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Disclosures

Forks and Airdrops Policy

Version 25 September 2025

Overview

Policy Oversight

This Zero Hash Europe Fork Policy (the "Policy") is maintained and enforced by Zero Hash Europe BV ("ZHEU"). By continuing to use any ZHEU service, you are agreeing to the terms of this policy and consenting to ZHEU's implementation and application thereof.

The Zero Hash Group Operating Committee (the "Operating Committee") is primarily responsible for the review of crypto asset Forks and Airdrops and advising the position that ZHEU will take. ZHEU functions may be involved in the process of reviewing new crypto assets but the ultimate authority to define a Legacy Chain and to decide whether a Fork and Airdrop will be supported by ZHEU, lies with the Operating Committee and the ZHEU Management Board.

Definitions

Airdrop. An "Airdrop" occurs when a crypto asset blockchain issues a new crypto asset to certain or all public keys or addresses from another blockchain. Private key holders of the receiving blockchain are distributed new crypto assets from the Airdropped blockchain to a new private key or address on the distributing blockchain.

Fork. A "Fork" is a permanent change in the consensus algorithm that emerges when a new consensus layer is applied to an existing blockchain. The result is the creation of a new blockchain, which can be significantly different from the original blockchain. Following a Fork, there are usually two, or more, versions of the Forked crypto assets, an older version and one that follows the new blockchain consensus. In some cases, the old version is abandoned, and all users and developers update to the new version of the blockchain. In other cases, two crypto assets continue to operate independent of one another (e.g., Bitcoin and Bitcoin Cash).

Legacy Chain. The "Legacy Chain" is the crypto asset blockchain which is deemed to be the original blockchain from which a Fork is created.

New Chain. The "New Chain" is a crypto asset blockchain that is created as part of a Fork. It is a new, independent blockchains continuing forward in place of the previous blockchain, potentially with its own unique consensus mechanism, characteristics, and corresponding crypto asset.

Policy Focus

Forks and Airdrops have become a vehicle for delivering crypto assets to holders of existing crypto currencies, and many questions have arisen concerning the ownership to and distribution of Forked and Airdropped crypto assets. Each Fork or Airdrop faces unique technical, safety, liquidity, and timing challenges. ZHEU will not make any Fork or Airdrop available to any account holders that is not also supported by its third-party wallet partner. ZHEU will take into account security, value, technical stability, market capitalization, liquidity, and costs, as well as any other factor ZHEU deems relevant, in the deployment of this Policy. This Policy addresses ZHEU's actions in the event of a Fork or Airdrop relating to any crypto asset made available by any ZHEU entity for custody or market services.

Supporting a Fork or Airdrop

There are different forms in which ZHEU may support a forked crypto asset. ZHEU will always aim to offer physical trading of crypto assets traded on the platform, but if wallet providers do not offer the Fork or Airdrop, ZHEU can facilitate other forms of support via financially settled transactions.

Physical Trading

To allow trading of the physical Fork or Airdrop on a ZHEU trading venue. See Physical Storage below for the requirements for this.

Financial Trading

To allow trading of financially-settled contracts related to the Fork or Airdrop on a ZHEU trading venue. This does not require ZHEU to have the ability to store the physical asset. Financially settled transactions settle to an index price, so ZHEU only requires access to pricing data.

Physical Storage

This requires ZHEU to have the ability to store the Fork or Airdrop, and therefore ZHEU must have the ability to generate wallets and interact with the New Chain through its third-party wallet provider, or otherwise. ZHEU may be restricted by its wallet provider, even if ZHEU wishes to facilitate storage. In the event that ZHEU plans to support a Fork or Airdrop, but the wallet infrastructure doesn't support it (e.g. a third-party wallet provider does not technically support the new asset), ZHEU customers will be restricted by this. ZHEU will use best commercial efforts to provide Forked or Airdropped crypto assets to those accounts holding the corresponding crypto assets at the time of the Fork or Airdrop.

Policy Disclaimer

ZHEU reserves the right to update this policy and the criteria for measuring the viability of a Fork or Airdrop from time to time based on new technological, legal, or environmental factors that may emerge. You agree and understand that ZHEU may not support all Forks and Airdrops and that the corresponding crypto assets of Forks and Airdrops will in some cases not be made available to you. Crypto asset values can and do fluctuate substantially, which may result in a total loss of the crypto assets held by ZHEU on your behalf after a Fork or Airdrop. ZHEU's support of any Forked or Airdropped crypto asset by making any such asset available to any account holders depends on third-party wallet providers that are outside of ZHEU's control. ZHEU does not own or control any of the protocols or blockchain algorithms of any crypto asset, Fork, or Airdrop, and, thus, ZHEU disclaims all liability relating to protocols or algorithms and any change in value of any crypto asset. ZHEU makes no guarantees regarding the security, functionality, or availability of crypto assets and their corresponding protocol, algorithms, or networks. In choosing to support a crypto asset, Fork, or Airdrop, ZHEU is not making any representation of that asset's value, features, safety, or stability. Nothing in this policy, or in the application of this policy, should be deemed an endorsement, recommendation, or repudiation of any crypto asset, Fork, or Airdrop.

Fork and Airdrop Support Policy

Review Process

Safety of customer account holdings and stability of ZHEU systems are ZHEU's primary concerns in the implementation of this Policy. ZHEU will monitor developments in all crypto assets for announced or planned Forks and Airdrops. For any Fork or Airdrop that ZHEU believes it may want or need to support, ZHEU will:

  1. Research the Fork or Airdrop. ZHEU aims to deeply understand the context surrounding a Fork or Airdrop, as well as the logistical implications, such as timing and structure.
  2. Determine support approach. ZHEU will aim to support the Fork or Airdrop, and will determine what that support will look like. For this, ZHEU will monitor any third-party wallet providers for announcements and notices regarding each provider's support of any Fork or Airdrop. ZHEU will then do a preliminary review of the Fork or Airdrop as per the Review Principles listed below. ZHEU will review the proposed Fork or Airdrop for technical safety, stability, cost of implementation, market capitalization and liquidity. A more formal Token Acceptance Framework review will be implemented later.
  3. Determine if there is a Legacy Chain, or if a Legacy Chain must be defined. This defines the ticker symbol and the asset that needs a Token Acceptance Framework review.
  4. Perform a Token Acceptance Framework review. This is a structured review on the basis of pre-defined Token Acceptance criteria.
  5. Notify all account holders when a decision is made to support any Fork or Airdrop.
  6. Make available any approved Forked or Airdropped crypto asset once ZHEU systems are able to support the crypto asset. ZHEU shall exercise sole discretion in the method and manor of distribution to any account holders.

Support for and distribution of any Forked or Airdropped crypto assets shall be at ZHEU's sole discretion. For any crypto asset held in any ZHEU account, you have no right, claim, or other privilege to any corresponding crypto assets resulting from an unsupported Fork or Airdrop.

Review Principles

Technical Stability and Security

ZHEU will not support any Fork or Airdrop where ZHEU believes that the resulting crypto assets are unsafe, vulnerable to attack, or may put ZHEU systems at risk. ZHEU will evaluate the technical stability of any proposed Fork or Airdrop. This review will include a detailed look at the technical team behind the Fork or Airdrop, replay and wipe-out-protection, mining capacity or validation mechanisms. Crypto assets that are deemed to be vulnerable to a 51% attack may not be accepted by ZHEU.

Market Capitalization and Liquidity

ZHEU will in principle aim to support all Forks and Airdrops.

Costs

Supporting new crypto assets involves significant overhead for ZHEU. Some Forked and Airdropped crypto assets may be similar to crypto assets already supported by ZHEU, and these will generally involve fewer resources to support. However, if an algorithm is significantly different than those blockchain crypto assets already supported by ZHEU, the costs may be significant. The costs associated with supporting a crypto asset will be a factor in ZHEU's review of all Forks and Airdrops. ZHEU may decide to support an asset with significant demand, but that support may be delayed due to the costs of such support.

Timing

Upcoming Forks and Airdrops are typically announced prior to any distribution of any new crypto assets. This notification may be provided days, weeks, or months in advance. Additionally, some Airdrop distributions take place during a short window of time, forcing adoption of the Airdropped asset to be rushed. Reviewing, approving, and supporting new crypto assets takes a significant amount of time. ZHEU's review of a proposed Fork or Airdrop may take longer than the notification period provided or the Airdrop window. Thus, ZHEU cannot guarantee that any Forked or Airdropped crypto asset will be made available at the time the Fork or Airdrop occurs, nor can ZHEU guarantee that any Airdrop with a window will be made available at all. ZHEU, at its discretion, may choose to make a Forked or Airdropped crypto asset available at any time. crypto assets that were rejected may, upon re-review, be accepted. For example, an Airdropped crypto asset that failed to meet ZHEU's market cap requirements may later meet those requirements; or, a Forked crypto asset that failed to provide replay protection may later provide such protection through a "soft fork" patch.

Should you wish to access potential Forks or Airdrops, it is your responsibility to purchase any crypto asset related to the desired Fork or Airdrop in advance of any planned Fork or Airdrop. ZHEU, at its sole discretion, may choose a date and time of record for each Fork or Airdrop (typically the date and time of the Fork or Airdrop as recorded on the blockchain of the Forked or Airdropped crypto asset). Crypto asset purchases must have settled as outline in your ZHEU agreements and the crypto assets must be present in your wallet as of the date and time of record in order to receive the related Forked or Airdropped crypto asset(s). If purchases of associated crypto assets have not settled and transferred to your wallet as of the date and time of record, ZHEU does not guarantee that you will have access to, or ownership of, the Forked or Airdropped crypto asset. Note that purchases on the same day of a Fork or Airdrop will not clear until the following day and that certain crypto assets transfers may take significant time to settle on the blockchain due to high volume or other network issues. ZHEU does not guarantee any time frame sufficient for a crypto asset transaction confirmation and transmission.

Legacy Chain Review

In all cases where ZHEU aims to support a Fork, the Operating Committee will be tasked with implementing this Legacy Chain Review. The Operating Committee may, at its own discretion, take a variety of factors into consideration in the implementation of this policy, including each resulting blockchain's network hashing rate, hash rate distribution, height, and average block size. The Operating Committee may also consider non-technical attributes, such as the greater market response, competitors' responses, wallet partners' actions, and regulatory reactions and opinions.

A Clear Legacy Chain Exists

If the Operating Committee determines that there is a clear Legacy Chain with a New Chain and new crypto asset being formed, such as the case of Bitcoin and Bitcoin Cash, then the Operating Committee must only review the New Chain and its new asset in the context of approving a new crypto asset. The Legacy Chain will retain the legacy asset name (e.g., Bitcoin) and market identifier (e.g., BTC). The New Chain will be listed with a new name (e.g., Bitcoin Cash) and market identifier (e.g., BCH).

ZHEU staff will apply the Zero Hash Token Acceptance Framework to each resulting Forked or Airdropped crypto asset in order to determine whether such crypto asset will be supported.

No Clear Legacy Chain Exists

When there is no clear Legacy Chain, such as the case of Bitcoin Cash ABC and Bitcoin Cash SV, the Operating Committee will monitor and review the technical and and non-technical aspects of each resulting blockchain and will also review the Token Acceptance Framework for each resulting Forked crypto asset. The Operating Committee, in its sole discretion, will then determine which blockchain and corresponding crypto asset is deemed to be the Legacy Chain and which is a New Chain. Once determined, the Operating Committee will review the New Chain under the Token Acceptance Framework and determine whether it will be supported as a new asset, in which case the Fork or Airdrop will become available to ZHEU participants.

The Operating Committee reserves the right to revisit any decision made pursuant to this policy should technical or market conditions change over time.

Legacy Chain Review Disclaimer

ZHEU disclaims all liability relating to any decision made pursuant to this policy. You agree that the implementation of this policy is left to ZHEU's discretion. You also agree and acknowledge that technical and non-technical aspects of each blockchain are subject to change and that there is no way to predict the greater market or technical support for any Fork following any decision made by ZHEU or the Operating Committee. ZHEU is not responsible or liable for any changes in support or value of any crypto asset following any decisions made pursuant to this policy.

Token Acceptance Framework Review

ZHEU maintains a Token Acceptance framework for the structured review of tokens.

Effect on Open Crypto Asset Contracts

In the case of any contract wherein a specific kind(s) and amount(s) of any crypto asset is to be delivered at a future date (e.g., forward contracts) entered by ZHEU participants, the party who is required to deliver pursuant to the terms of the contract will deliver only those assets contracted for (the "Deliverable Asset"). Unless the contract specifies otherwise, the receiving party is not entitled to any Airdropped crypto asset associated with the contracted for crypto asset that may be distributed between the date the contract was entered and the date of delivery.

In the case of any Fork, the Deliverable Asset shall be the crypto asset maintained by the Legacy Chain, as designated in accordance with the Legacy Chain Review above. The New Chain and its asset will not be part of the delivery obligation.

RFQ

Post-Trade Report

Trading Platform

Central Limit Order Book Post-Trade Report

Trading Platform

Central Limit Order Book Pre-Trade Report