Please read this policy on best execution in conjunction with our standard business terms.

1. Introduction:We are dedicated to conducting our business with honesty, fairness, and professionalism, always acting in your best interests when executing client orders. We will make reasonable efforts to achieve the best possible trading outcome for you, which means providing “best execution” while considering factors such as order nature, market prices available to us, the specific market involved, and a reasonable assessment of conflicting execution factors. Our goal is to maintain consistent standards and processes across all markets, clients, and financial instruments.We also aim to offer you and other market participants access to tradable prices on a fair and non-discriminatory basis. However, due to the diversity of markets, instruments, and types of orders, different factors will be taken into account for each transaction.
2. Exemptions from Best Execution Provision:Despite our intentions outlined above, we are not obligated to provide “best execution” in the following cases:
   1. Eligible Counterparties:In the wholesale OTC derivatives and bond markets, where our firm operates, it is common practice for buyers and sellers to approach multiple brokers/dealers for quotes without expecting best execution from a specific broker/dealer. As a sophisticated participant in these markets, unless you instruct us otherwise, we will assume this is your typical trading behavior.
   2. Client Instructions:If you provide us with specific instructions regarding your order or any particular aspect of it, including choosing a specific venue for execution, we will follow your instructions. However, please note that by following your instructions, we will be deemed to have taken all reasonable steps to provide the best possible outcome for the order or specific aspect covered by your instructions.
      
      
3. Clients:To ensure equitable and consistent handling of orders and expressions of interest, once a client is classified for a particular instrument, they may not request reclassification for a transaction of the same type they customarily undertake, unless exceptional circumstances arise with our consent.
4. Execution Venues:This Best Execution Policy outlines the venues where we may execute your orders. We act as the sole execution venue for all client orders executed on an ‘Over the Counter’ (OTC) basis. We have identified the venues where we regularly seek to execute your orders, considering the factors detailed below, to achieve the best possible results. Our ability to transact trades on your behalf extends to:

1. 1. Our liquidity providers;
   2. Regulated markets;
   3. Our customer base in the over-the-counter (OTC) markets, where applicable;
   4. Multilateral trading facilities operated by third parties;
   5. Systematic internalizes.
      
      When selecting a venue for executing trades, we will take reasonable measures to ensure that the chosen venue yields the best possible trading result for our clients. This selection is subject to the following factors:

1. 1. We can only provide visibility to prices communicated to us in the markets we operate in.
   2. We will provide details of all tradable bids and offers through the platform, considering other relevant factors.
   3. Price availability may vary due to trading lulls, spikes, and negotiation processes in different parts of the curve, making the “last traded” price an unreliable indicator of the current price.
   4. We will not allow clients to trade in a market unless we are reasonably satisfied that the client, directly or through an agent, can settle the trade.
   5. Fees may differ based on client agreements and activity levels.

5. Factors Influencing Execution:In the absence of explicit instructions from you, we will exercise our own judgment to determine the factors necessary to achieve the best possible execution outcome for you. These factors, applicable to the markets in which we operate, include but are not limited to:

1. 1. Client characteristics
   2. Order size, nature, and characteristics
   3. Likelihood and speed of execution
   4. Price and execution costs
   5. Settled block trades or positions exceeding the standard market size, which may be crossed at a specific stage during the trading day or kept anonymous to the majority of market participants, unless instructed otherwise.

6. Monitoring and Evaluation: While executing orders, we will take all reasonable measures to obtain the best possible outcome for you, considering factors such as price, costs, speed, likelihood of execution, settlement, size, nature, or any other relevant considerations (“Best Execution”). We have selected liquidity providers known for their strong reputation in providing deep liquidity in their respective markets. We will continuously monitor the effectiveness of our order execution arrangements and policies, making any necessary amendments.

Additionally, we will regularly assess whether the execution venues specified in our order execution policy continue to offer the best possible outcome for our clients. If required, we will make changes to our execution arrangements and providers. Ensuring the provision of Best Execution to our clients is our commitment, and we will conduct periodic due diligence and reviews of the liquidity provider(s) and the quality of service and execution provided.

Moreover, we will review our order execution arrangements and policies at least once a year or whenever a significant change occurs that may affect our ability to consistently achieve the best possible result for executing client orders using the venues stated in our order execution policy.

7. Order Management:We facilitate trade processing on an execution basis, utilizing ‘Straight Through Processing’ (STP), which automates transaction processing. The prices displayed on our trading platform and offered to you serve as indications of the prices at which we would be willing to buy from or sell to you. They are not fixed prices and should not be treated as such.

8. No Fiduciary Relationship:Our commitment to providing you with “best execution” does not imply that we owe you fiduciary responsibilities beyond the specific regulatory obligations imposed on us or as agreed upon in our contractual relationship. You retain responsibility for your own investment decisions, and we are not liable for any trading losses you may incur as a result of those decisions.