Order Execution Policy

Document owner: [DEALING OR BEST EXECUTION FUNCTION]

Version: [VERSION NUMBER]

Effective date: [EFFECTIVE DATE]

Last reviewed: [LAST REVIEW DATE]

1 Purpose

This policy explains how BARS 8 LTD, trading as BARS 8, receives and executes client orders in CFDs and any other approved products. It describes the execution model, factors considered, available venues or counterparties, order handling, slippage and monitoring.

The legal standard must be completed for the relevant entity and client category. Where BARS 8 owes a duty to take all sufficient steps, reasonable steps or another prescribed standard to obtain the best possible result, the final wording must use that exact standard.

2 Scope

This policy applies to [RETAIL CLIENTS, PROFESSIONAL CLIENTS AND OTHER IN-SCOPE CATEGORIES] who trade [APPROVED PRODUCTS] through [APPROVED PLATFORMS].

It applies when BARS 8:

• executes an order directly with a client;
• transmits an order to another entity for execution;
• receives an order through copy trading, PAMM or an approved automated tool; or
• closes or reduces a position under the Client Agreement.

The policy does not apply to a product or service expressly outside its stated scope. Eligible counterparties and transactions governed by a separate institutional agreement should be identified in [SCOPE SCHEDULE].

3 Execution model

[COUNSEL, DEALING AND COMPLIANCE MUST SELECT AND COMPLETE THE ACTUAL MODEL]

POSSIBLE PRINCIPAL MODEL LANGUAGE

BARS 8 acts as principal and contractual counterparty to client CFD transactions. Transactions are over the counter and are not executed by the client on a regulated exchange. BARS 8 may hedge some or all exposure with approved liquidity providers or retain exposure within risk limits. A hedge does not change the client's contract with BARS 8.

POSSIBLE AGENCY OR TRANSMISSION MODEL LANGUAGE

BARS 8 receives and transmits orders to [EXECUTING ENTITY OR VENUE TYPE] under approved arrangements. The relevant executing entity becomes [DESCRIBE COUNTERPARTY RELATIONSHIP].

Hybrid model language

BARS 8 applies [DEFINED CRITERIA] to determine whether an order is executed as principal, matched, hedged or transmitted. The method is governed by documented routing and conflict controls.

APPROVED FINAL DESCRIPTION

[COMPLETE DESCRIPTION OF COUNTERPARTY, ROUTING, HEDGING, MATCHING AND REVENUE MODEL]

4 Execution venues and sources

An execution venue can include BARS 8 itself, an affiliated entity, another broker, liquidity provider, market maker, regulated market, multilateral facility, organised facility or another permitted source of liquidity.

The current venue and counterparty schedule appears in Appendix A and at [VENUE LIST URL]. It should identify the product groups for which each is materially relied upon.

BARS 8 can use data from exchanges, banks, liquidity providers, brokers, aggregators and specialist price sources to construct quotes. The source used may differ by product and market condition.

5 Client consent

Before providing service, BARS 8 obtains the consent required for this policy and, where applicable, express consent to execute orders outside a regulated market, multilateral trading facility or organised trading facility.

Consent method: [CHECKBOX, SIGNATURE OR OTHER DURABLE EVIDENCE]

Record location and retention: [SYSTEM AND PERIOD]

Withdrawal of a consent can prevent BARS 8 from providing the relevant service and may require open positions to be closed under the Client Agreement.

6 Execution factors

When executing an order, BARS 8 considers:

• price;
• costs payable in connection with execution;
• speed;
• likelihood of execution;
• likelihood of settlement;
• order size;
• order nature, type and conditions;
• available liquidity and market impact;
• product characteristics;
• client characteristics and classification;
• venue characteristics; and
• any other circumstance relevant to obtaining the applicable execution objective.

For a Retail Client, the best possible result is generally assessed by total consideration, meaning the product price and execution-related costs, where applicable law uses that standard. Speed, likelihood and other factors can take precedence where they are instrumental in delivering the best result in context.

For a Professional Client, relative importance can vary with the client's expertise, instruction, order and market. The final weighting method is [APPROVED WEIGHTING METHODOLOGY].

7 Price

7.1 Quote formation

BARS 8 receives or derives reference prices from the approved sources listed in Appendix A. It may apply spreads, mark-ups, mark-downs, product adjustments, funding, rounding and other disclosed components.

For each product group, the final schedule must state:

• primary and fallback reference sources;
• whether quotes are executable or indicative;
• spread methodology;
• mark-up or commission treatment;
• stale-price controls;
• outlier and bad-tick controls;
• market-open and market-close method; and
• disruption and fallback method.

7.2 Bid and ask

A buy generally executes at the available ask and a sell at the available bid. Position valuation uses the applicable side of the quote unless the specification defines another method.

7.3 Price comparison

BARS 8 periodically assesses the fairness and quality of prices using relevant external data where available. Data-source limitations, OTC product adjustments and contract differences are documented.

8 Costs

Execution-related costs can include spread, commission, venue or provider charges and currency conversion. Overnight financing and other holding charges are disclosed separately and can affect the overall result.

BARS 8 will not structure or charge commissions in a way that unfairly discriminates between execution venues. Any payment, rebate, mark-up or benefit connected with routing must comply with conflicts and inducement requirements.

9 Speed, likelihood and size

Speed can be important in volatile markets, while likelihood can be more important for large, illiquid or conditional orders. An order larger than available liquidity can be rejected, partially filled, filled at several prices or subject to additional review.

Minimum and maximum trade size, maximum exposure, depth and order-frequency controls appear in the product specification or platform. BARS 8 may split or stage execution where the order type, model and client interest permit.

10 Order receipt and sequencing

An order is received when it enters the approved BARS 8 system in a valid format. Device display, button selection or local transmission time may differ from server receipt.

Comparable client orders are handled promptly and fairly in the order received unless order characteristics, market conditions, client instructions, system capacity or another legitimate factor makes another sequence appropriate.

BARS 8 maintains time stamps, order state, price, account, venue or source and execution outcome to the precision required by applicable law.

11 Order types

11.1 Market order

A market order requests execution at the best available price within applicable controls. The displayed price is not guaranteed. Slippage can be positive or negative.

11.2 Limit order

A limit order requests execution at the limit price or better. Reaching the displayed level does not ensure a fill if available liquidity, order priority, size or price duration is insufficient.

11.3 Stop order

A stop order becomes a market or other specified order when the trigger is reached. It can execute beyond the stop level during a gap or fast market.

11.4 Stop-limit order

Where available, a stop-limit order activates a limit order at the trigger. Price protection can result in no execution.

11.5 Trailing stop

Where available, a trailing stop adjusts according to the configured distance and platform logic. It may depend on the terminal or server being connected, as stated in the platform specification.

11.6 Take-profit order

A take-profit instruction seeks to close at the target or a more favourable available price. Execution remains subject to liquidity and the applicable order logic.

11.7 Expiry

Available expiry options can include good until cancelled, day, specified time or immediate-or-cancel. Platform labels and time-zone treatment must be documented.

12 Slippage

Slippage is the difference between the requested or trigger price and execution price. It can occur because prices and liquidity change between receipt, trigger and fill.

BARS 8 applies [APPROVED SLIPPAGE METHOD] without unfair asymmetry. Monitoring compares positive and negative slippage by product, client segment, venue, order type and market condition. Any tolerance, price band or rejection logic must be documented, tested and disclosed where material.

13 Requotes and rejection

[STATE WHETHER REQUOTES ARE USED]. Where a requote is permitted, the client receives a new price and the time available to accept it. The original price is no longer available.

An order may be rejected for insufficient margin, invalid parameters, size or position limits, closed session, lack of liquidity, price movement outside controls, system failure, legal restriction, suspected abuse or another reason stated in the Client Agreement.

Rejection data is monitored to identify unfair outcomes, technical faults and venue-quality issues.

14 Partial fills and aggregation

Where the product and system permit, an order may be filled in parts at one or several prices. The account confirmation shows the resulting execution data.

BARS 8 may aggregate a client order with another order or proprietary transaction only where permitted and where the process is unlikely overall to disadvantage a client. Allocation must be fair, prompt and governed by a written method. Partial aggregate fills use [APPROVED ALLOCATION METHOD].

15 Specific instructions

If you provide a specific instruction about an order or execution factor, BARS 8 will follow it where accepted. The instruction can prevent BARS 8 from applying this policy to the instructed element and can lead to a different result.

BARS 8 remains responsible for non-instructed elements to the extent required by law. It may decline an instruction that is unclear, impossible, unlawful, outside available functionality or inconsistent with risk controls.

16 Trading outside regular hours

Where extended or weekend sessions are offered, liquidity, price sources, spreads and volatility can differ from core market hours. Some underlying markets may be closed, increasing reliance on futures, alternative venues or indicative calculations.

Orders can remain pending across a closure and become eligible at a materially different reopening price. Product sessions, maintenance breaks and holiday changes appear in the current specification.

17 Market opening, closing and gaps

At session opening or after a halt, multiple orders can become eligible around the same time. BARS 8 applies the approved sequence and available liquidity. Stop orders can execute beyond triggers and limit orders can remain unfilled.

Near session close, liquidity can fall and price movement can accelerate. Orders received too late for processing can be rejected or remain pending according to their expiry.

18 Corporate actions, expiries and rolls

Corporate actions can require a price, cash, quantity or instrument adjustment. Futures-referenced products can be closed, rolled or adjusted under the product specification. Execution can be restricted around the event.

BARS 8 considers the underlying market, provider treatment, tax and contract terms. The Client Agreement governs client-level adjustment and notification.

19 Trading halts and disrupted markets

If an underlying market or material price source is halted, suspended, erroneous or unavailable, BARS 8 may suspend execution, restrict order types, use a fallback source, widen controls, value under a reasonable method or close an affected product as the Client Agreement permits.

The dealing function records the event, sources, decisions, client impact and restoration. Compliance reviews material events.

20 Copy trading and PAMM orders

Orders arising from copy trading or PAMM can be received after the provider or manager order because of allocation calculations, sequencing, network or risk checks. Followers and investors can receive different prices or sizes.

Minimum trade size, rounding, insufficient margin, product permission, position limits and account settings can prevent or alter replication. BARS 8 monitors allocation and execution differences according to [SERVICE MONITORING STANDARD].

21 Automated and high-frequency activity

Orders from expert advisers, APIs or algorithms follow the same validation and execution framework unless an approved service agreement states otherwise. Message-rate, size, duplicate, price-band and stability controls can apply.

BARS 8 may throttle, reject or suspend activity that threatens service stability, violates law or exceeds account terms. Controls must not be used to create an unfair execution result.

22 Client close-out and BARS 8 close-out

Client-requested close-out is executed under the available order type and market conditions.

Margin or default close-out can occur automatically when a contractual trigger is reached. The close-out sequence is [APPROVED SEQUENCE]. Execution factors may place speed and likelihood above price when delay could increase a deficit. The process can close positions at different prices and times.

23 Venue and counterparty selection

BARS 8 evaluates a venue or counterparty using factors such as:

• pricing and depth;
• execution speed, fill rate, rejection and slippage;
• product coverage and trading hours;
• creditworthiness and settlement capacity;
• technology, resilience and security;
• regulation and legal enforceability;
• data quality and transparency;
• concentration and continuity risk;
• fees, rebates and conflicts; and
• ability to support client outcomes and regulatory reporting.

Due diligence occurs before appointment and periodically thereafter. Material deterioration can lead to remediation, reduced use, suspension or removal.

24 Venue concentration

Reliance on a limited number of sources can improve consistency while increasing outage, pricing and counterparty concentration. BARS 8 assesses whether adding or replacing a source would improve execution quality after considering integration, depth, product terms and resilience.

Where BARS 8 is the sole venue for an OTC product, monitoring uses relevant external prices and outcome data to assess fairness and effectiveness.

25 Conflicts and inducements

Conflicts can arise where BARS 8 acts as principal, earns from spread or client activity, selects affiliated providers, retains risk or receives a rebate. These conflicts are managed through approved pricing, routing, risk limits, remuneration, monitoring, governance and disclosure.

Venue selection is not based on a fee or non-monetary benefit that would impair the duty owed to a client. Material arrangements are recorded and reviewed under [CONFLICTS POLICY].

26 Monitoring execution quality

BARS 8 monitors outcomes using measures appropriate to the model, which can include:

• quoted and executed spread;
• price improvement and negative slippage;
• execution time;
• fill and partial-fill rate;
• rejection and requote rate;
• order-size and liquidity impact;
• price-source deviation;
• system availability and latency;
• stop-order outcomes;
• complaint and correction data; and
• venue or counterparty concentration.

Analysis is segmented where relevant by product, order type, client class, size, time, venue and market condition. Exceptions and trends are investigated. Methodology, data gaps and thresholds are documented.

27 Periodic review

The policy, execution arrangements and venue schedule are reviewed at least annually and whenever a material change affects the ability to achieve the required result. Triggers include a new product or venue, model change, sustained quality decline, major outage, legal change, conflict, complaint trend or significant market event.

The review is approved by [GOVERNANCE BODY]. Material deficiencies receive a remediation owner and deadline.

28 Client information and reports

Where required, BARS 8 publishes execution-quality, venue or routing reports in the prescribed form and period. The final list is [REGULATORY REPORTING SCHEDULE].

On reasonable request and subject to law, we can explain how this policy applied to a client order using available records. Confidential provider terms, security information and information about others may be protected.

29 Material changes

BARS 8 will notify clients of a material policy change through [NOTICE METHOD] before or when it takes effect as required. The current version, effective date and venue list remain available at [ORDER EXECUTION POLICY URL].

30 Questions and complaints

Questions: [DEALING OR SUPPORT CONTACT]

Complaints: [COMPLAINTS EMAIL AND POSTAL ADDRESS]

External escalation: [ELIGIBLE EXTERNAL DISPUTE BODY AND URL]

Appendix A Execution venue and price-source schedule

Product group

BARS 8 role

Primary venue or source

Fallback

Material costs or conflicts

FX CFDs

[ROLE]

[VENUE OR SOURCE]

[FALLBACK]

[DISCLOSURE]

Metal CFDs

[ROLE]

[VENUE OR SOURCE]

[FALLBACK]

[DISCLOSURE]

Commodity CFDs

[ROLE]

[VENUE OR SOURCE]

[FALLBACK]

[DISCLOSURE]

Index CFDs

[ROLE]

[VENUE OR SOURCE]

[FALLBACK]

[DISCLOSURE]

Share CFDs

[ROLE]

[VENUE OR SOURCE]

[FALLBACK]

[DISCLOSURE]

Crypto CFDs

[ROLE]

[VENUE OR SOURCE]

[FALLBACK]

[DISCLOSURE]

Appendix B Product execution controls

Control

Approved method

Quote status

[EXECUTABLE OR INDICATIVE RULE]

Slippage

[METHOD AND TOLERANCES]

Requotes

[METHOD OR NONE]

Partial fills

[AVAILABILITY AND METHOD]

Order sequencing

[SEQUENCE]

Aggregation

[METHOD OR NONE]

Price correction

[MANIFEST ERROR PROCEDURE]

Stale price

[THRESHOLD AND RESPONSE]

Stop-out

[LEVEL AND SEQUENCE]

Market disruption

[DECISION AND SOURCE HIERARCHY]

Extended hours

[PRODUCTS AND SOURCES]

Appendix C Review evidence

The annual review file should include:

• venue and source inventory;
• product and client scope;
• execution-quality metrics and methodology;
• outliers, complaints and corrections;
• conflicts and payment arrangements;
• outages and continuity events;
• provider due diligence and concentration;
• comparison with reasonable alternatives;
• decisions and approved changes;
• client-notice assessment; and
• governing-body approval.