Trading Rule

eXchange1:- Platform Trading Rules

TABLE OF CONTENTS

Purpose and Scope
Glossary of Definitions
Eligibility and User Registration
Platform Trading
Trading Conduct
Fees and Charges
Transaction Reporting and Record-Keeping
Governance, Operational Resilience and Incident Management
Limitation of Liability
User Complaints
Miscellaneous

Annex I: Order Record-Keeping and Reporting

Annex II: List of Sanctions

1. PURPOSE AND SCOPE

These Platform Trading Rules establish the terms and conditions governing User access to and trading on the platform (“Platform”) operated by INSTIX GLOBAL SPÓŁKA Z.O.O: (“Company”). Their purpose is to set forth clear and transparent policies and procedures designed to facilitate fair, orderly and transparent operations of the Platform while ensuring compliance with Applicable Law. The Platform Trading Rules should be read to complement with Terms of Use of the Platform which Users are required to acknowledge and accept prior to accessing the Platform.

2. GLOSSARY OF DEFINITIONS

Applicable Law Laws, regulations, and rules applicable to the Platform and its Users, including Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCA), Regulation (EU) No 596/2014 on Market Abuse (MAR), and relevant laws of the Platform's Home Member State.

Asset-referenced token A type of Crypto-Asset that maintains a stable value by referencing other values or rights, including official currencies.

Available Balance The total value of Crypto-Assets and fiat currency credited to a User's Platform Account available for trading, excluding assets subject to a Hold.

Basis Points A unit of measurement equal to 1/100th of 1% (0.01%), commonly used in expressing differences in trading fees or spreads.

Bid-Ask Spread The difference between the highest price a buyer is willing to pay (bid) and the lowest price a seller is willing to accept (ask) for a Crypto-Asset.

Co-location Services Services providing Users with physical placement of their trading systems in close proximity to the Platform's matching engine to minimize latency.

Committed Balance The portion of a User's Available Balance allocated to an Open Order and subject to a Hold.

Connected Person Employees, management, shareholders, or other persons linked to the Platform by control.

Crypto-asset A digital representation of value or right that can be transferred and stored electronically using distributed ledger technology.

Crypto-asset service provider An entity providing professional Crypto-Asset services to third parties.

Distributed ledger technology (DLT) Technology supporting the distributed recording of encrypted data.

Dynamic Price Boundaries Price limits that automatically adjust based on market conditions to prevent excessive price movements and maintain orderly trading.

Electronic money token (e-money token) A Crypto-Asset designed for exchange purposes that maintains stable value by referencing an official currency.

Enhanced Due Diligence (EDD) Additional verification and monitoring measures applied to higher-risk Users or transactions.

Execute/Execution The completion of a Trade through matching corresponding Buy and Sell Orders.

Fill-or-Kill Orders Orders that must be executed immediately in their entirety or cancelled if complete execution is not possible.

Good-till-Cancelled Orders Orders that remain active in the order book until explicitly cancelled by the User or matched for execution.

Hold A restriction on a User's Committed Balance making assets unavailable until associated Open Order(s) are Executed or cancelled.

Home Member State The EU Member State where Company is authorized as a CASP under MiCA.

Immediate-or-Cancel Orders Orders that must be executed immediately, either fully or partially, with any unfilled portion being cancelled.

Legal Person Participants An entity which is not a natural person, that is an entity registered under the law.

Issuer A legal person who offers Crypto-Assets to the public or seeks admission of Crypto-Assets to a trading platform.

Know Your Customer (KYC) Procedures for verifying the identity of Users and assessing their suitability for Platform access.

Limit Order An Order to buy or sell a specified amount of Crypto-Asset at a specified price or better.

Liquidity Provider A market participant who commits to providing liquidity by maintaining continuous quotes in specified Crypto-Assets.

Maker Order An Order posted to the Order Book without immediate execution, providing liquidity.

Market Abuse Any activity that distorts markets or manipulates prices, including insider trading, wash trading, or other deceptive practices.

Market Data Information about trading activity, including prices, volumes, and other metrics distributed to market participants.

Market Making Activities Activities undertaken to provide continuous liquidity and facilitate orderly trading by maintaining two-sided quotes.

Market Order An Order to buy or sell immediately at the best available market price.

Market Quality Metrics Quantitative measures used to assess market performance, including liquidity, price efficiency, and execution quality.

Matching Engine The automated system matching Buy and Sell Orders based on Price-Time Priority.

Offer to the public Communication providing sufficient information about offer terms and Crypto-Assets to enable purchase decisions.

Open Order Maker Order posted to the Order Book awaiting execution or cancellation.

Order User instruction to buy or sell a specified quantity of Crypto-Asset.

Order Book The Platform's automated ledger containing all Open Orders organized by Trading Pair and price.

Platform Crypto-Asset trading system maintained by the Company.

Post-Trade Transparency The dissemination of information about completed trades, including price, volume, and time of execution.

Pre-Trade Transparency The dissemination of information about current trading opportunities, including orders and quotes available in the market.

Price-Time Priority Order matching methodology ranking Orders first by price, then by time of receipt.

Recovery Point Objective (RPO) The maximum targeted period in which data might be lost due to a major incident.

Recovery Time Objective (RTO) The targeted duration of time within which a business process must be restored after a disaster.

Settlement Finality The point at which a transaction becomes irrevocable and unconditional.

Settlement Guarantee Mechanisms ensuring the completion of trades even if a counterparty defaults.

Settlement Risk The risk that one party in a transaction fails to deliver the agreed-upon assets or payment.

Suspicious Transaction Any transaction that might indicate money laundering, terrorist financing, or other financial crime.

System Resources Computing and technical resources allocated to process trading activities, including processing power and memory.

Taker Order An Order executing immediately against existing Orders on the opposite side.

Time-weighted Average Spread The average bid-ask spread over a specific time period, weighted by the time each spread was maintained.

Trade A completed Execution between corresponding Buy and Sell Orders.

Trading Hours Hours when the Platform's Order Books are open for Order placement and Execution.

Trading Pair Two Crypto-Assets that can be exchanged through a Trade.

User A natural or legal person registered to access and use the Platform.

User Agreement Terms and conditions governing Platform access and use.

Utility token A Crypto-Asset providing access to goods or services supplied by its Issuer.

This glossary is provided for reference purposes and should be read in conjunction with the Trading Rules.

3. ELIGIBILITY AND USER REGISTRATION

3.1 General Access Conditions and Governing Principles

The Exchange maintains exclusive authority to grant, deny, suspend, or terminate Platform access. This authority is exercised through a systematic evaluation process designed to ensure market integrity, user protection, and regulatory compliance. The Exchange assesses each application based on objective criteria while retaining discretion to make determinations in the best interest of market stability and user safety.

In exercising this authority, the Exchange adheres to the principles of fairness, transparency, and non-discrimination, while maintaining rigorous standards for market participation. All decisions regarding Platform access are made in accordance with applicable regulations, including but not limited to the Markets in Crypto-Assets Regulation (MiCA) and relevant anti-money laundering laws.

3.2 Comprehensive Onboarding Procedures

The Exchange implements a thorough onboarding process that must be completed satisfactorily before any access to trading functionality is granted. This process consists of multiple verification layers and assessments, each designed to ensure compliance with regulatory requirements and protect market integrity.

3.3 Identity Verification Requirements

Identification Documentation Requirements

The Platform shall require prospective Users to provide comprehensive identification documentation. A high-resolution copy of a valid, government-issued photo identification document shall be mandatory. Such documentation must be current, with all security features clearly visible in the submitted copy. For identification documents not in English or Lithuanian, Users shall provide certified translations. The Platform shall verify the authenticity and validity of all submitted documentation through established verification procedures.

Residence Verification Standards

Users shall provide conclusive evidence of current residential address through submission of recent documentation dated within three months of application. Acceptable documentation includes utility bills, bank statements, or official government correspondence. All submitted documents must display the User's full name and complete residential address. The Platform shall require digital copies to be in colour, displaying all document edges to ensure authenticity. Enhanced verification measures shall apply to addresses in designated jurisdictions requiring additional scrutiny.

Enhanced Due Diligence Protocols

The Platform shall implement enhanced due diligence measures based on specific risk factors associated with User profiles. These measures shall be determined by anticipated trading volumes, jurisdictional considerations, account classification, and comprehensive risk assessment outcomes. Additional documentation requirements shall align with regulatory obligations specific to the User's jurisdiction of residence.

Due Diligence Procedures

The Platform shall conduct thorough due diligence extending beyond standard identification verification. This process shall incorporate risk-based assessment procedures to ensure comprehensive evaluation of User profiles. Regular reviews of verification documentation shall be conducted to maintain accuracy and compliance with evolving regulatory requirements. The Platform shall maintain detailed records of all verification procedures and outcomes, ensuring availability for regulatory review as required.

Anti-Money Laundering Screening Protocols

The Platform shall implement comprehensive background screening against global watchlists and sanctions databases as specified in Annex II . This screening process shall extend to all connected parties and beneficial owners associated with Platform accounts. The Platform shall maintain continuous monitoring of transactions and trading patterns to identify potential money laundering activities. Risk assessments shall be regularly updated based on observed account activity and emerging threat patterns.

Counter-Terrorist Financing Verification Measures

Rigorous verification procedures shall be conducted against international counter-terrorist financing databases to prevent misuse of Platform services. The Platform shall assess jurisdictional risk factors and evaluate transaction patterns and counterparties for potential terrorist financing indicators. Risk-based monitoring systems shall be implemented to ensure early detection of suspicious activities related to terrorist financing.

Source Of Funds Verification Requirements

The Platform shall require comprehensive documentation establishing the legitimate origin of trading funds. This includes verification of banking relationships and thorough assessment of funding source legitimacy. Deposit patterns and volumes shall undergo continuous monitoring to ensure consistency with declared source of funds and to identify unusual activity patterns requiring enhanced scrutiny.

Platform Access Conditions

The Platform shall grant User access only upon satisfaction of mandatory onboarding requirements. Users must explicitly accept the User Agreement and these Rules, affirming their commitment to comply with all Platform requirements and obligations. This acceptance shall be documented and maintained in Platform records.

Verification Documentation

Users shall provide comprehensive documentation for Know Your Customer and Anti-Money Laundering purposes. This includes verified proof of identity, current residential address, and detailed source of assets documentation. Corporate Users shall submit all required corporate documentation demonstrating proper authorization and ownership structures. The Platform shall maintain thorough records of all submitted documentation in accordance with regulatory requirements.

Compliance- KYC and AML/CTF

User acceptance shall be contingent upon successful completion of all Know Your Customer and Anti-Money Laundering verification procedures. The Platform shall conduct thorough background screening in accordance with established KYC/AML Policy requirements. Enhanced due diligence measures shall be applied where required based on User risk assessment outcomes.

In relation to KYC and AML/CTF, we:

(i) shall promulgate and update our KYC and AML/CTF policies to meet the standards set by applicable laws, rules and regulations;

(ii) shall promulgate and update the guidelines and rules relating to the operation of this Platform and our staff shall facilitate the provision of the Services to you in accordance with such guidelines and rules;

(iii) shall design and execute procedures for transaction monitoring and control, which includes, but is not limited to rigorous identity authentication procedures, and maintain a dedicated team to address AML;

(iv) adopt a risk-based approach to due diligence and supervision of our Users;

(v) have the right to review and inspect the transactions to, from and on our Platform;

(vi) shall have the right to report Transactions that we deem in our sole discretion to be suspicious to the relevant authorities; and

(vii) shall maintain the Registration Data and Identification Information (as defined herein) for a minimum of 6 years.

Where you are an individual, we shall collect certain information from you, including, but not limited to, your:

(i) name;

(ii) address (and permanent address if it differs from your address). Your address (or permanent address) shall be verified in the manner prescribed by us;

(iii) valid email address;

(iv) date of birth;

(v) nationality;

(vi) photograph of you with your identification documents;

(vii) official identification documents, including passports, identify cards (both front and back) and other identification documents issued by the relevant authorities; and

(viii) other information that we may request from you from time to time,

the “Personal Identification Information”.

Where you are a legal entity other than an individual, we shall collect certain information from you, including, but not limited to, your:

(i) registration and incorporation documents;

(ii) articles of association or memorandum;

(iii) ownership structure and description of such ownership structure;

(iv) board resolution designating your authorised person responsible for the Account;

(v) identification documents of the directors, major shareholders and the authorised person(s). Generally, shareholder’s holding 10% or more of the relevant entity’s voting power is required to be identified;

(vi) your address; and

(vii) other information that we may request from you from time to time,

the “Corporate Identification Information” and together with the Personal Identification Information, the “Identification Information”.

Identification Information that we request from you may vary according to your jurisdiction and we also may require you to notarise copies of documents you provide to us. We shall have the right to request the notarised translation of your Identification Information to English.

Risk Acknowledgment

Users must demonstrate clear understanding of Crypto-Asset trading risks through formal acknowledgment of the Risk Disclosure Statement. This acknowledgment shall be recorded and maintained as part of the User's onboarding documentation. The Platform shall ensure Users receive comprehensive risk disclosures prior to commencing trading activities.

User Requirements and Qualifications

To access and utilize the Platform, Users are encouraged to possess and maintain the following essential qualifications:

Technical Competence: Users are presumed to have obtained sufficient technical knowledge and capability to effectively operate the Platform, including but not limited to understanding blockchain technology, digital wallet management, and cryptographic principles. The Platform assumes no responsibility for losses arising from Users' lack of technical expertise.

Financial Resources: Users are presumed to have maintained adequate financial resources to fulfill all trading obligations, including initial deposits, margin requirements, transaction fees, and potential losses. Users acknowledge that trading on the Platform in Crypto Assets involves substantial financial risk and agree to trade only with funds they can afford to lose

3.4 Additional requirements for Legal Person Participants

Admission and Ongoing Requirements for Legal Person Participants and Institutional Participants

Platform shall identify participants that are Legal Person Participants by using the legal entity identifier provided by that participant. Such Legal Person Participants shall be subject to Enhanced Due Diligence, as may be required.

For the purposes of these rules, an Institutional Participant shall mean any entity that qualifies as a credit institution, investment firm, insurance undertaking, collective investment scheme, pension fund, central bank, government entity, or other regulated financial institution under applicable law, or any entity whose primary business activity consists of dealing in financial instruments or Crypto-Assets.

The admission of Institutional Participants shall be subject to the satisfaction of the following requirements, which shall be maintained on an ongoing basis throughout the duration of the participant's membership:

The applicant shall demonstrate:

Authorization and registration with the competent regulatory authorities in their jurisdiction of incorporation, evidenced by current licenses and regulatory permissions pertinent to Crypto-Asset trading activities.
Minimum regulatory capital of [ _ _ ] or its equivalent, which shall be maintained at all times and verified through quarterly financial reporting to the Platform.
Professional indemnity insurance coverage of not less than [ _ _ ] per claim, with aggregate coverage of [ _ _ ] annually, from an insurer with a minimum credit rating of A- from Standard & Poor's or equivalent.

The Institutional Participant shall undergo enhanced due diligence procedures prior to admission and at regular intervals thereafter. These procedures shall include:

Corporate Documentation Requirements

The Platform shall require comprehensive corporate documentation for entity verification for Legal Person Participants and Institutional Participants. This includes official certificates of incorporation, current constitutional documents, and complete registers of directors and shareholders. Entities must provide memoranda and articles of association, along with certificates of good standing issued within a three-month validity period. A detailed corporate organization chart demonstrating group structure shall be mandatory, accompanied by valid Legal Entity Identifier (LEI) registration and tax identification numbers for all operational jurisdictions.

Beneficial Ownership Verification

Legal Person Participants and Institutional Participants shall disclose and verify all beneficial owners maintaining ownership interests. Enhanced due diligence measures shall be implemented for beneficial owners holding 25% or greater ownership stakes, including comprehensive source of wealth verification. The Platform shall conduct thorough background screening against sanctions lists (Annex II) for all beneficial owners. Political Exposed Person (PEP) screening shall be mandatory for beneficial owners and senior management personnel.

Management And Control Assessment

The Platform shall verify the identity and credentials of all board members and executive directors through documented validation procedures. This includes review of professional curricula vitae for executive directors and comprehensive background checks for senior management. Legal Person Participants and Institutional Participants must disclose any past or ongoing regulatory actions or investigations.

Financial Crime Prevention Protocols

Legal Person Participants and Institutional Participants shall demonstrate robust financial crime prevention frameworks through documented policies and procedures addressing anti-money laundering and counter-terrorism financing requirements. Documentation must include sanctions screening procedures, transaction monitoring systems, and customer risk assessment methodologies. Entities shall maintain suspicious transaction reporting procedures and implement staff training programs focused on financial crime prevention.

Ongoing Monitoring Requirements

The Platform shall implement systematic monitoring procedures including annual reviews of Know Your Customer documentation and quarterly sanctions screening. Transaction patterns shall be monitored monthly to identify suspicious activities. Legal Person Participants and Institutional Participants must provide immediate notification of material changes to ownership or control structures. Regular risk rating assessments shall be conducted to maintain effective oversight.

The Platform reserves the right to review and modify category assignments based on participants' trading behaviour, risk profile, and compliance history. All Legal Person Participants and Institutional Participants must maintain continuous compliance with their respective category requirements to retain trading privileges.

3.5. User Exclusions

To maintain market integrity and comply with Applicable Law, the following categories of users would be excluded from participation:

Sanctioned Individuals or Entities:

· Users listed under EU, US or UN sanctions or other international sanctions lists (e.g., OFAC) applicable to the Platform provided in ANNEX II.

· Any user whose assets are frozen or whose activities are restricted under applicable laws.

Restricted Jurisdictions:

· Users residing in or accessing the Platform from jurisdictions classified as high-risk or non-cooperative by the Financial Action Task Force (FATF).

· Prohibited jurisdictions provided in ANNEX II.

· These jurisdictions may include those with weak anti-money laundering (AML) and counter-terrorism financing (CFT) measures.

Minors:

· Individuals under the age of 18 or below the legal age to trade in their jurisdiction.

Non-Compliant Users:

· Users who fail to complete Know Your Customer (KYC) or Enhanced Due Diligence (EDD) requirements.

· Users providing false or incomplete information during onboarding or trading activities.

Users Engaging in Prohibited Activities:

· Users identified as engaging in market manipulation, including wash trading, spoofing, front-running, or insider trading.

· Users attempting to evade sanctions or regulatory controls using anonymizing tools (e.g., mixers, tumblers, VPNs).

4. PLATFORM TRADING

4.1 Limit Orders

Order Placement Protocol

The Platform shall enable Users to place Limit Orders specifying prices at which they seek to buy or sell Crypto-Assets. Each Limit Order shall establish a maximum purchase price or minimum sale price at which the User agrees to execute the transaction. The Platform shall maintain precise records of all specified parameters for each Limit Order placed.

Order Duration And Management

Limit Orders shall remain active in the order book until execution occurs at the specified price or better, the User initiates a cancellation, or the order expires according to designated time-in-force parameters. The Platform shall maintain systematic monitoring of all active Limit Orders to ensure adherence to specified conditions and parameters.

Execution Considerations

The Platform explicitly notes that Limit Order placement does not guarantee execution, even in circumstances where market prices reach specified limit prices. Market conditions, including liquidity and trading volumes, may impact execution capability. The Platform shall maintain transparent communication regarding factors that may affect Limit Order execution.

Conditional Order Types

The Platform supports enhanced Limit Order functionality through specified conditional parameters:

· Fill-or-Kill orders require immediate execution of the entire order quantity or automatic cancellation.

· Immediate-or-Cancel orders permit partial execution with immediate cancellation of any unfilled portion.

· Good-till-Cancelled orders persist in the order book until explicitly cancelled by the User.

The Platform shall maintain precise documentation of all Limit Order specifications and execution parameters, ensuring alignment with market integrity requirements and operational capabilities. Regular assessment of order execution processes shall be conducted to ensure continued effectiveness and compliance with regulatory obligations. Pre Trade and Post Trade Transparency shall be maintained as provided in Annex I

4.2 Market Orders

Order Placement Protocol

The Platform shall enable Users to place Market Orders for immediate execution in Crypto-Asset trading pairs. Market Orders facilitate the purchase or sale of Crypto-Assets at prevailing Market prices, providing immediate execution capability. The Platform shall maintain comprehensive records of all Market Order placements and executions.

Order Execution Process

Market Orders shall be executed immediately against the best available prices in the Platform's order book. The Platform shall process Market Orders according to price-time priority, matching against existing limit orders to achieve optimal execution prices. Execution shall occur systematically against multiple price levels as necessary to fulfil the complete order quantity.

Price Considerations

The Platform acknowledges that final execution prices for Market Orders may deviate from displayed prices due to slippage, particularly during periods characterized by elevated Market volatility or reduced liquidity conditions. The magnitude of price deviation shall depend on prevailing Market conditions and order size relative to available liquidity.

Risk Acknowledgment

Users entering Market Orders explicitly acknowledge the potential for significant price slippage and elevated execution costs. The Platform shall maintain clear documentation regarding these risks and ensure Users understand the implications of Market Order placement under varying Market conditions. Regular assessment of Market Order execution processes shall be conducted to ensure continued effectiveness and compliance with Market integrity requirements.

Pre Trade and Post Trade Transparency shall be maintained as provided in Annex I. Both Pre Trade and Post Trade data shall be provided separately.

4.3 Order Execution Framework And Trading Requirements

Matching Principles and Execution Hierarchy

The Platform executes all orders in strict accordance with Price-Time priority principles. Orders placed at identical price levels shall be executed based on chronological precedence, with earlier orders receiving priority. The Platform's automated matching engine facilitates order execution, maintaining comprehensive records of all matching events and execution outcomes.

Funding And Balance Requirements

Users must maintain sufficient funding prior to order execution. Buy Orders require full purchase amount coverage including applicable fees, while Sell Orders necessitate complete Crypto-Asset availability plus associated fees. Account balances must adequately cover principal Order amounts, trading fees, applicable margin requirements, and additional buffer allocation for Market Order price fluctuations.

Prohibited Activities and Enforcement

The Platform strictly prohibits self-trading activities, wash trading, manipulative practices, and placement of Orders without genuine execution intent. Automated trading systems require explicit Platform approval prior to deployment. Violation of these requirements may trigger immediate remedial actions, including Order cancellation, account suspension or termination, profit forfeiture, and regulatory authority notification.

The Platform shall maintain detailed documentation of all execution processes and enforcement actions, ensuring compliance with regulatory obligations and market integrity requirements. Regular assessment of execution frameworks shall be conducted to ensure continued effectiveness and alignment with evolving market conditions.

4.4 Execution Procedures and Trading Phases

In furtherance of maintaining fair, orderly, and efficient markets, and in compliance with all applicable regulatory requirements, the Platform hereby establishes comprehensive procedures governing Order execution and trading phases. These procedures shall be implemented uniformly across all Users/Traders and trading sessions, subject to the specifications and requirements set forth herein.

Order Entry Requirements and Validation Protocols

For the purposes of ensuring market integrity and maintaining orderly trading conditions, all Orders submitted to the trading Platform shall be subject to rigorous validation procedures and must contain comprehensive Order information as specified herein:

Instrument Identification Standards

The Platform mandates comprehensive instrument identification parameters for all submitted Orders. Each Order shall include a standardized unique identifier for the Crypto-Asset, conforming to international identification conventions. Orders must specify explicit trading pair designations, incorporating both base and quote assets according to Platform-standardized naming conventions.

Order Parameter Requirements

The Platform requires detailed Order parameters for all submissions. Orders shall designate specific Order types from the Platform's standardized catalog, precise asset quantities as defined in technical specifications, and applicable price parameters expressed in quote currency with prescribed decimal precision. Order validity specifications must include defined durations or timestamps. Each Order shall contain unique client identification codes enabling unambiguous originator identification, explicit trading capacity designation, and any supplementary execution instructions affecting Order characteristics.

Validation Framework

The Platform implements systematic Order validation procedures encompassing comprehensive verification measures. This includes real-time position verification, assessment against maximum Order parameters, evaluation against Dynamic Price Boundaries, and verification of Order submission rates. The validation framework incorporates statistical and absolute risk measures while ensuring compliance with regulatory trading restrictions.

Execution Quality Standards

The Platform maintains sophisticated execution quality measurement and enhancement protocols. This framework establishes comprehensive quality assessment measures, control mechanisms, and governance procedures ensuring optimal execution outcomes. The Platform implements advanced price formation monitoring systems incorporating real-time surveillance, deviation detection, and multiple reference price validation mechanisms.

Price Formation Protocols

The Platform employs advanced price formation and discovery mechanisms through sophisticated monitoring systems. These include continuous price formation surveillance, deviation detection algorithms calibrated to specific instruments, and multiple reference price validation sources. The Platform implements statistically robust methodologies for fair value determination appropriate to instrument characteristics while facilitating systematic price improvement opportunities through advanced matching algorithms.

5. TRADING CONDUCT

Compliance Requirements

The Platform requires Users to maintain strict compliance with these Rules, Applicable Law, and the highest standards of market integrity in all Platform activities. Users shall demonstrate appropriate conduct in account access and trading operations, ensuring all activities support fair and orderly markets.

Prohibited Market Practices

The Platform strictly prohibits all forms of market manipulation and abuse. Users shall not engage in artificial trading activities or non-bona fide transactions designed to create misleading market impressions. The Platform explicitly forbids deceptive trading strategies including layering, spoofing, quote stuffing, and other manipulative schemes. Users shall not conduct front-running operations, exploit material non-public information, or engage in wash trading between affiliated accounts. All activities prohibited under the Market Abuse Regulation or other Applicable Law shall be strictly forbidden.

System Integrity Protection

Users shall not engage in practices that compromise Platform integrity or orderly market operations. The Platform prohibits the submission of Orders intended to test system capabilities or disrupt market functioning. Users shall not obscure order origins through omnibus accounts or coordinate trading activities to circumvent Platform controls. The systematic placement of small Orders to probe Order Book depth shall be prohibited.

Account Security Obligations

Users bear sole responsibility for maintaining account security and protecting access credentials. The Platform requires immediate notification of any unauthorized access attempts or security breaches. Users maintain complete accountability for all activities conducted through their accounts, including any unauthorized access resulting from compromised credentials.

The Platform shall maintain comprehensive surveillance systems to detect and prevent prohibited activities, implementing immediate remedial measures when violations are identified. Regular assessment of market conduct monitoring systems shall be conducted to ensure continued effectiveness in maintaining market integrity.

6. FEES AND CHARGES

Company shall charge fees for Platform trading as set out in the Fee Schedule published on the Platform website. Fees may be assessed as a percentage of Trade value or as a flat amount and may vary based on User classification, trading volume, or other factors. Company reserves the right to modify the Fee Schedule at any time subject to 30 days prior notice.

Separate Maker fees and Taker fees shall apply based on an Order's status when executed. Maker fees shall be the default for Limit Orders and Taker fees for Market Orders, unless a mixed Maker/Taker fee applies to Limit Orders partially matched upon placement.

All fees shall be automatically debited from the User's Available Balance as part of Trade settlement and reflected in the User's transaction history. Fees are non-refundable once incurred.

7. TRANSACTION REPORTING AND RECORD-KEEPING

Company shall maintain a complete, accurate and time-sequenced record of all Orders and Trades for a minimum of 5 years, including:

(a) The User ID, time, price, quantity, underlying Crypto-Asset and Order type of each Order;

(b) The same details of each resulting Trade along with the counterparty User IDs and execution timestamp;

(d) The Platform's end-of-day trading summary and open interest report.

Company shall submit complete and accurate daily transaction reports within 24 hours to each competent authority for Crypto-Assets it has admitted to trading, as required under Applicable Law.

Users may access their full Platform transaction history through the secure portal provided for this purpose, including details of Orders placed, Trades executed, fees charged, and current balances.

8. GOVERNANCE, OPERATIONAL RESILIENCE AND INCIDENT MANAGEMENT

8.1 Governance

Members of the management body of Company shall be of sufficiently good repute and possess the necessary knowledge, skills, and experience, both individually and collectively, to perform their duties effectively. Individuals with convictions related to money laundering, terrorist financing, or any other offenses impacting their reputation shall be prohibited from serving. Additionally, management members shall demonstrate their ability to dedicate sufficient time to fulfil their responsibilities.

Shareholders and members, whether direct or indirect, holding qualifying stakes in trading entities shall also be of sufficiently good repute. Those with convictions related to money laundering, terrorist financing, or any other offenses compromising their reputation shall be ineligible to hold such stakes.

The Company shall maintain a separate policy on governance and repute standards to ensure compliance with the aforementioned clauses. This policy shall outline procedures for evaluating the reputation, qualifications, and eligibility of members of the management body and shareholders with qualifying holdings. The policy shall also include mechanisms for continuous monitoring and periodic reviews to uphold these standards and address any changes in circumstances promptly.

All activities conducted on the Platform would adhere to the principles and provisions outlined in the Platform’s conflict of interest policy, which governs the identification, prevention, management, and disclosure of any conflicts of interest that may arise during the provision of trading services including that relating to placing of Crypto-Assets and market making.

The Company shall adopt and maintain an orderly wind-down policy to safeguard its operations and ensure compliance with regulatory requirements. This policy shall establish a structured approach for an orderly wind-down of operations if required. The policy shall be reviewed periodically and include mechanisms to protect clients' interests, maintain operational stability, and comply with applicable legal and regulatory obligations.

8.2 MARKET MAKING

Platform may engage in market-making activities to enhance liquidity, reduce price volatility, and promote efficient trading on the Platform. Market-making activities may include placing buy and sell Orders for specific Crypto-Assets to ensure a fair and orderly market.

Transparency and Disclosure

Platform commits to full transparency regarding its market-making activities. The Platform will:

Clearly disclose its role as a market maker in these Rules and other relevant documentation.
Publish periodic reports on the scope and impact of its market-making activities, including liquidity provision metrics.

Users are notified that market-making activities may impact Order execution but are designed to ensure a balanced and efficient market.

Conflict-of-Interest Management in market making

To avoid conflicts of interest in market making, Platform implements the following measures:

Operational Separation: The market-making team operates independently from the Platform's operational and governance teams, including order matching and execution functions.
Fair Access: Market-making activities do not receive preferential treatment. Orders submitted by the market-making team are subject to the same execution rules (e.g., price-time priority) as those submitted by users.
Internal Monitoring: Regular audits of market-making activities are conducted to ensure compliance with MiCA and internal conflict-of-interest policies.

Scope and Limitations

Platform will not engage in market-making activities that:

Manipulate prices or create artificial trading volumes (e.g., wash trading or spoofing).
Undermine the fair and transparent operation of the Platform.
Market-making activities are limited to Crypto-Assets admitted for trading on the Platform, and Platform will not trade Crypto-Assets for speculative purposes

Regulatory Compliance

All market-making activities are conducted in compliance with Applicable Laws. Platform will report its market-making activities to the competent regulatory authority as required under Applicable Laws and maintain detailed records for a minimum of five years.

User Protection

Market-making activities are designed to benefit the Platform’s users by providing:

Tighter bid-ask spreads.
Greater depth in the order book for supported trading pairs.
Users are assured that their orders are executed fairly, without bias, and in accordance with the Platform's execution policies.

8.3 Exclusion of Issuer and Crypto-Assets

The Platform retains exclusive authority to exclude or deny admission to any Crypto-Asset failing to meet established requirements under Applicable Laws. This authority extends to Issuers and their associated Crypto-Assets that present risks to market integrity, consumer protection, or regulatory compliance.

GROUNDS FOR EXCLUSION

Regulatory Compliance Requirements

The Platform shall exclude Crypto-Assets lacking a compliant and approved White Paper under MiCA regulations. Exclusion shall apply when Issuers fail to fulfill disclosure obligations or provide accurate and comprehensive information. Non-compliance with anti-money laundering and counter-terrorism financing requirements, particularly under Directive (EU) 2015/849, shall constitute grounds for exclusion.

Exclusion shall be warranted for Crypto-Assets demonstrating technical deficiencies or unreliable infrastructure. Issuers must maintain robust governance frameworks and sufficient financial resources to ensure Crypto-Asset stability. Further, any Crypto-Asset with an in-build anonymisation tool for holder of such Crypto-Asset shall also be excluded.

Involvement in market manipulation, price distortion, or artificial volume creation shall result in exclusion. This includes activities such as wash trading and spoofing. Association with fraudulent schemes or misleading marketing practices shall constitute grounds for immediate exclusion.

Exclusion Procedures

The Platform shall conduct periodic reviews of Issuers and Crypto-Assets, evaluating compliance reports, market performance metrics, and user feedback. Decisions regarding exclusion shall be based on comprehensive assessment of these factors.

Issuers shall receive formal notification of intended exclusion, including detailed justification. A minimum 30-day remediation period shall be provided, except in cases requiring immediate action to protect market integrity.

Issuers retain the right to appeal exclusion decisions within 15 days of notification by submitting additional documentation or requesting review. The Platform shall conduct impartial review of appeals and communicate final decisions within 30 days.

Immediate Exclusion Provisions

The Platform maintains the right to implement immediate exclusion without prior notice under specific circumstances:

· Identification of imminent risks to Platform users or market stability

· Receipt of regulatory mandates due to legal violations

· Implementation of enforcement actions by relevant authorities

This framework ensures systematic evaluation and management of Crypto-Asset exclusions while maintaining market integrity and regulatory compliance. Regular review and updates of these procedures shall be conducted to reflect evolving market conditions and regulatory requirements.

Ongoing Monitoring

The Platform continuously monitors Crypto-Assets and Issuers admitted for trading to ensure compliance with admission standards. Any Crypto-Asset identified as non-compliant during these reviews will be subject to exclusion proceedings as described in this section.

User Protection

Users holding excluded Crypto-Assets will be notified of the exclusion and provided with instructions for withdrawal or alternative arrangements within a reasonable timeframe. The Platform will ensure that users are not unduly disadvantaged by an Issuer’s failure to comply with regulatory or operational requirements.

8.4 Fair Access Provisions and Equal Treatment

The Platform shall ensure fair and non-discriminatory access to all trading services, facilities, and information. These provisions establish the fundamental principles and specific requirements for maintaining equitable market access and participation.

Access to Trading Infrastructure

The Platform shall provide all participants with equal access to trading infrastructure according to their respective participant categories. This includes:

(a) The Platform shall maintain uniform technical specifications for connectivity, ensuring that all participants within the same category receive equivalent response times. Maximum latency variations shall not exceed 10 milliseconds between participants of the same category accessing from the same geographic region.

(b) System Resources Computing resources, including processing capacity and memory allocation, shall be distributed equitably among participants based on objective criteria such as message volume and order frequency. The Platform shall document and regularly review resource allocation methodologies.

(c) Where Co-Location services are offered, they shall be available to all participants under uniform terms and conditions, including equivalent pricing for equivalent services. The Platform shall maintain transparent procedures for allocating data center space and resources.

Market Data Distribution

The Platform shall ensure equitable access to market data through the following measures:

(a) Data Dissemination All market data shall be distributed simultaneously to all participants through standardized protocols. Any variations in data delivery times must be solely attributable to technical differences in connectivity choices made by participants.

(b) Data Content Market data content shall be identical for all participants within the same category, including order book depth, transaction data, and trading statistics. Any enhanced data services shall be available to all participants meeting objective criteria.

(c) Historical Data Access to historical market data shall be provided under uniform terms and conditions, with standardized pricing based on objective criteria such as data volume and frequency of access.

8.5 Continued Trading Eligibility of Crypto-Assets

Liquidity Requirements

The Platform shall continuously monitor and evaluate the liquidity of all admitted Crypto-Assets. For a Crypto-Asset to remain eligible for trading, it must maintain the following liquidity thresholds in addition to their Exclusion criteria:

(a) Daily Trading Volume The Crypto-Asset must maintain a minimum daily trading volume of [ _ _ ] , calculated as a rolling 30-day average. Should the trading volume fall below this threshold for five consecutive trading days, the Platform shall initiate a liquidity review procedure.

(b) Market Depth The order book must consistently maintain sufficient depth to execute a standardized transaction size, defined as €10,000, with a maximum price impact of 3%. This depth requirement shall be measured continuously during trading hours.

(c) Bid-Ask Spread The time-weighted average spread during primary trading hours shall not exceed 300 basis points over any rolling 24-hour period. Spreads shall be calculated and monitored on a continuous basis.

8.6 Trading Suspension Framework

Market Integrity Criteria

The Platform shall implement immediate trading suspension upon detection of activities that compromise market integrity. This includes identification of market manipulation schemes, unauthorized market making operations, and coordinated trading activities designed to artificially influence asset prices. Trading shall be suspended when surveillance systems detect trading patterns indicative of potential insider trading or other forms of market abuse.

Technical And Operational Considerations

Trading suspension shall be initiated in response to critical technical vulnerabilities affecting the underlying blockchain infrastructure. This encompasses scenarios involving significant network degradation, smart contract vulnerabilities, or identified exploits that pose material risks. Additionally, failures in custody or settlement systems that impact operational integrity shall trigger immediate suspension of trading activities.

Regulatory And Compliance Requirements

Trading suspension shall be mandatory upon identification of regulatory non-compliance, including failures to meet ongoing disclosure obligations. The Platform shall suspend trading activities when subject to regulatory investigations or enforcement actions that materially affect trading operations. Changes in regulatory status or violations of applicable laws and regulations shall necessitate immediate trading suspension.

Market Quality Standards

The Platform shall implement trading suspensions when market quality metrics fall below established thresholds. This includes persistent failures to maintain required liquidity levels, instances of excessive price volatility that exceed dynamic thresholds, and significant deterioration in market depth. Trading shall be suspended upon detection of breakdowns in the price formation process that compromise market efficiency.

Implementation of these suspension protocols shall be immediate and systematic, with clear procedures for communication to market participants and relevant stakeholders. Trading resumption shall require comprehensive review and verification that triggering conditions have been adequately addressed.

Implementation Procedures

Upon identification of conditions warranting trading suspension, the Platform shall execute immediate implementation procedures. Trading shall be halted through a systematic process that includes cancellation of all pending orders in the affected Crypto-Asset and prevention of new order entry. Market data dissemination shall continue throughout the suspension period to maintain market transparency. The Platform shall promptly notify relevant regulatory authorities of the suspension and its underlying causes.

Communication Framework

The Platform shall maintain comprehensive communication protocols during trading suspensions. A formal suspension notice shall be published on the Platform and distributed to all participants through established communication channels. Regular status updates shall be provided to ensure stakeholders remain informed of developments. The Platform shall issue detailed incident reports documenting the circumstances leading to the suspension, actions taken, and measures implemented to address the underlying issues.

Resumption Requirements

Trading resumption shall be contingent upon satisfaction of clearly defined criteria. The Platform shall verify complete resolution of the conditions that triggered the suspension through thorough assessment procedures. A market readiness evaluation shall be conducted to ensure system stability and market participant preparedness. The resumption process shall be implemented in phases to ensure orderly market restoration.

Documentation And Reporting

The Platform shall maintain detailed documentation of all suspension events, including timing of implementation, communication records, and remediation measures. Post-incident analysis reports shall be prepared to identify potential improvements to suspension protocols and prevent recurrence of triggering conditions.

This framework ensures systematic handling of trading suspensions while maintaining market integrity and participant confidence through clear communication and structured resumption procedures. All protocols shall be regularly reviewed and updated to reflect evolving market conditions and regulatory requirements.

8.7 Settlement Procedure

Crypto-Asset Settlement Procedures

The Platform shall execute all Crypto-Asset settlements within a maximum timeframe of 24 hours from initiation. Real-time monitoring systems shall be implemented to track settlement confirmations. The Platform shall maintain automated processing of settlement instructions with clearly defined procedures for managing settlement failures. Settlement completion shall require multiple blockchain confirmations, with the specific number determined by individual network characteristics. The Platform shall implement automated verification systems for on-chain settlement confirmation and comprehensive reconciliation processes. Backup settlement procedures shall be maintained to ensure operational continuity.

Pre-settlement risk monitoring systems shall be implemented to assess and mitigate potential settlement risks. The Platform shall maintain robust collateral management procedures and settlement guarantee mechanisms. Comprehensive protocols shall be established for handling failed settlements.

Fund Settlement Procedures

The Platform shall execute all fiat currency settlements within a maximum timeframe of 24 hours from initiation. Payment instruction generation shall be automated, with real-time tracking capabilities for settlement status monitoring.

Settlement shall be standard for all currencies, with predetermined cut-off times established for each currency. Processing schedules shall be clearly defined and adjusted according to recognized holiday calendars.

Settlement accounts shall be pre-funded to mitigate settlement risk. The Platform shall maintain real-time exposure monitoring systems and enforce settlement limits. Currency conversion controls shall be implemented to manage associated risks.

Settlement Finality Framework

All settlement procedures shall be legally binding, with established protocols for participant default and dispute resolution.

Technical Implementation Requirements

The Platform shall ensure settlement irreversibility through automated confirmation systems. Settlement tracking mechanisms shall be implemented with complete audit trail maintenance and system reconciliation procedures. Real-time settlement monitoring capabilities shall be maintained. The Platform shall generate regular settlement efficiency reports and conduct settlement failure analysis. Performance metrics shall be tracked and reported systematically.

8.8 Exchange Timing, Security and Operational Resilience

The Platform shall operate continuously on a twenty-four (24) hour basis, seven (7) days per week throughout the calendar year, except during designated maintenance periods. The Exchange shall provide reasonable notice to Users of any scheduled maintenance windows that may impact Platform availability.

Security And Resilience Requirements

The Company shall implement and maintain comprehensive security systems and operational controls to ensure Platform integrity and resilience. This encompasses advanced safeguards against cyber threats, data breaches, and technical failures that could compromise Platform operations. The security framework shall be subject to regular assessment and enhancement to address emerging threats.

Testing And Assessment Protocols

Security systems shall undergo regular penetration testing and vulnerability assessments conducted by qualified personnel. These evaluations shall identify potential weaknesses in Platform infrastructure and security controls. The Company shall implement prompt remediation measures to address identified vulnerabilities, maintaining detailed documentation of all testing procedures and outcomes.

Business Continuity Management

The Company shall maintain comprehensive disaster recovery and business continuity plans enabling rapid restoration of Platform operations following major disruptions. These plans shall undergo regular testing and updates to ensure effectiveness. The Company shall maintain adequate technical expertise and staffing levels to ensure continuous Platform monitoring and incident response capabilities. This shall be in compliance with the necessary policies and procedures under Applicable Law.

Incident Notification Requirements

The Company shall implement immediate notification protocols for significant operational incidents. This includes:

System Outages: Prompt notification shall be provided to users and relevant authorities regarding significant system outages or technical failures affecting Platform accessibility or functionality.

Security Incidents: Immediate disclosure shall be made of cyber attacks, data breaches, or security incidents that compromise user assets or information.

Compliance Breaches: The Platform shall provide timely notification of material breaches of Platform Rules or Applicable Law that could impact Platform integrity.

Documentation And Reporting

The Company shall maintain comprehensive documentation of all security protocols, incident responses, and remediation measures. Regular reports shall be generated to assess the effectiveness of security controls and identify areas for enhancement. This documentation shall be available for review by relevant authorities upon request.

This framework ensures maintenance of robust Platform security while providing transparent communication regarding operational incidents. Regular review and updates shall be conducted to reflect evolving security threats and regulatory requirements.

In the event of a major operational disruption, Company may suspend all Platform operations and cancel all Open Orders. Trading shall resume only when the underlying cause has been identified and resolved and an orderly market can be restored.

Company shall undertake regular testing and auditing of Platform systems and operations to verify their ongoing compliance with these Rules and Applicable Law.

8.9 Data Privacy

The Company shall implement and maintain a Data Privacy Policy to ensure the security and confidentiality of personal and sensitive information handled during its operations. This policy shall comply with applicable data protection laws and regulations, including the General Data Protection Regulation (GDPR) and Applicable Law where applicable. It shall outline measures for the collection, storage, processing, and disposal of data, ensuring its protection against unauthorized access, loss, or misuse. The policy shall also include procedures for handling data breaches, obtaining necessary consents, and conducting regular audits to maintain compliance.

8.10 On Principal Adverse Impact relating to climate and environment

Platform shall make publicly available, in the hyperlink related to the principal adverse impacts on the climate and other environment-related adverse impacts of the consensus mechanism used to issue each Crypto-Asset in relation to which they provide services. That information would be obtained from the white papers

8.11 Outsourcing

Outsourcing shall not result in the delegation of responsibilities, alter relationships with clients, modify authorization conditions, or hinder supervisory authorities’ ability to oversee activities. The Platform shall retain the expertise and resources to evaluate, supervise, and manage outsourced services effectively, while ensuring that data protection standards of the Applicable Law are upheld.

The Platform shall ensure that outsourcing arrangements are managed effectively. This includes conducting detailed assessments to evaluate the risks and necessity of outsourcing, performing due diligence to confirm the suitability of third parties, and formalizing contracts that clearly define the rights and obligations of all parties involved. The Platform shall also monitor and review outsourced functions regularly to ensure compliance with regulatory and performance standards.

The Platform shall maintain an outsourcing policy providing for contingency plans and exit strategies for outsourced functions. These strategies shall ensure the continuity and quality of services in the event of unexpected termination or disruption of outsourcing arrangements. Plans shall be updated regularly and include measures to minimize risks associated with potential disruptions.

The Platform shall keep comprehensive and up-to-date records of all outsourcing arrangements. These records shall include details of risk assessments, due diligence reports, contractual agreements, and ongoing performance evaluations. Proper documentation shall ensure transparency and facilitate regulatory compliance.

The Platform shall ensure that third parties involved in outsourcing arrangements cooperate fully with the competent authorities. This shall include granting access to relevant information and enabling supervisory authorities to perform on-site inspections as required to ensure adherence to all applicable regulations.

8.12. ORDER RECEPTION AND TRANSMISSION POLIC

Regulatory Compliance Foundation

The Platform maintains comprehensive compliance with regulatory requirements governing the reception and transmission of Crypto-Asset orders on behalf of Users in the form of a written policy maintained by the Platform. The Platform implements sophisticated technological systems and operational procedures ensuring immediate Order logging with precise timestamping. Orders undergo sequential processing according to strict time priority, with prompt routing to appropriate execution venues. The Platform maintains complete audit trails documenting all Order handling steps while providing real-time status monitoring. All Orders receive immediate transmission through secure encrypted channels, incorporating complete Order specifications as provided by clients. The Platform ensures transmission execution without undue delay, maintaining adherence to best execution principles throughout the process. The Platform does not receive payments, remuneration, or discounts from trading venues or other service providers in exchange for Order routing. Non-monetary benefits or incentives that could influence routing decisions are strictly forbidden. The Platform bases routing decisions exclusively on best execution criteria, client instructions, prevailing market conditions, and technical capabilities of execution venues.

The Platform implements rigorous safeguards protecting client Order information, including strict access controls, comprehensive system monitoring, and regular staff training. Employees must execute confidentiality agreements covering Order information and are prohibited from utilizing pending Order information for benefit. The Platform maintains mandatory compliance training programs and implements clear protocols for handling sensitive information.

9. LIMITATION OF LIABILITY

Liability Acknowledgment

The Platform explicitly acknowledges its liability and responsibility for losses, damages, or other adverse consequences arising from specific operational failures, misconduct, or breach of obligations as defined herein. This acknowledgment of liability shall apply notwithstanding any other provisions limiting Platform liability.

The Platform shall assume liability for losses or damages arising from document mishandling, including loss, destruction, or unauthorized alteration of client documentation. The Platform accepts responsibility for any misrepresentations or misleading statements made by the Platform in connection with its services or operations.

The Platform acknowledges liability for acts, errors, or omissions resulting in breaches of legal and regulatory obligations, including the fundamental obligation to act honestly, fairly, and professionally in client dealings. This extends to breaches of confidentiality obligations and failures to maintain appropriate conflict of interest prevention procedures.

The Platform assumes responsibility for losses arising from business disruption or system failures that impact service provision or client assets. In cases involving custody services, the Platform acknowledges liability for gross negligence in safeguarding client Crypto-Assets and funds, maintaining appropriate security measures and controls.

The Platform explicitly accepts liability as prescribed under Applicable Law regarding its obligations toward clients. This includes responsibility for losses arising from unauthorized transactions, security breaches, or other operational failures within the Platform's control.

Limitation Exclusions

Except for those liabilities explicitly acknowledged in the preceding section, the Platform excludes all other liabilities, obligations, and responsibilities, whether in contract, tort, negligence, breach of statutory duty, or otherwise arising. This exclusion encompasses any indirect, special, incidental, or consequential damages, including but not limited to loss of profits, loss of business opportunity, loss of data, or trading losses arising from market volatility or external market conditions.

The Platform explicitly disclaims liability for losses arising from market conditions, including price volatility, liquidity constraints, or market disruptions beyond the Platform's direct control. Users acknowledge that Crypto-Asset trading involves inherent risks, and the Platform shall not be liable for trading losses incurred through regular market operations.

The Platform bears no liability for losses, damages, or disruptions arising from third-party actions, including but not limited to changes in underlying blockchain protocols, actions by other market participants, or decisions by regulatory authorities. This exclusion extends to circumstances involving force majeure events, regulatory changes, or market-wide disruptions.

Subject to the Platform's explicit acknowledgment of liability for system failures, the Platform excludes liability for technical limitations, including network latency, display delays, or other technical constraints inherent in digital asset trading systems. Users acknowledge these technical limitations as inherent aspects of Crypto-Asset trading infrastructure.

These liability exclusions shall be enforced to the maximum extent permitted by applicable law and regulatory requirements. Where complete exclusion of any liability is prohibited by law, such liability shall be limited to the minimum extent required by applicable regulations.

This exclusion of liability operates in conjunction with, and subject to, the Platform's explicit acknowledgment of specific liabilities as required by ESMA and MiCA regulations.

10. USER COMPLAINTS

The Platform shall implement accessible complaint submission channels, accepting submissions through electronic and written means. Complaints may be submitted in any language used for Platform marketing or communication, or in official EU languages of relevant Member State. All complaint handling services shall be provided free of charge. Complaints may be submitted using the standard template available on the link

Submissions may be made via:

- Email:
- Online Portal: eXchange1.com

The Platform shall acknowledge receipt of all complaints promptly, providing complainants with relevant contact details, timeline expectations, and confirmation of admissibility. Investigation procedures shall incorporate thorough assessment of all relevant information while avoiding unnecessary requests to complainants. The Platform shall maintain continuous communication regarding complaint status and promptly address any requests for clarification.

The Platform shall provide comprehensive written responses addressing all aspects of complaints within two months of receipt. Where exceptional circumstances necessitate extended resolution timeframes, the Platform shall provide clear justification for delays. Responses shall maintain consistency with previous similar cases or provide explicit reasoning for any deviation. All communications shall employ clear, comprehensible language in the complainant's chosen submission language.

The Platform shall maintain secure electronic records of all complaints, including detailed documentation of investigation steps, decisions, and response timelines. Regular analysis of complaint data shall be conducted to identify trends, assess handling effectiveness, and implement necessary improvements. The Platform shall generate periodic reports analyzing complaint volumes, processing times, and resolution outcomes.

The Platform shall dedicate sufficient resources to ensure effective complaint handling, including appropriately trained personnel with access to relevant information systems. Management shall maintain active oversight of complaint handling procedures through regular review of implementation effectiveness and improvement measures. The Platform shall conduct periodic reviews of this framework to ensure continued regulatory compliance and operational effectiveness.

11. MISCELLANEOUS

Company reserves the right to amend or supplement these Rules at any time in its sole discretion to promote fair and orderly trading, safeguard User assets and information, ensure compliance with Applicable Law, or for any other legitimate reason.

By continuing to access and use the Platform after any amendment to these Rules takes effect, a User is deemed to accept the revised Rules. Users who object to any amendment may terminate their Platform access and close their account.

These Rules and their implementation shall be overseen by Chief Compliance Officer of the Company in coordination with other control functions and under the overall supervision of the firm's management body.

Company shall periodically review and audit Platform operations to verify ongoing compliance with these Rules and Applicable Law, promptly addressing any deficiencies.

ANNEX I: ORDER RECORD-KEEPING AND REPORTING

ORDER RECORDS

Comprehensive records of all client orders, including:

¾ Order type (e.g., Market Order, Limit Order, Stop Order).

¾ Order status (e.g., pending, executed, canceled, or modified).

¾ Timestamps for order creation, modification, and cancellation.

¾ Additional execution conditions such as time-in-force parameters.

PRE-TRADE AND POST-TRADE TRANSPARENCY RECORDS

The Platform shall ensure detailed pre-trade and post-trade transparency records, which shall be disaggregated. Data will be provided in following form:

Description of Trading Systems and Related Information

	Continuous Auction Order Book Trading System	A system operating via an order book and trading algorithm without human intervention, matching sell orders with buy orders based on the best available price continuously.	The aggregated number of orders and the Crypto-Assets they represent at each price level for at least the five best bid and offer price levels.
Quote-Driven Trading System	A system where transactions are concluded on the basis of firm quotes continuously made available to participants.	The best bid and offer by price of each participant in Crypto-Assets traded on the system, along with the volumes associated with those prices.
Periodic Auction Trading System	A system matching orders based on periodic auctions and a trading algorithm operated without human intervention.	The price at which the auction trading system would best satisfy its trading algorithm for Crypto-Assets and the volume potentially executable at that price.
Automated Market Makers	A system relying on liquidity pools and mathematical pricing and valuation models for automatic transaction execution.	(i) The mathematical equation used to determine price and quantity of Crypto-Assets in liquidity pools; (ii) the level of liquidity in the pool at any moment; and (iii) any additional information for determining the price of specific orders.
Hybrid Trading System	A system combining two or more trading system types (e.g., those listed above).	For simultaneous combinations, the requirements match those applicable to each system. For sequential combinations, the requirements depend on the active system at a given time.
Other Trading Systems	Any other type of trading system.	Adequate information on the level of orders or quotes and trading interests in Crypto-Assets, especially the five best bid and offer price levels and/or two-way quotes from market makers.

	{ALPHANUM-n}	Up to n alphanumeric characters	Free text field.
{CUR RENCY CODE _3}	3 alphanumeric characters	3-letter currency code as per ISO 4217.
	ISO 8601 date and time format	Date and time formatted as YYYY-MM-DDThh:mm:ss.ddddddZ, recorded in UTC.
{DEC IMAL-n/m}	Decimal number	Numerical field with up to n total digits, m of which can be fractional.
{MIC}	4 alphanumeric characters	Market identifier as per ISO 10383.

	Submission Date and Time	Date and time when the order or quote was introduced into the trading system.
Crypto-Asset Identification Code	Unique identifier of the Crypto-Asset in line with regulatory requirements.	Defined per delegated regulations.
Crypto-Asset Full Name	Full name of the Crypto-Asset.	{ALPHANUM-350}
Buy-Sell Indicator	Indicates whether the order is a buy or sell.	'BUYI' – Buy; 'SELL' – Sell
Price	The price of orders and quotes, excluding commissions and accrued interest.	{DECIMAL-18/13} or {DECIMAL-11/10} depending on expression type.
Price Currency	Currency in which the trading price is expressed.	Defined per ISO standards and delegated regulations.
Price Notation	Indicates if the price is in monetary value, percentage, yield, or basis points.	'MONE', 'PERC', 'YIEL', 'BAPO'.
Quantity	Number of units or nominal/monetary value of the Crypto-Asset.	{DECIMAL-18/17} for units; {DECIMAL-18/5} for nominal/monetary value.
Quantity Currency	Currency in which the quantity is expressed.	Defined in the delegated regulation.
Quantity Notation	Indicates if the quantity is in units, nominal value, or monetary value.	'UNIT', 'NOML', 'MONE', '{CRYP}'.
Venue	Identification of the Crypto-Asset trading platform where the order was submitted.	{MIC}
Number of Orders/Quotes	Aggregated number of orders/quotes for Crypto-Assets.	{DECIMAL-18/0}
Trading System	Type of trading system used.	'CLOB', 'QDTS', 'PATS', 'HYBR', 'AMMS', 'XXXX'.
Publication Date and Time	Date and time when information was published.

Field Identifier	Content to be Reported	Formats and Standards
Trading date and time	Date and time when the transaction was executed.
Crypto-asset identification	Unique identifier of the Crypto-Asset in accordance with specified regulation (Article 68(10) of Regulation (EU) 2023/1114).	Populated per specific guidelines.
Crypto-asset full name	Full name of the Crypto-Asset.	{ALPHANUM-350}
Price	Traded price of the transaction, excluding commission and accrued interest. If traded in a currency pair, the price reflects the quote currency for one unit of the base currency.	{DECIMAL-18/13} if expressed in monetary value.
Missing price	If price is not available or applicable, use predefined codes: 'PNDG' (pending) or 'NOAP' (not applicable).	PNDG / NOAP
Price notation	Indicates how the price is expressed: monetary value, percentage, yield, or basis points.	MONE, PERC, YIEL, or BAPO.
Price currency	Currency in which the trading price is expressed. For currency pairs, the base currency is listed first, and the quote currency determines the price.	Per ISO and DTI standards.
Quantity	Executed quantity of Crypto-Assets.	{DECIMAL-18/17} for units, {DECIMAL-18/5} for monetary/nominal value.
Quantity currency	Currency in which the quantity is expressed. Applicable when denominated in monetary value or Crypto-Asset units.	As specified in relevant regulation.
Quantity notation	Indicates how the quantity is expressed: number of units, nominal value, or monetary value.	UNIT, NOML, MONE, or CRYP.
Venue of execution	Identifier of the trading platform where the order was executed.	{MIC} – Segment or operating MICs.
Publication date and time	Date and time when the transaction was published.
Venue of publication	Code used to identify the trading platform publishing the transaction.	{MIC}
Transaction identification	Alphanumerical code assigned to reference the specific trade.	{ALPHANUM-52}

Symbol	Data Type	Definition
{ALPHA NUM-n}	Up to n alphanumerical characters	Free text field.
{CURR ENCY CODE_3}	3 alphanumerical characters	3-letter currency code, as defined by ISO 4217 currency codes.
	ISO 8601 date and time format	Date and time in the following format: YYYY-MM-DDThh:mm:ss.ddddddZ. Details: 'YYYY' is the year; 'MM' is the month; 'DD' is the day; 'T' indicates the separator; 'hh' is the hour; 'mm' is the minute; 'ss.dddddd' is the second and fractional seconds; 'Z' is UTC.
{DECIMAL -n/m}	Decimal number of up to n digits in total, of which up to m digits can be fractional	Numerical field for positive and negative values. Decimal separator is '.' (full stop); negative numbers prefixed with '-' (minus). Values are rounded, not truncated.
{MIC}	4 alphanumerical characters	Market identifier as defined in ISO 10383.

Flag Name	Description
CANC	Cancellation flag: Indicates that a previously published transaction has been cancelled.
AMND	Amendment flag: Indicates that a previously published transaction has been amended.

Records related to active investigations, audits, or disputes shall be preserved until the conclusion of such proceedings or as required by relevant regulations.

Records must be stored in a secure and durable medium that ensures:

Immediate accessibility upon request by competent authorities.

Readability and usability throughout the retention period.

Protection against unauthorized alterations, deletions, or destruction.

Backup and disaster recovery systems shall be implemented to safeguard all records. These systems must enable data restoration within specified Recovery Time Objectives (RTO) and Recovery Point Objectives (RPO).

Records shall be maintained in standardized formats that facilitate interoperability and regulatory review, such as ISO-compliant formats for data reporting.

The Platform shall submit detailed and timely reports to competent authorities as required under Applicable Law. These reports shall include:

Aggregated order data reflecting market activity and liquidity conditions.

Reports on suspicious transactions identified under AML/CTF policies.

Trade and transaction summaries in standardized formats prescribed by competent authorities.

Periodic summaries (e.g., monthly or quarterly) may be required, depending on regulatory guidelines.

Immediate incident reports shall be filed for material events, such as security breaches or significant operational disruptions.

The Platform shall conduct periodic audits of its record-keeping and reporting systems to ensure compliance with this Annexure and regulatory requirements.

Audits shall include:

Verification of record completeness and accuracy.

Assessment of data security measures and access controls.

Evaluation of reporting timeliness and adherence to prescribed formats.

Findings from audits shall be documented, and corrective actions shall be implemented promptly to address identified deficiencies.