Order Execution Policy

At Venga, we are committed to handling your crypto-asset orders with transparency, care, and in line with the regulatory standards set out in the Markets in Crypto-Assets Regulation (MiCA), specifically Article 80, as well as other applicable laws and industry standards. This policy explains how we receive and forward client orders for execution, ensuring your instructions are processed efficiently and in your best interest.

The reception and transmission of orders refers to the process of receiving a client instruction to buy, sell, or subscribe to one or more crypto-assets, and forwarding that instruction to an external execution partner for processing. This applies whenever a user places an order through the Company’s platform that is sent to a third-party for execution.

By accepting the Company’s Terms and Conditions, clients authorize the Company to receive and transmit their orders in line with this policy. The latest version is made available on the Company’s website, and clients are notified of any material changes that may affect how orders are handled.

Orders placed on the platform are transmitted to a trusted third-party service provider for execution. The Company selects these providers based on multiple criteria to ensure the best possible outcome for Clients, including:

• Price: The provider’s market quote is used, with a clearly disclosed fixed spread to ensure transparent and consistent pricing.
• Costs: All related costs are assessed, including third-party fees, blockchain/network charges, and platform fees. No hidden commissions or undisclosed payments are applied.
• Speed: Order processing and confirmation times are regularly evaluated.
• Likelihood of Execution and Settlement: The probability of successful execution and asset delivery is taken into account.
• Order Size and Nature: The potential impact on pricing or liquidity, along with the order type (e.g., buy, sell, recurring), is considered.
• Other Factors: Market volatility, operational risks, and technical conditions are reviewed continuously.

Orders are processed fairly and promptly, in the sequence received and without preference based on size, frequency, or client profile. Each order is recorded and tracked to ensure proper execution.

The execution provider’s performance is routinely monitored—covering price accuracy, speed, and reliability—to ensure ongoing compliance with the Company’s standards. If specific client instructions are provided for handling an order, they will be followed when legally and technically feasible. However, doing so may limit the application of the broader execution strategy described in this Policy.

The Company does not receive payments, discounts, or inducements for routing orders to any provider. Upon request, or where required by law, Clients will be informed of the identity of the execution provider and receive a breakdown of associated costs.

While orders are generally executed through regulated trading platforms, there may be situations requiring execution outside such platforms (e.g., via over-the- counter providers).

In such cases, the situation will be clearly explained and explicit permission will be obtained from the user before proceeding. Additional risks, such as settlement or counterparty risk, will also be outlined in advance.

The Company treats all order-related information as strictly confidential. Internal safeguards are in place to prevent unauthorized access, misuse, or disclosure. Personnel are bound by strict internal policies and are prohibited from using client data for personal gain or disclosing it without legal basis or explicit client consent.

No incentives, payments, or discounts are accepted in exchange for routing client orders. All routing decisions are made solely in the interest of the client.

Any breach, unauthorized access, or misuse of order information may result in disciplinary measures, including possible reporting to the appropriate regulatory authorities.

This Policy is reviewed regularly to ensure it remains compliant with applicable regulations and accurately reflects the Company’s order handling practices. Any material changes—especially those affecting client rights or order execution—will be clearly communicated to users in a timely manner.

For questions about this Policy or how your orders are processed, you can contact our support team or refer to the full version of this Policy available on our website.