Order Execution Policy
We, FFA Private Bank (Dubai) Limited (“FFA”), are committed to treating Clients fairly and have a duty to provide
them with “best execution” when entering into transactions with or for them. This Orders Execution Policy (the
“Policy”) sets forth our approach to achieving the best possible result for our clients when executing their orders
in compliance with the rules and regulations of the Dubai Financial Services Authority.
This Policy should be read in conjunction with Terms of Business that are applicable to your account (the “Terms
of Business”). Any capitalised terms used in this Policy but not otherwise defined here in shall have the meaning
given to them in the Terms of Business Agreement.
SCOPE OF THIS POLICY
Subject to the DFSA Laws and Regulations, this Policy does not apply with respect to any Transaction which
FFA undertakes with or for a Client classified as Market Counterparty as defined under chapter (2) of the
Conduct of Business Module.
FFA shall, when executing transactions comply with this Policy and you consent to such Policy as it is
amended and updated from time to time. The Policy and any amendments are available on our website
(www.ffaprivatebank.com). We will notify you of any material changes to the Policy although it is your
responsibility to ensure that you are referring to the most up to date version.
FFA enters into all Transactions with or for Clients as ‘agent’ or as Principal (limited to deals undertaken on
a Matched Principal basis only).
EXECUTION FACTORS
When executing orders on your behalf in relation to financial products as defined by the DFSA’s GEN APP2,
FFA will take reasonable care to obtain the best possible result for Clients taking into account a number of
execution factors, including, price, direct costs and indirect costs, speed, likelihood of execution and
settlement arrangements, size, nature of the order, timing of a Client’s order that could affect decisions on
when, where and how to trade, or any other considerations relevant to the execution of the order.
In determining the relative importance of these factors, FFA shall use its own commercial experience and
judgment, together with the size and nature of the order, the characteristics of the financial instruments to
which the order relates, as well as the possible execution venues to which that order can be directed
In general, FFA shall regard price as the most important of these factors for obtaining the best possible
result. In compliance with the DFSA rule COB 6.4.2, FFA shall take reasonable care to determine the best
overall price available under the prevailing market conditions and deals at a price which is no less
advantageous to the Clients. However, there may from time to time be circumstances for some Clients,
particular instruments or markets, where other factors may be deemed to have a higher priority.
EXECUTION VENUES
In establishing this Policy, FFA has identified a variety of different execution venues and entities that it
intends to use, as it considers that these enable it to obtain the best possible result on a consistent basis
when executing orders on behalf of Clients.
FFA may transmit the order to third party agents for execution. In such cases, FFA may determine itself the
ultimate execution venue by accessing specific execution venues through such third parties.
FFA may be the execution venue and act on a ‘matched principal’ basis to the effect of completing certain
transactions, including on financial instruments admitted to trading on a regulated market. By signing the
Terms of Business Agreement (account opening document), the Client has provided a prior express
consent to this effect.
Where FFA acts on a ‘matched principal basis’ or ‘as agent’, it will take reasonable care to determine the best
overall price available for Clients’ Investment under the prevailing market conditions and deals at a price
which is no less advantageous to the Client.
EXCEPTIONS TO THE DUTY OF BEST EXECUTION
Where the Client is offered with a quote and accepts it through a routing / Direct Market Access electronic
connections, orders executed are excluded from this Policy as the Client takes direct responsibility for his
order’s execution.
Where FFA is provided with specific instructions in relation to the execution of an order, FFA shall execute the
order in accordance with those specific instructions which may prevent it from taking the steps set out in
this Policy to obtain the best result in respect of those elements covered by those instructions.
The above exceptions to the best execution policy apply even where, as part of its general relationship with
the Client, FFA communicates trade ideas, relevant market opportunities or indicative prices to the Client..
REPORTS OF SETTLEMENTS AND ORDER MONITORING
FFA shall monitor and/or record any or all orders given to FFA by telephone or by electronic means.
Where FFA is dealing on behalf of a Client as agent or on a matched principal basis, reports of settlement
(confirmation notes) sent by FFA to the Client shall be deemed a final proof of execution by FFA of the
Client's order, and FFA shall not provide the Client with any report from external execution venues or
entities.
Where FFA, acting as an introducing broker, is arranging a deal on behalf of the Client to be executed by a
third party financial institution and where the Client’s account is held by the third party financial institution,
FFA shall request the said third party financial institution to send directly the reports of settlement (contract
notes) to the Client.
The Client shall at all times be responsible for checking his reports of settlement (contract notes) and
statements of accounts. The Client hereby acknowledges that if he does not receive reports of settlements
and statements of account for any period, it is his responsibility to request such document(s) from FFA
immediately.
MONITORING AND REVIEW
FFA shall act in accordance with this Policy on a best effort basis, in order to achieve the best outcome for
the Client. Nevertheless, FFA cannot guarantee that every Client order will be executed at the best posted
price, particularly in cases such as, but not limited to, system delays or failures.
FFA shall monitor regularly its order execution arrangements, as well as the quality of both its execution and
that of third parties to whom it has passed orders. Such review shall enable FFA to identify and implement
changes to its policy and execution arrangements as necessary. Clients shall be advised of any material
change to FFA's Execution Policy if and when deemed necessary by FFA.