Order Execution Policy

This information about IND-X's Order Execution Policy is provided to professional clients of IND-X and is not applicable to business conducted with retail clients or eligible counterparties.

Circumstances in which "IND-X" will provide best execution

When executing orders ("Order") on your behalf in relation to financial instruments, IND-X will take all reasonable steps to achieve best execution of your Orders by following our Order execution policy. This is subject to any specific instructions received from you. We will do this by following procedures which are designed to obtain the best possible execution result, taking into account the nature of your Orders, any conditions which you place to fill such orders, the market in question and conditions therein. The aim of this is to produce a result which provides, in our view, the best possible execution result across a range of sometimes conflicting factors.

Order Execution Policy

When executing your Order, we will take into account the following criteria, in addition to those set out below:

1. The characteristics of the client;

2. The characteristics of the client order

3. The characteristics of financial instruments that are the subject of that order

4. The characteristics of the execution venues to which that order can be directed.

Execution Factors:

We will take in to consideration a range of different factors which include not just price, but which may also include such other factors as the cost of the transaction, the need for timely execution, the liquidity of the relevant market (which may make it difficult to even execute an order), the size of the order and the nature of the financial transaction including whether it is executed on a regulated market or over-the-counter.

We will also take into account your understanding and experience of the market in question, your dealing profile, the nature of the dealing service you require of us and the specific and general instructions given to us by you which may prioritise how we are to fill your orders.

In the absence of express instructions from you, we will exercise our own discretion in determining the factors that we need to take into account for the purpose of providing you with "best execution".

Our commitment to provide you with "best execution" does not mean that we owe you any fiduciary responsibilities over and above the specific regulatory obligations placed upon us or as may be otherwise contracted between us.

Execution Venues

In accordance with IND-X's obligation to take all reasonable steps to obtain on a consistent basis the best possible result for our clients, IND-X will pass the orders to an approved panel of brokers for execution.

Our policy, in providing you with the best execution is to exercise the same standards and operate the same processes across all the different markets and financial instruments on which we execute your Orders. However, the diversity in those markets and instruments and the types of Orders that you may place with us mean that different factors will have to be taken into account when we assess the nature of our execution policy in the context of different financial instruments and different markets.

While we will take all reasonable steps based on those resources available to us to satisfy ourselves that we have processes in place that can reasonably be expected to lead to the delivery of best execution of your orders, we cannot guarantee that we will always be able to provide best execution of every order executed on your behalf.

IND-X has implemented procedures and arrangements which provide for the prompt, fair and expeditious execution of your Orders, relative to the other client Orders. These procedures or arrangements allow for the execution of otherwise comparable client orders in accordance with the time of their reception by us.

IND-X ensures you that Orders executed on your behalf will be promptly and accurately recorded and allocated. We will carry out otherwise comparable client orders sequentially and promptly unless the characteristics of the Order or prevailing market conditions make this impracticable, or your interests require otherwise.

Specific instructions

Where you give us specific instructions, including specifying the characteristics relating to an order or a particular aspect of an order, we will execute the order in accordance with those instructions. This will mean, in the context of this order or aspect of this order we will not follow our best execution policy.

Monitoring

While we will take all reasonable steps based on those resources available to us to satisfy ourselves that we have processes in place that can reasonably be expected to lead to the delivery of best execution of your orders, we cannot guarantee that we will always be able to provide best execution of every order executed on your behalf.

We will monitor the effectiveness of our Order execution arrangements and our execution policy. We will assess on a regular basis whether the execution venues and the brokers and dealers to whom we transmit orders, allow us to achieve best execution on a consistent basis or whether we need to make changes to our execution arrangements. We will also review our execution arrangements and policy whenever a material change occurs in respect of one of our chosen execution venues or otherwise that affects our ability to continue to achieve best execution. Should there be any material changes to our order execution arrangements or order execution policy, we will notify you.