Last Updated: 13 February 2026

1. Introduction

This Order Handling and Best Execution Policy (“Policy”) sets out how Bitpace (we, us, our, the company) is handling Client (“yours”, ”you”, ”yourself”) orders in order to meet the best execution requirements as defined in the Markets in Crypto Assets Regulation (EU) 2023/1114 (MiCA). This Policy applies to all clients, natural persons and legal entities.

Scope and Purpose

This Policy lays out the general approach to how we handle orders to obtain consistently the optimal results for you when we provide the services of execution of orders for crypto-assets on behalf of clients. You should read it carefully.

A link to this Policy is provided in our Standard Terms and Conditions. In order to become our client, you need to complete our onboarding process, explicitly agree to our Standard Terms and Conditions and attest acceptance and consent to this Policy and also consent that the transactions in crypto-assets are executed outside a trading platform.

We seek to achieve the best possible result for our clients when executing orders related to our two core services:

• Over-the-Counter (OTC) transactions, and
• Crypto payment gateway for merchants.

Any material changes to this Policy will be communicated to you via email.

2. Principles of Best Execution

Bitpace operates on the following key principles:

• Fair and Transparent Access: All clients are treated equally without preference or discrimination.
• Consistent Pricing and Fees: Fees are disclosed in advance and applied consistently to clients under similar circumstances.
• Client Asset Segregation: Client funds and crypto-assets are safeguarded in segregated accounts with licensed institutions or custodians.
• Complaint Handling: BItpace maintains a transparent, non-discriminatory complaint procedure accessible to all clients.

3. Execution Factors

When executing client orders, we consider several factors to achieve the best possible outcome. Depending on the service, these include:

Factor	OTC Desk	Payment Gateway
Price	Sourced from multiple liquidity providers	Automated API integration with aggregated liquidity pools
Costs	Transparent spreads and fees disclosed	Transaction fees stated in merchant agreements
Speed	Manual execution based on order size	Execution within seconds via automated routing
Likelihood of Execution	Based on counterparty availability and market liquidity	High likelihood due to automated routing
Custody of Assets	Segregated client wallets	Segregated client wallets
Size of the order	The size of the order or transaction executed,  accounting for how this affects the price of execution	The ability to handle orders of varying sizes, being able to replace liquidity taken from the order book and matching efficiently

We may adjust the weighting of these factors depending on the client’s classification, the asset involved, and the prevailing market conditions.

4. Execution Channels

Bitpace currently uses:

• OTC Desk (manual execution) – orders executed directly by BItpace’s financial operations team.
• Smart Order Routers/Aggregators – semi-automated systems routing transactions to multiple venues for the crypto payment gateway and settlement products.

Bitpace sources liquidity from several reputable providers to ensure competitive pricing and deep liquidity. The list of liquidity partners may change over time; an up-to-date list can be provided upon request.

5. Client Rights and Disclosures

• Transparency of Pricing: Clients receive clear quotations before confirming a transaction.
• Order Confirmation: Trades are executed only upon client confirmation.
• Reporting: Execution reports are available upon request.
• Changes to this Policy: BItpace will notify clients of any material changes to this Policy through our website or direct communication.

6. Conflict of Interest

BItpace does not maintain inducements or revenue-sharing arrangements that impair our duty to clients. Any potential conflicts of interest are identified, managed, and mitigated under our internal Conflicts of Interest Policy.

7. Recordkeeping

In line with MiCA requirements, BItpace maintains records of orders, transactions, and related communications for at least five (5) years and provides such records to competent authorities upon lawful request.

8. Financial Statement Request

You can request your financial statements from our Financial Operations department, and they will be available to you within 1 to 5 business days.

Once the request is addressed, a response will be provided to the originating department/unit to ensure proper communication and follow-up. To ensure transparency, the Key Account Manager will be looped in on mail threads or confirmed directly via Slack channel.

9. Data Protection

Personal data is handled in compliance with the EU General Data Protection Regulation (GDPR). Data relating to orders and transactions is retained only for as long as required under MiCA and AML/CTF laws.

10. Notice

This Public Best Execution Policy is a summary of BItpace’s internal execution arrangements. Certain operational and security details have been omitted for confidentiality and to ensure the integrity of our systems.

11. General Risks

You should be aware of the following risks in relation to the execution of trades of crypto-assets:

11.1. Slippage – refers to the risk of a difference that might appear between the expected price of a trade when the order is submitted and the price at which the trade is executed. We monitor timing and price of trades together with other execution factors and take necessary steps to address weaknesses in controls; however, we cannot guarantee the best possible result for clients for each trade (although we take all sufficient steps to obtain that), especially in circumstances of decreased liquidity, market movements and other stress scenarios outside our control.

11.2. Trading Outages – can arise from either technical failures, malfunctions, connectivity issues or other events of a similar nature. We have SLAs in place to ensure and monitor system uptime, and escalation processes in place where SLAs are not met.

11.3. Technical problems and cybersecurity – Unlike normal money, when you buy, sell or transfer crypto-assets, you are dealing with a digital asset, not a tangible asset. This means that, like any other digital system, crypto-assets are at risk of being hacked or affected by technical problems. This could result in you losing your crypto-assets or delaying your ability to sell, transfer or spend them.

11.4. Regulation – The regulation (or lack of regulation) of crypto-assets and crypto service providers across different geographies can change at any time. Any change is likely to affect the value of any crypto-assets we hold for you.

11.5. Volatility – The value of crypto-assets can fall (and is more likely to do so than normal money is). This could happen if, for example, a new, better crypto-asset is created, software developers make unexpected changes to how the crypto-asset works, or there is a change in crypto-asset regulation. The price or value of crypto-assets can rapidly increase or decrease at any time. It may even fall to zero. Unlike normal money, no bank or government can stabilise the value of crypto-assets if it changes suddenly.

11.6. Asset Delisting – in certain situations, Bitpace can choose on its own to delist a token due to several reasons, including, among others, regulatory and compliance issues, insufficient liquidity, token security issues or negative publicity. Such situations can make the price or the crypto-asset rapidly decrease. Bitpace is not liable for losses if a token’s value falls to zero or if it must be delisted due to unforeseen external events.