ORDER EXECUTION POLICY

1. Purpose, Scope and Regulatory Alignment

1.1 Purpose

This Order Execution Policy (“Policy”) defines how AURUM NEO-BANK sp. z o.o. (the “Company”) executes client crypto-asset orders in a fair, transparent, and compliant manner.

This Policy implements the Company’s obligations under:

• Markets in Crypto-Assets Regulation, including Articles 61 (Governance), 72 (Honest, Fair and Professional Conduct), and 76 (Order Execution Transparency);
• Regulation (EU) 2023/1113 (Travel Rule);
• Polish AML/CFT legislation;
• Supervisory expectations of the Polish Financial Supervision Authority.

1.2 Business Model

The Company operates an OTC principal model, meaning:

• The Company acts as direct counterparty to client trades;
• No public order book or multilateral trading facility is operated;
• The Company does not provide investment advice or portfolio management;
• The Company does not maintain long-term custody of client assets.

1.3 Client Eligibility and Risk Restrictions

Order execution is strictly limited to:

• Customers classified as Low or Medium Risk under the AML Policy;
• Fully KYC-verified clients;
• Clients not subject to sanctions;
• Clients not classified as High Risk or PEP.

Orders from clients reclassified as High Risk shall not be executed.

2. Best Execution Commitment

2.1 Core Obligation

The Company takes all sufficient steps to obtain the best possible result for clients, considering:

1. Price
2. Total cost
3. Speed
4. Likelihood of execution
5. Likelihood of settlement
6. Order size and nature

For retail clients, price and total cost are given primary importance.

2.2 No “Last Look” Commitment

The Company does not apply discretionary “last look” practices.

Once a client confirms a firm quote:

• The price is locked;
• The order will not be rejected for pricing advantage;
• Rejection may only occur for AML, sanctions, technical failure, or manifest error grounds.

3. Pricing Methodology

3.1 Price Formation

Quotes are derived from:

• Aggregated real-time data from multiple external liquidity venues;
• Consolidated best bid/ask pricing;
• A transparent and consistently applied spread.

The Company does not widen spreads opportunistically based on client direction, order size, or expected profitability.

3.2 Transparency

Clients are shown:

• The firm execution price;
• Any fees;
• Validity window of quote.

Quotes expire automatically after a short duration (e.g., 10 seconds).

4. Execution Process

4.1 Order Finalization

An order becomes final when:

• Client confirms the quote;
• Quote remains valid;
• Sufficient balance exists;
• No compliance flags exist.

After confirmation:

• Execution begins immediately;
• Price is guaranteed under normal market conditions.

4.2 Liquidity Sourcing

Execution may occur through:

• Internal liquidity (limited inventory); or
• Immediate external hedging via selected liquidity providers.

Liquidity sourcing prioritizes:

• Competitive pricing;
• Execution speed;
• Settlement reliability.

5. Slippage Controls

Under normal conditions:

• Slippage after confirmation = 0%.

Control mechanisms include:

• Short quote validity windows;
• Pre-set internal hedging tolerances;
• Execution time benchmarking;
• Automated liquidity switching.

6. Market Stress & Volatility Protocol

In extreme market conditions (e.g., flash crashes, liquidity evaporation):

The Company may:

• Temporarily widen spreads;
• Reduce maximum trade size;
• Suspend quoting;
• Activate trading halt procedures.

Triggers include:

• Price deviation thresholds;
• Liquidity depth reduction;
• Exchange feed outages.

All stress actions are documented and reviewed.

7. Manifest Error Policy

A manifest error may only be invoked where:

• The price deviates materially and obviously from prevailing market levels;
• The deviation is caused by technical malfunction;
• The error is objectively identifiable.

Invocation requires:

• Approval from senior management;
• Full documentation;
• Client notification.

Manifest error may not be used to reject trades due to unfavorable but valid market movement.

8. Liquidity Provider Governance

8.1 Due Diligence

Liquidity providers are subject to:

• Regulatory status review;
• AML and sanctions compliance verification;
• Financial stability assessment;
• Execution performance benchmarking.

8.2 Ongoing Monitoring

Performance metrics include:

• Fill speed;
• Price competitiveness;
• Downtime frequency;
• Settlement reliability.

Providers may be removed if performance deteriorates.

9. Quantitative Execution Quality Metrics

The Company monitors:

• ≥95% of trades executed within internal latency threshold;
• Target 0% post-confirmation slippage;
• 100% full-fill rate for confirmed orders (normal conditions);
• Quote rejection rate;
• Execution-to-market benchmark variance.

Metrics are reviewed quarterly by Compliance and reported to the Board.

10. Conflict of Interest Management

10.1 Principal Trading Disclosure

The Company earns from spreads between market hedge price and client execution price.

Conflicts are mitigated through:

• Rule-based pricing methodology;
• Market benchmarking;
• No discriminatory pricing;
• No inducement-based routing.

10.2 Employee Conduct

Employees:

• May not front-run client orders;
• May not use confidential order flow data;
• Are subject to trading restrictions.

11. Prudential Safeguards

The Company maintains sufficient own funds and liquidity buffers to:

• Absorb short-term market risk between quote confirmation and hedging;
• Ensure operational continuity;
• Meet MiCA prudential expectations.

12. Recordkeeping and Transparency

The Company retains:

• Full order lifecycle data;
• Quote timestamps;
• Execution source logs;
• Settlement references.

Records are maintained for 10 years.

Aggregate execution statistics may be published periodically.

13. Governance Oversight

Oversight structure:

• CCO monitors execution metrics quarterly;
• Board reviews execution quality annually;
• Independent testing may be conducted;
• Policy updates require senior approval.

14. Policy Review

The Policy is:

• Reviewed annually;
• Updated upon regulatory or structural changes;
• Communicated to clients upon material amendment;
• Documented in version control logs.