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.
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:
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.
Achieving best execution requires Blockrise to consider various factors relevant to the execution of the Investor's Order. These factors are:
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:
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.
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.
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.
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.
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.
Blockrise uses a selection of multiple Execution Venues to achieve the best execution on a consistent basis for its Investors.
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:
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:
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.