SECTION I. GENERAL EXECUTION

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1 EXECUTION POLICY for spread betting

2 SECTION I. GENERAL EXECUTION Introduction 1 The Applicable Regulations and our regulators, Financial Conduct Authority, require us to take all reasonable steps to obtain the best possible result for our Retail and Professional Clients when executing their orders or when receiving and transmitting their orders for execution. 2 The purpose of this document is to provide you with our order execution policy and obtain your consent to it. This policy should be read in conjunction with our Terms & Conditions. Therefore, by agreeing to our Terms & Conditions, you also agree to the terms of this execution policy.. Any material changes to our execution policy will be specifically notified to you in writing. All changes to this execution policy will be published on our Website at We will clarify any aspect of our policy and provide further information on request. 3 We apply this execution policy when we are executing your Orders and when we are receiving and transmitting your Orders with a view to obtaining the best possible result in terms of the total consideration, representing the price of the Spread Betting Products and the costs and expenses relating to execution of an Order, including the fees of the Underlying Market, the clearing and settlement fees as well as other fees and commissions payable to third parties in relation to the execution of the Order. Please also see our Market Information Sheet for spread betting on our Website. 4 All Trades in Spread Betting Products are entered into according to the rules and requirements applicable to the relevant Underlying Market, as well as in compliance with the governing law for the respective Spread Betting Products. DF Markets treats its clients equally. 5 We monitor and review the effective performance of this execution policy on an ongoing basis. If there is a need to update or amend this policy, we shall do so immediately. Nothing in this execution policy constitutes legal, investment or tax advice and this document is provided for information purpose only. An up to date copy of our execution policy is published on our Website. Unless separately defined in this Policy, We, Us or Our means DF Markets (Delta Financial Markets Limited) and You, Your or Yourself means the person to whom DF Markets provides its Services under its Terms and Conditions. Execution Criteria 6 In connection with our obligations under the Financial Conduct Authority regulations, we have established this order execution policy. Our policy requires us to take into consideration the following criteria: 1) your Client Classification; 2) the nature and characteristics of your Order; 3) the Spread Betting Products subject of your Order; 4) Underlying Market to which your Order can be directed; 5) we have complied with our obligation for best execution if we have executed the Order or a specific parameter thereof in accordance with your specific instructions; 6) execution factors relevant to the effective execution of the Order. 7 Subject to specific instructions received from you, we will execute your Orders directly outside a regulated market or Multilateral Trading Facility (provided we have your express consent) with a view to obtaining the best possible result for your executions in terms of the total consideration. 8 Where there are two or more competitive Underlying Markets specified in our execution policy for an Order relating to Spread Betting Products, we shall evaluate and compare possible results for each of these competing Underlying Markets and our commission and the execution expenses will be taken into account to achieve best execution. Relevant Factors 9 Relevant factors that we take into consideration include price, costs, speed of execution, likelihood of execution and settlement, size, type, and nature of the Order and any other consideration. These factors will only take precedence over the immediate price and cost consideration insofar as these are instrumental in delivering the best possible result to you. 10 We execute Client Orders in the best interest of our Clients and shall take all reasonable steps to determine the: 1) best price for the Client according to the Order submitted; 2) time of submission of the Order; 3) type of Order (market, limit, stop, limit/stop/ attached to a position, trailing stop, etc. which is to be confirmed, executed and valued manually or automatically); 4) speed and likelihood of execution (Orders to be executed in the moment of opening or closing of the relevant market on which the Spread Betting Product the subject of the Order is traded; execution in case of force majeure, etc.); 5) current liquidity of the relevant markets where the Spread Betting Products or underlying instrument is traded; 1

3 6) size of the Order (in particular when the quantity and/or requested price of the Order render its execution partially or completely impossible on the relevant market where the Spread Betting Product and/or the underlying instrument is traded); 7) price restrictions, if any, at the relevant market where the Spread Betting Product and/or the underlying instrument is traded; 8) amount of costs, if any; and 9) other circumstances relating to the execution of the Order. Consent 11 Before we are able to provide you our Services, we will require your prior express consent to this execution policy. You will be deemed to have provided such prior express consent if we receive an instruction to execute any Order on your behalf. 12 Notification of consent from you, after due consideration by you, may be given to us in writing by post, or online during the Account Opening Process by webpage click through or tick box. By doing so you acknowledge and confirm that you have received this order execution policy and accept our policy. You further accept that transactions on your behalf may be effected outside a regulated market or a multilateral trading facility. 13 Specific instructions from you in relation to the manner in which Transactions on your behalf should be given effect may prevent us from taking the steps that we have designed and implemented as part of our order execution policy to obtain best execution in respect of the elements covered by your specific instructions. Specific Instructions Warning 14 When you give us specific instructions in relation to the execution of a particular Order, we shall execute your Order according to your instructions. However, your specific instructions may affect our ability to follow our execution policy and the criteria set out in our execution policy may not be met. You acknowledge and accept your specific instructions may contradict our execution policy and may not necessarily lead to the best possible result in terms of the total consideration and that in such circumstances, we would be deemed by you to have complied with our obligation to provide for best execution. Provided we act according to your specific instructions, you accept we will not be held liable for any direct or indirect loss or damage that may result from the execution of your Order, which risks and consequences are to be borne entirely by yourself. 15 In order to provide its clients with the most competitive trading technology, we strive to use procedures which minimize the risk of delays and diminishing liquidity. In cases of Force Majeure events as provided in our Terms and Conditions or other events or factors which may influence the respective market, we may not be able to maintain the usual liquidity in the same volumes. The possible effects of such factors are unpredictable. These effects may cause considerable widening of the spreads, delay of the execution and when market, limit, stop or other orders are placed, they may be executed at prices significantly different from those at which they would have been executed in normal market conditions. Execution Venues: OTC 17 Orders executed on the over the counter ( OTC ) markets will be quoted by our electronic Trading Platform system. This system is not multilateral trading facilities (MTF) as defined in the MiFID. For OTC markets, there may not be a publicly available market price for the Spread Betting Products being traded. 18 Depending on the relevant factors available to us, such as unusual market conditions, size or type of the order, certain Spread Betting Products may be quoted manually, whether partially or completely, using our experience and commercial judgment when applying this execution policy with a view to achieving the best possible result in terms of the total consideration. However, the execution of an Order may be delayed under such circumstances and may reflect on the price at which the Order is executed. The Trade execution price will not always be the best price for the Client as compared to similar prices which are available or have been available on other execution venues. 19 With regard to trading in financial instruments on the OTC market, we shall execute your Orders by acting as a Counterparty (principal) to all Trades and as the only execution venue for your Orders. 20 In order to offer the best prices to our Clients, we have created a wide variety of Orders by which, in accordance with a certain trading strategy, our Clients may achieve their planned results. 21 The types of Spread Betting Products traded by us are: Bets on FX Products (based on currencies and precious metals) and Bets on non-fx Products (based on shares, indices, ETFs and futures). We act as the execution venue for all Orders for trading Bets on FX Products and Bets on non-fx Products. 1) Bets on FX Products The prices used for quoting currencies and precious metals are not based on futures, but have as a source, independent banks, as well as market makers providing liquidity on an unregulated market. 2) Bets on Non-FX Products 2

4 We have access to the quotes of at least one stock exchange whereon the underlying shares, indices, ETFs or futures are traded. In addition, we may enter into trades in Bets on shares, Bets on indices, Bets on ETFs and/or Bets on futures with at least one investment firm or market maker and it is on this basis that the price of the respective Spread Betting Product is determined. Our experience allows us to use sources which provide reliable services, with the key factors for the price composition being the reliability and frequency of renewals. Alternative Execution Venue 22 In the event we believe an alternative execution venue outside of our specified list of execution venues may be more suitable in achieving our execution policy objectives, you accept we are entitled to use such execution venues on either an occasional or permanent basis, as appropriate. We endeavour to ensure that we do not directly or indirectly discriminate between Client Orders when executing via multiple execution venues. 23 If at the moment of placement of the Order from a Client, we are not able to execute that Order on the execution venue, as stipulated in this Policy, due to an official holiday, commercial events or technical restrictions, the Order may be executed on an alternative execution venue, provided the Client s interests are protected in accordance with the this execution policy. If the alternative execution venue chosen cannot be used, additional instructions from the Client regarding his execution venue will be required. 24 If an Order is received outside the trading hours of the requested execution venue, it will be executed on the following trading day for that execution venue. If the Client wishes the Order to be directed for execution on the same day, he must instruct us on the specific execution venue. Without such additional instructions on the specific execution venue from the Client, we will not change the execution venue for the Order, even if such Order is not or cannot be executed on the requested execution venue for a long period of time. SECTION II. MONITORING AND REVIEW 25 From time to time, we will monitor and review the effectiveness of our order execution policy and assess whether execution venues meet our regulatory obligations. Material changes to our order execution policy and its arrangements will be notified to you in writing. 26 The provision of our best execution policy does not mean we assume any additional duties or responsibilities over and above the regulatory obligations imposed on us by MiFID and the FCA Rules or as may otherwise be contracted between us. 27 For Spread Betting Products which do not fall into a certain class of assets, specific instructions from our Client regarding their execution venue are required. 3

5 D e l t a F i n a n c i a l M a r k e t s L i m i t e d is a company registered in England and Wales It is authorised and regulated by the Financial Conduct Authority (FCA) Business Address: 5 Harbour Exchange Square, London E14 9GE, UK; Tel. +44(0) , Fax +44(0) Registered Address: 3rd Floor, Fairgate House, 78 New Oxford Street, London WC1A 1HB, UK Company Registration Number:

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