Order Execution Policy

1. Introduction

1.1. Luramic Ltd (“Luramic”, “Company”, “we”, “us”) is licensed as an Investment Dealer (Full Service Dealer Excluding Underwriting) by the Financial Services Commission (FSC) in Mauritius. This Order Execution Policy should be read in conjunction with our standard terms and conditions and any other applicable legal documentation governing the relationship between the Client and the Company.

1.2. This Order Execution Policy (“Policy”) describes the arrangements adopted by the Company to obtain the best possible result when executing, receiving and transmitting, arranging, or otherwise facilitating Transactions for its Clients. We are committed to conducting business with you honestly, fairly and professionally and to act in your best interests when executing client orders and we will take reasonable steps to achieve the best overall trading result for you.

1.3. The Company primarily provides liquidity and execution services to professional clients, institutional clients, brokers, financial institutions, asset managers, proprietary trading firms, and other sophisticated counterparties. The Company acts as principal and not as agent unless expressly agreed otherwise in writing.

1.4. We also intend to provide you and other market participants with access to (where possible) tradable prices on a non-discriminatory basis. However, the diversity in those markets and instruments, and the kind of orders that you may place, mean that different factors will have to be taken into account in relation to any particular transaction. The Client acknowledges that our price may differ from any price which is or might have been available elsewhere.

2. Scope Of Application

2.1. This Policy applies whenever the Company executes Orders, receives and transmitsWe are committed to conducting business Orders, arranges Transactions, provides liquidity, acts as principal counterparty or otherwise facilitates Transactions in Financial Products offered by the Company.

2.2. The Policy applies to all Financial Products made available by the Company from time to time, including foreign exchange instruments, precious metals, commodities, indices, contracts for difference, equities, digital assets (where permitted), and any other products offered pursuant to the Client Agreement.

2.3. The Company’s obligation is to take reasonable steps to obtain the best possible result for Clients on a consistent basis. Such obligation does not constitute a guarantee that the best available price or outcome will be achieved in every circumstance.

3. Client Classification And Market Practice

3.1. The Company generally provides services to Professional Clients, Eligible Counterparties, Institutional Clients and other sophisticated counterparties.

3.2. In wholesale over-the-counter markets, it is common market practice for market participants to obtain quotes from multiple liquidity providers, trading venues and market participants before entering into Transactions. Accordingly, Clients acknowledge that prices available from the Company may differ from prices available elsewhere and that the existence of alternative prices does not, of itself, indicate that best execution has not been achieved.

3.3. The Company may take into account the sophistication, experience, expertise and categorisation of the Client when determining the relative importance of execution factors.

4. Client Instructions

4.1. Where the Client provides specific instructions regarding an Order or any aspect of an Order, the Company shall execute the Order in accordance with those instructions to the extent reasonably practicable.

4.2. Where the Company follows a specific instruction provided by the Client, the Company shall be deemed to have satisfied its execution obligations in relation to those aspects of the Order covered by the instruction.

4.3. Specific instructions may prevent the Company from taking steps that it would otherwise take in order to obtain the best possible result for the Client.

5. Execution Factors

5.1. When executing Orders, receiving and transmitting Orders, arranging Transactions, or otherwise providing execution services, the Company shall take reasonable steps to obtain the best possible result for its Clients, taking into account all relevant circumstances prevailing at the time of execution.

5.2. In determining the manner in which an Order will be executed, the Company may consider a variety of execution factors, including but not limited to the price available in the market, the costs associated with execution, the speed and likelihood of execution and settlement, available liquidity, market depth, the size and nature of the Order, the characteristics of the relevant Financial Product, prevailing market conditions, operational considerations, counterparty risk, and any other factor which the Company reasonably considers relevant.

5.3. The relative importance assigned to each execution factor may vary depending upon the characteristics of the Client, the Financial Product, the Order itself, the execution venue, prevailing market conditions, liquidity availability and any specific instructions provided by the Client. Accordingly, the Company may determine that factors other than price are more important in achieving the best overall result in a particular circumstance.

5.4. The Company shall exercise its discretion reasonably and in good faith when determining the relative importance of execution factors and selecting the execution arrangements that it considers most appropriate in the circumstances.

6. Execution Venues And Liquidity Sources

6.1. The Company may execute Transactions through one or more execution venues and liquidity sources that it considers appropriate for obtaining the best possible result for Clients.

6.2. Execution venues may include banks, prime brokers, prime-of-prime providers, non-bank liquidity providers, market makers, regulated markets, multilateral trading facilities, organised trading facilities, systematic internalisers, electronic communication networks, internal liquidity pools and other counterparties approved by the Company.

6.3. The Company may add, remove, suspend or replace execution venues or liquidity providers at any time where it considers such action necessary to maintain execution quality, improve operational efficiency, manage risk or comply with legal and regulatory requirements.

6.4. The Company is under no obligation to disclose the identity of any particular liquidity provider, execution venue or hedge counterparty unless required by applicable law.

7. Liquidity Aggregation And Execution Methodology

7.1. The Company may aggregate liquidity from multiple sources and utilise automated execution technologies, smart order routing systems, aggregation engines, matching engines and other execution tools in connection with the execution of Client Orders.

7.2. Orders may be routed to one or more liquidity providers, executed against internal liquidity, matched against other client flow, split across multiple execution venues, partially executed or otherwise handled in a manner which the Company reasonably considers appropriate.

7.3. The selection of execution venues and liquidity sources is based upon a range of considerations, including the quality and reliability of pricing, available liquidity, execution performance, settlement capability, technological resilience, operational efficiency, creditworthiness and overall quality of service.

7.4. The Company continuously evaluates the suitability of its execution venues and liquidity providers and may add, remove, suspend or replace any execution venue or liquidity source at its discretion where it considers such action necessary to maintain execution quality, manage risk, improve operational efficiency or comply with applicable legal and regulatory requirements.

8. Principal Execution And Internalisation

8.1. The Company primarily acts as principal when entering into Transactions with its Clients. Accordingly, the Company may be the direct counterparty to a Transaction and may subsequently hedge, offset, retain or otherwise manage the resulting market exposure in accordance with its risk management arrangements.

8.2. In providing execution services, the Company may utilise liquidity aggregation technology, smart order routing systems, automated execution engines, matching systems and other execution tools designed to facilitate efficient execution and access to available liquidity. Orders may be routed to one or more liquidity providers, executed in whole or in part against internal liquidity, split across multiple execution venues, or otherwise handled in a manner which the Company reasonably considers appropriate to achieve the best possible overall result.

8.3. The Company is under no obligation to route any Order to a particular liquidity provider, execution venue or counterparty. Furthermore, the Company may determine that the best possible result can be achieved through internalisation, by matching Orders against other available liquidity, or through execution against the Company’s own principal position.

8.4. The Company does not guarantee that every Order will be executed at the best available price in the market at any given moment. Rather, the Company’s obligation is to take reasonable steps to achieve the best possible overall result having regard to all relevant execution factors and the circumstances prevailing at the time of execution.

9. Pricing And Quotations

9.1. Prices offered by the Company may be derived from one or more liquidity providers, market data vendors, exchanges, benchmark sources, proprietary pricing models or other sources deemed appropriate by the Company.

9.2. The Company may apply spreads, commissions, mark-ups, mark-downs, financing charges, swap rates, administrative fees or other charges as disclosed in the Client Agreement or applicable fee schedule.

9.3. The Company’s prices may differ from prices available through other market participants and may reflect market conditions, liquidity availability, volatility, execution risks and commercial considerations.

10. Execution Risks

10.1. Clients acknowledge that execution may be affected by market volatility, liquidity shortages, market disruptions, communication failures, technology outages, trading halts, latency, force majeure events, slippage, partial fills, rejected Orders and other factors beyond the Company’s reasonable control.

10.2. The Company does not guarantee execution at any particular price, time or level unless expressly agreed in writing.

11. Monitoring And Review

11.1. The Company monitors the effectiveness of its execution arrangements on an ongoing basis and regularly assesses whether its execution venues, liquidity providers and execution methodologies continue to achieve the objectives of this Policy.

11.2. The Company may review execution quality by reference to pricing competitiveness, execution speed, fill ratios, rejection rates, settlement performance, technological resilience and other relevant metrics.

11.3. This Policy shall be reviewed at least annually and whenever a material change occurs that may affect the Company’s ability to obtain the best possible result for Clients on a consistent basis.

12. Consent To Execution Arrangements

12.1. By entering the Terms and Conditions and continuing to place Orders with the Company, the Client acknowledges and accepts the terms of this Policy and consents to the Company’s execution arrangements, including execution outside a regulated market, multilateral trading facility or organised trading facility where applicable.

13. No Fiduciary Duty

13.1. Nothing in this Policy shall create any fiduciary relationship between the Company and the Client.

13.2. The Client remains solely responsible for its investment, trading and risk management decisions and acknowledges that the Company does not provide investment advice, portfolio management services or discretionary management services.