Order Execution Policy

Table of Contents

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1. Purpose and scope

1. This policy describes the measures implemented by Fipto PI SAS (“Fipto”) to obtain the best possible result when executing its Customers’ orders, in accordance with the MiCA Regulation. It applies to the service of exchanging crypto-assets for funds used by authorised Customers on Fipto’s Platform.

2. Regulatory framework

2. Fipto complies in particular with Article 78 MiCA (best execution), as well as with all positions or guidelines made public by European or national authorities.

3. Scope of the policy

3. This policy applies to all orders executed by Fipto on behalf of its Customers in the course of its activity as a crypto-asset service provider authorised in France.

4. It covers:

  • purchase, sale or exchange transactions of crypto-assets for funds, or of crypto-assets for other crypto-assets, carried out via the Fipto platform;
  • operations executed through manual conversion (RFQ) where an employee intervenes directly;
  • and, more broadly, any transaction for which Fipto acts in the execution of a Customer order.

5. This policy does not apply to:

  • transactions carried out at the exclusive initiative of the Customer without Fipto’s intervention;
  • investment or payment services provided by partner entities operating under another authorisation (EMI, credit institution).

6. The best-execution principles are applied uniformly to all professional and non-professional Customers, subject to the specific obligations provided for by the applicable regulation.

4. Best execution principle

7. Fipto takes all necessary measures to obtain the best possible result taking into account price and total cost, speed of execution and settlement/delivery, likelihood of execution and settlement, size/impact and the regulated status of the venue/partner.

8. Orders are processed promptly and recorded immediately after execution.

5. Execution factors and hierarchy

9. The hierarchy applied by Fipto places price / total cost first, then speed. The other factors (likelihood of execution/settlement, size/impact, regulated status) are considered in order to optimise the overall result.

10. A documented internal methodology sets out the operational weighting by order type and is subject to periodic reviews.

6. Execution arrangements

11. Two arrangements are offered:

  • Automated conversion (platform): a firm price is displayed for a short period allowing online acceptance; the accepted order is executed and immediately recorded.
  • Manual conversion (RFQ): during business hours, an employee contacts the Customer (recorded call) to verify identity, validate the quote and propose the price. If the Customer confirms, the order becomes final and is executed; the details are logged.

12. Fipto ensures that:

  • orders are processed promptly, in the order of receipt, unless the characteristics of the order or market conditions require different handling in the Customer’s interest;
  • transactions are logged and traced in order to provide proof of their execution and to enable the subsequent verification of best execution.

13. No modification or cancellation of an order is possible after the Customer has accepted the price, save in the case of a manifest error attributable to Fipto or a technical malfunction.

7. Customer’s specific instructions

14. Specific instructions (e.g. time or method constraints) are not admissible in the automated flow. They may be accepted in manual conversion, it being specified that they may prevent the best overall result from being achieved.

15. Records and supporting documents are retained for 5 years.

8. Execution venues

16. Fipto selects and evaluates several execution venues or counterparties in order to guarantee the best possible result for its Customers.

17. The selection is based on a continuous comparative analysis of the following criteria:

  • competitiveness of prices and of the total cost for the Customer,
  • speed and reliability of settlement/delivery,
  • operational security and regulated status of the partner,
  • technical robustness and availability of the execution flow.

18. The allocation of orders across the different execution venues may change over time depending on market conditions, liquidity, and the results of periodic effectiveness controls.

9. Post-execution transparency

19. Fipto makes available to the Customer, as soon as possible, the post-trade information: date/time, order type, execution against own account or identification of the venue, asset, direction (buy/sell), quantity, unit price, fees, total price. This information is accessible in the Customer area.

10. Aggregated orders

20. Fipto may aggregate several orders only where such aggregation does not disadvantage any Customer.

21. If the order is only partially executed, the executed portion is allocated in priority to the Customer.

22. If this proves impossible, Fipto carries out a fair allocation, provided that it can demonstrate that this execution method offered the Customer more favourable conditions than if the order had been executed separately.

11. Absence of inducements and conflicts of interest

23. Fipto does not receive any financial or other inducement for routing orders to a particular provider. Selection and execution take place within the framework of a dedicated conflict-of-interest management policy (prohibition of payment-for-order-flow practices).

12. Retention and archiving

24. Transaction information and order-related data (including, where applicable, specific instructions) are retained in accordance with the provisions laid down by MiCA.

13. Controls, review and governance

25. Fipto monitors regularly, or whenever circumstances so require, the effectiveness of its execution arrangements, in particular in the event of a change in its activity, a regulatory change or any event affecting the ability of execution venues to deliver the best result.

14. Customer consent

26. Before any first use of Fipto’s services, the Customer reviews this execution policy and consents to its application.

27. This consent is obtained:

  • either by electronic acceptance when creating the account on the Fipto platform;
  • or by signing a framework agreement or a specific mandate, where the contractual relationship so provides.

28. Any substantial modification of the policy is notified to the Customer at least 15 days before it comes into force.

15. Publication of information

29. Where applicable, Fipto publishes on its website aggregated information relating to execution quality (prices/volumes).

16. Updates — notice

30. The policy is published on Fipto’s website and notified at least 15 days before any substantial modification, specifying the nature of the change, its date of application and the link to the new version. Use of the services constitutes acceptance of the policy in force.