Monolith Market — Operated by Monolith Private Wealth Limited
1. What Is This Notice?
Monolith Private Wealth Limited (“MPW”, “we”, “us”) operates the Monolith Market trading platform and is licensed by the Financial Services Commission of Mauritius as an Investment Dealer (Full-Service Dealer, excluding Underwriting) and an Investment Adviser (Unrestricted) under the Securities Act 2005.
This Notice summarises how MPW seeks to achieve the best possible result for you when handling and executing your orders — a standard known as “best execution”. It is derived from MPW’s full Best Execution Policy, which is available on the Monolith Market platform and on request free of charge. By opening an account and placing orders through Monolith Market, you acknowledge and consent to this Notice and to the full Policy.
2. Our Best Execution Obligation
MPW is required under the FSC Code of Business Conduct (Guiding Principles 1 and 4) and the Securities Act 2005 to take all sufficient steps to obtain the best possible result for you when executing or transmitting your orders. Best execution applies across all of the following activities:
- Executing your orders on the Monolith Market platform;
- Transmitting your orders to external execution venues or liquidity providers;
- Providing investment advice or managing your portfolio under a mandate where MPW also handles the execution leg; and
- Intermediating in securities transactions on your behalf.
Important: Best execution is an obligation to take all sufficient steps — it is not a guarantee that the absolute best price will be achieved on every single order, particularly during periods of market volatility, low liquidity, or gapping.
3. How We Determine Best Execution
When handling your order, MPW considers the following execution factors and their relative importance based on your client classification (Retail Investor or Sophisticated Investor), the type of order, the financial instrument, and the available execution venues.
| Execution Factor | What it means for your order |
|---|---|
| Price | The price at which your order is or can be executed. |
| Costs | All direct and indirect costs to you, including venue or clearing fees, financing charges on leveraged positions, and any mark-ups applied to spreads. |
| Speed | How quickly your order is executed — particularly important in fast-moving markets. |
| Likelihood of Execution and Settlement | The probability that your order will be filled in full and that the resulting trade will settle normally. |
| Order Size | How the size of your order relative to available liquidity may affect the price and fill rate. |
| Nature of the Order | The type of order (market, limit, stop, conditional) and the characteristics of the instrument. |
| Other Considerations | Settlement arrangements, venue availability, operating hours, and any other factor relevant to achieving the best result in your interest. |
Retail Investors for Retail Investors, MPW’s primary criterion is total consideration — that is, the execution price combined with all costs directly related to the order. Other factors are applied only where they are instrumental in improving total consideration. MPW does not depart from the total-consideration criterion for retail orders without documented justification.
Sophisticated Investors for Sophisticated Investors, MPW may take a broader range of factors into account and may, with your prior express agreement, prioritise factors other than total consideration where this better serves your interests — for example, prioritising certainty of execution on a time-sensitive large order. Total consideration nonetheless always remains a material consideration.
4. Where and How Your Orders Are Executed
MPW routes your orders to external execution venues and liquidity providers selected and monitored by MPW’s Trading and Compliance functions. Venue selection is based on the quality of execution the venue can achieve for you across all relevant execution factors, including its pricing, reliability, settlement efficiency, and overall performance record.
MPW monitors venue performance on an ongoing basis — first line by the Trading function on a daily basis and second line by the Compliance function monthly. Venue arrangements are reviewed at least quarterly. MPW will update its venue list and routing arrangements where monitoring indicates that a change would improve execution quality for clients.
A list of the principal execution venues and liquidity providers used by MPW is available in the full Best Execution Policy on the Monolith Market platform. MPW will notify you of any material change to its execution venue arrangements.
5. Your Right to Give Specific Instructions
You may give MPW a specific instruction regarding how your order should be executed — for example, requesting execution at a particular venue or at a specific price limit. Where you do so, MPW will follow your instruction. Compliance with a specific instruction satisfies MPW’s best execution obligation in respect of the elements of your order covered by that instruction.
Note: A specific instruction may limit MPW’s ability to take all of the steps it would otherwise take to obtain the best possible result. MPW will never encourage or induce you to give a specific instruction that is against your interests.
6. Costs and Charges
All fees, commissions, spreads, and other charges applicable to your orders are set out in the Costs and Charges Schedule, which is available on the Monolith Market platform. When assessing best execution, MPW takes the all-in cost of trading into account, not only the quoted instrument price. You are entitled to receive a clear statement of all costs associated with your transactions before you trade and, where applicable, on a periodic basis thereafter.
7. Order Handling Protections
MPW applies the following protections when handling your orders:
- Aggregation — where MPW aggregates your order with orders from other clients or with firm orders, it will do so only where aggregation is unlikely to disadvantage you, and it will allocate the resulting execution fairly.
- Comparable limit orders — if you place a limit order in an equity or equity-like instrument that is not immediately executable, MPW will take steps to facilitate the execution of that order as soon as market conditions permit, unless you instruct otherwise;
- Prompt and fair handling — your orders are handled promptly and equitably relative to orders from other clients;
- No misuse of order information — MPW does not use information about your pending orders for the benefit of the firm or any other client.
8. Special Market Conditions
During periods of market disruption, extreme volatility, or abnormal liquidity conditions, MPW may adjust its execution arrangements — including widening quoted spreads, temporarily restricting certain order types, or suspending acceptance of new orders in affected instruments. MPW will communicate any such measures through the Monolith Market platform where practicable. In all circumstances, MPW continues to act in your best interests and in accordance with applicable FSC requirements.
9. Monitoring and Reporting
MPW monitors the quality of execution achieved on your behalf on an ongoing basis. At least annually, MPW prepares a report identifying the top execution venues used for each class of financial instrument and summarising key execution quality data. This report is approved by the Compliance Officer and is made available to you upon request.
MPW’s full Best Execution Policy is reviewed at least annually and updated whenever there is a material change in applicable Mauritius law or FSC regulation, in the firm’s products or business model, or where monitoring indicates that the policy or its implementation requires adjustment. You will be notified of any material change in good time before it takes effect.
10. Questions and Complaints
If you have questions about how MPW handles or executes your orders, or if you wish to request a copy of the full Best Execution Policy or the annual execution quality report, please contact MPW’s Compliance Department through the contact details on the Monolith Market platform.
If you believe that MPW has not met its best execution obligations in respect of a specific order, you may raise a complaint through MPW’s Complaints Handling Procedure. Complaints may also be referred to the Ombudsperson for Financial Services under the Ombudsperson for Financial Services Act 2018, or escalated to the FSC.
Regulatory Notice
This Notice has been prepared by Monolith Private Wealth Limited in compliance with its obligations under the Securities Act 2005 and the FSC Code of Business Conduct. It is a summary document. The full Best Execution Policy is the governing instrument for all order handling and execution activity.
This Notice does not constitute investment advice or a guarantee of any specific execution outcome. In the event of any conflict between this Notice and the full Best Execution Policy, applicable Mauritius law, or the FSC’s rules, those instruments shall prevail.