Summary of Order Execution Policy

Introduction

In the interest of Investor protection, as well as to promote effective procedures for executing orders (Order), this Order Execution Policy outlines the framework and procedures of Blockrise Capital B.V. (Blockrise) applicable for the best execution of Orders of Blockrise’s investors (Investor).

Blockrise is committed to achieving the best possible execution of Orders for its Investors. In fulfilling this obligation, the company takes all necessary steps to ensure that relevant factors such as price, costs, speed, likelihood of execution and settlement, size, and Order types are carefully considered. Additionally, any other relevant factors are evaluated to secure the best possible outcome.

Order Execution Approach

A four-step approach is implemented within the Investor dashboard to facilitate Orders for Investors from their wallet (Investor Wallet) or account at stichting Blockrise (Stichting Blockrise), ensuring the best execution of the transaction (Transaction). This four-step approach is provided in the following procedure:

  1. Order initiation and preparation process:
    Blockrise selects the best execution venue (Execution Venue) periodically, using the best execution analysis. Once the best execution venue for that period is chosen, Investors initiate their Orders as follows:
    1. The Investor initiates the Order execution in the Investor dashboard;
    2. Estimated Order information, including fee estimations, is shown to the Investor.
    3. Investor validates and confirms the Order;
  2. Asset Transaction to Execution Venue process:
    The process of facilitating an asset transaction from the Investor to the Execution Venue varies depending on whether the Transaction involves funds (Funds) or crypto assets (Crypto Asset):
    1. Fund Transactions: Transactions are sent from the Investor’s account at Stichting Blockrise to the Execution Venue;
    2. Crypto Asset Transactions: Crypto Assets are transferred from the Investor Wallet to the trade wallet (Trade Wallet), which are then automatically sent to the Execution Venue.
  3. Trade execution process:
    Once received at the Execution Venue, assets are traded as required. Deposits of Funds or Crypto Assets at the Execution Venue are monitored every minute. After a deposit is detected, the corresponding trade is immediately executed.
  4. Withdrawal to the Investor:
    The process of withdrawal varies depending on whether the Transaction involves Funds or Crypto Assets:
    1. Fund withdrawals: immediately transferred to the Investor’s account at Stichting Blockrise;
    2. Crypto Asset withdrawals: proceeds are immediately withdrawn to Trade Wallet, then immediately transferred to the Investor Wallet.

Best Execution Practices

This section describes Blockrise’s approach to ensuring the best execution of Orders, designed to obtain the best possible result for Investors when executing Orders on behalf of them, considering key factors such as the specific Crypto Asset, the available Execution Venues, and other relevant conditions described below. Blockrise is committed to fulfilling its best execution obligation when executing Orders directly with an execution venue. This approach ensures that Blockrise consistently acts in the best interests of its Investors, in line with industry best practices.

Best Execution Factors

Achieving best execution requires Blockrise to consider various factors relevant to the execution of the Investor's Order. These factors are:

  • Price: price at which the Order execution of the Investor can be executed.
  • Costs: all costs including fees related to the Order execution.
  • Speed: speed at which the Order execution can be finalised;
  • Size: size of the Order execution in relation to the order book depth and the influence that the Order can have on the market price;
  • Liquidity at Execution Venues: the liquidity available at the Execution Venues, to minimise the price impact in relation to the Order execution;
  • Market conditions: the nature of the volatility and market at the time of Order execution;
  • Order types: the types of Order executions offered by the Execution Venues.

Best Execution Approach

The best execution approach combines all best execution factors to optimise the best possible result for the Investor. A high-level description is provided as follows:

  1. Order type and Execution Venue assessment:
    1. Blockrise evaluates the list of available Execution Venues, to determine which Execution Venues are available for executing the Investor’s Order;
    2. For each selected Execution Venue, Blockrise assesses all possible Order types (e.g., OTC, market Order, limit Order) available per Execution Venue.
  2. Calculation process of Best Execution:
    1. Blockrise calculates the relative consideration price (Relative Consideration Price) for each Execution Venue periodically. The Relative Consideration Price considers the relative expenses per Execution Venue, incurred by the Investor, including but not limited to any market price impact given the Order size;
  3. Determination of best execution
    1. The best execution for Investor’s Orders is determined by lowest Relative Consideration Price between Execution Venues;
    2. Blockrise executes the Order at the Execution Venue that obtained the best execution results during the last periodic review;
    3. In the case of rejection or failure of execution of the Order, Blockrise will retry the Order.

Specific instructions from the Investor

When an Investor provides specific instructions, Blockrise will execute the Order accordingly. It is important to note that such instructions may override aspects of this Order Execution Policy. Best execution obligations included in this Policy do not apply to specific instructions of Investors.

Investors are notified that this could potentially impact Blockrise's ability to deliver the best execution as outlined in this Policy, either partially or fully, depending on the nature of the provided instructions. Investors receive a notification in their Investor dashboard if the specific instruction of their Order exceeds the parameters of Blockrise’s best execution.

Trade Desk

If best execution parameters cannot be achieved due to specific instructions, Investors are informed to contact the trade desk (Trade Desk) to discuss alternative options.

Conflict of Interest

Blockrise does not receive any remuneration, discount or non-monetary benefit for routing Order execution to a particular Execution Venue. Any infringements on the requirements of conflicts of interest (Conflict of Interest) must be prevented. Therefore, Blockrise ensures that Order execution routing decisions are made solely based on the best execution analysis for Investors.

Usage of Investor Funds

Blockrise handles the Funds of Investors exclusively for the purpose of Order execution. Investor Funds are not used for any other purposes such as lending or proprietary trading. Blockrise cannot access the Investor Funds held in custody due to the structure of its custody environment.

In this regard, the principle of segregation of funds is maintained, meaning that Investor’s assets and Funds will be strictly separated from Blockrise’s operational funds and held within the Stichting Blockrise.

Best Execution commitment

Blockrise takes all necessary steps to achieve the best execution for its Investors. This includes carefully selecting and monitoring our Execution Venues and continuously refining our Order routing processes.

Execution Venues

Blockrise uses a selection of multiple Execution Venues to achieve the best execution on a consistent basis for its Investors.

Selection of Execution Venues

Blockrise evaluates both new and existing Execution Venues to ensure compliance with its best execution obligations for Investors. The following approach is applied in the selection and ongoing review of Execution Venues:

  • Blockrise verifies that CASPs are authorised to offer Crypto Asset Services as a trading platform under MiCAR;
  • Blockrise validates the compatibility of the Execution Venues with Blockrise’s corporate structure and compliance;
  • The trading desk of Blockrise assesses the performance and reliability of its Execution Venues through the Execution Venue assessment, to maintain consistent quality and best execution for its Investors;
  • Any other factors deemed relevant by Blockrise, based on its professional judgement, are considered in the evaluation process.

Monitoring and Review

Every six months the Trade Desk carries out a review to determine whether the Execution Venue complies with the best execution obligations and arrangements. The monitoring protocol and review encompass the following key aspects:

  • The analysis of Blockrise’s Execution Venues, which reviews the quality of the Execution Venues semi-annually, such that the best execution possible is arranged for Blockrise’s Investors;
  • Execution Venues that do not meet the requirements must be excluded. Transactions and Orders must then be routed towards viable Execution Venues;
  • The record keeping of Orders and Transactions.

General information on Order Execution

Blockrise provides, according to Article 78(3) in conjunction with Article 78(6) of MiCAR, on a durable medium, in easily understandable words, and in a clear and comprehensible form, information regarding Order execution to the Investor, as included in Services Agreement.

The Investor can always access the Services Agreement via the Blockrise Investor dashboard. The Investor is also authorised to request a copy of the agreement at any time during the term of the agreement which will be provided without any charges.

The Investor is notified thirty days in advance of any changes in the agreement and is deemed to accept the changes in the agreement if they have not terminated the agreement before the thirty days have passed.

Investors can file a complaint (Complaint) following the Complaints procedure as described on the website of Blockrise (https://www.blockrise.com/en/legal/complaints).

Finally, the Investor is allowed to terminate the Services Agreement in accordance with the terms included in the Services Agreement.