1. PURPOSE AND SCOPE
This Order Execution Policy ("Policy") regulates the general principles regarding the acceptance, processing, and execution of orders received from customers within the scope of buying and selling, initial sale or distribution, exchange, and transfer of crypto assets to be carried out through Arbitex Kripto Varlık Alım Satım Platformu A.Ş. ("Platform"), as well as the custody services required for these transactions and other related activities.
In this Policy, order and transaction principles are determined for the purpose of ensuring that transactions are carried out by the Platform in a reliable, transparent, efficient, stable, fair, honest, and competitive manner, and to ensure the detection, prevention, and non-recurrence of market-distorting acts and transactions.
This Policy has been prepared within the framework of the relevant capital markets legislation, particularly the Capital Markets Law No. 6362, the Communiqué on the Establishment and Operating Principles of Crypto Asset Service Providers No. III-35/B.1, and the Communiqué on the Operating Principles and Capital Adequacy of Crypto Asset Service Providers No. III-35/B.2, and it is published on the Platform's website within the scope of Article 24/2-e of the Communiqué No. III-35/B.1.
2. PRINCIPLES REGARDING THE RECEIPT OF ORDER TRANSACTIONS
2.1 OBTAINING A CUSTOMER NUMBER
The procedures for obtaining a registration number from the MKK (Central Registry Agency) on behalf of the customer and matching it with the customer number are carried out within the framework of electronic transaction procedures and systems determined by the MKK. A separate customer number is allocated to each customer with whom a framework agreement is concluded within the Platform. This allocated customer number cannot be re-allocated to another customer unless ten years have elapsed from the expiration date of the relevant framework agreement.
Before accepting orders on behalf of each customer or processing any order given on behalf of the customer, the Platform obtains a registration number for the said customer before Central Registry Agency (Merkezi Kayıt Kuruluşu A.Ş. – “MKK”) and ensures that this registration number is matched with the relevant customer number. The Platform cannot accept orders from accounts that have not obtained a registration at MKK or have not matched with a registration number. In the event that a registration number previously obtained on behalf of the customer exists, it is ensured that this registration number is made compatible with the current customer number.
2.2. THE ENVIRONMENT IN WHICH CUSTOMER ORDERS ARE RECEIVED AND TRANSACTIONS ARE EXECUTED
2.2.1. Valid Order Channels and Responsibilities
Customers must perform the necessary transactions in accordance with the relevant legislation within the scope of the "Know Your Customer" principle. Users who have not performed identity verification procedures, or whose information and documents submitted during identity verification cannot be verified and/or approved, cannot perform transactions.
The Platform accepts customer orders exclusively through its official website, mobile applications, and other channels permitted by law. Orders transmitted via social media or instant messaging applications (WhatsApp, Telegram, Instagram, etc.) are invalid.
If it is claimed that a transaction has not taken place, the burden of proof regarding the placement of the order belongs to the customer.
2.2.2 Transaction Process and Parties
Crypto asset buy-sell orders given within the Platform are matched within the trading environment. In addition to being executed through the trading environment, customer orders may also be fulfilled by the Platform acting as a direct counterparty.
Customer orders may also be fulfilled by the Platform acting as a direct counterparty, excluding transactions conducted within the scope of liquidity provision and market making. In transactions where the Platform takes place as a counterparty, it is possible for a price difference to occur in favor of the Platform or against the customer depending on market conditions. Such transactions are carried out in accordance with the relevant legislation and in a manner that will not create a conflict of interest. The sales transactions made by the Platform with its own assets are limited to the amount of crypto assets it owns and are netted at the end of the day (at 23:59 every day). In transactions where the Platform is the counterparty, since customer loss can turn into the Platform's gain, utmost care is taken to prevent conflicts of interest.
2.2.3 Market Makers and Liquidity Providers
The Platform works or may work with market makers and liquidity providers for the purpose of providing liquidity. These entities are independent service providers, and the Platform will exercise the necessary diligence when working with these parties and will perform an evaluation based on criteria such as past performance, management structure, and financial adequacy.
The said entities are obliged to support market stability and liquidity. Within this scope, they are obliged to provide continuous quotations during trading hours, ensure certain transaction volumes, and act in accordance with market fairness. Furthermore, they are expected to act in compliance with Platform policies and applicable Turkish legislation in all their activities.
3. TRANSACTION PRINCIPLES REGARDING ORDER EXECUTION ACTIVITY
The Platform executes orders belonging to customers in line with the provisions contained in the framework agreement concluded with the customer, in this Policy, and in the relevant Platform procedures.
The Platform is obliged to fulfill orders in a way that will yield the best possible result for the customer within the framework of the order execution policy and transaction principles, taking into account the preferences of customers regarding matters such as price, cost, speed, likelihood of execution, settlement, size, custody, and similar issues.
3.1. Order Number and Order Book
An order number is assigned by the platform system to all transmitted and accepted orders. Orders assigned with an order number turn into transactions by matching with other pending orders according to the order, transaction, and priority rules valid within the framework of this Policy, or they are recorded in the relevant order book without turning into a transaction. Orders contained in the order book are sorted according to the principles of price and time priority.
The Platform prioritizes each transaction type within itself by creating separate memory queues for buy and sell orders.
3.2 Price and Time Priority
Price and time priority rules are applied respectively as the priority rule in matching the orders recorded in the Platform system. The price priority rule expresses that lower-priced sell orders are met before higher-priced sell orders, and higher-priced buy orders are met before lower-priced buy orders; the time priority rule expresses that in case of price equality, orders recorded earlier into the system in terms of time are met with priority.
3.3. PRINCIPLES REGARDING ORDER TYPES, VALIDITY PERIOD OF ORDERS, THEIR ACCEPTANCE, AND CANCELLATION
3.3.1 Order Types
1- Market Order: A market order allows the investor to buy or sell instantly at the current market price. This order is executed immediately by matching with the best counter-order in the exchange order book. However, due to the volatile nature of crypto assets, a price difference may occur in the brief period between the moment the order is entered and the moment it is executed; this situation creates the risk of "slippage".
2- Limit Order: A limit order allows the investor to execute a transaction at a specific price level. The order is not processed before the determined price occurs. The order is executed when market conditions reach the price determined in the limit order; otherwise, the transaction may not take place.
Two possibilities are in question: If the order is at a level further away from the market price, it waits to be traded by being added to the book. If the order is at a level equal to or more advantageous than the market price, it is executed immediately like a market order, and in this case, a higher transaction fee may apply. This structure provides protection against extreme price fluctuations.
3- Stop Limit Order: In a stop limit order, when a specific stop price is reached, the order becomes active over the determined limit price.
It is accepted that the customer has sufficient knowledge and experience regarding the order type they will give. Independent of the order type, due to the slippage that may occur in prices, the Platform may not be able to execute customer orders from the level seen by the Customer. Especially during periods when depth disappears, buy-sell price differentials increase, and price fluctuations intensify, "market, limit, and stop orders" are executed not from the price level determined by the customer, but from the market prices that the Platform can procure. Depending on the price conditions at the moment of triggering stop orders, a difference may occur between the price at which the stop order is executed and the price expected by the Customer.
3.3.2. Order Validity Periods
Good-till-canceled validity is applied to the orders to be entered by the customer on the Platform. Orders remain in the order book until they are executed or canceled. However, the Platform may determine other options regarding the validity periods of orders, and reserves the authority to ex-officio cancel, partially or completely stop/close customer orders in cases deemed necessary.
3.3.3 Principles Regarding the Acceptance of Orders
Order acceptance refers to the process of recognition and processing of orders transmitted by customers by the Platform. The basic principles to be applied within this scope are as follows:
Validity Criteria: Only orders that are created in accordance with the technical and legal requirements of the Platform and meet the valid order types and transaction rules are accepted. These criteria include elements such as appropriate price, transaction volume, order type, and compliance with legal legislation.
Verification Process: Prior to the acceptance of an order, verification of elements such as sufficient balance, asset availability, transaction limit, and similar factors is carried out.
Order Transmission Channels and Matching Mechanism: Orders are received exclusively through the methods specified in this policy and are recorded electronically by the system. The Platform uses fully or partially automated systems in matching the transmitted orders. Matching transactions are carried out in line with the explanations contained in the policy.
Technical Suitability: Orders are accepted only if there is no systemic failure or interruption at the moment they are transmitted. Otherwise, the order is not processed.
3.3.4. Principles Regarding Order Cancellation
Customers can create crypto asset buy-sell orders through the mobile application and website of the Platform. Transactions given in the form of market orders are executed instantly over the current market price. In limit order and stop order types, orders wait in the system for the completion of the transaction when the determined price level is reached.
Limit orders can be completed in a short time depending on market conditions, as well as being executed at a later date or may never be executed. In case of partial execution, the remaining part of the order continues to wait in the system.
Stop orders, on the other hand, are in a passive state until the trigger price is reached and maintain their validity unless canceled by the customer. When triggering occurs, the stop order turns into a market order and is processed.
Customers cannot make changes to market orders after giving them. Although limit and stop orders can be canceled, it is not possible to make a change other than cancellation for both order types.
4. RECORDS REGARDING ORDERS
Records regarding all orders received, including those canceled, unexecuted, and modified, contain customer number or account number, the crypto asset subject to the transaction, order type, whether the order is a buy or sell order, price information of the order, quantity of the order, date and time the order was received and transmitted, validity period of the order, sequence number of the order, currency to be transacted, and parity or crypto asset information.
The Platform regularly maintains electronic log records containing date, time, quantity, price, customer information, and IP numbers regarding all customer orders received over the internet or other electronic environments, as well as voice records, in a manner that shows the source of the order. These records are stored in such a way that they can be turned into writing and immediately transmitted to the Board when necessary. The said records are preserved for ten years pursuant to Article 82 of the Turkish Commercial Code No. 6102. However, records and documents that are the subject of a dispute continue to be retained until the said dispute is definitively concluded.
5. UPDATE AND NOTIFICATION
This Policy is reviewed at least once a year. In addition, updates are carried out in the Policy in cases deemed necessary by incorporating legislative amendments performed by the Board and making evaluations in line with the experiences gained in practice. Changes to be made in this policy are notified to customers at least fifteen days in advance. The burden of proof regarding the notification being made belongs to the Platform.