading ahead of client orders.

We maintain appropriate segregation between our proprietary trading activities and client order execution to prevent conflicts of interest. Staff involved in execution are trained on our best execution obligations and the importance of acting in clients' best interests.

9. Reporting

In accordance with regulatory requirements, we publish annual reports on the quality of execution obtained for our clients. These reports include information on the execution venues we use, the percentage of orders executed at each venue, and analysis of execution quality. The reports are available on our website and can be requested from our compliance team.

We also provide clients with information on the execution venues used for their orders upon request. Clients who wish to receive more detailed information about their execution quality should contact our client services team.

10. Client Consent

By opening an account with ZenGuard Markets Ltd and placing orders through our platform, you acknowledge that you have read, understood, and accepted this Best Execution Policy. You consent to our executing your orders in accordance with the arrangements described in this policy.

We recommend that you retain a copy of this policy for your records. If you have any questions about how we execute your orders or about this policy, please contact us before placing orders.

11. Policy Updates

We may update this Best Execution Policy from time to time to reflect changes in our execution arrangements, regulatory requirements, or market conditions. When we make material changes, we will notify you by posting the updated policy on our website and, where appropriate, by email or through a notice on our trading platform.

Your continued use of our services after any updates constitutes your acceptance of the revised policy. We encourage you to review this policy periodically to stay informed about how we execute your orders.

12. Contact

If you have any questions about this Best Execution Policy or our order execution practices, please contact us:

ZenGuard Markets Ltd Compliance Department Email: compliance@zenguardmarkets.com Address: 1 Canada Square, Canary Wharf, London E14 5AB, United Kingdom

For general client inquiries, you may also contact our client support team at support@zenguardmarkets.com.