Order Execution Policy

Genie has established this Order Execution Policy, together with other arrangements, to ensure that all reasonable steps are taken to achieve the best possible result for clients. The Company is committed to providing clear and accessible information regarding this policy, and a copy may be provided upon written request. This policy forms an integral part of the Client Agreement, and by accepting that agreement, clients confirm their understanding and acceptance of the Order Execution Policy. When executing trades, Genie directly places orders in the market on behalf of clients to ensure that trading decisions are carried out promptly and accurately. The price feed made available to clients is sourced from a combination of bank and non-bank liquidity providers, or through Genie’s proprietary ECN model, with the aim of supporting best execution during Straight Line Processing with Genie’s liquidity providers.

Genie LTD offers leveraged margin trading in Forex and CFD instruments on an execution-only basis. Clients access markets offered solely by Genie LTD, with each market representing a derivative of the relevant underlying instrument, and Genie acts as principal, counterparty, and execution venue while providing two-way price quotes. Under Genie’s proprietary ECN model, certain qualified liquidity providers participate in pricing competition within the interbank pool and hold collateral directly with Genie under safeguarding procedures. Genie recognizes that clients rely on the Company to provide bid and offer prices that consistently reflect the best available market pricing. Although every reasonable effort is made, displayed prices may not always match prevailing market rates because of volatility, spreads, or additional transaction-related costs. Where orders are placed with third-party entities for execution, Genie continues to act in the best interests of clients and takes all reasonable steps to achieve the best possible outcome.

Execution factors include price, costs, speed, likelihood of execution and settlement, order size, order nature, and any other relevant considerations. The importance of these factors is determined by reference to the characteristics of the client, the client’s order, the financial instrument involved, the available execution venues, and the overall total consideration. The best possible result is assessed on the basis of total consideration, including the instrument’s price and all direct execution costs, such as execution venue fees, clearing charges, settlement fees, and any relevant third-party costs. Key execution factors include Genie’s market-pricing algorithm applied to underlying market feeds, the transparent application of commissions or financing charges, liquidity limits that may affect spreads at certain sizes, and execution speed supported by market-specific deal size limits.

While Genie aims to provide competitive pricing, market volatility, spreads, and transaction-related charges may occasionally prevent quotes from reflecting the absolute best market price at all times. Certain markets may also be quoted outside normal trading hours, including grey markets, where price consistency may vary during periods of heightened volatility or reduced liquidity. Financing charges applied by Genie are intended to be competitive, fair, and transparent and are disclosed on the website and trading platform. Any commission sharing or other income arising through third-party or affiliated arrangements will be disclosed clearly to clients upon request.

Genie LTD continuously monitors the efficiency of its order execution framework and this Order Execution Policy to identify and rectify any deficiencies or areas requiring improvement. The Company reviews its order execution procedures at least annually, or whenever a significant change occurs that may affect its ability to consistently deliver the best possible outcome. By placing an order with Genie LTD, clients are deemed to provide prior consent to this policy and acknowledge the basis on which their orders are executed. Genie LTD acts as the execution venue for client orders and provides prices derived from leading global banks, non-bank liquidity providers in wholesale foreign exchange markets, and ECN-qualified participants within Genie’s execution infrastructure. Genie provides execution-only services for Forex and CFD instruments, and clients make all trading decisions independently.

Genie determines which markets are made available to clients, and each market is a derivative of the underlying instrument. Genie is the exclusive execution venue through which clients access those prices, and no advisory services or equity share trading are offered as part of the CFD portfolio. The Company regularly monitors the effectiveness of this policy, evaluates the quality of executed orders, and seeks to ensure the best possible results for clients. Any deficiencies identified are addressed promptly, and clients are informed of any material updates to the policy or associated arrangements.