Nume Order Handling & Best Execution Policy

1. Purpose

This Policy sets out Nume’s standards and procedures for receiving, transmitting, and executing client orders and for taking all sufficient steps to obtain the best possible result (“Best Execution”), consistent with COBS 11 and UK regulatory obligations. It forms the basis for compliance, monitoring, testing and record-keeping for order handling and best execution across Nume.

As an Appointed Representative (AR), Nume follows RiskSave’s framework and is subject to RiskSave’s oversight.

2. Applicability

Applies to all Nume directors, officers, employees, contractors, secondees and any third parties acting on Nume’s behalf (e.g., execution and custody partners). It covers all retail client order flows via the Nume app/website and any assisted channels (e.g., phone/email where applicable).

3. Principles

This policy is designed to align with the FCA Conduct of Business Sourcebook (COBS) section 11, which governs best execution obligations. Accordingly, Nume follows these key principles:

• Client interest first. Client orders have priority over firm/staff dealings.
• All sufficient steps. We consider price, costs, speed, likelihood of execution/settlement, size, nature and any other relevant factors to secure the best possible result on a consistent basis.
• No market abuse. Order handling must not facilitate manipulative practices or misuse of information.
• Proportionality. Controls are commensurate with our business model, instruments, volumes and reliance on third-party execution venues/partners.

4. Access via Electronic Trading Applications

Where clients place orders directly in the Nume app (or connected interfaces) and determine order parameters, this is generally treated as a specific instruction for those aspects. Orders are straight-through processed to our execution partners (e.g., Interactive Brokers UK or other approved venues). Nume must ensure its platform is stable, secure, and resilient, with testing to minimise outages and client harm.

5. Receiving & Confirming Orders

Orders may be received electronically (primary) or, where supported, by recorded telephone/video. Channels intended to lead to execution must be recorded.

Following execution, clients receive a trade confirmation showing instrument, side, price, size, execution time, venue/counterparty and relevant account identifiers in a durable medium.

6. Best Execution – Factors & Relative Importance

When executing or transmitting orders, we consider:

• Characteristics of the client and order
• Characteristics of the instrument
• Characteristics of available venues/execution partners

Execution factors (non-exhaustive):

• Price – typically primary factor for retail flow.
• Costs – explicit (commissions/fees) and implicit (spreads/venue fees).
• Speed – timely execution unless delaying is reasonably likely to improve overall outcome and is appropriate.
• Likelihood of execution/settlement – venue liquidity, instrument tradability, operational certainty.
• Size & nature – potential need to work/divide the order; market impact considerations.
• Any other relevant factors – e.g., market conditions, volatility, corporate actions.

Nume (and/or its execution partners) will prioritise factors according to the prevailing market and the client’s order type and instructions.

Revised allocation of aggregated orders

A revised allocation of an aggregated order is permitted only under the following circumstances:

• Error correction: An error is identified in either the intended basis of allocation or the actual allocation. In such cases, the Appointed Representative must record the reason for the reallocation and ensure it occurs within one working day of identifying the error.
• Uneconomic: The order is only partially executed, resulting in an uneconomic allocation to some customers. In such cases, the Appointed Representative must take reasonable steps to ensure that any reallocation is in the best interests of the customers involved in the trade.

7. Specific Instructions

Where a client gives specific instructions (e.g., venue, time-in-force, limit/stop, exact size, no shaping/slicing), Nume will execute accordingly. This may prevent us from obtaining best execution for those elements covered by the instruction. Staff and disclosures will warn clients that specific instructions can limit our ability to achieve the best overall outcome.

8. Use of Execution Venues & Partners

Nume may route or instruct execution through approved third-party brokers/venues (e.g., Interactive Brokers UK or other approved venues). Venue selection considers cost, reliability, coverage, liquidity access and operational controls. We maintain an Approved Venues/Brokers List (held by Compliance) and review it periodically.

9. Aggregation & Allocation

Nume may aggregate a client order with other client orders only where:

• it is unlikely to disadvantage any client;
• clients are informed that aggregation may on some orders work to their disadvantage; and
• a fair allocation policy is applied.

Allocation rules

• Full fill: each client receives their full order at the average price of the aggregated execution.
• Partial fill: allocate pro-rata by original order size at the average price, unless a documented, pre-authorised alternative method is fairer.
• Firm vs client: if an AR order is aggregated with a client order, client allocation has priority.
• Reallocations allowed only to correct errors (record rationale within 1 business day) or to avoid uneconomic allocations where in clients’ best interests.

10. Client Limit Orders (Shares on a Regulated Market)

If a client limit order is not immediately executed, and the client has not instructed otherwise, we will take steps to publish the order promptly so other participants can access it, in line with applicable rules.

11. Prohibited Practices

• Churning/switching that conflicts with the client’s objectives.
• Dealing ahead/front-running client orders.
• Any behaviour inconsistent with the Market Abuse and Personal Account Dealing policies.

12. Trade Errors

Potential errors (e.g., wrong instrument, size, account, or misallocation) must be reported immediately to a local manager and RiskSave Compliance within 24 hours if material. Correct expeditiously; clients must not bear losses from firm error. Maintain a Trade Error Log; review periodically to identify control improvements.

13. Disclosures to Clients (Client-Facing Policy)

Nume provides clients with clear disclosures covering at minimum:

• Instruments offered;
• Execution venues/partners and selection approach;
• Costs & charges (commissions, FX, platform/venue fees);
• How orders are executed and how the execution factors are applied;
• Warning that specific instructions may limit our ability to achieve best execution.

These disclosures are available on our website/app and via durable medium upon request.

14. Controls, Monitoring & MI

• Order handling testing: sample checks to verify orders were executed per client parameters and in line with policy.
• Best execution monitoring: periodic review of execution quality (price improvement, spreads, fill rates, latency, rejects, venue quality).
• Incident management: log and escalate breaches; root-cause analysis and remediation.
• Change management: product/venue changes assessed for execution impact.
• Interaction with Market Abuse Surveillance: where feasible, align samples and insights.
• Governance: MI and findings reported to Nume senior management and RiskSave; remedial actions tracked to closure.

15. Record-Keeping (≥ 5 years)

Maintain:

• Order & trade records (timestamps, venue, fills, cancellations);
• Client communications related to orders (incl. voice recordings where applicable);
• Trade Error Log and remediation;
• Best execution reviews/MI, venue assessments, Approved List;
• Aggregation/allocation workings and rationales;
• Disclosures issued to clients.

16. Associated Policies

• Market Abuse Policy
• Personal Account Dealing Policy
• Conflicts of Interest Policy
• Complaints Handling Policy
• Financial Promotions Policy

17. Breaches, Waivers & Escalations

• Breaches: record on the Breaches Register; investigate root cause; remediate; assess any customer detriment; report to RiskSave.
• Waivers: only where strict adherence would conflict with other regulatory duties; require formal RiskSave approval and periodic review.
• Escalations: material issues (regulatory breaches; systemic/repeat issues; potential material customer detriment) must be escalated to RiskSave within 24 hours of identification.

18. Queries

Staff Acknowledgement: All relevant staff must confirm they have read, understood, and will comply with the Nume Order Handling & Best Execution Policy.