Best Execution Policy

Procedural Rules of Arev Securities hf. on Best Execution when Transmitting Orders

Purpose

These rules of procedure are issued in accordance with the Markets in Financial Instruments Act 115/2021, and Regulation (EU) 2017/565.

Arev Securities hf. (hereinafter "the company" or "Arev") is not a member of any organised securities market or financial instruments market, does not carry on its own trading activities, nor is it authorised to act as an investment firm, except in connection with asset management. Furthermore, the company is not authorised to execute orders on behalf of clients, and therefore all transactions for Arev's clients are executed by a third party, i.e.i.e. a financial institution authorised to execute orders in securities (hereinafter also "third party").

Best execution in the transmission of orders for the purchase and sale of securities refers to the obligation on the firm to secure the best possible outcome for its clients, in accordance with Article 64 of Regulation (EU) 2017/565. The firm will seek all reasonable means, in accordance with law, regulations and these procedures, to secure the best possible outcome for its clients when executing their orders for securities transactions.

Scope

The procedures apply to the execution of Arev's asset management instructions for securities transactions on behalf of the company's clients, for both retail and professional investors.

The procedures apply to the execution of asset management when Arev's asset management directs trading instructions to a third party on the basis of an asset management agreement.

The rules of procedure apply to transactions in all types of investment services and investment activity, as that term is defined in Article 4 of the Markets in Financial Instruments Act 2021 (No. 115/2021).

These rules describe how Arev's asset management will generally pass on instructions to third parties, on behalf of its clients who have entered into an asset management agreement with the company, when clients do not request specific execution of trade orders.

The procedures are intended to cover the transmission of instructions from asset management for securities transactions for both retail and professional investors, all types of financial instruments, different markets and different instructions. The procedures therefore do not provide an exhaustive list of all the factors that Arev's asset management considers when communicating securities trading orders to third parties for the purposes of asset management, or how Arev's asset management assesses each case individually. but rather the rules establish a specific framework so that the company's asset management clients can gain an overview of how the company's asset management ensures best execution when transmitting securities trading orders.

'Transmission of orders' refers to how the company transmits orders for securities transactions of a client, who has entered into a discretionary management agreement with the company, to a third party.

On Best Practice in the Communication of Directives

(1) Factors taken into account and their weighting:

In the performance of asset management, the firm's asset management will seek all reasonable means to achieve the best possible outcome for its asset management clients when it directs securities transactions to a third party under an asset management agreement.

This will be done by implementing these procedures and the processes based on them, which are designed to achieve the best possible outcome for the company's asset management clients, taking into account price, cost, speed, likelihood of execution, size and nature of the transaction and other relevant factors.

Although the price in a transaction generally carries the greatest weight in securing the best possible outcome, it is possible for the company's asset management to assess the circumstances such that factors other than price are considered more important in specific cases. The relative importance of each factor varies and is determined, among other things, by the following criteria:

Characteristics of the client, including whether they are considered a retail investor or a professional investor.
1. Type of financial instruments to which the instructions apply.
1. Nature of the client's instructions.
1. The characteristics of the markets on which the trade orders can be executed.

Annex I contains an overview of the methods the company uses to determine the relative importance of the aforementioned factors.

(2) Implementation of instructions

If a client with asset management has not given the company specific instructions for the execution of transactions, Instructions for securities transactions will be executed by referring requests for transactions to third parties with whom the company has entered into an agreement to execute instructions for securities transactions on behalf of its asset management clients in the market. The company will only enter into agreements with authorised financial institutions licensed to execute securities trading orders on securities markets or a multilateral trading facility for financial instruments, which operate in accordance with recognised rules.

(3) Best result given the circumstances

Whilst every reasonable effort will be made to achieve the best possible outcome for clients of the asset management business, having regard to the resources available and the circumstances in which it is operating, the company cannot guarantee that in any particular case the best possible outcome will always be achieved. Where the firm's asset management staff comply with these rules in full, it will be generally considered that the firm has fulfilled its obligation to ensure that its asset management clients receive best execution when transmitting orders for securities transactions in accordance with Articles 64-66. Articles 64-66 of Regulation (EU) 2017/565.

(4) The client specifies the particular execution of instructions.

When a client specifies particular instructions for the transmission of orders for securities transactions to a third party, they shall be executed in accordance with the client's instructions. The client acknowledges that when it gives specific instructions, the firm is not obliged to take into account all the factors set out in these procedures to achieve the best possible result, with regard to that part or aspect of the instructions to which the client's specific instructions relate, but the company shall nevertheless always be guided by the duty to protect its clients' interests.

Markets

(1) Execution of orders for transactions in financial instruments on financial markets

The execution of asset management involves the transmission of client orders for securities transactions on organised markets to a third party.

If instructions for securities transactions from the asset management client include a request to buy or sell securities traded on a regulated market or an organised market place, asset management emphasises that the transactions in the relevant securities are execution on that market. The company emphasises this approach as a general principle, as pricing on an organised market or a multilateral trading facility is transparent, the speed of trade execution is high, the cost of executing the trade is easy to ascertain, and the likelihood of the trade being executed is generally high.

The company itself, however, is not a member of an organised securities market or a multilateral trading facility and is not authorised to execute orders, and therefore the final decision is always in the hands of a third party. (a financial institution authorised to execute orders in securities transactions).

The Company endeavours to select third parties in such a way as to safeguard the interests of its clients, and Arev has entered into an agreement with Íslandsbanki for the trading of financial instruments on its behalf on the relevant regulated market or multilateral trading facility.

(2) Implementation of instructions on over-the-counter securities transactions

Although Arev emphasises that orders for securities transactions are generally executed by a third party on regulated markets, a third party may assess the circumstances such that a better execution is obtained for the asset management client when executing orders outside of regulated markets.ef markets or financial instrument market places. Where all execution and/or the decision to execute orders outside of organised markets or financial instrument venues is made by a third party, they will assess on a holistic basis whether it is more advantageous to execute the orders outside such markets or venues or on them.

A client's consent to these procedures provides that the client gives general consent for asset management instructions for securities transactions, in accordance with these procedures, to be executed by a third party outside of regulated markets and marketplace of financial instruments.

Market Disturbance

In the event of a market disruption, or an interruption to the company's operations due to events such as power failures and computer system failures, the company may be unable to execute trades in accordance with these rules. In such circumstances, the Company will, to the best of its ability, seek all reasonable means to achieve the best possible outcome for its clients, as well as informing clients of such difficulties without delay and as soon as they become apparent.

Principles for the Implementation of Mediation in Injunctions

Client instructions are passed on without delay and in the order in which they are received, unless circumstances prevent this or if it is considered to be more advantageous for the client for the instructions to be passed on to a third party in another way.

Arev will not permit a third party to aggregate orders from the company. However, Arev's client is aware that a third party may aggregate orders from other clients of the financial institution and/or orders for the financial institution's own account in relation to a client's instructions for securities transactions that Arev's asset management has brokered, as the third party deems this to result in the best possible outcome for the Arev wealth management client.

Monitoring and Review of the Regulations

The Executive Director of the association is responsible for ensuring that the implementation of these procedures is monitored and that staff comply with the rules in their entirety.

The procedures shall be reviewed regularly, at least once a year, and the association shall assess whether they are sufficiently effective in practice. The firm shall regularly assess whether the measures under these rules, including the selection of third parties to transmit orders for securities transactions and the markets that the rules provide for to be used for transmitting orders, lead to the best possible outcome for clients.

The Company will obtain information from its counterparties, who execute orders at its request, for the purpose of monitoring that the execution of asset management orders for the Company's clients is in accordance with the procedures for best execution when transmitting orders.

Duty to Inform

At the request of a client, the firm shall be able to demonstrate that its asset management instructions for securities transactions have been executed in accordance with its best execution procedures. In order to fulfil this obligation, the firm will record and/or store in electronic form all information regarding clients, the firm's instructions for their transactions, and the execution of those instructions by a third party.

These procedures are available to clients on the company's website: www.arev.is, specifically at www.arev.is/upplýsingar.

These procedures shall be reviewed annually, as well as whenever a significant change occurs that affects Arev's ability to achieve the best possible outcome when executing clients' instructions in a consistent manner. Should the procedures be amended, the firm will inform its clients. By publishing the amended best execution procedures on its website, the firm will be deemed to have fulfilled its obligation to inform its clients under this provision.

Take effect

So approved by the Board of Directors of Arev Securities hf. on 27 March 2026.