Execution Policy
Pepperstone incorporates trade execution, with pricing from multiple banks and liquidity providers and 100% automated execution. Pepperstone has a commitment to absolutely ‘No Dealing Desk’ intervention on any of our trading instruments. Trade execution is from as low as 50ms of latency (0.05 of a second) and settled immediately.

Aggregating Tier-1 Multi-Bank Liquidity from the largest selection of Banks using our Interbank Network in New York – Pepperstone aims to offer our clients the tightest Interbank Spreads and trading conditions.

1. Market risk mitigation, monitoring and reporting
We don’t take proprietary positions based on an expectation of market movements. However, we don’t hedge all client transactions, so we may have a net position (and exposure to market risk) to the extent that we have a residual un- hedged position in any of the markets on which we offer financial products.
We have internal market risk procedures that limit our net exposure arising from client activities and hedging for every financial market in which our clients trade, as well as certain groups of markets which we consider to be correlated.

4. List of current hedging counterparties
Our primary hedging counterparties are:
• Jefferies Financial Services, Inc;
• LMAX Limited;
• IG Markets Limited; and
• IS Prime Limited.

5. Counterparty Risk:
Pepperstone is the issuer of OTC Derivatives subject to this TMD. This means that the Investor is dealing with Pepperstone as the counterparty to every transaction. Accordingly, the Investor is exposed to the financial and business risks of trading with Pepperstone.

Liquidity Provider means a counterparty that we pass trades to, to manage our risk, also known as a hedging counterparty.
11.1 We may hedge our liability to you by opening analogous positions with other institutions or in the Underlying Market.

18. Disclosure of conflicts of interest
18.1 We may have a conflict of interest in acting as principal on both sides of a transaction. Because of the nature of the financial products that we provide, we can sometimes have residual long or short Contracts as a result of total client volume in one particular direction.

Negative Balance Protection is when we will waive negative equity balance incurred on your Account.