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Order Execution Policy

1. Introduction

This Order Execution Policy (the “Policy”) sets forth the principles, procedures, and factors that Bancara adheres to when executing client orders for Contracts for Difference (CFDs) and other leveraged derivative products. Bancara operates exclusively on an execution-only basis, acting as the sole execution venue and counterparty to its clients, as explicitly stated in the Bancara Terms and Conditions. The fundamental objective of this Policy is to provide comprehensive transparency regarding Bancara’s execution practices, ensuring that client orders are processed and executed fairly, efficiently, and in strict compliance with Bancara’s Terms and Conditions and all Applicable Law.

2. Definitions

For the purposes of this Policy, the following terms shall have the meanings ascribed to them below:

  • Account: The trading account opened by the Client with Bancara, through which the Client may execute Orders and manage their funds, as defined in the Terms and Conditions.
  • Applicable Law: All relevant laws, statutes, regulations, directives, rules, and guidance issued by governmental, regulatory, or self-regulatory authorities in any jurisdiction pertinent to Bancara’s operations or the client’s contractual relationship.
  • Bancara: Refers to the specific Bancara entity or entities as defined in the Bancara Terms and Conditions.
  • Best Execution: While Bancara operates as the sole execution venue and counterparty, the concept of Best Execution within this context refers to Bancara’s commitment to take all reasonable steps to obtain the best possible result for its clients when executing orders, taking into account the execution factors outlined in Section 4 of this Policy.
  • CFD: A Contract for Difference, a derivative product allowing the Client to trade on the price movement of an underlying asset without owning the asset itself, as defined in the Terms and Conditions.
  • Client: The individual or legal entity that has entered into a contractual relationship with Bancara, as defined in the Bancara Terms and Conditions.
  • Execution Venue: The entity where orders are executed. For all client orders, Bancara acts as the sole Execution Venue.
  • Limit Order: An instruction to buy or sell a financial instrument at a specified price or better.
  • Market Data: Real-time or near real-time price feeds, liquidity information, and other relevant market-related data utilized by Bancara to determine executable prices.
  • Market Order: An instruction to buy or sell a financial instrument immediately at the best available current market price.
  • Order: An instruction from the Client to execute a trade, including Market Orders, Limit Orders, Stop Orders, and other order types supported by the Platform, as defined in the Terms and Conditions.
  • Platform: The trading software, web interface, and mobile applications provided by Bancara for the execution of Orders and management of the Account, as defined in the Terms and Conditions.
  • Slippage: The difference between the expected price of an Order and the actual price at which the Order is executed. Slippage can be positive (executed at a better price) or negative (executed at a worse price) and typically occurs during periods of high market volatility or low liquidity.
  • Stop Order: An instruction to buy or sell a financial instrument once its price reaches a specified stop price. Once the stop price is reached, the Stop Order becomes a Market Order and is executed at the best available current market price.
  • Terms and Conditions (T&Cs): The Bancara Terms and Conditions, as amended from time to time, which govern the contractual relationship between Bancara and its clients.

3. Execution-Only Service and Counterparty Status

3.1  Bancara operates strictly on an execution-only basis. Bancara does not provide investment advice, personal recommendations, or financial guidance regarding the merits of any transaction.

3.2  Furthermore, Bancara acts as the sole execution venue and principal counterparty to its clients for all orders. Bancara does not transmit client Orders to external execution venues, exchanges, or multilateral trading facilities.

3.3  Clients are solely responsible for their own investment decisions, for understanding the risks associated with trading CFDs and leveraged products, and for ensuring that any transaction they undertake is suitable for their individual financial situation, investment objectives, and risk tolerance.

4. Factors Affecting Order Execution

When executing client Orders, Bancara takes into account a range of execution factors to achieve Best Execution for its clients. These factors are considered in conjunction with Bancara acting as the sole Execution Venue and counterparty. The relative importance of these factors may vary depending on the specific financial instrument, market conditions, and the nature of the client’s Order.

  1. Price: The prevailing bid and ask prices displayed on the Bancara Platform at the time of execution.
  2. Cost: Applicable commissions, financing charges (swaps), and spreads.
  3. Speed and Likelihood of Execution: The promptness with which an Order can be executed and the probability of its execution. In fast-moving markets, rapid execution may be prioritized over achieving a specific price to ensure the Order is filled.
  4. Size of Order: The volume or notional value of the Order. Larger orders may have a greater impact on available liquidity and may be subject to different execution dynamics.
  5. Market Conditions: The prevailing conditions in the underlying markets, including:
    • Volatility: Periods of high price fluctuation can lead to rapid price changes and increased Slippage.
    • Liquidity: The ease with which a financial instrument can be bought or sold without significantly affecting its price. Low liquidity can result in wider spreads and greater Slippage.
    • Market Gaps: Sudden price movements that occur when the market opens or after periods of low trading activity, leading to Orders being executed at prices significantly different from the last traded price.
    • News Events: Major economic announcements or geopolitical events can cause sudden and significant market movements.

4. Client Order Handling Procedures and Operational Realities

4.1  Market Orders: Market Orders are designed for immediate execution. They will be executed at the best available price on the Bancara Platform at the time the Order is received and processed. Due to the inherent volatility of financial markets, the actual execution price may differ from the price displayed at the exact moment the Order was placed (i.e. Slippage).

4.2  Limit Orders: Limit Orders are executed at the specified price or a more favorable price. Limit Orders are not guaranteed to be filled if the market price does not reach the specified limit price.

4.3  Stop Orders: Stop Orders are triggered when the market price reaches the specified stop price. Once triggered, a Stop Order automatically converts into a Market Order and will be executed at the best available price on the Bancara Platform. Clients acknowledge that due to market gaps or rapid price movements, the execution price of a Stop Order may be significantly different from the specified stop price (i.e. Slippage).

4.4  Re-quotes: In rapidly moving markets, if the requested price is no longer available, Bancara may offer a re-quote. The client will have the option to accept or reject the re-quoted price.

4.5  Order Amendments and Cancellations: Clients can amend or cancel pending Orders through the Bancara Platform, provided the Order has not yet been executed. Bancara cannot guarantee the amendment or cancellation of an Order, especially in fast-moving markets.

5. Compliance, AML, and Sanctions Controls

5.1  Bancara’s obligation to execute client orders is strictly subordinate to its regulatory compliance obligations. Bancara reserves the absolute right to reject any Order, cancel any executed trade, or suspend execution services entirely, without prior notice and without liability for “failure to execute” or “loss of opportunity,” if Bancara reasonably determines that such action is necessary to comply with Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), or sanctions laws, or instructions from banking and payment partners.

6. Technical Considerations and Platform Operation

6.1  Platform Availability and Reliability: Bancara employs robust systems and infrastructure to ensure the continuous availability, reliability, and security of its Platform. However, Bancara does not guarantee uninterrupted access to the Platform. Technical issues, system failures, maintenance, or external factors beyond Bancara’s reasonable control may occasionally disrupt service. Bancara will take all reasonable steps to restore service as quickly as possible.

6.2  Internet Connectivity and Client Equipment: Clients acknowledge that their ability to place and manage Orders is dependent on their internet connectivity, hardware, and software. Bancara is not responsible for any losses, delays, or failures arising from issues related to the client’s internet connection, equipment, or third-party service providers.

6.3  Latency: Network latency (the delay in data transmission) between the client’s device and Bancara’s servers can impact the speed at which Orders are received and executed. Clients acknowledge that such latency is an inherent aspect of online trading.

7. Conflicts of Interest

7.1  Bancara has implemented comprehensive measures to identify, prevent, and manage potential conflicts of interest that may arise in the course of its business operations. As Bancara acts as the counterparty to client trades, a potential conflict of interest inherently exists.

7.2  Bancara manages this potential conflict through:

  • Operating a robust risk management framework.
  • Ensuring fair and transparent execution practices as outlined in this Policy.
  • Maintaining strict internal controls and segregation of duties.
  • Adhering to its regulatory obligations and internal compliance policies.

8. Policy Review and Updates

8.1  This Order Execution Policy will be subject to regular and systematic review by Bancara’s Legal and Compliance departments, at least annually, or more frequently as necessitated by changes in Applicable Law, regulatory guidance, internal policies, or market practices. Any amendments to this Policy will be communicated to Clients via Bancara’s website or other appropriate channels.

Version: 2.0

Effective Date: June 30, 2026