Order Execution Policy

This Order Execution Policy sets out the approach taken by Atlas Market Exchange to execute client orders in financial instruments in a manner that achieves the best possible result for our clients. This policy is provided in accordance with the requirements of applicable financial regulations, including the Markets in Financial Instruments Directive (MiFID II) and the guidelines of the Danish Financial Supervisory Authority (FSA).

Atlas Market Exchange is a fully licensed Danish bank committed to delivering transparent, fair, and consistent order execution across all asset classes available on our platform, including stocks, ETFs, forex, cryptocurrencies, CFDs, and mutual funds. We are legally obligated to take all sufficient steps to obtain the best possible result for our clients when executing orders.

By opening an account and placing orders through the Atlas Market Exchange platform, you acknowledge that you have read and understood this Order Execution Policy and consent to orders being executed in accordance with its terms. This policy forms part of our Terms and Conditions and should be read alongside our Risk Disclosure Statement and all other applicable documentation.

Atlas Market Exchange reviews this policy at least annually and whenever a material change occurs that affects our ability to achieve best execution for clients. Clients will be notified of any significant changes to this policy.

1. Scope and Application

This Order Execution Policy applies to all orders placed by retail and professional clients through the Atlas Market Exchange platform across all available financial instruments and asset classes. It applies to:

• Market orders, limit orders, stop orders, stop-limit orders, and all other order types available on the platform.
• Orders placed through the web platform, mobile application, and any other interface provided by Atlas Market Exchange.
• All financial instruments including equities, exchange-traded funds (ETFs), foreign exchange (forex), cryptocurrencies, contracts for difference (CFDs), and mutual funds.
• Orders placed directly by clients as well as orders placed by authorised representatives acting on behalf of clients.

This policy does not apply to eligible counterparty clients, who are subject to separate execution arrangements as agreed under the applicable regulatory framework.

2. Best Execution Obligation

Atlas Market Exchange is required to take all sufficient steps to obtain the best possible result for clients when executing orders, taking into account the following execution factors:

• Price: The price at which the order is executed, including the bid-offer spread and any applicable commissions or fees.
• Costs: All transaction costs associated with the execution of the order, including explicit costs such as commissions and implicit costs such as the bid-ask spread.
• Speed of Execution: The time taken to execute the order from the moment it is received by our systems.
• Likelihood of Execution: The probability that the order will be executed at or near the desired price, particularly for limit and stop orders.
• Likelihood of Settlement: The probability that the executed trade will settle successfully and within the expected timeframe.
• Size of the Order: The impact of the order size on the available market liquidity and the achievable execution price.
• Nature of the Order: The specific characteristics of the order type and any client instructions that may influence the execution approach.
• Any Other Relevant Consideration: Any other factor that may be relevant to achieving the best possible execution outcome for the specific order.

For retail clients, best execution is primarily determined by the total consideration, which represents the price of the financial instrument plus the costs of execution. Price will therefore be given the highest relative importance in most circumstances, unless other factors such as speed or likelihood of execution are more relevant given the specific nature of the order.

3. Execution Venues

Atlas Market Exchange routes client orders to execution venues that we have determined are capable of consistently delivering the best possible execution results. Our selection of execution venues is based on a rigorous assessment of each venue's pricing quality, liquidity, reliability, and overall execution performance.

3.1 Regulated Markets and Exchanges

For equities and ETFs, Atlas Market Exchange executes orders on or through regulated stock exchanges and trading venues across more than 30 global markets, including major exchanges in North America, Europe, and Asia-Pacific. Orders are routed to the primary listing exchange of the financial instrument or to an alternative regulated market where better execution can be achieved.

3.2 Multilateral Trading Facilities (MTFs)

In certain circumstances, Atlas Market Exchange may route orders to Multilateral Trading Facilities (MTFs) where doing so is consistent with achieving the best possible execution outcome for the client. MTFs are regulated trading platforms that operate under the same regulatory oversight as traditional stock exchanges.

3.3 Over-the-Counter (OTC) Execution

For certain financial instruments including forex, CFDs, and some fixed income products, orders may be executed on an over-the-counter (OTC) basis directly with Atlas Market Exchange acting as the counterparty or through our network of liquidity providers. OTC execution allows us to provide continuous pricing and execution outside of standard exchange trading hours where applicable.

3.4 Systematic Internalisers

Atlas Market Exchange may also execute client orders through systematic internalisers where this results in better execution outcomes for clients in terms of price, costs, speed, and overall execution quality.

3.5 Liquidity Providers

For certain asset classes, Atlas Market Exchange works with a network of approved external liquidity providers to source competitive pricing and ensure sufficient market depth for the execution of client orders. All liquidity providers are subject to rigorous onboarding criteria and ongoing performance monitoring.

4. Order Types and Execution Approach

Atlas Market Exchange supports a range of order types to give clients flexibility and control over how their orders are executed. The following order types are available on our platform:

4.1 Market Orders

A market order is an instruction to buy or sell a financial instrument immediately at the best available price in the market at the time the order is received. Market orders are designed to prioritise execution certainty over price certainty. Key characteristics include:

• Market orders are typically executed immediately upon receipt during normal trading hours.
• The execution price may differ from the quoted price at the time the order was placed due to market movements between order placement and execution.
• During periods of high market volatility or low liquidity, the execution price may differ significantly from the quoted price, resulting in slippage.
• Market orders placed outside of normal trading hours will be queued and executed at the market open on the next available trading day, subject to the prevailing market price at that time.

4.2 Limit Orders

A limit order is an instruction to buy or sell a financial instrument at a specified price or better. Limit orders prioritise price certainty over execution certainty. Key characteristics include:

• A buy limit order will only be executed at the specified limit price or lower.
• A sell limit order will only be executed at the specified limit price or higher.
• There is no guarantee that a limit order will be executed, as the market price may not reach the specified limit price during the validity period of the order.
• Limit orders may be executed in full, partially, or not at all, depending on market conditions and available liquidity at the specified price level.

4.3 Stop Orders

A stop order (also known as a stop-loss order) is an instruction to buy or sell a financial instrument once the market price reaches a specified trigger price. Key characteristics include:

• Once the stop price is reached, the order is triggered and executed as a market order at the best available price.
• The final execution price may differ from the stop trigger price, particularly during periods of high volatility or when markets gap significantly.
• Stop orders are used by clients primarily as a risk management tool to limit potential losses on open positions.
• Atlas Market Exchange uses neutral reference prices sourced from major interbank venues to trigger stop orders, minimising the risk of premature stop-outs.

4.4 Stop-Limit Orders

A stop-limit order combines the features of a stop order and a limit order. Once the stop trigger price is reached, the order becomes a limit order rather than a market order. Key characteristics include:

• Stop-limit orders provide greater control over the execution price compared to standard stop orders.
• However, there is a risk that the order may not be executed if the market moves rapidly through the limit price after the stop is triggered.

4.5 Good Till Cancelled (GTC) and Good Till Date (GTD) Orders

Clients may specify the validity period for their orders. Orders can be set as:

• Day Orders: Valid only for the current trading session and cancelled automatically at the end of the trading day if not executed.
• Good Till Cancelled (GTC): Remain active until the order is either executed or manually cancelled by the client.
• Good Till Date (GTD): Remain active until a specified date and time, after which the order is automatically cancelled if not executed.

5. Execution Quality and Monitoring

Atlas Market Exchange is committed to maintaining and continuously improving the quality of order execution for all clients. Our execution quality monitoring framework includes:

• Real-Time Monitoring: Our systems continuously monitor order execution quality in real time, including execution speed, price improvement, and fill rates across all asset classes and execution venues.
• Venue Performance Reviews: We conduct regular assessments of the execution quality delivered by each venue and liquidity provider, including analysis of pricing competitiveness, execution speed, rejection rates, and overall reliability.
• Annual Execution Quality Reports: In accordance with applicable regulations, Atlas Market Exchange publishes annual reports summarising the top five execution venues used for each class of financial instrument and the quality of execution achieved.
• Slippage Analysis: We regularly analyse the difference between the expected execution price and the actual execution price to identify patterns and implement improvements where necessary.
• Client Complaints Monitoring: Execution-related client complaints are tracked and reviewed as part of our quality assurance process, and systemic issues are escalated and addressed promptly.

6. Specific Execution Arrangements by Asset Class

The execution approach applied by Atlas Market Exchange varies depending on the asset class and the specific characteristics of the financial instrument being traded:

6.1 Stocks and ETFs

Orders in equities and ETFs are routed to the primary regulated exchange on which the instrument is listed or to an alternative venue where better execution can be demonstrated. We access liquidity across 30+ global exchanges and continuously assess where the best execution outcome can be achieved for each order. For orders in thinly traded securities or in non-standard sizes, we may use algorithms to minimise market impact and achieve optimal execution.

6.2 Forex

Forex orders are executed through our network of tier-one liquidity providers and interbank market participants. We aggregate pricing from multiple sources to present competitive bid-offer spreads to clients. Market orders in major currency pairs are typically executed within milliseconds under normal market conditions. Average execution speed for spot FX market orders is 0.009 seconds. We apply asymmetric slippage controls to ensure that clients benefit from favourable price improvements where available, without being disproportionately disadvantaged by adverse movements.

6.3 Cryptocurrencies

Cryptocurrency orders are executed on our regulated platform with access to competitive pricing sourced from our approved digital asset liquidity providers. Cryptocurrency markets operate 24 hours a day, 7 days a week, and our platform provides continuous access to execution throughout. Due to the highly volatile nature of cryptocurrency markets, clients should be aware that execution prices may move rapidly between order placement and execution.

6.4 CFDs

CFD orders are executed on an OTC basis with Atlas Market Exchange acting as the counterparty. Prices for CFDs are derived from the underlying asset prices obtained from our liquidity providers and are streamed continuously to clients. We apply a consistent and transparent spread model to all CFD instruments, and no additional dealer intervention is applied to the execution of client orders in standard market conditions.

6.5 Mutual Funds

Mutual fund orders are executed at the net asset value (NAV) price calculated by the fund manager at the relevant dealing deadline. Subscription and redemption orders are forwarded to the relevant fund administrator in accordance with the fund's dealing schedule. Execution at the prevailing NAV is guaranteed subject to the order being received before the applicable dealing cut-off time.

7. Client Instructions

Where a client provides specific instructions regarding the execution of an order, Atlas Market Exchange will follow those instructions to the extent that it is reasonably practicable to do so. Clients should be aware that:

• Specific client instructions may prevent Atlas Market Exchange from taking certain steps that would otherwise be required to achieve best execution in accordance with this policy.
• Where a client specifies a particular execution venue, price, or timing, Atlas Market Exchange will follow those instructions but cannot guarantee that best execution will be achieved in respect of the elements covered by the client's specific instructions.
• In all other respects where specific instructions have not been given, Atlas Market Exchange will continue to apply this Order Execution Policy to achieve the best possible result for the client.
• Clients are responsible for ensuring that any specific instructions they provide are clearly communicated and unambiguous. Atlas Market Exchange will not be liable for any adverse execution outcome resulting from unclear or conflicting client instructions.

8. Aggregation and Allocation of Orders

In certain circumstances, Atlas Market Exchange may aggregate a client's order with orders from other clients or with orders for the firm's own account, where aggregation is unlikely to work to the overall disadvantage of any client. The following principles apply to order aggregation and allocation:

• Aggregation may allow clients to benefit from better pricing and lower transaction costs that might not be available for smaller, individual orders.
• Where an aggregated order is only partially filled, the executed portion will be allocated to clients on a pro-rata basis or in accordance with a pre-determined fair allocation methodology.
• Atlas Market Exchange will not aggregate client orders in circumstances where aggregation is likely to be disadvantageous to any individual client participating in the aggregated order.
• All order aggregation and allocation decisions are documented and are subject to review by our compliance team to ensure fairness and consistency.

9. Conflicts of Interest

Atlas Market Exchange recognises that conflicts of interest may arise in the context of order execution, particularly where we act as counterparty to client orders in OTC instruments such as CFDs and forex. We manage these conflicts through the following measures:

• Atlas Market Exchange does not take positions against clients in the market. Our hedging activities are designed to manage our own risk exposure and not to profit at the expense of clients.
• Our pricing model is designed to provide competitive and consistent spreads to all clients, regardless of the size or frequency of their trading activity.
• Atlas Market Exchange does not engage in practices such as last look, where a liquidity provider or dealer can reject or re-quote an order after it has been submitted by the client.
• All potential conflicts of interest in the context of order execution are identified, managed, and disclosed in accordance with our Conflicts of Interest Policy and applicable regulatory requirements.

10. Market Disruption and Abnormal Conditions

During periods of market disruption, extreme volatility, or other abnormal conditions, Atlas Market Exchange may take steps to protect clients and manage risk that differ from normal execution procedures. These measures may include:

• Widening of bid-offer spreads to reflect increased market uncertainty and reduced liquidity.
• Suspension of trading in specific instruments where market prices are unreliable, absent, or where there is a regulatory suspension of trading.
• Implementation of reduced position limits or enhanced margin requirements to manage systemic risk during periods of extreme market stress.
• Delayed or modified execution of orders where normal execution channels are unavailable or where execution at the requested price would not be possible.

Atlas Market Exchange will communicate any material changes to execution arrangements due to market disruption to clients as promptly as practicable and will work to restore normal execution conditions as quickly as possible.

11. Consent and Policy Updates

By placing an order through the Atlas Market Exchange platform, you provide your express consent to the execution of your orders in accordance with this Order Execution Policy, including the use of execution venues and methods described herein.

Atlas Market Exchange reviews this policy at least annually and whenever a material change occurs that may affect our ability to achieve best execution for clients. Where changes are material, we will notify clients in advance through the platform or via email. Your continued use of our services following any update constitutes your acceptance of the revised policy.

The most current version of this Order Execution Policy is always available on the Atlas Market Exchange platform and website.

12. Contact Us

If you have any questions about this Order Execution Policy, wish to request information about our execution arrangements, or have a concern about the execution of a specific order, please contact us through the following channels:

• Email: info@atlasmarketexchange.com
• Client Support: Available through the Platform's live chat and help centre.
• Registered Address: Atlas Market Exchange, Hong Kong.

We are committed to providing all clients with clear, accurate, and accessible information about how their orders are executed and to maintaining the highest standards of execution quality across all asset classes and market conditions.