ORDER EXECUTION POLICY
Original Issue Date:

December 2018

Approver(s):Board of Directors

Owner(s):Contact Person:
Operational Applicability:

TTCM TRADERS CAPITAL LIMITED
Chief Executive Officer
All personnel & Clients

Last Revision Date:

December 2019

Last Reviewed Date:
Next Review Date:

December 2019
December 2022

Version:
Other Languages:

2
N/A

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

Contents
1.

INTRODUCTION ....................................................................................................................................................................52.

DEFINITIONS .........................................................................................................................................................................5

3.

SCOPE AND SERVICES ...........................................................................................................................................................7

4.

BEST EXECUTION FACTORS ...................................................................................................................................................8

5.

BEST EXECUTION CRITERIA .................................................................................................................................................13

6.

SPECIFIC INSTRUCTIONS .....................................................................................................................................................14

7.

EXECUTION VENUES ...........................................................................................................................................................14

8.

CLIENT CONSENT ................................................................................................................................................................18

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.
4

ORDER EXECUTION POLICY1.
1.1.

INTRODUCTION

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and
6/132C(1) of the Companies Act 1981, registered with the Registrar of Companies under Company
number 54135 and with registered address 5th Floor, Andrew’s Place, 51 Church Street Hamilton HM 12
Bermuda.

1.2. The Company is operating in accordance with the above mentioned Laws.
1.3.

Best Execution is only owed when the Company accepts an Order to execute a transaction on the Client’s
behalf, or in other circumstances where the Client has otherwise expressly agreed to accept such Best
Execution obligations. As such, the obligation of Best Execution applies when the Company, acting in its
capacity as an intermediary, executes transactions based on an Order of a Client to buy or sell a Financial
Instrument, or when the Company is handling transaction Orders under its Portfolio Management
Services.

1.4.

When the Company provides quotes or negotiates a price with a Client on request (i.e. dealing on a
Request for Quote or „RFQ‟ basis), irrespective of whether it has initiated the transaction, the Company
will not be receiving a “Client Order” as part of a service where Best Execution will apply to determine
the price given to the Client. Accordingly, if the Client gives specific instructions for the execution of an
Order accepted by the Company, the Company will follow such instructions irrespectively of whether
by doing so it can achieve the best possible result from the execution of the specific Client Order.

1.5.

This Policy forms an integral part of the Company’s ‘Client Agreement - Terms and Conditions ofBusiness’. Therefore, by entering into a Client Agreement with the Company, the Client is also agreeing
to the terms of the Company’s Order Execution Policy, as set out in this document.

2.
2.1.

DEFINITIONS

For the purposes of this policy, the following words and expressions shall have the meaning set out next
to them:a. “Financial Instrument(s)”, when used hereinafter, unless the context requires otherwise, shallmean any one or more of the following financial instruments:(i)transferable securities;(ii)

money-market instruments;(iii)

units in collective investment undertakings;

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.
5

(iv)

derivative contracts that relate to securities, currencies, interest rates, yields, otherderivative instruments, financial indices which may be settled physically or in cash;

derivative contracts relating to commodities that may be settled in cash other than on
default or other termination event;(vi)
derivative contracts relating to commodities that can be physically settled if traded on an
RM and/or MTF;
(v)

(vii)

(viii)(ix)(x)

derivative contracts relating to commodities, physically settled, but not for commercial
purposes which have characteristics of other derivative financial instruments having
regard to whether they are cleared and settled through recognized clearing houses orare subject to margin calls;
derivative instruments for the transfer of credit risk;
financial contracts for differences;derivative contracts relating to climatic variables, freight rates, emission allowances or
inflation rates or other official economic statistics that must be settled in cash as well asderivative contracts relating to assets, rights, obligations, indices etc…;

if, and then only to the extent that, they are made available for trading through the Electronic
Trading Platform(s) of the Company, via the Company’s Website(s).

b.

“Order”, when used hereinafter, unless the context requires otherwise, shall mean an
instruction to buy or sell a Financial Instrument which is accepted by the Company fortransmission to a third party.

c.

“Execution Venue”, when used hereinafter, unless the context requires otherwise, shallmean a market maker, or other liquidity provider, or an entity that performs a function
in a third country that is similar to the function performed by any of the foregoing.

d.

“Execution Factors”, when used hereinafter, unless the context requires otherwise, shallmean those factors listed in Section 4 of this Policy.

e.

“Execution Criteria”, when used hereinafter, unless the context requires otherwise, shallmean those factors listed in Section 5 of this Policy.

f.

“Multilateral Trading Facility (“MTF”)”, when used hereinafter, unless the context
requires otherwise, shall mean a multilateral system, operated by an investment firm ora market operator, which brings together multiple third party buying and selling interest
in Financial Instruments.

2.2.

Unless the context otherwise requires, any capitalized words and expressions not
specifically defined in this Order Execution Policy, shall have the meanings assigned tothem in the “Client Agreement – Terms and Conditions of Business”, as published on our
Website.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.
6

3.

SCOPE AND SERVICES

3.1.

This Policy applies to ‘Retail’ and ‘Professional’ Clients.

3.2.

This Policy applies when executing transactions with Clients for the Financial Instruments provided by
the Company. The Financial Instruments provided by the Company are mainly derivatives of anunderlying Financial Instrument, and it is up to the Company’s discretion to decide which types ofFinancial Instruments to make available and to publish the prices at which and the manner in whichthese can be traded.

3.3.

The Client acknowledges that the transactions entered into with the Company in Financial Instruments
are undertaken through the Electronic Trading Platform(s) of the Company. The Orders will be executedon an ‘over the counter’ (OTC) basis rather than on a regulated market or a Multilateral Trading Facility.
Such Orders are automatically routed to an Execution Venue which the Company has assessed as toprovide for the best execution.

3.4.

The Client is given the option to place with the Company the following Orders for execution in thefollowing ways:a. The Client may place a “Market Order” which 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 thanthe 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 thetime of placing the Order) is an Order to limit a Client’s profit.
b. The Client may place a “Pending Order”, which is an Order to be executed at a later time at theprice that the Client specifies. The Company will monitor the Pending Order and when the priceprovided by the Company reaches the price specified by the Client, the Order will be executed atthat price. The following types of pending Orders are available: ‘Buy Limit’ (an Order to purchasea Financial Instrument at or below a specified price), ‘Buy Stop’ (an Order to buy a Financial
Instrument, which is entered at a price above the current offering price; it is triggered when themarket price touches or goes through the buy stop price), ‘Sell Limit’ (an Order to sell a Financial
Instrument at a specified price or better), and ‘Sell Stop’ (an Order to sell a Financial Instrument
when it reaches a certain price). The Client may attach to any Pending Order a Stop Loss and/or
Take Profit.

3.5.

The Client may modify an Order before it is executed. The Client has no right to change or remove ‘Stop
Loss’, ‘Take Profit’ and ‘Pending Orders’ if the price has reached the level of the Order execution.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.
7

4.

BEST EXECUTION FACTORS

4.1.

In Order to achieve Best Execution of Client Orders, the Company will use its own commercial
experience and judgment to determine the relative importance of a number of factors including price,costs, speed and likelihood of execution, settlement, size and any other factors relevant to the executionof your Order, together with the possible execution venues to which the Order can be directed.

4.2.

The Company will assume that the best available price at the time is the most important outcome for a
Client’s transaction unless it is instructed at the time of dealing that another factor is of greater
importance.

4.3.

To calculate the price, the Company will determine the total consideration. This is represented by theprice of the Financial Instrument and all expenses that are directly related to the execution of the Order,
including ‘Execution Venue’ fees, clearing and settlement fees and any other fees paid to third parties
involved in the execution of the Order.

4.4.

In particular, 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:A. Price:a. Bid – Ask Spread: For any given Financial Instrument the Company will quote two prices: thehigher price (“ASK”) at which the Client can buy (go long) that Financial Instrument, and thelower price (“BID”) at which the Client can sell (go short) that Financial Instrument; collectively
they are referred to as the Company’s price. The difference between the lower and the higher
price of a given Financial Instrument is the spread.
b. Pending Orders: Such Orders as Buy Limit, Buy Stop and Stop Loss / Take profit for opened shortposition are executed at ASK price. Such Orders as Sell Limit, Sell Stop and Stop Loss / Take profit
for opened long position are executed at BID price.
c.

Co mpa n y’s p ri ce : The Company’s price for a given Financial Instrument is calculated
by reference to the price of the relevant underlying Financial Instrument, which theCompany obtains from third party external reference sources. The Company’s prices areconstructed with reference to the given Financial Instrument’s Spreads and Conditions, which
can be found on the Company’s website.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

8

The Company updates its prices as frequently as the limitations of technology andcommunications links allow. The Company reviews it’s used third party external reference
sources at least once a year, to ensure that the data obtained continue to be competitive.
The Company will not quote any price outside Company’s operations time (see Execution Venue
below) therefore no Orders can be placed by the Client during that time.

B. Costs:
For opening a position in some types of Financial Instruments the Client may be required to pay
commission or financing fees, if applicable, the amount of which is disclosed in the Spreads andConditions section on the Company’s website.
a. Commissions: Commissions may be charged either in the form of a percentage of the overallvalue of the trade or as fixed amount.
b. Financing Fee: In the case of financing fees, the value of opened positions in some types ofFinancial Instruments is increased or reduced by a daily financing fee “swap” throughout thelife of the contract. Financing fees are based on prevailing market interest rates, which may varyover time. Details of daily financing fees applied are available under Spreads and Conditions
section on the Company’s website. For all types of Financial Instruments, which the Company
offers, the commission and financing fees are not incorporated into the Company’s quoted priceand are instead charged explicitly to the Client account.

C. Speed of Execution:
The Client acknowledges that the transactions entered into with the Company in Financial
Instruments are undertaken through the Electronic Trading Platform(s) of the Company. The Orders
will be executed on an ‘over the counter’ basis rather than on a regulated market or a Multilateral
Trading Facility. Such Orders are automatically routed to an Execution Venue which the company
has assessed to be the best execution. The Company places a significant importance when executing
Client’s Orders and strives to offer high speed of execution within the limitations of technology andcommunications links.
If the Client undertakes transactions on an electronic system, like the Company’s Electronic Trading
Platform(s), he/she will be exposed to risks associated with the system including the failure of
hardware and software (Internet/Servers). The result of any system failure may be that the Client’sOrder is either not executed according to the Client’s instructions, or it is not executed at all. The
Company does not accept any liability in the case of such a failure. The use of wireless connections
or dial-up connections or any other form of unstable connection at the Client’s end, may result in
TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

9

poor or interrupted connectivity or lack of signal strength causing delays in the transmission of data
between the Client and the Company when using the Company’s Electronic Trading Platform(s). Thisdelay may result in sending to the Company out of date “Market Orders”. In this case the Company
will update the price and execute the Order at the market price that is available.
The Client may request the Company to execute upon receipt instructions conveyed by telephone,facsimile, e-mail or any other written or oral means of communication that each of the present andfuture account holders, attorneys and duly authorized representatives shall give individually to theCompany, even if these instructions are not followed by a confirmation in writing. The Company
does not accept any liability in case of misunderstanding, error in the identification of the person
giving the instruction or other errors on its part related to such method of communication and which
may involve losses or other inconveniences for the Client. The Company reserves the right not to
execute instructions transmitted by telephone or fax. Telephone conversations may be recorded,
and the Client will accept such recordings as conclusive and binding evidence of the instructions.

D. Likelihood of Execution:
The Client acknowledges that the transactions entered into with the Company in Financial
Instruments are undertaken through the Electronic Trading Platform(s) of the Company. The Orders
will be executed on an ‘over the counter’ basis rather than on a regulated market or a Multilateral
Trading Facility. Such Orders are automatically routed to an Execution Venue which the company
has assessed to be the best execution. The Company places a significant importance when executing
Client’s Orders and strives to offer high speed of execution within the limitations of technology andcommunications links.
While the Company strives to execute all Orders placed by its Clients, it reserves the right to decline
an Order of any type or execute the Order at the first available market price. In case of technicalfailure of the trading platform or quote feeds, the Company may not transmit the Order for
execution or it may change the opening/closing price of an Order.
Under certain market conditions such as a fast moving market or low liquidity, the Company
reserves the right to modify the spread of the transactions.
In certain circumstances, such as unusual market conditions or the size and nature of the Client’sOrder, it may be wholly or partly manually priced and/or an Order may be manually transmitted forexecution, and then have an impact on the price at which the Order is executed.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

10

E. Orders:
The Client may request a quotation at the price that is stated on the Company’s Electronic Trading
Platform(s). However, due to the high volatility of the market, prices may change before a Client
can execute Orders at their determined price. The Company at this point, has the right to offer the
Client a new price. The Client can either accept the new price and execute the Order, or refuse thenew price, cancelling the Order transaction completely.
Orders can only be placed, executed, modified or closed within the trading time and shall remain
effective through to the next trading session. The Client’s Order shall be valid according to the type
and time of the given Order. If the time of validity of the Order is not specified, it shall be valid
indefinitely.
Order status is always shown on the Company’s Electronic Trading Platform(s) and can be accessed
via the Client’s online trading terminal. Should access to the Company’s Electronic Trading
Platform(s) not be possible, Clients may contact the Company by telephone and request the statusof any of their pending Orders.
‘Stop Loss’, ‘Take Profit’, ‘Buy Limit’, ‘Buy Stop’, ‘Sell Limit’, ‘Sell Stop’ Orders on Financial Instrument
contracts are executed at the price selected by the Client on the first current price touch. But undercertain trading conditions it may be impossible to execute such Orders (‘Stop Loss’, ‘Take Profit’,‘Buy Limit’, ‘Buy Stop’, ‘Sell Limit’, and ‘Sell Stop’) on any Financial Instrument contract at thedeclared price. In this event, the Company has the right to execute the Order at the first available
price. This may occur, for example, in the following circumstances:a. Trading Session start-up moments;b. During news times;c. During volatile markets where prices may move significantly up or down and away fromdeclared price;d. Where there is rapid price movement, if the price rises or falls in one trading session to suchan extent that under the rules of the relevant exchange, trading is suspended or restricted;
e. If there is insufficient liquidity for the execution of the specific volume at the declared price.
The Company strives to provide the best possible price to its Clients, and will make every effort andnecessary arrangements to do so; however, it may be impossible to guarantee the execution of any
or all of the Pending Orders at the declared price.
TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

11

The minimum level for placing ‘Stop Loss’, ‘Take Profit’, ‘Buy Limit’, ‘Buy Stop’, ‘Sell Limit’ and ‘Sell
Stop Orders’ is between 1 to 5 times the spread for a given Financial Instrument.

F. Likelihood of Settlement:
The Company shall proceed to a settlement of all transactions upon execution of such transactions.

G. Size of Order:
The minimum size of an Order is 0.01 lots. A lot is a unit measuring the transaction amount and it isdifferent for each type of Financial Instrument. Please refer to the Spreads and Conditions section
on the Company’s website for the value of each lot for a given Financial Instrument type. The
Company reserves the right to decline an Order as explained in the terms and conditions enteredwith the Client. The Company will make every effort to fill the Order of the Client irrespective of thevolume. However, if this is achieved, it may be at a best available price, different from declared
price, as the market liquidity may allow at the time of execution (See also above, Likelihood of
Execution).

H. Market Impact:
Some factors may affect rapidly the price of the underlying Financial Instruments from which theprice quoted by the Company for its Financial Instruments is derived. These factors may influencesome of the factors listed above. The Company will take all reasonable steps to obtain the best
possible result for its Clients.
4.5.

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. Furthermore, the Company may also take into
consideration a range of different factors including, the need for timely execution, availability of priceimprovement, the liquidity of the market (which may make it difficult to execute an Order), potential
price impact, the size of the Order, the nature of the financial transaction and the quality and costeffectiveness of any related clearing and settlement facilities. Nevertheless, whenever there is a specificinstruction from the Client the Company shall make sure that the Client’s Order shall be executed
following the specific instruction.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

12

5.
5.1.

BEST EXECUTION CRITERIAThe 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 accountthe criteria described below:
a. the characteristics of the Client including the categorization of the Client as a ‘Retail’ or‘Professional’ Client;b. the characteristics and nature of the Client Order;c. the characteristics of the Financial Instruments that are the subject of that Order;
d. the characteristics of the Execution Venues to which that Order can be directed;

e. the technical means at the disposal of the Company or in operation for the transmission of the
Client’s Order.
5.2.

For ‘Retail’ Clients, the best possible result shall be determined in terms of the total consideration,
representing the price of the Financial Instrument and the costs related to execution, which shall include
all expenses incurred by the Client which are directly related to the execution of the Order, including
execution venue fees, clearing and settlement fees and any other fees paid to third parties involved in
the execution of the Order.

5.3.

Where there is more than one available Execution Venue for the execution for an Order, thecommissions and the costs of the Company for transmitting the Order on each of the eligible Execution
Venues shall be taken into account when assessing and comparing the results for the Client that would
be achieved by executing the Order on each of the eligible Execution Venues.

5.4.

In cases of continuous fluctuations of the markets, the Company shall take into account the fact thatthe speed of execution may be more important than the selection of multiple offers from different
market participants.

5.5.

The Company undertakes not to structure or charge its commissions in such a way as to discriminate
unfairly between Execution Venues.

5.6.

Demonstrating best execution does not necessarily involve a transaction-by-transaction analysis, butrather involves an assessment of a record of transactions over a period, indicating that overall the best

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

13

result is achieved by executing Orders on the Client’s behalf on the Execution Venues and in the manner
described in this Order Execution Policy.

6.
6.1.

SPECIFIC INSTRUCTIONS

Exceptionally, when a Client provides specific instructions in respect of the execution of his Order, theCompany, notwithstanding its Order Execution Policy, shall execute the Order following the Client’s
specific instructions to the extent that the Order is affected by said instructions. The Client
acknowledges that the Company’s compliance with his specific instructions may deter the Company
from implementing measures it has established with the aim of attaining the best possible result for the
Client’s interests. To the extent that specific instructions relate to only one part of the Order, theCompany applies its Order execution policy for that part of the Order which is not covered by the Client’s
instructions, provided this is possible and in compliance with the instructions. In the event that, due toany reason whatsoever, the execution of the Client’s Order in accordance with his specific instructions
is not possible, the Company shall promptly inform the Client of the impossibility of execution and shallrequest new instructions relating to the execution of the Orders, having the right to act in accordancewith the Client’s presumable interest.

7.

EXECUTION VENUES

7.1.

Execution Venues are the entities with which the Client’s Orders are placed or to which the Company
transmits Orders for execution.

7.2.

The Client acknowledges that the transactions entered into through the Electronic Trading Platform(s)of the Company will be executed on an ‘over the counter’ basis rather than on a regulated market or a
Multilateral Trading Facility. Such Orders are automatically routed to an Execution Venue which thecompany has assessed to be the best execution. The Company places a significant importance when
executing Client’s Orders and strives to offer high speed of execution within the limitations oftechnology and communications links.

7.3.

For such online Orders, the Company is currently connected electronically to a wide range of RetailService Providers (RSP) who are market makers and liquidity providers in a range of instrument types.
When an Order is received the Company’s system will request a price from all Retail Service Providers
offering a price in the requested security and will select the best price returned and complete the Orderfollowing confirmation from its Client. In the event that an Order cannot be executed online it will berouted to a dealer who will negotiate the price with a market maker by telephone with reference to any

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

14

available electronically displayed prices. The Company believes that these execution methods ensurethat it takes all reasonable steps to meet its Best Execution obligations.
7.4.

In such instances, best execution is delivered in the form of transmitting the Clients’ Orders to those
Retail Service Providers, which can deliver, according to their Order Execution Policy, best execution of
the transmitted Orders. In the case of Retail Service Providers established in the European Union the
Company may reasonably presume that the Retail Service Provider enjoys a high grade of credibility.

7.5.

With respect to the transmission of Orders to such Retail Service Providers:a. The Company reserves the right to refuse the transmission of Orders concerning specificfinancial instruments if it does not have access to the execution venue through a Retail Service
Provider.
b. The Client is entitled to give specific instructions regarding the Retail Service Provider which will
execute his Order or other characteristics of the Order. In Order for these instructions to bebinding for the Company, the latter must expressly accept them. The acceptance of these
instructions further depends on the content of the cooperation agreement between the
Company and the Retail Service Provider and on the possibility and/or the intention of the latterto cooperate with the Company for the above purpose.
c. In case the Client has not given such instructions, the Company transmits the Client’s Order tothe Retail Service Provider of its choice. The choice of the Retail Service Provider is made withdue diligence, in Order to safeguard the Client’s interests. The Company is entitled to change
Retail Service Providers, according to the business requirements existing from time to time andaccording to its Clients’ interests.
d. The Retail Service Provider may carry out the transactions in the name of the Company on behalfof the Company’s Clients or directly in the name of the Client, depending on the terms agreed
between the Company and the Retail Service Provider and, if applicable, between the Client andthe Retail Service Provider.
e. The Company transmits the Client’s Orders to the Retail Service Providers with due diligence.
The Company also transmits any special instructions on behalf of the Client to the Retail Service
Provider. The Client Orders are executed in accordance with the Best Execution Policy of the
Retail Service Provider. The Company will not be liable towards the Client for any action or

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

15

omission of the Retail Service Providers within the course of execution of the Client’s Orders.
Should the Client suffer any damage due to actions or omissions of the Retail Service Provider,
the Company will provide assistance to the Client, if such assistance is necessary, in Order forthe latter to obtain satisfaction of his claim.
f.

The clearing and settlement of these transactions may be carried out by the Client’s Custodianor by third party firms other than the Retail Service Providers (hereinafter the “Clearing
Custodian”) either in the name of the Company (through the Company’s customers’ accounts)
or directly in the name of the Client, depending on the agreements between the parties involved
thereto as well as on the Client’s clearing and settlement instructions. In every case, theparticulars of the Clearing Custodian will be notified to the Client in a timely manner. The
Company does not undertake the custody of the financial instruments acquired directly in thename of the Client, such custody being carried out either by the Client’s Custodian or by the
Clearing Custodian, depending on the Client’s clearing and settlement instructions.

7.6.

The Company regularly assesses the Execution Venues available in respect of any products that theCompany provides to its Clients to identify those that will enable the Company, on a consistent basis, toobtain the best possible result when transmitting Orders for execution.

7.7.

Where there is more than one available Execution Venue for the execution of an Order, the commissions
and the costs of the Company for transmitting the Order on each of the eligible Execution Venues shallbe taken into account when assessing and comparing the results for the Client that would be achievedby executing the Order on each of the eligible Execution Venues.

7.8.

The Company places significant reliance to the above Execution Venue based on the above mentioned
factors and their relevant importance. It is the Company’s policy to maintain such internal proceduresand principles in Order to act for the best interest of its Clients and provide them the best possible result(or “best execution”) when dealing with them.

7.9.

The Client acknowledges that the transactions entered in Financial Instruments with the Company are
not undertaken on a recognized exchange, rather they are undertaken on an ‘over the counter’ (OTC)basis through the Company’s Electronic Trading Platform(s) 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 theCompany’s Electronic Trading Platform(s) or quote feeds.

7.10. Furthermore, in the above cases, there is no particular execution venue other than the Retail Service
Providers with which the Company shall negotiate the transactions. The Company undertakes all
reasonable endeavours in Order to select the Retail Service Provider fulfilling the Company’s best
execution requirements for the performance of each transaction. Nevertheless, the above selection
TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

16

may be limited depending on the number of Retail Service Providers accessible to the Company andavailable for the execution of such transactions from time to time. Therefore, in these instances, theClient’s transaction may not be performed in the best conditions (e.g. price or other) available in theentire OTC market but in the best conditions (e.g. price or other) available at the moment of negotiation
amongst the Retail Service Providers negotiating with the Company. In cases of continuous fluctuationsof the markets, the Company shall take into account the fact that the speed of execution may be more
important than the selection of multiple offers from different market participants.
7.11. While the Company strives to execute all Orders placed by its Clients, it reserves the right to decline an
Order of any type or execute the Order at the first available market price. In case of technical failure of
the Company’s Electronic Trading Platform(s) or quote feeds, the Company may not transmit the Orderfor execution or it may change the opening/closing price of an Order. Under certain market conditions
such as a fast moving market or low liquidity, the Company reserves the right to modify the spread of
the transactions. In certain circumstances such as unusual market conditions or the size and nature of
the Client’s Order, it may be wholly or partly manually priced and/or an Order may be manuallytransmitted for execution, and then have an impact on the price at which the Order is executed.
7.12. Clients will be able to close open positions in regard to any given Financial Instrument only during theoperating hours of the Company’s Electronic Trading Platform(s).
7.13. The operating hours of the Company’s Electronic Trading Platform(s) are as follows:a.

Working periods: round – the – clock from 00.00.01 A.M. Bermuda Time (GMT -4)
Monday through 00.00.00 P.M. Bermuda Time (GMT -4) Friday.

b.

Non-working periods: from 00.00.01 A.M. Bermuda Time (GMT -4) Saturday through00.00.00 P.M. Bermuda Time (GMT -4) Sunday.

c. Holidays: Holidays will be announced through the internal mail of the trading terminal suppliedby the Company.
7.14. The Company does not undertake any obligation to participate in additional markets or MTFs in which
the Financial Instruments concerned by the Client’s Order may be negotiated. In the event that theCompany participates in the future in another market or MTF – beyond those stated above – it willcommunicate its revised policy to the Client.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

17

8.

CLIENT CONSENT

8.1.

When establishing a business relation with the Client, the Company is required to obtain the Client’s
prior consent to this Policy. The Company is also required to obtain the Client’s prior express consent
before it executes or transmits its Order for execution outside a regulated market or an MTF(Multilateral Trading Facility). The Company may obtain the above consents in the form of a generalagreement.

8.2.

When this ‘Order Execution Policy’ is modified (hereinafter referred to as “Change(s)”) we will post such
Changes on our Website(s). Each such notification shall be deemed as sufficient notice and it is yourduty to consult and/or to check regularly this ‘Order Execution Policy’ on our Website(s) regarding any
such Changes. Therefore, you should review this ‘Order Execution Policy’ from time to time so as toensure that you will be aware of any such Changes.

8.3.

All amended terms shall be effective five (5) calendar days after their initial posting on our Online
Trading Facility, or as of the first time that you access and/or use our Online Trading Facility after such
amendments were made, whichever is sooner.

8.4.

Your continued access and/or use of our Website(s) and/or Online Trading Facility after the publicationof any Changes shall be considered as your agreement to such Changes and shall be governed by this‘Order Execution Policy’, as modified.

8.5.

IF YOU DO NOT WISH TO BE BOUND BY SUCH CHANGES, YOU SHOULD CEASE TO ACCESS AND/OR USE
OUR SERVICES AND/OR ONLINE TRADING FACILITY, AND INFORM US IN WRITING, IMMEDIATELY.

8.6.

You will be deemed to have accepted and to have agreed to any such Changes unless you notify us tothe contrary in accordance with the details of the Changes notified in accordance with the foregoing
within five (5) calendar days of the date of our notice of the relevant Changes. Where you object to a
Change, the Change will not be binding on you, but your Account will be suspended and you will be
required to close your Account as soon as it is reasonably practicable.

8.7.

Any Change will supersede any previous agreement between us on the same subject matter and will
govern any Transaction and/or Contract entered into after, or outstanding on, the date the new editionof this ‘Order Execution Policy’ comes into effect.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

18

9. MISCELLANEOUS
9.1.

In exceptional cases, especially in cases of force majeure, including failure of communication withselected Intermediaries, the Company may be obliged to use other execution methods than those
provided for in the present Order Execution Policy.

9.2. Upon the Client’s request, the Company is obliged to provide to the Client information concerning theexecution of the Client’s Orders in compliance with the Order Execution Policy. The Client’s request
must be submitted to the Company in writing and should make specific reference to the Order for which
information is requested.
9.3. Any such requests for information concerning the execution of a Client’s Orders in compliance with the‘Order Execution Policy’, and/or any other questions about this ‘Order Execution Policy’ must be direct
to the Company’s Compliance Department: compliance@traders-trust.com.

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

19

TTCM Traders Capital Limited, a limited liability Company, incorporated in Bermuda under section 14 and 6/132C(1) of theCompanies Act 1981 and registered with the Registrar of Companies under Company number 54135.

20