September 2026
1. INTRODUCTION
1.1 Elev8 Markets (the 'Company') is incorporated in Mauritius under company registration number C186509 and is licensed and regulated by the Financial Services Commission ('FSC') of Mauritius as an Investment Dealer (Full Service Dealer, excluding Underwriting) under licence number GB21027161. The Company is authorised under the Securities Act 2005 and conducts its business in accordance with the Financial Services Act 2007 and the applicable rules, codes and guidelines issued by the FSC.
1.2 This Policy explains the arrangements through which the Company seeks to obtain the best possible result when executing client orders. It applies to leveraged and over-the-counter ('OTC') products, including contracts for difference ('CFDs'), made available through MetaTrader 4, MetaTrader 5 and Elev8Trader (each a 'Trading Platform').
1.3 This Policy should be read with the Customer Agreement, Risk Disclosure, Conflict of Interest Policy, Customer Complaint Policy, contract specifications and trading conditions published on the Company's website. Where a capitalised term is not defined in this Policy, it has the meaning given in the Customer Agreement.
1.4 This Policy applies to clients who are classified as retail investors for the purposes of the Securities Act 2005. The Company categorises clients in accordance with the Customer Agreement, and the safeguards available to a client may differ depending on that categorisation.
1.5 By entering into the Customer Agreement, the client agrees to this Policy and expressly consents to the Company executing the client's orders otherwise than on a regulated exchange, multilateral trading facility or other trading venue—that is, on an over-the-counter basis with the Company acting as counterparty.
2. HOW THE COMPANY PRICES AND EXECUTES CLIENT ORDERS
2.1 When a client trades with the Company, the Company acts as principal and contractual counterparty. The client's transaction is entered into directly with the Company on an OTC basis and is not executed on a regulated exchange, multilateral trading facility or external market. The Company is the sole execution venue for orders covered by this Policy.
2.2 The Company may, at its discretion, hedge all or part of the net market exposure resulting from client transactions through separate transactions with third-party counterparties. Any such hedging is undertaken for the Company's own account and does not constitute the routing or external execution of a client order.
2.3 The Company uses Bid and Ask prices received electronically from its Liquidity Provider (LP). The LP supplies prices and is not an execution venue for client orders. The spread may vary depending on the product, account type and market conditions.
2.4 Prices displayed on a Trading Platform are indicative until an order is accepted and recorded as executed on the Company's trading server. The Company identifies, prevents or manages conflicts of interest through externally referenced pricing, automated processing, approved trading parameters, access controls, audit trails, monitoring and escalation arrangements. Where the Company's organisational or administrative arrangements are not sufficient to ensure the fair treatment of the client, the relevant conflict will be appropriately disclosed to the client in accordance with the Company's Conflict of Interest Policy.
2.5 The execution model may give rise to an inherent conflict of interest because the Company's financial interests may not always correspond with those of the client. The Company manages this conflict through externally referenced pricing, automated processing, approved trading parameters, access controls, audit trails, monitoring, and escalation arrangements, all under the Company's Conflict of Interest Policy.
2.6 A client buying a product transacts at the Company's Ask price, and a client selling a product transacts at the Company's Bid price. The difference between the Bid and Ask prices is the spread.
2.7 A CFD or other derivative transaction does not give the client ownership of, or any right to physical delivery of, the underlying asset.
3. BEST EXECUTION FACTORS
3.1 When executing an order, the Company considers the factors relevant to obtaining the best possible result for the client, including: (a) the available price and the total cost of execution, including the spread, commission, financing or swap charges and any applicable conversion charge; (b) speed and likelihood of execution; (c) the size and nature of the order and the characteristics of the product; (d) prevailing market conditions, including volatility, liquidity and price continuity; and (e) any other circumstance relevant to fair and orderly execution.
3.2 For a retail client, the best possible result is determined in terms of the total consideration, being the price of the product together with the costs of execution. Price and costs will therefore generally receive high importance. However, speed, likelihood of execution, order size, market conditions, or other factors may take greater importance where reasonably necessary to obtain the best possible result. Best execution does not guarantee execution at the most favourable price observable elsewhere at a particular moment.
4. CLIENT ORDER INSTRUCTIONS
4.1 Client orders are submitted through the trading functionality available on MetaTrader 4, MetaTrader 5 or Elev8Trader. The Company executes orders in accordance with the order type, volume, price parameters and other instructions supported by the relevant Trading Platform. The Company may be unable to accept instructions that fall outside the functionality or execution arrangements made available through those platforms.
4.2 Where the client gives the Company a specific instruction (for example, as to price, size, timing or order type), the Company will execute the order in accordance with that instruction so far as reasonably possible. A specific instruction may prevent the Company from taking the steps set out in this Policy to obtain the best possible result in respect of the elements covered by the client's instruction.
5. ORDER TYPES, SLIPPAGE, AND MARKET GAPS
5.1 Orders are submitted electronically, validated automatically and, under normal conditions, processed in the sequence in which they reach the Company's trading server. An order accepted by the Company is normally executed in full at the price available on the Trading Platform. The execution price may differ from the displayed or requested price due to market movements, price gaps, volatility, liquidity conditions, latency, or other circumstances affecting execution. Where an order cannot be executed in accordance with the applicable trading conditions, it may be rejected.
5.2 A market order is executed at the price available on the Trading Platform. A limit order will not be executed at a price worse than its specified limit. When a stop order, Stop Loss or stop-entry instruction is triggered, it is treated as a market order and may execute at the next available price. A Take Profit or other limit instruction remains subject to its specified limit.
5.3 Slippage is the difference between the price requested or displayed when an order is submitted and its execution price. Slippage may occur and may be positive, resulting in a more favourable execution price, or negative, resulting in a less favourable price, particularly during rapid price movements, market gaps, news events, market opening or closing, reduced market activity, network latency or disruption to pricing sources.
5.4 Spreads may widen during volatility, reduced market activity, rollover, market opening or closing periods, significant news, holidays, weekends, disruption to pricing sources or other exceptional conditions. The Company does not guarantee a particular execution time, but valid orders are processed automatically without undue delay under normal conditions.
5.5 The order types made available may include market orders, limit orders, stop orders, Stop Loss, and Take Profit instructions. The available order types and functionality may vary by product, account type, and Trading Platform.
5.6 Minimum and maximum order sizes, trading hours and other product-specific conditions may apply as stated in the relevant contract specifications or trading conditions. A pending order may be modified or cancelled by the client before execution, subject to the functionality of the relevant Trading Platform and prevailing market conditions. Once an order has been executed, it cannot ordinarily be modified or cancelled by the client.
5.7 Executed transactions are recorded on the Company's trading server and confirmed to the client without delay, electronically through the relevant Trading Platform. The transaction record may include the product, direction, volume, execution price and execution time.
6. ORDER REJECTIONS AND EXCEPTIONAL MARKET CONDITIONS
6.1 Exceptional market events or conditions may include unusually high volatility, significant price gaps, insufficient market activity, the suspension or closure of an underlying market, significant economic or political events, force majeure events, disruption or failure of pricing sources, technology or communication failures, or any other circumstance that prevents the Company from maintaining its normal pricing or execution arrangements.
6.2 An order or request may be rejected, cancelled, delayed or restricted where, for example, no valid price is available; a product is closed, suspended or in close-only mode; parameters are invalid; free margin is insufficient; an applicable volume or system limit is exceeded; a system, communication or pricing failure occurs; exceptional market conditions exist; or the account is restricted under the Customer Agreement, law or Company policy.
6.3 During exceptional conditions, spreads may widen, and the Company may reasonably adjust margin or leverage requirements, reject or delay new orders, suspend a product, apply close-only mode, cancel pending orders where permitted, or take other temporary measures necessary to protect clients, the Company or the integrity of its systems.
6.4 Positions may be closed automatically at the available price where the applicable stop-out level is reached. A transaction based on a manifestly erroneous price or affected by an objectively verifiable system or processing error may be investigated and corrected, cancelled or reinstated in accordance with the Customer Agreement.
7. MONITORING, REVIEW, AND PUBLICATION
7.1 The Company periodically assesses the effectiveness of its execution arrangements. Relevant indicators may include price-feed quality, spread behaviour, execution time, rejected orders, slippage, platform availability, manifest errors and execution-related complaints. Material incidents or adverse trends are investigated and escalated through the Company's governance arrangements. In particular, the Company assesses the quality and competitiveness of the prices received from its LP against appropriate market reference data as part of its best execution review.
7.2 This Policy will be reviewed at least annually and whenever a material change may affect the Company's ability to provide fair and consistent execution. The current version will be published on the Company's website, and material changes will be communicated in accordance with the Customer Agreement and applicable requirements.
7.3 Where the Company becomes aware of a material difficulty affecting the proper execution of client orders, the Company will take reasonable steps to address the difficulty and, where reasonably practicable, inform affected clients.
7.4 The Company keeps records sufficient to demonstrate compliance with this Policy, including records of client orders, execution data, the reference prices and data sources used, and the results of its monitoring, and retains such records for at least seven (7) years after completion of the relevant transaction, or for any longer period required by applicable law or the FSC requirements.
8. COMPLAINTS AND CONTACT INFORMATION
8.1 A client who is dissatisfied with the execution of an order may submit a complaint to complaints@elev8.com. The complaint should include the client's name, trading account number, affected order or transaction number, relevant date and time, a description of the issue, and the requested resolution.
8.2 Execution-related complaints will be handled in accordance with the Company's Customer Complaint Policy. When investigating a complaint, the Company may review server logs, platform records, reference prices, correspondence and other relevant evidence. If the client remains dissatisfied following the Company's final response, the client may refer the complaint to the Financial Services Commission of Mauritius through the complaint channel specified in the Customer Complaint Policy.
8.3 Registered address: Office 15, 1st Floor, CentrePoint, Trianon, Mauritius. Business address: 90 St Jean Road, Office No. 104, Palm Court Offices, 1st Floor, Quatre Bornes, Mauritius.