Best Execution
RTS 28 – Annual Publication
Class of Instrument Contracts For Differences (CFDs)
Notification if <1 average trade per business day in the previous year N
Top five execution venues ranked in terms of trading volumes (descending order) Proportion of volume traded as a percentage of total in that class Proportion of orders executed as percentage of total in that class Percentage of passive orders Percentage of aggressive orders Percentage of directed orders
(213800FDA9H1T5HTLC19) 79.06%  43.91%  66.69%  20.74%  0%
 (213800FIDYGIQ9SJPK78) 20.94%  56.09%  33.31%  79.25%  0%


Midtou, when executing trades on behalf of our clients, gives importance to price, speed, and likelihood, which are the main factors taken into consideration for the execution venues (liquidity provider) that are used. Our main target in any liquidity provider is to have the best bids and offers prices without any delay and their speed of execution. Midtou also ensures that the connection between both ours and the liquidity provider’s systems never goes down and there is a 24/5 support to help fix any issue. Midtou can also confirm that there are no close links, conflicts of interest and common ownerships with respect to any of the liquidity providers used to execute orders.

Midtou has agreements in place with liquidity providers to firstly obtain their prices, and secondly to transmit orders to them. Depending on the specific nature of the agreements, there are instances where Midtou would pay a monthly fee to the liquidity providers, unless a certain volume of orders are sent, whereby for which Midtou will be paid rebates and it will be deducted from the monthly fee paid. As part of a regular review, Midtou can make the decision to disconnect or discontinue with a liquidity provider, if we notice that the prices are delayed, or the spread is not competitive or faces technical issues on a regular basis.

Midtou currently uses an in house tool called ‘Electronic Communication Network (ECN)’ which is an automated system that matches buy and sell orders, taking into account the best possible prices and the speed of the executions. The ECN allows Midtou, to ensure that when transmitting orders on to liquidity providers, that it is achieving the best possible outcome for its clients.