This Best Execution Policy (the "Policy") outlines the principles adopted by Penguin Securities Pte. Ltd. (the "Company") to ensure that client orders are executed in a manner that consistently delivers the best possible result. The Policy is designed to comply with the requirements set forth by the Monetary Authority of Singapore (“MAS”) and to uphold transparency and fairness in trade execution.

This Policy applies to all transactions executed by the Company, specifically transactions associated to Securities, Collective Investment Schemes, Listed Derivatives Contracts, OTC Derivatives Contracts as defined in the Securities and Futures Act 2001(“SFA”) of Singapore and offered by PSPL within its licensing scope under SFA.

When executing client orders, the Company considers multiple factors to ensure the best possible outcome:

• Price: Striving to obtain the most favourable price available.
• Cost: Considering all transaction-related fees and spreads.
• Speed: Ensuring timely execution in liquid markets.
• Likelihood of Execution and Settlement: Ensuring trade completion and reliability.
• Market Impact: Minimising potential adverse effects on the market when executing large trades.

The relative importance of these factors may vary depending on market conditions, client instructions, and the nature of the financial instrument being traded.

The Company may use the following execution methods depending on market conditions and the nature of the order:

• Exchange Execution: Orders are sent to recognised exchanges with sufficient liquidity.
• Over-the-Counter (OTC) Execution: Orders are executed directly with counterparties.
• Liquidity Provider Execution: Prices from multiple liquidity providers are evaluated to ensure optimal execution.

If a client provides specific instructions regarding the execution of an order, the Company will adhere to those instructions. However, clients should note that such instructions may prevent the Company from achieving the best execution result as defined under this Policy.

The Company will regularly monitor the effectiveness of this Policy to ensure best execution standards are met. A periodic review will be conducted to account for changes in market conditions and regulatory requirements.

Key elements of the monitoring process include:

• Reviewing execution quality across different execution venues.
• Assessing the effectiveness of liquidity providers.
• Evaluating client order handling and outcomes.

The Company provides clients with a summary of this Policy and, upon request, can offer further details on execution practices. The Company also maintains proper records of order execution in compliance with MAS regulations.

To enhance transparency, the Company may publish periodic reports on its execution performance, where required by regulatory standards.

While the Company aims to provide best execution at all times, market conditions, liquidity constraints, and technological factors may affect execution quality. Clients acknowledge and agree that the Company will act in good faith to achieve the best possible execution based on prevailing conditions.

This Policy will be reviewed at least annually or whenever there are significant regulatory or operational changes. Any amendments will be approved by senior management and communicated to relevant stakeholders.

Clients can contact us to find out additional information about our Best Execution Policy.