Order Execution Policy

1.1 This policy describes the manner in which we handle, transmit and execute Orders that you send to us in respect of the financial instruments we make available on our trading platforms. The instruments in scope are: (a) rolling-spot foreign exchange contracts and CFDs (contracts for difference) referencing external underlyings such as currency pairs, precious metals, equity indices and crypto-assets (together, the "Currency-Venue Instruments"); and (b) synthetic instruments produced by our own price engine, comprising our Volatility Indices (the Alpha, Delta and Sigma families) and our Surge Indices (the SRU/SRD 300 and 600 families) (together, the "Synthetic Instruments").

1.2 This policy applies to all Orders you place through any interface we make available, including our web platform, our mobile applications, third-party platforms we integrate with, and any application programming interface we expose to you. It applies to all account types offered by TFC Global Markets and to both demo and real-money accounts, save that Orders on demo accounts are simulated and are not executed against any external venue.

1.3 We provide services only to natural persons who are eighteen years of age or older and who are treated by us as consumer clients. We do not offer services to eligible counterparties, and we do not classify any client as a professional client. We do not accept United States persons and we do not solicit business in jurisdictions where the offer of contracts for difference to retail persons is prohibited.

In this policy, capitalised terms have the following meanings unless the context requires otherwise.

3.1 We deal with you as principal, and not as agent. On every Order accepted by us, we are the counterparty to the resulting contract. You do not enter into any contract with any third-party venue, exchange or Liquidity Provider by virtue of trading with us, and no order is passed through to any external market in your name.

3.2 In respect of Synthetic Instruments, prices are generated by our own price engine. There is no external market for the Synthetic Instruments and no straight-through routing to any third-party venue in respect of them. Our price engine derives quotes from parameters including reference volatility, tick generation rules and the published contract specification for each instrument. The published specifications for each Synthetic Instrument, including tick size, tick value, contract size, margin rate and Trading Hours, are available on our website and within the Platform.

3.3 In respect of Currency-Venue Instruments, we operate a straight-through processing model. On acceptance of your Order, we contemporaneously enter into an equal and opposite transaction with one or more Liquidity Providers, or manage the resulting exposure on our own book, at our discretion and consistent with our risk management framework. In every case, the contract between you and us is a principal-to-principal contract, and your rights and obligations are owed to and by us.

3.4 We do not act as a broker, agent or introducer in relation to any Order. We do not receive any Order on behalf of, or transmit any Order for the account of, any third party. We do not pass identifiable client Order flow to any Liquidity Provider, and no Liquidity Provider has visibility of you as an identified client.

3.5 The economic effect of the principal model is that our revenue in respect of any given trade is derived from the spread between our bid and offer prices, any published commission or financing charges, and (in the aggregate across all client positions) the difference between amounts received from and paid to clients. This model is disclosed to you and the structural conflict that arises from it is addressed in section 14.

4.1 When executing your Orders, we take into account a range of factors, which we refer to as the Execution Factors. The Execution Factors are:

(a) price;

(b) cost (including spread, commission and any applicable financing);

(c) speed of execution;

(d) likelihood of execution and of settlement;

(e) size of the Order;

(f) nature of the Order (including whether it is a market, limit, stop or other Order type); and

(g) any other consideration relevant to the execution of the specific Order.

4.2 For our client base, which consists exclusively of consumer clients trading through electronic Platforms in modest sizes and with strong sensitivity to transaction cost, we assign the following relative importance to the Execution Factors:

(a) price and cost together are the most important factors and are treated jointly as "total consideration";

(b) speed of execution and likelihood of execution and settlement are the next most important;

(c) size, nature and other considerations are relevant on an Order-by-Order basis and may become the most important factor where the specific Order requires it (for example, a large Order in a thin market where likelihood of execution predominates).

4.3 This ordering may be varied for a particular Order where the specific circumstances of that Order, or a specific instruction from you (see section 7), so require.

5.1 For Synthetic Instruments, the sole execution venue is our internal book. Our price engine is the sole source of quotes, and we are the sole counterparty. There is no alternative venue against which we could route Orders in Synthetic Instruments, and there is no external reference price against which such Orders could be benchmarked.

5.2 For Currency-Venue Instruments, the execution venue is our internal book, priced from and hedged against quotes provided to us by our Liquidity Providers. The identity of our Liquidity Providers is available on request to legal@tfcglobalmarkets.com. Our Liquidity Providers include tier-one and tier-two financial institutions and specialist non-bank market makers. We reserve the right to add, remove or replace Liquidity Providers at any time and without prior notice to you where doing so is consistent with the Execution Factors and with our risk management framework.

5.3 The list of Instruments we make available, together with their contract specifications, margin rates and Trading Hours, is published on our website and within the Platform. We reserve the right to add, remove, suspend or modify Instruments in accordance with the Client Agreement.

6.1 Market Order. A market Order is an instruction to execute at the best price we are then quoting. On receipt, and subject to system availability, we will execute the Order at our then-current price. That price may differ from the price displayed on the Platform at the moment you submitted the Order because of price movement between submission and receipt. See section 8 regarding slippage.

6.2 Limit Order. A limit Order is an instruction to execute only at a specified price or better. A buy limit Order will be executed at or below the specified price; a sell limit Order will be executed at or above the specified price. Where our quoted price reaches or crosses the limit level and market conditions permit, the Order will be executed. Where the level is not reached, the Order will remain pending in accordance with its time-in-force.

6.3 Stop Order. A stop Order is an instruction that becomes a market Order once a specified trigger price is reached. Once triggered, execution follows the same rules as a market Order, and the executed price may differ from the trigger price.

6.4 Stop-loss and take-profit Orders. Stop-loss and take-profit Orders are contingent Orders attached to an open position. A stop-loss becomes a market Order to close the position when the trigger price is reached; a take-profit is treated as a limit Order to close the position at or better than the specified price. Neither Order type guarantees execution at the specified level, and stop-loss Orders in particular may be filled at a materially different price during periods of volatility, illiquidity or trading halts.

6.5 Trailing stop. Where available, a trailing stop is a stop Order whose trigger level is adjusted automatically by reference to the movement of the market price in your favour. It does not adjust in the opposite direction. On triggering, it is treated as a market Order.

6.6 Time-in-force. We support the following time-in-force designations, subject to availability on the relevant Platform: good-till-cancelled and good-for-day. Where you do not specify a time-in-force for a pending Order, the default is good-till-cancelled.

7.1 Where you give us a specific instruction in relation to an Order, or any particular aspect of an Order, we will execute the Order in accordance with that instruction to the extent we are able to do so. A specific instruction may prevent us from taking the steps in this policy that we would otherwise take to seek the best possible result for you.

7.2 The submission of an Order using non-default parameters (for example, a limit price, a specified size, a specified time-in-force, or a maximum permitted deviation) constitutes a specific instruction in respect of that parameter. It does not constitute a specific instruction in respect of any parameter for which you have not deviated from the default.

8.1 Slippage means the difference between the price at which you expected to be executed (or the price displayed on the Platform at the moment of submission) and the price at which the Order was actually executed. Slippage may occur in either direction: negative slippage produces a worse execution price for you, and positive slippage produces a better execution price for you.

8.2 Where positive slippage arises on the execution of your Order, we pass the benefit of that slippage to you in full. We do not retain positive slippage.

8.3 Where negative slippage arises, execution is subject to a maximum permitted deviation set by us per Instrument. If the available execution price at the moment of processing is worse than the reference price by more than the maximum permitted deviation, the Order will be rejected, and no position will be opened. You may also specify your own, tighter maximum permitted deviation on an Order-by-Order basis, in which case that instruction will apply as a specific client instruction under section 7.

8.4 Slippage tends to be more pronounced around scheduled economic releases, at the open and close of major sessions, during periods of low liquidity and in fast-moving markets. You should size and time your Orders accordingly.

9.1 In respect of certain Instruments and certain Order types, we may respond to your Order by offering you an alternative price at which we are willing to deal. This is a requote. A requote is not an execution; it is an offer that lapses if not accepted within the time we specify.

9.2 Requotes may occur where the price displayed on the Platform at the moment of submission is no longer available at the moment of processing, or where market conditions are such that we cannot honour the displayed price consistent with our risk management framework. Requotes are more likely on illiquid Instruments and in fast-moving markets.

10.1 An Order may be executed in part where the size available at the acceptable price is less than the size of the Order. Where an Order is partially filled, the executed portion becomes an open position and the unexecuted portion is either cancelled or remains pending, in accordance with the Order type and time-in-force.

10.2 We do not charge additional commission for partial fills of a single Order beyond the commission that would have applied to the Order as a whole, where commission applies.

11.1 We do not aggregate Orders across clients. Each client's Order is handled on its own terms, and no client's execution is dependent on the execution of another client's Order.

11.2 We may internalise offsetting flow between our own book positions, but this internalisation takes place after Order acceptance and does not affect the price at which any client Order is executed.

12.1 Each Instrument has published Trading Hours. Orders in respect of Currency-Venue Instruments submitted outside Trading Hours will be accepted as pending Orders and will be considered for execution on the next opening of the relevant market. The opening price may be materially different from the last traded price before the close, and pending Orders (including stops) may be triggered on the opening quote.

12.2 Our Synthetic Instruments trade twenty-four hours a day, seven days a week, subject to scheduled maintenance windows notified in advance. Orders in Synthetic Instruments may be placed at any time during their published Trading Hours.

12.3 We may suspend trading in any Instrument during periods of extreme volatility, disorderly markets, technical incidents affecting our systems or those of our Liquidity Providers, or any other circumstance we reasonably consider to warrant suspension. During any such suspension, no Order will be executed and pending Orders in the affected Instrument will not be triggered.

13.1 We operate an internal execution-quality monitoring process. That process is conducted by our own staff, according to standards we set ourselves, as a matter of commercial and operational best practice. It is not a regulator-mandated best-execution regime, and nothing in this policy should be read as a representation that we are subject to such a regime.

13.2 Our monitoring process examines, on a sampling and periodic basis: quoted spreads against reference data; realised slippage distributions; rejection rates; latency between Order submission and Order acceptance; and the incidence of requotes and partial fills. The output of that monitoring feeds into decisions about our price engine parameters, our maximum permitted deviations, and the composition of our panel of Liquidity Providers.

13.3 We keep records of Order and execution data sufficient to enable this monitoring and to respond to any query you may raise about the execution of a specific Order. If you have a concern about the execution of a specific Order, you may raise it with us at support@tfcglobalmarkets.com in accordance with the complaints procedure set out in the Client Agreement.

14.1 Because we act as principal on every Order and are the sole counterparty to your trades, our revenue depends, in the aggregate across all clients, on the difference between what we receive from clients and what we pay to clients. There is therefore a structural conflict between our interests and yours: taken as a whole, we benefit when clients as a group make losses.

14.2 We disclose that conflict to you rather than obscure it. We manage the conflict through the following measures:

(a) we publish our spread schedules and contract specifications, and we do not vary them on a client-by-client basis for reasons connected to that client's profitability;

(b) we do not exercise dealer discretion over the execution of Orders that have been accepted by our system; execution is automated and follows the rules set out in this policy;

(c) our risk management function, which manages our aggregate exposure, is organisationally separate from our client-facing functions, and neither function has visibility of, or influence over, decisions taken by the other in respect of any individual client;

(d) our compensation arrangements for client-facing staff are not linked to individual client trading results; and

(e) our Synthetic Instrument price engine operates on published rules and is not adjusted in response to the position of any individual client.

14.3 Further information about our approach to conflicts of interest is set out in the Client Agreement.

15.1 We review this policy at least annually, and on any material change to our execution arrangements, our panel of Liquidity Providers, the composition of our Instrument range, or the internal monitoring output referred to in section 13.

15.2 A material change to this policy will be notified to you by publication of an updated version on our website and, where the change materially affects your rights or the way in which your Orders are handled, by direct notice to the email address registered on your account. Your continued use of our services after publication of an updated policy constitutes your acceptance of that update.

16.1 By opening an account with us, by continuing to hold an account with us following publication of this policy, and by placing an Order with us, you consent to this policy and to the execution of your Orders in accordance with it, including in respect of the execution of Orders outside a regulated market or multilateral trading facility (there being no such market or facility in respect of the Instruments we make available).

16.2 If you do not consent to any part of this policy, you must not place Orders with us and you should close your account in accordance with the Client Agreement. Any query about this policy may be directed to legal@tfcglobalmarkets.com.