Order execution policy

1. Purpose

This Policy has been prepared with the aim of ensuring that the processes of receiving, matching, executing and recording the orders of customers of Paribu Kripto Varlık Alım Satım Platformu A.Ş. (Paribu Crypto Asset Trading Platform Inc.) ("Paribu") concerning crypto asset trading transactions are carried out in a reliable, transparent, effective, stable, fair, honest and competitive manner, and of establishing the principles that will ensure the detection, prevention and non-recurrence of acts and transactions of a market-distorting nature.

2. Scope and Basis

This Policy covers all customer orders on the Paribu platform; it has been prepared on the basis of the Capital Markets Law No. 6362, the Communiqués No. III-35/B.1 and No. III-35/B.2, the Communiqué No. VII-128.10 on Information Systems, the regulations of the Capital Markets Board (SPK) and Paribu's code of ethics.

3. Definitions

• Paribu: Paribu Kripto Varlık Alım Satım Platformu A.Ş.
• Customer: All natural and legal persons, and entities without legal personality, to whom Paribu provides services.
• Wallet: Software, hardware or applications that enable the transfer of crypto assets and the storage of those assets or of the private and public keys related to those assets.
• Transfer: The transfer of crypto assets to other wallets via distributed ledger technology.
• API: Application Programming Interface.
• KYC: The Know Your Customer process.
• MKK: Merkezi Kayıt Kuruluşu A.Ş. (Central Securities Depository).
• Law: Capital Markets Law No. 6362.
• SPK: Sermaye Piyasası Kurulu (Capital Markets Board).
• Price Monitoring Unit: The Risk Management System unit responsible for examining transactions and behaviour that cannot be explained on reasonable and economic grounds in relation to assets listed on the platform whose price is formed in Türkiye, and for detecting market-distorting acts and transactions.
• Communiqué No. III-35/B.1: The Communiqué on the Principles Regarding the Establishment and Operation of Crypto Asset Service Providers.
• Communiqué No. III-35/B.2: The Communiqué on the Working Procedures and Principles and Capital Adequacy of Crypto Asset Service Providers.

4. General Principles

4.1. Receiving Customer Buy/Sell Orders

Paribu is obliged to execute customer orders in a manner that produces the best possible result for the customer, taking into account the customer's preferences regarding price, cost, speed, likelihood of execution, settlement, size, custody and similar matters, within the framework of the principles set out in the Framework Agreement.

4.1.1. Order Types

Only the following order types are accepted on the Paribu platform:

1. Buy Order: An order submitted to purchase a crypto asset.
2. Sell Order: An order submitted to sell a crypto asset.
3. Transfer Order: An order submitted for a crypto asset to be transferred to another wallet.

The following sub-types apply to buy and sell order types:

1. Market Order: The order submitted by the customer is attempted to be executed immediately at the prices currently valid in the market. No price is specified in the order; it is the order type in which speed is the priority. Such orders may be created by the customer by specifying only the quantity. Depending on the order amount, the transaction may be executed not at a single price but progressively at different price levels.
2. Easy Buy - Easy Sell Order: An order that is filled from the own wallet of Paribu or of an authorised market maker at the market price.
3. Limit Order: An order created by the customer by setting a price and a quantity. Limit orders are executed only at the determined price level or at a more favourable price.
4. Conditional Limit Order (Stop-Limit): Two price levels are set by the customer: the trigger price and the limit price. When the determined trigger price is reached, an order is created automatically at the determined limit price and is processed in the same way as an ordinary limit order.
5. Conditional Market Order (Stop-Market): A trigger price is set by the customer. When the determined trigger price is reached, the order is attempted to be executed immediately at the market price at that moment.
6. Post Only (Add Only or Cancel): The order is added to the order book only as a market maker; if it would match immediately, it is cancelled in its entirety. The main purpose of this order is to benefit from the commission advantage arising from being a market maker.
7. FOK (Fill or Kill): Used when the customer wants the order either to be executed in full or not at all. It is preferred in cases where partial fills are to be avoided.
8. IOC (Immediate or Cancel): The order is executed to the extent of the quantity that can be filled at the moment it is submitted. The portion that cannot be filled does not enter the order book and is cancelled automatically.
9. OCO (One Cancels the Other): An order in which a take-profit and a stop-loss order are submitted together, and the triggering of one automatically cancels the other. A trigger price and then a limit or market order are set for both orders.

4.1.2. Order Validity Periods

Orders remain registered in the system until they are executed; Paribu may set a validity period for orders, provided that this is announced.

As an exception to this general rule, FOK, IOC and Post Only orders are evaluated instantaneously; the portions that cannot be filled are cancelled automatically and are not held in the system as pending orders. Conditional Limit Orders and Conditional Market Orders wait passively for an indefinite period until the trigger price is reached; once triggered, the resulting order becomes subject to the validity principles of its own type. In an OCO order, when one side is executed or triggered, the other is cancelled automatically without waiting for any period.

4.1.3. Order Acceptance Principles

Customers may submit their orders only via the Paribu website at https://www.paribu.com/, the mobile application or the API; order submission via any channel other than those specified (telephone, physical forms, etc.) is not accepted. For customers opening an account for the first time, the KYC process and MKK registration procedures must have been completed.

An order number is assigned to each accepted order, the order is signed by the system with a time stamp, and the valid order is either executed by being matched in accordance with the transaction and priority rules or is recorded in the order book.

The following information is recorded for each order:

1. The customer numbers or account numbers of the party submitting the order and of the matching party,
2. Crypto asset subject to the transaction,
3. Order type,
4. Order direction (Buy/Sell),
5. Order price,
6. Order trigger price,
7. Order quantity,
8. Date and time the order was received,
9. Date and time the order was executed,
10. Validity period of the order,
11. Sequence number of the order,
12. Currency or trading pair in which the transaction will be carried out.

4.1.4. Matching of Orders

Orders are matched in a fair and transparent manner by the automatic order matching engine integrated into the Paribu system, in accordance with the price and time priority rules.

1. Measures may be taken against the matching of buy and sell orders belonging to the same customer or to related accounts that would fill one another; this matter is monitored by the Price Monitoring Unit in order to prevent artificial volume.

4.1.5. Cancellation of Orders

Customers may cancel their orders that have not yet been executed; in the event of partial execution, only the remaining portion is cancelled. Conditional orders may be cancelled before they are triggered.

The specific principles regarding the cancellation of FOK, IOC, Post Only, Conditional Limit, Conditional Market and OCO orders are set out in Article 4.1.2 (Order Validity Periods) of this Policy.

4.1.6. Order Status Notification

Customers are informed in real time via the Paribu platform of the status of the orders they have submitted:

1. Open: Awaiting matching.
2. Successful: The order has been fully executed.
3. Partially Successful: A portion of the order has been executed.
4. Unsuccessful: The order could not be executed.
5. Cancelled: The order has been cancelled.

4.1.7. Principles for the Modification and Cancellation of Orders

As there is no order modification flow, a customer wishing to modify an order cancels the existing order and submits a new one. In extraordinary situations not originating from Paribu, pending or executed orders may be modified or cancelled. Erroneous orders may be cancelled by the customer until they are executed. In cases such as extraordinary price movements, technical failures or network problems, transactions may be suspended temporarily and orders may be put on hold.

4.1.8. Price Steps to be Applied to Orders Submitted and Principles for Price Display of Crypto Assets to be Listed

1. Price Steps: The price steps to be applied to orders are determined separately for each asset.
2. Price Display: The necessary monitoring activities are carried out to ensure that the opening price of crypto assets to be listed for the first time is formed in line with global market prices.

4.2. Receiving Buy/Sell Orders of Customers Engaged in Market-Making Activities

Market Makers are customers who contribute to price formation and market depth by regularly providing two-sided quotations on the Paribu platform. They are expected to comply with the following standards:

1. They must submit orders only for genuine trading purposes; any market-distorting activity is strictly prohibited. Technical limits applicable to Market Makers (minimum time on the platform, cancellation rate, order frequency, etc.) are determined by decision of senior management; compliance is monitored regularly and reported to the Board of Directors.
2. Market Makers are obliged to meet the spread, depth and activity criteria determined by written agreements; performance is monitored regularly and the necessary measures/sanctions are determined.

4.3. Receiving Buy/Sell Orders of Customers Engaged in Liquidity Provision Activities

Liquidity Providers are customers who bring depth and continuity to the market by regularly submitting orders and by operating with high-frequency strategies.

1. They are obliged to submit their orders in a manner that will not be the subject of market-distorting activity and for genuine trading purposes; their order behaviour is monitored by the Price Monitoring Unit.
2. Technical limits are determined by decision of senior management; compliance is monitored regularly and reported to the Board of Directors.
3. Liquidity Providers are obliged to meet the spread, depth and activity criteria determined by written agreements; performance is monitored regularly and the necessary measures/sanctions are determined.

1. Purpose

This Policy has been prepared with the aim of ensuring that the processes of receiving, matching, executing and recording the orders of customers of Paribu Kripto Varlık Alım Satım Platformu A.Ş. (Paribu Crypto Asset Trading Platform Inc.) ("Paribu") concerning crypto asset trading transactions are carried out in a reliable, transparent, effective, stable, fair, honest and competitive manner, and of establishing the principles that will ensure the detection, prevention and non-recurrence of acts and transactions of a market-distorting nature.

2. Scope and Basis

This Policy covers all customer orders on the Paribu platform; it has been prepared on the basis of the Capital Markets Law No. 6362, the Communiqués No. III-35/B.1 and No. III-35/B.2, the Communiqué No. VII-128.10 on Information Systems, the regulations of the Capital Markets Board (SPK) and Paribu's code of ethics.

3. Definitions

• Paribu: Paribu Kripto Varlık Alım Satım Platformu A.Ş.
• Customer: All natural and legal persons, and entities without legal personality, to whom Paribu provides services.
• Wallet: Software, hardware or applications that enable the transfer of crypto assets and the storage of those assets or of the private and public keys related to those assets.
• Transfer: The transfer of crypto assets to other wallets via distributed ledger technology.
• API: Application Programming Interface.
• KYC: The Know Your Customer process.
• MKK: Merkezi Kayıt Kuruluşu A.Ş. (Central Securities Depository).
• Law: Capital Markets Law No. 6362.
• SPK: Sermaye Piyasası Kurulu (Capital Markets Board).
• Price Monitoring Unit: The Risk Management System unit responsible for examining transactions and behaviour that cannot be explained on reasonable and economic grounds in relation to assets listed on the platform whose price is formed in Türkiye, and for detecting market-distorting acts and transactions.
• Communiqué No. III-35/B.1: The Communiqué on the Principles Regarding the Establishment and Operation of Crypto Asset Service Providers.
• Communiqué No. III-35/B.2: The Communiqué on the Working Procedures and Principles and Capital Adequacy of Crypto Asset Service Providers.

4. General Principles

4.1. Receiving Customer Buy/Sell Orders

Paribu is obliged to execute customer orders in a manner that produces the best possible result for the customer, taking into account the customer's preferences regarding price, cost, speed, likelihood of execution, settlement, size, custody and similar matters, within the framework of the principles set out in the Framework Agreement.

4.1.1. Order Types

Only the following order types are accepted on the Paribu platform:

1. Buy Order: An order submitted to purchase a crypto asset.
2. Sell Order: An order submitted to sell a crypto asset.
3. Transfer Order: An order submitted for a crypto asset to be transferred to another wallet.

The following sub-types apply to buy and sell order types:

1. Market Order: The order submitted by the customer is attempted to be executed immediately at the prices currently valid in the market. No price is specified in the order; it is the order type in which speed is the priority. Such orders may be created by the customer by specifying only the quantity. Depending on the order amount, the transaction may be executed not at a single price but progressively at different price levels.
2. Easy Buy - Easy Sell Order: An order that is filled from the own wallet of Paribu or of an authorised market maker at the market price.
3. Limit Order: An order created by the customer by setting a price and a quantity. Limit orders are executed only at the determined price level or at a more favourable price.
4. Conditional Limit Order (Stop-Limit): Two price levels are set by the customer: the trigger price and the limit price. When the determined trigger price is reached, an order is created automatically at the determined limit price and is processed in the same way as an ordinary limit order.
5. Conditional Market Order (Stop-Market): A trigger price is set by the customer. When the determined trigger price is reached, the order is attempted to be executed immediately at the market price at that moment.
6. Post Only (Add Only or Cancel): The order is added to the order book only as a market maker; if it would match immediately, it is cancelled in its entirety. The main purpose of this order is to benefit from the commission advantage arising from being a market maker.
7. FOK (Fill or Kill): Used when the customer wants the order either to be executed in full or not at all. It is preferred in cases where partial fills are to be avoided.
8. IOC (Immediate or Cancel): The order is executed to the extent of the quantity that can be filled at the moment it is submitted. The portion that cannot be filled does not enter the order book and is cancelled automatically.
9. OCO (One Cancels the Other): An order in which a take-profit and a stop-loss order are submitted together, and the triggering of one automatically cancels the other. A trigger price and then a limit or market order are set for both orders.

4.1.2. Order Validity Periods

Orders remain registered in the system until they are executed; Paribu may set a validity period for orders, provided that this is announced.

As an exception to this general rule, FOK, IOC and Post Only orders are evaluated instantaneously; the portions that cannot be filled are cancelled automatically and are not held in the system as pending orders. Conditional Limit Orders and Conditional Market Orders wait passively for an indefinite period until the trigger price is reached; once triggered, the resulting order becomes subject to the validity principles of its own type. In an OCO order, when one side is executed or triggered, the other is cancelled automatically without waiting for any period.

4.1.3. Order Acceptance Principles

Customers may submit their orders only via the Paribu website at https://www.paribu.com/, the mobile application or the API; order submission via any channel other than those specified (telephone, physical forms, etc.) is not accepted. For customers opening an account for the first time, the KYC process and MKK registration procedures must have been completed.

An order number is assigned to each accepted order, the order is signed by the system with a time stamp, and the valid order is either executed by being matched in accordance with the transaction and priority rules or is recorded in the order book.

The following information is recorded for each order:

1. The customer numbers or account numbers of the party submitting the order and of the matching party,
2. Crypto asset subject to the transaction,
3. Order type,
4. Order direction (Buy/Sell),
5. Order price,
6. Order trigger price,
7. Order quantity,
8. Date and time the order was received,
9. Date and time the order was executed,
10. Validity period of the order,
11. Sequence number of the order,
12. Currency or trading pair in which the transaction will be carried out.

4.1.4. Matching of Orders

Orders are matched in a fair and transparent manner by the automatic order matching engine integrated into the Paribu system, in accordance with the price and time priority rules.

1. Measures may be taken against the matching of buy and sell orders belonging to the same customer or to related accounts that would fill one another; this matter is monitored by the Price Monitoring Unit in order to prevent artificial volume.

4.1.5. Cancellation of Orders

Customers may cancel their orders that have not yet been executed; in the event of partial execution, only the remaining portion is cancelled. Conditional orders may be cancelled before they are triggered.

The specific principles regarding the cancellation of FOK, IOC, Post Only, Conditional Limit, Conditional Market and OCO orders are set out in Article 4.1.2 (Order Validity Periods) of this Policy.

4.1.6. Order Status Notification

Customers are informed in real time via the Paribu platform of the status of the orders they have submitted:

1. Open: Awaiting matching.
2. Successful: The order has been fully executed.
3. Partially Successful: A portion of the order has been executed.
4. Unsuccessful: The order could not be executed.
5. Cancelled: The order has been cancelled.

4.1.7. Principles for the Modification and Cancellation of Orders

As there is no order modification flow, a customer wishing to modify an order cancels the existing order and submits a new one. In extraordinary situations not originating from Paribu, pending or executed orders may be modified or cancelled. Erroneous orders may be cancelled by the customer until they are executed. In cases such as extraordinary price movements, technical failures or network problems, transactions may be suspended temporarily and orders may be put on hold.

4.1.8. Price Steps to be Applied to Orders Submitted and Principles for Price Display of Crypto Assets to be Listed

1. Price Steps: The price steps to be applied to orders are determined separately for each asset.
2. Price Display: The necessary monitoring activities are carried out to ensure that the opening price of crypto assets to be listed for the first time is formed in line with global market prices.

4.2. Receiving Buy/Sell Orders of Customers Engaged in Market-Making Activities

Market Makers are customers who contribute to price formation and market depth by regularly providing two-sided quotations on the Paribu platform. They are expected to comply with the following standards:

1. They must submit orders only for genuine trading purposes; any market-distorting activity is strictly prohibited. Technical limits applicable to Market Makers (minimum time on the platform, cancellation rate, order frequency, etc.) are determined by decision of senior management; compliance is monitored regularly and reported to the Board of Directors.
2. Market Makers are obliged to meet the spread, depth and activity criteria determined by written agreements; performance is monitored regularly and the necessary measures/sanctions are determined.

4.3. Receiving Buy/Sell Orders of Customers Engaged in Liquidity Provision Activities

Liquidity Providers are customers who bring depth and continuity to the market by regularly submitting orders and by operating with high-frequency strategies.

1. They are obliged to submit their orders in a manner that will not be the subject of market-distorting activity and for genuine trading purposes; their order behaviour is monitored by the Price Monitoring Unit.
2. Technical limits are determined by decision of senior management; compliance is monitored regularly and reported to the Board of Directors.
3. Liquidity Providers are obliged to meet the spread, depth and activity criteria determined by written agreements; performance is monitored regularly and the necessary measures/sanctions are determined.