1. PURPOSE AND SCOPE

This Order Execution Policy (the "Policy") has been prepared within the framework of Capital Markets Law No. 6362 (the "Law"), Communiqué No. III-35/B.1 on the Establishment and Operating Principles of Crypto Asset Service Providers (the "Operating Principles Communiqué"), Communiqué No. III-35/B.2 on the Working Procedures and Principles and Capital Adequacy of Crypto Asset Service Providers (the "Operating Procedures Communiqué"), and other relevant capital markets legislation, in order to establish the fundamental principles governing the acceptance, processing, and execution of customer orders in activities carried out through the Aquanow platform, including Crypto Asset trading, initial sale and distribution, transfer, settlement, and custody.

2. PERMITTED SERVICES

Aquanow accepts orders within the scope of the following services:

a) Acceptance, execution, settlement, transfer, and custody of orders relating to Crypto Assets.
b) Intermediation in the initial sale or distribution of Crypto Assets.
c) Custody and management of Crypto Assets or the relevant private keys.
d) Provision of investment advisory services in relation to Crypto Assets.
e) Trading, settlement, transfer, and custody transactions involving non-fungible tokens (NFTs).
g) Financial analysis and general recommendation services relating to Crypto Assets.
h) Other services and activities designated by the Capital Markets Board.

3. CHANNELS FOR SUBMITTING ORDER REQUESTS

Customers may submit order requests through Aquanow's website, mobile application, official telephone lines assigned to Company personnel, or other channels designated with the permission of the relevant authorities.

4. ORDER EXECUTION PRINCIPLES

4.1 Achieving the Best Result

Aquanow is required to execute customer orders so as to achieve the best result, taking into account criteria such as price, cost, speed of execution, likelihood of execution, settlement, size, and custody conditions.

• Price and Cost: Commissions charged, market-maker fees, and additional costs arising from network congestion are taken into account.
• Speed: Transactions are intended to be completed as quickly as possible.
• Likelihood of Execution: Liquidity and market conditions are assessed.
• Order Size: The impact of orders on the market is analysed.
• Other Conditions: Market volatility and custody conditions are taken into account.

4.2 Price and Time Priority

Orders are matched by applying price priority first, followed by time priority. Orders with more favourable prices are processed first; where prices are equal, orders submitted earlier have priority.

4.3 Non-Aggregation and Non-Splitting of Orders

Aquanow does not process customer orders by aggregating them with or splitting them into other orders.

4.4 Order Records

All orders are recorded so as to include the following information:

• Customer or account number,
• Crypto Asset subject to the transaction,
• Order type and direction (purchase/sale),
• Price and amount,
• Date and time of order receipt and transmission,
• Order validity period,
• Order sequence number,
• Relevant currency or trading pair.

4.5 Data Records and Retention

For all orders, including orders received via the internet, mobile applications, or telephone, customer IP addresses, timestamps, transaction logs, and voice recordings are retained. These data are retained for at least 10 years. The retention period may be extended in the event of a dispute.

4.6 Market Integrity and Fair Treatment

Aquanow establishes its order and transaction principles so as to provide a secure, transparent, efficient, stable, fair, and competitive market environment.

5. ORDER TYPES

• Limit Order: An order to purchase or sell at a specified price or a more favourable price.
• Advanced Limit Order: In addition to the features of a limit order, this order type includes options such as automatic cancellation if the order is not executed.
• Market Order: A purchase or sale is executed immediately at the prevailing market price.
• Other Order Types: Aquanow may offer order types with different features according to need.

6. GROUNDS FOR ORDER CANCELLATION

6.1 Circumstances in Which Orders May Be Cancelled

• Submission of orders contrary to legislation,
• Indications of a suspicious transaction,
• Technical failure or cyberattack,
• Insufficient funds,
• Restriction placed on the account,
• Suspicion of money laundering or terrorist financing,
• Delisting of the relevant Crypto Asset,
• Market-disruptive conduct,
• Restrictions imposed by competent authorities,
• The customer acting to match their own orders.

6.2 Erroneous Orders and Their Consequences

Due to the nature of blockchain-based systems, erroneous transactions cannot be reversed. In such circumstances, the commission fee will not be refunded.

7. FINAL PROVISIONS

7.1 Review of the Policy

This Policy is reviewed at least annually and in light of legislative changes or implementation experience, and the necessary amendments are made.

7.2 Notification of Amendments to Customers

Any amendment to the Policy is announced to customers at least 15 days before it takes effect. Records evidencing that notification was made are retained by the Platform.

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