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Order Execution Policy

I. INTRODUCTION

Scope of policy

The Policy sets out our approach for carrying out exchange orders (hereinafter – “Orders”)
from origination to execution, the venues we use and an explanation of how the different
factors influence our execution approach, so that we can obtain the best possible result
when executing your Orders. Unless separately defined in this document, words and
expressions have the meanings given to them in our Customer Agreement or are used in a
widespread trading practices.

The trading Assets carry a high degree of risk. They are not suitable for everyone. You
should not trade with us unless you understand the nature of the transaction you are
entering into and the extent of your potential loss from a trade. You must satisfy yourself
that it is suitable for you in the light of your circumstances, financial resources and
investment objectives. If you are in any doubt you should seek independent advice. You
trade entirely at your own risk.

II. EXECUTION VENUES

We execute each Order you place with us by placing an order identical in all respects on to
the B2BX Exchange or in another Liquidity Pool. Our general approach is to place your
orders on the B2BX Exchange. B2BX Exchange provides exchange quality execution to both
buy-side and sell-side trading members. We have selected B2BX Exchange as the primary
execution venue.

III. LIQUIDITY POOLS

We may execute a Back to Back Order on other Liquidity Pools in order to facilitate fair and
orderly trading when it is not possible to do so on the B2BX Exchange. We will only execute a
Back to Back Order with a single liquidity provider who has provided consistent and reliable
historic pricing. All trading will be executed on a firm liquidity basis with no last look.

IV. EXECUTION OF ORDERS

Execution of orders. We execute each Order you place with us by placing an order identical
in all respects (a Back to Back Order) on B2BX Exchange or another Liquidity Pool. We place
Orders as principal and not as an agent on your behalf; we are the sole counterparty to your
trades. When our Back to Back Order is matched, we will execute a trade on your Account at
the same price and size.

Prices. The prices on which you trade with us will be the prices available to us on the B2BX
Exchange or another Liquidity Pool. Notwithstanding, the prices of such Back to Back Orders
may differ from the prices that are displayed at the time that you place your Order to trade
with us due to factors such as quantities on the order book, speed of execution and your
choice of connectivity.

V. EXECUTION FACTORS

The execution factors which we take into account when we execute your Orders and their
relative importance are as follows:

Price – highest importance:

The prices you receive are set by participants with the best Buy and Sell Orders determining
the bid and ask prices. Our prices mirror those of the B2BX Exchange and may differ from
those on other exchanges.

An Order placed with us for a specific size can result in a number of trades being executed
on the B2BX Exchange (or a Liquidity Pool) to fill that Order in whole or in part. If that occurs,
the prices you receive from us will depend on the liquidity on B2BX Exchange (or offered by
Liquidity Pools) at the time that the corresponding part of our trade is executed and the
prices may differ for each of the trades executed. In the case of Limit Orders the price you
receive at execution will be the price in your instruction or better. In the case of Market
Orders, Stop Market Orders the price you receive at execution will be the best price available
at the time our Back to Back Order is executed in whole or part on the B2BX Exchange (or another
Liquidity Pool). This could be better or worse than the price on B2BX Exchange (or a
Liquidity Pool) at the time your Order is placed with us.

Speed, consistency and likelihood of execution – high importance:

You may place Orders with us on-line via the WebGUI or over the Software Trading Tools
(API). We are under no obligation to accept an Order from you. However, we shall normally
do so if you have sufficient funds in your Account with us, you are not otherwise in breach of
the Terms of Business and it is possible to execute such Order. Factors such as the size of
your Order and liquidity available in the Deliverable Digital Currency Contracts you wish to
trade will impact whether and when it is possible to execute your Order.

The times at which you are able to submit Orders to us are might be restricted. Please see
the Website for further details. It is important that you familiarize yourself with the
restrictions on the submission of Orders before you commence trading with us, for these
restrictions may affect your trading strategy.

We may be unable to execute all or part of your Order if there is insufficient liquidity in the
Deliverable Digital Currency Contracts you wish to trade. If this occurs, the following will
apply: In the case of Limit Orders, the remaining quantity will stay on the Order Book until
canceled (Limit Orders is “Good ‘Til Canceled” or “GTC” orders on B2BX Exchange)

Limit Orders and Quantity available to trade – medium importance:

We have restrictions in place in terms of the minimum size of order you may hold in a
Deliverable Digital Currency Contracts at any one time. Any opening Order you place with us
will be subject to these restrictions. Our minimum order sizes are set by us for each
Deliverable Digital Currency Contract and may vary depending on current market conditions.
Our minimum order sizes as they apply from time to time can be found in the Instrument
Information on the Website. In addition, please note our ability to fill your Order is
dependent on our ability to fill our Back to Back Order.

Cost – low importance:

We will levy a separate commission charge for each trade that is opened or closed on your Account.
You do not incur an additional ‘spread’ charge with us as your trade is executed by
us at the same price as we obtain from the B2BX Exchange (or a Liquidity Pool). You will pay
the same commission whether we fill your order via B2BX Exchange or via another Liquidity
Pool. As such, commission is not a factor for choosing whether to fill Orders using B2BX
Exchange or another Liquidity Pool.

We shall wherever possible seek to comply with this Policy when we are required to exercise
our judgment in obtaining the best outcome for the execution of your Orders.

VI. FINAL PROVISIONS

Customer Communications. We will notify you of any material changes to our order
execution arrangements or this Policy in a durable medium or by updating our Website. By
trading with us, you will be taken as having agreed to the contents of this Policy.