1. Purpose of the Policy

In accordance with applicable laws, Investium Limited (referred to as "the Company," "we," "our," and "us") is mandated to establish an Order Execution Policy and to undertake all necessary measures to achieve the best possible outcome (best execution) for its Clients. This Order Execution Policy outlines the methods by which we will fulfill our best execution obligations when executing orders for our Clients. It is important to note that this Policy does not impose any fiduciary responsibilities or duties beyond the specific regulatory obligations imposed on us or as may be contractually agreed upon between us and our Clients.

Our Order Execution Policy applies when executing orders from you to trade in any of the Financial Instruments offered by us, including (but not limited to) Shares, Fractional Shares, Exchange Traded Funds (ETFs), Exchange Traded Notes (ETNs), and Exchange Traded Commodities (ETCs).

Subject to any specific instructions provided by you, we will strive to achieve the best possible result for you, taking into account the Execution Factors outlined below. The application of best execution, especially in cases where the Company engages with a Client based on a request for quote basis, shall depend on whether the Client "legitimately relies" on the Company to safeguard their interests regarding pricing and other elements of the transaction. These factors include speed or likelihood of execution and settlement, which may be affected by the choice made by the Company when executing the Order. What constitutes best execution will vary with the circumstances of the Order and the preferences of the Client.

We have assessed the relative importance of the Execution Factors in accordance with our legal and regulatory duty to ascertain the best possible result in terms of total consideration, which encompasses both the price of the financial instrument and the associated execution costs.

2. Execution Factors

We have established that the order of importance of the execution factors remains consistent across all Company’s products and markets. For all Retail Clients, we prioritize achieving the best possible result based on the total consideration, which encompasses both the price of the financial instrument and the associated execution costs. Annex 1 provides a list of all execution factors per relative importance.

Price:

For all financial instruments offered by the Company, we provide two quoted prices: the higher price (BUY), which allows you to purchase the instrument, and the lower price (SELL), which enables you to sell it. These prices are determined based on the value of the relevant underlying financial instrument.

The Company's prices are accessible through the Application. These prices are updated as frequently as technology and communication limitations permit, but they should be regarded as an indication of the live market price rather than a formal quotation. The quantity and price of shares provided are indicative and may differ at the execution of Market Orders. Such variations in the indicative price may occur due to factors including, but not limited to, fluctuations in foreign exchange markets between the Order placement and execution times. Similarly, delays between placing an Order and its execution may also lead to price discrepancies.

The Application may display the target profit in the currency of your account. However, please note that this information is indicative and not guaranteed. The Company regularly reviews its third-party external reference sources to ensure the data obtained is as timely and accurate as possible. When the price reaches a level set by you for an Order, such as Stop, Take Profit, Market Order, or Limit Order, these Orders are executed promptly. Nonetheless, under certain trading conditions, there is a possibility that these Orders may not be executed at your requested price.

In such instances, the Company reserves the right to execute the Order at the first available price. This scenario may arise during periods of rapid price fluctuations, such as when the price rises or falls significantly within a single trading session, leading to trading suspension or restriction as per the rules of the relevant exchange. Such fluctuations can result in the receipt of a price that is either better or worse than anticipated. Similarly, this situation may occur during periods of thin liquidity.

When a trade is executed outside of a regulated trading venue, such as for Fractional Shares, the Order will be filled at a price no worse than the reference price on the reference exchange.

Costs:

The Company does not impose any commission charges or additional spreads on execution prices. However, it does apply FX conversion costs when purchasing securities in a currency different from your deposit currency. These fees are transparent and visible to you before the point of sale, as they fluctuate in accordance with the relevant underlying spot market. Additionally, other relevant fees, such as those related to stamp duty or local tax regulations, are applied in adherence to the governing body's regulations. These fees are also visible within the Application before trading.

All costs associated with any execution, as determined by the Company, are transparently detailed within the Application. These costs are not contingent upon any priority criteria chosen by the Company or the execution method.

Speed of Execution:

We define speed as the efficiency with which we process your Order. If your instructions specify a particular rate at which we should process your order, we will adhere to your instructions unless there is an immediate and significant conflict with the price. In cases where your instructions do not specify a speed, we will process your Order at a rate that we deem strikes a balance between minimizing market impact and executing your order promptly, thereby reducing execution risk.

Transaction Size and Nature:

All transaction executions are subject to size considerations. If the requested transaction size exceeds the Company's capacity to trade in the underlying market on the relevant exchange at that moment, the entire transaction or order may be restricted or rejected. Each market quoted by the Company has an absolute minimum and maximum permitted transaction size. The maximum transaction size may vary depending on market conditions and is always at the discretion of the Company.

Likelihood of Execution and Settlement:

In almost all cases, your transaction requests will be automatically executed at the specified level or prevailing market level in the case of a Market Order request, provided the requested size is equal to or under the size permissible by the Company at that time.

To minimize the likelihood of rejections, the Company applies maximum Client Order sizes aligned with the typical liquidity of the underlying instrument or security, ensuring a high execution rate.

However, in certain circumstances—such as due to internet communication speed, market volatility, or erroneous price submissions—the Company may reject transactions if the price requested by you does not reflect the underlying market price upon receipt by the Company.

Alternatively, the Company may opt for a partial fill of a transaction request instead of outright rejection. If an Order can only be partially executed due to various reasons or applicable limits, you authorize us to use all reasonable efforts to execute that part of the Transaction.

When assessing the importance of other factors (such as speed, likelihood of execution and settlement, the size and nature of the Order), the Company will exercise discretion in evaluating the criteria necessary to provide Clients with the best result. The relative importance of these criteria will be judged based on the total consideration, representing the price of the financial instrument and the costs relating to execution, and with regard to market conditions, including the need for timely execution, availability of price improvement, liquidity of the market, size of your Order (which may affect execution), and potential impact on total consideration. In certain circumstances, therefore, the Company may prioritize speed and likelihood of execution and settlement over immediate price and cost factors if they are crucial in achieving the best possible result. This scenario may occur, for instance, for Orders in illiquid shares or when a stop has been triggered.

3. Transparency of Pricing

In executing your Orders, the Company does not receive any remuneration, discount, or non-monetary benefit for routing Client Orders to a particular Trading or Execution Venue, which would violate any conflicts of interest or inducement requirements under MiFID II.

However, in the event that the Company receives such inducements, they may be accepted only if they are intended to enhance the quality of the relevant service to the Client and do not compromise compliance with the Company’s duty to act honestly, fairly, and professionally in accordance with the best interests of its Clients. The Company charges fees only as outlined in the Company’s Terms and Conditions, or as may be otherwise agreed upon between the Company and you.

4. Algorithmic Trading

The Company does not rely on algorithmic trading systems to consistently achieve the best possible result for the execution of your Orders.

5. Execution Criteria

The Execution Criteria considered include:

a. the Client, including its categorization;

b. Order specifications;

c. Attributes of the Financial Instruments involved in the Order; and

d. Available Execution Venues for directing the Order.

To ensure comprehensive coverage, the Company has classified all clients as Retail and extends best execution practices to all clients accordingly.

6. Execution Venues

For all transactions except in some instances the ones involving Fractional Shares, the Company may act as an agent and direct your Orders to one of its designated brokers, who will execute them at any of the available venues. As part of its post-trade notification process, the Company will always notify you of where the transaction has been executed.

The Company may act as an internaliser on a non systematic basis for Client Orders related to Fractional Shares.

The Company prioritizes price and execution costs (total consideration) as the primary factors for its Clients, considering them to be the most crucial elements in most cases. However, it also takes into account the impact of other execution factors, such as speed of execution and the probability of Order acceptance, across various markets and Order types.

The Company also takes into account the financial stability and order execution policies of any counterparty or venue.

For clarity, our Order Execution Policy stipulates that the Company may execute client transactions in Fractional Shares outside of regulated markets or MTFs. This approach aims to consistently secure the best price for your Orders. However, it also entails higher counterparty and settlement risks compared to trading on exchanges. More details regarding these risks are available in the Risk Disclosures Notice.

The Company directs client Orders to various executing venues to ensure the best possible execution results. These venues may change at the discretion of the Company and may include regulated markets, multilateral trading facilities (MTFs), executing brokers, and other liquidity providers. An indicative list of the execution venues, which the Company significantly relies on, will be published on the Order Execution Policy page of the Website and will be updated at least annually.

Periodically, the Company reviews the execution venues it utilizes, taking into account factors such as the firms' reputation, the accessibility of liquidity pools, regulated markets, and MTFs through the venue, and the utilization of smart Order routing technologies to source the best available prices.

7. Trading outside a Regulated Market, Multilateral Trading Facility (MTF), or Organised Trading Facility (OTF)

In accordance with CySEC regulations, if an instrument is listed on a Regulated Market, MTF, or OTF, we are obligated to obtain your explicit consent before executing an Order for such instruments at an alternative venue. By agreeing to our Terms and Conditions, you provide consent for us to execute your Orders outside of these venues.

Orders executed outside of Regulated Markets, MTFs, or OTFs will adhere to our Best Execution Policy and should not put you at a disadvantage. When executed in this manner, all Market Orders in equity instruments will be executed at the best available price on the primary trading venue of the relevant financial instrument, nearly or at 100% of the time.

Trades conducted off-exchange will be filled at a price no worse than the prevailing best Bid/Offer on the reference exchange.

For transactions executed outside of a Trading Venue, specific transparency requirements must be met, and relevant information must be made public. This information will be disseminated via an Approved Publication Arrangement.

8. Execution arrangements involving connected parties

The Company does not execute Orders with connected parties (e.g., an entity within the same group).

9. Aggregation

The Company will not aggregate your Order with another Client’s Order unless the following conditions are met:

a. It is determined that the aggregation will not result in an overall disadvantage to any Client whose Order is to be aggregated.

b. Each Client whose Order is to be aggregated has been duly informed that aggregation may potentially work to their disadvantage concerning a specific Order, as stipulated in the Company’s Terms and Conditions.

c. The aggregation of Orders will adhere to this Policy, which aims to ensure equitable allocation of aggregated Orders and transactions. This includes defining how volume and price of Orders influence allocations, as well as outlining procedures for handling partial executions.

10. Allocation Policy

In compliance with applicable laws, the Company is committed to providing you with timely, equitable, and efficient execution of Orders relative to other Orders from its Clients. To fulfill this commitment, the Company:

a. promptly and accurately records and allocates Orders executed on behalf of Clients;

b. sequentially and promptly executes comparable client Orders, unless impractical due to the characteristics of the Order or prevailing market conditions, or if the Client's interests necessitate otherwise; and

c. promptly informs Clients of any significant difficulty relevant to the proper execution of Orders upon becoming aware of such difficulty.

11. Ensuring Best Execution

As the manufacturer of Fractional Shares, the Company provides its quotes to conform to the Firm’s specific product terms. To fulfill its best execution obligation to you, the Company ensures that in providing market prices, due consideration is given to the market price for the given financial instrument. The Company subscribes, via its data vendor, to multiple price feeds, including those from nominated wholesale market participants and regulated markets/exchanges, to identify the market price of financial instruments. Periodically, the Company reviews the list of exchanges used for sourcing the best market prices to ensure access to the best available price.

Due to the inherent nature of online trading platforms, when you issue a trade instruction via the Application, quotes are provided to you on an indicative basis. Upon receiving the Order request, the Company verifies the Order terms (price, quantity, direction) against live bid/offer quotes to facilitate execution. In instances of price slippage occurring between the time of trade instruction and execution, the Company employs symmetric price slippage, meaning both positive and negative slippage will impact the execution price.

When the Company receives specific instructions from you regarding how to execute an Order, such as with Limit Orders, it fulfills its obligation to take all necessary steps to achieve the best possible result by adhering to those instructions. Specific instructions may override this Policy. In cases where specific instructions do not cover all aspects of the Order, such as with Market Orders, the Company applies this Policy to those parts or aspects of the Order not addressed by your instructions.

In standard market conditions, the Company consistently places the highest priority on price, including all associated costs (total consideration), when striving to achieve the best outcome for you. The Company diligently monitors the market and its participants, including their fee structures, and adjusts its procedures accordingly upon detecting any signs of change concerning best execution.

In the event of system failures or exceptional market conditions, deviations from these execution principles may be necessary in rare instances. However, even under such circumstances, the Company will exert every effort to achieve the best possible result for you.

Market conditions can impact the timing of order execution for all order types, including Limit Orders, Stop Orders, and Market Orders. Orders are executed in due sequence, but we cannot guarantee execution of a Limit Order or a Stop Order even if the Limit or Stop Price is reached. We do not assume liability for any actual or potential loss resulting from execution delays. Market conditions might cause execution of a Stop Order at a price above or below the Stop Price. Additionally, we reserve the right to impose temporary or permanent restrictions on certain types of Orders (e.g., Limit Order, Stop Order, and/or Market Order) for specific or all Investments.

12. Monitoring

Monitoring is a fundamental aspect of our operations, ensuring the effectiveness of our order execution arrangements and adherence to our Order Execution Policy. We are obligated to conduct regular monitoring to identify and promptly address any deficiencies. This process ensures that our performance aligns with the standards outlined in our Policy.

Furthermore, independent assessments of our order execution procedures are conducted by our internal auditors to provide assurance regarding their effectiveness.

13. Review

The Company is committed to assessing whether the execution venues outlined in this Order Execution Policy continue to deliver the best possible results for you. We undertake to review our order execution arrangements and this Policy at least annually, or whenever a material change occurs that could affect our ability to consistently achieve the best execution outcome using the venues specified herein.

For the purposes of this Policy, a material change is defined as a significant event that could potentially impact key parameters of best execution, including cost, price, speed, likelihood of execution and settlement, as well as the size, nature, or any other relevant consideration pertaining to order execution.

Such material changes encompass various factors, including but not limited to:

a. Addition or removal of Execution Venues or brokers;

b. Changes in products or services offered by the Company;

c. Alterations in the relative importance of best execution factors and criteria;

d. Material market impact;

e. Significant changes in costs resulting from connection to a venue;

f. Introduction of significant new execution procedures or alterations to the market model of an existing venue;

g. Major modifications to existing arrangements, such as substantial changes in the human or technical resources relied upon by the Company for providing best execution;

h. Client complaints regarding major issues (although this may not necessarily trigger a review of the entire Policy).

14. Fractional Shares

A Fractional Share refers to an investor’s purchase of less than a whole share. An investor may acquire multiple fractional shares over time, potentially accumulating enough to constitute one or more whole shares in aggregate. Trading in Fractional Shares with the Company includes transactions involving share fractions and trades in low quantities, typically one or two shares.

To support accurate administration of Fractional Shares, the Company upholds a meticulous record-keeping system that:

• Tracks all fractional share positions with precision up to eight decimal places.

• Logs the total equivalent in full shares based on the aggregate of fractional positions.

• Separately manages ledgers for fractional shares and whole share holdings.

• Documents all corporate actions and their respective impact on fractional share positions.

Fractional Shares are not independently listed on any exchange, whereas the full, relevant shares generally are listed. Certain trading venues may restrict or prohibit orders for a single share, which may result in execution uncertainty. As such, orders for these small quantities shall be executed via internalization by the Company. Any conflicts of interest that may arise from this execution method are disclosed within the Company’s Disclosure Notice.

The Company shall, in all respects, comply with “best execution” obligations for all Orders in accordance with its regulatory requirements. This ensures that execution prices are no worse than the prevailing bid/offer on the reference exchange at the time of the Order, encompassing both full share and fractional share components within a transaction. Any Order exceeding one share and involving a fractional component will be executed in a mixed capacity, whereby the Company may act as a principal or as a riskless principal for the fractional share portion. In the event an Order is solely for a fractional share, the Company shall execute this trade over-the-counter and match it internally, ensuring a price no worse than the prevailing bid/offer on the reference exchange at the time of the Order. Orders placed outside of regular trading hours shall only be executed if 24/5 Trading applies.

If an Order is placed for a specific monetary amount that is insufficient to acquire one or more whole shares, the monetary amount may be enough only to acquire a fractional share. In this case, the Company shall execute a Fractional Share transaction whereby the underlying reference instrument will represent a percentage of the share specified in the Order.

The Company shall round all fractional holdings to eight decimal places. For all notional-based Orders, transactions shall not exceed the specified order amount. Rounding may affect the crediting of cash dividends, stock dividends, and stock splits to fractional holdings. For example, if an investor holds 0.00000001 shares in a stock paying a dividend of one cent per share, no fractional cent will be credited to the investor’s cash balance. The Company shall employ reasonable efforts to approximate the Order amount; however, it shall not be liable for any loss or damage arising from or related to rounding, except where such loss or damage is directly attributable to the Company’s negligence, fraud, wilful default, breach of contract, or breach of the CySEC Rules.

15. Fractional Share Settlement

The Company settles Fractional Share transactions through dedicated internal books and records to ensure accurate and timely reflection of all client positions. Specifically:

Immediate Position Updates: Client positions are updated immediately upon execution of each transaction, providing clients with a real-time reflection of their holdings in both fractional and whole shares.

Segregated Account Holdings: The underlying whole shares corresponding to fractional share transactions are held in segregated accounts, ensuring a clear distinction between client assets and Company assets, and safeguarding the integrity of client holdings.

Simultaneous Settlement of Fractional and Whole Share Components: The settlement of fractional share components occurs in tandem with any whole share portions within a single transaction. This ensures consistent and streamlined execution, minimizing settlement delays and maintaining alignment with regulatory standards.

Full Backing of Fractional Positions by Whole Shares: Each fractional position held by clients is fully supported by the necessary whole shares, guaranteeing that fractional shares are backed by actual assets, thereby reinforcing client confidence and regulatory compliance.

16. Consent

Your prior consent to our Order Execution Policy is required, which is deemed to be granted when you provide us with an Order. Any modifications to this 'Order Execution Policy' (referred to as "Changes") will be communicated by posting them on our Website. Each notification of such Changes is considered sufficient notice, and it is your responsibility to regularly review this 'Order Execution Policy' on our Website for any updates. Therefore, it is advisable to periodically review this policy to stay informed of any Changes.

Your continued access and use of our Website and/or Application after the publication of any Changes signify your agreement to them, and you will be bound by the modified 'Order Execution Policy'. If you do not wish to be bound by such Changes, you should immediately cease accessing and/or using our services and inform us in writing.

You will be deemed to have accepted any Changes unless you notify us otherwise within five (5) calendar days of our notice of the relevant Changes. If you object to a Change, it will not be binding on you, but your Account will be suspended, and you will be required to close it as soon as reasonably practicable.

Any Change will replace any previous agreement between us on the same subject matter and will govern any Transactions and/or Contracts entered into after, or outstanding on, the effective date of the new edition of this 'Order Execution Policy'.

17. Status of this Policy

This Policy is an integral component of the Investium Limited Terms and Conditions.

Any terms or phrases emphasized but not explicitly defined in this Order Execution Policy shall bear the same definitions as outlined in our Terms and Conditions.

18. Definitions

Execution Venue means a Regulated Market, an MTF, an OTF, a Systematic Internaliser, or a market maker or other liquidity provider or an entity that performs a similar function in a third country to the function performed by any of the foregoing.

Market hours means the time span of trading on the financial markets as indicated on our Website. During those market hours, the Clients shall have the right to place Orders for execution for those Financial Instruments whose exchanges are open for trading.

Market Order is an Order instantly executed against a price that the Company has provided. The Client may attach to a Market Order a ‘Stop Loss’ and/or ‘Take Profit’. ‘Stop Loss’ (an Order to close a previously opened position at a price less profitable than the price at the time of placing the Order) is an Order to limit a Client’s loss, whereas ‘Take Profit’ (an Order to close a previously opened position at a price more profitable than the price at the time of placing the Order) is an Order to limit a Client’s profit.

Multilateral Trading Facility (MTF) means a multilateral system operated by an investment firm or a market operator, which brings together multiple third-party buying and selling interests in Financial Instruments – in the system and in accordance with non-discretionary rules in a way that results in a contract in accordance with the provisions of MiFID II.

Order means an instruction to buy or to sell as placed by you via your Account on the Application.

Organised Trading Facility (OTF) means a multilateral system, which is not a regulated market or an MTF and in which multiple third-party buying and selling interests in bonds, structured finance products, emissions allowances or derivatives are able to interact in the system in a way that results in a contract in accordance with the provisions of MiFID II.

Regulated Market means a multilateral system, operated and/or managed by a market operator, which brings together or facilitates the bringing together of multiple third-party buying and selling interests in Financial Instruments – in the system and in accordance with its non-discretionary rules – in a way that results in a contract, in respect of the Financial Instruments admitted to trading under its rules and/or systems, and which is authorised and functions regularly and in accordance with the provisions of MiFID II.

Stop Price - A Stop Price is the price predetermined by you when setting a Stop Order. Once the stock hits the Stop Price, the Stop Order becomes a Market Order.

Systematic Internaliser means an investment firm, which, on an organised, frequent and systematic basis, deals on own account by executing Client Orders outside a regulated market or an MTF.

Annex 1: Relative importance of best execution factors

Last updated: 28 October 2024