Chinese (Simplified)

Order Execution Policy  

The services provided on www.malfex.com are provided by Malfex Investment LLC, a company incorporated  in Dubai license number 1091827 acting as mother company MFX investment stock joint company in Baku  Azerbaijan and existing under the laws of Azerbaijan under registration number IS-06, licensed by the  “Central bank of Azerbaijan” . 

Over-the-counter margined derivative contracts including contracts for difference and spot foreign  exchange are complex instruments. They come with a high risk of losing money rapidly due to leverage.  You should consider whether you understand how these products work, and whether you can afford to  incur losses and have the appropriate risk appetite. We recommend you seek professional advice  before investing.  

  1. General Information 

1.1. Malfex has established this policy along with other arrangements to meet our overarching obligation to take all reasonable steps to obtain the best possible result for our Clients. 

1.2. Malfex has an obligation to provide its Clients with appropriate information on this Policy. In  order to comply with this obligation, the firm will make this Policy available to Clients upon written request.  

1.3. Malfex’s Order Execution Policy forms part of our Client Agreement and as such, by agreeing to  the Client Agreement, you are agreeing to the terms of our Order Execution Policy.  

1.4. When Malfex makes a decision to deal, we will carry out the trade by executing the order  directly in the market ourselves.  

1.5. The price feed streamed to Clients consists of liquidity from various bank and non-bank providers or Malfex’s OXO ECN model (as described below) to ensure the Client has the best  execution possible. We do not aggregate or allocate client orders when Straight Line  Processing our trading flow to Malfex’s liquidity providers.  

  1. Malfex’s Best Execution Obligations 

2.1. Malfex provides leveraged (margin) trading, on an execution-only basis for its Client’s in Forex and CFD trading.  

2.2. It is Malfex’s decision as to what markets to offer its clients and we will deal with you as principal  and counterparty to each trade, providing you with two-way price quotes. As such, every  market offered by Malfex is quoted as a derivative of the underlying market and we are the only  execution venue to which you have access through us.  

2.3. Under the OXO (Orders-Crossing-Orders) ECN model, certain Malfex Qualified Participants are  able to provide liquidity in competition within the interbank pricing pool. Such Qualified  Participants hold collateral directly with Malfex (and not vice versa) to ensure that funds are  protected under strict client funds procedures. To qualify, Qualified Participants must be financial  institutions that have met the necessary capital requirements and have the sophisticated  technological means to provide the required streaming pricing.  

2.4. Malfex acknowledges that if you may rely upon us to provide or display bid and offer prices which 

are the best available prices for investors on a consistent basis.  

2.5. Malfex will act in accordance with the best interests of our Clients when placing orders with  

other entities for execution. In complying with this duty Malfex must take all reasonable steps to  obtain the best possible results. 

2.6. The execution factors are: price, costs, speed, likelihood of execution and settlement, size,  nature, and any other consideration relevant to the order.  

2.7. The relative importance of these factors must be determined by reference to the “execution  criteria” and, the requirement to determine the best possible result in terms of the total  consideration (see below). The execution criteria are as follows:  

(i) the characteristics of the Client; 

(ii) the characteristics of the Client order; 

(iii) the characteristics of the financial instrument that are the subject of that order; and(iv) the characteristics of the execution venues to which that order can be directed. 

2.8. When Malfex executes an order on behalf of a Client, the best possible result must be  determined in terms of the total consideration, representing the price of the financial instrument and the costs related to execution, which must include all expenses incurred by the Client which are directly related to the execution of the order. These will include the execution venue fees, clearing and settlement fees and any other fees paid to third parties involved in the execution of the order.  

2.9. While Malfex will seek to ensure that the prices we display are competitive we are not able to  give a warranty, express or implied, that the bid and offer prices displayed on our trading systems always represent the best prevailing market prices for investors. Our quoted prices may reflect market volatility or additional costs and charges which may result in an increase in the spread as well as per transaction.  

2.10. Factors include:  

(i) Price: Malfex takes the underlying market price of the derivative it is quoting and then applies an algorithm to this price to achieve its own market price. The underlying feed that Malfex uses may be from one source in the case of FX from several feeds. Where several feeds are used the best bid and offer combinations are used to maintain tight spreads at all times. 

(ii) Costs: Our market price will often be different to the underlying as it may also include commissions or financing. 

(iii) Liquidity: The price made by Malfex, similar to the underlying market, is usually good in up to a certain size. In order to maintain additional liquidity, a different spread may be applied to the price provided in the underlying market. 

(iv) Speed of execution: In order to facilitate the speed of execution Malfex has imposed a maximum deal size on every market. This limit is regularly monitored and takes into consideration many factors including liquidity and volatility to determine an amount that we are confident to accept without referral to speed up execution. 

2.11. Other Factors: While the above four factors are considered by Malfex to be the most  important in our best execution policy, there are many other situations which can arise leading to  price 


(i) Some markets which are quoted by Malfex are done so outside of normal market hours, and as such are known as ‘grey markets’. In these situations, while every effort is made to keep 

prices and spreads consistent, this may not always be possible during particular volatile 

periods or during periods of illiquidity in corresponding markets. 

(ii) Financing charges made by Malfex are fair, competitive and transparent. These may 

include fees required to roll over open positions, and shall be disclosed to you on our website and the trading platform. 

(iii) There may be situations, through third party introductions or through partnership deals with affiliated companies that a commission or other income generated from your trade is shared with third parties. In such circumstances this will be made abundantly clear to the client by the party concerned and this information is available on request. 

  1. Malfex’s Strategy 

3.1. Monitoring: Malfex will monitor the effectiveness of its order execution arrangements, including this Order Execution Policy to identify and, where appropriate, correct any deficiencies.  

3.2. Review: We will review our order execution arrangements and this Order Execution Policy at least annually or whenever a material change occurs that affects our ability to obtain the best result for the execution of orders on a consistent basis using the venues included in this Order Execution Policy.  

3.3. Consent: Malfex is required to obtain your prior consent to our order execution policy. You will be  deemed to provide such prior consent when you give us an order.  

  1. Execution Venue 

4.1. Execution Venue means the firm directly executing the orders. In this instance Malfex is the Execution Venue who is quoting prices which are provided to Malfex by:  

(i) top tier global banks, 

(ii) non-bank liquidity providers in the wholesale foreign exchange markets, and

(iii) OXO ECN Qualified Participants, that the firm believes will provide the best available prices to its clients on a consistent basis. 

4.2. Malfex provides execution-only trading and services for its Clients in Foreign Exchange, and CFD  trading.  

4.3. Malfex does not offer any advice and does not offer equity share trading in its CFD offerings. It is the  decision of Malfex’s as to what markets it offers its clients and it does so, not as a broker but as  a principal and counterparty to each trade. As such, every market offered by Malfex is quoted  as a derivative of the underlying market and we are the only execution venue to which you have  access through us.  

  1. Monitoring & Review 

5.1. This policy along with all effective arrangements will be reviewed annually or whenever a material change occurs that affects the firm’s ability to continue to obtain the best possible result for our  Clients. 

5.2. On a regular and ongoing basis, Malfex shall monitor the effectiveness of this policy and assess the  quality of the best order execution and ensure we are providing the best possible result for our  Clients. Any deficiencies in our arrangements or within this policy will be corrected and Clients will  be notified of any material changes.