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Execution Policy

Updated May 2026

This page contains a summary of Northstake's Order Execution Policy. The full policy is provided to clients prior to order execution, and prior consent is obtained from each client before any order is executed.

Best execution

When executing orders for crypto-assets on behalf of clients, Northstake takes all necessary steps to obtain the best possible result, taking into account the execution factors required by Article 78(1) of Regulation (EU) 2023/1114 (MiCA): price, costs, speed of execution and settlement, likelihood of execution and settlement, size, nature, conditions of custody, and any other relevant consideration.

For retail clients, the best possible result is determined primarily by the total consideration — the sum of the price of the crypto-asset and the costs related to execution. Other factors are taken into account only to the extent they contribute to delivering the best total consideration.

How we execute orders

Northstake acts strictly as an agent on behalf of the client. We do not act as a counterparty to client trades and do not use proprietary capital to settle orders.

Client orders are executed on carefully selected regulated execution venues. Our primary execution venue is selected following an assessment of pricing, costs, settlement reliability, regulatory standing, and operational suitability. Where the primary venue cannot deliver the best possible result for a particular order — for example due to an outage, insufficient liquidity, or the availability of a material price improvement elsewhere — Northstake may route the order to a pre-approved secondary venue. When a secondary venue is used, the client is informed in the trade confirmation.

Northstake does not execute client orders outside a trading platform.

Client instructions

Where a client gives a specific instruction in relation to an order — for example, a price limit, a particular venue, or a time-limit period — Northstake will execute the order in accordance with that instruction. Following a specific instruction may prevent Northstake from taking the steps designed to obtain the best possible result in respect of the elements covered by the instruction. Clients are informed of this where appropriate.

Information provided to clients

Before executing an order, the client receives a cost disclosure showing expected proceeds, fees, third-party costs, and the expected net amount, as well as a warning on the irreversibility and settlement finality of the transfer.

After execution, the client receives a trade confirmation containing the venue used, executed price, type and amount of crypto-asset traded, itemised fees and charges, wallet addresses, the on-chain transaction reference, and the value date.

Fees

All fees are disclosed to the client before execution. Fees are distinguished between Northstake's service fee and third-party costs such as network fees ("gas fees") and venue fees. Northstake does not receive any remuneration, discount, or non-monetary benefit in exchange for routing client orders to any execution venue.

Monitoring and review

Northstake monitors the effectiveness of its execution arrangements on an ongoing basis and reviews the order execution policy and venue selection at least annually. Clients with an ongoing relationship are notified of any material changes at least 30 days before they take effect. The current version of this policy is published on this page at all times.

Right to demonstration

A client may at any time request Northstake to demonstrate that an order was executed in accordance with this policy. Northstake will respond within a reasonable period with the relevant supporting information.

Complaints

A client who believes that an order has not been executed in accordance with this policy may submit a complaint in writing to [email protected].

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