Order Execution Policy

Order Execution Policy

1. SUMMARY
This Summary Best Interest and Order Execution Policy (“the Policy”) is an appendix to theServices Agreement and is provided to you (Client or prospective Client) in accordance with theFinancial Advisory and Intermediary Services Act, as subsequently amended from time to time(“the Law”), pursuant to which Midori FX (Pty) Ltd trading as ‘Midori FX’ (“the Company”) isrequired to take all reasonable steps to act in the best interest of its Clients when receiving andtransmitting their Client Orders and to achieve the best execution results when executing their
Client Orders and to comply, in particular, with the principles set out in the Law when providing
investment intermediary services.

2. SCOPE
This Policy applies to Retail and Professional Clients, as well as to Eligible Counterparties (asdefined in the Company’s Client Classification section in the Terms and Conditions). The
application of this Policy to all the Company’s Clients is for the Clients to ensure that the Companyto which orders are transmitted for execution has execution arrangements that enable them tocomply with their ‘duty to act in the best interest of Clients and best execution’ obligations fortheir Clients.
This Policy applies when receiving and transmitting or executing Client Orders for the Client for
the Contracts for Differences (“CFDs”) offered by the Company.

3. BEST EXECUTION FACTORSThe Company shall take all reasonable steps to obtain the best possible results for its Clients taking
into account the following factors when dealing with Clients orders: price, costs, speed ofexecution, likelihood of execution and settlement, size of order, market impact or any otherconsideration relevant to the execution of the order in its capacity as intermediary between theClient and the issuer of the contract for difference, more commonly referred to as a liquidity
provider.
The Company does not consider the below list exhaustive and the order in which the above factors
are presented shall not be taken as priority factor:(a)Price: For any given CFD, the Company will quote two prices (as received by the issuer ofthe contract for difference): the higher price (ASK) at which the Client can buy (go long) that CFD,
and the lower price (BID) at which the Client can sell (go short) that CFD. Collectively, the ASK
and BID prices are referred to as the Company’s price. The difference between the lower and the2|Page
Midori FX (Pty) Ltd is an Authorised Financial Services Provider registered and existing in the Republic of South Africa underregistration number 2023/526901/07 and regulated by the Financial Sector Conduct Authority under license number 53077,
pursuant the Financial Intermediary and Services Act 37 of 2002 (“FAIS’).

Order Execution Policy

higher price of a given CFD is the spread. The Company’s execution price for a given CFD is setby reference to the price of the relevant underlying asset, which the Company obtains from therelevant liquidity providers. Pre trade indicative prices are streamed by the Client’s technology
provider directly to the Client’s trading platform/system. The Company updates its liquidity
providers’ prices as frequently as the limitations of technology and communications links allow.
The Company reviews its liquidity provider’s prices from time to time to ensure that the dataobtained continues to remain competitive. In any manner, the Company will not quote any priceoutside the Company’s operations time, therefore no orders can be placed by the Client during thattime.
(b)
Costs: For opening a position in some types of CFDs the Client may be required to pay
commission, spread or financing fees. Commissions may be charged either in the form of apercentage of the overall value of the trade or as fixed amounts per units of volume traded. In thecase of financing fees, the value of opened positions in some types of CFDs is increased or reduced
by a daily financing fee “swap rate” throughout the life of the contract. Financing fees are basedon prevailing market interest rates, which vary over time. For the CFDs that the Company offers(as received by the issuer of the contract for difference), the commission or financing fees may not
be incorporated into the Company’s quoted price and are instead charged explicitly to the Client
account. Details of commission, spread or financing fees applied are specified under theCompany’s Trading Terms Scheme which shall be duly communicated to the Client.
(c)Likelihood of Execution: When the Company transmits Orders for Execution the likelihoodof execution depends on the availability of prices of the liquidity providers. In some case it maynot be possible to arrange an Order for execution, for example (but not limited to) in the following
cases: during news times, during trading session start moments, during volatile markets whereprices 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, when a force majeure event has occurred etc. In the event that the Company isunable to proceed with an Order with regard to price or size or other reason, the Company will not
send a re-quote to the Client with the price it is willing to deal, so the Order will not be executed.
(d)
The Company may in its sole discretion, while making reasonable efforts for postnotification, alter transactions, not transmit, not execute or cancel an executed transaction if:i.
The transaction was executed by arbitrage/exploitation of market failures or off market
rates;
ii.

A technical problem withheld the transaction from being executed as desired;iii.

A liquidity provider has cancelled or altered the transaction with the Company; and/or3|Page
Midori FX (Pty) Ltd is an Authorised Financial Services Provider registered and existing in the Republic of South Africa underregistration number 2023/526901/07 and regulated by the Financial Sector Conduct Authority under license number 53077,
pursuant the Financial Intermediary and Services Act 37 of 2002 (“FAIS’).

Order Execution Policyiv.
The transaction covering was failed or partially executed with the liquidity provider. The
Company is also 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 Requestor Instruction of the Client in circumstances explained in the Client agreement/General Terms andConditions.
(e)Likelihood of settlement: The Financial Instruments offered by the Company, CFDs, do
not involve the delivery of the underlying asset, so there is no settlement as there would be forexample if the Client had bought shares.
(f)
Size of order: The actual minimum size of an order is different for each type of account orinstrument. A lot is a unit measuring the transaction amount and it is different for each type ofCFD. For the value of minimum and maximum size of an order and each lot for a given CFD type,please refer to the Trading Terms Scheme and Procedures, which shall be duly communicated tothe Client. The liquidity provider reserves the right to change any contract specifications at any
time depending on the market situation and risk management policy with no prior notification, but
after making available to the Clients the changes through the website or in a durable medium. For
this reason, the Client is responsible to check for changes in the contract specifications every time
before placing a new order.
(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 otherfactors listed herein. The Company will take all reasonable steps to obtain the best possible resultfor its Clients.
(h)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.
(i)
Warning: any specific instructions from a Client may prevent the Company from taking
the steps that it has designed and implemented to obtain the best possible result for the executionof those orders in respect of the elements covered by those instructions.
(j)
The Company provides to its Clients access to a number of liquidity providers, in order toensure the highest possible liquidity in the market. The Company cannot and do not, however,guarantee that its quoted prices will be at a price which is as good, or better, than one might havebeen available elsewhere.

4|PageMidori FX (Pty) Ltd is an Authorised Financial Services Provider registered and existing in the Republic of South Africa underregistration number 2023/526901/07 and regulated by the Financial Sector Conduct Authority under license number 53077,
pursuant the Financial Intermediary and Services Act 37 of 2002 (“FAIS’).

Order Execution Policy

4. BEST EXECUTION CONDITIONSThe Company will take into account the best execution standards 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; and•The characteristics of the execution venues (if other than the Company) to which that ordercan be directed.
The best possible result will be determined in terms of the total consideration, representing theprice 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, besecondary to price and cost considerations, unless they would deliver the best possible result forthe client in terms of total consideration.

5. CLIENT EXPLICIT INSTRUCTIONSWhenever there is a specific instruction from or on behalf of a Client, the Company shall arrange– to the extent possible – for the execution of the Client order strictly in accordance with thespecific instruction.
It is noted that the specific instruction may prevent the Company from taking the steps in the Policy
to obtain the best possible result for the Client. Trading rules for specific markets or market
conditions may prevent the Company from following certain of the Client’s instruction.
To the extent that a Client’s instruction is not complete, the Company will determine any nospecified components of the execution in accordance with this Policy or reject the instruction.

6. EXECUTION OF ORDERS
Clients’ orders shall be transmitted to the Company’s system from the Client’s system byelectronic means. The Company shall satisfy the following conditions when carrying out Clientorders:(a) Ensures that orders executed on behalf of Clients are promptly and accurately recorded andallocated;
5|PageMidori FX (Pty) Ltd is an Authorised Financial Services Provider registered and existing in the Republic of South Africa underregistration number 2023/526901/07 and regulated by the Financial Sector Conduct Authority under license number 53077,
pursuant the Financial Intermediary and Services Act 37 of 2002 (“FAIS’).

Order Execution Policy(b) Carries out otherwise comparable Client orders sequentially and promptly unless thecharacteristics of the order or prevailing market conditions make this impracticable, or the interestsof the Client require otherwise;(c) Informs all its Client about any material difficulty relevant to the proper carrying out of orders,within reasonable timeframe, upon becoming aware of the difficulty.

7. EXECUTION VENUESThe Client acknowledges that the transactions entered in CFDs with the liquidity provider are notundertaken on a recognized exchange, rather they are undertaken over the counter (OTC) and assuch they may expose the Client to greater risks than regulated exchange transactions. Therefore,the Company may not manage to have an Order executed, or it may change the opening (closing)price of an Order in case of any technical failure of the trading platform or quote feeds.

8. CLIENT AGREEMENT
By entering into a Services Agreement with the Company for the provision of Investment
Intermediary Services, the Client is consenting to an application of this Policy on him.

9. ALTERATION OF THE POLICY AND FURTHER INFORMATIONThe Company reserves the right to review and/or amend the Policy and arrangements whenever it
deems this appropriate without notice to the Client. The last and current version in force shall be
the one posted by the Company in its website.
Should you require any further information and/or have any questions about the Policy please
direct your request and/or questions to support@midorifx.com .

6|PageMidori FX (Pty) Ltd is an Authorised Financial Services Provider registered and existing in the Republic of South Africa underregistration number 2023/526901/07 and regulated by the Financial Sector Conduct Authority under license number 53077,
pursuant the Financial Intermediary and Services Act 37 of 2002 (“FAIS’).