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Best Execution Mandate

Order Execution Policy

REF: BEST-EXEC-REG-606 // ACTIVE

1. Best Execution Mandate

The Firm is committed to seeking the most favorable terms for client orders reasonably available under the circumstances. This includes price, costs, speed, likelihood of execution and settlement, size, nature, and other relevant considerations.

2. Dark Liquidity Routing

A significant portion of The Firm's order flow is routed to non-displayed liquidity pools ("Dark Pools") to minimize market impact for large block orders. Clients acknowledge that execution in these venues provides price improvement but may lack pre-trade transparency.

3. No Payment for Order Flow (PFOF)

The Firm does NOT accept payment for routing order flow to specific venues. Our routing logic is purely algorithmic and designed to minimize slippage and maximize fill rate for institutional-sized tickets.

4. Handling of Limit Disorders

We protect your limit orders by routing them to venues that adhere to the Limit Order Display Rule (Rule 604), unless the order is of block size or otherwise exempt.

Last Updated: Q4 2025Compliance Officer Approval: GR-77