Policies on Churning

MY INVESTMENT MARKETS (the "Company") operates under a rigorous execution philosophy designed to provide superior market access and liquidity. The Company functions as a professional bridge to global financial markets, acting as both a primary dealer and a sophisticated intermediary.

(a) Agency Brokerage: In its capacity as a broker, the Company utilizes advanced matching technology to connect Bid and Ask liquidity, ensuring transparent price discovery and efficient order routing.

(b) Principal Liquidity Provision: To ensure immediate execution and market depth, the Company may act as a Principal/Dealer. In this mode, the Company utilizes its own capital and institutional liquidity pools to satisfy client demand instantaneously at competitive market terms.

(c) Intermediary Order Management: As a dedicated intermediary, the Company processes Market and Limit orders with high precision. All orders are monitored in real-time to ensure they are filled at the most favorable prevailing rates.

Churning is categorized by the Company as a serious violation of fiduciary trust and professional ethics. It involves the intentional execution of excessive trading volume within a client's discretionary or self-directed account for the sole purpose of maximizing commission revenue. The Company identifies churning as trading activity that is manifestly disproportionate to the client's stated investment objectives, financial capacity, or risk profile. MY INVESTMENT MARKETS maintains a zero-tolerance policy towards any behavior that encourages or facilitates churning.

To ensure the highest standards of client protection, the following operational safeguards are strictly enforced:

3.1. Client-Initiated Execution: The Dealing Team is strictly prohibited from initiating trades without an explicit request or algorithmic trigger authorized by the client.

3.2. Market-Neutral Principal Basis: Transactions conducted on a principal-to-principal basis are executed to provide depth and stability, not to influence trade frequency.

3.3. Best Execution Surveillance: Our Compliance department conducts periodic reviews of trading frequency and rate competitiveness.

3.4. Real-Time Transparency: Every executed trade is backed by a digital audit trail.

3.5. Regulatory Alignment: This policy is integrated with our "Client Agreement" and is subject to the oversight of the FSC Mauritius.