Order Execution Policy

^{Last Version: 25 February 2026}

1. Purpose and Regulatory Framework

This Order Execution Policy (the “Policy”) describes the principles and arrangements implemented by TRAKX SAS (“TRAKX”, the “Company”) to ensure that, when executing orders for crypto-assets on behalf of its Clients, it takes all sufficient steps to obtain the best possible result in accordance with Regulation (EU) 2023/1114 on Markets in Crypto-assets (“MiCA”), in particular Article 78 thereof.

This Policy forms an integral part of the Terms and Conditions and is incorporated therein. By using the TRAKX Services, Clients acknowledge that they have read, understood and accepted this Policy.

2. Scope of Application

This Policy applies to the execution of orders for crypto-assets and Crypto Tradable Indices (“CTIs”) placed by Retail and Corporate Clients through the TRAKX Platform, including:

• buying and selling of CTIs;
• exchange of crypto-assets for other crypto-assets;
• execution of market and limit orders;
• execution of orders submitted via automated or algorithmic processes.

3. Execution Venues and Execution Model

TRAKX operates a crypto-asset trading platform within the meaning of MiCA and executes Client orders primarily:

• on its own trading platform and order book; and/or
• through automated execution systems and predefined execution logic.

Unless otherwise specified, TRAKX acts as principal when executing Client orders.

Orders are matched against available liquidity on the platform and may be executed in full or in part depending on market conditions, order size and available counterparties.

4. Best Execution Factors

When executing Client orders, TRAKX takes into account the following execution factors, as required by MiCA:

• Price of the crypto-asset or CTI;
• Costs related to execution, including fees and spreads;
• Speed of execution;
• Likelihood of execution and settlement;
• Size and nature of the order;
• Market conditions, liquidity and volatility;
• Custody and settlement conditions of the relevant crypto-assets.

For Retail Clients, the total consideration (price and costs) generally represents the most important factor. For Corporate Clients, the relative importance of execution factors may vary depending on the characteristics of the order.

5. Order Types and Execution Characteristics

Orders submitted on the TRAKX Platform are executed according to the following principles:

• Orders are executed using automated systems;
• Market orders are executed at the best available price at the time of execution;
• Limit orders are executed only if market conditions reach the specified limit;
• Partial execution may occur;
• Slippage may occur due to market volatility or liquidity constraints;
• Once an order (or part of an order) is executed, it becomes irrevocable.

Clients may cancel an order only insofar as it has not yet been matched or executed, in accordance with the Terms and Conditions.

6. No Inducements or Conflicts

In accordance with Article 80 of MiCA, TRAKX does not receive any remuneration, rebate or non-monetary benefit for routing Client orders to a particular trading venue or execution system.

TRAKX has implemented appropriate measures to identify, prevent and manage conflicts of interest that may arise in the execution of orders, as further described in its Conflicts of Interest Policy.

7. Monitoring and Review

TRAKX monitors the effectiveness of its order execution arrangements on an ongoing basis and reviews this Policy periodically, or whenever a material change occurs that may affect its ability to obtain the best possible result for Clients.

Any material amendments to this Policy will be communicated to Clients through an update on the TRAKX website or via other appropriate means.

8. Client Consent

By accepting the Terms and Conditions and using the TRAKX Services, Clients expressly consent to this Order Execution Policy and acknowledge that their orders will be executed in accordance with the principles described herein.