POLICY FOR THE EXECUTION OF CLIENTS’ ORDERS

of Deltastock AD

General Terms

1.1. The current POLICY FOR EXECUTION OF CLIENTS ORDERS of Deltastock AD (referred for brevity as the Company) is created in accordance with the requirements of Art. 30, Para 2, of the Markets in Financial Instruments Act and Ordinance № 38 regarding the requirements for the activities of investment intermediaries and has the purpose of ensuring high quality of execution of orders to the clients accounts of the investment intermediary and maintaining of the completeness and effectiveness of the financial system.

1.2. The Policy for execution is applied to all types of orders submitted by the clients to the Company for purchase, sale or exchange of securities or other financial instruments according to Article 3 of the Markets in Financial Instruments Act.

1.3. Transactions with financial instruments are executed according to the rules and requirements applicable respectively to the place of execution as well as according to the applicable for the respective place and financial instruments legislation.

1.4. Deltastock AD may not execute orders to the accounts of clients if they have not given their prior consent to the implemented Policy for the execution of clients’ orders /Policy/.

1.5. The current Policy is based on the principle that when performing investment services and activities to the account of the client, Deltastock AD will operate fairly, justly and as a professional in accordance with the best interests of its clients, and that Deltastock AD will execute immediately, fairly and accurately the received clients’ orders, following the order of identical orders receipt.

1.6. Deltastock AD treats its clients equally.

1.7. Deltastock AD  executes transactions with financial instruments to the account of the clients at the best conditions and strives to achieve the best execution according to the clients’ order.

1.8. In keeping the obligation for achieving the best result for the client Deltastock AD executes immediately, when possible, the orders of its clients, except if that would be clearly against the clients’ best interest.

1.9. The company executes the clients’ orders, by complying with the specific parameters, listed in the client’s order. The company will always execute the client’s order in strict compliance with the specific instructions of the client, given in the order or in some other way. In some cases, the parameters of the individual order may not allow the Company to implement the current Policy and execute a trade, which does not correspond to the requirement for best execution of a trade with financial instruments listed in the Policy.

All special instructions by the client negate the terms of this Policy, for which the client is considered informed by accepting the current Policy and signing a contract with the Company. When executing orders according to the specific instructions by the clients, the parties accept and unconditionally agree, that the Company has fulfilled its obligation to achieve the best result. The company is not responsible, if, accurately and in good faith, it has executed the client’s order, following the given by the client parameters of the transaction. The risk and the consequences from the execution of such orders are completely at the expense and responsibility of the client.

I. FACTORS FOR EXECUTION

2.1. Deltastock AD executes clients’ orders in their best interest by making a reasonable effort to establish:

● the best price for the client according to the specifications in the order;

● time of order placing;

● type of the order(market( for direct execution), limit, stop, OCO, limit/stop/OCO conditional orders, trailing stop, conditional etc, which needs to be confirmed, executed and priced manually or automatically);

● speed and probability of execution( orders, which need to be executed at the moment of opening or closing of the market corresponding to the financial instruments, subject to the order or in the case of force majeure events).

● Momentary liquidity on the markets on which the financial instrument or the base asset is traded as well as the available liquidity in the module L2 of the platform Delta Trading.

● Amount of the order (in case, that the quantity and/or the price of execution of the order makes it impossible for it to be executed completely or partially on the respective market on which the financial instrument or base asset is traded).

● Price limitations (in the case that there are such on the respective market on which the financial instrument or base asset is traded).

● Amount of expenses (if there are any);

● All other conditions connected with the execution of the order.

2.2.      Requirements for determining the relative value of the factors of execution, applicable to the orders of all clients.

When processing clients orders Deltastock AD takes into account the relative significance of the factors for execution according to the following categories:

● characteristics of the client, including whether he is classified as non-professional, professional or acceptable counterparty;

● characteristics of the client’s order;

● characteristics of the financial instruments, subject to the order;

● characteristics of the places of order execution, where the order may be submitted for execution.

The company has fulfilled its obligation to act for achieving the best result for its clients if it has executed the order or specific aspect of the order, following the special instruction of the client.

2.3. Additional requirements, applicable to the orders of non-professional clients.

When executing orders, submitted by a non-professional client, the best execution of the order is determined by the total value of the transaction, including the price of the financial instrument and the expenses, connected with the execution. The expenses, connected with the execution, include all expenses, which are directly connected with the execution of the order, including the taxes for the place of execution, the taxes for clearing and settlement, as well as other taxes and commissions, payable to third parties and connected with the execution of the order.

For achieving the best execution, in the cases when there are more than one competitive locations for execution of an order connected with financial instruments and when making an evaluation and comparison of the results, which may be achieved for the non-professional client when executing the order at each location of execution shown in the current policy, and that are appropriate for its execution, are considered the commission of the intermediary and the expenses for the execution of the order on each of the possible places of execution.

2.4. Effect of other factors influencing the executions of orders.

Most orders will receive a price and will be quoted by the automatic electronic systems for trading with the Company, which are not multisided trading systems according to the meaning of the Law for Markets in Financial Instruments. In accordance with factors, such as unusual market conditions, amount of the order or type of the order, the instruments may partially or completely receive manually a price and/or the execution of the order may be delayed in its processing, which may reflect the price of the order execution.

In order to provide its clients the most competitive technology for trading, Deltastock AD strives to use procedures which may lower the risk of delays to a minimum. Regardless of this, in the case of a force majeure circumstances, during the time of important news or other events or factors, which may influence the respective market, the Company may not be able to maintain the usual liquidity in the same volume, where it's even possible to retrieve all its offers present in the L2 module of the Delta Trading platform. The possible effects of the influence of these factors are unpredictable, including that they may cause considerable unusual widening of the spreads, and during the placing of market orders trades may be executed at prices significantly different from those at which they would have been executed at normal market conditions, including those at a fixed spread.

II. Locations for order execution

Deltastock AD executes client orders at the following locations:

3.1. Places for the execution of clients’ orders with financial instruments in exchange for their full price in the country or abroad.

- Exchanges in Bulgaria (Locations for order execution)

* Bulgarian stock exchange AD - Sofia

- Exchanges in the United Stated (Deltastock AD places orders in its own name but at the clients expense)

* American Stock Exchange (AMEX)

* Arca (NYSE)

* ArcaEdge

* BATS

* Bloomberg Tradebook (BTRADE),

* Chicago Stock Exchange (CHX)

* Direct Edge, EDGEA, INET (Island)

* ISE Stock Exchange

* Knight Securities

* LAVA

* Liquidnet

* NASDAQ

* National Stock Exchange (NSX)

* New York Stock Exchange (NYSE)

* NYSE Arca Bonds

* Pink Sheets

* Timber Hill Auto-Ex Stocks

* TrackECN

- Exchanges in Europe (Deltastock AD  places orders in its own name but at the clients expense)

* XETRA

* Bucharest Stock Exchange

* Bolsa de Madrid

3.2. Locations for execution of clients’ orders with financial instruments traded outside a regulated market.

Concerning trading with financial instruments at an “Over the Counter” market (OTC), including trading through the Level 2 module of the Delta Trading platform, the Company executes orders, acting as a counterparty to all trades, and is the location for their execution. The types of financial instruments traded by the Company are listed below. In its aspiration to offer the best possible execution price, the Company has created a wide variety of orders, with which, along with a trading strategy, the client may achieve the desired results. The Company’s clients have the opportunity to trade with certain financial instruments at fixed spreads, as well as on the basis of price – quantity, where the counterparty to all trades is Deltastock AD The tariff on the interest rates, fees and commissions charged by Deltastock AD are accessible to all clients, both in the Company’s offices and also on its website.

- Orders associated with Contracts for Difference on securities.

            The Company has access to the quotes of at least one stock exchange, on which the base assets of the given financial instruments are traded. As well as having the ability to deal with Contracts for Difference on securities at minimum one brokerage or market maker, on the basis of which, the price for the respective CFD is determined.

- Orders associated with Contracts for Difference on indices.

            The Company has access to the quotes of at least one stock exchange, on which the base assets of the given financial instruments are traded. As well as having the ability to deal with Contracts for Difference on indices at minimum one brokerage or market maker, on the basis of which, the price for the respective CFD is determined. The prices of the indices depend on the price of their underlining futures.

- Orders associated with Contracts for Difference on commodity futures.

            The Company has the ability to deal with Contracts for Difference on indices at minimum one brokerage or market maker, on the basis of which, the price for the respective CFD is determined.

 - Orders associated with trading currencies and precious metals.

Concerning the execution of orders associated with currency and precious metals Deltastock AD acts as the location for all deal execution. The prices used for quoting currencies and precious metals are not based on futures, but have as a source, independent Trade and Central banks, as well as market makers providing liquidity on an unregulated market. The experience gained by Deltastock AD defines the use of sources, which provide a reliability of the services, with the key factors for the price composition being the dependability and frequency of renewals.

3.3 Deltastock AD does not collect its commissions in a way, which explicitly and unjustly discriminate between the different locations for execution.

III. Closing remarks

For separate financial instruments that cannot be listed in any particular asset class, the Company must receive instructions from the client regarding the location for the order execution.

If due to an official holiday, trade events or technical limitations at the moment of order placement, and if the Company is not in the condition to execute it at the trade location, which corresponds to the Policy for the execution of clients’ orders, the order might be executed at another location, under the condition, that the clients’ best interests are kept.

            If the locations for execution, chosen by the Company as alternatives cannot be used, then the Company must receive additional instructions from the client concerning the location for execution.

            If an order is received outside of the trading hours of the planned exchange location, the order will be rerouted only to the specified execution location on the following trading day. If the client wishes to have the order rerouted the following day, he/she must give instructions as to the execution location. The company will not change the location for execution of the order, even if it is not, or cannot be executed at the chosen location for a prolonged period of time without further instructions from the client.

            A review of the present Policy for the execution of clients’ orders is done regularly, at least once a year. The final applicable version of the present Policy for the execution of clients’ orders is accessible for clients at the company’s offices, as well as on its internet website (www.deltastock.com)

            The present Policy has been approved via Protocol from 01.04.2009 at a conference of the Board of Directors of Deltastock AD and all clients will be informed if essential changes are made.