This policy describes the approach Oval Money Limited will take when dealing with investment order instructions.
1.1. Oval Money Limited (“Oval”) does not itself execute order(s) or instruction(s) to trade received by it, but transmits such order(s) or decision(s) to Issuers, which then execute such orders themselves and/or place them with other entities for execution.
2.1. As a receiver and transmitter of users’ orders, Oval will satisfy its obligation to act in the best interests of the user when:
2.1.1 it receives and transmits orders for execution to Issuers, which meet the MiFID II (as defined below) best execution obligations and are in a position to deliver the best possible result for the Retail Customer. Where the Issuers do not execute orders themselves, but place them with third parties, the Issuers will meet their best placement obligations and carry out regular (and at least annually) evaluations of the quality of executions obtained from such third parties to ensure such third parties are able to offer best execution. The Issuers will inform and report to Oval on the proper execution of the user’s orders. As an entity falling within the scope of the Directive 2014/65/EU of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments (hereafter "MiFID II"), the Issuers have solid best execution policies enabling Oval to comply with its obligations to act in the best interest of the user. Where the Issuers place orders with entities that do not fall within the scope of MiFID II (depending on the financial instruments or markets concerned), the Issuers will consider putting in place formal arrangements with selected entities to ensure that they meet the MiFID II best execution standards. A list of all third parties which may be used by the Issuers for the execution of user orders may be provided by Oval to the user on request from the user;
2.1.2. it takes all sufficient steps so that the Issuers, when executing orders transmitted by Oval, ensure the best possible result for the user, including from a price, cost, speed, execution, size, nature of order or any other consideration relevant to the execution of the order. Oval draws to the attention of the user that depending on the type of financial instruments, achieving the best possible result may be complex. In addition, in cases where the user gives a specific instruction (indicating the process for execution of the instruction), Oval will transmit the instruction in compliance with that instruction, which might not be in line with Oval’s RTO Policy as well as with the Issuers’ best execution policies and may not be, in Oval’s view, in the best interest of the Customer; and
2.1.3. it monitors and reviews the execution quality of the user’s orders and corrects any deficiencies.
3.1. Unless agreed otherwise, when receiving (and accepting) an order from the user involving the purchase/subscription or sale/redemption of financial instruments, Oval will transmit such order with the relevant Issuer which may, in accordance with its best execution policy:
3.2. Users will be informed without delay of any material difficulty in executing a transaction as soon as Oval becomes aware of any issues. As a general rule, in accordance with each Issuer’s order execution principles, Issuers will execute orders quickly, efficiently and fairly, and executed orders shall promptly and accurately be recorded and allocated.