1.Purpose

The purpose of this policy is to establish effective arrangements for obtaining the best possible result for its clients, when executing clients’ orders.

This document aims to set out those arrangements and to ensure compliance with legislative requirements and the departmental and general procedures which are set within this Internal Procedures Manual.

This Policy applies when receiving and transmitting client orders or executing orders made by the client for all the types of Financial Instruments (e.g. Binary Options) offered by the Company.

2.Legal Framework

In accordance with the Investment Services and Activities and Regulated Markets Law of 2007, CIFs must take all reasonable steps to obtain, when executing orders, the best possible result for their clients taking into account price, costs, speed, likelihood of execution, size, nature or any other consideration relevant to the execution of the order. Nevertheless, whenever there is a specific instruction from the client, the CIFs shall execute the order following the specific instruction.

In addition, CIFs must establish and implement an order execution policy to allow the CIF to obtain, the best possible result.

3.Policy

Dealing Room is the relevant department to which the order execution policy mainly applies. Senior Management reviews the policy on an annual basis or / and whenever a material change occurs that impacts the Company’s ability to continue offering the best execution of its clients’ orders using the Company’s trading platform.

The Company proceeded to the establishment and maintenance of an Order Execution Policy, in order to ensure compliance with the obligation to execute orders on terms most favourable to the clients and to achieve the best possible results for its clients, taking into consideration its clients’ ability, needs and trading policies, where applicable and possible.

The policy outlines the process that the Company follows in executing trades, taking all reasonable steps to consistently obtain the best possible result for clients through this Policy. It is noted however that when executing an order following a specific client instruction, the Company will execute the order in line with those instructions and will consider that it has discharged its best execution obligations.

3.1. Best Execution Criteria

The Company will take into account the best execution criteria for determining the relative importance of the execution factors:

• The characteristics of the client
• The characteristics of the client order
• The characteristics of the financial instruments that are the subject of that order
• The characteristics of the execution venues to which that order can be directed.

The best possible result will be determined in terms of the total consideration, representing the price of the contract and the cost related to execution. The other execution factors of speed, likelihood of execution size, nature or any other relevant consideration will, in most case, be secondary to price and cost considerations, unless they would deliver the best possible result for the client in terms of total consideration.

3.2. Execution Factors

The Company, when managing client’s orders takes into account various execution factors, provided that there are no specific instructions from the client to the Company about the way of execution of the orders. The execution factors include:

• Price
• Speed and likelihood of execution
• Costs or commissions
• Size and nature of the order
• Market conditions and variations
• Execution capability
• Any other direct consideration relevant to the execution of the order

3.3. Specific Instructions

In circumstances where the client provides the Company with a specific instruction as to how to execute an order and the Company has accepted this instruction, then the Company will execute the order in accordance with that specific instruction.

Nevertheless, if the client provides a specific instruction to carry out an order, then by executing that order the Company will be complying with the Company’s duty to provide the client with best execution. This may result in being unable to follow the Company’s Order Execution Policy for that particular order.

3.4. Execution Venues

In particular, the client deposits funds with the Company and places an order via a trading platform and the Company is responsible for the safeguarding of clients’ funds in segregated accounts. Upon receipt of the order, the Company opens an identical order in its name with the market maker, per order received or accumulatively. In this respect, the Company executes the client‘s order by acting as a riskless principal (i.e. enters into true back to back trades).

3.5. Pricing

The Company will provide its own tradable prices which are derived from independent price providers. The main way in which the Company will ensure that the client receives the best execution will be to ensure that the price provision to the client is made with reference and compared to a range of underlying price providers and data sources.

At an initial stage, the Company’s trading platform is integrated with the following price providers:

• SpotOption Exchange Limited

The provider is continuously updating its prices, therefore the latest updated prices are displayed on the Company’s trading platform.

The price for a given type of Binary Option is calculated by reference to the price of the relevant underlying asset, which the Company obtains from third party external reference sources.

All orders in Binary Options with the Company are executed as Market Orders i.e. at the best available market price. Therefore the execution/target price as well as closing/expiration prices of orders in Binary Options can take a value between the Bid and the Ask price of the underlying reference price at the time of execution or expiration of the binary option.

3.6. Costs

The Company does not charge fees of commission for the clients’ orders or their execution.

3.7. Size of order

All orders are placed in monetary value. The client will be able to place his order as long as he has enough balance in his trading account. If the client wishes to execute a large order, in some cases the price may become less favourable considering the feed obtained from its price provider.

3.8. Speed

Obviously, prices change over time. The frequency with which they do so varies with different financial instruments and market conditions. Considering that the tradable prices which are distributed via the Company’s trading platform/terminal, technology used by the client to communicate with the Company plays a crucial role. For instance, the use of a wireless connection, or dial up connection, or any other communication link that can cause a poor internet connection can cause unstable connectivity to the Company’s trading platform/terminal. The result for the client is to place his orders at a delay and the order to be executed at better or worst prevailing market price offered by the Company via its platform/terminal.

3.9. Nature of the order

The particular characterizing of an order depends on the Binary option to be selected by the client. The value of the option is mainly dependent on the volatility of the underlying instrument, the set time of option expiration and the risk management to be selected by the client.

3.10. Likelihood of execution

Due to the levels of volatility affecting the underlying instrument’s price, the Company seeks to provide client orders with the fastest execution reasonably possible. The likelihood of execution depends on the availability of prices of other market makers/financial institutions. In some cases it may not be possible to arrange an order for execution. In the event that the Company is unable to proceed with an order with regards to price or size or other reason, the order will not be executed.

3.11. Likelihood of settlement

The Company shall proceed with the settlement of all transactions upon the execution and/or time of expiration of the specific transaction.

3.12. Market Impact

The Company’s quoted prices which are derived from its independent price providers may be affected by various factors which could also affect the abovementioned factors. The Company will take all reasonable factors to ensure the best possible result for its clients.

3.13. Conclusion

Appropriate information is provided to the client on the content of the execution policy. The prior consent of the clients is obtained regarding the documented order execution policy to be followed. In addition, a clear and prominent warning is disclosed to the Company’s clients (within the Client Agreement) that any specific instruction from a client may prevent the Company from taking the steps that is has designed and implemented in its execution policy for obtaining the best possible result for the execution of those orders in respect to the elements covered by those instructions.

Adequate information is provided to the clients through this policy in relation to the factors that are taken into consideration by the management when handling clients’ orders. Also, the policy is reviewed periodically by the Company and the clients are informed accordingly in relation to any material changes.