Legal Documents

Introduction

KONG SHING WEALTH COMPANY LIMITED (hereinafter referred to as the "Company") is incorporated in accordance with the laws of the Autonomous Island of Anjouan, with registration number 15705 and registered address at Hamchako District, Mutsamudu City, Autonomous Island of Anjouan. The Company holds an international brokerage and clearing license and is authorized to conduct all types of brokerage business in accordance with Government Notice No. 005 of 2005 (hereinafter referred to as the "Law"), and is regulated by the Anjouan Offshore Financial Authority.

The Company's purpose is to provide diversified brokerage services to corporate and individual clients outside the Autonomous Republic of Anjouan, including but not limited to:

The Company must take all reasonable steps to obtain the best possible results (or "best execution") for clients when executing clients' orders or receiving and transmitting orders for execution. These rules require the Company to establish an execution policy specifying how it will obtain best execution for clients and to provide clients with appropriate information about its order execution policy.

Scope and Services

This Policy applies to both retail clients and professional clients.

This Policy applies to the Company's provision of investment services related to the receipt and transmission of orders in respect of one or more financial instruments and/or the execution of orders on behalf of clients. The Company's financial instruments are Contracts for Difference (CFDs) on underlying assets, and the Company reserves the right to determine in its discretion which types of CFDs to offer from time to time and to publish trading prices based on prices provided by its liquidity providers/execution venues.

When a client trades CFDs with an execution venue, the Company always acts as an agent (acting on behalf of its clients); therefore, if a client decides to open a position on the Company's platform, that position can only be closed through that execution venue on the Company's platform.

Execution Venues

The Company is not an execution venue for executing clients' CFD orders. Therefore, in clients' CFD transactions, the Company does not act as a counterparty to execute clients' orders on its own account. The Company transmits clients' orders or arranges for execution by a third party. Therefore, that third party will be the execution venue rather than the Company. In this regard, if a client decides to open a position with an execution venue on the Company's platform, that position can only be closed through that execution venue on the Company's platform.

The execution venue for clients' orders is Huantaichang Global Co., Ltd.

The Company relies heavily on the above-mentioned execution venue based on the above factors and their relative importance. The Company's policy is to maintain internal procedures and principles to act in the best interests of clients and to obtain the best possible results (or "best execution") for clients when transmitting clients' orders to execution venues for execution.

The Company's operating hours are: 00:06:00 (GMT +3) every Monday to 00:55:00 (GMT +3) every Friday, operating 24 hours a day. Changes to the Company's operating hours and holidays and trading hours for specific financial instruments will be displayed on the Company's website.

The client acknowledges and agrees that transactions in financial instruments with the Company's execution venue are not conducted on a recognized exchange or multilateral trading facility (MTF), but through the Company's trading platform (i.e., over-the-counter trading), which may expose the client to greater risks than trading on a regulated exchange. The terms and conditions and trading rules are formulated solely by the execution venue. The client may only close an open position in any given financial instrument during the opening hours of the Company's trading platform. The client must also close any open position through the execution venue.

Best Execution Factors

When executing clients' orders, the Company will take all reasonable steps to obtain the best possible results for clients based on the quoted prices provided by its liquidity providers/execution venues, considering the following factors:

Price:

Bid-Ask Spread: For any given financial instrument, the Company will quote two prices, provided by the liquidity provider/execution venue: the higher price (ASK) is the price at which the client can buy (go long) the financial instrument, and the lower price (BID) is the price at which the client can sell (go short) the financial instrument; collectively, they are referred to as the Company's prices. The difference between the lower and higher prices for a given financial instrument is the spread.

Pending Orders: Orders such as "Buy Limit", "Buy Stop" and "Stop Loss"/"Take Profit" for open short positions will be executed at the ASK price; orders such as "Sell Limit", "Sell Stop" and "Stop Loss"/"Take Profit" for open long positions will be executed at the BID price.

Company's Prices: The Company's prices for a given financial instrument are provided by the execution venue, so the prices offered by the Company to clients are determined by the execution venue. The Company will update its prices as frequently as possible subject to technical and communication link limitations. The Company will not quote prices outside the Company's operating hours (see Section 3 above) or outside the trading hours for specific CFDs (as published on the Company's website), so clients cannot place orders during these periods. The Company cannot guarantee that the Company's prices will be the most favorable for the client when transmitting the client's order to the execution venue for execution. The primary way the Company ensures that clients receive the best execution price is to ensure that the liquidity provider/execution venue calculates the bid-ask spread by reference to a range of external data sources and independent price providers. The Company reviews the external reference sources of its execution venues at least annually to ensure that the data obtained continues to be competitive.

Costs:

For opening positions in certain types of financial instruments, the client may be required to pay commissions or financing fees (if applicable), the amounts of which are disclosed in the contract specifications on the Company's website or trading platform.

Commissions: Commissions may be charged as a percentage of the total transaction value or as a fixed amount.

Financing Fees: In the case of financing fees, the open position value of some types of financial instruments will be increased or decreased daily by a financing fee ("swap") for the duration of the contract. Financing fees are based on current market interest rates and may change over time. Details of daily financing fees can be found in the contract specifications section of the Company's website or trading platform.

For all types of financial instruments offered by the Company, commissions and financing fees are not included in the Company's quoted prices but are explicitly debited or credited to the client's trading account.

Execution Speed:

The Company attaches great importance to the efficient execution of clients' orders and strives to provide high execution speed within the limitations of technology and communication links.

Nature of Orders:

The specific nature of an order will affect the execution of the client's order. Clients may choose to place orders with the Company for execution in the following ways:

The client places a "Market Order", which is an order executed immediately at the price provided by the Company from the execution venue. If the market moves at the time the client places a market order, the order may be executed at the first available price or not executed at all. The client may modify a market order to attach a "Stop Loss" and/or "Take Profit". A "Stop Loss" is used to limit the client's losses, while a "Take Profit" is used to limit the client's profits.

The client places a "Pending Order", which is an order to be executed at a price specified by the client at a later time. The Company will monitor pending orders, and when the price provided by the execution venue reaches the price specified by the client, the pending order will automatically become a market order. The following types of pending orders are available: "Buy Limit", "Buy Stop", "Sell Limit" and "Sell Stop". The client may attach a "Stop Loss" and/or "Take Profit" to any pending order. The client may modify the order before it is executed. According to the contract specifications available on the Company's website or trading platform, the minimum level for setting "Stop Loss", "Take Profit", "Buy Limit", "Buy Stop", "Sell Limit" and "Sell Stop" orders is 1 to 10 times the spread of the given financial instrument. If the price reaches the order execution level, the client has no right to change or delete the "Stop Loss", "Take Profit" and "Pending Order".

Likelihood of Execution:

As stated in Section 3 of this Policy, the Company is not an execution venue for executing clients' CFD orders. The Company relies on liquidity providers of execution venues to provide prices and available liquidity, so the execution of clients' orders will depend on the pricing and available liquidity of these providers. Although the Company accepts and executes all orders placed by clients, it reserves the right to reject any type of order.

The Company endeavors to provide clients with the best possible prices and makes all efforts and necessary arrangements to this end; however, it cannot guarantee that all or any pending orders will be executed at the stated price. For financial instruments offered by the Company, "Stop Loss", "Take Profit", "Buy Limit", "Buy Stop", "Sell Limit" and "Sell Stop" orders will be executed at the price stated by the client when the current price is first reached. However, under certain trading conditions, it may not be possible to execute orders (Stop Loss, Take Profit, Buy Limit, Buy Stop, Sell Limit, Sell Stop) for any financial instrument at the stated price. In such cases, the Company is entitled to execute the client's order at the first available price. This may occur in the following situations:

At the start of a trading session / opening gaps

During news releases

During periods of extreme market volatility, where prices may fluctuate significantly up or down, deviating from the stated price

If prices rise or fall sharply within a single trading session to such an extent that trading is suspended or restricted under the rules of the relevant exchange

If there is insufficient liquidity for the specific volume at the stated price.

If the client trades on the electronic system, the client will be exposed to system-related risks, including hardware and software (internet/server) failures. Any system failure may result in the client's order not being executed as instructed or not being executed at all. The Company shall not be liable for any such failures.

Likelihood of Settlement:

The Company will settle all transactions after their execution.

Order Size:

All client orders are placed in lots. The minimum tradable size is 0.01 lot or as stated in the contract specifications on the Company's website. A lot is a unit of measurement for transaction volume and varies for different types of financial instruments. Please refer to the contract specifications on the Company's website for the lot value of each given type of financial instrument. Although there is no limit on the maximum order size that a client can place with the Company in some cases, the Company reserves the right to reject an order if the order size is too large and cannot be filled.

The Company will make every effort to fill the client's order regardless of the volume. However, if filled, it may be executed at the first available price, which may differ from the price stated by the client, depending on market liquidity at the time of execution (see the Likelihood of Execution section).

Market Impact:

Certain factors, such as abnormal market conditions, may quickly affect the prices of financial instruments offered by the Company. These factors may impact some of the factors listed above. The Company will take all reasonable steps to obtain the best possible results for the client.

The Company considers the above list of execution factors to be non-exhaustive, and the order in which the above factors are listed shall not be deemed to be based on the priority of each factor. However, if the client has specific instructions, the Company will ensure that the client's order is executed in accordance with the client's specific instructions (see Section 6: Client-Specific Instructions).

Best Execution Standards

The Company will determine the relative importance of the aforementioned factors based on its business judgment and experience with available market information, and will take into account the following criteria:

Client characteristics, including the classification of the client as a retail client or a professional client

Characteristics of the client's order

Characteristics of the financial instrument involved in the order

Characteristics of the execution venues to which the order may be directed

For retail clients, the best possible result will be determined based on the total consideration, which includes the price of the financial instrument and costs related to execution. Such costs cover all fees directly incurred by the client for order execution, including execution venue fees, clearing and settlement fees, and other fees paid to any third parties involved in the order execution process.

Client-Specific Instructions

Any specific instructions from the client may prevent the Company from taking the steps designed and implemented in this Policy to achieve the best possible result in the execution of the order concerning the relevant elements. This is because the Company will execute the order in accordance with the client's specific instructions. By executing the client's order in line with the specific instructions provided by the client, the Company will fulfill its obligation to provide best execution for the client.

Review and Monitoring

The Company will review the established execution policy and any related order execution arrangements on an annual basis. Such a review will also be conducted whenever there is a material change that affects the Company's ability to continue using execution venues to consistently achieve the best possible results for client order execution. In addition, the Company will continuously monitor the effectiveness of the policy and the related order execution arrangements to identify and implement any appropriate improvements. It should be noted that the Company will not notify clients individually of changes to the policy, unless such changes are material and significant. Therefore, clients should refer to the Company's website from time to time to obtain the latest version of the policy.

Client Consent

This Policy forms part of the account opening agreement between the Company and the client. Therefore, by entering into an agreement with the Company, the client also consents to the terms of this Order Execution Policy.

The client further consents to the Company receiving and transmitting their orders for execution outside of regulated markets.