Best Execution Policy

YWO (MU) LTD (the “Company”) is incorporated and existing under the Laws of Mauritius with registration number 229766, and registered address Legacy Capital Co Ltd, 2 Floor, Suite 201, The Catalyst, Ebene, Republic of Mauritius.

The Company is an Investment Dealer (Full-Service Dealer, Excluding Underwriting) Licensee, regulated and authorized by the Financial Services Commission (“FSC”), Mauritius under the license number GB25205550.

1. INTRODUCTION & SCOPE OF SERVICES

This document sets out the Company’s Best Execution Policy in respect of financial instruments/securities and applies to both retail and institutional clients, as applicable.

The financial instruments covered under this Policy include, but are not limited to:

(i) Derivatives of these instruments, including Contracts for Difference (CFDs) on securities; (ii) Equities, such as shares in companies typically listed on an exchange; and (iii) Fixed income products, such as government and corporate bonds.

The Policy applies, as applicable, to both institutional and retail clients.

The Company is committed to conducting business with its clients in an honest, fair, and professional manner. In executing or transmitting client orders relating to one or more financial instruments, the Company shall always act in the best interests of its clients. The Company will take all reasonable steps to achieve the best possible overall trading outcome (“best execution”), taking into account the nature of the client’s orders, the prices available in the market, the characteristics of the relevant market, and a balanced assessment of the sometimes overlapping or conflicting execution factors (as detailed below).

In most cases, the financial instruments offered by the Company are Contracts for Difference (CFDs) on underlying assets, as defined under the Securities Act. The Company retains full discretion to determine the types of CFDs it will trade, in line with its business plan.

The Company’s objective is, as far as practicable, to apply consistent standards and operate uniform processes across all markets, clients, and financial instruments in which it conducts business.

Furthermore, the Company aims to provide clients and other market participants with access to tradable prices on a non-discriminatory basis, wherever possible. Nevertheless, given the diversity of markets and instruments, as well as the variety of orders that may be placed, different factors may need to be considered for each specific transaction.

2. EXEMPTIONS FROM THE PROVISION OF BEST EXECUTION

Notwithstanding the above, the Company shall not be obliged to provide 'best execution' where the order falls within any of the following exemptions:

2.1. Eligible Counterparties

In the wholesale OTC derivatives and bond markets (including, for the avoidance of doubt derivatives in Equities, Energy, and Commodities) in which the Company operates, it is standard market practice for buyers and sellers to “shop around” by requesting quotes from multiple brokers or dealers. In such circumstances, the parties acknowledge that the selected broker/dealer is not expected to provide “best execution.” Unless otherwise notified by the client, we will assume that, as a sophisticated participant in the wholesale markets, this represents the client’s usual trading practice.

2.2. Client Instructions

Where a client provides the Company with specific instructions regarding an order, or any aspect of an order—including, for example, an instruction to execute the trade on a particular venue— the Company will execute the order in accordance with those instructions. It should be noted, however, that by following such instructions, the Company will be deemed to have satisfied its obligation to take all reasonable steps to achieve the best possible result for the client in respect of the order, or the aspect of the order, to which the specific instructions relate.

3. CLIENTS

Because the Company intends to handle orders and expressions of interest in an equitable and consistent manner, once a client has been classified for the purposes of a particular instrument, that classification will apply on a continuing basis and the client may not elect to be reclassified for a single transaction of a type it customarily undertakes. Exceptional circumstances may be considered with the Company’s consent; however, the Company reserves the right to decline providing the service where reclassification is requested.

4. EXECUTION VENUES

This Best Execution Policy outlines the venues through which the Company may execute client orders. The Company will act as the sole execution venue for all client orders executed on an Over-the-Counter (OTC) basis. The Company has identified the venues it most frequently uses to execute client orders, as well as those it considers most likely to provide the best possible outcome for clients, taking into account the factors described below.

The Company may execute trades on behalf of the client through the following execution venues:

• Regulated Liquidity providers
• Regulated Markets
• Authorised Trading Platforms

When selecting a venue for executing trades, the Company will take reasonable steps to ensure that the chosen venue delivers the best possible trading result for clients, taking into account the following factors:

• In the markets in which the Company operates, it can only give clients visibility to prices that have been communicated to them;
• The Company will provide details of all tradable bids and offers through the platform, subject to the other considerations outlined below.
• Time availability of prices: in many markets, trading activity experiences lulls and spikes as negotiations align interests across different times and parts of the curve. Consequently, the “last traded” price may not always be available or serve as a reliable indicator of the current price.
• The Company will not allow clients to trade in a market unless it is reasonably satisfied that the client (or their agent) is capable of settling the relevant trade.
• Fees may vary between clients depending on individual agreements and levels of trading activity.

5. EXECUTION FACTORS

Clients may instruct the Company to execute an order in a specific manner. Depending on the nature of such instructions or restrictions, the Company’s ability to follow the steps outlined in its Best Execution Policy may be limited. In such cases, the Company will endeavor to achieve the best possible outcome while complying with the client’s instructions.

In the absence of specific instructions, the Company will, at its discretion, determine the factors necessary to deliver the best possible execution result, based on its quoted prices provided b the Liquidity Provider (if applicable) or the selected Execution Venue.

These execution factors, in the markets in which the Company operates, will include, but are not limited to, the following:

• characteristics of the client;
• size, nature and characteristic of the order;
• pending orders;
• likelihood and speed of execution;
• price and costs of execution; and
• settled block trades, or positions larger than standard market size, may be crossed at a particular stage in the trading day or kept anonymous to the majority of market participants; unless otherwise directed.

Events such as extreme market volatility, system disruptions, and other circumstances beyond our control may be considered when developing the execution strategy to achieve best execution.

6. MONITORING AND REVIEW

The Company shall regularly review whether the execution venues and quoted prices provided by its Liquidity Providers, as outlined in the Order Execution Policy, continue to offer the best possible results for clients, and whether any adjustments to execution arrangements of providers are necessary.

The Company is committed to providing “best execution” and ensuring that the selection of liquidity providers is fair, based on service quality, execution performance, reputation, and depth of liquidity offered. This includes providing competitive pricing and superior liquidity relative to other market participants. Periodic due diligence and reviews of liquidity providers will be conducted to assess the quality of service and execution provided.

The Company will monitor the effectiveness of its order execution arrangements and policy to identify and implement any necessary improvements. Order execution arrangements and procedures will be reviewed at least annually or whenever a material change occurs that could impact the Company’s ability to consistently achieve the best possible results for client orders. Reviews will also be triggered by factors or significant changes affecting the Company’s ability to obtain optimal prices from its liquidity providers or execution venues.

The Investment Dealer team is responsible for overseeing the Company’s best execution framework, including the policy, associated processes, controls, and monitoring arrangements.

7. ORDER MANAGEMENT

The Company provides trade processing on an execution-only basis, where transactions are automatically executed on its Trading Platform. The prices displayed on the platform and offered to clients reflect the rates at which the Company, via its Liquidity Provider or Execution Venue, is willing to buy from or sell to the client. These prices are indicative and should not be considered firm or guaranteed.

8. STATEMENT ON CHURNING

Churning is the practice of executing trades in a customer’s investment account by a broker or brokerage firm solely to generate commissions. It occurs when a broker engages in excessive buying and selling in a client’s account that is unnecessary to achieve the client’s investment objectives.

Roles of the Company:

A) Broker role: When the Company acts as a broker, it connects Person A (placing a Bid order) with Person B (placing an Ask order). In this case, the Company earns a commission for facilitating the transaction.

B) Dealer/principal role: When the Company acts as a dealer, it sells securities directly from its own inventory. If the customer agrees with the terms and the price, the Company executes the sale without searching for liquidity in the market.

Policy and procedures to prevent churning

• The Investment Dealer Team will execute orders only as requested by clients.
• The Company will enter into trading transactions with clients as principal only if this has been fully disclosed to them.
• The Investment Dealer Team will ensure that clients are notified once a trade has been executed and that contract notes are sent to them.
• Both the client and the Company are required to abide by the “Investment Dealer Client Agreement.”

Contract for investment dealer team

To the extent necessary, the contract of the Investment Dealer Team may include a clause prohibiting any member from receiving commissions directly from clients. Such conduct is strictly forbidden. If any instance of this is reported and comes to the attention of Management, it will constitute grounds for dismissal. The Company shall implement monitoring programs to detect any such activity. Should any violation be identified, it may result in disciplinary action.

9. NO FIDUCIARY RELATIONSHIP The Company’s commitment to provide the client with “best execution” does not mean that the Company owes the client any fiduciary responsibilities over and above the specific regulatory obligations placed upon it or as may be otherwise contracted between the client and the Company.

The client remains responsible for his/her own investment decisions and we will not be responsible for any market trading loss suffered as a result of those decisions.

10. CONFLICT OF INTEREST

The Company’s Conflicts of Interest Policy governs its duty to prioritize clients’ interests and to identify and manage any conflicts of interest arising from its operations. Under this Policy, all employees and management are required to report any actual or potential conflicts of interest. Additionally, the Policy mandates that employees act solely in the best interests of clients at all times.

11. CLIENT CONSENT

This Best Execution Policy forms an integral part of the Investment Dealer Client Agreement between the Company and the Client. By accepting the terms and conditions of the Investment Dealer Client Agreement, the Client also agrees to comply with the provisions of this Best Execution Policy.

12. AMENDMENT AND REVIEW

The Company reserves the right to amend, update, or replace this Policy at any time to reflect changes in applicable laws, regulatory requirements, market practices, or business operations. Any updated version of the Policy will be made available on the Company’s website and shall take effect from the date of publication.