Order Execution Policy

One of the services offered by Venga is the execution of orders related to crypto-assets on behalf of clients. This means entering into agreements, on behalf of clients, for the sale and purchase of one or more crypto-assets, or the subscription on behalf of clients for one or more crypto-assets, and includes entering into contracts to sell crypto-assets at the time of their offer to the public or their admission to trading.

At Venga, we are committed to executing your orders related to crypto-assets promptly, fairly, and diligently, and in accordance with the regulatory standards established in the Markets in Crypto-Assets Regulation (MiCA).

This policy explains how we execute clients' asset sale and purchase orders seeking to obtain the best possible result for them, taking into account various factors such as, among others, price, costs, speed, and the likelihood of execution and settlement at execution venues (defined below) external to Venga.

As part of the registration process as a user on the platform, clients are required to read and expressly and separately accept the General Terms and Conditions of Service, the Privacy Policy, the Terms and Conditions for custody, and the Order Execution Policy. Through the consent given to the Order Execution Policy, clients authorize Venga to execute orders on their behalf, in accordance with this policy and the internal procedures for order execution.

The Order Execution Policy applies to all client orders that Venga executes through designated execution venues in relation to crypto-assets. When the Client provides specific instructions for the execution of their orders, Venga may act in accordance with such instructions, although it will expressly and prior to the execution of the order warn the Client that following such instructions may prevent Venga from taking the necessary measures to obtain the best possible result in the execution regarding the elements covered by such instructions.

In the absence of specific instructions from the Client, all orders are executed exclusively in accordance with this Order Execution Policy and the established execution arrangements. Venga retains full discretion to determine how orders are executed in order to achieve the best possible result for the Client, in line with applicable regulatory requirements and always within the framework of this Policy.

To this end, Venga will use its professional judgment and experience to weigh and balance both the Execution Factors and the Execution Criteria in each case, taking into account available market information and established execution arrangements.

The ‘Execution Factors’ that Venga considers to determine quality each time it executes an order are: price, size (understood as the quantity of the crypto-asset subject to the order and its potential impact on liquidity and price), costs, speed, likelihood of execution and settlement, nature (understood as the specific characteristics of the order), custody conditions, among other relevant factors such as market conditions and the volatility of the crypto-asset.

The determination of the relative importance of the aforementioned factors is carried out based on the following ‘Execution Criteria’: the Client criterion (profile and execution objectives), the Order criterion, which refers to its nature, type, and size, the Crypto-asset criterion (i.e., its characteristics such as market situation, liquidity, price, and volatility), and the Execution Venue criterion, understood as compliance with MiCA.

Furthermore, it employs a price tolerance strategy prior to the confirmation of the execution of the purchase and sale order. For this purpose, it utilizes price deviation (slippage) control mechanisms.

The mechanism operates for the benefit of the Client with the objective of protecting them against significant price deviations. When the estimated deviation is favorable to the Client, the order will be executed in any case, transferring the price improvement in full to the Client's balance. When the estimated deviation exceeds the maximum applicable threshold and is unfavorable to the Client, the order will not be executed and will be automatically canceled, informing the Client of the impossibility of executing the transaction under appropriate market conditions.

Venga does not obtain any economic benefit derived from price deviations occurring during order execution.

In order to provide the service, Venga will select the execution venues it considers most appropriate to consistently achieve the best possible results for its clients.

An “execution venue” is defined as any entity that facilitates the execution of orders in crypto-assets, including, but not limited to, trading platforms and other crypto-asset service providers that allow the execution of clients' orders.

Venga continuously monitors the effectiveness of its order execution mechanisms and of this Policy to identify and correct any deficiencies.

Furthermore, it applies robust monitoring and evaluation procedures to assess the quality of execution on a continuous basis, both ex-ante (pre-trade) and ex-post (post-trade).

In the case of execution outside a trading platform, Venga will inform clients in advance about this possibility and about the implications of such execution.

Prior to proceeding to execute client orders outside a trading platform, Venga will require the express consent of the client, either in the form of a general agreement or with respect to individual transactions.

Upon the client's request or when required by law, the client will have access to information corresponding to the execution venue where the order was executed, and that the order was executed in accordance with this Policy.

Venga will also provide the client with information on the costs and charges associated with the execution of the order, including any commissions or charges that Venga or any third party may apply.

Venga guarantees that no misuse of information regarding client orders occurs in the execution process, nor is information regarding client orders disclosed to third parties other than those directly involved in the execution process, unless required by law or with the client's consent.

To this end, Venga applies safeguards to prevent any misuse, manipulation, or leakage of client order information.