Email: info@xmtrading.com | Web: www.xmtrading.com | Address: F20, 1st Floor, Eden Plaza, Eden Island, Seychelles

ORDER EXECUTION POLICY
1. Introduction
Tradexfin Limited (formerly known as “Trading Point (Seychelles) Limited”) operating under the trading
name XMTrading is a Securities Dealer Licensee regulated and authorised by the Financial Services
Authority (“FSA”) in Seychelles under the Licence Number: SD010 (hereinafter called the “Company”).
The Company is operating under the Securities Act 2007 (the “Act”), Securities (Conduct of Business)
Regulations 2008, Securities (Forms and Fees) Regulations 2008, Securities (Prospectus) Regulations
2008, Securities (Takeovers) Regulations 2008, Securities (Takeovers) Regulations 2008 and theSecurities (Advertisements) Regulations 2008 (collectively the “Act and Applicable Regulations”).
In accordance with the Act and Applicable Regulations, the Company is required to take reasonable steps
to find and deal on the terms which are the best available to the client when dealing with or for a client(“best execution”). In order to comply with this requirement, the Company established and provides its
clients and potential clients with its Order Execution Policy ( the “Policy”).
This Policy forms part of our Terms and Conditions of Business and by agreeing with our Terms andConditions of Business, which is a contractually binding agreement between you and the Company, youare also agreeing to the terms of the Policy set forth in this document.
2. Scope and services
This Policy applies when executing transactions with you for the Securities provided by the Company. It isup to the Company’s discretion to decide which types of Securities to make available and to publish theprices at which these can be traded. The Company is always the counterparty (or principal) to every trade;
therefore, if the Client decides to open a position in a Security with the Company, then that open position
can only be closed with the Company.
The Client is given the option to place with the Company the following orders for execution in the following
ways:
2.1. The Client places a “Market Order” which is an order instantly executed against a price that theCompany has provided. The client may attach to a market order a Stop Loss and/or Take Profit. StopLoss is an order to limit Client’s loss, whereas Take Profit is an order to limit Client’s profit.
2.2. The Client places a “Pending Order”, which is an order to be executed at a later time at the price that
the Client specifies. The Company will monitor the pending order and when the price provided by theCompany reaches the price specified by the Client, the order will be executed at that price. The
following types of pending orders are available: ‘Buy Limit’ (an order to purchase a Security at or below
a specified price), ‘Buy Stop’ (an order to buy a Security, which is entered at a price above the current
offering price; it is triggered when the market price touches or goes through the buy stop price), ‘SellLimit’ (an order to sell a Security at a specified price or better), and ‘Sell Stop’ (an order to sell aSecurity when it reaches a certain price). You may attach to any ‘Pending Order’ a ‘Stop Loss’ and/or‘Take Profit’.
2.3. You may hold up to 200 positions simultaneously (considered as summary of “Market” and “PendingOrders” per “Client”).
The Client may modify an order before it is executed. The Client has no right to change or remove StopLoss, Take Profit and Pending Orders if the price has reached the level of the order execution.
3. Best execution factors
The Company shall take all reasonable steps to obtain the best possible result for its Clients taking into
account the following factors when executing Clients orders against the Company’s quoted prices:

Email: info@xmtrading.com | Web: www.xmtrading.com | Address: F20, 1st Floor, Eden Plaza, Eden Island, Seychelles

3.1. Price
3.2. Costs
3.3. Speed of Execution
3.4. Likelihood of Execution
3.5. Likelihood of settlement
3.6. Size of order
3.7. Market Impact
The Company does not consider the above list exhaustive and the order in which the above factors arepresented shall not be taken as priority factor. Nevertheless, whenever there is a specific instruction fromthe Client the Company shall make sure that the Client’s order shall be executed following the specificinstruction.
4. Best execution criteria
The Company will determine the relative importance of the above factors by using its commercial judgment
and experience in the light of the information available on the market and taking into account the criteria
described below:
4.1. the characteristics of the client
4.2. the characteristics of the order
4.3. the characteristics of Securities that are the subject of that order
4.4. the characteristics of the execution venues to which that order can be directed
5. Execution venue(s)For the purposes of orders for the Security provided by the Company, the Company acts as principal andnot as agent on the Client’s behalf; therefore, the Company is the sole Execution Venue for the executionof the Client’s orders. The Company does not transmit the Client’s order in the external market if the orderis for the Security provided by the Company.
Best Execution: It is the Company’s policy to maintain such internal procedures and principles in order toact for the best interest of its Clients and provide them the best possible result (or “Best Execution”) when
dealing with them.
Off-exchange transactions: The Client acknowledges that the transactions entered in Securities with theCompany are not undertaken on a recognized exchange, rather they are undertaken through theCompany’s Trading Platform and, accordingly, they may expose the Client to greater risks than regulated
exchange transactions. Therefore, the Company may not execute an order, or it may change the opening(closing) price of an order in case of any technical failure of the trading platform or quote feeds. The terms
and conditions and trading rules are established solely by the counterparty which in this case is theCompany. The Client is obliged to close an open position of any given Security during the opening hoursof the Company’s Trading Platform. The Client also has to close any position with the same counterparty
with whom it was originally entered into, i.e. the Company.
6. Monitor and review
The Company will monitor on a regular basis the effectiveness of this Policy and, in particular, the execution
quality of the procedures explained in the Policy and, where appropriate, reserves the right to correct any
deficiencies.
In addition, Company will review the Policy at least annually. A review will also be carried out whenever amaterial change occurs that affects the ability of the Company to continue to the best possible result for
the execution of its client orders on a consistent basis using the venues included in this Policy. TheCompany will notify its affected clients on any changes in its Policy.

Email: info@xmtrading.com | Web: www.xmtrading.com | Address: F20, 1st Floor, Eden Plaza, Eden Island, Seychelles

7. Client consent
The Company may obtain the above consents in the form of a general agreement where the Client is
informed that any orders placed with the Company for the Securities offered by the Company, the Company
acts as the principal and the Company is the sole Execution Venue.
The Company reserves the right to review and/or amend its Policy and arrangements, at its sole discretion,
whenever it deems fit or appropriate.

Email: info@xmtrading.com | Web: www.xmtrading.com | Address: F20, 1st Floor, Eden Plaza, Eden Island, Seychelles