CNPJ 37484255000187



Order Execution Policy

1. Purpose of the Policy

Under the Applicable Laws, Trading BitBaxter Markets (hereafter referred to as “the Company”,

”the Firm”,”we”, “our” and “us”) is required to have in place an Order Execution Policy
and to take all sufficient steps to obtain the best possible result (best execution) on behalf of
its Clients. This Order Execution Policy sets out the means, by which we will meet our best
execution obligations when executing orders for our Clients. This Policy does not impose any
fiduciary responsibilities or duties over and above the specific regulatory obligations placed
upon us or as may be otherwise contracted between us.
Our Order Execution Policy applies when we execute Orders from you to trade in any of the
Financial Instruments offered by us, which include (but are not limited to) Contracts for
differences on Currency pairs (Forex), Indices, Commodities, Futures, Exchange Traded
Funds (ETFs), Cryptocurrencies, Shares, Fractions of Shares (a proportion of a share),
cash-settled Equities and ETFs.
Subject to any specific instructions that may be given by you, we will take all sufficient steps
to obtain the best possible result for you, taking into account the Execution Factors listed
below. The application of best execution, where the Company engages with a Client on a
request for quote basis, will depend on whether the Client “legitimately relies” on the
Company to protect his or her interests in relation to the pricing and other elements of the
transaction, such as speed or likelihood of execution and settlement, that may be affected
by the choice made by the Company when executing the Order. What constitutes best
execution will vary with the circumstances of the Order and the preferences of the Client.

We have determined the relative importance of the Execution Factors in line with our legal
and regulatory obligation to determine the best possible result in terms of the total
consideration, representing the price of the financial instrument and the costs relating to the
execution of an Order.

2. Execution Factors

We have determined that the order of importance of the execution factors is the same
across all BitBaxter products and markets; that for all Retail Clients, the best possible result will be
determined in terms of the total consideration, representing the price of the financial
instrument and the costs related to execution.

For all financial instruments the Company offers, we quote two prices: the higher price (BUY),
at which you can buy the instrument, and the lower price (SELL), at which you can sell it. The
price for a given contract is calculated by reference to the price of the relevant underlying
financial instrument. We obtain this price from a range of third-party reference sources.
With respect to our Share Dealing Services, there will be a third-party securities exchange
from which we will obtain this price.
The Company’s prices can be found on Trading BitBaxter’s proprietary Trading Platform. The prices are
updated as frequently as the limitations of technology and communications links allow, but
should be considered an indication of the live market price rather than a quotation. The
number and price of shares are indicative and may vary at execution of Market Orders. This
indicative price may vary from the price, at which a trade may be executed, depending on
factors such as, but not limited to, movements in the foreign exchange markets between the
time that you place the Order and the time that the Order has been executed. The same
applies if there is a delay between the time that you place an Order and the time that the
Order is executed.
The Trading Platform may show you the target profit in the currency of the account. This
information is indicative and not guaranteed. The Company reviews its third-party external
reference sources from day to day to ensure that the data obtained is as timely and
accurate as can be. When the price reaches an Order level set by you, for example: Stop,
Take Profit, Trailing Stop, Market Order, Limit Order, these Orders are executed immediately.

However, under certain trading conditions, there is a possibility that these Orders cannot be
executed at your requested price.
When this happens, the Company has the right to execute the Order at the first available
price. This may occur, for example, at times of rapid price fluctuations if 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. Such fluctuation can result in a better or worse price
being received. This may also occur during thin liquidity conditions.
If a trade is executed outside of a regulated trading venue (e.g. for fractional shares), the
Order will be filled at no worse a price than that of the reference price on the reference
In exceptional circumstances (such as increased volatility or reduced liquidity in relation to
the underlying market concerned), BitBaxter may be forced to alter the spreads on CFD products

For CFD contracts, in most circumstances, BitBaxter applies a spread (mark-up on the underlying
spread), and no other charges or commissions are payable by Clients. The price quote
shown on the Trading Platform already includes any additional spread, and there will be no
additional spread or commissions added to the execution price. For any positions held open
overnight, the Company will credit or debit your account on a daily basis with an overnight
interest swap, which is charged at 10 pm (CET). The amounts of these interest swaps are
updated daily and can be found within the Trading Platform product information pages.
For Share and ETF transactions, BitBaxter does not charge any commission or apply additional
spread upon the execution prices, it does, however, apply FX conversion costs in the
purchasing of securities in a currency other than your deposit currency. All fees are visible to
you prior to the point of sale as they fluctuate in line with the relevant underlying spot
market. Other applicable fees relating to stamp duty or local tax regulations are applied in
accordance with the relevant governing body and visible within the Trading Platform prior to
All costs associated with any execution as added by BitBaxter are detailed within the “Trading
Instruments” section of our Website and within the Trading Platform and are not dependent
on any priority criteria chosen by BitBaxter or execution method.

Speed of Execution
When you submit a Market Order or a stop loss is triggered, BitBaxter considers that the speed
with which a trade is executed is of significant importance to its Clients. BitBaxter’s execution
engine ensures all CFD contracts are executed automatically. Market Orders are therefore
filled immediately on the next available price, whilst Stop or Limit Orders would be filled once
their target level is reached.
Similarly, for Share and ETF transactions, where T212 has chosen to route the Order to the
Firm’s own ‘Systematic Internaliser’ venue, Market Orders will be executed on the next price
update once received from the relevant securities venue to validate the reference price, for
most products this will result in immediate execution. If a Market Order is routed to a
regulated market/exchange, execution will be confirmed to you once a trade confirmation is
received from the trading venue. Whilst the majority of Orders are filled immediately, BitBaxter will
generally prioritize price of execution over speed, depending on market conditions prevailing
that it is in the best interest of the Client.
Other factors that may affect execution speed include poor internet connection or any other
link to the Company’s servers and platform, which may affect the execution of your Orders.

Additional Factors:
BitBaxter also takes into consideration other best execution factors, including the likelihood of
execution and settlement of Orders, the size and nature of the transaction or Order, liquidity
in the market and the availability of price improvement, in order to obtain the best possible
result for you.

Transaction Size and Nature:
All transaction execution is subject to size considerations. If the requested transaction size is
larger than BitBaxter is able to trade in the ‘underlying market’ on the relevant exchange at that
time, then the entire transaction or Order may be restricted or rejected, but BitBaxter may offer
greater liquidity than the ‘underlying market’ at its discretion. Every market quoted by BitBaxter
has an absolute minimum and maximum permitted, and this can be found by clicking on
the information icon button associated with each market. The maximum transaction size
may vary due to market conditions and is, at all times, at the discretion of BitBaxter.

In the event of a transaction request of unusual size or where the market in which the
transaction has been requested is liquid or very volatile, BitBaxter may prioritize price over
speed of execution and may, at its sole discretion, only accept the transaction after BitBaxter has
covered the exposure in the underlying market.
Likelihood of Execution and Settlement:
In almost all circumstances, your transaction requests will be executed automatically at the
level requested or prevailing market level in case of a Market Order request, subject to the
size requested equal to or under the size permissible by BitBaxter at that time.
In order to minimise possible rejections, BitBaxter applies maximum Client Order sizes in line with
the typical liquidity of the underlying instrument or security, therefore enabling BitBaxter to
maintain a high execution rate.
In certain circumstances, due to speed of internet communications, market volatility or in
the case of an erroneous price being submitted, transactions may be rejected by BitBaxter, if the
price requested by you is not representative of the ‘underlying market’ price when received
by BitBaxter.
In some situations, BitBaxter may provide a partial fill of a transaction request as an alternative to
outright rejection. If an Order can only be executed partially due to various reasons or
applicable limits, you authorise us to make all reasonable efforts to execute that part of the
In determining the importance given to the other factors (speed, likelihood of execution and
settlement, the size and nature of the Order), BitBaxter will exercise its discretion in assessing the
criteria that we need to take into account to provide Clients with the best result. The relative
importance of these criteria will be judged in terms of the total consideration representing
the price of the financial instrument and the costs relating to execution and with reference
to market conditions including the need for timely execution, availability of price
improvement, the liquidity of the market and size of your Order (which may make it difficult
to execute an Order) and the potential impact on total consideration. In certain
circumstances, therefore, BitBaxter may determine that the speed, and likelihood of execution
and settlement, for example, may take precedence over immediate price and cost factors if
they are instrumental in delivering the best possible result. This may be the case, for

example, for Orders in illiquid or non-electronically executable shares or when a stop has
been triggered.

3. Transparency of Pricing

In executing your Orders, BitBaxter does not receive any remuneration, discount, or
non-monetary benefit for routing Client Orders to a particular Trading or Execution Venue,
which would infringe any conflicts of interest or inducement requirements under MiFID II.
However, and in the case where the Firm receives such inducements, such amounts may be
received if and only if the inducement is designed to enhance the quality of the relevant
service to the Client and does not impair compliance with the Firm’s duty to act honestly,
fairly, and professionally in accordance with the best interest of its Clients. BitBaxter charges fees
only as provided in the Firm’s Invest Terms, or as may otherwise be agreed between BitBaxter and
you. It is noted that the price when executing Orders may include a mark-up/down. The
mark-ups depend on various circumstances, including, amongst others, the nature of the
Financial Instrument and market conditions. When CFDs are offered, BitBaxter may charge a
spread on the transaction. This spread includes a mark-down on the bid (sell) price and a
mark-up on the ask (buy) price we receive from our price source and/or the prices we
receive from our selected Execution Venues. In general, in relation to CFD products, the term
“spread” often encompasses two layers of costs since a markup to a reference price may be
applied, but that reference price is also derived from a market price with an accrued ‘core’
spread already factored in. Any mark-up applied will be symmetrical to either:
a. the data received from independent market data providers or publicly available
sources (when dealing on own account), or
b. the price provided by the selected Execution Venues or liquidity providers relating to
the provision of CFDs and other speculative products. We will not seek to benefit from
you through asymmetric price movements.

4. Algorithmic Trading

BitBaxter does not place significant reliance on algorithmic trading systems to meet its obligation
to take sufficient steps to obtain on a consistent basis the best possible result for the
execution of your Orders.

5. Execution Criteria

The Execution Criteria that will be taken into account are the characteristics of:
a. the Client (and the Client’s categorization);
b. the characteristics of the Order;
c. the characteristics of the Financial Instruments that are the subject of that Order; and
d. the Execution Venues to which that Order can be directed.
For completeness, the Company has chosen to classify all of its clients as Retail and offer
best execution to all its clients accordingly.
6. Execution Venues
Whilst BitBaxter typically acts as principal in respect of Client Orders, it will assess the venues
available to it for the pricing and hedging of CFD contracts and the execution of Share and
ETF transactions. Presently whilst CFDs are manufactured by BitBaxter, it is, therefore, the sole
execution venue available for CFD contracts and, therefore, will always act in a principal
For Share Dealing transactions BitBaxter may act as agent and route your Orders directly to one
of its nominated brokers, who will execute at any of the available venues or will act as
principal and execute Orders via the Firm’s own ‘Systematic Internaliser’ venue. BitBaxter will
always inform you where the transaction has been executed as a part of its post-trade
notification process. BitBaxter is required to publish annually the top five execution venues that
we use and the summary of the analysis of the quality of execution obtained on the
execution venues. These are published on the Company Website.
BitBaxter views that price and costs associated with the execution (total consideration) are, in
most cases, the most important factors for Clients and therefore are prioritised when
determining the best possible result for its Clients, but also considers how each of the other
execution factors are affected, for example, speed of execution and likelihood of Order
acceptance in a variety of markets and Order types.

The financial soundness and Order execution policies of any counter party or venue are also
considered. In respect of CFDs, the Firm will seek to manage risk as a market maker and may
choose whether to hedge part or all of the CFD contracts in the underlying market. With this
approach, BitBaxter believes there is a greater likelihood of reduced execution costs and market
price impact for its Clients overall. Where hedging in the underlying market is required, this
may affect the price of the Contract that BitBaxter enters into with you, considering the prevailing
market prices available to BitBaxter.
For the avoidance of doubt, our Order Execution Policy provides that BitBaxter may execute Client
Share and ETF transactions and will execute client CFD Contracts outside a regulated market
or MTF. This approach allows BitBaxter to consistently source the best price for your Orders,
however, it does bring with it a greater counter party and settlement risk compared to
trading on exchange. Further information is provided within the Disclosures Notice in relation
to these risks.
BitBaxter directs client Orders to executing venues, which allows it to obtain on a consistent basis
the best possible result for the execution of client Orders. Such venues are subject to change
as the Firm sees fit and shall include, amongst others, regulated markets, multilateral
trading facilities (‘MTFs’), market makers (e.g., RSPs), systematic internalisers, executing
brokers and other liquidity providers. A non-exhaustive list of the execution venues, upon
which the Firm places significant reliance is to be published on the Order Execution Policy
page of the Website and will be updated at least annually.
BitBaxter periodically reviews which execution venues it uses and will consider, amongst other
factors, the firms’ reputation, the number of liquidity pools/regulated markets/MTFs
accessible via the venue and the use of smart Order routing technologies to source the best
available prices. Additionally, where BitBaxter operates its own systematic internaliser, BitBaxter will
regularly review the performance of the Systematic Internaliser’s best execution delivery
against executions available via other trading venues and assess whether additional
sources of quotations could improve the execution performance for you.

7. Trading outside a Regulated Market or a
Multilateral Trading Facility (MTF) or Organised

Trading Facility (OTF)
Under Brasil gov. rules, where an instrument is admitted to trading on a Regulated Market,

we are required to obtain your prior express consent before we arrange for an
Order in such instruments to be executed at an alternative venue. When agreeing to our
terms and conditions, you express your consent to us arranging for their Orders to be
executed outside a Regulated Market.
Orders executed outside a Regulated Market,will conform to our Best Execution
Policy and should not disadvantage you. When executed in this manner, all Market Orders in
equity instruments will be executed at the best available price on the primary trading venue
of the relevant equity instrument near to or at 100% of the time.
Trades executed off-exchange will be filled at a price no worse than the prevailing best Bid
/Offer on the reference exchange.
For transactions executed outside a Trading Venue, there are certain transparency
requirements, and specific information has to be made public. The information will be
published via an Approved Publication Arrangement.

8. Execution arrangements involving connected

Where BitBaxter is executing your Orders with a connected party (e.g., an entity within the same
group), it will remain responsible for delivering best execution to you. BitBaxter ensures that any
such arrangements with a connected party:
a. are made on an arm’s-length basis, such that the connected party is considered
alongside other third-party venues and is selected because it allows the Firm to
deliver the best possible result to you on a consistent basis.

b. allow the Firm to have sufficient, independent oversight of its execution arrangements
(i.e., that oversight is not performed by the connected party).
c. ensure sufficient and free access to information to ensure the Firm can effectively
monitor and challenge execution prices provided by the counterparty; and
d. where a connected party is selected on the basis that it offers reduced execution
costs, the Firm will ensure that this would result in a benefit to you.

9. Aggregation

The Company will not aggregate your Order with another Client’s Order, unless the following
conditions are met:
a. It is likely that the aggregation will not work to the overall disadvantage of any Client,
whose Order is to be aggregated;
b. It has been disclosed to each Client, whose Order is to be aggregated, that the effect
of aggregation may work to its disadvantage in relation to a particular Order (as
disclosed in the Firm’s Invest Terms); and
c. the Order will be aggregated in accordance with this Policy, which is designed to
achieve a fair allocation of aggregated Orders and transactions, including how the
volume and price of Orders determine allocations and the treatment of partial

10. Allocation Policy

In accordance with the obligations under the applicable laws, the Company will endeavour
to provide you with prompt, fair and expeditious execution of Orders placed with the
Company relative to other Orders from its Clients. In so doing, the Company:
a. promptly and accurately records and allocates Orders executed on behalf of Clients;
b. carries out 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; and

c. informs Clients about any material difficulty relevant to the proper carrying out of
Orders promptly upon becoming aware of the difficulty.

11. Ensuring Best Execution

As a manufacturer of CFDs, BitBaxter’s quotes are bespoke to the Firm’s own product terms and
therefore, the way in which BitBaxter ensures that it meets its best execution obligation to you is
by ensuring that in its calculation of its bid/offer prices, due regard is given to the market
price for the underlying reference product to which the CFD relates. BitBaxter subscribes via its
data vendor to multiple price feeds, including nominated wholesale market participants and
from regulated markets/exchanges, upon which its products are listed or from which its
instruments are derived. BitBaxter reviews the list of exchanges used for sourcing the Best
Bid/Offers periodically in Order to source the best available liquidity.
Due to the nature of online trading platforms, when you instruct a trade via the Trading
Platform, quotes are shown indicatively to you. Upon receipt of the Order request, BitBaxter
validates the Order terms (price, quantity, direction) against the live bid/offer quotes to
provide execution. In the event of price slippage between the time that you instruct a trade
and its execution, BitBaxter operates symmetric price slippage, i.e. both positive and negative
slippage will be passed onto the execution price.
Where BitBaxter receives specific instructions from you as to how to execute an Order, as is the
case with Limit Orders, BitBaxter will have complied with its obligation to take all sufficient steps to
obtain the best possible result when executing that Order by following those instructions.
Specific instructions may prevent BitBaxter from following this Policy. To the extent that specific
instructions do not cover every aspect of the Order, as is the case with Market Orders, BitBaxter
will apply this Policy for those parts or aspects of the Order not covered by the your
In normal market conditions, BitBaxter will always prioritize the price, inclusive of all associated
costs (total consideration), as the highest priority in determining the best outcome for you.
For Share and ETF transactions, where the size and nature of the Order permit it,BitBaxter will
execute the Order via its Systematic Internaliser in the first instance. Following this priority of
venues ensures that the price given to you will, in most cases, be at least as good as the
best Bid/Ask price of the primary exchange, upon which the instrument is listed. Furthermore,
BitBaxter is able to provide immediate execution and therefore, there is a greater likelihood of

execution and settlement. By eliminating the usual broker transaction fees (broker
commission), the total consideration when executing a your Order via BitBaxter’s Systematic
Internaliser should always be cheaper overall than what you would pay for this instrument
with other market participants. However, BitBaxter will continuously monitor the market and the
market participants with their fee models and adjust its procedures accordingly if there are
indications of a change with regard to best execution.
In case of system failures or exceptional market conditions, in rare cases, it may be
necessary to deviate from these execution principles. Even in these circumstances, BitBaxter will
make every effort to achieve the best possible result for you.
Market conditions can affect the time it takes to execute all orders/order types, including
Limit Orders, Stop Orders and Market Orders. All Orders are executed in due turn. We cannot
guarantee that a Limit Order or a Stop Order will be executed even if the Limit or Stop Price is
reached. We do not accept any liability for any actual or potential loss you may suffer if
there is a delay in execution. Market conditions may result in the execution of a Stop Order
being at a price above or below the Stop Price. We may also introduce restrictions on a
temporary or permanent basis regarding a certain type of Order (e.g. Limit Order, Stop Order
and/or Market Order) in certain or all Investments.

12. Monitoring

BitBaxter is required to monitor the effectiveness of its order execution arrangements and this
Order Execution Policy to identify and, where appropriate, correct any deficiencies. BitBaxter
conducts regular monitoring of its performance in accordance with this Policy to ensure that
deficiencies are identified and corrected in a timely manner. Independent assessment of the
manner of order execution is also performed by Bitbaxter’s internal auditors to provide assurance
as to the effectiveness of the processes.
Where required, BitBaxter provides on an annual basis data reports relating to the top five places
of execution in terms of trading volumes in the preceding year in accordance with the
Commission. These reports will be publicly available on
our Website.

13. Review

BitBaxter will assess whether the execution venues included in this Order Execution Policy provide
the best possible result for you or whether we need to make changes to our execution
arrangements. We will review our order execution arrangements and this Order Execution
Policy at least annually or whenever a material change occurs that affects our ability to
obtain the best result for the execution of orders on a consistent basis using the venues
included in this Order Execution Policy. For the purpose of this Policy, a material change shall
be a significant event that could impact parameters of best execution, such as cost, price,
speed, the likelihood of execution and settlement, size, nature or any other consideration
relevant to the execution of the Order.
Such material changes will include, amongst others, consideration of the following:
a. the addition or removal of Execution Venues or brokers;
b. changes in products (financial instruments) or services offered by the Company;
c. changes in the relative importance of best execution factors and criteria;
d. material market impact;
e. material change in the level of costs resulting from connection to a venue;
f. development of significant new execution procedures or a change in the market
model of an existing venue;
g. major change to existing arrangements, such as a material change in the human or
technical resources that the Company relies on to provide best execution;
h. complaints in relation to a major issue noted by a Client (in such case, this would not
necessarily trigger a review of the entire Policy).

14. Fractional Shares

A fractional share is a term used to describe the purchase by an investor of a proportion of a
share. An investor may accrue multiple fractions to own more than one share in aggregate.
Trading Fractional Shares with BitBaxter, therefore, encompasses fractions of a share and trading
in low numbers, typically one or two shares.

Fractions of shares are not listed on an exchange in their own nature, while the relevant
share is usually listed on an exchange. Similarly, single share Orders in shares may often be
prohibited by some execution venues, leading to uncertainty of execution. Orders in these
small sizes will therefore be executed via BitBaxter’s Systematic Internaliser. Our Disclosure Notice
covers any conflicts of interest issues that might arise in such a situation.
BitBaxter will comply in all respects with “best execution” on all Orders executed through BitBaxter in
line with its regulatory requirements. This means that execution will be based on a price no
worse than the prevailing bid/offer on the reference exchange as of the time of your Order
for all full share and fractional share components of a transaction. Any Order greater than
one share that includes a fractional share component will be executed in a mixed capacity.
BitBaxter will act in either a principal or risk less principal capacity with respect to the fractional
share components of the transaction. If you enter an Order solely for a fractional share, BitBaxter
will execute your trade over-the-counter, matching it internally based on a price no worse
than the prevailing bid/offer on the reference exchange as of the time of your order. Orders
entered outside of regular trading hours cannot be executed.
If you place an Order for a share (which Order is denominated in a certain monetary
amount), and that monetary amount is not enough to buy one or more shares, you may
only have enough money to acquire a fraction of a share. In order to give effect to your
Order, BitBaxter will enter into a Fractional share transaction with you in terms of which the
underlying reference instrument will be a percentage of the share specified in your Order.
BitBaxter rounds all fractional holdings to eight decimal places. For all notional based Orders,
your transaction will never exceed the order amount. Rounding may also affect your ability
to be credited for cash dividends, stock dividends and stock splits. For example, if you own
0.00000001 shares of stock that pays a one cent dividend per share, we will not credit your
cash balance a fraction of a cent. In carrying out rounding, we will use reasonable
endeavours to get as close as possible to your Order, however, we shall not be liable for any
loss or damage suffered or incurred by you arising out of or in connection with such
rounding, save to the extent directly attributable to our negligence, fraud, wilful default,
breach of contract or breach of Rules.

15. Consent

We are required to obtain your prior consent to our Order Execution Policy. It will be deemed
that you have provided such prior consent when they have given us an Order.
When this ‘Order Execution Policy’ is modified (hereinafter referred to as “Change(s)”), we will
post such Changes on our Website. Each such notification shall be deemed as sufficient
notice, and it is your duty to consult and/or to check regularly this ‘Order Execution Policy’ on
our Website regarding any such Changes. Therefore, you should review this ‘Order Execution
Policy’ from time to time, so as to ensure that you will be aware of any such Changes.
Your continued access and/or use of our Website and/or Online Trading Facility after the
publication of any Changes shall be considered as your agreement to such Changes and
shall be governed by this ‘Order Execution Policy’, as modified.
You will be deemed to have accepted and to have agreed to any such Changes, unless you
notify us to the 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.
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 edition of this ‘Order Execution Policy’ comes into effect.

16. Status of this Policy

This Policy forms part of the Trading BitBaxter Markets & PRIME CONSULTORIA E COMERCIO DE ALIMENTOS LTDA

CFD Terms and Invest Terms.
All words and phrases highlighted and not defined in this Order Execution Policy, shall have
the same meaning as defined in our Invest Terms and CFD Terms.

17. Order types and processing

When trading, Clients can make use of several Order types. Please note that some order
types are only applicable to the Share Dealing Services, while other order types are
applicable only to CFD trading.
Associated Order – This order type is only applicable to CFD trading. It shall be executed if
the market price reaches the price specified in the order. This order is associated with an
open position. If the open position is closed, then the Associated Order shall be
automatically cancelled. During market hours, the Associated Order shall be executed at the
specified price. The Associated order may be executed at a different price when the market
opens. There are 3 types of Associated Orders:
a. Stop Loss Order – it is used to close the open position at a certain loss. The Trading
Platform may show you the target loss in the currency of your account. This
information is indicative and not guaranteed.
b. Take Profit – it is used to close the open position at a certain profit. The Trading
Platform may show you the target profit in the currency of your account. This
information is indicative and not guaranteed.
c. Trailing Stop – a Stop Loss Order where the specified price follows the market price at
a certain distance.
Entry Order – This order is applicable only to CFD trading. It shall be executed if the market
price reaches the price specified in the Order. The Entry Order is used to open a new position
or to modify an existing open position. The execution price of the Entry Order is not
guaranteed. This order may be executed at a different price, especially when the market is
volatile or not liquid. There are 3 types of Entry Orders:
a. Stop/Limit – this is either a “Stop” order or a “Limit” order. The Trading Platform shall
automatically set the type of the order according to the current market price and the
specified price.
b. One cancels the other (OCO) – is a combination of two Entry Orders where the
execution of one of them automatically cancels the other.

Market Order – This Order type will be executed immediately (or upon the next price update)
at the best available market price. This Order should be used if you want execution at any
event. Please note that the price might change before execution, especially with less liquid
financial instruments. This Order type triggers execution but does not guarantee the price, at
which it will be executed. Therefore, please use this type of Order with care.
Limit Order – Using this Order type, you can set a minimum price (for a sell Order) or a
maximum price (for a buy Order) for which you want to execute your Order. In the case of a
Limit Order to sell, your Order will be executed if the price obtainable in the market is equal to
or higher than the price you have set. In the case of a Limit Order to buy, your Order will be
executed if the price obtainable in the market is equal to or lower than the price you have
set. You are responsible for cancelling any Limit Order instructions set on stocks that you
wish to withdraw. Applicable only to Invest trading.
Pending Order – This order type is applicable to CFD and Invest trading. It is an Order to be
executed at a later time and with regard to at the price that the Client specifies. The
Company will monitor the Pending Order and when the price provided by the Company
reaches the price specified by the Client, the Order will be executed at (the best available
price) that price. The following types of Pending Orders are available:
● ‘Buy Limit’ (an Order to purchase a Financial Instrument at or below a specified price);
● ‘Buy Stop’ (an Order to buy a Financial Instrument at or above a specified price);
● ‘Sell Limit’ (an Order to sell a Financial Instrument at or above a specified price); and
● ‘Sell Stop’ (an Order to sell a Financial Instrument at or below the specified price).
Please note that Pending Orders will be executed instantly in cases when the current market
price fits the predefined Order specifications.
Once accepted by us, a Pending Order CFD trading services can still be modified by you.
While, once accepted by us, a Pending Order for Invest services cannot be amended. If you
would like to amend an Invest Pending Order that you have already placed, you have to
cancel it (before it has been executed) and make a new one.
At all times, we reserve the right to amend or cancel your Pending Order due to market
Stop Order – A Stop Order is an Order to buy or sell a stock once it meets the Stop Price
predetermined by you. When the stock hits your Stop Price, the Stop Order becomes a

Market Order. It then executes the Order at the best price available (or upon the next price
update). Investors often place Stop Orders to help reduce potential losses in case the stock
moves in the wrong direction. There is the risk that short-term fluctuations in a stock’s price
can trigger a Stop Order resulting in a Market Order being executed. If you place a Stop
Order that is higher than the normal market size and the price at which it is to be executed is
significantly different from the Stop Price, we will still proceed to execute the Order.
Applicable only to Invest trading.
Stop Limit Order – This type of Order operates similarly to the Stop Order, however, instead of
generating a Market Order, upon hitting your pre-defined stop-loss limit, our systems
generate a Limit Order. The main advantage is that an Order cannot be executed at a worse
price than your limit, however, there is an additional risk that due to this limit, no execution
may take place at all. Applicable only to Invest trading.
Cancelling an Order
If you place a Limit Order or Stop Order on an Investment in respect of which trading is
suspended or has a Corporate Action before execution or if your Account is suspended, we
may, at our sole discretion, cancel the Pending Order.

18. Definitions

Execution Venue means a Regulated Market, an MTF, an OTF, a Systematic Internaliser, or a
market maker or other liquidity provider or an entity that performs a similar function in a
third country to the function performed by any of the foregoing.
Market hours means the time span of trading on the financial markets as indicated on our
Website. During those market hours, the Clients shall have the right to place Orders for
execution for those Financial Instruments whose exchanges are open for trading.
Market Order 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 than the 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 the time of
placing the Order) is an Order to limit a Client’s profit.

Multilateral Trading Facility (MTF) means a multilateral system operated by an investment
firm or a market operator, which brings together multiple third-party buying and selling
interests in Financial Instruments – in the system and in accordance with non-discretionary
rules in a way that results in a contract in accordance with the provisions of MiFID II.
Regulated Market means a multilateral system, operated and/or managed by a market
operator, which brings together or facilitates the bringing together of multiple third-party
buying and selling interests in Financial Instruments – in the system and in accordance with
its non-discretionary rules – in a way that results in a contract, in respect of the Financial
Instruments admitted to trading under its rules and/or systems, and which is authorised and
functions regularly and in accordance with the provisions of MiFID II.
Stop Price – A Stop Price is the price predetermined by you when setting a Stop Order. Once
the stock hits the Stop Price, the Stop Order becomes a Market Order.
Systematic Internaliser means an investment firm, which, on an organised, frequent and
systematic basis, deals on own account by executing Client OOrders outside a regulated
market or an MTF.
Order means an instruction to buy or to sell as placed by you via your Account on the
Trading Platform.
Organised Trading Facility (OTF) means a multilateral system, which is not a regulated
market or an MTF and in which multiple third-party buying and selling interests in bonds,
structured finance products, emissions allowances or derivatives are able to interact in the
system in a way that results in a contract in accordance with the provisions of MiFID II.

19. Miscellaneous

In exceptional cases, especially in cases of force majeure, including failure of
communication with selected Intermediaries, the Company may be obliged to use other
execution methods than those provided for in the present Order Execution Policy.
Upon execution , the Company is obliged to provide you with information concerning the
execution of your Orders in compliance with the Order Execution Policy. Your request must be

submitted to the Company in writing and should make specific reference to the Order for
which information is requested.
Any such requests for information concerning the execution of your orders in compliance
with the ‘Order Execution Policy’, and/or any other questions about this ‘Order Execution
Policy’ must be directed to the Company’s Compliance Department:
This Order Execution Policy was last updated and published on 11.09.2023. A copy of the most
up-to-date version of this Order Execution Policy is available on our Website.

When investing, your capital is at risk. Investments can rise and fall and you may get back less than you invested.


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