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Order Reception & Transmission Policy
1. Introduction
Xborder Partners Wealth — Empresa de Investimento, S.A. (“Xborder”) is authorised and supervised by the Comissão do Mercado de Valores Mobiliários (“CMVM”) as an investment firm providing, among other services, the reception and transmission of orders (“RTO”) in relation to financial instruments on behalf of clients.
Xborder does not execute orders on its own account or on trading venues. Instead, when a client places an order with Xborder, Xborder transmits that order to the investment platform or financial intermediary where the client’s investment is held (the “Platform”). The Platform is responsible for determining how and where the order is executed in accordance with its own execution policies. Xborder does not hold client assets or funds.
This Policy explains Xborder’s approach to the transmission of client orders, the due diligence it performs in respect of Platforms, and the steps Xborder takes to satisfy its regulatory obligations in that process.
This Policy applies to all clients of Xborder for whom RTO services are provided. By entering into an agreement with Xborder for the provision of RTO services, clients are deemed to have been informed of, and to have consented to, this Policy.
2. The Best Selection Obligation
Unlike investment firms that execute client orders directly, Xborder’s role is to receive and transmit orders to third parties for execution. Xborder is subject to Article 64 of Commission Delegated Regulation (EU) 2017/565. However, as Xborder transmits orders to the platform where the client’s investment is held, Xborder does not independently select the entities that execute the orders. The Platform itself is responsible for executing the order in accordance with its own best execution policy.
“Best possible result” is assessed on the basis of the total consideration for the client, which for most transactions means the price of the financial instrument combined with the costs associated with execution (including the fees, commissions and charges of the Platform). However, for professional clients and where relevant, other factors may also be taken into account (see Section 4 below).
3. Due Diligence on Platforms
Although Xborder does not select the entity to which a client’s order is transmitted (as orders are transmitted to the Platform), Xborder performs due diligence on the platforms and intermediaries with which it works. This due diligence is designed to confirm that such platforms are appropriately regulated and capable of providing adequate execution services to clients.
In conducting its due diligence, Xborder considers the following factors:
- Regulatory authorisation and compliance: The Platform must be duly authorised and regulated under MiFID II or an equivalent regulatory framework;
- Execution arrangements: Xborder reviews the Platform’s execution arrangements and policies to assess its ability to obtain appropriate execution outcomes for clients;
- Costs and charges: Xborder considers the costs (including commissions, fees and transaction costs) associated with the Platform;
- Range of instruments: The range of financial instruments accessible through the Platform;
- Reliability and operational capability: The reliability and technical capability of the Platform in handling and executing orders; and
- Financial soundness: The financial stability and reputation of the Platform.
4. Execution by Platforms
The Platform to which an order is transmitted is responsible for determining how and where to execute the order in accordance with its own best execution policy. When executing orders, the Platform may take into account factors such as:
| Execution Factor | Description |
|---|---|
| Price | The price at which the financial instrument is offered for purchase or sale |
| Costs | All costs incurred by the client, including Platform fees and commissions |
| Speed | The speed with which the order is likely to be executed |
| Likelihood of execution | The probability that the order will be executed in full |
| Size | Whether the size of the order may affect the price or likelihood of execution |
| Nature of the order | The type and characteristics of the order (e.g., market, limit) |
| Other relevant considerations | Any other factor relevant to the quality of execution in the specific circumstances |
5. Client Instructions
Where a client provides Xborder with specific instructions regarding the transmission of an order (for example, a limit price or particular timing), Xborder will transmit those instructions to the Platform to the extent practicable. The Platform will then seek to follow those instructions in accordance with its own policies and procedures.
Clients are reminded that specific instructions may affect the Platform’s ability to obtain the best possible result in respect of the elements covered by those instructions.
6. Classes of Financial Instruments
This Policy applies to orders in the following classes of financial instruments, to the extent they are within the scope of Xborder’s authorised services:
- Transferable securities (including shares and bonds);
- Units and shares in collective investment undertakings (UCITS and AIFs);
- Exchange-traded funds (ETFs);
- Structured finance products; and
- Other financial instruments as may be added from time to time.
7. Monitoring and Review
Xborder will monitor the effectiveness of this Policy and the execution quality achieved by Platforms on a regular basis. Monitoring will include:
- Periodic review of the execution quality achieved by Platforms across relevant instrument classes;
- Assessment of whether Platforms continue to satisfy the due diligence criteria set out in Section 3; and
- Identification of any deficiencies and implementation of corrective measures where necessary.
This Policy will be reviewed at least annually and updated as necessary to reflect changes in market conditions, Xborder’s business model, the regulatory environment, or the performance of Platforms. Any material changes to this Policy will be communicated to clients in advance.
