Trading Platform Operating Rules

Trading Platform Operating Rules

Version 1.1 – January 2025

1. Admission of Crypto-Assets to Trading

ZBX has established and maintains a comprehensive framework for the admission of crypto-assets to trading on its platform.

1.1 Assessing the suitability

ZBX only admits to trading on its platform crypto-assets issued by reputable issuers or reputable unsolicited crypto-assets. Prior to admitting a crypto-asset to trading on its platform, ZBX carries out appropriate research to assess the quality of the crypto-asset. ZBX as a minimum takes the following factors into account (as applicable):

(a) identity, technological experience, track record and reputation of the issuer and its development team; 

(b) legal and regulatory status of the crypto-asset including whether it falls under the definition of “securities” or “electronic money”;

(c) purpose and application of the crypto-asset, which must be legitimate, economically sustainable, legal and ethical;

(d) market factors like listings on other major exchanges, market capitalisation, trading volume, and others;

(e) potential association with illicit or fraudulent activities and the associated money laundering and terrorist financing risks; and 

(f) reliability of technical solutions used.

1.2 Due Diligence Process

If applicable, ZBX obtains and assesses the issuer’s and/or development team’s due diligence documentation and conducts risk screenings to ensure adherence to the AML/CFT and know-your-customer (KYC) requirements.

1.3 Approval process 

ZBX delegates the responsibility of reviewing, making recommendations, determining admissions, and monitoring admitted crypto-assets to the Company’s Risk & Compliance Committee (the “RCC”). The RCC is also entitled to suspend and/or remove crypto-assets from trading on the ZBX platform.

The members of the RCC include senior management of ZBX who are i.a. responsible for managing key business lines, risk management, and compliance functions. The members of the RCC are appointed and approved by the board.

1.4 Crypto-assets not admitted to trading

ZBX does not admit to trading any crypto-assets:

i. which have any inbuilt anonymisation functions unless the holders of those crypto-assets and their transaction history can be identified by ZBX;

ii. for which no corresponding crypto-asset white paper has been published in the cases required by the applicable regulations; or

iii. which do not satisfy the quality assessment criteria listed under the “Assessing the Suitability” section.

1.5 Non-discriminatory access

All ZBX trading clients have equal access to the platform, provided they meet the participation criteria. However, trading limits may be set based on the client's financial situation, experience, and risk profile.

Practices that could be perceived as favouritism, such as offering exclusive deals to certain clients without clear, transparent reasons, are not allowed. Feedback is encouraged from clients to identify areas of improvement in the participation rules and criteria.

2. Maintaining Admission to Trading

ZBX will continuously monitor and review each admitted crypto-asset to ensure its eligibility and suitability for admission. The responsibility for this monitoring is delegated to the RCC, which conducts periodic regular reviews and ad hoc reviews, as necessary.

2.1 Liquidity thresholds

To maintain admission to trading, crypto-assets must demonstrate daily average transaction volume above a specified threshold determined by ZBX from time to time.

2.2 Periodic disclosure

The following information, and any changes thereof, must be disclosed by the Issuers to maintain the crypto-asset’s admission to trading (as applicable):

(a) whitepaper compliant with the applicable regulatory requirements,

(b) regulatory status and any developments that might affect the regulatory status,

(c) information about key advisors and partners,

(d) information about the project’s governance model,

(e) crypto-asset project’s business model and roadmap,

(f) crypto-asset’s utility and functionality, and

(g) any material events that could significantly impact the project or crypto-asset’s value, such as changes in management, legal actions, etc.

2.3 Ongoing monitoring

ZBX ensures that every admitted crypto-asset remains suitable for trading through continuous monitoring processes carried out by the Operations function. The monitoring responsibilities are overseen by ZBX’s Risk & Compliance Committee.

Periodic reviews are scheduled at least annually to evaluate compliance with applicable regulations and these Rules. Ad hoc reviews may be triggered by significant changes or events impacting the crypto-asset, such as regulatory updates or market fluctuations.

ZBX adopts a risk-based approach, with higher scrutiny applied to crypto-assets that exhibit greater risks, such as high volatility or unclear regulatory classifications.

3. Trade Transparency

ZBX shall make public the following information in the context of pre-trade and post-trade transparency:

(a) the range of current bid and offer prices and the depth of trading interest at those prices which are advertised through the ZBX platform for crypto-assets traded on its platform on a continuous basis during trading hours;

(b) the price, volume and time of the transactions executed in respect of crypto-assets traded on the ZBX platform, as close to real-time as technically possible; and

(c) other information in line with the applicable regulatory technical standards.

The pre-trade and post-trade transparency data mentioned above shall be published separately and non-discriminatory access to the information shall be ensured.

The information will made available to the public: 

i. free of charge for at least 15 minutes after publication; and

ii. free of charge or on a reasonable commercial basis after the lapse of 15 minutes after publication.

4. Trading Halts and Suspensions

4.1 General principles

Crypto-assets are always admitted to trading subject to the condition that, where ZBX considers it necessary for the protection of the market participants or the maintenance of an orderly market, it may, at any time, halt or suspend the dealings in a crypto-asset or remove any crypto-asset from trading platform subject to such conditions as it deems appropriate, whether requested by the issuer (or the person who was initially seeking admission of the crypto-asset to trading on the ZBX trading platform), as applicable, (the “Issuer”) or otherwise.

ZBX applies the following principles in connection with a halt and/ or suspension of trading of an Issuer’s crypto-asset: 

(a) in the interests of a fair and continuous market, interruptions to trading should be kept to a minimum;

(b) before agreeing to a trading halt or suspension requested by the Issuer, ZBX needs to be satisfied that the circumstances justify an interruption to trading. ZBX reserves the right to request further information from the Issuer including (but not limited to):

i. the reasons for the halt and/or suspension, and 

ii. the reasons for the inability of the Issuer to make an immediate announcement to the market that would avoid the need to halt and/ or suspend trading;

(c) where an Issuer requests ZBX to halt or suspend the trading of a crypto-asset, ZBX shall require such request to be submitted in writing;

(d) ZBX is not obliged to accept a request of an Issuer to halt and/or suspend the trading of a crypto-asset. If ZBX does not agree to the halt and/or suspension of trading of a crypto-asset, it shall advise the Issuer immediately. It shall also discuss alternative arrangements with the Issuer, which may instead include an immediate market announcement;

(e) In the case of a request by the Issuer for a trading halt or suspension in connection with an announcement of any matter, the Issuer shall use its reasonable endeavours to issue the announcement within 24 hours from the request to ZBX;

(f) An Issuer shall continue to comply with all continuing admission obligations and disclosure standards during trading halt or suspension unless ZBX and the Issuer agree otherwise; and

(g) Unless otherwise prescribed by applicable law, no loss or damage sustained by market participants as a result of trading halts or suspensions shall be compensated by ZBX.

4.2 Trading halts

A “trading halt” is defined as a short-term interruption to trading of a crypto-asset at the request of the Issuer of that crypto-asset or at the discretion of ZBX whereby no trades are executed, and no new prices are determined. 

During a “trading halt” the crypto-asset remains listed and the trading clients are able to place, amend or cancel orders for, but are not able to trade in (i.e. place market orders), the respective crypto-asset. Existing orders for the respective crypto-asset are not automatically cancelled but instead, remain valid with the same price/time priority and are available for execution when trading resumes after the halt has been lifted. This arrangement reflects the short-term nature of a trading halt compared to a trading suspension.

The duration of the halts should be as short as possible and typically should not exceed 48 hours or until the issue is resolved (e.g. in the case of technical or operational issues).

Trading halts imposed by ZBX

ZBX shall impose a “trading halt” in the following cases:

(a) if there is a significant price movement in a crypto-asset on its platform during a short period of time, for example, if the current price is at 20% deviation or more from the previous fulfilled trade;

(b) in exceptional cases, to be able to cancel, vary or correct any transaction;

(c) if it is reasonably required for the Issuer or ZBX to fulfil their continuous disclosure obligations;

(d) in case of suspicion of market abuse or manipulation related to crypto-asset prices or trading patterns;

(e) in case of technical or operational disruptions;

(f) when ZBX has reason to believe that this is in the interest of the public or investors in general, including whenever:

i. trading in the affected crypto-asset might occur while the market participants are not reasonably informed about material events or facts concerning the affected crypto-asset, and

ii. the market in the affected crypto-asset could be false or disorderly due to other reasons;

(g) if in the ZBX’s opinion, the Issuer no longer fulfils the requirements of or has failed to satisfy or comply with or has contravened any provisions of the applicable regulations, or the agreement entered into between the Issuer and ZBX.

Trading halts requested by the issuer

Where an Issuer requests ZBX to halt the trading of a crypto-asset, the Issuer shall be requested to provide the following information and give the following explanations to ZBX:

(a) its reasons for the trading halt;

(b) the expected duration of the trading halt;

(c) the events if any which will result in the termination of the trading halt; and

(d) any other information that may be reasonably required by ZBX to assess the Issuer’s request.

Decisions on trading halts

The decision to halt trading is taken by the Company’s Chief Operating Officer. If automated, trading halts will be triggered in accordance with a set of predefined criteria.

The decision to resume the halted trading is taken by the Company’s Chief Operations Officer upon:

i. the resolution of circumstances that led to the trading halt imposed by ZBX; or

ii. the Issuer’s request to resume trading in the case of trading halts requested by the Issuer.

4.3 Trading suspension

A “trading suspension” refers to a medium to long-term suspension of the trading of a crypto-asset at the request of the Issuer or at the discretion of ZBX. During a suspension the Trading Clients are not able to place orders for, or trade in (i.e. place market orders), the affected crypto-asset. Clients are allowed to cancel existing orders. This treatment reflects the longer-term nature of a suspension compared to a trading halt.

Suspension of trading imposed by ZBX

ZBX shall suspend the trading of a crypto-asset in the following cases:

(a) if in its opinion the Issuer has furnished ZBX with false, inaccurate or misleading information;

(b) if in its opinion the Issuer has acted in a manner which is detrimental to ZBX, its trading clients or the public in general;

(c) in the case of persisting conditions that had previously triggered a trading halt in the absence of clear plans by the Issuer to resolve the issue; 

(d) if the suspension has been authorised by the relevant regulatory authorities; 

(e) in case it is determined through ongoing monitoring that the crypto-asset no longer satisfies the admission criteria;

(f) in case the crypto-asset no longer satisfies the provisions of ZBX’s internal policies, procedures and risk assessments (for the avoidance of doubt, ZBX is not obliged to disclose such provisions to the Issuer);

(g) if in the ZBX’s opinion the Issuer otherwise no longer fulfils the requirements of or has failed to satisfy or comply with or has contravened any applicable laws and regulations or the agreement entered into between the Issuer and ZBX; and

(h) if it otherwise has reason to believe that this is in the interest of investors or the general public. 

Suspension of trading by the issuer’s request

Where the Issuer requests the Company to voluntarily suspend trading of a crypto-asset, the Issuer shall be requested to provide the following information and give the following explanations to ZBX:

(a) its reasons for the suspension of trading;

(b) the expected duration of the suspension;

(c) the events if any which will result in the termination of the suspension; and

(d) any other information that may be reasonably required by the Company to assess the Issuer’s request.

In the event of a prolonged voluntary trading suspension of a crypto-asset, the Company shall consider removal from trading of the said crypto-asset.

Decisions on trading suspension

Decisions to suspend the trading of crypto-assets are taken by ZBX’s Risk and Compliance Committee.

The final decision to resume the previously suspended trading of a crypto-asset is taken by the Risk and Compliance Committee upon:

i. the resolution of circumstances that led to the suspension of trading initiated by ZBX; and

ii. the request to resume trading in the case of suspension of trading requested by the Issuer.

5. Removal from trading (delisting)

5.1 Delisting imposed by ZBX

ZBX may delist crypto-assets at any time and may do so in any circumstance including (but not limited to):

(a) in the case of breach of or non-compliance with any of the continuous admission requirements per the Company’s Terms of Business, the Listing Agreement or the applicable laws and regulatory requirements;

(b) whenever the crypto-asset removal from trading is demanded by the regulatory authorities;

if the Issuer enters into the process of liquidation or is about to be merged into or amalgamated with another entity; 

(c) if the crypto-asset has been subject to a trading halt or suspension for a prolonged period without the Issuer taking adequate action to resume trading;

(d) if the crypto-asset falls outside of the ZBX risk appetite in accordance with its risk management policies;

(e) if the crypto-asset demonstrates insignificant trading volumes for a prolonged period of time; or

(f) for any other reason providing a 30-day advance notice to the Issuer.

5.2 Delisting requested by the issuer

The Issuer may be allowed to get its crypto-asset delisted upon a 30-day advance notice to ZBX, provided the requirements of the ZBX Terms of Business, Listing Agreement, Listing Rules and the applicable regulatory requirements are duly complied with.

The Company may decide to delay the delisting in case it would be likely to cause significant damage to the investors’ interests or the orderly functioning of the market.

5.3 Consequences of delisting

Upon delisting, the crypto-asset will be made unavailable for trading by ZBX trading clients and ZBX shall purge all existing orders for the crypto-asset.

Trading clients who hold the affected crypto-assets will be advised to withdraw their assets before the withdrawal deadline set by ZBX.

In the case of delisting, ZBX shall not be liable for any resulting loss of profit, tax obligations or any other loss, damage or expense incurred by the Issuer or its investors.

Upon request by the Issuer and at its own discretion, ZBX may readmit the crypto-asset that was previously delisted upon the fulfilment of conditions and requirements that had initially led to delisting, if applicable.

5.4 Decisions for delisting

All decisions on delisting and/or readmission to trading are taken by the ZBX’s Risk and Compliance Committee.

6. Public announcements

6.1 Public announcements in the case of a trading halt and suspension

Upon a trading halt or suspension, ZBX will immediately make this decision public in the form of announcements on its website, in its mobile application and by sending email notifications to all active trading clients. The announcements will provide the rationale and clearly distinguish between trading halts and suspensions.

The announcements will contain the expected duration of the halt and/or suspension and the options available to clients for further actions.

ZBX will also make public the subsequent decision to resume trading of the affected crypto-asset, if applicable. 

6.2 Public announcements in the case of delisting

Upon making a decision to delist a crypto-asset ZBX will make this decision public at least 30 days in advance in the form of announcements on its website, in its mobile application and by sending email notifications to all active trading clients.

The announcements will provide the rationale for delisting and detail the options available to trading clients with regard to further actions.

6.3 Communications to the authorities

Whenever a decision to halt or suspend trading of or to delist a crypto-asset carries regulatory implications, the decision shall also be communicated to the relevant regulatory authorities.

7. Fair and Orderly Trading

7.1 Order execution and cancellation

ZBX offers continuous trading sessions 24 hours a day, 7 days a week. All orders are continuously automatically executed based on a pre-funded trading model, meaning no orders from a trading client will be accepted, unless there are sufficient funds (fiat or crypto-assets) available in the client’s trading account.  

When a trading client places an order, the relevant amount of the concerned fiat or crypto-assets (including applicable fees) is placed on hold in the client account until the order is filled, expires, or is cancelled. 

A trading client may cancel an order after it is submitted, as long as such order has not been executed pending confirmation by the trading platform. Crypto-assets which are the subject of a pending trade shall not be reflected in the user’s account, and shall therefore not be available for the user to trade.  Orders become irreversible once the order is executed.

7.2 Settlement of transactions

All filled orders are settled immediately, by debiting and crediting the relevant balances of crypto-assets and fiat funds in both seller’s and buyer’s accounts.

ZBX shall initiate the final settlement of crypto-asset transactions on the distributed ledger as close to real-time as is technically possible but in any case not later than within 24 hours of the transaction being executed on the ZBX trading platform, or in the case of transactions settled outside the distributed ledger, by the closing of the day at the latest.

ZBX shall ensure the final settlement of clients' fiat money, if applicable, as soon as possible in accordance with the terms and conditions duly disclosed to clients in advance.

7.3 Prevention of market abuse and manipulation

ZBX prohibits market participants and the Company’s clients, employees, directors and other stakeholders from engaging in insider dealing, manipulative transactions and/or disseminating misleading information about any crypto-assets whether listed on the ZBX platform or not which are intended to:

i. artificially affect or manipulate the price or trading volume of a crypto-asset;

ii. deceive, mislead, or otherwise improperly take advantage of ZBX or its clients; or

iii. recommending or inducing other persons to engage in either of the above.

Manipulative transactions specifically include, without limitation: layering (spoofing), wash trading, pump and dump, front running, cornering the market, quote stuffing, marking the close, etc.

ZBX implements necessary procedures, systems, and controls to prevent, detect and report orders, transactions and activities that could constitute market abuse. These are capable of flagging and generating alerts to allow for further analysis of actual or potential insider dealing and market manipulation.

The implemented controls include:

(a) trigger-based alerts related to market activity, with subsequent interventions to be taken in the case of suspicions of market manipulation;

(b) post-transactional order monitoring to detect any abnormal trade pricing, volumes, order placing patterns and other indications of potential manipulative practices;

(c) internal reporting of market manipulation risk incidents in line with the ZBX enterprise-wide risk management policies;

(d) enhanced monitoring of clients and accounts that raise suspicion or demonstrate elevated risk of market manipulation; and

(e) placing activity limits and other account restrictions or terminating business relationships with clients who demonstrate suspicions or elevated risk of market manipulation.

ZBX shall immediately report to the relevant regulatory authorities any activity, orders or transactions if it has knowledge or suspicion that these breach the market abuse and manipulation provisions.

ZBX shall not deal on its own account on the trading platform it operates.

7.4 Matched principal trading

ZBX does not engage in matched principal trading.

8. Trading Systems

ZBX has put in place and maintains robust ICT infrastructure, systems, and controls to support its business activities and operations by following industry practices while achieving a high level of information security, system resilience, and business continuity.

ZBX puts every effort to ensure its trading systems:

(a) have sufficient capacity to deal with peak order and message volumes by ensuring effective scalability and eliminating single points of failure;

(b) are able to ensure orderly trading under conditions of severe market stress without performance degradation;

(c) are able to reject orders that exceed pre-determined volume and price thresholds or are clearly erroneous;

(d) are subject to effective business continuity arrangements including effective data backup solutions to ensure the continuity of services if there is any failure of the trading system;

(e) are subject to independent and qualified third-party assessments conducting annual IT audits as well as regular penetration tests;

(f) are sufficiently robust to prevent or detect market abuse; and

(g) are able to prevent illicit activities related to money laundering or terrorist financing.

9. Fees and Rebates

ZBX is committed to transparency in its pricing. All fees are clearly listed on our website and communicated to clients prior to transaction completion. Our goal is to offer transparent, competitive, and fair pricing while ensuring compliance with regulatory requirements and maintaining the highest standards of service quality.

The following fees are being charged by ZBX in the context of operating a trading platform:

i. Account Activation, Maintenance, and Dormancy Fees;

ii. Crypto-to-Crypto Trading Fees;

iii. Fiat-To-Crypto Trading Fees;

iv. Crypto-Asset Withdrawal Fees; and

v. Listing Fees.

All current fees are available on the ZBX website except for the Listing Fee which is subject to individual negotiations with the customer seeking admission to trading. Fees can differ for individual and corporate clients. Minimum fees can apply whenever a fee is expressed as a percentage.

ZBX reserves the right to update the fees from time to time based on market conditions, regulatory changes, or operational costs. Clients are invited to consult the ZBX website on a regular basis for the most current information. Promotional discounts and offers may be available periodically whereby details of such promotions will be communicated through official channels.

Fees charged for completed transactions are non-refundable. In the event of an error or dispute, clients can contact customer support at [e-mail] for resolution.

10. Reporting to Regulatory Authorities

ZBX shall report to the relevant authorities any activities or transactions which breach or which ZBX suspects to have breached, the applicable regulations.

11. Record Keeping

ZBX shall retain records relevant to the operation of its trading platform in line with its record-keeping policies and the applicable regulatory requirements.