Order Execution Policy

Order Execution Policy

Version 2.3 – October 2025

1.    General Information

The aim of this Order Execution Policy (“the Policy”) is to regulate the provision of execution of orders for crypto-assets on behalf of clients service (“the Execution Services”) by Zillion Bits Ltd. (“ZBX” or “the Company”).

The provisions of this Policy have been designed in a manner that ensures clear disclosure of the rights and responsibilities of ZBX and its clients and the effective protection of ZBX and its clients’ rights.

2.    Scope and General Principles

The Company shall:

• provide information to clients on its order execution policy and obtain their prior consent to it; and
• immediately notify existing clients, in writing, of any material changes to its order execution arrangements.

A summary of this Policy will form an integral part of the Terms of Business of the Company and/or any other agreement entered into with clients. In this way, any client shall be deemed to have provided consent to this Policy.

If clients make any reasonable and proportionate additional requests for information (including additional information about this Policy), the Company shall answer clearly and within a reasonable time.

3.    Executing Orders on Terms Most Favorable to the Client

The Company shall, as set out in this Policy, take all sufficient steps to obtain the best possible result for the client by taking into account price, costs, speed, the likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of the order (the “Execution Factors”).

The relative importance of the Execution Factors will be determined by reference to the characteristics of the client, the order, the crypto-assets that are the subject of that order and the entities to which that order can be directed for execution.

The Company shall demonstrate to clients, at their request, that it has executed their orders in accordance with its order execution policy.

4.    Best Execution Factors

When executing clients’ orders, ZBX shall take all reasonable steps to obtain the best possible results for its clients while taking into account the following factors:

4.1.      Price

For any given crypto-asset, ZBX will quote the price at which the client can buy and at which the client can sell. Price is given the highest relative importance among the execution factors; however, ZBX does not guarantee that its quoted prices will be equal to or better than those available elsewhere.

These prices can be found on ZBX’s platform. ZBX updates its prices as frequently as necessary or technically possible.

4.2.      Costs

For opening a position, in addition to encountering a spread, the client may be required to pay a fee. The fee amount is disclosed on ZBX’s website[1] and the platform before confirming the order. Fees may be charged either in the form of a percentage of the overall value of the trade or as fixed amounts.

Overall costs are given high relative importance amongst the execution factors, whereby ZBX shall implement any available means to optimise fee costs for its clients.

Costs are defined as explicit charges and costs directly related to order execution, including all expenses incurred by the client which are directly associated with the execution of an order.

ZBX will consider the total costs of execution, including execution venue fees, clearing and settlement fees (where applicable), and any other fees paid to third parties involved in the execution of the order.

4.3.      Speed of Execution

Due to the levels of volatility affecting the crypto-asset prices, ZBX seeks to execute client orders as close to real-time as technically possible.

4.4.      Likelihood of Execution

In some cases, it may not be possible to execute an order, for example, in the following cases:

• during volatile markets where prices may move significantly up or down and away from declared prices;
• where there is insufficient liquidity for the execution of the specific volume at the declared price; or
• where a force majeure event has occurred.

If ZBX is unable to proceed with an Order due to any reason, the Order will not be executed. In addition, the Company is entitled, at any time and at its discretion, to decline any Order in the circumstances explained in the ZBX’s Terms of Business.

4.5.      Likelihood and Speed of Settlement

ZBX puts every effort to ensure the settlement of funds which will depend upon market practice and the ability of ZBX’s providers to settle within that market. The speed of settlement is given medium-high relative importance amongst all execution factors when determining the best execution scenario.

4.6.      Size of Order

The minimum and/or maximum size of an order may vary depending on the asset class and the type of client and is disclosed on the ZBX’s platform. ZBX reserves the right to decline an order if it does not satisfy the minimum and/or maximum size requirements.

4.7.      Nature of Order

ZBX only offers market orders that constitute orders to buy or sell immediately at the currently quoted price.

4.8.      Conditions of Custody

ZBX only employs its own custody solution designed as a hot storage of which the security is enhanced by multi-party computation technology.

4.9.      Specific Instructions

Whenever there is a specific instruction from the client, ZBX shall follow that specific instruction when executing the order and, by doing so, will satisfy its obligation to provide the best execution in relation to that aspect of the order.

If a client requires an order to be executed in a particular manner not following the Company’s general best execution principles, the client must clearly state the desired method of execution when placing the order.

Before following such instructions, ZBX shall warn the client, in writing, that any specific instructions may prevent ZBX from obtaining the best possible result for the execution of orders in respect of the elements covered by those instructions.

4.10.  Other Considerations

As the duty of best execution not only relates to price but also involves the consideration of other factors, if a trade appears not to have been executed at the best possible price, it does not necessarily constitute a violation of the duty of best execution

5.  Methodology for Determining the Relative Importance of Execution Factors

When executing orders, ZBX determines the relative importance of execution factors based on a comprehensive assessment that considers the following criteria:

a) Client Characteristics: The classification and specific needs of the client, including whether the client is a retail or professional client, and any specific execution instructions provided.

b) Order Characteristics: The nature and size of the order, including whether it is a market order or limit order, the urgency of execution, and the potential market impact of the order.

c) Crypto-Asset Characteristics: The liquidity, volatility, and trading patterns of the specific crypto-asset being traded, as well as the depth and reliability of available market data.

d) Market Conditions: Prevailing market conditions at the time of order execution, including overall market volatility, available liquidity across execution venues, and any relevant market events or circumstances.

ZBX applies these criteria systematically before executing each order to ensure that the most appropriate execution approach is selected. This methodology ensures that client orders are executed in a manner that achieves the best possible result in accordance with this Policy

6.    Execution Venues

ZBX may use one or more execution venues where it will execute orders to obtain the best possible result on behalf of the client. When doing so, ZBX shall ensure that the execution venue it selects for the execution of orders will enable it to obtain results for its clients that are at least as good as the results that it reasonably could expect from using other execution venues.

The Company maintains a list of Execution Venues, which is periodically reviewed and updated. Selection of the relevant entity is made on a case-by-case basis. The Company reserves the right to include/exclude at its own discretion one or more of the Execution Venues.

Where ZBX selects Execution Venues to provide order execution services, ZBX will summarise and make public on an annual basis, the top five execution venues in terms of trading where ZBX executed orders in the preceding year and the quality of execution obtained.

Upon reasonable request from a client, the Company shall provide its clients or potential clients with information about Execution Venues where the orders are executed.

If ZBX applies different fees depending on the type of execution venue, ZBX shall explain the differences in sufficient detail to allow clients to understand the advantages and disadvantages of the choice of a single execution venue. ZBX shall not structure or charge its fees in such a way as to discriminate unfairly between execution venues.

Where a client is invited to choose an execution venue, the client will be provided with fair, clear and non-misleading information to prevent the client from selecting solely based on the price.

6.1           Execution Quality Monitoring and Verification

ZBX has established comprehensive procedures to monitor and verify the quality of order execution on an ongoing basis.

Monitoring Procedures

ZBX conducts continuous monitoring of execution quality through:

a) Real-time monitoring of order execution to identify and address any execution issues promptly.

b) Regular reviews of execution metrics, including achieved prices, execution speed, and fill rates compared to prevailing market conditions.

c) Periodic compilation and analysis of execution data to identify trends, patterns, and potential areas for improvement.

Verification Procedures

To ensure ongoing compliance with best execution obligations, ZBX implements the following verification procedures:

a) Transaction Analysis: Regular review of executed orders to verify that execution approaches were appropriate given order characteristics and market conditions.

b) Best Execution Testing: Periodic testing to confirm that selected execution venues and approaches continue to deliver optimal outcomes for clients.

c) Client Outcome Assessment: Evaluation of execution outcomes from the perspective of client interests, ensuring that the Policy's application consistently serves clients' best interests.

6.2           Selection and Assessment of Execution Venues

ZBX selects Execution Venues based on a rigorous evaluation process, considering the following selection criteria:

a) Execution Quality: The venue's demonstrated ability to achieve optimal execution prices and minimise slippage.

b) Liquidity Provision: The depth and consistency of liquidity across relevant crypto-asset trading pairs.

c) Operational Reliability: The venue's technical infrastructure, system uptime, and order processing capabilities.

d) Regulatory Compliance: The venue's regulatory status, compliance with applicable laws, and adherence to market conduct standards.

e) Risk Management: The venue's risk controls, security measures, and safeguarding arrangements for client crypto-assets.

f) Cost Structure: The transparency and competitiveness of the venue's fee structure and transaction costs.

g) Market Access: The range of crypto-assets available and the venue's connectivity to broader market liquidity.

ZBX conducts comprehensive assessments of Execution Venues on an annual basis. The annual assessment process includes:

a) Quantitative Analysis: Review of execution quality metrics, including price improvement, execution speed, and fill rates.

b) Qualitative Review: Assessment of operational performance, service quality, and any material changes to the venue's operations or regulatory status.

c) Comparative Evaluation: Benchmarking of execution outcomes across different venues to identify the venues that consistently deliver optimal results.

d) Risk Assessment: Evaluation of counterparty risk, operational risk, and any incidents or issues that may have arisen during the review period.

ZBX's Chief Operating Officer is responsible for conducting these assessments and ensuring that Execution Venues continue to meet ZBX's standards for best execution.

6.3           Execution of Orders Outside ZBX's Standard Execution Venues

Client orders normally shall not be executed outside the pre-selected standard execution venues. However, in exceptional circumstances, before executing orders outside the standard execution venues, ZBX shall inform clients about that possibility and obtain their prior express consent before proceeding, either in the form of a general agreement or with respect to individual transactions.

6.    Execution of Orders Outside a Trading Platform

Client orders normally shall not be executed outside a trading platform. However, in exceptional circumstances, before executing orders outside a trading platform, ZBX shall inform clients about that possibility and obtain their prior express consent before proceeding, either in the form of a general agreement or with respect to individual transactions.

7.    Aggregation, Split and Allocation of Orders

The Company is not permitted to carry out a client’s order in aggregation with another client’s order unless the following conditions are met:

• it must be unlikely that the aggregation of orders will work overall to the disadvantage of any client whose order is to be aggregated;
• it is disclosed to each client whose order is to be aggregated that the effect of aggregation may work to its disadvantage in relation to a particular order; and
• where the Company has aggregated transactions on its own account with one or more clients' orders, the related trades will not be allocated in a way that is detrimental to a client. If such an order is partially executed, the Company shall allocate the related trades to clients in priority to itself.

As part of the order execution strategy, the orders of clients may, at the discretion of ZBX, be aggregated with the Company’s own orders, orders of any of the Company’s associates and/or other clients, provided the above conditions are met. Furthermore, the Company may split the client’s orders as well as aggregate orders before executing such.

Fair Allocation Methodology

When orders are aggregated and subsequently executed, ZBX applies a fair allocation methodology to distribute executed crypto-assets or proceeds among clients. The primary allocation method is pro-rata allocation based on order size, ensuring proportional distribution relative to each client's original order volume.

For specific circumstances, ZBX may apply alternative allocation methods:

a) Volume-Weighted Allocation: Applied when large orders require staged execution, ensuring that all clients participating in the aggregated order receive equitable treatment relative to their order sizes.

b) Price-Sensitive Allocation: Applied when execution prices vary across different tranches of an aggregated order, ensuring fair distribution of price improvements or costs.

Order Volume and Price Influence on Allocations

ZBX applies the following principles when order volume and execution price influence allocation decisions:

a) Larger orders within an aggregated transaction receive proportional allocations but do not receive preferential treatment solely based on order size.

b) When execution prices vary, all clients participating in the aggregated order share proportionally in any price improvements or unfavourable price movements.

c) No client's order is systematically prioritised or disadvantaged based on order characteristics alone.

Partial Execution Procedures

When an aggregated order is only partially executed, ZBX follows these procedures:

a) Proportional Allocation: Executed volume is allocated proportionally among all clients whose orders were aggregated, based on their respective order sizes.

b) Minimum Thresholds: ZBX considers minimum viable transaction sizes to ensure that partial allocations are economically meaningful for clients.

c) Remainder Distribution: Any remainder amounts that cannot be proportionally allocated are distributed in a fair and transparent manner.

d) Client Notification: Clients are promptly notified of partial executions and the allocated amounts.

In circumstances where proportional allocation would result in unfair outcomes, ZBX may apply alternative allocation approaches that better serve clients' interests, ensuring transparency and fairness in all allocation decisions.

8.    Conflicts of Interest

ZBX shall not receive any remuneration, discount or non-monetary benefit for routing client orders to a particular execution venue. It is also disallowed for ZBX employees to receive such remuneration or similar benefits.

ZBX employees shall be explicitly warned that the misuse of any information relating to clients’ orders is forbidden and can lead to disciplinary measures.

9.    Cooperation with Authorities

Upon request by the relevant regulatory authorities (including the MFSA), ZBX shall provide all the necessary information and documentation to demonstrate compliance with the requirements pertaining to the execution of orders on behalf of clients.