Order Execution Policy

Version 1.0 — June 2026

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1. Introduction and Scope

1.1. This Order Execution Policy (the "Policy") sets out how ST Global Markets (Mauritius) Limited (the "Company", "we", "us" or "our") executes Client Orders in foreign exchange (**"FX"**) and Contracts for Difference (**"CFDs"**), and the steps the Company takes to obtain the best possible result for its Clients.

1.2. This Policy forms part of, and should be read together with, the Company's Terms of Business. Capitalised terms used but not defined in this Policy have the meaning given to them in the Terms of Business.

1.3. This Policy applies to both Retail Clients and Professional Clients. It applies to the execution of Orders in all Instruments the Company makes available.

1.4. By accepting the Terms of Business and by placing an Order with the Company, you consent to this Policy, including to the execution arrangements described in section 5 and the consent set out in section 14.

2. The Company's Execution Model

2.1. The Company provides execution-only dealing services. It does not provide investment advice, personal recommendations or discretionary portfolio management, and does not assess the suitability or appropriateness of any Order.

2.2. The Company operates a straight-through-processing (STP) model. It quotes prices for FX and CFDs which are derived from one or more third-party liquidity providers. When you place an Order, the Company executes the resulting Transaction against its own prices and hedges its exposure back-to-back with its liquidity provider(s) on a matched-principal basis. The Company does not warehouse market risk against Clients on its own account (it does not operate a "B-book").

2.3. All Orders are executed over-the-counter (OTC). The Company is the sole execution venue for your Orders. Your Orders are not executed on a regulated exchange, a multilateral trading facility or any other external venue, and each Transaction is entered into between you and the Company as counterparty.

2.4. The Company's trading platform is MetaTrader 5 (MT5), hosted on the Company's own server.

3. Best Execution Obligation

3.1. The Company will take all reasonable steps to obtain the best possible result for Clients on a consistent basis when executing Orders, taking into account the Execution Factors set out in section 4 and consistent with its duty under the Securities Act 2005 and the FSC Rules to act honestly, fairly, professionally and in the best interests of its Clients.

3.2. The obligation to take all reasonable steps does not mean that the Company must obtain the best possible price for every individual Order. It means that the Company maintains arrangements and processes designed to deliver the best possible result for Clients on an overall and consistent basis.

4. Execution Factors

4.1. In executing Orders, the Company takes into account a range of factors, including:

  • price;

  • costs (including spreads, commissions and financing/swap charges);

  • speed of execution;

  • likelihood of execution and settlement;

  • size of the Order;

  • nature of the Order; and

  • any other consideration relevant to the execution of the Order.

4.2. For Retail Clients, the best possible result is determined primarily in terms of the total consideration, being the price of the Instrument together with the costs of execution. The remaining factors (speed, likelihood of execution and settlement, size and nature) are given precedence over price and cost only to the extent that they are instrumental in delivering the best possible total consideration.

4.3. For Professional Clients, the Company takes into account the same factors, but their relative importance may differ according to the characteristics of the Client, the Order and the Instrument concerned.

5. Execution Venues and Pricing

5.1. As set out in section 2, the Company is the sole execution venue for Client Orders. The Company does not transmit your Orders to, or execute them on, any external venue.

5.2. The Company derives its quoted prices from one or more third-party liquidity providers selected by the Company. The Company applies its spreads and any applicable mark-up to those prices, as published in the Trading Conditions and Contract Specifications on the Website.

5.3. Prices displayed on the Trading Platform are indicative until an Order is executed. The Company does not guarantee that its quoted price for any Instrument will be within any particular percentage of the price of the underlying asset, and, where the underlying market is closed, the Company's quotes reflect its reasonable view of the current price.

5.4. The Company selects and retains its liquidity provider(s) on the basis of factors including the depth and quality of liquidity, pricing, reliability, and execution quality. The Company conducts periodic due diligence on, and review of, its liquidity provider arrangements.

6. Specific Client Instructions

6.1. Where you give the Company a specific instruction as to the execution of an Order or any particular aspect of it, the Company will execute the Order in accordance with that instruction so far as reasonably possible.

6.2. You acknowledge that a specific instruction may prevent the Company from taking the steps set out in this Policy to obtain the best possible result in respect of the aspects of the Order covered by your instruction. To the extent of any specific instruction, the Company is deemed to have satisfied its best execution obligation in respect of that aspect of the Order.

7. How Orders Are Handled

7.1. Order types. The Trading Platform supports market Orders and pending Orders, including limit, stop and (where available) stop-limit and trailing-stop Orders, as well as Stop Loss and Take Profit instructions attached to positions.

7.2. Execution basis. Orders are executed on a market-execution basis: an Order is filled at the best price available to the Company at the time of execution. Because the market price may move between the moment you submit an Order and the moment it is executed, the execution price may differ from the price displayed when you submitted the Order.

7.3. Slippage. Slippage is the difference between the price expected when an Order is submitted and the price at which it is actually executed. Slippage may be positive (in your favour) or negative (against you) and results from market movement, volatility and available liquidity. The Company applies slippage symmetrically and does not systematically apply negative slippage only.

7.4. Gapping. In fast-moving or illiquid markets, or at market open following a weekend, holiday or trading-session gap, prices may "gap", such that an Order — including a Stop Loss Order — is executed at a price materially different from the level you specified. The Company does not guarantee execution at the specified level of any pending Order or Stop Loss Order.

7.5. Requotes. Under market execution, the Company does not generally issue requotes; an Order is executed at the next available price.

7.6. Partial execution. Where the full size of an Order cannot be executed at a single price, the Order may be executed at more than one price or, where applicable, partially executed.

7.7. Order duration. Pending Orders are Good Till Cancelled (GTC) unless otherwise specified. It is your responsibility to monitor, manage and cancel your Orders.

7.8. Trading hours. The Company accepts and executes Orders only during its usual trading hours for the relevant Instrument, as published on the Website.

8. Factors Affecting Execution

8.1. Execution may be affected by market conditions, including volatility, reduced liquidity, latency in price feeds or connectivity, news and economic events, and the opening and closing of markets. These conditions may affect the speed and price of execution and may give rise to slippage or gapping.

8.2. The Company is not liable for any delay or failure in execution caused by your terminal, your internet connectivity, or third-party systems, or arising from a Force Majeure Event or Market Disruption Event, as set out in the Terms of Business.

9. Aggregation

9.1. The Company executes each Client Order individually and does not aggregate your Orders with those of other Clients in any manner that operates to your disadvantage. The back-to-back hedging the Company carries out with its liquidity provider(s) is conducted for the Company's own account and does not affect the execution of your Order.

10. Costs of Execution

10.1. The costs applicable to your Transactions — including spreads, commissions, financing/swap charges and any other applicable fees — depend on your account type and are set out in the Trading Conditions and Contract Specifications on the Website and in the Terms of Business.

11. Conflicts of Interest

11.1. The Company maintains a Conflicts of Interest Policy. Because the Company is the counterparty to your Transactions and hedges them with its liquidity provider(s), it identifies and manages the potential conflicts arising from this arrangement in accordance with that policy.

11.2. The Company does not select a liquidity provider, or handle your Orders, on the basis of remuneration it might receive in any manner that conflicts with its obligation to obtain the best possible result for you.

12. No Fiduciary Relationship

12.1. The provision of best execution under this Policy does not create any fiduciary or advisory relationship between the Company and you, beyond the regulatory obligations the Company owes under the Securities Act 2005 and the FSC Rules. You remain solely responsible for your own trading decisions and for any resulting loss.

13. Monitoring and Review

13.1. The Company monitors the effectiveness of its order execution arrangements and of this Policy, including the quality of execution obtained and the performance of its liquidity provider(s), and addresses any deficiency it identifies.

13.2. The Company reviews this Policy and its execution arrangements at least annually, and whenever a material change occurs that affects its ability to obtain the best possible result for Clients on a consistent basis. Amendments take effect when published on the Website.

14. Client Consent

14.1. By accepting the Terms of Business and by placing an Order with the Company, you consent to this Policy and, in particular, to your Orders being executed over-the-counter, with the Company as counterparty and sole execution venue, and outside a regulated market or multilateral trading facility.

Capitalised terms used in this Policy have the meaning given to them in the Company's Terms of Business. In the event of any conflict between this Policy and the Terms of Business, the Terms of Business prevail.