Client order execution principles
Effective from 01.07.2026
Ungaro OÜ (registry code 14562753, hereinafter "Swapin") executes client orders with the objective of achieving the best possible outcome for its clients. This summary explains, in general terms, how Swapin receives, handles, and executes client orders. It is made available to clients before the execution of any order and is also published on Swapin's website so that clients can review the order execution policy at any time.
1. Scope
These principles apply only to the extent that Swapin provides a service that constitutes the execution of crypto-asset orders on behalf of clients. Where a particular activity or service does not, in substance, constitute such a service, these principles do not apply, and the legal classification of the relevant service will be assessed separately in accordance with applicable law.
2. Best execution
Best execution means that Swapin takes all reasonable steps to achieve the best possible outcome for the client when executing an order.
In determining the best possible result, Swapin may take into account, among other things:
- the price or exchange rate;
- direct and indirect costs;
- execution speed;
- likelihood of execution;
- likelihood and reliability of settlement;
- the size and nature of the order;
- the method of payment;
- the characteristics of the relevant crypto-asset and its transfer arrangements;
- the characteristics of the execution venue; and
- any other factors relevant to the execution of the particular order.
As a general rule, Swapin assigns the greatest importance to price and costs, unless the client's interests justify giving greater weight to other execution factors.
When determining the relative importance of execution factors, Swapin considers the characteristics of the client, the characteristics of the order, the characteristics of the relevant crypto-asset or crypto-asset type, and the characteristics of the available execution venue.
Where the client's order is comparable to that of a retail client and the client has not provided specific instructions, Swapin generally considers the total consideration, including the price or exchange rate of the crypto-asset, together with all costs borne by the client.
3. Execution venues
Swapin executes client orders through one or more execution venues that have been assessed in advance.
An up-to-date list of execution venues, together with information on the crypto-assets or crypto-asset categories for which they are used, forms part of this document.
Where multiple execution venues are available for the same crypto-asset, Swapin selects the most appropriate execution venue for each individual order based on the execution factors and assessment criteria described in these principles.
Swapin regularly reviews its execution venues and relies only on venues that can reasonably be expected to consistently deliver the best possible outcome for clients.
Where Swapin adds a new execution venue or removes an existing one, the list of execution venues will be updated. Clients will be informed of any material changes before they take effect, where such changes may affect the execution of their orders.
Swapin confirms that it does not receive or accept any fee, rebate, refund, commission, non-monetary benefit, or any other direct or indirect economic incentive in exchange for routing client orders to a particular execution venue.
Swapin also ensures that its fee and commission structure does not unfairly favour one execution venue over another.
4. Client consent
Before executing a client's order, Swapin ensures that the client has been provided with either this summary or the full order execution policy in a clear, sufficiently detailed, and understandable form, and that the client has given prior consent to the application of these principles.
Client consent is obtained through an active action via an electronic channel, client interface, mobile application, or another channel approved by Swapin.
Swapin will not begin executing an order until the client's consent has been verified and recorded.
Swapin maintains evidence of the client's consent, including at least:
- the date and time of consent;
- the channel used;
- the version of the order execution policy made available to the client; and
- the client's identifier.
5. Client instructions
Where a client provides specific instructions regarding the execution of an order, Swapin applies these principles only to those aspects of the order that are not covered by the client's instructions.
Before accepting or executing such an order, Swapin informs the client that specific instructions may prevent or limit its ability to take the measures otherwise required to obtain the best possible execution for those aspects of the order covered by the instructions.
Swapin executes the order in accordance with the client's instructions to the extent permitted by applicable law. In doing so, Swapin may not be able to apply some or all of the execution factors or methods described in these principles.
6. Order handling, aggregation, and allocation
Swapin ensures that client orders are handled fairly and executed promptly, taking into account the characteristics of the order, prevailing market conditions, and the client's interests.
Unless the client provides specific instructions, Swapin generally begins executing an order immediately after it has been received.
Comparable client orders are normally executed in the order in which they are received unless the characteristics of the order or market conditions justify a different approach in the client's best interests.
As a general rule, Swapin executes each client's order separately.
Orders may be aggregated where:
- aggregation is unlikely to disadvantage any client;
- the orders are in the same direction and relate to the same crypto-asset; and
- aggregation is expected to achieve lower transaction costs or a better execution price than executing the orders individually.
Where an aggregated order is only partially executed, the executed quantity is allocated proportionally according to the relative size of each client's order.
Swapin does not aggregate client orders with orders executed on its own account.
7. Confirmation of execution
Following the execution of a transaction on behalf of a client, Swapin provides the client with confirmation of execution.
Where appropriate for the relevant service and order type, the confirmation includes at least:
- the execution time;
- the execution venue or execution arrangement used;
- the execution price or exchange rate;
- the executed quantity; and
- the applicable fees and charges.
8. Market volatility and execution risks
Market volatility may cause significant changes in the price of a crypto-asset between the time an order is received and the time it is executed.
As a result, clients may experience, among other things:
- execution at a materially different price than expected;
- partial execution of an order;
- execution of larger orders through multiple transactions at different prices;
- periods of unusually high market activity;
- order book imbalances; and
- other risks arising from market conditions.
9. Additional information and notification of material changes
Swapin makes this summary available to clients before providing order execution services through its website, client interface, mobile application, or another durable medium.
Clients are entitled to request additional information regarding Swapin's order execution arrangements and may request a copy of the full order execution policy in a durable medium.
Swapin reviews these principles and its execution venues on a regular basis.
Clients will be informed of any material changes to these principles before such changes take effect, unless an immediate amendment is necessary to protect clients' interests, comply with legal or regulatory requirements, or ensure the orderly functioning of the market.
Notifications of material changes will be provided through the client interface, mobile application, email, or another communication channel agreed with the client. The notification will describe the nature of the change, its effective date, its impact on the execution of client orders, and, where applicable, any new or additional client consent required.
Contact information
Email: customer@swapin.com
Website: www.swapin.com
