Effective Date: November 25, 2025

This Best Execution Policy describes the procedures and commitment of Delta Capital Business LLC (hereafter "Delta Capital Pro" or the "Advisor") to obtain the most favorable execution for client orders, as required by applicable securities regulations in the United States (U.S.).

1. Objective of the Policy

The primary objective of Delta Capital Pro is to seek Best Execution for all financial asset transaction orders on behalf of our clients.

Best Execution is not limited solely to the most advantageous price, but rather to obtaining the most favorable overall terms available under the circumstances at the time of execution, considering the total value of the transaction to the client.

2. Scope and Applicability

This Policy applies to all executed transactions involving managed assets, including, but not limited to, Stock Options, Treasury Bonds, Futures, and Cryptocurrencies, executed by Delta Capital Pro in discretionary management accounts.

3. Definition of Best Execution Factors

In seeking Best Execution, Delta Capital Pro evaluates the total quality of execution through a variety of factors, and not just the transaction price.

The main factors considered include:

Factor
Description

Price
The most favorable price possible for the security or instrument.

Speed
The speed with which the order is executed.

Likelihood
The probability of execution of the order and settlement of the transaction.

Cost
The total cost of the transaction, including commissions, fees, and taxes.

Size/Nature
The size and nature of the order (e.g., large orders may require special considerations).

Settlement Quality
The quality and efficiency of the clearing and settlement practices of the intermediary.

Delta Capital Pro bears the responsibility to consistently execute orders on behalf of all clients in a manner that results in the most advantageous outcome.

4. Selection and Monitoring of Intermediaries (Brokers)

4.1. Selection Criteria

Delta Capital Pro evaluates and selects broker-dealers/custodians (currently Tastytrade, or similar U.S.-regulated entities) based on factors that ensure the best execution for the Delta Trading Pro strategy.

These criteria include:

• Regulatory compliance (requires SEC/FINRA regulation).

• Technology and order routing capability.

• Competitiveness in terms of costs and commissions.

• Capability to handle the types of assets and complex strategies (Options, Futures) utilized by the Advisor.

4.2. Continuous Monitoring

Delta Capital Pro regularly monitors (at least annually) the quality of execution provided by selected intermediaries to ensure they continue to meet the Best Execution standard.

5. Order Aggregation Practice

Delta Capital Pro may aggregate orders for multiple clients into a single block trade when it believes that such aggregation will provide more efficient execution and a better average price for all participating clients.

• Fair Allocation: When an aggregated order is only partially filled, the shares will be allocated fairly and equitably (pro-rata) among the participating client accounts.

6. Review and Disclosure

6.1. Policy Review

This Best Execution Policy is reviewed by Delta Capital Pro at least once every 12 months, or whenever there is a material change in trading practices, technology, or the regulatory environment that may affect our ability to obtain Best Execution.

6.2. Client Acknowledgment

By entering into a Client Service Agreement (CSA) with Delta Capital Pro, the client acknowledges and agrees to the terms of this Best Execution Policy and authorizes the Advisor to select and use intermediaries as determined by the Advisor.

7. About Delta Capital LLC

Delta Capital Delta Capital Business LLC (hereinafter referred to as “Delta Capital,” “Delta,” or “firm” and also doing business as RFJ Capital) provides investment management and financial advice to individuals, executives and small business owners.

Delta started in Brazil in 2021 and its owners are registered with the Brazilian Financial and Capital Markets Association (“ANBIMA”), and in 2025 registered with the SEC and has a US office in Atlanta, Georgia. The firm provides investment advisory services to clients who meet the standard of a “qualified clients” under Rule 205-3 of the Investment Advisers Act of 1940.

Delta Capital Business LLC (also registered as RFJ Capital with SEC) is registered as investment adviser with SEC (CRD # 338957/SEC # 801-135131), focused on the strategic allocation and growth of high net worth assets. We blend deep technological foresight with decades of global corporate expertise to engineer the financial freedom and legacy our exclusive clients deserve.

Delta charges a performance fee of 15% to 20% for any of the investment gains made in your account over the prior month (depending on the initial amount invested).

Additionally, free and simple tools are available to research firms and financial professionals at https://www.investor.gov/CRS, which also provides educational materials about broker dealers, investment advisers, and investing.

Our firm assists clients in developing a comprehensive strategy primarily focused on the following investment advisory services to families and family offices: portfolio management (we review your portfolio, investment strategy, and investments); financial planning (we assess your financial situation and provide advice to meet your goals). As part of our standard services, we monitor client accounts on an ongoing basis. We limit the types of investments that are recommended since not every type of investment vehicle is needed to create an appropriate portfolio.

As part of our transparency policy and mission, we strongly recommend you accessing DELTA CAPITAL - Investment Adviser Firm which is SEC’s official channel for customer to check financial advisor status. At this link you can find all ADV files submitted to SEC as details of our operations as well. Transparency is a very important pilar of our business and we practice it daily at every interaction with our customers.