Order Handling and Execution Policy

Boku Securities SIA

Effective Date: 27th April 2026

1. Definitions

   1. Agreement: The agreement between you and us for the provision of investment services and ancillary services.
   2. Best Execution: The obligation to take all sufficient steps to obtain the best possible result when executing your Orders, in accordance with MiFID II and the FIML.
   3. BBO (Best Bid and Offer): The highest bid and lowest offer prices available on the Primary Reference Venue for a given Financial Instrument at any given time.
   4. Board: The Company's board of directors.
   5. Broker: Alpaca Securities LLC, a FINRA-registered US broker.
   6. Client: A natural person registered and accepted as an investor on the Platform in accordance with the Agreement.
   7. Company: Boku Securities SIA.
   8. Execution Venue: The venue where your Orders are executed.
   9. Financial Instrument: Financial instruments as defined in the Financial Instrument Market Law of the Republic of Latvia.
   10. FIML: Financial Instrument Market Law of the Republic of Latvia.
   11. Internal Ledger: The Company's internal record of all Client positions and cash balances, maintained in real time.
   12. Margin Risk Procedure: The Company's Margin Risk Mitigation Procedure, governing leverage limits, hedging triggers, margin calls, and related risk controls.
   13. MiFID II: Directive 2014/65/EU of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments.
   14. MiFIR: Regulation (EU) No 600/2014 of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments.
   15. NBBO (National Best Bid and Offer): The best available bid and offer prices consolidated in real time across all major US national exchanges, representing the most comprehensive reference for prevailing market conditions for US-listed equities.
   16. Omnibus Account: The single client asset account maintained by us with the Broker, designated as a client asset account.
   17. Order: An instruction by you to purchase or sell a Financial Instrument via the Platform.
   18. Platform: The Company's mobile and web application through which Clients access investment services.
   19. Policy: This Order Execution Policy.
   20. Primary Reference Venue: For US-listed equities: the primary US exchange on which the relevant instrument is listed, used as the benchmark for best execution monitoring purposes.
   21. Retail Client: A Client who is not a Professional Client. The Company exclusively serves Retail Clients.
   22. Total Consideration: The price of the Financial Instrument and all costs directly related to the execution of an Order, including any commission charged by us where applicable.
   23. Trading Venue: A Regulated Market, Multilateral Trading Facility (MTF), or Organised Trading Facility (OTF).

2. Purpose and general provisions of the Policy

   1. The primary purpose of this Policy is to describe how we execute your Orders in Financial Instruments and to set out the steps we take to obtain the best possible result for you — that is, to deliver Best Execution.
   2. This Policy is adopted in accordance with:
      1. Directive 2014/65/EU on markets in financial instruments (MiFID II);
      2. Regulation (EU) No 600/2014 on markets in financial instruments (MiFIR);
      3. Commission Delegated Regulation (EU) 2017/565 supplementing MiFID II as regards organisational requirements and operating conditions for investment firms;
      4. Commission Delegated Directive (EU) 2017/593 supplementing MiFID II with regard to safeguarding of client financial instruments and funds; and
      5. The Financial Instrument Market Law of the Republic of Latvia (FIML) and related secondary legislation issued by Latvijas Banka.
   3. This Policy is binding on all our employees involved in the execution or oversight of your Orders.
   4. We exclusively serve Retail Clients. We do not serve Professional Clients. This Policy therefore applies to all of our clients without distinction.
   5. This Policy is publicly available on our website. You will be acquainted with this Policy before we begin providing investment services to you.
   6. You will be notified of any material changes to this Policy via in-app notification, email, or other durable medium, with sufficient advance notice before any such change takes effect.

3. Financial Instruments and Services Covered

   1. This Policy applies to the handling and best execution of your Orders in Financial Instruments (MiFID II Annex I, Section A, point 2) by the Company.
   2. Currently the Company only handles Orders in equities (shares). Our current product offering is limited to shares whose primary Trading Venue is a US exchange. The Company implements and maintains a control to ensure that only qualifying instruments are made available to you, and keeps this restriction under review as new instruments are considered for addition to the Platform.
   3. Fractional shares are covered by this Policy and are addressed specifically in Section 8.
   4. Notwithstanding the instruments and services covered by this Policy, we have an overriding duty to act honestly, fairly, and professionally in the best interests of our clients at all times.

4. How your Orders are Executed

   1. Execution Model Overview
      1. We either execute your Order by dealing on its own account (acting as a principal) or transmits the Order to the Broker for execution. All Orders received are either promptly and fairly executed by us or transmitted to the Broker. When the Company transmits the Order to the Broker, the complete and final details of any transactions under the transmitted Order will become known to us only upon confirmation from the broker.
      2. When acting as a counterparty to your transactions, we are responsible for the execution of your Orders and will take all sufficient steps to consistently execute them on the most favourable terms and in accordance with this Policy.
      3. When transmitting Orders to the Broker, we take all sufficient steps to ensure that the Broker consistently executes them on the most favourable terms and in accordance with its respective best execution policy. Where the Broker does not have a best execution policy or its standards do not meet the requirements set forth in the FIML, we enforce best execution standards through legal arrangements with the Broker, having your best interest in mind.
      4. Despite our obligation to consistently obtain the best result for you, neither we nor the Broker can guarantee that the best possible result will be achieved on every single Order and in respect of each Client. This may occur for several reasons, including the fact that the same instrument may be traded across different venues at slightly varying prices; new Orders may enter the market and be executed ahead of your Order; or other investment firms may have access to better pricing that is not available to us or the Broker.
   2. Lifecycle of an Order
      1. You submit an Order via the Platform.
      2. We register all Orders we receive. The Orders placed are registered automatically in our books and records, which meet the legal requirements of a durable medium. The system immediately captures, in chronological Order, the following data about the Orders placed:
         1. date and exact time of the Order;
         2. client identification data;
         3. financial instrument identification data in relation to the placed Order;
         4. Order instruction (buy, sell);
         5. Order type.
      3. We validate the Order terms — instrument, size, and direction — and performs pre-trade controls to check for insufficient balance, Order error, or improper use of the Platform.
      4. If the Order is accepted, the Company immediately updates its Internal Ledger and reflects this status on the Platform.
      5. You will have the option to cancel Orders on the Platform by hitting the “Cancel” button next to the Order which shall be cancelled. However, the “Cancel” button will be available only until the Order is executed by us or transmitted to the Broker for execution. Generally, all market Orders will be executed immediately after placing; thus, the Order cancellation option will be not practically possible. There is also no other method for cancellation of Orders, other than via the Platform.
      6. The Order will be either executed by us or transmitted to the Broker for execution, unless it was rejected.
      7. Once there is a result regarding the execution of the Order, we will cascade the information back to you promptly via the Platform.
      8. We also take responsibility for overseeing and facilitating the settlement of Orders executed by us or the Broker. As such we ensure that funds and/or financial instruments subject to the Order are promptly and correctly delivered to the appropriate accounts. This is ensured through implementation of legal and operational arrangements both internal and entered between us and the Broker.
   3. Order Handling
      1. Orders are executed promptly and in the sequence in which they are received, except where the nature or size of the Order, or your interest, requires otherwise, or where you have provided a specific instruction (see Section 6).
      2. Front-running of Client Orders is strictly prohibited and is subject to monitoring under the Company’s market conduct procedures.
      3. We will inform you of any material difficulty likely to affect the proper execution of your Order as soon as it becomes aware of such difficulty. In the event of market disruptions, system outages, or force majeure events that prevent execution in accordance with this Policy, the Company will take all reasonable measures available to it to achieve the best possible result for Clients in the circumstances.
   4. Post-Execution Trade Confirmation
      1. For each executed Order, we promptly make available to you, on the Platform as a durable medium, a trade confirmation containing the following information:
         1. Date and time of execution;
         2. Whether the Order was a purchase or a sale;
         3. The Financial Instrument purchased or sold;
         4. Quantity (including fractional amounts where applicable);
         5. Unit price at which the Order was executed;
         6. Fees charged, where applicable; and
         7. Total notional value of the transaction.

5. Best Execution Application and Criteria

   1. To comply with the obligation to act in accordance with your best interests, when we execute an Order for Financial Instruments, we must take all sufficient steps to obtain the best possible result taking into account the execution factors: price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of an order.
   2. The relative importance of these factors must be determined by reference to the execution criteria and to the requirement to determine the best possible result in terms of the Total Consideration, representing the price of the financial instruments and the costs related to execution, which must include all expenses incurred by you which are directly related to the execution of the order, including, where applicable, execution venue fees, clearing and settlement fees and any other fees paid to third parties involved in the execution of the order. Implicit costs, such as spreads and slippage shall also be considered.
   3. When Best Execution Applies
      1. Because we serve only Retail Clients, Best Execution is assessed primarily in terms of Total Consideration — being the price of the Financial Instrument and all costs directly related to the execution of the Order. This is the overriding criterion.
      2. The rebuttable presumption under MiFID II applies: a Retail Client legitimately relies on us to protect their interests in relation to price and other execution parameters, including where we execute as principal on the basis of a firm quote. Accordingly, Best Execution applies to all Orders executed by us in our principal capacity.
      3. Best Execution does not apply to the specific elements of an Order covered by your specific instruction — see Section 6.
   4. Execution Factors
      1. When executing your Orders, we take into account the following execution factors:
      2. Price:
         For all Financial Instruments we offer, there are two quoted prices on the Platform: the higher price (BUY), at which Client can buy the instrument, and the lower price (SELL), at which they can sell it.
         The prices are updated as frequently as the limitations of technology and communications links allow. The number and prices of instruments are indicative and may be different from those at the time of the execution of Market Orders due to factors such as, but not limited to, movements in the foreign exchange markets.
         The Company regularly reviews its third-party external reference sources to ensure that the data obtained are as timely and accurate as possible. For example, in cases of Stop, Market, or Limit Orders, these Orders will be executed immediately as soon as the price reaches the Order level set by you. However, under certain trading conditions, there is a possibility that these Orders cannot be executed at the requested price.
         When this happens, we have the right to execute the Order at the first available price. This may occur, for example, at times of rapid price fluctuations if the price rises or falls in one trading session to such an extent that trading is suspended or restricted under the rules of the relevant exchange. Such fluctuation can result in a better or worse price for you. This may also occur when trading for the relevant Financial Instrument is experiencing relatively low trading volumes (low liquidity).
      3. Costs:
         For share transactions, we do not charge any commission. All fees are visible to you before placing Orders as they fluctuate in line with the market prices. Other applicable fees relating to stamp duty or local tax regulations are applied in accordance with the relevant governing body and visible within the Platform prior to trading.
      4. Speed (meaning the time taken to execute an order for financial instruments):
         When Clients submit a market order or a stop order is triggered, we consider that the speed with which a trade is executed is of significant importance to our clients. For Share transactions, Market Orders will be executed on the next price update once received from the relevant securities venue to validate the reference price, for most products this will result in immediate execution. Whilst the majority of Orders are filled immediately, price of execution will be generally prioritised over speed, depending on market conditions prevailing that it is in your best interest.
         Other factors that may affect execution speed include poor internet connection or any other link to our servers and platform, which may affect the execution of Orders.
      5. Likelihood of execution and settlement:
         In almost all circumstances, your transaction requests will be executed automatically at the level requested or prevailing market level in case of a market order, subject to the size requested equal to or under the size permissible by us at that time.
         In order to minimise execution failure, we apply maximum order sizes in line with the typical liquidity of the underlying Financial Instrument, therefore enabling us to maintain a high execution rate.
         In certain circumstances, due to speed of internet communications, market volatility or in the case of an erroneous price being submitted, transactions may be rejected by us if the price requested by you is not representative of the ‘underlying market’ price when received by us.
         In some situations, the Company may provide a partial fill of a transaction request as an alternative to outright rejection. If an Order can only be executed partially due to various reasons or applicable limits, the Company makes all reasonable efforts to execute that part of the transaction.
      6. Order size and nature (meaning the size of the order placed and how this affects the price of execution — typically only relevant for large transactions):
         Every order execution is subject to size considerations. If the requested transaction size is larger than the size that can trade on the reference Trading Venues at that time, then the entire transaction or Order may be restricted or rejected, but we may offer greater liquidity than reference Trading Venues at our discretion. Every market quoted by us has an absolute minimum and maximum permitted which are indicated on the Platform. The maximum transaction size may vary due to market conditions and is, at all times, at our discretion.
         In the event of a transaction request of unusual size or where the market in which the transaction has been requested is illiquid or very volatile, the Company may prioritise price over speed of execution and may, at its sole discretion, only accept the transaction after the exposure in the underlying market has been covered.
   5. Prioritisation of Factors
      1. We prioritise achieving the best overall price (including all related costs) as the most important execution factor, in line with FIML for retail clients, and generally assume this aligns with Clients primary objective. However, we balance this against other factors — such as speed, liquidity, and technology reliability — since the "best price" alone may not deliver the optimal result if offset by higher direct or indirect costs (e.g., market impact or exchange/clearing fees), venues with less liquidity or inadequate technology or product features. In certain circumstances, therefore, the Company may determine that the speed and likelihood of execution and settlement may take precedence over immediate price and cost factors if the former are instrumental in delivering the best possible result. This may be the case, for example, for Orders in illiquid or non-electronically executable shares or when a Stop Order has been triggered.
      2. There may be circumstances in which we deviate from this standard prioritisation — for example, in the case of particularly large or illiquid Orders where certainty of execution is more critical than immediate price, or in the event of severe market disruptions. In all such cases, we will inform you of any material difficulty promptly. If you provide specific instructions in respect of your orders, your instructions will take priority.

6. Orders Subject to Specific Instructions

   1. Where you provide specific instructions as to the manner of execution of an Order — most commonly in the form of a limit Order specifying a maximum purchase price or minimum sale price — the Company will follow those instructions.
   2. By following your specific instructions, we are deemed to have satisfied our Best Execution obligation with respect to the elements of the Order covered by those instructions. We remain responsible for achieving the best possible result in relation to all execution factors not covered by the specific instruction.
   3. You should be aware that specific instructions may prevent us from following this Policy in full in respect of the elements covered by those instructions.

7. Selection of Execution Venue per trade

   1. In relation to US shares, the Company will either act as a counterparty to the your transactions and thus serve as an execution venue for the Orders or to transmit the Orders to the Broker. In the latter case, it is in the Broker's discretion to choose the execution venue for transmitted Orders, as long as the result will meet the standards and requirements set out in this Policy. The Broker might execute the trades by itself thereby acting as the execution venue for the submitted Order, on Trading Venues, and with other liquidity providers. We will always inform you where the transaction has been executed as a part of its post-trade notification process.
   2. When we act as a counterparty (principal) to your transactions we execute Orders against our proprietary capital and outside a Trading Venue, which is called over-the-counter (“OTC”) trading. When we transmit Orders to the Broker, the Broker might also execute the transmitted Orders outside of a Trading Venue or via an intermediary.
   3. The Company is required, under Article 28(1) MiFID II and Article 64 of Commission Delegated Regulation (EU) 2017/565, to obtain your explicit consent before executing Orders outside a Trading Venue. By accepting the Agreement, you provide this explicit consent to off-venue execution.
   4. When we transmit your Orders in respect of shares listed in the United States, we utilise Alpaca Securities LLC, a US broker-dealer registered with the Securities and Exchange Commission and a member of the Financial Industry Regulatory Authority and Securities Investors Protection Corporation.
   5. We reserve the right to add or remove brokers and execution venues as deemed appropriate in order to obtain the best possible result for you. We select only brokers that combine high quality service standards with effective best execution arrangements in Order to obtain best execution on a consistent basis.

8. Fractional Shares

   1. We facilitate trading in fractional shares — being a portion of a whole share — acting in a principal capacity. Fractional shares are not listed on an exchange in their own right; they are executed internally against our own book.
   2. Best Execution applies to fractional share Orders in the same manner as to whole share Orders: Total Consideration is the primary criterion and the NBBO is the reference benchmark. There is no distinction in execution quality between fractional and whole share Orders.
   3. Fractional holdings are recorded to eight decimal places in the Internal Ledger. Rounding of very small fractional positions may in edge cases affect distributions for corporate actions; any such rounding is conducted using reasonable endeavours and is disclosed to you.

9. Aggregation and Allocation

   1. When executing or transmitting Orders to brokers for execution, we do not aggregate Orders of one client with another.
   2. Your positions are individually and separately recorded in the Internal Ledger at all times. We do not commingle our firm assets with your assets in our internal records.
   3. In accordance with its obligations under applicable law, the Company will endeavour to provide Clients with prompt, fair, and expeditious execution of Orders placed with the Company relative to other Orders from its Clients. In so doing, the Company:
      1. Promptly and accurately record and allocate Orders executed on your behalf;
      2. Carry out your comparable Orders sequentially and promptly, unless the characteristics of the Order or prevailing market conditions make this impracticable, or your interests require otherwise; and
      3. Inform you of any material difficulty relevant to the proper carrying out of your Orders promptly upon becoming aware of the difficulty.

10. Quoting Methodology

    1. We provide quotes to you based on the real-time NBBO. The NBBO is the benchmark we consider most appropriate for US-listed equities because it consolidates the best available bid and offer prices in real time across all major US national exchanges — including NYSE and NASDAQ — thereby representing the widest and most liquid pool of reference prices available for the instruments we currently offer. This is the standard used by US regulators and market participants to reflect prevailing market conditions for US equities, and it is the reference price against which any execution in those instruments would be assessed by a competent authority.
    2. We do not just display the NBBO price as is, but also take into account potential negative slippage and any potential market impact arising from your Order size to come up with a final quote that most likely indicates the actual execution results of your Orders.
    3. Where the NBBO price is not available (ie. during the overnight session), the firm will reference the prices from available Trading Venues.
    4. US shares are primarily quoted in USD. If you request quotes in other currencies such as EUR, the same USD-denominated quotes will be converted using our own foreign exchange rate.
    5. A quote displayed on the Platform is indicative and may differ from the price at which a trade may be later executed due to factors that make the quote manifestly out of date, such as the changing market conditions and the time elapse between the quote generation and the Order submission.

11. Conflict of Interest

    1. Nature of the Conflict
       1. Executing orders by dealing on our own account may introduce conflicts of interest and we aim to avoid conflicts of interest wherever possible.
       2. Additionally, the Company may carry an intraday book that could, in theory, create an incentive to price away from the market in order to manage its own exposure.
    2. Mitigation measures
       1. This conflict is managed through the following controls:
          1. Quote consistency: We provide firm quotes to you and conduct regular review through our Best Execution monitoring programme (Section 12) to ensure that these quotes are consistently in line with the NBBO. We do not exercise individual discretion over the prices of specific quotes for you; prices are generated from the real-time NBBO feed according to a defined and consistently applied process.
          2. Best Execution monitoring: The independent monitoring programme described in Section 12 provides systematic verification that execution quality for Clients is not being subordinated to the Company’s hedging or inventory management interests.

12. Best Execution Monitoring

    1. General Obligation
       1. The Company is required to monitor the effectiveness of its Order execution arrangements on an ongoing basis and to identify and correct any deficiencies promptly, in accordance with Article 27(7) MiFID II and corresponding FIML requirements.
    2. Benchmark
       1. For all your executions in US-listed equities, the benchmark against which execution quality is assessed is the NBBO published by the Primary Reference Venue at the time the Order was received from you.
       2. The NBBO, wherever available, is the appropriate benchmark for this purpose because it aggregates the best available bid and offer prices across all major US national exchanges in real time, and therefore represents prevailing market conditions for the relevant instruments in the most comprehensive manner available.
       3. During the overnight trading hours where the NBBO is not available, we will reference prices from Blue Ocean Alternative Trading System.
    3. Current Monitoring Programme
       1. Our current monitoring programme involves manual review of a representative sample of executions on a quarterly basis, covering the following elements:
          1. Price tolerance: Each sampled execution is compared against the NBBO at the time of Order receipt making sure the price difference, if any, is within an acceptable deviation. Executions outside the tolerance are flagged for review.
          2. Slippage analysis: The difference between the NBBO at the time of Order receipt and the final execution price (slippage) is recorded for all sampled Orders.
    4. Review Process and Escalation
       1. The Operations Department conducts the quarterly sample review. Executions flagged by price tolerance breaches are escalated to the Head of Operations. The Compliance Department independently reviews the Operations Department’s findings as second-line oversight. Material issues are escalated to the Chief Executive Officer and/or Chief Compliance Officer, and further to the relevant Board committee as appropriate.
       2. Where a best execution failure is identified, we assess whether client remediation is required. Where it is, we will offer a price improvement or cash adjustment to the affected client or clients.

13. Review, and Updates

    1. This Policy shall be reviewed at least annually, or whenever a material change occurs that affects Best Execution parameters. Material changes include, among others: changes to the instruments or services offered; changes to the execution model; changes to the NBBO benchmark data sources; and regulatory developments affecting best execution obligations.
    2. You will be notified of material changes to this Policy in advance of those changes taking effect, via in-app notification, email, or other durable medium.