EU Trading Platform Operating Rules

Operating Rules

Introduction

Zero Hash Europe BV ("ZHEU") operates a trading platform for the trading of CLOB supported Crypto-Assets. This document establishes the Operating Rules for the ZHEU trading platform under MiCAR. It applies to all activities and operations of ZHEU related to the trading of Crypto-Assets in the CLOB, defined below.

It addresses the Order types and Execution conditions available, the price and priority rules for trading and the various trading phases. It also addresses cancellation procedures, trading safeguards (pre-trade risk controls) and other trading conditions.

The following set of trading rules governs Orders placed via these markets.

Definitions

Account: The account set up in an End Customer's name for use in relation to the Exchange, created when an End Customer's request for access to and use of the Exchange is granted. Each End Customer's Account may have the following under their Account:(a) Fiat currency balance reflecting the End Customer's fiat currency balance(s); and(b) Crypto-Asset position reflecting the End Customer's sellable amount of Crypto-Asset

AFM: The Dutch Authority for the Financial Markets (Autoriteit Financiële Markten), the competent regulator of ZHEU in the Netherlands

Aggressor: An aggressor is a trader who initiates a trade by placing an order to buy or sell a Crypto-Asset at a specific price. In a buy or sell order on a CLOB, the aggressor is the trader who placed the incoming order that will match with a Passive trader's Order

BBO Midpoint: A reference price that is the midpoint value between the current best buy (bid) and best sell (ask) price

CLOB: Central Limit Order Book, subject to the rules laid down hereunder

Closing Price: The price of a Crypto-Asset at the end of a trading day in the ZHEU CLOB. The end of day is at 00:00 UTC

Crypto-Asset: A CLOB supported MiCAR crypto-asset as made available from time to time on the website of ZHEU here: [link to supported Crypto-Assets on ZHEU website]

End Customer: Any end customer of a Platform Operator granted a right of access to and use of the Exchange, and whose access or use has not been terminated

Exchange: The CLOB operated by ZHEU

Execute or "Executed" or "Execution": Effecting a Trade where Orders have been matched by debiting and crediting the available balance in the relevant End Customer's accounts

Instrument: This refers to the tradable symbol which is a Crypto-Asset and fiat grouping. e.g. BTC/EUR

Liquidity Provider: Market participant and intermediary who ensures that there is an adequate supply of assets for active trading in Crypto-Assets, contracting with ZHEU.

Maker: Trader or Orders that add liquidity to a market by placing orders to buy or sell Crypto-Asset's that are not immediately matched with an opposing order. A Maker or Maker Orders are always the Passive side of an Execution. Makers are also sometimes referred to as "Market Makers" or "Liquidity Providers"

MiCAR: Markets in Crypto-Assets Regulation, Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on markets in crypto-assets

Operating Rules: The rules set out in these operating rules

Order: An Order to buy or sell a quantity of a Crypto-Asset which may be;(a) a bid Order, being an offer to buy; or(b) an offer Order, being an offer to sell

Passive: A Passive trader responds to an Aggressor's Order by placing an opposing Order at the same price. The Passive trader is taking a reactive role in the trade and is looking to fill their order with the Aggressor's order.

Platform Operators: As defined under Clause 4

Settlement Price: The price at which a Crypto-Asset positions are valued. The settlement price will be the last trade price on the CLOB or the ZHEU Index price if there has been no Executions for a period of 5 minutes or greater.

Side: Indicates if an Order is a buy or sell

Taker: Refers to a trader or Order that removes liquidity from a market by filling orders that are already in the order book. A Taker or Taker Orders are always the Passive side of an Execution.

Time In Force: In respect of an Order, the duration applicable to the Order. Further details available below.

Trading Sessions: ZHEU operates the CLOB 24/7 so the Trading Sessions can be;

• 'Pre-Open' which means the Instrument is available for Order entry but Executions can't occur;
• 'Continuous Trading' which means the Instrument is available for trading. Order activity is available or only temporarily restricted;
• 'Close' which means the Instrument is unavailable for trading for an extended period of time with no scheduled re-opening or permanently.

Trading States: This refers to the status of a Crypto-Asset Trading Symbol and the status will impact how Orders are handled when sent to the CLOB.

ZHEU: Zero Hash Europe BV

ZHLS: Zero Hash Liquidity Services LLC

ZHEU Index: ZHEU makes use of a professional third-party data provider to source index values for a wide range of asset pairs. ZHEU uses transaction data from a sample of top exchanges in its calculation. Those exchanges are Bitfinex, Bitstamp, Coinbase Pro, Gemini, HitBTC, Huobi Pro, itBit, Kraken and OKCoin. For each exchange that has trading volume, ZHEU calculates the volume-weighted average price (VWAP) over the preceding hour and then takes the arithmetic mean of this value across all exchanges. If there is no trading activity on any exchange during this period, ZHEU will utilize the last index value.

Status

The latest version of these Operating Rules is published in the English language on the website of ZHEU [link].

The Operating Rules are part of the agreement entered into by the End Customer and ZHEU and must be accepted by an End Customer before accessing the CLOB.

Trading Platform

ZHEU partners with third party platform operators ("Platform Operators") to offer Crypto-Assets to their End Customers. ZHEU facilitates the buying and selling of Crypto-Assets by obtaining Crypto-Asset prices from various Liquidity Providers. The ZHEU order book is then displayed to the End Customer on the Platform Operator's front end (website or mobile app). Any placing or Orders and trading is subject to the terms and rules set out in these Operating Rules.

Participating on the Trading Platform

Objective Criteria for Admission to Trading

Both Platform Operators and End Customers must be accepted as clients in accordance with ZHEU Acceptance, Pricing and Transaction Disclosure available here [link]. No Zero Hash Group entities are admitted nor permitted to trade on the ZHEU trading platform.

How to Apply

End Customers can sign up through a Platform Operator's interface (usually a website or mobile app), and agree to ZHEU's User Agreement and the Platform Operator's Agreement. Either ZHEU itself collects End Customer KYC data, risk rating and geolocation data and reviews and tests it based on risk factors or the Platform Operator collects End Customer KYC data, risk rating and geolocation data, which validates it using a ZHEU-approved vendor and passes the information to ZHEU, which further reviews and tests it based on risk-indicators.

Obligations

Obligations for Platform Operators and/or End Customers are:

• Accept and adhere to the ZHEU Acceptance, Pricing and Transaction Disclosure Policy.
• Compliance with these Operating Rules and the terms and conditions in the User Agreement.
• Platform Operators and End Customers must provide any information ZHEU reasonably needs and promptly update any changes to their personal or business information.
• End Customers must engage in transactions with honesty and integrity.
• Platform Operators are charged a monthly technical support fee, depending on the scale of the Platform Operator.

CLOB

The CLOB at ZHEU allows End Customers of Platform Operators that have enabled the CLOB for their end customers to buy or sell specific Crypto-Assets using various Order types.

To place an Order on ZHEU's CLOB, the End Customer account must have enough available funds to cover the total value of the transaction. Orders may be subject to minimum and maximum Order size requirements, varying per trading pair, to be set by ZHEU at its own discretion, as indicated in the trading environment of the relevant trading pair. Subject to the rights of ZHEU under Clause 12 (Trade Disputes), an End Customer placed Order is a final Order when the available End Customer funds can cover the total value of the potential transaction and the Order is placed in the Order book for matching.

Fees and costs for trading on the CLOB are applicable and are set out in the ZHEU's Acceptance, Pricing and Transaction Disclosure Policy.

The CLOB matches Orders whenever buyers and sellers' Orders overlap: e.g. a Liquidity Provider Order is matched with a Client Order or two different Client Orders are matched. Where there are multiple Orders entered at the same price, the CLOB will implement its Price/Time priority algorithm aimed at prioritizing Orders in a fair and objective way. Matching Orders is prioritized based on 1) the best price, and then 2) the time in which those Orders were submitted.

ZHEU has multiple Liquidity Providers in order to provide quality pricing to End Customers as well to ensure redundancy and consistent trading availability. Order size does impact the ultimate price that the trade is executed at: on a buy Order, larger Orders that exceed the first pricing level quantity are typically filled at an average weighted price that is less than the first pricing level and vice-versa for sells Orders.

Order Types

Limit Order

An Order to buy or sell an Instrument at a specific price or better. A buy limit Order can only be executed at the specified limit price or lower, and a sell limit Order can only be executed at the specified limit price or higher. Limit Orders entered during the continuous trading session are Executed either fully or partially, as market conditions permit.

If the execution of a limit Order is not immediately possible and the Time In Force is Good Til Cancel (GTC) or Good Til Time (GTT), it is placed in the Order book in descending buy-price Order or ascending sell-price Order (the price priority principle) and joins the queue of Orders at the same price (the time priority principle).

Market To Limit Orders

An Order to buy or sell a Crypto-Asset immediately. This type of Order guarantees that the Order will be executed if there is liquidity but does not guarantee the Execution price.

If the market to limit Order fill all the open liquidity, the remainder quantity of the market to limit or will rest on the CLOB as an open limit Order with the price set at the last filled price of the Order.

If no matching Order is available, the Order will be rejected. Unmatched Orders will be rejection immediately with no predetermined wait time in the Order book if there is no matching supply for the Order.

Stop Limit Order

An Order to buy or sell an Instrument that is triggered once the price of the Crypto-Asset reaches a specified price through its last trading price or Settlement Price, known as the stop price. When the stop price is reached, a stop limit Order becomes a limit Order at the specified Order quantity and Order price. An End Customer can specify the reference price they want the stop price to trigger based of.

Time in Force and Order Validity

Good till Cancelled (GTC)

This is an Order to buy or sell a Crypto-Asset that lasts until the Order is fully filled or cancelled.

Immediate or Cancel (IOC)

This is an Order to buy or sell a Crypto-Asset that attempts to Execute all, or part immediately and then cancels any unfilled portion of the Order.

Good till Time (GTT)

This is an Order to buy or sell a Crypto-Asset in respect of which the End Customer selects an expiration date and time up until which the Order will remain in force; or cancel unexecuted Orders at the specified expiration date.

Order Protections

ZHEU has implemented pre-trade risk controls for all incoming Orders. These controls are applicable to all End Customers. The following checks are currently set in place and are configured in the firm's market surveillance system:

Wash Trade Check

A self-trade prevention mechanism is in place to prevent End Customers from Executing against their own Order.

Maximum Order Notional Value

A prevention mechanism that restricts an End Customer from placing an Order over a notional value. The Max Order Notional is 500,000 Euro.

Minimum Order Notional Value

A prevention mechanism that restricts an End Customer from placing an Order below a notional value. The Minimum Order Notional is 1 Euro.

Order Book Matching

Price Time Priority

The CLOB matches Orders whenever buyers' and sellers' Orders overlap. Where there are multiple Orders entered at the same price, the CLOB will implement its price/time priority algorithm aimed at prioritizing Orders in a fair and objective way. Matching Orders is prioritized based on 1) the best price, and then 2) the time in which those Orders were submitted.

Process of Trading on the CLOB

1. Liquidity Providers submit intent to transact Crypto-Asset to the CLOB, specifying basic information such as prices, quantities, and direction of their intent (buy or sell).
2. The CLOB collects all of these active Orders into an Order book.
3. The CLOB then organizes and publishes the Order book to all of its users.
4. In order to consummate a transaction, another party (a Taker) must accept the prices and quantities available on the Order book. The CLOB operator matches the taker's acceptance with the corresponding Orders in the Order book that fulfill the taker's Order at the currently available best prices.

Transparency

The ZHEU Exchange is subject to pre- and post-trade requirements in accordance with MICAR.

To adequately inform End Customers, and the public as the case may be, as mandated by MiCAR, ZHEU makes available pre- and post-trade information to the public here: [link].

This information will be made available free of charge after publication in a machine-readable format and will remain published for at least two years.

ZHEU publishes pre-trade and post-trade transparency data separately as set out below.

All End Customers have full and equal real-time access to market data. Market data is made available through the web interfaces and ZHEU API.

Pre-trade Transparency

ZHEU makes bid and ask prices available during trading hours in line with Commission Delegated Regulation (EU) 2025/417 of 28 November 2024 supplementing Regulation (EU) 2023/1114 of the European Parliament and of the Council with regard to regulatory technical standards specifying the manner in which crypto-asset service providers operating a trading platform for crypto-assets are to present transparency data ("RTS"):

• The aggregated number of orders and the Crypto-Assets that they represent at each price level for at least the five best bid and offer price levels.
• The details of the Orders in accordance with the standard templates in Annex 1 of the RTS.

Post-trade Transparency

ZHEU makes public the details of each transaction executed on the Exchange. ZHEU will disclose the following details as close to real-time as is technically possible and in any case within thirty (30) seconds after the execution of the transaction:

• price
• volume
• time of the transaction
• market identified code (identifying CLOB)

All in accordance with the standard templates in Annex 2 of the RTS.

Crypto-Assets Admitted to Trading

Crypto-Asset admitted to trading on Exchange have to comply with these operating rules and the suitability requirements set by ZHEU. ZHEU assesses the suitability of Crypto-Assets before admitting them to the Exchange. ZHEU evaluates in particular the reliability of the technical solutions used and the potential association to illicit or fraudulent activities, taking into account the experience, track record and reputation of the issuer of those Crypto-Assets and its development team.

• Only Crypto-Assets for which has been published a white paper can be admitted to trading
• Issuers must have policies and procedures for compliance with applicable laws regarding money laundering and terrorist financing
• ZHEU assesses the suitability of a Crypto-Asset, including the reputation of the issuer, before admitting it to trading on the platform
• In order to identify Crypto-Assets consistently ZHEU uses the Digital Token Identifier issued by the Digital Token Identifier Foundation
• ZHEU sets conditions for Crypto-Assets to remain accessible for trading, including liquidity thresholds and periodic disclosure requirements.

Types of Crypto-Assets that Will Not Be Admitted to Trading

ZHEU prevents the admission to trading of Crypto-Assets that have an inbuilt anonymisation function unless the holders of those assets and their transaction history can be identified by ZHEU.

ZHEU will not admit to trading on a trading platform any Crypto-Assets that, following binding guidance from the AFM, ESMA, EBA or the joint ESA's, are considered non-MiCAR compliant and cannot be admitted to trading on a trading platform in the EU.

Trading Conduct

Market Abuse

All End Customers have equal access to the web interfaces and ZHEU API and, where applicable, SDK. ZHEU does not provide prioritized access to any End Customer or other participant. All End Customers have full and equal real-time access to market data. Market data is made available through the web interfaces and API.

End Customers are prohibited from engaging in market abuse activities which includes market manipulation. Market manipulation includes, but is not limited to, the following activities:

Pump and dumps: End Customers who artificially inflate the price of a Crypto-Asset through false and misleading statements, in order to sell the purchased Crypto-Assets at a higher price.

Wash trading: End Customers who buy and sell a Crypto-Asset for the sole purpose of feeding misleading information to the market.

Front-running: End Customers who buy/sell Crypto-Assets with inside information that will influence the price of the digital asset, resulting in an economic gain for the participant.

Churning: End Customers who place both buy and sell Orders nearly at the same price to increase the price by attracting more trade(r)s.

Spoofing / layering: End Customers who create the illusion of pessimism (or optimism) in the market by placing buy or sell Orders without the intention of filling them.

ZHEU informs the AFM when cases of market abuse or attempted market abuse occurring on or through the trading systems are identified.

Monitoring

ZHEU will monitor the use by End Customers of the Exchange.

ZHEU may conduct a review of a transaction to determine whether the transaction is suspicious

Suspension of Crypto-asset

Trading of a Crypto-Asset will be suspended by ZHEU if this is necessary or following a request from a competent regulator:

• To ensure fair and orderly trading on the Exchange
• To comply with a request from a regulator

Suspension of an End Customer

ZHEU may suspend access of a participant to the Exchange if:

• The participant has breached the Operating Rules
• Upon the request of a competent regulator

Market Integrity

Trade and Order Cancellations

All orders placed are subject to the following pre-trade risk checks:

Wash Trade Check: A self-trade prevention mechanism is in place to prevent customers from executing against their own order. This will prevent artificially inflated trading volume and creating a misleading impression of higher or lower demand for an asset. This rule is set at account level.

Price Collar: If a market order aggresses multiple open limit orders at different prices, any trade that would cause execution price to be greater or less than 10% from the BBO Midpoint would be rejected. This will prevent bad fill prices at times of extreme volatility or thin liquidity. This rule is set at the system level and applies to all instruments.

Relative Price Check: A prevention mechanism that prevents a customer from entering a buy or sell order at a price that is far away from the current reference price. This will prevent clearly erroneous orders with bad prices from being submitted. This rule is set per instrument in the instrument manager.

Maximum Order Notional Value: A prevention mechanism that restricts a customer from placing an Order over a notional value. The Maximum Order Notional is EUR 500,000. This rule is set per instrument in the instrument manager.

Minimum Order Notional Value: A prevention mechanism that restricts a customer from placing an Order over a notional value. The Minimum Order Notional is EUR 1. This rule is set per instrument in the instrument manager.

Rate Limiting: A rate limit of the number of messages that can be sent per second is set per End Customer. The rate limit will prevent any unintentional or intentional high volume attacks from impacting the trading system performance. This rule is set per Platform.

Trade Finality

All trades are final meaning all fills are final and will not be reversed unless:

• ZHEU is required to do so by any applicable law or regulation; or
• Due to a serious technical error, Orders or fills do not occur as specified in these Rules - in which case ZHEU will make all reasonable efforts to restore all End Customers to the position they would have been in had the error not occurred.

Order Cancellation Procedures

Order cancellation may occur for various reasons, including both user actions and system-triggered events.

User-Initiated Cancellations: Customers can manually cancel open orders through the trading interface at any time. The cancellation request is processed by ZHEU. This includes:

• Full Cancellation: The customer chooses to cancel the entire open order.
• Partial Cancellation: The customer may cancel part of the order (e.g., reduce the order size), with the remaining quantity still open for execution.

System-Initiated Cancellations: Certain situations may automatically trigger the cancellation of orders, even without user input. These include:

• Price Collar Violation: If a market order interacts with multiple limit orders and the execution price would exceed a 10% deviation from the BBO Midpoint, the system will reject the trade and cancel the order to prevent bad fills. This helps safeguard against extreme price movements during volatile periods.
• Time Expiry: Orders may be canceled automatically after a specified time if they are not filled or partially filled. For example, Good-Til-Cancelled (GTC) orders can be automatically canceled after a set duration to avoid leaving stale orders open. These expirations are defined based on the instrument's settings in the instrument manager.
• Price Discrepancy (Relative Price Check): If an order is placed far outside the acceptable price range (as defined by the relative price check), it will be rejected or canceled to prevent the entry of erroneous orders with unrealistic prices.
• Market Conditions: If the market experiences a drastic change, such as a significant shift in liquidity or price volatility, ZHEU may cancel orders that cannot be filled at an acceptable price. This ensures that orders are not left open under unfavorable market conditions. These cancellations are triggered automatically by system algorithms designed to monitor liquidity and price fluctuations in real-time.
• Order Type Violations: In certain cases, if an order does not meet the predefined parameters for order types (e.g., exceeding max notional value or violating minimum size), the system will cancel the order automatically.
• Technical or System Issues: If there is a technical failure or a serious error in processing the order (such as order mismatch or server failure), the system may cancel or invalidate the order and notify the user. ZHEU will take all reasonable steps to resolve the issue and restore users to the position they would have been in if the error had not occurred.
• Abusive Behavior or Market Manipulation: ZHEU may cancel orders from customers who, at ZHEU's discretion, are suspected of engaging in abusive trading practices such as market manipulation or flooding the system with excessive API requests, which could harm the platform's functionality or market fairness.

ZHEU reserves the right to cancel orders or trades at its sole discretion under the circumstances outlined above. If an order is canceled due to a technical error, a regulatory requirement, or any other reason as deemed necessary by ZHEU, ZHEU will take reasonable steps to restore the customer to the position they would have been in, had the error not occurred.

ZHEU reserves the right, but has no obligation to, and shall not be held liable should it declare null and void a Crypto-Asset transaction that ZHEU considers to be erroneous.

Interruptions and Technical Issues

If technical reasons prevent or degrade End Customers' ability to place or cancel Orders, or prevent or degrade access to ZHEU APIs or affect the operation of our Order books or matching engines, then ZHEU may, in its discretion, take one or more of the following actions in respect of one or more Order books:

• Temporarily halt Order books to prevent further issues.
• Temporarily disable depositing or withdrawing assets.

Risk Management

Price Collar

If a market Order aggressive multiple open limit Orders at different prices, any trade that would cause execution price to be greater or less than 15% from the BBO Midpoint would be rejected.

Relative Price Check

A prevention mechanism that prevents an End Customer from entering a buy or sell Order at a price that is far away from the current best bid or offer. Orders will not be accepted if placed 60% away from the current reference price (see below).

Circuit Breakers

ZHEU does not use circuit breakers or automated trading halts based on predetermined price bands. ZHEU Operations team may, in its discretion, halt trading due to the reasons in section 5.2.

Reference Price CLOB

There are several reference prices used by ZHEU depending on the scenario a reference price is required:

Settlement Price

The reference price is determined by the ZHEU Index price which can't be manipulated by CLOB activity. It is updated Monday-Friday at 4pm UTC on the ZHEU CLOB.

The Price Percentage Away pre-trade risk check uses the Settlement Price as the reference.

When a market Order is submitted, its initial value is calculated by Qty * Settlement Price. This value must be greater than the minimum Order notional value.

This value can be set to be the trigger price on stop Orders.

BBO Midpoint

The BBO Midpoint is the value between the current best buy (bid) and best sell (ask) price. The price collar pre-trade risk check uses the BBO Midpoint as the reference price.

If an Order book has no bid price, has no ask price or has no bid and ask price then the reference price for price collar checks is set to the Settlement Price.

Last Trade Price

The last trade price (LTP) is the price of the last trade that executed on that order book. This value can be set to be the trigger price on stop Orders.

Open, High, Low, Close Price

These reference prices are purely informational. The Open price is the price at the time an instrument trading state is set to Open. As ZHEU operates a 24/7 market, this price will remain as open until there is a temporary halt and the Order book re-opens again. The Close price is the price at the time when an instrument trading state is set to Closed. This would only be set during an unscheduled Halting or a scheduled maintenance.

Access to Information

All End Customers have equal real-time access to market Data. Market data is made available through the ZHEU FIX API's.

Market Data Comprises the Following:

• All limit Orders placed on the Order book (price, quantity, and time).
• The displayed amounts of all Iceberg limit Orders placed on the Order book (price, displayed quantity, and time).
• All canceled Orders on the Order book (price, quantity, and time).
• All fills or Executions (price, quantity, and time).

Market Data Does Not Include the Following:

• Resting stop Orders (stop Orders that have been placed but not triggered)
• Any information about which trader placed or canceled an order.

Settlement and Finality

Any End Customer CLOB transaction executed under these Operating Rules will be settled in final in near real time in the Hosted Wallet of an End Customer maintained by the Foundation of ZHEU as set out below. ZHEU performs the final settlement of a Crypto Asset transaction:

A Transaction Between an End Customer and a LP

By:

• updating the respective Hosted Wallet, maintained by the safekeeping Foundation of ZHEU, of the End Customer that is party to the transaction (crediting in case of an End Customer purchase transaction and debiting in case of a sale transaction);
• updating the respective Hosted Wallet, maintained by the safekeeping Foundation of ZHEU, of the LP (debiting in case of End Customer purchase transaction and crediting in case of sale transaction);
• where the LP does not have enough Crypto-Assets available in its Hosted Wallet to enable ZHEU to settle the transaction with the End Customer out of available Crypto-Assets of the LP, the required Crypto-Assets for settlement are provided to the LP by ZHLS acting in its capacity as settlement provider for the LP in near real time.

A Transaction Between End Customers

By updating the respective Hosted Wallets, maintained by the safekeeping Foundation of ZHEU, of the respective End Customers that are party to the transaction (by debiting the Hosted Wallet of the selling End Customer and crediting the Hosted Wallet of the purchasing End Customer).

Settlement Confirmation and Delays

Final settlement confirmation will be passed on to the End Customer via the Platform Operator. In the unlikely event that a settlement fails, ZHEU will inform the End Customer as soon as possible of the settlement failure via the Platform Operator.

Settlement for all matched transactions on CLOB is conducted off-chain. Under normal operating conditions, settlement is final and occurs in near real-time through immediate credit and debit updates to the End Customer's wallet on the internal ledger.

In the highly unlikely event of exceptional circumstances, such as a temporary liquidity or inventory shortfall at one of the parties to a trade, final settlement may be delayed. The economic terms of the transaction, including the agreed-upon price and quantity, are fixed at the moment of execution and will not be affected by any such settlement delay. In such a scenario, Zero Hash Europe will undertake all necessary measures to ensure the transaction is settled by no later than the close of the following business day (T+1).

Trade Disputes

Trade Cancellations

Orders cannot be cancelled by End Customers once they are final. All End Customer trades are final. Withdrawals are on-chain and irreversible.

ZHEU may, at its sole discretion, cancel any market order. ZHEU will send you a notification upon the occurrence of a cancellation of any market order.

If a previously published trade is cancelled, ZHEU makes public a new trade report containing all the details of the original trade report and the cancellation flag.

Record Keeping

ZHEU's company records and trade records and the data contained within them, are kept and managed responsibly. The purpose of these procedures is to ensure that ZHEU is compliant with applicable laws and regulatory requirements and with its business needs, in the way it deals with its company records:

By participating on the Exchange, End Customers acknowledge that ZHEU will retain records of their use of the trading platform for five years in accordance with the Record Keeping Policy and Procedure.

If deemed necessary records will be reported to regulatory authorities, for example in the case of (attempted) market abuse.

[Link to Privacy Policy].

Complaints

Any complaints regarding Zero Hash Europe B.V. may be sent to either entity at Herengrach 244-3, 1016 BT Amsterdam, the Netherlands, or through email at legal@zerohash.com. Alternatively, the complaints form on the ZHEU website can be used [LINK].

A complainant may also bring their complaint to the attention of the Dutch Authority of the Financial Markets ("AFM") through the internet at https://www.afm.nl/en/consumenten/klachten. Complaints may also be directed at the Dutch Institute for Financial Disputes ("KiFID") at https://www.kifid.nl/form_reg/.

Governing Law

These Operating Rules are governed by and construed and enforced in accordance with the laws of the Netherlands. If you are an End Customer, you additionally enjoy the protection afforded to you by mandatory provisions of the law of your country of residence.

Disputes arising from out of or in connection with the Operating Rules will exclusively be settled by the competent court of the District Court of Amsterdam. This clause does not affect any rights you have as a consumer to have a dispute heard in a different court.

Scheduled Downtime

The ZHEU Exchange will be open for trading near 24/7, 365 (the "Trading hours").

There is a maintenance window every Monday at 16:00 UTC until 16:30 UTC. This is to support our weekly sequence number reset schedule. Any system maintenance or system upgrades will be performed during this window.

Trading Session and States

ZHEU operates the Exchange 24/7 so the standard Trading Session will nearly always be 'Continuous Trading'. Non-standard Trading Sessions will be 'Pre-Open' and 'Close' for the CLOB. Details of when each CLOB Trading Session would be used is detailed below.

The table below highlights the trading states that apply to each Trading Session:

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Pre-Open

The Pre-Open will be an Order accumulation period during which all Orders entered by End Customers are automatically recorded in the CLOB without being executed.

Pre-Open session will be initiated in very few circumstances by the ZHEU Operations team such as the initial opening of the market for an Instrument or after a market halt. The minimum time for this period is 15 minutes.

Orders can be cancelled during this session by End Customers or by ZHEU Operations team. Entry of limit Orders with Time In Force of Good Til' Cancelled or Good Til' Time are permitted. No market Orders, or limit Orders with Time In Force of Immediate or Cancel and Fill or Kill are allowed during this session.

At the end of the Pre-Open session, an Order matching process will happen at the Opening Price UTC established during the session. If there are matching Orders in the Order Book when the session is changed from Pre-Open to Trading, Executions will take place based on the Opening Price calculation.

Continuous Trading

This is the Continuous Trading session where Orders can be entered and cancelled. The Instrument(s) is/are listed as active. All Orders that are unexecuted at the Pre-Open session are forwarded into the Continuous Trading session. All Order types available to End Customers are permitted during the Trading session.

Closed

If a short-term market halt is required due to an unexpected event such as a technical issue then End Customers are prohibited from placing any new Orders while an Instrument is Halted. End Customers can cancel their open Orders while an Instrument is Halted.

When a cessation of trading request is made for any Instrument the session will be changed to Suspended or Terminated.

End Customers are prohibited from placing any new Orders and all open Orders are cancelled.

Suspended refers to the Instrument being halted for an extended period of time or for more than 1 hours with no re-opening scheduled.

Terminated refers to the Instrument being delisted and trading is permanently disabled.

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Appendix

Calculation of Opening Price

There are three steps in determining the opening price. If an opening price cannot be determined after the first step, the model progresses to the second step and, if necessary, the third. The steps to calculate the opening price are applied in the following order:

Step 1: Maximum Virtual Asset quantity traded

The price level that allows the maximum quantity to trade is the opening price. At each price level (i.e., prices of queued Orders) the total quantity available in the market is calculated. The total quantity available is determined for both the buy and sell side of the market.

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Step 2: Minimum quantity imbalance  

If more than one price level allows the maximum quantity of underlying CryptoAsset to trade, the price level with the minimum imbalance in quantity becomes the opening price.  Imbalance quantity is the amount of underlying remaining after all trades occur at a particular price level (e.g., if the total quantity available for a trade to occur is 9 and the sell quantity that can be traded is 8, the imbalance is 1 on the buy side.)

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Step 3: Better price for the market side in high demand 

If more than one price level allows the maximum quantity to trade with equal minimum imbalances in quantity with both imbalances on the same side of the market, the price to be selected is the price that is better for the side of the market with no remaining volume (the side that is opposite to the side of the market with the imbalance). 

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