Commercial and Pricing Mechanism Disclosure

1. Purpose and Overview

CoinJar Europe Limited (“CoinJar Europe”, “CoinJar”, “CEL”, “we”, “our” or “the Firm”) is a corporate entity established in Ireland in 2022, with its headquarters in Dublin. The Firm provides secure and compliant crypto-asset trading solutions across the European Economic Area (“EEA”).

We offer our customers two interrelated products — CoinJar Custody/Wallet and the CoinJar App — which are primarily accessed via iOS and Android mobile applications. Through these products, customers can buy, sell, send, and receive supported crypto-assets by entering into trades directly with us. At this time, CoinJar is restricting it’s customers from transferring EMT’s (stablecoins) off platform.

CoinJar Europe is authorised for the following crypto-asset services as defined under Article 3(1)(6) of the Markets in Crypto-Assets Regulation (MiCAR): a) Providing custody and administration of crypto-assets on behalf of clients; c) Exchange of crypto-assets for funds; d) Exchange of crypto-assets for other crypto-assets; j) Providing transfer services for crypto-assets on behalf of clients.

2. Disclosure Statement

This Pricing Disclosure (the “Disclosure”) outlines the commercial practices, pricing methodology, and client protection measures. for crypto-asset related services. The Disclosure ensures transparency, fairness, competitiveness, and regulatory compliance in alignment with MiCAR, the Consumer Protection Code 2012 (“CPC”), and Central Bank of Ireland (“CBI”) expectations.

This Disclosure applies to all consumer-facing crypto-asset exchange and custody services provided by CoinJar to EEA-based customers. This includes:

• Exchange of fiat for crypto
• Exchange of crypto for fiat
• Exchange of crypto for crypto
• Custody services (offered at no charge)

3. Types of Clients and Eligibility

CoinJar Europe provides services to a broad range of clients. including:

• Natural persons (retail and professional investors)
• Legal entities and institutional clients

Non-discriminatory criteria are applied to ensure fair access. CoinJar may impose limits or restrictions on client types to meet regulatory requirements. Any such restrictions will be published on CoinJar’s website.

Client Onboarding and Terms & Conditions

Prospective clients must:

1. Complete CoinJar Europe’s onboarding/KYC process
2. Pass due diligence checks (and ongoing monitoring assessments), which may vary by client type or risk profile
3. Consent to CoinJar Europe’s Terms & Conditions and relevant addendums
4. Comply with CoinJar Europe’s Terms & Conditions and this Disclosure

Clients must not engage in conduct that:

• Violates MiCAR or other applicable laws
• Breaches CoinJar’s Terms & Conditions or agreements
• Threatens fairness, reputation, or operational integrity
• Contravenes this Disclosure

CoinJar Europe may restrict account access or suspend services for reasons including:

• Security concerns or suspected malicious activity
• Withdrawals to wallets associated with fraud or illegal activity
• Reversal of recent transactions by banks or card issuers
• Inaccurate or outdated identity/contact information
• Failure to respond to regulatory requests
• Clients ineligible under regulatory requirements

Service Availability

CoinJar Europe’s platform is intended to operate 24/7, except during scheduled or unscheduled downtime. The platform may be suspended to maintain market integrity, for reasons including:

• System disruptions, software errors, or database issues
• Disorderly market conditions or excessive volatility
• Network, hosting, or cloud infrastructure issues
• Adverse market or on-chain events
• Regulatory or supervisory restrictions

4. Pricing Components

Component	Description
Network Fees	Third-party blockchain fees are incurred by CoinJar and passed on to clients.
Spread	The difference between buy and sell prices, determined by real-time market data.
Service Fees	Fixed/variable charges based on the payment method or platform usage.

Overall Pricing Structure:

Element	Description
Base Crypto Price	Dervied from blended market inputs.
Fixed Fee	Typically 1% rising to 2% for card payments.
Variable Spread*	Between 25bps and 60bps based on internal vs external fill.
Network Fees	Dynamic fees vary by cryptocurrency and network congestion.

*For further details on the calculation of the Variable Spread, please refer to Appendix 1 to this document.

Scenario-Based Spreads:

Scenario	Additional Spread (bps)
Internal inventory sufficient	25 - 50
Crypto sourced from external liquidity provider post-trade	40 - 60

5. Pricing Publication & Methodology

CoinJar Europe publishes prices for the crypto-assets it offers for exchange. We may also publish limits on the amount of a crypto-asset that can be exchanged at any time.

CoinJar Europe reserves the right to withhold, withdraw, or suspend published prices, or to suspend the exchange of specific or all crypto-assets, without prior notice. This may occur due to:

• Significant market volatility
• Technical or human errors in price publication
• Discretion exercised by CoinJar Europe for operational or risk management reasons

Transaction Execution and Finality

• For each transaction, the client is presented with a firm quote based on published prices or derived from our methodology.
• Clients have a reasonable opportunity to review and accept the quote.
• Once accepted, the price is final, and CoinJar Europe will execute the transaction only at the agreed price.
• Firm prices may change over time, for example due to trade size or market conditions, but all executed transactions are completed at the agreed price.

Pricing Methodology

CoinJar Europe determines prices for crypto-assets using a comprehensive methodology designed to ensure:

• Accuracy and fairness
• Alignment with prevailing market conditions

Consistency with CoinJar Europe’s Principal Dealer Model

CoinJar Europe (CJEU) acts exclusively as a principal dealer for all cryptoasset transactions. This means CJEU sets its own prices, commits its own capital, and manages all associated market risks internally. CJEU does not act as an agent, does not engage in back-to-back or riskless principal trading, and does not pass trades directly through to third parties. All positions and risks are internalised on CJEU’s balance sheet.

CoinJar uses an internal pricing engine ("PriceHub") which is a request-for-quote (RFQ) model through our mobile application and web platform. This is an automatic feature with no manual intervention and is non-discriminatory. The pricing methodology is as follows:

• Primary Pricing Feed: Prices are derived from CoinJar’s proprietary pricing engine, which aggregates data from multiple data sources (in real-time), and considers other factors such as internal demand and supply from our customers, showing our own liquidity, user activity, and order flow. There may also be additional fees depending on the payment processing method selected by the customer, for example fees tied to card payments.
• Final Client Quote: The client is presented with a firm quote, valid for a time window (e.g., 30 seconds), during which they may accept or reject the price. Once accepted, the transaction is executed at the quoted rate using CoinJar’s proprietary liquidity.
• Exchange for Crypto-to-Crypto: In crypto-to-crypto trades, the pricing is similarly derived from the aggregated fiat values of both assets, with additional spread applied to account for dual volatility risk.

CoinJar’s pricing engine dynamically incorporates real-time market data, and adjusts pricing and spreads based on:

• Market Volume and Depth: Lower trading volume or thin order books for a given asset pair will lead to wider spreads or limited availability, as the cost of replacing own liquidity rises.
• Liquidity Provider Slippage: Where external liquidity provider quotes are volatile or execution slippage increases, CoinJar’s system factors this into the pricing buffer to ensure quote integrity.
• Asset Classification: High-volume trading pairs benefit from narrower spreads and lower transaction costs, ensuring competitive pricing. In contrast, lower liquidity assets may carry wider spreads due to increased execution risk.

6. Customer Protection & Fairness

• No discriminatory pricing based on geography or customer profile.
• Trade size and market conditions are transparently reflected in pricing.
• Pricing-related complaints are handled in accordance with our Complaints Handling Policy. Customers may contact support@coinjar.com. All disputes will be managed transparently and efficiently.

7. Quote Execution and Risk Controls

• Quotes include direction (buy/sell), price, maximum size, and expiry.
• Symmetrical slippage tolerance ensures quotes are cancelled if the market moves >3% within the quote window.
• All clients receive identical pricing for the same crypto-asset and quantity, ensuring fairness.

When you execute a trade with CoinJar Europe, the price you see includes all fees and is valid for 30 seconds. Once accepted, your trade is recorded immediately, and crypto-assets are sourced from CoinJar’s inventory or third-party liquidity providers. Assets may be temporarily restricted until fully settled; you will be notified of this via email.

Adverse Market or Sourcing Risk: In rare circumstances, if CoinJar cannot source the requested crypto-assets from its inventory or a liquidity provider, your trade may be delayed, partially executed, or cancelled. CoinJar will notify you promptly and return any associated funds, if applicable.

Significant market volatility, network issues, or on-chain events may also affect execution or settlement. By trading, you acknowledge and accept these risks.

8. Discounted Pricing

Discounts to individual customers must follow a structured approval process to ensure fairness, transparency, and regulatory compliance:

• Initiation: An initiation for a discount request, providing justification and expected commercial value.
• Documentation: All requests must be submitted using the Pricing Discount Request Form and logged in the Pricing Exception Register.
• Review: The request must be reviewed and approved internally by the appropriate stakeholders.

9. Monitoring and Review

The Disclosure will be reviewed at least annually.

10. Record-Keeping Requirements

CoinJar maintains complete, accurate, and timely records to demonstrate compliance with the requirements of this Disclosure. Record-keeping supports accountability, traceability, regulatory reporting, and audit readiness. Please see CoinJar’s Record Management & Data Retention Disclosure for more information.

Appendix 1: Price Mechanism and Spread Determination

1. Principal Dealer Model

CoinJar Europe (CJEU) acts exclusively as a principal dealer for all cryptoasset transactions. This means CJEU sets its own prices, commits its own capital, and manages all associated market risks internally. CJEU does not act as an agent, does not engage in back-to-back or riskless principal trading, and does not pass trades directly through to third parties. All positions and risks are internalised on CJEU’s balance sheet.

2. Reference Price: Liquidity-Weighted Index

CJEU determines the reference price for each supported cryptoasset using a proprietary, liquidity-weighted index. This index aggregates real-time prices from multiple public, centralised exchanges, weighting each source according to its available liquidity. This methodology ensures the reference price is a robust and fair representation of the prevailing market value at any given moment. The sources and calculation methodology for this index are documented and reviewed regularly.

3. Determinants of the Variable Spread

The spread applied to the index price is determined by a systematic, rules-based process that is consistent with the principal dealer model. The key factors influencing the spread are:

• Inventory Position: CJEU’s objective is to manage its market risk and inventory levels. If CJEU seeks to increase its inventory (i.e., is looking to buy), it may offer a more attractive (higher) bid price to encourage client sales. Conversely, if CJEU seeks to reduce its inventory (i.e., is looking to sell), it may offer a more competitive (lower) offer price to encourage client purchases. This dynamic is consistent with principal dealers who must actively manage their own market risk.
• Market Liquidity: Lower liquidity, such as thinner order books or higher volatility, results in a wider spread to compensate for greater execution and market risk.
• Volatility Premium: The spread includes a deterministic premium based on recent price volatility and the cost of maintaining a firm price for the 30-second quote window. Higher volatility leads to a higher premium.
• Trade Size: Larger orders may be quoted with a wider spread, reflecting the increased risk and potential market impact of executing larger transactions.

4. Quote Structure and Execution

• Each quote is executable at the specified price, valid for 30 seconds, and includes direction (buy/sell), price, maximum size, and expiry. All clients receive the same price for the same cryptoasset and maximum quantity, ensuring fair and non-discriminatory treatment.
• Symmetrical Slippage Tolerance: To protect both clients and CJEU from unanticipated market movements, every quote is subject to a symmetrical slippage tolerance. If, during the 30-second validity window, the market price (as measured by the liquidity-weighted index) moves by more than 3% in either direction from the quoted price, the quote is automatically cancelled by the system. This process is entirely non-discretionary. CJEU cannot override or selectively apply this rule under any circumstances. Cancellations are enforced automatically and uniformly, regardless of whether the market movement is favourable or unfavourable to either party. This ensures that neither party is disadvantaged by executing trades at prices that are no longer representative of prevailing market conditions.

5. Price Transparency and Fairness

CJEU is committed to full price transparency and fair pricing:

• All clients receive the same quote for the same cryptoasset and maximum quantity, with no client-specific adjustments.
• CJEU publishes a list of recent trades conducted with other CJEU clients, enabling all clients to verify the fairness and consistency of pricing.