1. Rizzo, Farrugia & Co (Stockbrokers) Ltd (hereinafter “RFC”) gives a date and time stamp to each order received from a client. RFC’s policy is to execute trades individually and in the order they are received namely on a “first come, first served” basis, even in the case of partial execution. In principle therefore, RFC does not aggregate clients’ orders.
2. Nevertheless in particular circumstances RFC may decide to aggregate clients’ orders. Aggregation of orders is normally to the client’s advantage since execution fees are spread out over a larger number of securities. Nevertheless in certain circumstances aggregation may work to the client’s disadvantage, as for example when the supply of the security in question is insufficient to meet the aggregated order.
3. Where RFC aggregates an order with one or more other client orders and the aggregated order is partially executed, RFC will allocate the related trades in accordance with paragraph 1 above.
4. If RFC aggregates transactions for own account and with one or more client orders then the client’s order shall be allocated first and in the case of multiple clients the clients’ orders shall be allocated first in accordance with paragraph 1 above. This paragraph shall apply also in the case of partial execution of an aggregated order. RFC will only allocate transactions to its own account after all clients’ order/s have been satisfied.
5. Due to systems failures or other unavoidable reasons, RFC may execute orders in a method that differs from that stated in this policy. Even in such a case, however, RFC endeavors to execute orders on the best terms available at that point.
6. RFC shall notify clients of any material changes to its order allocation policy. The policy shall be reviewed annually.