Purpose
When you trade environmental certificates — REGOs, RGGOs, GOs, I-RECs, carbon units or anything similar — execution quality matters as much as price.
This policy explains exactly how we:
- source pricing
- verify market levels
- execute trades
- avoid conflicts
- prove we act in your best interest
- ensure transparent, fair outcomes every time
No hidden spreads.
No selective quotes.
No “price games.”
1. Our execution principles
Every trade we perform follows five principles:
A. Fairness
All counterparties receive equal access to:
- pricing
- product information
- availability
- settlement timelines
No one receives preferential treatment that distorts the market.
B. Transparency
We tell you:
- what the price is
- what it includes
- what we earn
- how it was sourced
If anything affects price or execution, we disclose it.
C. Consistency
Trades are executed using:
- standardised processes
- standard confirmations
- verified data
- documented approvals
Consistency reduces errors and prevents manipulation.
D. Accuracy
We verify:
- serials
- volumes
- certificate type
- production period
- registry deliverability
- counterparty readiness
No trade is booked without full verification.
E. Integrity
We execute trades solely based on:
- your instructions
- your best interests
- market conditions
Not internal agendas, not “house positions,” not private order flow.
2. Best-price commitment
We commit to offering:
- the best price available to us
- sourced from a competitive, active market
- consistent with live liquidity
- verified before execution
We do not:
- inflate spreads
- add silent mark-ups
- favour our own positions
- hold back better prices for strategic reasons
- quote against stale or outdated markets
If the market moves, we update you.
If liquidity changes, we tell you.
If someone else is offering a better price for the same product, we will not pretend otherwise.
3. How we source prices
We gather pricing from:
- active counterparties
- direct registry-connected suppliers
- buyer interest
- bilateral markets
- verified brokers
- historical transaction data
- observable trades
We prioritise current, real liquidity over theoretical price models.
Prices must be:
- recent
- relevant
- based on actual bids/offers
- backed by deliverable volume
If we can’t verify the price as real, we don’t use it.
4. Execution process
1. We confirm your request
Volume, certificate type, period, max/min price, and delivery requirements.
2. We source real liquidity
Across our network, without favouring any party.
3. We present you with the best available price
Clean, all-in, transparent.
4. You agree or decline
No pressure, no games.
5. We execute immediately
Lock the price → book the trade → confirm via registry → issue trade confirmation.
6. We record everything
A complete audit trail is kept, including:
- timestamps
- quotes received
- quotes offered
- confirmation logs
- registry transfers
No part of the process is undocumented.
5. No front-running. No misuse of information.
We never:
- trade ahead of client orders
- use your instructions to position against you
- share your order intentions with others
- tilt execution to benefit a third party
- enter proprietary trades using knowledge of your interest
If we know you want a particular volume or period, that information remains confidential.
6. Margin transparency
We disclose:
- how we earn (fee, spread, or commission)
- how it is calculated
- whether it is fixed or variable
- any additional costs (registry, transfer, settlement)
There are no hidden charges.
No retroactive additions.
No surprises at settlement.
7. Error handling
Execution errors occasionally happen in any market.
When they do, we follow a strict process:
- Identify the error immediately
- Inform all relevant parties
- Correct the error transparently
- Adjust documentation accordingly
- Implement internal checks to prevent repeat issues
We never conceal or minimise errors.
8. Conflicts of interest
Our conflict controls include:
- separating internal roles (trading vs compliance)
- pre-trade and post-trade checks
- independent oversight
- restrictions on proprietary trading
- mandatory conflict disclosures
If we believe a conflict exists, we tell you before the trade — not after.
9. Documentation
We use clear, standardised documentation for every trade:
- trade ticket
- confirmation
- invoice
- delivery record
- settlement proof
- registry evidence
If anything looks unclear, we rewrite it immediately.
10. Ongoing review
We regularly review:
- pricing sources
- execution speed
- settlement accuracy
- counterparty feedback
- audit logs
- market conditions
Weaknesses are corrected, not excused.
Why this matters
Execution is where trust is won or lost.
Our process ensures:
- clean trades
- fair pricing
- transparent margins
- no hidden agendas
- strong audit trails
- equal treatment
- predictable outcomes
Exactly what you want from a certificate-trading counterparty.