Policy Document

Trade Execution Policy

How Payhound conducts its trades

Updated: June 2026

As part of our Best Execution Policy, Payhound is required to take all reasonable steps to obtain the best possible results for its clients when executing orders, considering, among others, the following best execution factors:

  • The crypto asset price;
  • Cost of transaction;
  • Speed of execution;
  • Size of trade;
  • Conditions of custody of the crypto;
  • Likelihood of execution and settlement;
  • Speed of execution and settlement;
  • Nature of the order;
  • Liquidity;
  • Outstanding settlements; and
  • Any other considerations specific to the order.

When executing orders, Payhound is required to check the fairness of the price proposed to the client by gathering market data used in the estimation of the price of such crypto asset and, where possible, by comparing with similar or comparable crypto assets.

Where client orders are executed outside our trading platform, Payhound shall inform the client about that possibility and shall obtain express consent of the clients before proceeding to execute their orders outside the trading platform, either in the form of a general agreement or with respect to individual transactions.

Selection of execution venues

In choosing execution venues, Payhound shall ensure that the venue or entity it selects will enable it to obtain results for its clients that are at least as good as the results that it reasonably could expect from using alternative entities. In making this choice, Payhound will consider, among other factors, the following parameters:

  • Reputation;
  • Regulatory and legal status;
  • Market intelligence;
  • Product and service offering;
  • Technical and technological capabilities;
  • Depth and spread-efficiency; and
  • Availability of services.

In addition, Payhound shall not be permitted to receive any remuneration, discount or non-monetary benefit for routing client orders to a particular trading venue or execution venue which would be in breach of the requirements on conflicts of interest or inducements set out in the Law or in the MiCA Rulebook.

Specific client instructions

When specific instructions are provided by the client relating to a specific trade, the order execution will be carried out in accordance with the client’s instructions. The client acknowledges and accepts that carrying out orders according to the specific instructions given (such as liquidating assets at a particular time on a specific exchange) might not result in the best possible result for the order execution and could preclude Payhound from carrying out one or more of the steps required to enable best execution. For this purpose, Payhound shall be deemed to have taken all reasonable steps to obtain the best possible result for a client to the extent that it executes an order, or a specific aspect of the order, following specific instructions from a client relating to the order, or to the specific aspect of the order.

General terms of order handling

Payhound shall execute client orders in a prompt, fair and expeditious manner unless:

  • Instructed otherwise by the client;
  • Market conditions make this impracticable; or
  • Client expectations cannot be reasonably achieved.

Specifically, the Company shall satisfy the following conditions when carrying out client orders:

  • Ensures that orders executed on behalf of clients are promptly and accurately recorded and allocated;
  • Carries out otherwise comparable client orders sequentially and promptly unless the characteristics of the order or prevailing market conditions make this impracticable.

Payhound reserves the right to decline any order or transaction, at any time, in our sole discretion. We further reserve the right to cancel, modify, suspend or discontinue, temporarily or permanently at any time in its sole discretion any existing order and/or the ability to place any orders including without limitation, limit orders such as buy limit and/or sell limit, either generally or with respect to a specific instrument or with respect to a specific direction of a specific instrument.

Under no circumstances shall any obligation to the client under our Best Execution Policy amount to a condition of any transaction, and failure to comply with this Best Execution Policy which is not attributable to fraud, willful default or gross negligence on behalf of Payhound shall not entitle the client to cancel, terminate or rescind any transaction.

Security and confidentiality

Payhound acknowledges that confidentiality of client information, including information on a client’s intended or desired order, is an important factor in ensuring that client orders are executed in the client’s best interests and, further, that such information is not misused by Payhound employees, whether for their own gain or benefit, or for the gain or benefit of others. All reasonable steps are taken to ensure that client information is kept secure and confidential and to ensure that the misuse of information is prevented. Towards this end, access to information related to the client’s trade orders is limited and made available to responsible persons, on a strictly ‘need to know’ basis.

Keeping our customers updated

Payhound will review its order execution arrangements regularly and will inform its clients with whom it has an ongoing client relationship of any material change to its Best Execution Policy or its order execution arrangements.