Table of Contents

• 1.
  Introduction
• 2.
  Scope
• 3.
  Regulations
• 4.
  Providing Best Execution
• 4.1
  Execution Factors
• 4.2
  Execution Criteria
• 4.3
  Order Handling
• 4.4
  Order Instructions
• 4.4.1
  Order Instructions Where Best Execution Has Limited Scope
• 4.5
  Restrictions
• 4.6
  Affiliates and Connected Parties
• 4.7
  Execution Costs
• 4.8
  Inducements
• 5.
  Execution Venues And Brokers
• 6.
  Monitoring And Review
• 7.
  Record Keeping
• Appendix 1

1. Introduction

• This policy sets out the standards that Webull Securities (Singapore) Pte. Ltd. (the ‘Company’) must adhere to in respect of best execution and order handling for customers, where applicable. The Company has a fiduciary duty to take all sufficient or reasonable steps to obtain the best possible result for all customers when executing orders or transmitting orders to a third-party broker or affiliate on their behalf in respect of investment products. Best execution does not guarantee that the best price will be achieved but ensures that the Company acts in the best interests of all customers.

2. Scope

• This policy applies to the Company, without a distinction on the customers’ residency, and regardless of where the transaction is executed.
• This policy applies to the following investment services:
• (i)
  placing and/or executing orders on behalf of customers; and
• (ii)
  receiving and transmitting customers’ orders to a third-party broker or affiliate for execution.
• The Company has determined that best execution is owed when we accept an order to place and/or execute a transaction on behalf of a customer. The Company will place and/or execute an order in accordance with this policy upon acceptance of a customer’s order. If there is a specific customer instruction, the Company will place and/or execute the order following such specific instruction.

3. Regulations

• The governing regulations are the ‘Notice on Execution of Customers’ Orders’ (SFA04-N16) and the ‘Guidelines on Execution of Customers’ Orders’ (SFA04-G10), issued by the Monetary Authority of Singapore.
• Whilst the regulations do not subject the Company to the Best Execution requirements when dealing with institutional investors (as defined in the Securities and Futures Act 2001, of Singapore), the Company shall at its utmost best, apply the same principles when dealing with them.

4. Providing Best Execution

• 4.1
  Execution Factors
• The Company takes into consideration a range of execution factors when determining how to obtain the best possible result for the customer. Some of the below factors are considered to be more important than others; however, there are situations where the relative importance of these factors may change in accordance with customer’s instructions or broader market conditions.
• The execution factors that the Company considers includes but are not limited to:
• (i)
  Price – this is the price an investment product is traded at.
• (ii)
  Cost – this includes all fees and cost related to order execution.
• (iii)
  Speed – this is the time it takes to execute a transaction.
• (iv)
  Size – this is the size of the transaction.
• (v)
  Likelihood of execution and settlement – this is the likelihood that the company would be able to complete the transaction and that the transaction will settle.
• (vi)
  Nature of the order and any other consideration relevant to the execution of the order – (e.g., particular characteristics of customer’s order which can affect how best execution is achieved).
• In determining the relative importance of each execution factor, the Company will take into account the following considerations:
• (i)
  Types of customers (e.g., retail/accredited/institutional investor);
• (ii)
  Types of capital market products’ order for which the Company accepts, places or executes;
• (iii)
  Characteristics of the execution venues or brokers to which the order can be directed; and
• (iv)
  Characteristics of the orders (including any specific instructions received).
• 4.2
  Execution Criteria
• The Company considers that the most important execution factor is the price at which the transaction of the investment product is executed. However, there may be circumstances where the primary execution factors may vary and price is no longer the dominant execution factor.
• 4.3
  Order Handling
• The following shall apply:
• (i)
  Customers’ orders are executed promptly and accurately recorded and allocated.
• (ii)
  Comparable Customers’ orders are executed sequentially in accordance with the time of receipt of such orders unless the characteristics of the order or prevailing market conditions make this impractical or the interests of the customer require otherwise.
• (iii)
  The Company will, on a best effort basis, inform customers about any material difficulties relevant to carrying out of orders promptly upon becoming aware of any difficulty.
• (iv)
  Where the Company is responsible for overseeing or arranging the settlement of an executed order, it shall take all reasonable steps to ensure that the investment products or monies received for settlement are promptly and correctly delivered to the account of the customer.
• (v)
  Only dealing team personnel are granted access to the trade desk and customer order and execution data. However, customer order and execution data may be made available to the Company’s Compliance, Risk, Legal, Operations and IT personnel.
• (vi)
  The Company may disclose books, records, and other documentation, including order and trade information to third parties in certain circumstances, to the extent permissible by law.
• 4.4
  Order Instructions
• Execution Of Customer Orders
• The Company uses an automated system to route and execute customer orders. Depending on the market, customer orders are either directly routed to an execution venue or to our third-party broker or affiliate. Third- party broker or affiliate may in turn route the orders to other market maker firms, venues, or exchanges.
• Executing Transactions For Related Persons
• Employees instructions for their personal trade follows the personal trading policy of the Company. Please refer to the policy for more information. For employee accounts opened with the Company, approved orders shall be executed sequentially in accordance with the time of receipt of such orders similar to the execution of Customer orders.
• 4.4.1
  Order Instructions Where Best Execution Has Limited Scope
• Forced Liquidation
• Forced liquidation can occur as a result of failing to meet a margin call, which arises when the value of the securities falls below a predetermined level that has been communicated to customers. In such circumstances, the Company will follow the terms and conditions to liquidate and offset the debt owed by the customer. Please refer to the procedures for handling margin call and forced liquidation for more information.
• Specific Order Instructions
• Customers may provide the Company with specific instructions in relation to an order. The Company will follow that instruction so far as it is reasonably possible when executing the trade. By following customer’s specific instruction, the Company would have satisfied the obligation to provide the customer with best execution in relation to that transaction.
• However, where the customer has given a specific instruction that covers only one part or element of an order, the Company will still owe the customer best execution in relation to the rest of the order (i.e. the part not covered by the specific instruction).
• Aggregation and Allocation
• The Company will not aggregate proprietary orders (including those of its employees) with that of customers. However, under certain scenarios and for certain product types (e.g., mutual funds), the Company may aggregate all customers’ orders (including proprietary and employee’s orders). When aggregated:
• (i)
  it is unlikely that the aggregation of orders and transactions will work overall to the disadvantage or detriment of any customer whose order is to be aggregated;
• (ii)
  the Company will disclose to each customer whose order is to be aggregated that the effect of aggregation may work to its disadvantage in relation to the particular order;
• (iii)
  aggregated orders and transactions are fairly allocated.
• Mutual fund shares will be allocated to all customers within the aggregated order based on a pro-rata basis. If this results in a rounding, the rounding will be allocated pro-rata to all customers. If this rounding allocation results in an over allocation, the over allocation will be removed from the customer that has been given the highest allocation. If there is an under allocation, the allocation will be given to the customer that has received the lowest allocation of the rounding. For all orders of the same value, the over allocation will be removed and the under allocation will be allocated on a random basis.
• Equities will be allocated pro-rata to each customer. If there are excess shares, they will be allocated to the highest order values in turn. Where there are orders for the same value, allocation will be made to the first order that was created for that particular aggregated order out of the orders with the same order value.
• 4.5
  Restrictions
• Where the Company is subject to internal trading restrictions, it may not be possible to accept certain orders. Such investment products will be removed from the platform in a timely manner. However, due to timing differences, the product may be removed only after the customer order has been accepted by the platform. Such customers will be notified of this fact as soon as the Company becomes aware of the removal of the investment product.
• 4.6
  Affiliates And Connected Parties
• The Company may use a connected party to execute an order only if it is in the best interests of the customer to do so and that any conflicts of interest are managed appropriately.
• 4.7
  Execution Costs
• When providing services to customers, the Company may charge customers a fee, commission, mark up or spread in the execution price, which would have been disclosed to the customers beforehand.
• 4.8
  Inducements
• The Company will not receive any monetary or non-monetary benefits from third parties which are not in compliance with the applicable laws and internal policies.

5. Execution Venues And Brokers

• The Company has an obligation to provide best execution for its customers’ orders. This includes the selection of execution venues or brokers. The Company will consider the respective merits of each venue or broker and document the basis of the selection.
• The Company will have execution arrangements with selected execution venues or brokers to ensure compliance with this Policy and its obligations in relation to best execution.
• A list of execution venues and brokers used by the Company can be found in Appendix 1.

6. Monitoring And Review

• The Company will monitor compliance with, and the effectiveness of its execution arrangements under this policy (including whether such execution arrangements have delivered the best available terms to customers on a consistent basis), and where appropriate, correct any deficiencies.
• The Company will review this policy at least annually or whenever a material change occurs that affects the company’s ability to obtain the best possible result for the execution of customer orders on a consistent basis using the execution venues and brokers included in the appendix of this policy. Any revisions to this policy will be made available on the Company’s website and will be in force as from publication.

7. Record Keeping

• Reception, transmission, and execution of orders, which will or may result in trade will be stored in the backend platform in accordance with applicable regulations.

Appendix 1

Execution Venues

Execution Brokers