Best Execution Policy

The purpose of this document ("Best Execution Policy") is to inform you of how MonFX Pte. Ltd. ("MonFX") will execute trades with its clients. This takes into consideration the MAS Notice [SFA 04-N16] and Guidelines to MAS Notice SFA 04-N16 on Execution of Customers' Orders, in respect of the implementation of written policies and procedures for the following:

• To place or execute clients' orders on the best available terms; and
• To place or execute comparable clients' orders in accordance with the time of receipt of such orders.

This document only applies to clients who are accredited investors dealing in foreign exchange ("FX") over-the-counter derivatives (excluding spot) contracts with MonFX. Best execution is owed to such accredited investors where MonFX executes orders on behalf of clients who place reliance on MonFX to protect their interests in relation to pricing and other elements of the transaction.

Best execution is not owed to institutional investors as defined under the Securities and Futures Act and clients who are not placing reliance on MonFX to protect their interests.

MonFX will determine if clients are placing reliance on MonFX by taking into account the following four considerations:

• Which party initiates the transaction: Where the client initiates the transaction, it is less likely that the client is placing reliance on MonFX. Trade ideas, market communications or indicative prices provided as part of our general business are regarded as purely informational and shall not be deemed to have initiated the transaction.
• Market practice, including the convention of the client to 'shop around' for the best deal: Where market practice for a particular product suggests the client has access to different providers for quotes and has the ability to shop around, it is less likely the client is placing reliance on MonFX.
• Relative levels of transparency within a market: Where pricing information is transparent and reasonably accessible to the client, it is less likely the client is placing legitimate reliance on MonFX.
• Information provided by the firm about its services and any agreement reached with the client: Where any terms of agreement with the client do not suggest an understanding of reliance on MonFX or an agreement to provide best execution.

MonFX has a list of execution venues to execute transactions which we determine as beneficial in providing best execution. These venues will be based on our commercial judgement, consistency and reliability.

Where a duty to achieve best execution applies, MonFX will take account of the following factors when executing a transaction on behalf of the client:

• Price;
• Costs (including fees charged for execution, and clearing and settlement costs);
• Speed of execution — the time it takes to execute the order will depend on the price volatility and liquidity of the market;
• The likelihood of execution and settlement;
• The size and nature of the order; and
• Any other consideration that MonFX deems to be relevant to the execution of the order.