Order Execution Policy

1. Purpose

This Order Execution Policy (the “Policy”) explains how CoinJar Europe Limited (“CoinJar”, “we”, “us”) executes crypto‑asset transactions when acting as a principal counterparty to you, the customer (“you”, “your”). As a regulated Crypto‑Asset Service Provider (CASP) under Regulation (EU) 2023/1114 (MiCAR), we aim to provide transparent, fair, and efficient execution of your orders.

By opening an account with us or placing an order, you agree to this Policy and acknowledge that you have reviewed it in full.

2. Scope

This Policy applies to all customers based in the European Economic Area (EEA) using CoinJar’s services for buying or selling crypto‑assets where CoinJar acts as principal (i.e., we transact directly with you).

3. Execution Model & Principal Role

• When you use our platform to buy or sell a crypto‑asset, CoinJar acts as the counterparty, meaning you transact directly with us rather than via multiple external exchanges or liquidity providers.
• The price you accept includes our negotiated spread and any applicable fees.
• Because we act as principal, we determine how the execution takes place — though we still aim to provide you with a favourable trading outcome in line with this Policy.

4. Execution Factors

In executing your orders, we consider the following factors (and others where relevant):

• Price: The price at which your crypto‑asset is bought or sold, inclusive of our spread.
• Costs: All costs you bear (fees, network costs, spreads) in addition to the price.
• Speed: Time between your order submission and execution.
• Likelihood of execution / settlement: Probability that we will complete your trade and settle it without failure.
• Size and nature of your order: Larger orders may affect the price or timing due to our liquidity constraints.
• Market conditions: Depth, volatility, liquidity of the asset, and any external constraints (e.g., network issues, forks).

5. Client Instructions - Possible Exception

If you provide specific instructions that are available as part of our service offering, we will execute your order in accordance with those instructions. However, by giving such instructions, you may limit our ability to apply our standard execution process, and you acknowledge this may lead to a less favourable outcome.

6. Settlement and Liquidity Sourcing

When you execute a trade with CoinJar:

• Quote Validity: The price you see includes all fees and is valid for a short period (typically 30 seconds).
• Immediate Recording: Once accepted, your trade is recorded immediately.
• Liquidity Sourcing: Crypto-assets are sourced from CoinJar’s own inventory or third-party liquidity providers.
• Account Updates: Your account balances update to reflect the trade, but assets may be temporarily restricted until fully settled.
• Maximum Settlement Time: Settlement and sourcing will be completed within 24 hours of trade acceptance, except in cases of extreme market or operational events.
• Adverse Market or Sourcing Risk: In rare circumstances, if CoinJar cannot source the requested crypto-assets from its inventory or a third-party liquidity provider, your trade may be delayed, partially executed, or cancelled. CoinJar will notify you promptly and return any associated funds if applicable.
• On-Chain and Market Events: Significant market volatility, network disruptions, chain splits, or hard forks may also affect execution or settlement. By trading, you acknowledge and accept these risks.

7. Transparency & Confirmations

• We will display the price, applicable spread and fees before you confirm your trade.
• After execution, we will provide a confirmation showing the executed price and breakdown of costs.
• Your trade will be deemed final once it is executed by us and recorded in your account.

8. Conflicts of Interest

• Because we act as principal, we may profit from the spread between our bid and ask prices.
• We have implemented internal controls, staff remuneration schemes, and order‑handling policies designed to prevent us from acting to the detriment of your interests.
• Where a material conflict of interest arises that we cannot avoid, we will disclose it to you in a clear and timely manner.

9. Limitations & Adverse Market Conditions

CoinJar’s duty to provide the client with best execution does not create any fiduciary responsibilities over and above the specific regulatory obligations placed upon it or as may be otherwise contracted between CoinJar and the client. The client remains responsible for the client's own investment decisions and CoinJar will not be responsible for any market trading loss the client suffers as a result of those decisions. CoinJar reserves the right to deviate from its standard order execution policy during adverse market conditions where strict adherence may compromise client outcomes, market integrity, or operational stability.

• In certain adverse market conditions we may deviate from this Policy to protect market integrity, our systems, or our clients.
• You accept these possibilities and acknowledge that execution in such circumstances may be cancelled, delayed or otherwise affected.

10. Client Acknowledgement

By placing an order, you confirm that you have read and understood this Policy and accept that CoinJar will execute your order as described above. If you do not wish to proceed under these terms, you must not place the order.

11. Review & Monitoring

We monitor our execution practices regularly to assess whether our execution outcomes for customers meet our internal standards. We review this Policy at least annually or when material changes in our business or the market occur. Any changes will be published and we will notify you of material updates.