Order Execution Policy

Vertex Capital & Tech Limited — Trading as Vorum Capital

1. INTRODUCTION

This document ("Policy") describes how Vertex Capital & Tech Limited ("the Company"), trading as Vorum Capital, executes client orders in foreign exchange (FX) contracts and Contracts for Difference (CFDs), and how the Company acts in clients' best interests when handling and executing orders.

This Policy applies to all clients of the Company and to all financial instruments available on the Trading Platform. By opening a Trading Account, you confirm that you have read, understood, and accepted this Policy.

This Policy is reviewed at least annually by the Compliance Officer and approved by the Board of Directors. Material amendments will be communicated to clients prior to taking effect.

2. EXECUTION MODEL — MARKET MAKER (PRINCIPAL)

2.1 Company as Principal Counterparty

The Company operates exclusively as a market maker. This means:

(a) The Company is the direct counterparty to every client trade — when you buy, the Company sells; when you sell, the Company buys;

(b) The Company does not route client orders to external execution venues, exchanges, or ECNs (Electronic Communication Networks) on the client's behalf;

(c) The Company does not operate an STP (Straight-Through Processing) or NDD (No Dealing Desk) model. Any reference to STP or NDD in third-party descriptions of the Company is incorrect;

(d) Prices quoted by the Company are set by the Company and derived from, but not identical to, reference prices from external liquidity providers;

(e) The Company's revenue is derived primarily from the bid/ask spread on client transactions.

2.2 Implications of the Market Maker Model for Clients

Clients should be aware of the following implications of dealing with a market maker:

• Price formation: Prices are the Company's own prices, not the interbank market price. They are derived from reference rates but include the Company's spread;
• Counterparty risk: As described in the Risk Disclosure and Client Agreement, your exposure is to the Company, not to the underlying market;
• Conflict of interest: The Company's financial interests may differ from yours (see Conflicts of Interest Policy for full disclosure and management measures);
• Hedging: The Company may or may not hedge the market risk from your positions in the interbank market — this is a risk management decision at the aggregate book level.

2.3 Voluntary Commitment to Best Execution

Notwithstanding the market maker model, the Company is committed to providing clients with consistently competitive prices, fair execution, and transparent trading conditions. This commitment reflects the Company's long-term commercial interest in client satisfaction and the sustainability of the business, not merely compliance with external regulation.

3. PRICES AND SPREADS

3.1 Price Formation

The Company's quoted prices for each instrument are calculated as follows:

Reference Price: Obtained in real-time from one or more external liquidity providers and/or market data vendors. Reference prices reflect prevailing conditions in the relevant underlying markets.

Company's Bid Price: Reference mid-price minus half the spread (and any applicable mark-up).

Company's Ask Price: Reference mid-price plus half the spread (and any applicable mark-up).

The Company's systems update prices continuously during trading hours. The frequency and speed of price updates is dependent on market liquidity and system capacity.

3.2 Standard Spreads

Standard indicative spreads for major instruments are published on the Company's website and displayed on the Trading Platform. These spreads represent typical spreads under normal market conditions and are not guaranteed under all circumstances.

Spreads may widen significantly during:

• The minutes surrounding major economic data releases (NFP, CPI, central bank rate decisions, GDP);
• Market opens (Sunday evening for FX, market-specific opens for equity index CFDs);
• Public holidays in relevant markets;
• Periods of extreme market volatility (flash crashes, geopolitical crises);
• After-hours trading for instruments linked to specific exchange sessions.

3.3 Overnight Financing (Swap Rates)

Positions held open at the end of the trading day (as defined by the Company, typically 22:00 or 00:00 GMT) are subject to overnight financing charges or credits (swap rates). These rates reflect:

• The interest rate differential between the two currencies in an FX pair;
• The Company's financing margin on the notional position value;
• Any applicable storage cost for commodity CFDs.

Swap rates are displayed on the Trading Platform for each instrument and may be positive (credit to the client) or negative (charge to the client) depending on the instrument and direction of the position. Swap rates are updated by the Company periodically to reflect changes in underlying interest rates and market conditions.

Triple Swap: For most FX and CFD instruments, the swap charge applied on Wednesday evening (to account for the weekend settlement convention) is three times the daily swap rate. Clients holding positions over Wednesday night should be aware of this.

4. ORDER TYPES AND EXECUTION

4.1 Available Order Types

The Company supports the following order types:

4.2 Market Order Execution

Market orders are executed at the price available in the Company's quote stream at the moment the order is received by the Company's systems. This price may differ from the price displayed when the order was submitted, due to:

• Latency between order submission and server-side processing (typically milliseconds under normal conditions);
• Price movement between order submission and execution;
• High volumes during news events causing temporary system queuing.

The Company applies slippage symmetrically — both positive and negative slippage are applied where applicable. The Company does not apply systematically negative-only slippage.

4.3 Limit Order Execution

Limit orders are executed at the specified price or better. A buy limit order is filled at or below the specified price; a sell limit order is filled at or above the specified price. If the market does not reach the specified price before the order expires, the order will not be executed.

Limit orders may be subject to partial fills in conditions of reduced liquidity.

4.4 Stop Order and Stop Loss Execution — Gap Risk

Stop orders (including stop-loss orders) instruct the system to execute when the market price reaches a specified level. Stop orders are NOT guaranteed to execute at exactly the specified price.

In normal market conditions, stop orders are executed at or near the specified level. However, during periods of market gapping (sudden price jumps), the execution price may be materially worse than the specified level. This risk is particularly acute:

• At market open following weekend events;
• During and immediately after major economic announcements;
• During geopolitical crises or emergency central bank interventions.

Example of gap risk on a stop-loss: You hold a long EUR/USD position with a stop-loss at 1.0800. Over the weekend, a significant geopolitical event occurs. When the market opens on Sunday evening, the first available price is 1.0720 — a gap of 80 pips below your stop-loss. Your position is closed at 1.0720, resulting in a loss 80 pips greater than your stop-loss level implied.

4.5 Requote Policy

A requote occurs when the price at which your order was submitted is no longer available when the order is processed. In this event, the system will present the current available price as a new quote. You may accept or decline the requote:

• Accept: Order is executed at the new (current) price;
• Decline: Order is cancelled; no execution occurs.

The Company's systems are designed to minimize requotes under normal market conditions. Requotes are more frequent during periods of high volatility and around major news releases.

5. EXECUTION QUALITY FACTORS

5.1 Best Execution Criteria

In executing client orders, the Company considers the following factors, weighted in the order listed:

• Price — The Company aims to provide competitive prices derived from reference market data; this is the primary execution quality factor;
• Speed — The Company's automated execution infrastructure is designed to minimize processing latency. Orders are typically processed within milliseconds under normal conditions;
• Likelihood of execution — Market orders are executed immediately under normal conditions; pending orders are queued and executed when the specified condition is met;
• Likelihood of settlement — All trades are settled internally; there is no counterparty settlement risk at the trade level;
• Size of order — Very large orders may affect execution quality due to the Company's own risk management capacity;
• Market impact — For very large orders, the Company may need to adjust its pricing to manage its own risk exposure;
• Any other relevant consideration — including the nature of the instrument, applicable trading hours, and market conditions at the time of execution.

5.2 Execution Quality Monitoring

The Company monitors execution quality on an ongoing basis, including:

• Regular analysis of slippage data (positive and negative);
• Review of requote frequency by instrument and time period;
• Monitoring of latency and system performance;
• Review of client complaints related to execution.

Execution quality reports are reviewed by the Compliance Officer quarterly. Where systemic execution issues are identified, they are escalated to the Board and remediated.

6. TRADING HOURS

6.1 Standard Trading Hours

Trading hours are subject to change during public holidays. The Company publishes holiday trading schedules on its website in advance where possible.

6.2 Orders Outside Trading Hours

Orders placed outside trading hours for a given instrument are queued and executed at the first available price when the market reopens. Gap risk between the prior close and the new open applies in full.

7. ORDER REJECTION

The Company may decline to execute an order in the following circumstances:

(a) Insufficient margin: Your account does not have sufficient free margin to support the requested position size;

(b) Price deviation: The requested price deviates from the current market price by more than the Company's acceptable deviation threshold (triggering a requote rather than outright rejection in most cases);

(c) Instrument unavailable: The requested instrument is temporarily suspended, outside trading hours, or has been removed from the platform;

(d) Account restricted: Your account is under review, frozen, suspended, or subject to compliance action;

(e) Position or exposure limits: The requested order would cause your position in a single instrument, or your total platform exposure, to exceed the Company's risk limits;

(f) System error: A technical failure prevents order processing;

(g) Compliance / AML: The order or associated transaction raises AML/CFT concerns requiring review.

The Company will notify the client of order rejection through the Trading Platform and, where appropriate, by email.

8. POSITION LIMITS AND EXPOSURE

The Company may, at its sole discretion, impose maximum position size limits per instrument, per client, or across the platform. These limits may vary by:

• Instrument volatility and liquidity;
• Client account size and margin profile;
• Aggregate Company exposure in the instrument;
• Market conditions (limits may be tightened during high-volatility periods);
• Company risk management policy.

Applicable position limits are displayed on the Trading Platform. Clients wishing to trade in excess of displayed position limits should contact support@vorumcapital.com before placing such orders.

The Company reserves the right to reduce existing position limits with reasonable advance notice where practicable, and without notice in emergency circumstances.

9. SLIPPAGE POLICY

The Company applies a symmetrical slippage policy:

• Positive slippage (execution at a better price than requested) is passed to the client in full;
• Negative slippage (execution at a worse price than requested) is applied where it reflects genuine market conditions;
• The Company does not systematically apply negative-only slippage;
• Slippage is not applied as a revenue-generating mechanism — it reflects genuine movement in the Company's quote stream between order submission and execution.

The Company's average slippage statistics (by instrument category, time period, and order type) are available to clients on request.

10. SPECIFIC PROVISIONS FOR HIGH-IMPACT ECONOMIC EVENTS

The Company reserves the right to apply the following measures around scheduled high-impact economic events (e.g., FOMC decisions, NFP, ECB rate decisions, CPI releases):

(a) Widen spreads in the period immediately before and after the announcement;

(b) Increase margin requirements temporarily;

(c) Restrict the placement of new orders in affected instruments in the minutes immediately before the announcement;

(d) Suspend trading in severely illiquid conditions immediately following an announcement.

The Company will communicate planned restrictions via the Trading Platform and, where advance notice is possible, by email.

11. CHANGES TO THIS POLICY

The Company will notify clients of any material changes to this Policy at least 14 days before the changes take effect, via email to the registered address. Continued use of the Trading Platform following the effective date of any changes constitutes acceptance of the revised Policy.