Best Execution Policy

CXM (hereinafter as “CXM” or “the Firm”) provides mainly automated execution-only services to retail and professional clients (“clients”) for the following instruments: Forex, Metals, Energy, Indices, Shares and Crypto.

CXM clients place significant trust in the firm to provide the best execution. CXM executes clients’ orders at the best prices available from our credited liquidity providers. The system is designed to automatically select the best available price and display it to clients on our online platform. CXM considers ‘price,’ ‘cost,’ and ‘speed’ to be critical factors in execution.

Trading platform

CXM clients can trade using the following trading platforms (“platforms”):

• MetaTrader 4 PC
• MetaTrader 4 Mobile
• MetaTrader Web
• MetaTrader 5 PC
• MetaTrader 5 Mobile
• CXM Trader

Trading is subject to trading hours’ restrictions and is provided per instrument on the platform.

Execution Venues

The firm also operates as an agent, where client transactions are received and transmitted to other reputable liquidity providers.

Price

CXM provides two-way pricing quoted live across all its products to clients, which can be accessed on CXM’s platform. CXM aims to provide clients with fast, reliable, and uninterrupted prices. To avoid over-reliance on any single provider, CXM receives raw price data for all trading instruments from its Liquidity Providers (“LPs”) and Data Providers such as banks, multilateral trading facilities (MTFs), and executing brokers, etc. Each LP is carefully onboarded, and due diligence is performed by the Risk and Compliance departments to ensure that the LP can offer the best and most reliable available prices to CXM’s clients. LPs and all data sources are reviewed on an ongoing basis by the Risk department. The raw pricing data is fed into CXM’s pricing engines, which deliver a smooth and consistent flow of quotes to the client, in accordance with the target and average spreads disclosed on CXM’s website.

Cost

Spreads and commissions are critical aspects of the expenses that CXM’s clients may incur, and the firm always aims to ensure that these costs are competitively reasonable compared to other operators in the Forex and CFD markets (e.g., spreads are continuously monitored by CXM’s Risk department). The costs clients incur when executing an order with CXM will be related to the spread and commissions. Spreads are dynamic and depend on several factors, including market liquidity and volatility. Clients are encouraged to fully understand the associated costs before transacting with CXM.

Speed, size and likelihood of execution

CXM’s clients benefit from immediate execution capability, meaning that if a client sees a price on the screen, in most cases, the trade is executed at the displayed price. CXM’s liquidity providers (LPs) are ready to absorb trade requests up to the maximum trade size set for each trading instrument. The maximum trade size is available in the contract specifications of each instrument on each trading platform. CXM determines the maximum trade size available to clients for each instrument. Regardless of the type of order, CXM executes any order at VWAP (Volume-Weighted Average Price) if the size of the order exceeds the tradable size at the time of execution. Depending on the tradable size, clients may experience execution at a less favorable price. However, CXM always considers ‘slippage’ and passes on positive slippage to clients if the market moves in their favor.

Best execution monitoring

CXM is continuously monitoring its ‘prices’ compare to the market through internal monitoring measures and third-party vendor solutions. Prices are monitored around execution time within set thresholds against market price and the underlying instrument. Where the underlying instruments are traded over the counter (OTC), such as Forex and Metals, the critical factor is the spread. CXM monitors the spread to ensure it sources the most competitive price available. The following parameters are taken into consideration for low, normal and high volatility trading periods: latency of price feed, the frequency of price updates, and complete representation of top of the book of orders.

No order aggregation

CXM’s general practice is not to aggregate any client orders with other client orders or any transactions for its account.

Client protection

Despite ensuring that CXM’s clients receive the best execution, CXM has implemented further measures to ensure that its clients are always protected. CXM also provides that its systems automatically offer default protections to its clients.

Stop Loss Orders

Clients have the option to trade “stop loss” and “trailing stop loss” orders. This allows clients to autonomously set the level at which they will sell out to limit losses. If the instrument price reaches this level, the position will be closed automatically. Such orders are always connected to an open position or a pending order.

Negative Balance Protection

CXM offers all retail clients negative balance protection. This means that clients will never lose more than their invested capital. For further information, kindly review CXM’s Negative Balance Protection Policy.

Abusive Behavior

However, if CXM suspects or has reason to believe that a client (or clients) abused or attempted to abuse the terms of the Firm’s policies by acting in bad faith, the Company reserves the right, at its sole discretion, to deny, withhold, withdraw or terminate the Negative Balance Protection and, if necessary:

• To withhold, cancel and charge any costs it deems, from that client’s account(s),
• To terminate that client’s access to services provided by the Company and/or terminate the contract between the Company and the client for the provision of services,
• To block that client’s Account(s) and to arrange for the transfer of any unused balance, less the offer amount, as well as any profits which the Company deems to have been gained via Abusive Behavior, to the client.

Example: Acting in bad faith can be described as the intentional execution of orders with the purpose to profit by exploiting the firm’s terms of execution or through software limitations. Executing large positions before a session break with the intent of profiting asymmetrically at market open is considered acting in bad faith.

Toxic Trading

CXM continuously monitors its executions to protect its liquidity providers from “toxic flow”, which can be described as the intentional manipulation of orders by a client with the purpose to profit not from the market opportunities, but from the liquidity providers’ execution procedures or by exploiting software technical limitations. In cases where CXM becomes aware of toxic trading patterns, the Firm reserves the right to alter the execution settings for detected accounts which can significantly affect the execution time and price at its sole discretion without any prior notice should the market or liquidity changes require.

Automatic Stop Out

CXM sets minimum margin requirements that result in automatic Stop Out levels to protect clients from losses. If during an open trade, the net worth of the account reaches the “margin level” equal to 30% of the required margins, positions will be closed in order of the largest losing trade until the net equity of the account reached the required margins.

Conflicts of interest disclosure

With regards to its clients, CXM offers the best execution to both retail and professional clients and its automatic execution flow does not differentiate or treat client orders differently. The variation may apply depending on the client risk appetite when compared to another. For example, professional clients may choose to take more risk or higher leverage as compared to retail clients.