1. Execution Policy

INTRODUCTION

Antos Pinnacles is a global broker providing online currency trading services. The company are registered under the law of Labuan LFSA, with registration number LL16538, 1-23A, 1st Floor, Paragon, Jalan Tun Mustapha, 87008 Labuan F.T. Malaysia.

This Policy summarises the general basis on which Antos Pinnacles (“we”, “us” or “our”) will provide “best execution” when dealing with or for a client. In this respect, the Company established and provides its clients and potential clients with its Order Execution Policy (the “Policy”).

SCOPE AND PURPOSE

This Policy applies when receiving and transmitting Client Orders or executing Client Orders for the Client for all the types of Contracts for Difference (“CFD’s”), as applicable, offered by the Company to the Client.

Antos Pinnacles acts as the principal in the execution of transactions for our Clients, both professional and retail. This Trading Order Execution Policy will apply when Antos Pinnacles executes transactions on behalf of our Clients.

The Policy takes into account external factors beyond the Company’s control, such as order size and liquidity of the underlying market. Nonetheless, Antos Pinnacles will take all reasonable steps to obtain the best possible trading outcomes for our Clients as permitted by this Policy. Antos Pinnacles does not, however, guarantee in any way that our executions will be more favourable than what alternative providers can offer.

BEST EXECUTION FACTORS

The Company shall take all reasonable steps to obtain the best possible results for its Clients taking into account the following factors when executing Orders.

Price

Antos Pinnacles actively sources price feeds from some of the world’s leading liquidity providers to ensure our Clients are supplied with the best possible price quotes. All trade orders accepted by the Company will be executed strictly at our Clients’ requested prices, provided that there are no “slippage” incidents and that the requested prices are still available.

Cost

Opening a position in some types of financial instruments provided by Antos Pinnacles might require Clients to pay a commission and/or other fees. These charges are detailed in our Terms of Business.

Speed & Likelihood of Execution

The Company places a significant importance when executing Client’s Orders and strives to offer the fastest possible speed of execution within the limitations of technology and communications links.

Orders will be filled at the requested prices within seconds, under normal circumstances. In some cases, it may not be possible to arrange an order for execution, (including but not limited to poor connection speed, abnormal market volatility, and intentional manipulation of quoted prices or other related data), orders can be declined by Antos Pinnacles, especially if requested prices are not reflective of market prices received by the Company.

Internet connectivity issues and price-feed errors can cause prices displayed on the Trading Platform to not reflect market rates. Though latency arbitrage does exist in the over-the-counter market where Clients engage in buy and sell transactions directly with the principal, the Company does not permit the practice of arbitrage on the Trading Platform. Antos Pinnacles reserves the right to revoke without prior notice all transactions that rely on loopholes or opportunities arising from price latency arbitrage. Please refer to the Allowed Trading Methods section for more information.

Liquidity

All client orders submitted to Antos Pinnacles are subjected to the relative size of the orders, where the minimum order size is 1,000 units of the base currency (there is no maximum order size). However, the Company reserves the right to decline orders should their size exceed our capability to process and execute them in the underlying market(s). Depending on the circumstances, Antos Pinnacles can opt to extend liquidity to Clients on a case-to-case basis.

Size of Order

All Orders are placed in monetary values. The Client will be able to place Order (s) as long as he/she has enough balance in his/her trading account.

The Company reserves the right to decline an order as explained in the Terms and Conditions / Agreement entered with the Client.

Aggregation

Clients’ orders may, at the discretion of Antos Pinnacles, be aggregated with the orders of Antos Pinnacles, Antos Pinnacles associates, and/or other Clients. Orders will only be aggregated when the Company believes that this is unlikely to be unfavourable to any Client. However, Antos Pinnacles is exempted from any liability if such aggregation works to any Client’s disadvantage under unforeseen circumstances.

BEST EXECUTION CRITERIA

The Company will determine the relative importance of the above factors by using it’s commercial judgement and experience in the light of the information available on the market and taking into account the criteria below:

– The categorization as a Retail or Professional client;

– Any special objectives you may have in relation to the execution of the order;

– The characteristics of your order;

– The characteristics of the financial instruments to which your order relates; and

– The characteristics of the venues (if there is more than one) to which your order –  may be directed.

ALLOWED TRADING METHODS

Antos Pinnacles generally permits all types of trading methods and styles. However, the Company reserves the right to close, suspend or recoup any closed profit without prior notice from accounts that it deems to be engaging in unethical or questionable trading styles, which include but are not limited to latency arbitrage, “flooding” our Trading Servers with pending orders and/or order modification requests, excessive logins, and using certain automated trading systems or Expert Advisors. Under normal circumstances, Antos Pinnacles will (but is not obligated to) express our concern in the form of a formal warning to such Clients via e-mail or telephone. However, should they continue to be in breach by failing to remedy the abovementioned unethical or questionable trading styles within a reasonable timeframe, Antos Pinnacles reserves the right to liquidate all or some open positions, close, suspend or recoup any closed profit from these accounts, and return any remaining proceeds to the Clients according to the Company’s account-closing procedures or any combination thereof.

SLIPPAGE

Whilst Antos Pinnacles aims to execute orders at requested prices, price slippages are beyond our control and can occur due to sudden increases in market volatility. Clients are advised to avoid trading during periods of high volatility, such as during news hours.

Whilst Antos Pinnacles aims to execute orders at requested prices, price slippages are beyond our control and can occur due to sudden increases in market volatility. Clients are advised to avoid trading during periods of high volatility, such as during news hours.

We would hereby reassure our Clients that slippage is normal and a common feature of the foreign exchange market, which is subject to unpredictable factors like liquidity insufficiency and sentiment volatility due to economic events and major news announcements. Antos Pinnacles shall not be held liable for losses suffered on account of slippages.

HEDGING

Hedging allows Clients to hold both buy and sell positions in the same product simultaneously. Clients have the ability to enter the market without choosing a particular direction. While the ability to hedge is an appealing feature, Clients should be aware of the factors that could affect their hedged positions.

It is important to note that even a fully hedged account may suffer losses due to rollover costs, exchange-rate fluctuations and/or widening spreads. Such losses may even trigger a margin call.

MARKET ORDERS

A market order is an order to buy or sell a financial instrument at the current price. Execution of this order results in opening a trade position. Financial instruments are bought at ASK price and sold at BID price. Stop Loss and Take Profit orders can be attached to a market order.

All types of orders offered by the company are executed as market orders.

PENDING ORDERS

It is noted that under certain trading conditions it may be impossible to execute these Orders at the Client’s requested price. In this case, Antos Pinnacles reserves the right to disable without prior notice the pending order function upon major news releases.

CONTRACT EXPIRATION
Energies

The Company’s oil and gas products do not carry expiration dates. Thus, Antos Pinnacles does not require Clients to provide rollover instructions. However, the underlying assets of the said instruments have expiration and/or delivery dates. The Company will not automatically close Client positions when the underlying assets of the traded instruments are expiring or have expired. Instead, the Company will roll over trading instruments from the price feeds of the expired underlying forward/future contracts to the price feeds of the following forward/future contracts. All open Client positions will be carried forward by the Company.

Antos Pinnacles reserves the right to decline opening new positions when rolling over expired underlying assets.

Indices

Index trading instruments offered by Antos Pinnacles carry expiration dates. We, however, do not require Clients to provide rollover instructions. The Company reserves the right to close all Client positions at the expiration of the traded instruments, and where possible, re-open the said positions with the same size and type at the opening of the market on the following day.

TRADING TIME ALERT
Currency Pair

Antos Pinnacles trading hours are from Monday 00:05 to Friday 23:57. Outside of operating hours, i.e. from Friday 23:57 to Monday 00:04, the Trading Platform will not execute trades.

Metal

Antos Pinnacles trading hours are from Monday 01:05 to Friday 23:55. Outside of operating hours, i.e. from Friday 23:55 to Monday 01:04, the Trading Platform will not execute, close or modify trades.

Energy

Antos Pinnacles trading hours are from Monday 03:05 to Friday 23:55. Outside of operating hours, i.e. from Friday 23:55 to Monday 03:04, the Trading Platform will not execute, close or modify trades.

HK Stock

Antos Pinnacles trading hours are from Monday to Friday, 04:35 to 10:55. Break hours are from 06:55 to 08:04. Outside of operating hours, i.e. from Friday 10:55 to Monday 04:35, the Trading Platform will not execute, close or modify trades.

US Stock

Antos Pinnacles trading hours are from Monday to Friday, 16:35 to 22:55. Outside of operating hours, i.e. from Friday 22:55 to Monday 16:35, the Trading Platform will not execute, close or modify trades.

Euro Stock

Antos Pinnacles trading hours are from Monday to Friday, 10:05 to 18:25. Outside of operating hours, i.e. from Friday 18:25 to Monday 10:04, the Trading Platform will not execute, close or modify trades.

UK Stock

Antos Pinnacles trading hours are from Monday to Friday, 10:05 to 18:25. Outside of operating hours, i.e. from Friday 18:25 to Monday 10:04, the Trading Platform will not execute, close or modify trades.

MONITOR AND REVIEW

Antos Pinnacles will regularly monitor the effectiveness of our order execution arrangements and policy to create the most favourable trading outcomes for our Clients. The Company reserves the right to correct any deficiencies in the policy and to make improvements to its execution arrangements as required from time to time.

2. Trading Risk Disclosure

RISK WARNING

Foreign exchange trading and speculation carry significant risk. Before deciding to trade with Antos Pinnacles, Clients are advised to carefully consider their investment objectives, financial status, level of experience, and risk tolerance. There is the distinct possibility of sustaining a partial or total loss of invested funds. Clients are therefore advised not to invest capital that they cannot afford to lose. Clients should also seek independent advice from reputable financial advisors if they have questions on the risks associated with foreign exchange trading.

MARKET COMMENTARIES

It is understood that market commentary, news, or other information provided or made available by the Company are subject to change and may be withdrawn at any time without notice.

The Company may, from time to time and at its discretion, provide the Client (or in newsletters which it may post on its Website or provide to subscribers via its Website or the Trading Platform or otherwise) with information, recommendations, news, market commentary or other information but not as a service.

The public should thus treat the information provided as general references only. Under no circumstances will Antos Pinnacles be liable for any loss or damage, including but not limited to loss of profit that may arise directly or indirectly from the use of or reliance on such information.

ONLINE TRADING RISKS

Antos Pinnacles strives on a best effort basis to provide the Client with a secure and smooth online experience. Trading online, no matter how convenient or efficient, does not necessarily reduce risks associated with currency trading. There will be exposed to risks associated with the system including the failure of hardware, software, servers, communication lines and internet failure. The result of any such failure may be that his order is either not executed according to his instructions or it is not executed at all.

The Client acknowledges that the internet may be subject to events which may affect his access to the Company’s Website and/or the Company’s trading Platform(s)/system(s), including but not limited to interruptions or transmission blackouts, software and hardware failure, internet disconnection, public electricity network failures or hacker attacks.

Antos Pinnacles is not responsible for any damages or losses resulting from such events which are beyond its control or for any other losses, costs, liabilities, or expenses (including, without limitation, loss of profit) which may result from the Client’s inability to access the Company’s Website and/or Trading System or delay or failure in sending orders or Transactions, not owed to the Company’s gross negligence or wilful default.

Orders are only deemed to be received by the Company when their requests reach our Trading Servers. The Company shall not be held liable for any delays in the transfer of information between Clients’ devices and our Trading Servers.

3. AML Policy

Money laundering allows movement of funds from criminal activities and makes funds available for terrorist activities.Antos Pinnacles complies with all applicable laws and regulations for the prevention of the use of the financial systems for the purpose of money laundering and terrorist financing.

Antos Pinnacles has adopted a programme that complies with the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act. As part of this programme, all applicable persons would need to provide evidence of identification to facilitate the above-mentioned need for compliance.

The Clients need to comply with Antos Pinnacles regulatory requirements by suppling clear and verifiable identification and to provide full and frank disclosures upon further inquiries by the Company. In verifying customer identity, appointed producers shall review all photo identification supplied. Antos Pinnacles relies on government-issued identification documents to establish a customer’s identity, but is under no obligation to determine the veracity of the identification documents supplied. The Company also reserves the right to suspend or close any account that had been approved if misleading or fraudulent identification information was discovered.

If a Client either refuses to provide the information described above or appears to have intentionally provided misleading information, the appointed agent shall notify their New Business team. Antos Pinnacles will decline the application and notify the AML Compliance Committee.

Antos Pinnacles also identifies, monitors and reports any kind of suspicious transactions. The Company has the obligation to undertake measures associated with its AML compliance, on the basis of the AML Financial Action Task Force’s recommendations.

Antos Pinnacles reserves the right to refuse the processing of a transaction at any stage if it believes the transaction to be connected in any way to money laundering or criminal activity. In accordance with international laws, Antos Pinnacles is not obligated to inform the Client when reports are made to the relevant authorities.

4. Client Verification & Administration Policy

INTRODUCTION

The Client Agreement shall commence once the Client Applicant receives his or her first confirmation from Antos Pinnacles that his or her Client Account has been approved by the Company, in line with the Account Opening Procedure of Antos Pinnacles.

ACCOUNT OPENING PROCEDURE
Required Documents

Depending on the type of Client Account being opened, Client Applicants must submit specific documents to confirm their identity and correspondence address as follows:

Personal Account

  • Proof of Identification – A clear color copy of your valid Passport or Government Issued Photo Identification card.
  • Proof of Residence – Utility Bills (Gas, Water, Electric, Phone, Internet), Credit Card or Bank Statement. Mobile phone bills are not accepted. Documents provided must not be older than three months.

 

Joint Account

  • Each of the two Client Applicants must provide the documents required for the opening of a Personal Account.
  • If both Applicants live at the same address, Antos Pinnacles will accept a statement or utility bill that shows the names of both Client Applicants and their address.

 

Corporate Account

  • Certificate of Incorporation
  • Memorandum and Articles of Association
  • Proof of Business Address
  • Verification of Two Directors
  • Verification of Shareholders Owning 25% or More of Shares

 

* If any of the Directors or Shareholders is a private individual, identification and address verification documents must be submitted as required for a Personal Account.

All documents provided must be of high quality and in full colour. Copies of identification cards and other such documents in card format is to be shown both the front and back sides. Identification documents that do not show the Client Applicant’s date of birth will not be accepted.

Antos Pinnacles may use the information you have provided for us to conduct any further enquiries about you as we may deem necessary or appropriate in the circumstances. We may also conduct other searches with third-party information providers and databases. You understand that we may conduct these enquiries at any stage of the relationship, and we expect you to assist us with any addition information or documents we may require, as failure to do so many lead to termination of the relationship between you and us.

Client Account Approval and Activation

When your application have been approved, we will confirm this to you by e-mail and we will provide you with details to access your account. Acceptance of you as a Client is a no guarantee that any further account with us will be accepted.

5. General Terms & Conditions

Please read these Terms and Conditions completely and carefully before accessing and/or using our Online Trading Facility. You must read, agree with and accept all of the terms and conditions contained in this Agreement without modifications, which include those Terms and Conditions expressly set out below, and those incorporated herein by reference, before you may become a client of Antos Pinnacles.

Antos Pinnacles reserves the right to change these terms and conditions at any point without prior notice. If you do not agree with these terms and conditions, please exit this website immediately.

GENERAL DISCLAIMER

To the extent that the Company’s website as well as the information and services on it are provided free of charge, we will not be liable for any loss or damage of any nature. We shall be absolved from all liabilities in respect of:

  • Any losses arising out of any event or events beyond our reasonable control;
  • Loss or corruption of any data, database or software; and
  • Any special, indirect or consequential loss or damage.

You accept that we have an interest in limiting the personal liability of our officers and employees, and having regard to that interest, you acknowledge that you will not bring any claim personally against our officers or employees in respect of any losses you suffer in connection with the website.

OWNERSHIP OF WEBSITE

Antos Pinnacles owns and maintains this website. No act of downloading or otherwise copying from this website will transfer the title to any software or material from this website to you. Anything that you transmit to this website becomes the property of Antos Pinnacles, AND may be used by Antos Pinnacles for any lawful purpose.

The abovementioned actions are further subject to disclosure as deemed appropriate by Antos Pinnacles, including to any legal or regulatory authority that Antos Pinnacles is subject to. Antos Pinnacles reserves all rights with respect to copyright and trademark ownership of all materials on this website, and will enforce such rights to the full extent of the law.

ACCESS OF WEBSITE

This website and the information, tools and materials it contains are not directed to, or intended for distribution to or use by, any person or entity who is a citizen or resident of or located in any jurisdiction where such distribution, publication, availability or use would be contrary to law or regulation or which would subject Antos Pinnacles or its affiliates to any registration or licensing requirement within such jurisdiction. 

COPYRIGHT

The materials contained in the Company’s website, including but not limited to all design, text, videos, sound recordings and images, are owned, except as otherwise expressly stated, by Antos Pinnacles. Except as otherwise expressly stated herein, they may not be copied, transmitted, displayed, performed, distributed (for compensation or otherwise), licensed, altered, framed, stored for subsequent use, or otherwise used in whole or in part in any manner without Antos Pinnacles’s prior written consent.

DISCLAIMER OF WARRANTY AND LIMITATION OF LIABILITY

Any third party content on our Online Trading Facility is provided on an “As it is” basis, our third party content providers expressly disclaim all warranties of any kind, express or implied, including without limitation any warranty of merchantability, fitness for a particular purpose or non-infringement.

The third party content providers and their parents, subsidiaries, affiliates, service providers, licensors, officers, directors or employees shall not be liable for any direct, indirect, incidental, special or consequential damages arising out of or relating to the use or the inability to use the third party content, including but not limited to damages for loss of profits, use, data or other intangible damages, even if such party has been advised of the possibility of such damages.

Although the information provided to you on this website has been obtained or compiled from sources that we believe to be reliable, Antos Pinnacles cannot and does not guarantee the accuracy, validity, timeliness or completeness of any information or data made available to you for any particular purpose. Neither Antos Pinnacles nor any of its affiliates, directors, officers or employees, nor any third-party vendor will be liable or have any responsibility of any kind for any loss or damage that you incur in the event of any failure or interruption of this website, or resulting from the act or omission of any other party involved in making this website or the data contained therein available to you, or from any other cause relating to your access to, inability to access, or use of the website or these materials, whether or not the circumstances giving rise to such cause may have been within the control of Antos Pinnacles or of any vendor providing software or services support.

Under no circumstances will Antos Pinnacles be liable for any consequential, incidental, special, punitive or exemplary damages arising out of any use of or inability to use this website or any portion thereof, regardless of whether Antos Pinnacles has been apprised of the likelihood of such damages occurring and regardless of the form of action, whether in Contract, Tort (including negligence), Strict Liability, or otherwise.

The information on this website is intended for informational purposes only. Therefore, it should not be regarded as an offer or solicitation to any person in any jurisdiction in which such an offer or solicitation is not authorised, or to any person to whom it would be unlawful to make such an offer or solicitation, nor be regarded as a recommendation to buy, sell or otherwise deal with any particular investment. You are strongly advised to obtain independent investment, financial, legal and tax advice before proceeding with any investment. Nothing in this website should be read or construed as constituting investment advice on the part of Antos Pinnacles, or any of its affiliates, directors, officers or employees.

The nature of investment in Financial Instruments is such that not all Financial Instruments are suitable for everyone unless they:

  • Are knowledgeable in investment matters;
  • Are able to bear the economic risk of the investment;
  • Understand the risks involved; and
  • Believe that the investment is suitable for their particular investment objectives and financial needs.

Should any non-professional investor invest in Financial Instruments, it is advisable that only a part of the sums that the investor intends to invest for the long term should be so invested. It is also advisable for all investors to seek professional advice from a qualified investment advisor before investing in Financial Instruments.

ANALYTICAL TOOLS & MARKET DATA

Antos Pinnacles may sometimes provide various analytical tools (such as market data, exchange rate, news, headlines and graphs), links to other websites, circulate newsletter and/or provide you third parties information on our websites, for your convenience only. Antos Pinnacles has no control over the content of such non-Antos Pinnacles websites. As such, the Company makes no warranties, either express or implied, concerning the content of such websites, including the accuracy, completeness, reliability or suitability thereof for any particular purpose, nor does Antos Pinnacles warrant that such websites and their content are free from any claims of copyright, trademark, or other infringement of the rights of third parties or that such websites and their content are devoid of viruses or other such cyber risks.

Antos Pinnacles does not guarantee the authenticity of documents on the Internet. Links to non-Antos Pinnacles websites do not imply any endorsement of or responsibility for the opinions, ideas, products, information, or services offered on such websites, or any representation regarding the content on such websites.

SECURITY

If you plan to communicate with Antos Pinnacles by e-mail, you should note that the security of Internet e-mail is uncertain. By sending sensitive or confidential e-mail messages that are not encrypted, you accept the risks of such uncertainty and possible lack of confidentiality over the Internet. The Internet is not 100% safe and someone may be able to intercept and read your details.

PRIVACY

Any personal information you provide us will be treated as confidential and shared only between the Company, its affiliates and business partners and will not be disclosed to any third party, except under any regulatory or legal proceedings. You provide your consent to us to process all such information for the purposes of complying with our legal obligations, performing our contractual obligations and administering the relationship between you and us. Antos Pinnacles is the Data Controller for the purposes of all applicable Personal Data Protection Legislation. For all information regarding privacy and data protection as well as for the legal bases and purposes of the processing of your personal data and other relevant information.

Website tracking systems may also collect data detailing the pages you have accessed, how you discovered this site, the frequency of visits and so on. The information we obtain is used to improve the content of our website and may be used by us to contact you, by any appropriate means, and to provide you with any information that we believe may be useful to you.

APPLICABLE LAW AND JURISDICTION

By accessing this website, you agree that, in the event any of the Terms and Conditions shall be held to be unenforceable, the remaining Terms and Conditions shall be unimpaired and the unenforceable Term or Condition shall be replaced by such enforceable Term or Condition as comes closest to the intention underlying the unenforceable Term or Condition. This Agreement does not replace or in any way amend any other agreement you have entered into with Antos Pinnacles.

Details of Associations or Relationships

Antos Pinnacles has a relationship with its nominated Execution and Clearing Broker. This relationship in no way influences the provision of financial services by Antos Pinnacles.

Antos Pinnacles has relationships with its Liquidity Providers and Prime Brokers. These relationships may influence the information provided to Clients.