Summary: Order execution policy for non-professionals

1. INTRODUCTION ON BEST EXECUTION

DNB Bank ASA (“DNB”) is an investment firm, licensed to perform investment services by the Norwegian Financial Supervisory Authority. In DNB, Investment banking activities are performed by the business area DNB Markets. In this document, DNB refers to activities in DNB Markets.

Best execution includes an obligation to implement processes that contribute to best execution and make it possible to document achieved results.

As an overarching principle, DNB must act honestly, fairly and professionally in accordance with our clients’ best interest. Specifically, DNB has a duty to take all sufficient steps to achieve the best possible result when executing client orders or when transmitting orders to other entities for execution (“Best Execution”).

Best Execution does not mean that DNB can guarantee that the best price will be achieved for all orders but we will at all times do our best in accordance with the order execution policy (full version).

In some financial instruments, the client requests a quote for an instrument, and by accepting the quote, the client trades with DNB as counterparty. Best Execution in these situations implies that DNB must be able to document fairness of the price quoted.

This document will provide a summary for our retail clients of the full version order execution policy available at www.dnb.no/mifid.

2. RELEVANT EXECUTION FACTORS FOR RETAIL CLIENTS

When DNB is executing an order on behalf of a retail client, the provision of Best Execution will be determined in terms of Total Consideration.

Total Consideration is the price of the relevant financial instrument plus the costs related to the execution when passed on to the client. These costs could include expenses incurred that are directly related to the execution of the order, such as execution venue fees, processing costs, clearing and settlement and any other relevant fees paid to third parties involved in the execution of the order, including stamp duty and financial transaction tax.

This means that other factors such as swiftness, probability for execution and settlement only take precedence over price and cost if this contributes to the Best Result for the client.

3. EXECUTION OF CLIENT ORDERS AND BEST EXECUTION

3.1 DNB uses different methods of execution:

3.1.1 Execution of behalf of clients

Execution of client orders on a trading venue (regulated market (RM) or a multilateral trading facility (MTF)) where DNB is a member. When providing this service, there is normally no intermediary between DNB acting on the client’s behalf and the execution venue.

3.1.2 Reception and transmission of client orders

When providing the investment service “receipt and transmission of order”, DNB receives the client order and passes it on to another investment firm for execution. This can for instance be the case when DNB is not a member of the trading venue where the instruments the client wants to buy or sell are admitted to trading.

3.1.3 Dealing on own account

The clients transaction is executed directly against DNBs own account by use of proprietary capital. This could also include trades where DNB acts as a Systematic Internaliser, Market Maker or Liquidity Provider.

3.2 SPECIFIC CLIENT INSTRUCTIONS

If DNB receives order-execution instructions from clients (e.g. with a specific price limit or within a specific timeframe), these instructions will be followed. This satisfies the Best Execution requirement by DNB for those aspects of the order. This could prevent DNB from executing the order according to our standard procedures and setup for obtaining Best Execution. Consequently, if such instructions are given, the provisions relating to Best Execution for those aspects of the order will not apply.

4. MONITORING AND REVIEW

DNB will at all times do our best to secure the best possible result for clients according to this order execution policy.

For all instrument classes, pre trade processes have been designed to achieve best execution.

Best execution procedures are in place to monitor execution quality. This includes continuous and detailed monitoring of the execution quality and the quality and appropriateness of the execution arrangements. Where available, prices are benchmarked against relevant external and internal reference prices to ensure that best execution is achieved on a consistent basis.

A summary of this monitoring will be published on a yearly basis on our website.

This order execution policy is subject to review at least annually, or when an update is needed due to material changes in execution processes. The latest version of this order execution can be found at www.dnb.no/en/mifid.

5. EXTERNAL CONDITIONS IN THE MARKET OR IN THE TECHNICAL SYSTEMS

Should external conditions occur in the market or in technical systems, DNB refers to our general business terms regarding liability and exemption from liability.