Order execution policy

This Order Execution Policy forms part of the Client Agreements as defined in the User Agreement

1. CONDUCTING BUSINESS

1.1. We have a general duty to conduct business with you honestly, fairly, and professionally and to act in your best interests when executing orders. More specifically, when we execute orders on your behalf we will provide you with "best execution", that is, we will operate according to procedures which we have established in order to take reasonable steps to obtain the best possible result for our clients on a consistent basis.

1.2. By agreeing to the terms of our User Agreement, you are also agreeing to the terms of this Order Execution Policy ("Policy").

2. INSTRUMENTS

2.1. We execute orders for cryptocurrency trading and mining contracts.

3. DUTY TO GIVE THE BEST EXECUTION

3.1. When executing your orders, we will take all reasonable steps to achieve the best possible outcome for you by executing those orders according to this Policy and subject to any specific instructions received from you. This Policy comprises a set of procedures that are designed to obtain the best possible execution result, subject to and taking into account the nature of your orders, the priorities you have identified to us in relation to filling of those orders and the practices relating to the market in question with the aim of producing a result which provides, in our view, the best balance across a range of sometimes conflicting factors. Our Policy cannot provide a guarantee that, when executing an order, our price will always be better than one which is or might have been available elsewhere.

4. DETERMINING WHETHER WE OBTAIN THE BEST EXECUTION FOR YOU

4.1. We act as principal in all dealings and as the sole execution venue for your orders which are not executed on a regulated exchange or multilateral trading facility. We are required to take a number of factors into account when considering how to deliver best execution. We have rated price as the most important followed by:

4.1.1. Cost;

4.1.2. Size;

4.1.3. Liquidity of the underlying market;

4.1.4. Speed;

4.1.5. Likelihood of execution and settlement.

We provide best execution by ensuring that in arriving at our bid/offer prices we use the market price for the underlying product to which your order relates. We have access to a number of different data sources in order to generate our market price, that is, our objective view of the bids and offers available to arm's' length traders.

5. SPECIFIC INSTRUCTIONS

5.1. Where you give us specific instructions with your order, including specifying the price of a transaction with us, or the price at which a transaction is to be closed if the market moves against you, those instructions take precedence over other aspects of this Policy. A transaction for which a trailing stop or other limit has been set will be closed at that level if the limit or stop price is reached.

5.2. Generally, cryptocurrency trading contracts have no expiry date, however, should a transformation event be announced based on a takeover or a re- organisation, the date of the event may be used as the expiry date.

6. NO JOINT ORDERS

6.1. We will not combine your order with those of other clients for execution as a single order.

7. MONITORING AND REVIEW OF OUR ORDER EXECUTION POLICY

7.1. We will monitor the effectiveness of our order execution arrangements and this Policy. We will assess from time to time whether the venues relied upon by us in pricing our transactions allow us to meet our regulatory obligations on a consistent basis or whether we need to make changes to our execution arrangements or this Policy. Should there be any material changes to our order execution arrangements or this Policy, we will notify you.

8. CONTRACT DETAILS

8.1. Full details of the trading conditions are available through the details link for each instrument on the TradeMux Trading Platform.

9. NO FIDUCIARY DUTY

9.1. We provide you with access to the TradeMux Trading Platform and are not acting in any other capacity including as a fiduciary.

9.2. Our commitment to provide you with "best execution" does not mean that we owe you any fiduciary responsibilities over and above the specific regulatory obligations placed upon us or as may be otherwise contracted between us.

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