The Company's main activity is to provide investment services, cf. section 2-1(1) of the Securities Trading Act, and associated services, cf. section 2-6(1) of the Securities Trading Act.

FXC AS (hereinafter "FXC" or "the Company") shall, when executing customer orders, take sufficient measures to achieve the best possible result for the customer. The Investment Firm shall have effective systems, procedures and arrangements to ensure compliance with the provisions on best execution, including guidelines for the execution of client orders. Investment firms that provide reception and transmission of orders shall take specified measures to achieve the best possible result for their clients when placing or transmitting orders for execution with other firms. The Investment Firm shall have guidelines that enable the Investment Firm to fulfill these obligations.

1.2 Legal basis- Securities Trading Act §10-19.- Commission Regulation (EU) 2017/565 articles 65 and 66.1.3 Definitions‍1.3.1 CustomerIn this context, a customer is defined as an investor.
‍1.3.2 Execution of orders on behalf of the customerEntering into agreements to buy or sell financial instruments on behalf of customers.
‍1.3.3 A significant changeA material change shall be a significant event that may affect the parameters for best execution, such as cost, price, speed, likelihood of execution and settlement, size, nature or other factors relevant to the execution of orders.

2.1 Board of DirectorsThe Board must be informed if the procedure is changed.The Board of Directors must be informed if the procedure is changed.

2.2 Compliance officerCompliance shall at least annually review guidelines for order execution. These guidelines shall ensure that the Investment Firm executes orders in order to achieve the best possible result for its clients and this shall be checked during the annual review.

2.3 Implementation of the procedure

2.3.1 General requirements for implementationThe Investment Firm ensures that all reasonable measures are taken to achieve the best possible result for a client to the extent that the Investment Firm executes an order or a particular part of an order in accordance with specific instructions from the client with regard to the order or a particular part of the order.

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3.1 General requirements for implementationThe Investment Firm ensures that all reasonable measures are taken to achieve the best possible result for a client to the extent that the Investment Firm executes an order or a particular part of an order in accordance with specific instructions from the client with regard to the order or a particular part of the order.

3.1.1 Customer and order assessmentsBefore the Investment Firm implements all measures necessary to achieve the best possible result, the Investment Firm must carry out the following assessments:Categorization of the customer - determine whether it is a non-professional or professional customerCategorization of ordersCategorization of the financial instruments that are the subject of the order

3.1.2 Best possible resultThe assessments mentioned in 4.3.1.1 shall be used as a basis when the Investment Firm ensures that all measures that are necessary to achieve the best possible result for its customers are implemented. The following factors are used as a basis:- Price- Costs- Probability of execution and settlement- Size- Type- Other considerations relevant to the execution of the order- In a specific instruction from the client, the Investment Firm shall execute the order according to this instruction
3.2 Guidelines for execution3.2.1 Review of guidelinesThe Investment Firm shall review its guidelines for order execution at least once a year. These guidelines are intended to ensure that the Investment Firm executes orders in order to achieve the best possible result for its clients and this shall be checked during the annual review.A review shall also be carried out when a material change occurs that affects the Firm's ability to consistently achieve the best possible result for the execution of its client orders. The Investment Firm shall assess whether a material change has taken place and shall consider whether changes should be made with regard to the significance of the best execution factors in meeting the overall best execution requirement.
3.2.2 Information to the custom1.3.2.2.1 GuidelinesIn good time before the service is provided, the Investment Firm must provide clients with information about the Investment Firm's guidelines for order execution.The information to be provided is:- Explanation of the relative importance that the Company attaches to the factors mentioned in section 1.3.1.2, or the method that the Company uses to determine the relative importance of these factors.- Information about the Investment Firm executing orders outside a trading venue and the consequences of this, e.g. counterparty risk that arises when orders are executed outside a trading venue. If the Client so requests, additional information about the consequences of such execution must be provided.- A clear and prominent warning that any specific instructions from the client may prevent the Investment Firm from taking the measures designed and implemented in its order execution policy to achieve the best possible result with regard to elements covered by these instructions.- Summary of the process of execution strategies, practices and processes used to analyze the quality of execution achieved and how the Firm monitors and controls the achievement of the best possible result for the client.This information shall be provided on a durable medium or website.If a client requests information about the Investment Firm's policies and arrangements and how they are reviewed by the Investment Firm and the request is reasonable and proportionate, the Investment Firm shall respond clearly and within a reasonable time.
‍3.2.3 Payments from third partiesThe Investment Firm shall only accept payments from third parties if the payment is designed to improve the quality of the service in question to the client and does not impair compliance with the Investment Firm's duty to be honest, fair and professional in accordance with the client's best interests.
‍3.2.3.1 Information to the customerThe nature and amount of the payment must be clearly disclosed to the customer, in a way that is accurate and understandable. The information must be provided prior to the provision of the service that the third party is to perform. The information must include a description of the fees that the Investment Firm charges all counterparties participating in the transaction. If these fees vary from client to client, the information must include the highest fees that may be charged. Where relevant, the Investment Firm must also inform the client about fees, commissions and benefits given in connection with the offer of an investment or additional service.
‍3.2.4 Non-professional customersWhen executing orders for non-professional clients, the Investment Firm must provide the clients with a summary of the relevant guidelines, with emphasis on the total costs incurred by the client. The summary shall also include a reference to the most recent information on execution quality that has been published.
‍3.3 Receipt and transmission of ordersWhen receiving and transmitting orders, the Investment Firm shall act honestly, fairly and professionally in order to safeguard the client's best interests when transmitting client orders for execution at other firms.
‍3.3.1 GuidelinesThe Investment Firm shall introduce and implement guidelines for the various classes of instruments. For each class, the Investment Firm shall identify the entities with which the orders are placed or to which the Investment Firm transmits orders for execution. These firms shall have execution arrangements in place to ensure that the Client's best interests are safeguarded when the Investment Firm places orders with or transmits orders to these firms for execution.The company must regularly carry out checks on how the guidelines function and must also check the quality of the performance of the companies identified in the guidelines. Where deficiencies are identified, these must be corrected.The undertaking shall review its policies and arrangements at least annually. This review shall also be undertaken in the event of significant changes to which trading venues or entities are considered trustworthy, with a view to meeting the overall best execution requirement.
‍3.3.2 Information to the customerThe Investment Firm shall provide information to its clients about the guidelines that have been established and provide the client with appropriate information about the Investment Firm and its services, and the entities selected for execution. In selecting other entities to execute client orders, the Investment Firm shall publish annually, for each class of financial instruments, an overview of the five most important entities, measured in terms of trading volumes, to which it has transmitted client orders or with which it has placed client orders for execution in the previous year, as well as information on the quality of execution achieved. The information shall be consistent with the information published in accordance with the regulatory technical standards of ESMA. See these here:https://www.esma.europa.eu/convergence/guidelines-and-technical-standardsIn response to a specific request, the Investment Firm must provide clients and potential clients with information about the firms to which orders are transmitted or placed with for execution.