Order Execution Policy

1. Introduction and Purpose

This Order Execution Policy (the "Policy") outlines how DB Finser executes client orders for financial instruments. The purpose of this Policy is to ensure that we take all sufficient steps to obtain the best possible result for our clients when executing orders on their behalf.

This Policy applies to all orders executed by DB Finser on behalf of clients in relation to financial instruments covered by applicable regulations. It is designed to comply with regulatory requirements and to ensure transparency in our order execution practices.

2. Execution Factors

When executing client orders, DB Finser considers multiple factors to achieve the best possible result. The relative importance of these factors depends on the characteristics of the client, the order, the financial instrument, and the execution venues.

2.1 Primary Execution Factors

The following factors are considered when determining the best possible execution:

• Price: The price of the financial instrument
• Costs: All costs related to execution, including commissions, fees, and spreads
• Speed: The likelihood of execution and settlement
• Likelihood of Execution: The probability of the order being executed
• Size of Order: The size and nature of the order
• Market Impact: The effect the order may have on the market price
• Nature of Order: Any specific instructions from the client

3. Execution Venues and Arrangements

DB Finser uses various execution venues to achieve the best possible execution for client orders.

3.1 Types of Execution Venues

We may execute orders through:

• Regulated markets and multilateral trading facilities (MTFs)
• Systematic internalizers
• Market makers and liquidity providers
• Other brokers or dealers
• Electronic communication networks (ECNs)

3.2 Selection of Execution Venues

The selection of execution venues is based on our assessment of which venues are most likely to deliver the best possible result for our clients, taking into account the execution factors outlined in Section 2. We regularly review our execution venues to ensure they continue to meet our execution quality standards.

4. Specific Client Instructions

When a client provides specific instructions regarding the execution of an order, DB Finser will execute the order in accordance with those instructions.

4.1 Effect of Specific Instructions

Where a client provides specific instructions that cover one or more aspects of the order execution, we will execute the order in accordance with those instructions. This may prevent us from taking the steps set out in this Policy to obtain the best possible result in respect of those aspects covered by the instructions.

4.2 Examples of Specific Instructions

Specific instructions may include:

• Specifying a particular execution venue
• Setting limit prices or stop loss levels
• Specifying timing of execution
• Requesting immediate or fill-or-kill execution
• Specifying partial execution preferences

5. Order Types and Execution

DB Finser accepts various types of orders, each with specific execution characteristics.

5.1 Market Orders

Market orders are executed at the best available price in the market at the time of execution. These orders are typically executed immediately, subject to market liquidity.

5.2 Limit Orders

Limit orders are executed at a specified price or better. These orders may not be executed if the specified price is not available in the market.

5.3 Stop Orders

Stop orders become market orders once a specified price level is reached. Execution is not guaranteed at the stop price, particularly in volatile market conditions.

5.4 Other Order Types

We may offer additional order types with specific execution characteristics. Details of available order types and their execution parameters are provided in our trading platform documentation and client agreement.

6. Order Aggregation and Allocation

DB Finser may aggregate client orders with our own orders or with orders of other clients under specific conditions.

6.1 Aggregation Conditions

Order aggregation may occur when:

• It is unlikely that the aggregation will work overall to the disadvantage of any client
• We have disclosed our aggregation policy to affected clients
• We have implemented procedures to ensure fair allocation of aggregated orders
• Aggregation is in the best interests of the clients involved

6.2 Allocation Procedures

When orders are aggregated, allocation is made on a fair and equitable basis, considering factors such as order size, timing of order placement, and any specific client instructions. Detailed records of aggregation and allocation decisions are maintained.

7. Monitoring and Review

DB Finser regularly monitors the effectiveness of our order execution arrangements and the quality of execution obtained for clients.

7.1 Regular Review

We conduct regular reviews of:

• The quality of execution obtained from our execution venues
• The effectiveness of our order execution arrangements
• Compliance with this Policy
• Client complaints related to order execution

7.2 Policy Updates

This Policy is reviewed at least annually, or more frequently if there are material changes to our execution arrangements, market conditions, or regulatory requirements. Any material changes to this Policy will be communicated to clients.

8. Client Classification

DB Finser classifies clients in accordance with regulatory requirements, which may affect certain aspects of order execution.

8.1 Professional Clients

Professional clients are presumed to have the experience, knowledge, and expertise to make their own investment decisions and properly assess the risks involved.

8.2 Retail Clients

Retail clients receive the highest level of protection under applicable regulations. This Policy is designed to ensure that retail clients receive the best possible execution in accordance with regulatory requirements.

9. Conflicts of Interest

DB Finser maintains policies and procedures to identify, prevent, and manage conflicts of interest that may arise in relation to order execution.

9.1 Conflict Management

We have implemented measures to manage conflicts, including:

• Chinese walls between different business areas
• Independent oversight of execution quality
• Transparent pricing and fee structures
• Regular monitoring of execution practices

9.2 Disclosure

Where conflicts of interest cannot be adequately managed, they will be disclosed to affected clients in accordance with our Conflicts of Interest Policy.

10. Record Keeping

DB Finser maintains comprehensive records of order execution in accordance with regulatory requirements.

10.1 Records Maintained

We maintain records of:

• Client orders and their execution
• Execution venues used
• Prices obtained for client orders
• Any specific client instructions
• Complaints related to order execution
• Reviews of execution quality

10.2 Retention Period

Order execution records are retained for a minimum of five years from the date of execution, in accordance with regulatory requirements.

11. Client Consent and Acknowledgement

By opening a trading account with DB Finser and placing orders, clients acknowledge that they have read, understood, and accepted this Order Execution Policy.

Clients consent to DB Finser executing their orders in accordance with this Policy. Where specific execution instructions are provided, clients acknowledge that this may affect the execution result obtained.