BEST EXECUTION PRINCIPLES

Updated November 10, 2025

This document contains a summary of the Best Execution Principles of Kvarn Capital Oy ("Kvarn"). The purpose of Kvarn's Best Execution Principles is to ensure that client orders are executed in the best possible manner for them. These Best Execution Principles define the policies and procedures through which Kvarn achieves the best possible result when processing client orders, considering in particular the price, costs, speed, and accuracy of execution.

In this document, 'Trading Counterparty' comprehensively refers to operators of regulated trading venues, suitable liquidity providers, and those counterparties to whom Kvarn either transmits orders for execution or with whom it executes trades directly.

Kvarn aims to achieve the best possible result (i.e. the best execution) for the client when executing orders, focusing on the most favorable price, low costs, and the rapid and precise processing of the order. To achieve this, Kvarn adheres to carefully prepared operating principles, according to which client orders are executed fairly and efficiently.

The key assessment factors include the price and costs of the order, the speed of execution, the likelihood of execution, as well as the size of the order and the impact of the market situation. The best possible result is assessed primarily based on the total consideration. However, in special situations, such as reduced liquidity, other factors may also be decisive. For example, with Trading Counterparties where liquidity is scarce, the rapid execution of the order may be more important than seeking the best price, in which case the total consideration alone is not the determining factor.

Kvarn requests the client's prior consent for the Best Execution Principles. By accepting these Best Execution Principles, the client gives Kvarn explicit prior general consent for Kvarn to execute the client's orders both on its selected regulated trading venues and outside of these trading venues (for example, directly with other liquidity providers permitted by applicable legislation); always, however, aiming to achieve the best possible result for the client's execution. If the client does not accept this procedure, they should not use Kvarn's service.

In selecting Trading Counterparties, Kvarn only uses those Trading Counterparties that can reasonably be believed to be capable of executing orders to the best total consideration for the client. Furthermore, Kvarn may split an order into several parts and execute it with several different Trading Counterparties or at different times to ensure the best result. In the event of a disruption, Kvarn may deviate from its usual principles but still strives for the best achievable result for the client.

Kvarn regularly assesses the efficiency of its Trading Counterparties and internal processes to ensure the best possible results for clients. An internal report is prepared on these assessments, documenting findings and recommended improvement measures. Clients are informed of significant changes to these Best Execution Principles without undue delay, so they can be aware of Kvarn's practices and possible updates to order execution.

Kvarn uses Trading Counterparties without special discounts or benefits and adheres to its strict duty of accountability. If necessary, Kvarn is prepared to demonstrate its compliance with its Best Execution Principles and to document the execution of orders in accordance with these Best Execution Principles at the request of the client or competent authorities. In this way, Kvarn aims to meet the requirements for operational principles and transparency, offering clients the best possible service securely and reliably.