Order Execution Policy

1. Scope

This policy applies to the receipt, transmission and execution of orders from retail and professional clients relating to the financial instruments within our authorisation.

2. Financial instruments

The policy covers the instruments for which we provide the relevant services. [LIST OF INSTRUMENT CLASSES HANDLED — TO CONFIRM]

3. Order types

Where supported, we handle the main order types (for example market, limit, stop and conditional orders). Specific client instructions are executed as indicated.

4. Execution factors

When executing orders we consider the following factors:

• price;
• costs;
• speed of execution;
• likelihood of execution and settlement;
• size of the order;
• nature of the order and any other relevant consideration.

5. Priority of factors

For retail clients, the best possible result is determined in terms of total consideration, i.e. the price of the instrument together with all costs related to execution. For professional clients, the relative importance of the factors is assessed also by reference to the characteristics of the order and the market.

6. Execution venues and arrangements

We select execution venues and intermediaries based on their ability to obtain, on a consistent basis, the best possible result for clients. [EXECUTION MODEL, VENUES AND INTERMEDIARIES ACTUALLY USED BY ASTEO — TO BE CONFIRMED. DO NOT STATE MODELS OR COUNTERPARTIES THAT HAVE NOT BEEN VERIFIED.]

7. Specific instructions

A specific client instruction may prevent us from taking the steps set out in the policy to obtain the best possible result in respect of the elements covered by that instruction.

8. Slippage and requoting

The execution price may differ from the requested price owing to volatility and liquidity (slippage). Where applicable to the operating model, requoting may occur before execution. [APPLICABILITY OF REQUOTING — TO CONFIRM]

9. Execution in volatile markets

In conditions of high volatility, reduced liquidity or at market open and close, execution may be delayed or occur at prices different from those expected.

10. Off-market orders

We do not knowingly execute orders at prices that do not reflect market conditions. Transactions executed at manifestly erroneous prices may be adjusted or cancelled under the applicable rules.

11. Monitoring and review

We monitor the effectiveness of the policy and review it at least annually and whenever a material change occurs. The updated version is available on request and in the client area.