Order Best Execution Policy

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Order Best Execution Policy

Metropol (Cyprus) Limited uses all reasonable efforts to ensure that its clients achieve the best execution of their orders to buy or sell securities that are quoted or traded on different regulated or OTC markets. As a full-licensed investment services firm, Metropol (Cyprus) Limited is committed to help customers to make informed investment decisions. One way we do that is to explain our Best Execution trading practices.

Please note that Best execution applies if you have been categorized as a Professional or Retail Client, but not if you have been categorized as an Eligible Counterparty. Your categorization has been previously communicated to you.

Metropol (Cyprus) Limited Approach to Best Execution

As a customer oriented broker/dealer, Metropol (Cyprus) Limited identifies and seeks to obtain the most favorable terms reasonably available when executing a buy or sell order for you.

To do this, Metropol (Cyprus) Limited relies on three basic components in this process:

1. Procedures for routing, monitoring and executing orders. 2. Careful consideration of the elements of order execution. 3. Regular and rigorous examination of overall execution quality.

I. Order Routing Procedures

Metropol (Cyprus) Limited uses elaborated procedures to receive, transmit and execute customer orders. When a customer order is received, it thoroughly analyzed and then routed for an execution that Metropol (Cyprus) Limited believes will provide the best result. For listed securities, Metropol (Cyprus) Limited routes orders to a third market maker for execution. For OTC securities, Metropol (Cyprus) Limited will execute the order dealing with one of counterparties or route the order to market-maker firms. Orders are only sent to firms that comply with internal procedures and criteria of Metropol (Cyprus) Limited related to counterparty.

Some of these firms also provide automated executions for orders. Routing determinations are based on the following criteria and are regularly reviewed.

Execution venues

Execution venues are a regulated market, multilateral trading facility (MTF, which operates like an exchange), Metropol (Cyprus) Limited itself (acting as a market maker or dealing for its own account), a systematic internaliser, or other liquidity providers either within or outside the European Economic Area. Any such firm may include a METROPOL Group Broker.

The venues on which we place significant reliance, i.e. the venues on which we will typically execute transactions, are as follows:

Equity instruments tradable on a regulated market: a. on a regulated market or

b. on a MTF or

c. with a METROPOL Group Broker as counterparty (against its own book) or as а Broker d. with other Metropol (Cyprus) Limited Clients or counterparties

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f. with an external broker-dealer duly authorized under legislation of the its registration country.

Equity instruments not tradable on a regulated market: a. with an appropriate vendor/purchaser or

b. with a METROPOL Group Broker as counterparty (against its own book) or as а Broker c. with an external broker-dealer duly authorized under legislation of the its registration country.

Fixed income securities (tradable and not tradable on a regulated market)

a. with a METROPOL Group Broker as counterparty (against its own book) or а Broker or b. with an appropriate vendor/purchaser or

c. on a regulated market or

d. with an external broker-dealer duly authorized under legislation of the its registration country.

Derivatives tradable on a regulated market: a. on a regulated market or

b. with a METROPOL Group Broker as counterparty (against its own book) or as а Broker; Derivatives not tradable on a regulated market:

a. with a METROPOL Group Broker as counterparty (against its own book) or as а Broker or

b. with an appropriate vendor/purchaser or

c. with an external broker-dealer duly authorized under legislation of the its registration country.

Units of mutual funds (established in Russia, Ukraine and other non-European Economic Area countries)

Shares (units) in charter capital (of Russian, Ukrainian companies and other companies established in non-European Economic Area countries)

Promissory notes and certain types of securities that can only be physically settled and are not traded on a regulated market or MTF and certain types of other derivatives which are for commercial purposes and which do not comply with particular criteria e.g. derivatives on emission allowances not traded on a regulated market nor cleared through a central

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clearing house and for which there are no regular margin calls (issued by Russian, Ukrainian issuers and other issuers established in non-European Economic Area countries) a. with a METROPOL Group Broker as counterparty (against its own book) or as а Broker or

II. The Elements of Best Execution

Metropol (Cyprus) Limited evaluates four principal criteria to determine the best way to execute an order for a client:

1. Speed and Certainty of Execution. Because of the unprecedented levels of volatility affecting both price and volume, Metropol (Cyprus) Limited seeks to provide customer orders with the fastest execution reasonably possible. To accelerate the process Metropol (Cyprus) Limited is evaluating now the possibilities of co-operation with brokers that automatically execute orders for up to a certain number of shares.

2. Price Improvement. Orders in OTC and listed securities are routed to market makers where opportunities for price improvement exist. The opportunity for "price improvement" – which is the opportunity, but not the guarantee, for an order to be executed at a better price than what is currently quoted publicly – is an important factor a broker should consider in executing its customers' orders. Other factors include the speed and the likelihood of execution. Best Market means the marketplace with the best bid (buy price) or offer (sell price) for a client order, unless in the reasonable judgment of Metropol (Cyprus) Limited trading staff the current or historical liquidity of the marketplace that has the best bid or offer will not likely be sufficient to ensure that the order has the best chance of execution. In such event, “Best Market” will mean an alternative market that Metropol (Cyprus) Limited has access to and can thereby facilitate the best execution of a client order. Of course, the additional time it takes some markets to execute orders may result in client’s getting a worse price than the current quote – especially in a fast-moving market. So MCL is required to consider whether there is a trade-off between providing its customers' orders with the possibility – but not the guarantee – of better prices and the extra time it may take to do so.

3. Size Improvement. In routing orders, Metropol (Cyprus) Limited shall seek markets that provide the greatest liquidity and thus potential for execution of orders.

4. Overall Execution Quality. When determining how and where to route or execute an order, the Firm’s traders shall draw on extensive day-to-day experience with various markets and market makers, focusing on prompt, reliable execution.

We execute orders in all of the above instruments and will offer you best execution for orders in those instruments except where:

• it is request for quote business and you are a Professional Client. This is generally the case for off-regulated market (OTC) transactions on money markets derivatives, foreign exchange derivatives, and fixed income securities. In the wholesale OTC derivatives and bond market in which Metropol (Cyprus) Limited operates it is normal market practice for

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buyers and sellers to “shop around” by approaching several brokers/dealers for quote. In these circumstances there is no expectation between the parties that MCL/dealer chosen will owe best execution;

• you give a specific instruction as to how we should execute your order or an aspect of your order;

• it is a highly structured transaction.

In all the cases here above the Metropol (Cyprus) Limited is not obliged to obtain the best possible result in accordance with these best execution principles.

With new issues of securities offered either publicly or non-publicly, best possible execution within the meaning of these execution requirements is effected by means of acceptance of the subscription application and allocation or supply of the securities by the issuer or organizer of distribution.

These “best execution” requirements do not apply to individual agreements between Metropol (Cyprus) Limited and client.

III. Regular and Rigorous Review of Execution Quality

Metropol (Cyprus) Limited regularly evaluates the overall quality of its executions. Metropol (Cyprus) Limited studies the quality of executions for listed and OTC retail market orders. Directors and senior managers shall meet periodically to evaluate execution quality and make recommendations regarding order routing practices. The Firm is continually reviewing and modifying its practices to improve the overall quality of executions.

IV. Price Volatility

Volatility is one factor that can affect order execution. Price volatility and trading volume have recently increased dramatically, especially among high-tech and Internet stocks. When investors place a high volume of orders with brokers, order imbalances and backlogs can occur, requiring more time to execute orders. This is because of delays caused by the number and size of orders processed, the speed at which current quotations or last-sale information is provided to Metropol (Cyprus) Limited and other brokerage firms, and system capacity constraints applicable to the exchanges, as well as to Metropol (Cyprus) Limited and other firms that certain delays in order execution may occur.

V. Effects on Order Execution

Investors should be aware of the following risks associated with volatile markets, especially at or near the open or close of the standard trading session:

• Execution at a substantially different price from the quoted bid or offer or the last reported sale price at the time of order entry, as well as partial executions or execution of large orders in several transactions at different prices.

• Delays in executing orders for securities that the Firm must send to another market maker and which may not be handled electronically if the trader must route the order manually to another firm.

• Opening prices that may differ substantially from the previous day’s close.

• Locked (the bid equals the offer) and crossed (the bid is higher than the offer) markets, which prevent the execution of customer trades.

• Increased price volatility resulting from imbalances between buy and sell orders during Initial Public Offerings (“IPOs”).

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VI. Alternative Types of Orders

Given the risks that arise when trading in volatile markets the customer shall consider using different types of orders to limit risk and manage investment strategies. Market order. This is the simplest type of order. Here, an investor tells a broker to execute a trade of a certain size as promptly as possible at the prevailing price. Firms are required to execute market orders without regard to price changes. Therefore, if the market price moves significantly during the time it takes to fill an investor’s order, the order will most likely be exposed to the risks outlined above, including execution at a price substantially different from the price when the order was entered.

Limit order. With a limit order, the investor sets the maximum purchase price, or minimum sale price, at which the trade is to be executed. If the market moves significantly away from this price, the order will not be executed unless or until the market price returns to the limit price. Thus, the investor may not receive an execution of the order.

Good Till Cancelled order (“GTC”) means an order that is valid until filled or cancelled.

Stop limit order. This is similar to a limit order, except that the order is held until the market reaches your “stopped” price, at which point the order may be executed as a limit order. Stop order. This type of order is held, and when your stopped price is reached, it is automatically sent for execution as a market order at the price then prevailing.

VII. Reports of Transactions

Metropol (Cyprus) Limited receives remuneration on certain transactions on a per share basis for execution of orders or directing orders to other broker/dealers or market centers for execution at prices equal to or better than the displayed national best bid or offer prices. One of the OTC brokers that Metropol (Cyprus) Limited routes orders to is IFC Metropol, who belongs to the same Metropol Group of Companies as Metropol (Cyprus) Limited. The source and nature of the compensation received in connection with a particular transaction will be furnished upon written request.

While we make every effort to transmit reports of transactions correctly, errors are sometimes unavoidable, especially during periods of heavy volume. We cannot be held responsible for the accuracy of the price as reported if your order was executed at another price.

Similarly, we cannot be responsible for reports of transactions which have not, in fact, occurred. Should an error be made we will report the correct information to you as soon as possible.

VIII. Conclusion

Metropol (Cyprus) Limited encourages you, before placing orders, to give careful thought to how the risks previously described may affect an investment in volatile markets. There are several Internet resources available to help explain these and other risks in greater detail, including the web site of Cyprus Securities and Exchange Commission (www.sec.gov.cy). You should also consider how different types of orders might help manage some of these risks.