Order Execution Policy

1. Introduction

This policy outlines the procedures and standards Transak will adhere to for executing client orders, ensuring compliance with MiCA requirements and other applicable regulatory requirements. Its primary objective is to ensure that all client orders are executed promptly, fairly, and expeditiously, minimizing the potential for misuse of client information.

This policy is designed to comply not only with MiCA but also with MiFID II and EU customer protection and disclosure regulations and other relevant laws and regulations in the countries of operation of Transak. In doing so, it provides the framework for the transparent execution of client orders, detailed disclosure of fees and costs, and rigorous controls on order execution and asset transfers. This Policy shall be periodically updated to reflect evolving regulatory standards and technical requirements as specified by the European Supervisory Authorities and other supervisory authorities.

2. Governing Law

This Policy is focused on legal and regulatory obligations in Austria due to the mandatory requirements Transak is subject to under MiCA. Equivalent or stricter provisions in the other jurisdictions of operations of Transak will apply locally and will be recorded as Annexes to this Policy.

Where local stricter obligations apply, these will be marked accordingly in an Annex to this Policy for each individual jurisdiction of operation of Transak.

• Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on markets in crypto-assets (MiCA);
• Directive 2014/65/EU of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments;
• Directive 2011/83/EU of the European Parliament and of the Council of 25 October 2011 on consumer rights.

3. Best Execution Obligation

Transak is committed to taking all necessary steps to achieve the best possible result for clients when executing orders. The following factors will be considered:

• Price: Ensuring execution at the most favorable price for the client. All prices are visible to the customer in real time. Transak implements a hybrid pricing schedule combining fixed and automated pricing components.
• Costs: Minimizing any costs associated with the execution.
• Speed: Executing orders promptly to capitalize on favorable market conditions.
• Likelihood of Execution and Settlement: Assessing the probability of successful execution and settlement.
• Order Size and Nature: Considering how the size and characteristics of the order may impact execution.
• Market Conditions: Taking into account current liquidity and volatility.

Transak will regularly assess and monitor the effectiveness of its order execution arrangements and policy to identify and correct any deficiencies.

In accordance with MiFID II requirements, Transak shall document its best execution policies and publish periodic reports on execution quality, including metrics on price improvement, order execution speed, and order handling integrity. This includes ensuring that all execution venues are subject to independent due diligence, and that any material deviation from best execution standards is immediately reviewed and remedied.

4. Order Types

To cater to diverse trading needs, Transak will support various order types, including:

• Market Orders: Executed immediately at the best available price.
• Limit Orders: Executed at a specified price or better.
• Stop Orders: Triggered when a specified price level is reached.
• Algorithmic Orders: Utilizing strategies like Time-Weighted Average Price (TWAP) and Percentage of Volume (POV) to minimize market impact.

TO CLARIFY, AT THE TIME OF ISSUING THIS POLICY ALL ORDERS CONDUCTED ON TRANSAK ARE MARKET ORDERS.

Enhancements to these practices will automatically trigger an amendment to this Policy.

In compliance with EU disclosure and customer protection requirements under MiFID II, Transak shall provide detailed risk disclosures for each order type, especially for algorithmic orders, including potential latency, slippage, and market impact risks. Clients will be provided with easy-to-understand summaries of how each order type may affect execution outcomes.

5. Execution Venues

Transak will utilize multiple execution venues to ensure optimal execution, including:

• Internal Order Books: Matching client orders within Transak's platform.
• External Exchanges: Accessing own liquidity from reputable external crypto-asset exchanges.
• Over-the-Counter (OTC) Desks: For large block trades requiring discreet execution.

The selection of execution venues will be based on their ability to provide the best possible result for clients, considering factors such as price, liquidity, and reliability. Transak will regularly assess the quality of execution across these venues.

Furthermore, Transak shall maintain a publicly accessible summary of its execution venue selection criteria, reviews, and performance metrics. This shall include periodic due diligence reviews of each venue and a clear explanation of the methods and methodologies used to monitor execution quality, as required by MiFID II. Any changes to the set of execution venues shall be communicated to clients in a timely manner.

6. Order Handling and Priority

Client orders will be handled promptly and in the sequence they are received, ensuring fairness. Transak will implement systems to prevent the misuse of information related to client orders by its employees.

All orders shall be processed based on the principle of fairness and non-discrimination, in line with MiFID II best execution standards. Detailed logs of order prioritization and handling shall be maintained, and any deviations or exceptions to the normal order flow must be documented and reviewed by independent compliance functions.

7. Transparency and Reporting

Transak will provide clients with clear information regarding:

• Fees and Charges: Detailed breakdowns of all fees associated with transactions.
• Order Status: Real-time updates on the status of their orders.
• Execution Quality: Reports on the quality of execution, including any factors that may have affected the outcome.

Additionally, Transak will publish pre- and post-trade data within the timeframes specified by MiCA to maintain transparency.

Risks associated with dealing in cryptocurrencies are publicly available on the Transak website at: https://eu.transak.com/compliance.

In addition, Transak will ensure that all pre-trade and post-trade disclosures meet the requirements set forth under MiFID II. This includes providing accessible, real-time aggregated trade data (e.g., price, volume, execution latency, and any partial executions) and clear, client-oriented explanations regarding any deviations from expected execution parameters. Furthermore, quarterly independent audits of the order execution process and execution quality shall be published to enhance transparency and client confidence.

8. Conflicts of Interest

Transak will establish and implement policies to identify and manage any conflicts of interest that may arise during order execution. This includes ensuring that any internal trading activities do not adversely affect client orders.

Moreover, in compliance with regulatory requirements, Transak shall publish its conflicts of interest practices relating to order execution. This disclosure will detail the procedures and safeguards in place to ensure the segregation of internal trading activities from client order processing, thus ensuring that client orders always receive unbiased execution.

Detailed definitions and internal processes relevant to conflicts of interest are defined in the Transak Conflicts of Interests Policy. A Conflicts of Interest Register will be put in place and will be made public on the Transak website whereby all identified conflicts of interest including mitigation and resolution measures will be recorded.

9. Client Consent

Before executing orders on behalf of clients, Transak will obtain their consent to applicable execution processes. Clients will be informed of any material changes to these processes in a timely manner before executing a transaction.

Client consent procedures shall be designed to meet the specific transparency and disclosure requirements under applicable regulations. Detailed consent documents, including clear descriptions of processes, potential risks, and fee structures, shall be made available to customers. Clients will have the option to review and confirm these details electronically, and any changes to these documents shall require renewed consent. All client consent records shall be maintained for audit and inspection.

10. Monitoring and Review

Transak will continuously monitor the effectiveness of its execution arrangements and policy. Regular reviews will be conducted to ensure compliance with MiCA requirements and other applicable regulatory requirements to ensure adequate adaptation to any changes in the regulatory environment or market conditions.

By implementing this transaction order and execution policy, Transak aims to uphold the highest standards of integrity and client service, ensuring compliance with MiCA and other applicable regulatory requirements and fostering trust in its trading platform.

In alignment with applicable disclosure obligations (such as the ones under MiCAR and MiFiD), Transak shall establish formal quantitative and qualitative monitoring systems that evaluate execution performance across its platform. This includes regular internal audits, independent reviews, and the use of performance benchmarks to measure factors such as execution speed, price improvement, and client satisfaction. These metrics shall be reported to the Board of Directors and where necessary made available to clients upon request, ensuring ongoing transparency and customer protection.