Best Execution Practice

HashKey MENA FZE (“HashKey”) trades virtual assets on behalf of its clients as part of HashKey’s brokerage services. In providing these services, HashKey acts in accordance with the best interests of its clients when executing Orders, transmitting Orders, or placing Orders on clients’ behalf with either its own execution venue or other entities for execution.

 

Hashkey sets out high level guidance that must be complied with to ensure that the VARA Best Execution Rules are adhered to, and ultimately to ensure that clients are being treated fairly.

 

Hashkey will exercise reasonable diligence to execute each client Order to buy or sell one or more virtual assets that it receives so as to obtain the most favourable price for the client under the prevailing market conditions, provided due consideration is given to the Execution Factors set out below to ensure the best possible result for the client.

1. the characteristics of the market for the virtual asset (e.g. price, spreads, volatility, relative liquidity and pressure on communications);
2. the size and type of transaction;
3. the number of markets or other sources of liquidity checked;
4. accessibility of quotes to trade in virtual asset(s) in question under the market conditions prevailing at the relevant time, noting that, even if the event that certain sources of liquidity are not available, HashKey is not relieved from taking reasonable steps and employing their market expertise in seeking to achieve the best execution of client Orders;
5. the terms and conditions of the Order which result in the transactions, as communicated to HashKey; and
6. any other consideration relevant to the Execution of the Order.

 

Where HashKey routes client Orders to another entity for Execution on an automated, non-discretionary basis, or where HashKey internalizes client order flows, HashKey will review, at least quarterly, the quality of execution received by their clients, with reference to how execution quality compares with the Execution quality that HashKey may have obtained from other markets or sources of liquidity. Currently, the proportion of client orders routed to any liquidity source does not exceed twenty percent (20%).

 

Hashkey does not hold or maintains funds or Virtual Assets or provides clearing services for other VASPs providing Broker-Dealer Services. Hashkey also does not refer or introduce clients to other Entities including, but not limited to, other VASPs.

 

Conflicts of Interest

In some cases, HashKey will route Orders solely to its own exchange, rather than external exchanges and trading venues. When doing so HashKey will still adhere to this Policy and will take into consideration the Execution Factors. HashKey will ensure measures are in place to identify, disclose and manage any conflicts that may arise, this includes:

• being transparent to clients about routing practices and potential conflicts;
• implementing robust systems to monitor the quality of execution to ensure Orders routed internally receive the same level of diligence; and
• regular independent reviews to ensure compliance with this Policy and the effective management of conflicts.