Best Execution Policy

INTRODUCTION

In Vetiva, it is our priority to deliver best execution to all categories of clients, whether individual or institutional clients. Consequently, Vetiva has established best execution guidelines which all our brokers are required to follow strictly in processing/executing client orders. In addition, there are NGX Regulation requirements in place to guide the execution of trades by brokers, and ensure that client orders are treated expeditiously and with priority over proprietary trades of the firm. This document sets out the processes we adopt in delivering our services.

BEST EXECUTION PRINCIPLES AND CONSIDERATIONS

Our established practice is to execute client orders in accordance with their mandates. When an order is received from a client, we take reasonable steps to obtain the best possible result in the execution of the order, subject to, and taking into consideration factors including (but not limited to) the following:

• Price
• Costs and Commissions
• Speed
• Likelihood of execution and settlement
• Client type
• Liquidity of the financial instrument
• Regulatory requirements on disclosure
• Execution capability
• Size, nature and restrictions on the order
• Any other consideration relevant to the execution of the order
• Terms and conditions of the client mandate.

We will inform our client about any material difficulty relevant to the proper execution of orders promptly upon becoming aware of the difficulty.

REGULATORY CONSIDERATIONS

As a regulatory requirement, Vetiva is not allowed to take advantage of an order or a block transaction that may influence the price of a security issued by a client or a group of clients; nor trade ahead of clients in the same direction of their orders before the clients' orders have been executed. Vetiva is also prohibited from making any deals or recommendations to other clients to trade in the same direction of the orders received before the execution of the order. Where Vetiva deals on its proprietary account and the counter party to the transaction is Vetiva's client, to ensure compliance with the best execution principle, the transaction shall be treated as an execution of the client's order, not Vetiva's order.

Where a client issues specific instructions in relation to the execution of an order, Vetiva will execute such order in line with the specific instructions given by the client, even where such specific instructions may prevent us from taking the steps we have put in place to provide the client with best execution.

In the absence of express instructions from the client, Vetiva will exercise its discretion, as much as possible in conformity to the client's order, in determining the factors that would be required to provide the client with best execution.

AGGREGATION AND ALLOCATION OF ORDERS

Where Vetiva aggregates a client's order with one or more other orders and the aggregated order is partially executed, Vetiva will allocate the trades in accordance with its order allocation policy, which shall provide sufficiently precise terms for the fair allocation of aggregated orders and transactions, including how the volume, price and/or time of receipt of orders determines allocations and the treatment of partial executions.

Vetiva may only execute a client's order in aggregation with another client order if the aggregation of orders and transactions will not work against acceptable fair allocation methodology, as published from time to time by the NGX.

Vetiva will not aggregate a client's order with a transaction for its proprietary account.

>MONITORING AND REVIEW OF BEST EXECUTION

Vetiva will monitor and undertake a regular review of the effectiveness of this Policy and its execution arrangements on an ongoing basis, to identify and implement any appropriate enhancements that would further improve the processes in place to provide clients with the best execution.

We maintain an open channel of communication via Bloomberg to access market data and information by our clients for instant orders and execution mandates.