Gemini Intergalactic EU, Ltd. Order Execution Policy

Last updated: 29 September 2025

1. Purpose & Scope 

Gemini Intergalactic EU, Ltd. (the “Company”, “Gemini”) is duly authorised as a crypto-asset service provider by the Malta Financial Services Authority (the “MFSA”)  to provide the following crypto-asset services:
  • providing custody and administration of crypto-assets on behalf of clients; 
  • exchange of crypto-assets for funds or other crypto-assets (dealing on own account); 
  • execution of orders for crypto-assets on behalf of clients; 
  • placing of crypto-assets; 
  • reception and transmission of orders for crypto-assets on behalf of clients; 
  • providing transfer services for crypto-assets on behalf of clients.
This Order Execution Policy (this “Policy”) outlines the principles and procedures employed by the Company to take all necessary steps to obtain, while executing orders, the best possible results for its clients (the “Clients”) in accordance with Regulation (EU) 2023/1114 on Markets in Crypto-Assets and other applicable laws, regulations, rules and guidelines (collectively, “Applicable Law”). 
This Policy forms part of the User Agreement of the Company. By accepting the terms of the User Agreement, the Clients are deemed to consent to the terms of this Policy.

2. Best Execution Obligations

The Company is committed to obtaining the best possible result for its clients when executing or transmitting orders for digital assets. This obligation applies irrespective of whether Gemini acts as a counterparty to the client’s transaction, or transmits the order to another (affiliated) execution venue.
To demonstrate compliance, the Company maintains detailed execution records, and evaluates performance periodically to ensure they align with best execution standards. By maintaining robust processes and leveraging advanced execution tools, Gemini ensures transparency, fairness, and adherence to regulatory expectations.
When Gemini executes orders on behalf of clients, it is not obligated to take steps to ensure best execution if the orders are carried out based on specific instructions provided by the client. In such cases, the responsibility for the execution result lies with the client, provided their instructions are clear and precise.

3. Execution Factors

The Company is required to take all necessary steps to execute orders on the most favourable terms for its Clients by considering certain best execution factors (the “Execution Factors”), namely price, costs, speed, likelihood of execution and settlement, size, nature, conditions of custody of the crypto-assets, or any other consideration relevant to the execution of the order.
In its dealings with Clients, the Company has a general duty to act honestly, fairly and professionally considering the best interests of Clients. The Company will determine the relative importance of the Execution Factors by using its commercial judgement and experience in the light of the market information available.
The Company evaluates and prioritizes the following factors to determine the best possible result for clients:
  • Price: Ensuring the most competitive pricing for the client’s order by considering the total cost of the transaction, including any applicable fees;
  • Size: Handling of large orders and specific client instructions with utmost diligence to prevent market impact;
  • Likelihood of Settlement: the probability that a trade, once executed, will be successfully completed, meaning that both the delivery of the cryptocurrency and the corresponding payment will occur as intended.
  • Conditions Custody of Crypto Assets: Ensuring that assets are accessible from hot wallets or cold storage and are readily available to trade.
  • Other Considerations: Any other relevant factors affecting order execution, which may include but are not limited to, time of placing the order.
The relative weight of these factors is assessed by considering the client's profile, the specifics of the order, and the characteristics of the digital assets in question.
Gemini may, in its absolute discretion and in light of available market information and/or conditions at the relevant time, decide that one or more of the Execution Factors listed above hold more weight and act accordingly. Furthermore, in certain instances, whether as a result of system failures, disrupted markets or otherwise, it may be necessary to execute orders of clients in a different manner to that set out in the Execution Policy. In such circumstances, Gemini will seek to achieve the best possible result available for the client under the prevailing conditions. 
A market disruption will occur when the markets cease to function in a regular manner (typically characterised by rapid and large market declines in the value of the digital and/or fiat currencies due to extraneous circumstances). In such instances, it may not be possible to achieve a balance across all the Execution Factors listed in the Execution Policy and, accordingly, Gemini may, in light of available market conditions at the time, need to determine that one or more of the Execution Factors will need to take precedence and act in the best interests of the client.

4. Order Execution and Types

All trades are subject to market conditions and applicable terms outlined in this Policy and the User Agreement. Clients will enter into all transactions on an “execution only basis”. This means that Clients will be solely responsible for all investment decisions and actions taken in respect of their Gemini accounts. 
Clients can place an Instant Order or Recurring Order in Gemini mode. In this case, the Company will act as a counterparty to your order. These orders are typically executed at the current market price, without allowing the client to set a specific price. As a result, execution prices may vary depending on market conditions at the time of the transaction.
If Clients choose a Limit Order, then the Company will execute this type of order with Gemini Trust
Company, LLC or other execution venues in the future. The criteria for the selection of execution venues for Limit Orders include venue reliability, costs associated with execution, and the likelihood of timely execution.
Clients are required to agree to this Policy before initiating trading activities, ensuring they understand the manner in which their orders will be handled and executed. By accepting the terms of the User Agreement, the Clients are deemed to acknowledge and consent to all matters set out in this Policy.
If a Client makes any reasonable and proportionate requests for information (including additional information about this Policy), the Company shall answer clearly and within a reasonable time. In particular, summaries of the execution strategies, the procedures and process used to analyse the quality of the execution obtained and how the Company monitors and verifies that best possible results will be obtained are available to Clients, upon request.

6. Specific Instructions

A Client may ask for orders to be executed in accordance with specific instructions, either generally or on a case-by-case basis. The Company will accommodate any such requests, if and to the extent possible. Where any specific instructions result in higher costs, the Company may reflect those higher costs in its fees to the Client. In the latter case, the Company will notify the client of any revised fees prior to accepting the orders. Where the Client’s instructions relate to only part of an order, the Company will continue to apply this Policy to those aspects of the order not covered by the specific instructions.
Clients should be aware that specific instructions may prevent the Company from taking the steps set out in this Policy to obtain the best possible result in respect of the elements covered by those instructions. Where there is a specific instruction from a Client, the Company shall be deemed to have satisfied its obligations to take all reasonable steps to obtain the best possible result for the Client - provided that the Company executes the order (or a specific aspect of the order) following the specific instructions.

7. Client Order Handling

The Company ensures the fair treatment of all Clients. Orders are promptly and accurately recorded and executed. Special consideration is given to time-sensitive orders, large transactions, and specific conditions requested by clients. 
The Company shall not misuse information relating to pending Clients’ orders and shall take all reasonable steps to prevent the misuse of such information by any employees, counterparties or any other relevant persons. This will be achieved via information barriers, access controls and encryption, surveillance and monitoring systems, and employee training.    
The Company does not aggregate Clients’ orders and executes all orders on an individual basis obtaining the best price available at that time.

8. Conflicts of Interest

Gemini has established and maintains a Conflicts of Interest Policy to identify, prevent, manage, and disclose any conflicts of interest. We ensure that the interests of Clients always take precedence in our order execution processes.

9. Monitoring & Review

Gemini continuously monitors the effectiveness of its execution arrangements and policy. This includes:
  • Conducting regular assessments of executed trades to evaluate if they meet best execution standards, considering factors like price, costs, speed, and settlement likelihood;
  • Auditing employee adherence to execution policies to ensure compliance and prevent conflicts of interest;
  • Reviewing external market conditions and updating criteria for execution arrangements when necessary;
  • Reviewing the execution policy at least annually, and when material changes occur

10. Material Changes & Client Notifications

The Company will promptly notify clients of any material changes to this execution policy or Gemini’s order execution arrangements. Notifications will be provided promptly and in a clear, concise manner.

11. Information Protection 

To prevent the misuse of information related to client orders, Gemini’s Compliance department maintains strict access controls, conducts employee training, and continuously monitors systems. Unauthorized use or dissemination of client order information is strictly prohibited and subject to disciplinary action.

12. Record-Keeping & Review

Gemini maintains comprehensive records of all executed and transmitted orders, including details of the execution factors considered. These records are retained for five (5) years, in accordance with applicable legal and regulatory requirements.

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