Ebury Partners Markets Cyprus BEST INTEREST AND ORDER EXECUTION POLICY SUMMARY V.1.1

1. Introduction

This Best Interest and Order Execution Policy ('the Policy') is provided to you (our Client or prospective Client) in accordance with the Investment Services and Activities and Regulated Markets Law of 2017 L. 87(I)/2017, as amended from time to time ('the Law').

Ebury Partners Markets Cyprus LTD (hereinafter, 'EPM', 'the entity', 'the firm' or 'the Company') is a Cyprus Investment Firm ('CIF') registered with the Cyprus Department of Registrar of Companies (HE 439971) and authorised and regulated by the Cyprus Securities and Exchange Commission ('CySEC') under license number 459/25.

Pursuant to the Law, EPM is required to take all sufficient steps to act in the best interest of its Clients either when executing or receiving and transmitting Client Orders for execution and to achieve the best execution results when executing Client Orders and to comply, in particular, with the principles set out in the Law when providing investment services.

The Company executes Client Orders in relation to Non-Deliverable Forwards, Options and other Balance Sheet hedging tools ('FINANCIAL INSTRUMENT's'). 'FINANCIAL INSTRUMENTS' are also referred to as Financial Instruments in this Policy.

EPM employs its permissions within a matched principal broker model in which it concludes FX agreements with its clients, and then, under a separate agreement, hedges its exposure through an equal and opposite trade concluded with a counterparty. As neither trade is negotiated on exchange, each transaction is considered to be 'over-the-counter' ('OTC').

Although clients transact directly with EPM, the quality of execution available to the client is inherently linked to the Company's ability to source pricing from its counterparties. Accordingly, in seeking to achieve the best possible outcome for clients, the firm assesses the execution quality offered by its counterparties. When best execution criteria are referenced within this policy, it should be understood that this is in reference to what the Company can source for itself, which is then passed onto the client.

By opening an account, you agree/consent to the fact that your Orders will be executed outside a Regulated Market (e.g. Regulated Stock Exchange) or a Multilateral Trading Facility or an Organised Trading Facility (e.g. European Financial Trading System).

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2. Regulatory Framework

As an investment company, the firm is expected to act in its clients' best interest when delivering its investment services. This obligation implies a series of specific obligations when it comes to handling clients' orders and ensuring their best execution and selection.

The key regulatory provisions in this respect are the following:

Best execution/selection

• Article 27 of the Directive 2014/65/EU of 15 May 2014 on markets in financial instruments ('MiFID II');

• Articles 64 to 66 of regulation (EU) 2017/565 of 25 April 2016 supplementing Directive 2014/65/EU of the European Parliament and of the Council as regards organisational requirements and operating conditions for investment firms and defined terms for the purposes of that Directive ('MiFID II L2R');

• Article 28 of Law 87(I)/2017 regarding the provision of investment services, the exercise of investment activities and the operation of regulated markets

Handling of orders

• Article 28 MiFID II;

• Articles 67 to 70 MiFID II L2R.

• Article 29 of Law 87(I)/2017

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3. Scope

3.1. Applicable Client Types

This Policy applies to Retail and Professional Clients only. Both of these definitions can be found within the Company's Client Categorisation Policy. The Company will always act honestly, fairly and professionally, and communicate in a way, which is fair, clear and not misleading, taking into account the nature of the client and his business.

This Policy applies when executing Client Orders for the Client for all the types of 'FINANCIAL INSTRUMENT's offered by the Company. Clients must therefore ensure that they have read, understood and consent to the contents of this Policy before trading with the Company.

3.2 Exemptions from Policy

This policy is not applied in the following cases:

a. If the client is categorised as an Eligible Counterparty, the Company will not owe Best Execution for transactions entered into with such Eligible Counterparties. Although the Order Execution Policy does not apply in such cases, the Company will act honestly, fairly and professionally, and communicate in a way, which is fair, clear and not misleading, taking into account the nature of the client and his business.

b. In the event of force majeure which affects, interrupts or stops (permanently or temporarily) the operation of the trading facility or other mechanism or systematic transactions in which a client's order is executed, beyond the reasonable control of the Company. In such exceptional circumstances, however, the Company will endeavour to execute the order, taking into account the prevailing circumstances, on a best effort basis.

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4. Best Execution Factors

4.1 Relevant Factors

The Company will take all sufficient steps to obtain the best possible result/outcome ('Best Execution') for its Clients when receiving, transmitting and executing Client Orders, taking into account prices, costs, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of the order ('Best Execution Factors'), as follows:

(a) Price: For any given 'FINANCIAL INSTRUMENT', the Company will quote a single price for the client as these are available on the currency pair of choice.

The Company's price for a given 'FINANCIAL INSTRUMENT' is calculated by reference to the price of the relevant to the currency pair as which the Company obtains from third party external reference sources (i.e. price feeders or Executive Venues). The Company updates its prices as frequently as the limitations of technology and communications links allow. The Company reviews its third party external reference sources from time to time to ensure that the data obtained continues to remain competitive. The Company will not quote any price outside the Company's operations time (see execution venue below) therefore no orders can be placed by the Client during that time. Certain ex-ante and ex-post quality checks are conducted by the Company to ensure that prices obtained and subsequently passed on to clients remain competitive. Such checks include, but not limited to, reviewing system settings/parameters, comparing prices with reputable price sources, ensuring symmetry of spread and checking the speed of price updating.

(b) Costs: For opening a position in some types of 'FINANCIAL INSTRUMENT', the Client may be required to pay commission, the amount of which is disclosed on the Company's website or provided in the pre-trade disclosure which is shared with the client at the time of execution.

Commissions: Commissions may be charged either in the form of a percentage of the overall value of the trade or as fixed amounts. Information on commissions (if relevant) can be found in the Client Information Pack which is shared with the client prior to execution. For all types of Financial Instrument that the Company offers, commissions, if applicable, are incorporated into the Company's quoted price.

Should the Company at any period of time decide not to charge such costs, it shall not be construed as a waiver of its rights to apply them in the future, with prior notice to the Client as explained in the Client Agreement found on the Company's website or agreed at the start of the relationship and as is amended from time to time. Such notice may be sent personally to the Client and/or posted on the Company's website.

(c) Speed of Execution: The Company is the Execution Venue for the execution of the Client's Order, but this is dependent on the equal and opposite Order with third party Execution Venues. The Company places a significant importance when executing Client's orders and strives to offer high speed of execution within the limitations of technology and communications links. For instance, in cases where Clients are using a wireless connection or a dial up connection or any other communication link that can cause a poor internet connection then this may cause unstable connectivity with the Company's trading platform resulting to the Client placing his Orders at a delay and hence the Orders to be executed at better or worst prevailing price offered by the Company.

(d) Likelihood of Execution: When the Company transmits Orders for Execution or executes it with another party, execution may be more difficult. The likelihood of execution depends on the availability of prices of other market makers/financial institutions. In some case it may not be possible to arrange an Order for execution, for example but not limited in the following cases: during news times, trading session start moments, during volatile markets where prices may move significantly up or down and away from declared prices, where there is rapid price movement, where there is insufficient liquidity for the execution of the specific volume at the declared price, a force majeure event has occurred. In the event that the Company is unable to proceed with an Order with regard to price or size or other reason, the Order will not be executed. In addition, the Company is entitled, at any time and at its discretion, without giving any notice or explanation to the Client, to decline or refuse to transmit or arrange for the execution of any Order or Request or Instruction of the Client in circumstances explained in the Client Agreement found or agreed at the start of the relationship and as is amended from time to time.

In order to improve speed and likelihood of execution the Company carries out certain ex-ante and ex-post quality checks. Such checks include, but not limited to, symmetric slippage checks, number of trades subject to slippage and comparing our average speed of execution with industry standards.

(e) Likelihood of settlement: The Company shall proceed to a settlement of all transactions upon execution of such transactions. Non-Deliverable Forwards and Forwards taken out of balance sheet hedging purposes are cash settled.

(f) Size of order: All Orders are placed in lot sizes. A lot is a unit measuring the transaction amount and it is different for each type of 'FINANCIAL INSTRUMENT'. The minimum size of an order is different for each type of Trading Account. Please refer to the Company's website for the value of minimum size of an Order and each lot for a given 'FINANCIAL INSTRUMENT' type. If the Client wishes to execute a significantly large sized Order, the price obtained may, in some cases, be less favourable. The Company makes every effort to fill the Order of the client but reserves the right to decline an Order in case the size of the Order is large and cannot be filled by the Company or for any other reason as explained in the Client Agreement found at or agreed at the start of the relationship and as is amended from time to time.

(g) Market Impact: Some factors may rapidly affect the price of the underlying instruments/products from which the Company's quoted price is derived and may also affect other factors listed herein. The Company will take all sufficient steps to obtain the best possible result for its Clients.

The Company does not consider the above list exhaustive and the order in which the above factors are presented shall not be taken as priority factor. Any factors which affect the best possible result and are identified by the Company and are not listed above, will be rectified accordingly in order to provide the client with the best possible result. Nevertheless, whenever there is a specific instruction from the Client, the Company shall make sure that the Client's order shall be executed following the specific instruction.

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5. Execution Practices in Financial Instruments

A. Slippage (Market Orders)

You are warned that Slippage may occur when trading in 'FINANCIAL INSTRUMENTS'. This is the situation when at the time that an Order is presented for execution, the specific price shown to the Client may not be available; therefore, the Order will be executed close to or a number of pips away from the Client's requested price. So, Slippage is the difference between the expected price of an Order, and the price the Order is actually executed at. If the execution price is better than the price requested by the Client, this is referred to as positive slippage. If the executed price is worse than the price requested by the Client, this is referred to as negative slippage. Please be advised that Slippage is a normal element when trading in financial instruments. Slippage more often occurs during periods of illiquidity or higher volatility (for example due to news announcements, economic events and market openings and other factors) making an Order at a specific price impossible to execute. In other words, your Orders may not be executed at declared prices.

It is noted that Slippage can occur also during Stop Loss, Take Profit and other types of Orders. We do not guarantee the execution of your Pending Orders at the price specified. However, we confirm that your Order will be executed at the next best available market price from the price you have specified under your pending Order.

B. Re-quoting (Instant Execution)

This is the practice of providing a secondary quote to the client after an 'instant order' has been submitted; the client must agree to this quote before the order is executed. The Company will requote 'instant orders' if the requested price originally specified by the client is not available. The secondary quote provided to the client is the next best available price received by the Company from its Execution Venue. The Company does not re-quote 'pending orders' or 'market orders'. Re-quotes apply to all types of Accounts.

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6. Types of Order(s) in Trading Financial Instruments

6.1. Placing of an order

The Client may place an order by using the following options:

• Electronically via email with the assigned dealer.

• Electronically via online client's portal;

• Telephone communication with the assigned dealer;

• Electronic video call with the assigned dealer.

6.2 Order Types

The particular characteristics of an order may affect the execution of the Client's Order. Please see below the different types of Orders that a Client can place:

A. Market Order(s)

A Market Order is an order to buy or sell a 'FINANCIAL INSTRUMENT' as promptly as possible at the prevailing market price that is available.

B. Instant Order(s)

An Instant Order is an Order to buy or sell a 'FINANCIAL INSTRUMENT' at the most recently available price. In Instant Execution if the requested price is not available, the current available price will be sent to the Client to confirm execution (re-quote). Instant Orders are offered for all types of 'FINANCIAL INSTRUMENT's Trading Accounts.

C. Pending Order(s)

A Pending Order is an Order that allows the user to buy or sell a 'FINANCIAL INSTRUMENT' at a predefined price in the future. These Pending Orders are executed once the price reaches the requested level. However, it is noted that under certain trading conditions it may be impossible to execute these Orders at the Client's requested price (see section 3.1. (a) above). In this case, the Company will execute the order at the next best available price. This may occur, for example, at times of rapid price fluctuations of the price, rises or falls in one trading session to such an extent that, under the rules of the relevant exchange, trading is suspended or restricted, or there is lack of liquidity, or this may occur at the opening of trading sessions. This is an Order to buy or sell a 'FINANCIAL INSTRUMENT' in the future at the next best available price once a certain price is reached.

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7. Best Execution Criteria

7.1 Relative Importance of Factors

The Company will determine the relative importance of the above Best Execution Factors (section 5) by using its commercial judgement and experience in the light of the information available on the market and taking into account:

(a) The characteristics of the Client, including the categorisation of the client as retail, professional or eligible counterparty.

(b) The characteristics of the Client order.

(c) The characteristics of the Financial Instruments that are the subject of that order.

(d) The characteristics of the execution venue to which that order is directed.

The Company assigns the following importance level to the Best Execution Factors:

When acting as executor for Retail or Professional Clients, the Company is responsible for selecting an Execution Venue where it executes the client order. In making this selection, it will take all sufficient steps to obtain the best possible results, under prevailing market conditions, for its clients, taking into account execution factors as above. When the Company acts as a Receiver and Transmitter of Client Orders, it ensures it will obtain the best possible results on behalf of clients by choosing the most appropriate Execution Entity to transmit the client order to.

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8. Client's Specific Instruction

Whenever there is a specific instruction from or on behalf of a Client (e.g. fills in the required parts on the Company's trading platform when placing an Order), relating to the Order or the specific aspect of the Order the Company shall arrange – to the extent possible – for the execution of the Client Order strictly in accordance with the specific instruction.

WARNING: It is noted that any specific instructions from a Client may prevent the Company from taking the steps that it has designed and implemented in this Policy to obtain the best possible result for the execution of those Orders in respect of the elements covered by those instructions. When the Client's instructions relate to a part of the order, the Company applies its Order Execution Policy in respect of the elements that are not covered by such instructions.

Trading rules for specific markets or market conditions may prevent the Company from following certain of the Client's instructions.

The Company is not permitted to induce a client to issue a specific instruction where it is aware that such an instruction would not deliver the best possible outcome for the client.

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9. Client Order Handling

The Company will satisfy the following conditions when carrying out Client Orders:

(a) ensures that orders executed on behalf of Clients are promptly and accurately recorded and allocated;

(b) carries out otherwise comparable Client orders sequentially and promptly unless the characteristics of the order or prevailing market conditions make this impracticable, or the interests of the Client require otherwise;

(c) informs its Client about any material difficulty relevant to the proper carrying out of orders promptly upon becoming aware of the difficulty.

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10. Execution Venues

10.1 Current Venues

Execution Venue is the entity or entities with which the Orders in Financial Instruments are placed and executed. The Company has the ability to execute Client Orders in Financial Instruments on an own account basis. The Company uses one or more third party Financial Institutions as Execution Venue(s). The Execution Venue(s) currently used by the Company are:

• Barclays

• Citi Bank

• Goldman Sachs

• Santander

• Societe Generale

• JP Morgan

The list may be changed at the Company's discretion by giving prior notice to the Clients, in accordance with the Client Agreement.

10.2 Venue Criteria

The Company evaluates and selects the Execution Venues based on a number of criteria including such as (but not limited to) the following:

a) the regulatory status of the institution;

b) the ability to deal with large volume of Orders;

c) Speed of response to a Request For Quotation and the speed of execution;

d) the competitiveness of commission rates and spreads;

e) the reputation of the institution;

f) the ease of doing business;

g) the legal terms of the business relationship;

h) the financial status of the institution;

i) various qualitative criteria such as clearing schemes, circuit breakers and scheduled actions.

j) having access to an execution venue on a permanent basis

The Company places different relative importance on each of the criteria mentioned above by using its commercial judgement and experience in the light of the information available on the market.

The Company selects to work with those third-party venues that enable the Company to obtain on a consistent basis the best possible result for the execution of client orders.

Where there is only one possible Execution Venue, best execution is achieved by execution on that venue, noting that as the Company executes transactions on 'own account' it maintains the ability to always give the client the price agreed, even if the price provided by the Execution Venues changes.

Best execution is a process, which considers various factors. This means that, when the Company is executing an order for a Client, the Company must execute it in accordance with its execution policy. The Company does not guarantee that the exact price requested will be obtained in all circumstances and, in any event, the factors may lead to a different result in a particular transaction.

The Company will strive to use Execution Entities that themselves have a MIFID II compliant Order Execution Policy.

The Company refrains from structuring or charging its commissions in such a way as to discriminate unfairly between execution venues.

In cases of specific Financial Instruments, which are negotiated in only one market, it is possible that there is only one available place for execution. During the execution of the order under these circumstances, the Company considers that it secures the best possible outcome on a systematic basis provided that it complies with the current rules of the particular market.

The Company does not receive any remuneration, discount or major non-monetary benefits for routing its Clients' orders to a particular trading or execution venue, which would infringe its obligations with regards to conflicts of interest or inducements.

10.3 Risks Associated with OTC

The Client acknowledges that the transactions entered in Financial Instruments with the Company are not undertaken on a recognised exchange, rather they are undertaken over the counter (OTC) and as such they may expose the Client to greater risks (e.g. counterparty risk) than regulated exchange transactions. If you require more information regarding the consequences of this means of execution, please contact us in one of the official contacting methods of the Company, outlined on our website.

10.4 Additional Venue Considerations

The Company, before deciding which Execution Venues to use for client orders, compares different venues and performs due diligence of them. In addition to the factors mentioned in point 9.1. above, some of the parameters that the Company evaluates, include the following:

• Pricing frequency (provided the trade is not executed on own account).

• Speed of communication/execution – How fast are the prices received/orders executed.

• Occurrence of price freezes and frequency.

• Depth of liquidity – What is the liquidity provided by the Liquidity Provider.

• Symmetry of slippage should be evaluated in detail for every order type.

In general, the Company places great significance on the choice of its Liquidity Providers as it strives to offer, on a consistent basis, best execution to its Clients.

10.5 Execution of Regulated Forwards via Independent Platform

10.5.1 Frequent Trade Types

To consistently and conveniently provide best execution for regulated FX contracts, EPM shall primarily book appropriate trades with assistance from an independent price aggregator. This system is configured to place price as the highest level of importance. As such, any trade booked using this platform should guarantee the best price is provided from the available and approved execution venues.

Note: the price aggregator platform only searches prices from approved and added execution venues. Any new venues must be added to the platform separately.

10.5.2 Special Circumstances

Whilst EPM requires its dealers to utilise the aggregator platform to book regulated forwards, certain scenarios may mean the system is not capable of providing a quote from one or more execution venues. This could occur in several ways, including (but not limited to):

• Requested trade size being too large for the platform/onboarded execution venues

• Exotic currency pairings that cannot be sourced

• Time zone and settlement capabilities

In these circumstances, traditional voice broking or quotes from independent platforms must be utilised. As stated in section 10.2, where there is only one possible Execution Venue, best execution is achieved via the use of that venue.

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11. Client's Consent

By entering into a Client Agreement with the Company for the provision of Investment Services, the Client is consenting to an application of this Policy on him/her (i.e. this Policy forms part of the Client Agreement found on the company's website).

The Company shall be able to demonstrate to its clients, at their request, that it has executed their orders in accordance with this Policy.

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12. Monitoring

To assess the effectiveness of the company's best execution arrangements and approach, post trade monitoring will be conducted. Outputs from the monitoring will be presented to the EPM board.

The Company will randomly select a sufficiently large sample of trades to ensure, with a high statistical confidence level, that it constantly obtains and will obtain the best possible results for the Clients. This is verified by selecting samples from different periods of time, for different instruments and different types of 'FINANCIAL INSTRUMENT's.

12.1 Regulated FX Contracts

When monitoring the best execution of regulated FX contracts, EPM will utilise the automated output produced by an independent aggregator platform. Review of these outputs will be conducted periodically, and will aim to identify scenarios where a better price was sourced but not utilised.

12.2 Options

Due to the bespoke offering provided by OTC options, EPM will conduct a quarterly benchmarking assessment across its execution venues. This will provide a standardised trade across each venue, with which the resulting quotes will be compared to identify approved venues versus outliers. For any trade conducted with a venue outside the approved list, evidence

This monitoring methodology will be reviewed annually, or more frequently where material changes to the Company (such as a new product or an increased volume of trades) or its execution venues occur.

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13. Review

The Company will review, at least annually or when a material change occurs, its execution policy as well as the effectiveness of its order execution arrangements in order to identify and, where appropriate, correct any deficiencies and to ensure that it complies with all regulatory requirements and obligations. The Company through regular monitoring will check that the best possible results were obtained for the clients and proceed with any corrective actions if needed.

The Company deems a material change to be significant changes to its execution venues, financial instruments, operating model (i.e. deviation from acting as a matched principal broker) or the regulations and laws for which this policy is required and executed.

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14. Amendment of the Policy and Additional Information

The Company reserves the right to review and/or amend its Policy and arrangements whenever it deems this appropriate according to the terms of the Client Agreement. It should be noted that the Company will notify Client in advance of any substantial material changes to the Policy via email and via the Company's online system.

Should you require any further information and/or have any questions about this Policy, the Company's execution arrangements and/or how these are reviewed by the Company, please direct your request and/or questions to info@ebury.com. The Company shall respond within a reasonable time.