Best Interest & Order Execution Policy
1. Introduction
This Best Interest & Order Execution Policy (the "Policy") sets out the arrangements adopted by LEVELS Ltd. (the "Company") for the execution of client orders and transactions.
The purpose of this Policy is to provide Clients with a general understanding of the execution factors, procedures, and practices applied by the Company when providing trading services.
This Policy forms an integral part of the Client Agreement and should be read together with all other Company policies and disclosures.
2. Scope
This Policy applies to all financial instruments, products, services, trading platforms, accounts, and transactions offered by the Company.
By entering into transactions with the Company, the Client acknowledges and accepts the principles set out in this Policy.
3. General Execution Principles
When executing orders, the Company shall take reasonable steps to obtain the best available result under the prevailing circumstances.
The Company shall consider a variety of execution factors, including:
- price;
- costs;
- speed of execution;
- likelihood of execution;
- likelihood of settlement;
- available liquidity;
- order size;
- market conditions;
- nature of the order;
- risk management considerations;
- any other factor reasonably relevant to execution.
No single factor shall necessarily be decisive in every circumstance.
4. Execution Venues
The Company may execute orders:
- internally;
- through liquidity providers;
- through market makers;
- through external counterparties;
- through electronic execution systems;
- through any other execution arrangements selected by the Company.
The Company reserves the right to change, add, remove, or modify execution venues and liquidity arrangements without prior notice.
5. Client Acknowledgements
The Client acknowledges and accepts that:
- a) execution prices may differ from prices displayed at the time an order is submitted;
- b) execution may be affected by market volatility, liquidity, order size, market conditions, communication delays, and technical factors;
- c) execution may not always occur at the requested price;
- d) orders may be rejected, delayed, partially executed, requoted, or executed at different prices depending on prevailing conditions;
- e) the Company does not guarantee uninterrupted availability of any execution venue, liquidity source, quote, spread, or market.
6. Order Types
The Company may make available various order types, including but not limited to:
- Market Orders;
- Limit Orders;
- Stop Orders;
- Stop Loss Orders;
- Take Profit Orders;
- Trailing Stop Orders;
- Pending Orders;
- Any other order type supported by the Company's trading platform.
The availability of specific order types may vary depending on the financial instrument, trading platform, market conditions, or operational requirements.
The Company reserves the right to modify, suspend, restrict, or discontinue any order type at any time.
7. Slippage
The Client acknowledges that orders may be executed at prices different from the prices requested or displayed at the time of order submission.
Slippage may be:
- Positive;
- Negative;
- Neutral.
Slippage may occur as a result of:
- market volatility;
- liquidity conditions;
- rapid price movements;
- market gaps;
- order size;
- communication delays;
- execution venue conditions;
- trading volume.
Slippage is a normal characteristic of financial markets and does not, by itself, constitute an execution error.
8. Market Gaps and Volatility
Market prices may move rapidly between successive quotations.
During periods of increased volatility, reduced liquidity, economic announcements, market openings, market closings, weekends, holidays, or extraordinary events, prices may gap or move significantly without trading at intermediate price levels.
Under such circumstances:
- Orders may be executed at the next available market price;
- Stop Loss Orders are not guaranteed unless expressly stated otherwise by the Company;
- Execution prices may differ substantially from requested prices.
9. Abnormal Market Conditions
The Company may determine that abnormal market conditions exist where circumstances materially affect the orderly operation of financial markets, liquidity conditions, pricing availability, execution quality, or risk management processes.
Examples may include:
- extreme volatility;
- market disruptions;
- trading halts;
- liquidity shortages;
- exchange suspensions;
- force majeure events;
- geopolitical events;
- technology failures;
- pricing disruptions.
Under such circumstances, the Company may take any reasonable action necessary to protect clients, counterparties, liquidity providers, and the integrity of its trading environment.
10. Large Orders and Liquidity Considerations
Execution quality may vary depending upon the size, frequency, concentration, and nature of trading activity.
The Client acknowledges that the execution conditions available for individual transactions may differ from those that would be available for larger aggregate exposures, concentrated trading activity, institutional-sized transactions, or unusual market conditions.
The Company may consider:
- available liquidity;
- market depth;
- concentration of positions;
- aggregate exposure;
- execution risk;
- market impact;
when assessing execution quality, risk management requirements, or trading conditions.
The Company does not guarantee that execution available for one transaction would necessarily be available for a larger volume of transactions or aggregated trading activity.
11. Rejection, Delay or Cancellation of Orders
The Company reserves the right to reject, delay, suspend, cancel, or decline any order where reasonably necessary, including where:
- insufficient margin exists;
- market conditions prevent execution;
- technical issues occur;
- pricing irregularities are detected;
- compliance concerns arise;
- risk management concerns arise;
- suspicious activity is identified;
- execution may expose the Company to unreasonable operational, financial, or regulatory risk.
The Company shall not be liable for losses arising from such actions where taken reasonably and in good faith.
12. Manifest Errors
The Company reserves the right to review, amend, cancel, void, adjust, or correct transactions, prices, executions, profits, losses, balances, credits, or account entries resulting from Manifest Errors.
Manifest Errors may include, without limitation:
- obvious pricing errors;
- system malfunctions;
- technical failures;
- data feed errors;
- communication failures;
- software defects;
- operational mistakes;
- abnormal pricing conditions.
The Company shall determine, acting reasonably and in good faith, whether a Manifest Error has occurred.
13. Execution Monitoring and Review
The Company regularly monitors execution arrangements, trading activity, liquidity conditions, operational performance, and execution quality.
The Company may review transactions where it reasonably considers that:
- execution irregularities may have occurred;
- pricing anomalies may exist;
- technical issues may have affected execution;
- unusual trading activity is identified;
- activity requires further compliance, operational, or risk assessment.
Such reviews may be conducted before, during, or after execution and may involve internal or external specialists.
14. Amendments to This Policy
The Company reserves the right to amend, supplement, replace, or update this Policy from time to time.
Any amendment may become effective upon publication on the Company's Website, Platform, Client Portal, or upon notification to Clients.
Continued use of the Company's services following such publication or notification shall constitute acceptance of the revised Policy.
15. Reservation of Rights
Nothing in this Policy shall limit any rights available to the Company under:
- the Client Agreement;
- the Abuse & Market Manipulation Policy;
- other Company Policies;
- applicable laws;
- regulatory obligations.
The rights and remedies available to the Company are cumulative and may be exercised independently or together.
16. Effective Date
This Policy shall become effective on the date determined and published by the Company and shall remain in force until amended, replaced, or withdrawn.
