Order Execution Policy

1. Introduction

This Order Execution Policy describes the measures Vakto takes to obtain the best possible result for clients when executing orders in financial instruments. As required by applicable regulations, we are obligated to take all sufficient steps to achieve the best possible execution on a consistent basis. Clients are deemed to have consented to this policy upon entering into an agreement with Vakto.

2. Scope of Application

This policy applies to all retail and professional clients when Vakto executes orders on their behalf. It covers all financial instruments offered on our platform, including currency pairs, commodity CFDs, index CFDs, equity CFDs, and cryptocurrency CFDs. This policy does not apply to eligible counterparties.

3. Best Execution Criteria

• —Price: the price at which the order is executed, compared to the best available market price.
• —Costs: all explicit and implicit costs associated with execution, including spreads and commissions.
• —Speed: the time taken from order submission to execution.
• —Likelihood of execution: the probability that the order will be executed at the requested price.
• —Likelihood of settlement: the probability of successful trade completion and settlement.
• —Order size: the impact of order size on the execution price, particularly for larger positions.
• —Nature of the order: whether the order is a market order, limit order, stop-loss, or other type.

4. Execution Venues and Model

Vakto operates as a matched principal broker on a no-dealing-desk (NDD) model. All client orders are transmitted to and executed with our network of institutional liquidity providers. We do not maintain a proprietary trading book that takes positions against clients. Our liquidity providers include major global banks and non-bank liquidity providers, ensuring competitive pricing across all instruments.

5. Price Formation

Prices displayed on the Vakto platform are derived from our liquidity providers in real-time. For each instrument, we aggregate bid and ask prices from multiple providers to present a competitive composite quote. Our spread represents the difference between the bid and ask prices and constitutes our primary source of revenue on Standard accounts. Raw spreads are available on Pro and VIP accounts with a separate commission.

6. Order Types and Execution

• —Market Orders: executed immediately at the best available price at the time of receipt.
• —Limit Orders: executed when the market reaches the specified price or better.
• —Stop Orders: triggered when the market reaches the specified price; executed as market orders.
• —Trailing Stops: stop orders that automatically adjust as the market moves in the client's favour.
• —Take Profit Orders: limit orders designed to close a position at a target profit level.

7. Slippage

Slippage is the difference between the expected price of an order and the price at which it is actually executed. Slippage may occur during periods of high volatility, low liquidity, or significant news events. Slippage can be positive (price improved) or negative (price worse than requested). Our systems are designed to minimise negative slippage, and we pass positive slippage directly to clients.

8. Specific Instructions

Where a client provides specific instructions regarding order execution (such as a specific price or venue), we will execute the order in accordance with those instructions, which may override our best execution obligations. Clients should be aware that specific instructions may prevent us from following this policy to obtain the best possible result.

9. Monitoring and Review

We monitor the quality of our order execution on an ongoing basis and conduct formal reviews of our execution arrangements and policy at least annually. We assess our liquidity provider relationships, execution statistics including fill rates and slippage data, and client feedback to ensure we continue to deliver best execution.

10. Disclosure and Consent

This policy is made available to clients prior to the commencement of our relationship. By opening an account with Vakto and accepting our Terms and Conditions, you confirm your informed consent to this Order Execution Policy. We will notify you of any material changes to this policy in advance of their implementation.