1. INTRODUCTION

• 1.1 We are Wealthyhood Europe AEPEY, an investment services company incorporated under the laws of Greece (business registry number 178577960000) with its registered address at Solonos 60, 10672, Athens, Greece (“we”, “us”, “our” or “Wealthyhood”).
• 1.2 Wealthyhood is authorised and regulated by the Hellenic Capital Markets Commission (HCMC) as an investment firm (“AEPEY” or “Investment Services SA”) under activity licence number 3/1014.
• 1.3 This Policy describes the arrangements we have in place to comply with our obligations under applicable law, including MiFID II, to take all sufficient steps to obtain the best possible result for our clients when executing or transmitting orders. Client consent to this Policy and to the execution arrangements described herein does not limit or waive Wealthyhood’s regulatory obligations to act honestly, fairly, and professionally in the best interests of its clients.
• 1.4 The "execution of orders on behalf of clients" refers to Wealthyhood acting to complete agreements to buy or sell financial instruments for our clients. The "reception and transmission of orders" involves receiving a client order and forwarding it to a third-party broker for execution or further transmission. For the purposes of this Policy, the term "execution of orders" includes the service of "reception and transmission of orders", unless otherwise specified.
• 1.5 The purpose of this Policy is to explain how we execute or transmit your orders for financial instruments to a third-party broker and when we are required to ensure the best possible outcome for our clients.
• 1.6 Best execution requires taking all appropriate measures to secure the most favourable result when executing client orders or transmitting them to another entity for execution. In this process, Wealthyhood evaluates various execution factors and determines their relative importance based on the nature of our clients, the financial instruments, and the markets in which we operate.
• 1.7 In every case, Wealthyhood is committed to providing services that are honest, fair, and professional, consistently prioritising the best interests of our clients when delivering investment services.

2. ORDER HANDLING

• 2.1 We have implemented procedures and arrangements to ensure that orders are processed swiftly, fairly, and efficiently. Market Orders placed through the Wealthyhood platform and app are immediately sent for execution unless the size or nature of the order prevents this or if explicitly stated otherwise. Limit Orders are instead held and only sent for execution once their specified Limit Price (or a better price) is reached, as described below.
• 2.2 For certain instruments, orders may be grouped and executed at specific times during the day. Individual client orders are executed in line with our best execution standards and are allocated directly to that client. Similar orders are processed in the order they are received and executed promptly unless the nature of the order or prevailing market conditions make this impractical or if it is in the client’s best interest to handle it differently.
• 2.3 In the case of aggregated orders, we take all reasonable steps to ensure that your interests are protected during the process. Only orders executed at specific times of the day will be pooled by Wealthyhood.
• 2.4 When you place a Market Order, we will provide you with indicative prices for the instruments you wish to buy or sell through the Wealthyhood platform and/or app. These prices are provided by third parties and are beyond our control. Due to market fluctuations, the final execution price may differ from the price shown at the time you place your order. This means that your Market Order may be executed at a price higher or lower than the quoted price. While market movements may result in execution at a price that is more or less favourable than the indicative price displayed, Wealthyhood will take all sufficient steps to obtain the best possible result for clients in accordance with this Policy and applicable regulatory requirements. For Limit Orders, the indicative price shown when you place the order does not determine your execution price. Instead, your order will only execute at your specified Limit Price or better, once that price is reached. Where you place a buy order by number of shares, the amount displayed to you is an estimate of the total cost: the number of shares is fixed by your instruction and the total cost is determined on execution, as described in clause 2.8.
• 2.5 For Market Orders, you may only cancel an order with us before it has been forwarded to a trading venue, third-party broker, or partner in cases where the instrument is not tradeable. If cancelling your order is still available, you will be able to cancel your order through the Wealthyhood platform and/or app, but due to the fast pace of execution, we cannot guarantee that the cancellation will be processed before the order is completed. Once a Market Order has been transmitted to a trading venue or third-party broker, cancellation may no longer be possible due to execution speed and market conditions. For Limit Orders, you may request to cancel your order at any time before it has executed, directly through the Wealthyhood platform and/or app. This is because a Limit Order can remain open for up to its Expiry Date (a maximum of 30 calendar days) while it waits for your Limit Price to be reached, and is only forwarded to a trading venue or third-party broker once that condition is met. As with Market Orders, we cannot guarantee that a cancellation request will be processed before the order executes.
• 2.6 Additional restrictions may occasionally apply to order submissions due to regulatory requirements or market conditions. These could include, but are not limited to:
  • 2.6.1 Trading restrictions imposed by regulators on certain instruments;
  • 2.6.2 Restrictions placed on Wealthyhood by regulatory bodies; or
  • 2.6.3 Restrictions set by trading venues or third-party brokers impacting Wealthyhood’s ability to submit orders.
• 2.7 Limit Orders
  • 2.7.1 In addition to Market Orders, Wealthyhood offers Limit Orders for individual Buy and Sell Orders. A Limit Order lets you set a Limit Price at which you're willing to buy or sell, and an Expiry Date of up to 30 calendar days.
  • 2.7.2 A Limit Order is only sent for execution once the market reaches your Limit Price or a better price. A Buy Limit Order will only execute at your Limit Price or lower; a Sell Limit Order will only execute at your Limit Price or higher. If your Limit Price is not reached before the Expiry Date, the order will expire without executing.
  • 2.7.3 Limit Orders are executed on an all-or-nothing basis; Wealthyhood does not currently support partial fills of Limit Orders.
  • 2.7.4 Limit Orders are currently available only for individual Buy and Sell Orders. They are not available for Portfolio Buy Orders, Repeating Investments, or Portfolio Rebalancing, which continue to be placed and executed as Market Orders.
• 2.8 Orders placed by number of shares
  • 2.8.1 For buy orders in individual instruments, you may instruct us either by the cash amount you wish to invest or by the number of shares (including fractional amounts) you wish to buy. This applies to both Market Orders and Limit Orders. Sell orders continue to be placed by number of shares.
  • 2.8.2 Where you place a Market Order to buy by number of shares, we reserve an amount of cash in your account that is higher than the estimated cost of the order, to allow for price movement and, where applicable, currency conversion between placement and execution. The same reservation applies to every such order, irrespective of the execution method applied to it and of whether the market is open at the time you place it. Where you place a Buy Limit Order, we instead reserve the estimated maximum cost of the order, based on your Limit Price and the cash value or number of shares you have specified. In both cases the amount reserved also includes an estimate of any fees payable in respect of the order, if applicable.
  • 2.8.3 The reserved amount is disclosed to you before you confirm the order and cannot be withdrawn or used for other orders while the order remains pending.
  • 2.8.4 The reserved amount is not a limit on the cost of the order. Where the total cost at the time of execution is higher than the amount reserved, the order will still be executed provided the available cash in your account covers that cost. Where the available cash in your account does not cover the total cost at the time of execution, the order will not be executed and will be rejected, and the reserved amount is released back to your available balance. Where the order is executed, only the amount actually payable, including any fees actually charged, is taken and the remainder of the reserved amount is released. This does not affect our obligation to take all sufficient steps to obtain the best possible result for orders that are executed.

3. ORDER EXECUTION

• 3.1 Wealthyhood receives and, where relevant, forwards orders placed via the Wealthyhood platform and/or app. These orders are either executed directly or transmitted to a third-party broker for execution, as outlined below:
  • 3.1.1 Execution on Trading Venues: Wealthyhood may execute orders directly on one or more trading venues. If we are not a direct member of a specific trading venue, we may facilitate trades indirectly through a third-party investment firm, such as a broker.
  • 3.1.2 Execution via Third-Party Broker: In cases where Wealthyhood is not a member of the trading venue where the instruments are listed and we do not have direct access via a broker, we will engage a third-party broker to execute the order. This broker may, in turn, pass the order to another broker or execute the transaction outside of a trading venue. By agreeing to Wealthyhood's Terms & Conditions and this Policy, you grant explicit consent for orders to be executed outside of EU trading venues (for execution on US venues) and, in some cases, outside of any trading venue (for fractional instrument transactions). When transmitting customer orders, we ensure that the third-party broker seeks the best possible execution.
• 3.2 In the unlikely event of disruptions at trading venues, third-party brokers, or Wealthyhood’s own systems, such as outages or technical issues, executing orders as described in this Policy may not be feasible. In such cases, Wealthyhood will take all reasonable steps to secure the best possible outcome for the customer under the given circumstances.

4. BEST EXECUTION FACTORS

• 4.1 In our dedication to ensuring the best execution for our clients, we evaluate a range of execution factors and assess their importance based on the specific circumstances. The factors we take into account include:
  • (a) Price: The price at which the instrument is executed.
  • (b) Costs: This covers both implicit costs, such as the potential impact on the market, and explicit external costs like exchange or clearing fees.
  • (c) Speed: The time it takes to execute an order.
  • (d) Likelihood of execution and settlement: The chances of successfully completing the order.
  • (e) Size: The quantity of the order, particularly how the size might affect the execution price.
  • (f) Nature of the transaction and other relevant considerations: Specific characteristics of a customer’s order that might influence how the transaction is executed and its impact on the market.
• 4.2 For the majority of our clients, the optimal outcome is usually determined by the total consideration, which includes both the price of the instrument and the costs associated with execution. While price and cost are often the most crucial factors for retail clients, other aspects may take priority if they contribute to achieving the best overall result in terms of total consideration.

5. THIRD-PARTY BROKERS

• 5.1 In instances where we do not have direct access to the trading venue where the Instruments are traded, we use a third-party broker for execution. The third-party broker is obligated to fulfil the best execution requirements and is mandated to disclose information about its execution practices and the venues it selects for executing transactions.
• 5.2 The third-party broker maintains systems to ensure that it can provide best execution for Customers or offer price benefits in scenarios where the third-party broker acts both as agent and principal to complete an Order.
• 5.3 By transmitting an Order to the third-party broker following a client's specific instruction, Wealthyhood is considered to have provided best execution as delineated in this Policy.
• 5.4 We conduct an annual review of our third-party brokers to ensure they continue to provide a high standard of execution. When evaluating third-party brokers, Wealthyhood carefully considers whether they can consistently deliver the best possible outcomes for our clients. This evaluation involves determining whether the broker:
  • 5.4.1 Adheres to best execution standards or agrees to follow them;
  • 5.4.2 Can demonstrate high-quality execution for the orders we place or forward to them; and
  • 5.4.3 Possesses the necessary expertise regarding the instruments to provide execution outcomes that are at least as favourable as those achievable through the transmission of orders to an alternative third-party broker.
• 5.5 Wealthyhood routinely assesses the market landscape to evaluate whether alternative third-party brokers could be utilised in place of the current provider.
  • 5.5.1 These evaluations are conducted annually or as needed, especially when significant changes arise that could impact Wealthyhood’s ability to consistently deliver the best possible execution of orders using the third-party broker.
  • 5.5.2 In addition, Wealthyhood continuously monitors the execution quality provided by the third-party broker, taking into consideration the execution factors detailed above.
  • 5.5.3 The relative importance of these factors may shift based on changing market conditions, such as times of low liquidity.

6. EXECUTION VENUES

• 6.1 When executing orders directly or through a third-party broker, we take all reasonable steps to review the execution venues selected. We expect client orders in financial instruments to be executed using one of the following types of execution venues:
  • (a) Regulated markets
  • (b) Multilateral trading facilities
• 6.2 We evaluate these execution venues based on their capacity to enable us or the third-party broker to achieve the best execution for our clients, taking into account execution factors and other relevant considerations.
• 6.3 The performance of these venues is assessed by looking at the overall value they provide in relation to these factors. The following factors are among the most important considerations when assessing execution venues, although the list is not exhaustive:
  • (a) Market share of the venue
  • (b) Likelihood of execution and settlement
  • (c) Cost of execution
  • (d) Speed of order transmission (latency)
  • (e) Venue features, including coverage across multiple listed instruments

7. POLICY REVIEW

• 7.1 We conduct annual reviews and ongoing monitoring of the effectiveness of our order handling and best execution arrangements, as well as the quality of execution obtained and the suitability of our execution arrangements as outlined in this Policy. The purpose of these reviews is to:
  • 7.1.1 Identify and implement any necessary amendments to this Policy;
  • 7.1.2 Ensure the Policy remains fit for purpose; and
  • 7.1.3 Ensure the Policy reflects any changes to applicable laws.
• 7.2 In addition to periodic reviews, Wealthyhood will review its execution arrangements without undue delay where a material change occurs that could affect its ability to obtain the best possible result for clients, including changes in market structure, third-party brokers, execution venues, or execution quality.
• 7.3 We shall notify you of material changes to this Policy in accordance with the process described in our Terms of Service.

8. CONFLICTS OF INTEREST

• 8.1 We ensure that our fee structure is designed to be impartial and does not create any preference for, or incentivise the use of, particular third-party brokers. In compliance with MiFID II regulations, Wealthyhood does not accept third-party payments, commissions, or non-monetary benefits that would violate these rules and will inform customers of any inducements received from execution venues in line with applicable law.
• 8.2 For additional information, please refer to the Conflicts of Interest Policy available on our Website at wealthyhood.com.

9. NO ADVICE

• 9.1 While we are committed to providing best execution in line with regulatory requirements, this should not be interpreted as creating any fiduciary responsibilities beyond those obligations or any other agreements explicitly made between Wealthyhood and the client.
• 9.2 You remain fully responsible for your own investment decisions, and Wealthyhood will not be held accountable for any trading losses that customers may experience as a consequence of those decisions.

10. CONTACT US

• 10.1 If you need to get in touch with Wealthyhood for any reason, our team is available via email at hello@wealthyhood.com.