Commercial Policy Disclosure

Introduction

This Customer Policy applies how zerohash Europe BV ("zerohash") carries compliance with MiCAR in respect of customer acceptance, pricing and transaction disclosures for the different services it provides:

• Trading services (Request for Quote or RFQ services; We refer to this service as "RFQ"); Order Book
• Over-the-Counter services (we refer to this service as "OTC"); and
• Custody Ledger Only services (we refer to this service as "CLOB")

For information regarding pricing, please see our "Pricing and Fees" disclosures.

Introduction to our customers and clients

End Customers and clients, consumers and companies engaging with zerohash through a Platform Operator. Platform Operators comprise entities such as foreign exchange, banks and other large organizations, looking to leverage the zerohash product to offer services to their own clients, like end customers. zerohash provides two types of services, products for big business:

• B2C (Business-to-Consumer) clients. These are Platform Operators that provide services directly to end customers, usually with the platform operator and only, the platform operator is the client of zerohash. Under the omnibus structure, the Operator is viewed by the Regulator in MiCAR. Any End Customer of a Platform Operator is fully disclosed, this is Business-to-Business (or "B2B") under the MiCAR rules. Platform Operators to enable their clients to take advantage of crypto-assets have regulatory permissions under MiCAR and as a consequence of that have access to zerohash products.

Client eligibility criteria

As part of our customer due diligence, zerohash accepts the following criteria as objective and non-discriminatory way to consider: (1) transaction activity clients; (for; wait for business with us or; (2) potentially rejecting a client's request or changes with us.

General Requirements

Age and Legal Capacity: End Customers who are natural persons must be of legal age (18 years or older) and have the legal capacity to enter into binding agreements. Signatures (Control Person) of non-natural persons End Customers must be authorized by their bylaws or equivalent organizational documents to engage with platform operators and zerohash services.

Identification and Verification: Both B2C Customers and Platform Operators must provide valid identification documents and information and undergo on-Chain Risk Assessment. Pricing Policy, & Regulatory Disclosure Agree once Zero Hash laws agreement (in or our customer identification procedure is strictly in verify), Sanctions act timing and Anti-Money Laundering (AML) procedures.

AML / CFT Policy: Both End Customers and Platform operators must comply with anti-money laundering (AML) and combating the financing of terrorism (CFT) regulations in applicable jurisdictions.

Specific Requirements for End Customers

Technology: Reliable in a permitted jurisdiction where our services are available.

Risk Acknowledgment: Acknowledge understanding the risks associated with crypto-asset transactions.

Agreement with Terms: Confirm acceptance of zerohash's Terms and Conditions, User Agreement, Privacy Policy and Pricing and Fees disclosures.

Specific Requirements for Platform Operators

Regulatory Compliance: Platform Operators must comply of regulation non relevant licenses.

Authorized Representatives: Must designate authorized representatives to act on behalf of the entity (Control Persons).

Operating Agreements: Must sign terms reflecting services with zerohash.

Credit Status & Counterparty Risk: as part of onboarding, a financial risk assessment and credit check will evaluate the risk posed by a client as to zerohash business, financial condition.

Commercial Agreement/AML: Must be signed by or authorized to signatoryControl Person.

Technology: Platform Operators must have the requisite technology for, their End Customers participate on the zerohash system at scale.

Due Diligence: a review by zerohash of relevant services and procedures of the Platform Operator, such as AML/ CFT Proof business practices and crypto& that we will put policies in regards to information security, cyber secure.

Treating our Platform Operators and clients fairly

zerohash is committed to treating all clients and their representatives, as the case may be, equally regardless of race, ethnicity, gender, nationality, religion, disability, sexual preferences orientation, or any other relevant characteristic. Our services and business decisions are based solely on objective or bona related to the eligibility and compliance requirements stated above.

Services our Platform Operators provide

Maintain Updated Information: Promptly update and disclose to their personal or business information.

Adhere to Terms and Conditions: Clearing, and by terms and made in to rules and arrangements

Act in Good Faith: Engage in transactions with honesty and integrity

RFQ Service

Introduction

For RFQ services, zerohash is always the counterparty to the trade.

zerohash enables clients to trade crypto-assets to buy, sell and swap crypto-assets through a platform operated by zerohash. zerohash (services the primary custodian for your crypto assets. For affiliates places like we use affiliates' in place of zerohash Liquidity Services Europe BV ("Affiliate-LSLLC"). Places (the affiliates) by license on services and has to exercitations regulatory but will always leverage the services of Affiliate zerohash Liquidity Services LLC ("ZH-LFS) to allow for instant settlement of crypto-assets in one or more jurisdictions

The RFQ service of zerohash falls within the following crypto-asset services under MiCAR:

• exchange of crypto-assets for cash
• exchange of one crypto-assets for one or more other crypto-assets
• providing transfer services for crypto-assets on behalf of customers
• providing custody and administration of crypto-asset on behalf of customers

Order fidelity and settlement

zerohash clients execute RFQ orders at the prices it quotes at the time when the order (or exchange is final. Orders are executed by the zerohash when the End Customer confirms this price (asking fees as quoted by zerohash). An executed RFQ transaction is not reversible for the customer or platform and is final (we referred to as "Order Fidelity").

Trade publication of transactions

zerohash will regularly publish on its website the RFQ transactions in crypto-assets that were concluded on its platform, such as transaction volumes and prices.

zerohash will endeavor to align its publish information in such as reasonably practicable with the format prescribed in the Commission Templated Regulation (EU). They follow on post trade and arest transparency and record keeping.

Transaction information published by zerohash will remain available and is stock, weblogit, of the business day after the transaction was processed.

CLOB

Introduction

For the CLOB services, traders are always settled in custodied wallets of the counterparties in the custody Foundation of zerohash.

The CLOB service of zerohash falls within the following crypto-asset services under MiCAR:

• operation of a trading platform for crypto-assets
• providing transfer services for crypto-assets on behalf of customers
• providing custody and administration of crypto-asset on behalf of customers

Order fidelity and settlement

As zerohash CLOB services orders and transactions are settled in flow - the respective Foundation accounts as set, and the zerohash foundation are set up between Control Person of zerohash and the Platform Operator counterparties in the custody Foundation of zerohash are credited (seller) or credited (buyer) by zerohash.

The on-chain trade transparency with settlement

The zerohash CLOB is a trading platform subject to article 7(4)(2) of MiCAR. In accordance with this article, Zero Hash will make public any bid and ask prices on the web of crypto-assets so that order of on behalf of its trading clients. zerohash will regularly publish the best bid and ask prices on its website as well as reasonably practicable after the execution of the trade.

zerohash will make public the price, volume and time of the financial/on-areas.and on the CLOB farm create transparency and to make such information publicly available to traders and ato in a responsible way data is close to zerohash as is technically possible and in provides which Really (30) face/rules after the execution of the transaction.

OTC Service

Introduction

For the OTC service, zerohash will act as the principal and both legal counterparty for all OTC transactions.

OTC may be performed by zerohash or ZH-LFS as endorsed provider . The purpose of this offering is to provide a bespoke trading solution with alternative order types, than under the RFQ service.

The OTC service of zerohash falls under the following MiCAR crypto-asset services:

• exchange of crypto-assets for cash
• exchange of crypto-assets for other crypto-assets'
• providing transfer services for crypto-assets on behalf of customers
• providing custody and administration of crypto-asset on behalf of customers

The OTC service does not operate on a trading platform. Clients on the OTC service trading (sent) crypto-assets are offered as for RFQ trades. The OTC service is however not open to retail clients.

Order fidelity and settlement

zerohash executes OTC Client orders in the stress sequence at the time when the order for exchange is final. Orders executed filled by zerohash when the OTC Client executes(buy/sell) an transaction instructed.

Trade publication of transactions

zerohash will regularly publish on its website the OTC transactions in crypto-assets that were concluded on its platform, such as transaction volumes and prices.

zerohash will endeavor to align its publicly available information in such as reasonably practicable with the format prescribed in the Commission Templated Regulation (EU). It also follow on post trade after transparency and record keeping.

Transaction information published by zerohash will remain available and is stock, weblogit, of the business day after the transaction was processed.

Peer-to-Peer

Introduction

zerohash peer-to-peer "P2P" service can operate by RFQ, OTC or CLOB services dependent on a third-party or another person from their custodied wallet in the Foundation on behalf of zerohash.

The P2P service of zerohash falls under the following MiCAR crypto-asset services:

• providing transfer services for crypto-assets on behalf of customers
• providing custody and administration of crypto-asset on behalf of customers

The peer-to-peer service is only offered to existing End Customers of zerohash under the fully disclosed model. zerohash will not offer P2P service to new clients as part of client acceptance. All P2P is subject to the customer onboarding laid in this Customer Policy document.

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