Order Execution Policy

This Order Execution Policy ("Policy") describes how we execute client orders and achieve best execution when placing or transmitting orders for execution in financial instruments on behalf of clients.

This Policy applies to all retail and professional clients trading foreign exchange (FX), contracts for difference (CFDs), and other leveraged products through our trading platform.

Our execution practices aim to obtain the best possible result for our clients, taking into account price, costs, speed, likelihood of execution and settlement, size, nature, and any other relevant considerations.

We access liquidity through multiple execution venues and liquidity providers to ensure competitive pricing and execution quality.

Primary Execution Venues: - Tier 1 banks and financial institutions - Electronic Communication Networks (ECNs) - Multi-lateral Trading Facilities (MTFs) - Our internal liquidity pool

We continuously monitor execution quality across all venues and may adjust our routing logic to optimize outcomes for clients. The selection of execution venue depends on factors including instrument type, order size, market conditions, and venue availability.

We maintain commercial relationships with liquidity providers and may receive rebates or commission sharing arrangements. These arrangements are disclosed in our fee schedule and do not influence our execution quality standards.

When executing client orders, we consider the following factors in order of priority:

1. Price - The quoted price for the instrument, including any markup or markdown

The relative importance of these factors may vary depending on: - Client classification (retail vs. professional) - Characteristics of the order (market vs. limit, size) - Characteristics of the financial instrument - Characteristics of the execution venues

For retail clients, the best possible result is determined in terms of total consideration, representing the price of the instrument and the costs related to execution.

We accept and process the following order types:

Market Orders - Executed immediately at the best available price. Market orders prioritize speed and likelihood of execution over price certainty.

Limit Orders - Executed at the specified price or better. Limit orders prioritize price over speed and may not be filled if the market does not reach the limit price.

Stop Orders - Converted to market orders when the stop price is reached. Stop orders are subject to slippage in fast-moving markets.

Stop-Limit Orders - Converted to limit orders when the stop price is reached. These orders provide price protection but may not be filled.

All orders are timestamped upon receipt and processed in sequence. However, we reserve the right to aggregate, split, or execute orders differently when doing so would be in the client's best interest or necessary for operational reasons.

Orders may be rejected or partially filled if: - Insufficient liquidity is available - The order size exceeds position limits - Technical issues prevent execution - Market conditions create excessive risk

We continuously monitor the quality of execution obtained for clients. This includes:

Daily Monitoring: - Price comparison across execution venues - Execution speed and fill rates - Slippage analysis for market orders - Rejection and partial fill rates

Quarterly Review: - Comprehensive assessment of execution quality by instrument class - Review of execution venue performance - Analysis of client complaints related to execution - Update of execution venue list if necessary

Annual Assessment: - Full review of this Policy and its effectiveness - Publication of top execution venues by volume and number of orders - Assessment of whether changes to execution arrangements are needed

Clients can request information about our execution quality and this Policy at any time. We will provide specific execution quality data upon reasonable request.

We may face conflicts of interest between our commercial interests and the duty to achieve best execution for clients.

Identified Conflicts:

Internal Execution: When we act as principal (counterparty) to client trades, we profit from the spread and may have an incentive to route orders internally rather than to external venues.

Payment for Order Flow: We may receive payments, rebates, or non-monetary benefits from execution venues or liquidity providers. These arrangements could influence routing decisions.

Proprietary Trading: We may engage in proprietary trading that could be adverse to client positions.

Mitigation Measures:

- Separation of proprietary trading from client order flow - Regular monitoring of internal vs. external execution quality - Disclosure of payment arrangements in fee schedules - Independent compliance oversight of execution practices - Price improvement policies that pass benefits to clients

Clients should be aware that despite these measures, conflicts may still affect execution quality. We encourage clients to monitor their execution quality and report concerns.

Clients may provide specific instructions regarding order execution. Where you provide specific instructions, we will execute the order in accordance with those instructions.

However, specific instructions may prevent us from taking the steps we have designed and implemented in this Policy to obtain the best possible result for your order. By providing specific instructions, you accept that we may not be able to achieve best execution for that order.

Examples of specific instructions: - Request to execute on a specific venue - Time-of-day execution requirements - Requirement to avoid certain types of venues - Instructions regarding aggregation with other orders

By using our services, you consent to this Policy and our execution arrangements. You may withdraw consent at any time, but this may require closing your account as execution under this Policy is integral to our service.

We will notify you of material changes to this Policy. Continued use of our services after notification constitutes acceptance of the updated Policy.