Best Execution Policy

1. RFC shall take all reasonable steps to obtain, when executing orders, the best possible result for its Clients taking into account price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of the order. Nevertheless, whenever there is a specific instruction from clients, RFC shall execute the order following the specific

2. RFC is a member of the Malta Stock Exchange. Hence, RFC will execute all orders from clients for all securities listed on the Malta Stock Exchange (in respect of each class of instruments). When the order is in respect of securities which are not listed on the Malta Stock Exchange, RFC will execute the order on one of the execution venues listed in Section M through a third party/parties with whom RFC has executed an agreement regarding the receipt and transmission of orders.

3. With respect to securities listed on the Malta Stock Exchange, the price at which an order is executed shall be determined by the then current price on the Malta Stock Exchange. With respect to all classes of instruments not listed on the Malta Stock Exchange, RFC shall obtain, or ensure that the third party/parties with whom an agreement is in place, obtains to the extent that it is possible to do so – the best price available – taking account of all relevant circumstances. For this purpose, the third party / parties with whom RFC has an agreement in place is/are also subject to best execution requirements and as such RFC places a degree of reliance on this third party/parties in order to comply with such requirements. Any specific instructions from a client may prevent RFC from taking the steps that it has designed and implemented in its execution policy to obtain the best possible result for the execution of those orders.

4. Where the Client’s instructions cannot be executed on the Regulated Market where the security is listed, RFC may satisfy the Client’s demands by selling/purchasing securities held on RFC’s own account.

5. Owing to systems failures or other unavoidable reasons, RFC may execute orders in a method that differs from the method selected pursuant to the Best Execution Policy. However, even in such circumstances, RFC endeavours to execute orders on the best terms available at that point.

6. RFC shall notify clients of any material changes to this policy by posting an updated version of this policy on its website. The policy shall be reviewed annually and special care will be taken to ensure that the entities commissioned by RFC to execute its orders for instruments not listed on the Malta Stock Exchange are indeed effective in their Best Execution efforts.

7. By continuing to use RFC’s services, Clients shall be deemed to have consented to the contents of the Best Execution Policy which is in force at the moment that the instructions are received by RFC.