Trading Platforms

Costa Markets customers can trade using the following trading platforms (“platforms”):

• Web Trader

• Costa Markets Trading Terminal

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Trading is subject to trading hours’ restrictions and are provided per
investment instrument on the platforms.

Execution Venues

Costa Markets provides two types of execution venues. Primarily, Costa Markets operates as a
principle which means that the Company is the counterparty of client
transactions.

In rare circumstances, the Company also operates as an agent whereby client
transactions are received and transmitted to other reputable liquidity
providers.

Price

Costa Markets provides two-way pricing quoted live across all its products to clients,
which can be accessed on Costa Market’s platforms. Costa Markets aims to provide
clients with fast, reliable and uninterrupted prices.

Costa Markets receives raw price data for all trading instruments from its Liquidity
Providers (“LPs”) and Data Providers such as regulated markets, multilateral
trading facilities (MTFs), executing brokers, etc. Costa Markets avoids
over-reliance on any single provider and manages its risk in compliance with
its Risk Management Framework.

Each LP is carefully on-boarded, and due diligence is performed by Risk and Compliance
departments to ensure that the LP can offer the best possible prices to Costa Market’s clients. For example, upon adding a new LP, the Risk and IT department
perform detailed tests to confirm the speed and accurateness of raw inputs by
comparing it against independent benchmark services.

LPs and all data sources are reviewed continually by the Risk department. All
pricing sources are subject to due diligence before they are activated. If a
pricing source is to be re-activated a review of its due diligence will be
required.

After receiving the raw data, it is fed to Costa Market’s price engines, which have the
purpose of delivering to the end user terminal a smooth and consistent flow of
quotes in accordance with the target and average spreads disclosed on the
website. Costa Markets has developed an in-house application that tracks price
level discrepancies and latency of all price feeds.

In the rare circumstances a client is unable to execute trades on the Firm’s
system (e.g. due to internet connectivity issues), Costa Markets allows clients to
submit instructions via phone or e-mail. When running client instructions over
the telephone, Costa Markets aims to quote the price as if the client is trading
through the trading platforms subject to any delays due to the manual process
of trading over the phone/e-mail. Costa Markets confirms the execution of client
trades immediately after the client indicates the desired action. If a trade is
confirmed by telephone, the client may request a confirmation of the execution
in writing.

Cost

Spreads and commissions are the critical aspects of the expenses Costa Market’s clients
can incur, and Costa Markets always aims to ensure that these are reasonably
competitive as compared to other operators in the CFD market (e.g. Spreads are
monitored continuously by Costa Market’s Risk department). The costs the client
will incur in executing an order with Costa Markets will be related to the spread
and commissions. Spreads are dynamic and are dependent on several factors
including market liquidity and volatility.

Information on “spreads”, “swaps” and “commissions” is available for the various securities
at where the target spread applied, along with average spreads, updated weekly,
commissions and swaps (where applicable) are displayed.

For transparency purposes, further details of the spreads, commissions and other
costs for each underlying instrument will be provided on Costa Market’s website.
Clients are encouraged to understand the associated costs prior to executing
with Costa Markets fully.

Speed, size, and likelihood of execution

Costa Market’s clients
receive immediate execution capability, meaning that, if a client sees a price
on the screen, in most cases the trade is executed at the displayed price. Costa Markets provides latency allowance on orders; if our system executes the market
price moves before a request, the order is filled at the order price if the
difference between the order and market prices is still within the relevant
slippage parameter. On the other hand, if latency causes the difference between
the order and market prices to be higher than the relevant slippage parameter, the order
is rejected.

Being the main counterparty to client trades, Costa Markets is ready to absorb trade
requests up to the maximum trade size set for each trading instrument. Maximum
trade size is available in the contract specifications of each instrument in
each trading platform.

Costa Markets determines the maximum size of trade available to clients for each CFD
instrument. Regardless of the type of the order Costa Markets executes any order
at VWAP (Volume-WeightedAverage Price) should the size of an order exceed the
tradable size at the time of the execution. Depending on the tradable size, Costa Market’s clients may experience that their orders may be executed at a less
favourable price.

However,
under all circumstances, Costa Markets pays due regard to ‘slippage’ and passes on
positive slippage to clients in case the market moves in favour of them.

No order aggregation

Costa Markets general practice is not to aggregate any client orders with other client
orders or any transactions for its account.

Client-specific instructions

If clients provide Costa Markets with instructions on how to execute an order,
complying with those instructions may prevent Costa Markets from taking the steps
that are set out in its Order Execution Policy to obtain the best execution for
its clients. In those circumstances, Costa Market’s execution in accordance with
the client’s instructions will be deemed the best execution.

Also, specific instructions from clients may
sometimes rate some execution factors over others; for example, size as a
factor may take precedence over price and cost.

Client Protection

Despite ensuring that Costa Market’s clients receive the best execution, Costa Markets has
implemented further measures to ensure that its clients are protected at all
times. Costa Markets also provides that it’s systems automatically offer default
protections to its clients.

Stop Loss Orders

Clients have the option to trade “stop loss” and “trailing stop loss” orders. This
allows clients to autonomously set the level at which they will sell out to
limit losses. If the security price reaches this level, the position will be
closed automatically.

Such orders are always connected to an open position or a pending order.

Negative Balance Protection

Costa Markets offers all retail clients negative balance protection. This means that
clients will never lose more than their invested capital.

Negative
balance protection means that any trading losses cannot exceed the funds on
your account and thereby giving you, the customer greater protection.
Therefore, whilst you can still lose all your account funds, you cannot exceed
that loss on your account which means that, in accordance with the policy
below, you will not owe money to us. Please note however that your entire
capital may still be at risk. Below is the policy by which Costa Markets shall
manage and calculate the negative balance on your trading account.

1)   This policy is only applicable to retail customers.

2)   Costa Market’s systems have always incorporates the requisite safeguards
to protect the customers from encountering negative balances when trading under
normal market conditions. Customers are provided with margin monitoring
functionality. If the margin level on customer account is equal to, or drops
below, 50%, Costa Market’s system automatically initiates the closing of current
open positions, starting from the most unprofitable considering trading hours
of particular instruments traded by the customer. Positions will be
automatically closed at the current market price. Also, the customers can and
should set personal limits for risk management purposes which can help limit
losses and maximize profits.

3)   In the event that there are certain market conditions which cause a
significant “market gap” and thereby making it possible to incur a negative
balance while trading, Costa Marketsshall absorb the negative balance. The
customer shall therefore be protected against such loss because the purpose of
the negative balance protection also provides a backstop in the case of extreme
market conditions.

4)   The customer should always maintain the appropriate levels of margin
in the trading account as the recommended method of risk management

Automatic Stop Out

Costa Markets sets minimum margin requirements that result in automatic Stop Out levels
to protect clients from losses. If during an open trade, the net worth of the
account reaches the “margin level” equal to 50% of the required margins, all
positions would be automatically closed.

Conflicts of interest disclosure

Costa Markets is the main execution venue as described above, and it acts as the
principal counterparty to its clients’ trades. However, in rare cases, Costa Markets acts as an agent and transfers its trades to a reputable counterparty.

Although there is a
general conflict of interest when Costa Markets acts as the principal counterparty
or execution venue for its clients, Costa Markets does not compromise on its
commitment to its clients to provide the best execution. Most orders are
executed at the ‘top of the book’, and there is no discrimination in the price
for one client vs any other. Costa Markets has a robust back-end price feed infrastructure
that ensures that prices are fed by several exchanges, MTFs, and by many
different liquidity providers.

In addition, Costa Markets is bound by its Order Execution Policy and continuously
looking to enhance its best execution monitoring capabilities.

Also, Costa Markets monitors its Complaints in this respect actively, and it is done
independently by the Compliance department, which further ensures to comply
with the Firm’s best execution obligations. With regards to its clients, Costa Markets offers the best execution to both retail and professional clients, and its
automatic execution flow does not differentiate or treat client orders
differently. The variation may apply depending on the client’s risk appetite
when compared to another. For example, professional clients may choose to take
more risk or higher leverage as compared to retail clients.

Best execution monitoring

Costa Markets is continuously monitoring its ‘prices’ compare to the market through
internal monitoring measures and third-party vendor solutions. Prices are
monitored around execution time within set thresholds against market price and
the underlying instrument.

Where the underlying instruments are traded over the counter (OTC), such as Forex and
Metals, the critical factor is the spread. Costa Markets monitors the spread to
ensure it sources the most competitive price. The following parameters are
taken into consideration for low, normal, and high volatility trading periods
latency of price feed, the frequency of price updates, and complete
representation of top of the book of orders.