Crypto-asset Execution Policy

1. Introduction and Regulatory Basis

1.1 This Execution Policy (this "Policy") is issued by DRW Europe BV ("DRW Europe" or the "Firm"), a company incorporated in the Netherlands and authorised by the Autoriteit Financiële Markten (the "AFM") as a crypto-asset service provider ("CASP") pursuant to Regulation (EU) 2023/1114 of the European Parliament and of the Council (the "Markets in Crypto-Assets Regulation" or "MiCA").

1.2 DRW Europe is authorised to provide the following crypto-asset services:

(a) exchange of crypto-assets for funds or other crypto-assets (the "Exchange Service"); and

(b) execution of orders for crypto-assets on behalf of clients (the "Execution Service").

1.3 DRW Europe crypto-asset Clients must consent to this Policy prior to onboarding and trading with DRW Europe. In doing so, they consent to all orders being executed outside of a trading platform, as described in Section 5 below.

2. Scope of Services

2.1 DRW Europe provides its Exchange Service and Execution Service exclusively on a bilateral, over the counter ("OTC") basis. DRW Europe acts as principal in all transactions with its clients. It does not operate a trading platform for crypto-assets and does not route orders to any trading platform or other crypto-asset service provider for execution.

2.2 DRW Europe will only trade crypto-assets that have been approved by its internal review process. The Firm's Commercial Policy sets out the type of clients with whom DRW Europe agrees to transact and the conditions that must be met by such clients.

2.3 DRW Europe provides services exclusively to institutional clients. It does not onboard or offer liquidity directly to retail clients.

3. Execution specific to the Exchange Service

3.1 When providing its Exchange Service, DRW Europe may execute transactions with clients through one or more of the following methods:

Via its trading system:

(a) Static Request for Quote. A quote requested by the client for a specific quantity of a specific crypto-asset (“RFQ”). A RFQ quote may be modified or withdrawn by DRW Europe.

(b) Request for Stream. A request by the client to receive a stream of quotes for a specified crypto-asset (“RFS”). A RFS quote may be modified or withdrawn by DRW Europe.

(c) Continual Stream. DRW Europe provides a continual stream of prices for a specified quantity of a specified crypto-asset (“CSF Quote”). A CSF quote may be modified or withdrawn by DRW Europe.

If a client decides to trade at the price quoted by DRW Europe via its trading system, DRW Europe may execute at that price provided the price is still valid when received by DRW Europe into its trading system.

Via its Relationship Managers:

Clients may request quotes from DRW Europe Relationship Managers via voice or electronic communication. Quotes provided via Relationship Managers may only be available to trade for a limited time. DRW Europe may change or cancel a quote at any time

3.2 DRW Europe has the right to change or update its Exchange Service quotes at any time.

4. Execution specific to the Execution Service

4.1 A resting limit order is an instruction from a client, that has been accepted by DRW Europe, to buy or sell a specified crypto-asset at a specified price (the "Limit Price”) or better, which remains in force until executed, cancelled, or expired in accordance with any validity period agreed with the client.

4.2 When providing its Execution Service, DRW Europe will only accept resting limit orders from clients. DRW Europe will not accept or execute any other type of order.

4.3 DRW Europe will execute as principal against the client's resting limit order. It will not route or transmit the order to any trading platform or other market participant for execution.

4.4 DRW Europe will execute some or all of a client's resting limit order when the price it has calculated for that client using its proprietary pricing methodology (the “DRW Europe Price”), matches or improves the level of the client's Limit Price for the relevant crypto-asset. When these conditions are met DRW Europe will execute at the DRW Europe Price, including where that price improves on the client’s Limit Price, unless the client has requested otherwise with DRW Europe.

4.5 DRW Europe may, at its own discretion, execute with a client in less than the full quantity of the client's resting limit order where it concludes that partial execution will contribute to obtaining the best possible result for the client (for example, where liquidity conditions or order size so warrant).

4.6 If DRW Europe has two or more identical limit orders for two or more clients that would execute at an identical DRW Europe Price then the order(s) that was/were received first, according to the DRW Europe’s timestamp, will have preference.

5. Execution common to both the Exchange and Execution Services

5.6 DRW Europe may set limits on the total notional amount it will execute with a client over a defined period, available to the specific client on request.

5.7 Under exceptional market conditions, including but not restricted to where the Firm's ability to maintain prudent risk management practices is impeded by technological issues, risk management issues or margining, or during planned or unplanned maintenance of systems, DRW Europe may withdraw its Exchange Service quotes or streaming entirely and it may cancel resting limit orders.

5.8 The price that DRW Europe quotes or streams to Exchange Service clients, and the DRW Europe Price, can vary per client notwithstanding the same market conditions for the same crypto-asset. DRW Europe takes into account the client’s credit risk, settlement reliability, typical quantity requirements and other relevant factors when calculating a price for that client.

5.9 DRWE may provide quotes or prices as set out above, unless financial, operational or risk control requirements prevent it from doing so, as set out in client agreements governing these services.

6. Execution Outside a Trading Platform

6.1 Pursuant to Article 78(5) of MiCA, where the order execution policy provides for the possibility that client orders may be executed outside a trading platform, the crypto-asset service provider shall inform its clients about that possibility and shall obtain the prior express consent of its clients before proceeding to execute their orders outside a trading platform.

6.2 DRW Europe executes all orders outside of a trading platform. By consenting to this Policy, each client expressly consents to all of its orders being executed by DRW Europe outside of a trading platform.

6.3 As DRW Europe acts solely as principal and does not route orders to trading platforms, the price at which an order is executed with DRW Europe may differ from prices available on trading platforms or from other crypto-asset service providers at the same time.

7. Execution factors for clients using the Execution Service

7.1 DRW Europe has designed its execution arrangements so as to take all necessary steps to obtain the best possible result for its clients that have chosen to enter limit orders with DRW Europe for execution with DRW Europe.

DRW Europe will take into account the following factors when executing client resting limit orders:

Price. DRW Europe's proprietary pricing is based on multiple data feeds from pricing sources globally, including indices, crypto-asset trading platforms, crypto-asset pricing services, and other pricing sources or methodologies. Pricing is impacted by market volatility and execution method. A client's resting limit order will only be executed when the DRW Europe Price matches or improves the client's limit price, thereby ensuring that, if filled, the client receives at least the price it has specified or better.
**Cost. **The prices that DRW Europe streams or quotes are all-in prices that include all of DRW Europe's business and commercial costs. They may be above or below a theoretical fair-market midpoint value calculated by DRW Europe using proprietary models. The "spread" between theoretical midpoint and quoted price may differ over time based on factors including market volatility, trade size, and overall liquidity of specific crypto-assets. Beyond this spread, DRW Europe does not impose any additional fees, expenses, or charges for transactions. DRW Europe will not charge commission unless required to do so by its client.
**Speed **of execution, meaning the time required to execute the order once the DRW Europe Price has equaled or improved the client’s Limit Price.
Likelihood of execution, meaning the probability that a client’s resting limit order will be executed as requested.
Likelihood of settlement, meaning the probability that a client’s executed order will be settled in a timely manner.
Size. DRW Europe takes order size into account in its pricing methodology. Where the Firm determines that executing the full quantity at once may not produce the best result for the client, it may execute partial fills.

8. Prioritisation of execution factors

8.1 In determining the relative importance of the execution factors described in Section 7.1, DRW Europe will, as a principle, assign the highest priority to price, followed by size. However, the relative importance of execution factors may vary depending on the characteristics of the order, the crypto-asset concerned, and prevailing market conditions.

9. Prevention of Misuse of Client Order Information

9.1 DRW Europe has established and maintains arrangements, systems, and controls designed to prevent the misuse of information relating to client orders by its employees.

9.2 These arrangements include, without limitation:

(a) information barriers between personnel with access to client order information and proprietary trading personnel;

(b) restrictions on personal account dealing;

(d) training and compliance policies requiring all relevant employees to be aware of, and comply with, applicable prohibitions on the misuse of confidential client information.

10. Monitoring and Review

10.1 DRW Europe will monitor the effectiveness of its order execution arrangements and order execution policy in order to identify and, where appropriate, correct any deficiencies in that respect.

10.2 DRW Europe shall be able to demonstrate to its clients, at their request, that it has executed their orders in accordance with this Policy, and shall be able to demonstrate to the AFM, at the AFM's request, the Firm's compliance with Article 78 of MiCA.

10.3 DRW Europe shall notify clients with whom it has an ongoing client relationship of any material changes to its order execution arrangements or this Policy.