This Order Execution Policy (the “Policy”) is issued by Kohle Capital Markets Limited (the “Company”, “we”, “us”, or “our”) and sets out the principles, standards, and arrangements by which the Company handles and executes orders on behalf of users of digital services operated under the KCM Trade brand (the “Services”).
This page provides an overview of the Company’s execution framework. The full Order Execution Policy (PDF) (v2) contains the complete policy. In the event of any inconsistency, the PDF document prevails.
The Company holds an Investment Dealer (Full Service Dealer) licence (Licence No. C117022600, SEC-2.1B) issued by the Financial Services Commission of Mauritius (FSC Mauritius) and is subject to obligations regarding the fair and timely execution of client orders under the Securities Act 2005 (Mauritius) and applicable FSC Conduct of Business Rules.
1. Scope
This Policy applies to:
- All orders placed through the KCM Trade platform, mobile application, and associated digital services
- All financial instruments available through the Services, including Contracts for Difference (CFDs) and foreign exchange (forex) instruments
- All users who place orders through the Services
The Company provides its Services on an execution-only basis. The Company does not provide investment advice, personal recommendations, or discretionary management, and nothing in the execution of an order constitutes advice on the merits or suitability of any transaction. Users are solely responsible for their own trading decisions.
2. Best Execution Obligation
The Company is required to take all reasonable steps to obtain the best possible result for clients when executing orders, having regard to the execution factors described in Section 3.
Where the Company acts as principal or market maker — that is, where the Company is the counterparty to a user’s trade — the best execution obligation is fulfilled through the consistent application of pricing and execution standards set out in this Policy, together with the safeguards described in the Company’s Conflicts of Interest Policy.
3. Execution Factors
When determining the best possible result for a user, the Company considers the following factors, weighted according to the nature of the order and prevailing market conditions:
| Factor | Description |
|---|---|
| Price | The price at which the order is executed, including any spread or commission |
| Cost | Total cost to the user, including fees, commissions, and financing charges |
| Speed of Execution | The time elapsed between order receipt and execution confirmation |
| Likelihood of Execution | The probability that the order will be executed at or near the requested price |
| Likelihood of Settlement | The probability that the executed order will be settled in a timely manner |
| Order Size | The volume of the order and its potential impact on available liquidity |
| Nature of the Order | The order type and any specific user instructions |
For most retail users under normal market conditions, price is the primary execution factor. Under conditions of high volatility or low liquidity, likelihood of execution and speed may take precedence over price.
4. Execution Infrastructure
The Company executes orders through its trading platform infrastructure, which operates via:
- MetaTrader 4 and MetaTrader 5 — trading platform software developed by MetaQuotes Software Corp.
- Leverate — technology solutions for platform connectivity and execution routing
- Liquidity providers — one or more external prime brokers and liquidity providers selected by the Company
Orders may be executed in either of the following ways:
- Against the Company as principal — the Company acts as market maker and fills the order from its own book at the quoted price
- Routed to external liquidity — the Company routes the order to an external liquidity provider for execution at the best available market price
The Company maintains relationships with liquidity providers to support competitive pricing and execution across all instruments offered through the Services. The specific liquidity providers used may change from time to time.
5. Order Types
The following order types are supported through the Services, subject to platform availability and market conditions:
| Order Type | Description |
|---|---|
| Market Order | Executed immediately at the best available price at time of placement |
| Limit Order | Executed at a specified price or better; may remain unfilled if the market does not reach the specified price |
| Stop Order | Converts to a market order when the market reaches the specified trigger price |
| Stop Loss | Automatically closes a position if the market moves against the user by a specified amount |
| Take Profit | Automatically closes a position when the market reaches a specified profit level |
| Trailing Stop | A dynamic stop loss that adjusts in the direction of a favourable price movement |
6. Specific Client Instructions
Where a user provides specific instructions regarding the execution of an order (for example, a specified price, size, or method), the Company will use all reasonable efforts to comply with those instructions.
Following specific client instructions may prevent the Company from taking all steps otherwise available under this Policy to achieve the best result for the user. In such cases, the Company will have met its best execution obligation in respect of the matters addressed by the specific instruction.
7. Slippage and Market Conditions
Slippage occurs when the price at which an order is executed differs from the price at which the order was placed. Slippage may be positive (execution at a price more favourable than requested) or negative (execution at a price less favourable than requested).
Slippage is more likely to occur in the following circumstances:
- High market volatility
- Low market liquidity
- Rapid price movements around major economic announcements or news events
- Market opening and closing periods
- Periods of system disruption
The Company does not guarantee execution at the exact price requested. Users are advised to review the Risk Disclosure Statement for further information on execution-related risks.
8. Partial Fills and Order Rejection
Orders may be partially filled where insufficient liquidity exists at the requested price. The unfilled portion may be cancelled or held as a pending order depending on the order type and user settings.
The Company may reject an order where:
- The requested price is outside available market prices
- The order would cause the user’s account to exceed applicable margin limits
- The relevant instrument is not available for trading at the time of submission
- The order is suspected to involve market manipulation, abuse, or prohibited conduct as defined in the Terms of Service
9. Overnight Financing Charges
Positions held open overnight or over weekends may be subject to overnight financing charges, commonly referred to as swap rates or rollover rates. These charges reflect the cost of funding the leveraged position and are calculated in accordance with the applicable Product Specification.
Financing charges may be positive (credited) or negative (debited) depending on the instrument, the direction of the position, and prevailing interbank interest rates.
10. Monitoring and Review
The Company monitors the effectiveness of its execution arrangements on an ongoing basis and reviews this Policy at least annually, or upon any material change to the Company’s execution infrastructure, applicable regulations, or market conditions.
Users will be notified of any material changes to this Policy in accordance with the notification procedures described in the Terms of Service.
11. Limitation of Liability
The Company takes all sufficient steps to obtain the best possible result for its clients in accordance with this Policy. However, to the maximum extent permitted by applicable law, the Company is not liable for:
- Slippage, requotes, gapping, or the price at which an order is executed under prevailing market conditions
- The rejection, cancellation, delay, or partial fill of any order
- Latency, disconnection, or failure of internet connectivity, trading platforms, or third-party infrastructure outside the Company’s reasonable control
- Losses arising from the user’s own trading decisions, instructions, or use of the Services
- Any indirect, consequential, incidental, or special loss
Nothing in this Policy limits the Company’s liability for fraud, gross negligence, or any liability that cannot be excluded or limited under applicable law. This Policy is to be read together with the limitation of liability provisions of the Terms of Service.
12. Consent
By accessing the Services and placing orders through the KCM Trade platform, users are deemed to have read, understood, and consented to this Order Execution Policy and the execution arrangements described herein.
The full Order Execution Policy (PDF) (v2) is available for download.