ClearBank Europe – Orders Execution Policy

This Order Execution Policy (the “Policy”) explains how ClearBank Europe N.V. (“ClearBank Europe”, “we”, “us”) executes and transmits client orders in relation to e‑money tokens (“EMTs”), specifically EURC and USDC issued by Circle Internet Financial Europe SAS (“Circle”).

The Policy is provided in accordance with Articles 78 and 80 of Regulation (EU) 2023/1114 on Markets in Crypto‑Assets (“MiCAR”) and is designed to give clients clear, fair and not misleading information on:

• how client orders are handled;
• how best execution is achieved; and
• what factors may affect execution quality.

By consenting to this Policy as part of onboarding, clients acknowledge and accept the execution arrangements described herein

This Policy applies to:

• Regulated financial institutions; and
• Clients established in, or operating within, the European Economic Area (EEA).

ClearBank Europe provides business‑to‑business services exclusively and does not offer services to retail clients.

This Policy applies to the following crypto‑asset services as defined under MiCAR:

• Execution of orders on behalf of clients; and
• Reception and transmission of orders,

in each case solely in relation to EMTs issued by Circle:

• EURC (Euro Coin)
• USDC (USD Coin)

No other crypto‑assets, including asset‑referenced tokens (ARTs), utility tokens, or unbacked crypto‑assets (e.g. Bitcoin or Ether), are covered by this Policy.

All orders are client‑initiated.

ClearBank Europe:

• does not provide investment advice;
• does not solicit or recommend transactions; and
• executes or transmits orders only upon receipt of explicit client instructions.

5.1 Execution Model 

Depending on the nature of the transaction, ClearBank Europe will:

• execute the order directly with the EMT issuer (Circle); or
• receive and transmit the order to Circle for execution.

ClearBank Europe currently supports Circle as the sole EMT issuer, to ensure consistent execution outcomes and operational resilience.

ClearBank Europe takes all sufficient steps to obtain the best possible result for clients when executing or transmitting orders, taking into account the following execution factors, where relevant:

1. Price
   • EURC and USDC are designed to maintain a fixed 1:1 value with their reference currency.
   • Orders are executed at par value (e.g. 1 EUR = 1 EURC).
2. Costs
   • Execution costs are transparent and disclosed prior to execution.
   • No hidden spreads, mark‑ups or inducements apply.
3. Speed
   • Orders are processed using automated workflows and real‑time rails where available.
   • Typical settlement occurs on a T+0 basis, subject to blockchain network conditions.
4. Likelihood of execution and settlement
   • High, as minting and redemption occur directly with the issuer.
5. Size and nature of the Order 
   • Large or complex orders may be staged or coordinated to ensure orderly execution.

These factors are applied consistently and in accordance with ClearBank Europe’s internal execution governance.

ClearBank Europe:

• does not receive remuneration, rebates, discounts or non‑monetary benefits from any issuer or third party for routing orders; and
• routes orders solely to achieve the best possible outcome for the client.

ClearBank Europe has appropriate organisational and technical measures in place to protect information relating to client orders.

Information relating to pending or executed client orders:

• is accessible only to personnel who require such information to perform their roles on a need‑to‑know basis;
• is subject to confidentiality, access‑control and monitoring arrangements; and
• is not used for proprietary trading, personal trading by staff, or any other purpose that may conflict with the interests of clients.

These arrangements are designed to ensure fair treatment of clients and to prevent the misuse of client order information in accordance with applicable legal and regulatory requirements.

Where a client provides specific instructions (for example relating to timing, settlement method, or execution parameters):

• ClearBank Europe will execute the order in accordance with those instructions, where operationally and legally feasible.
• Clients are informed that such instructions may limit the application of best execution factors for the aspects covered by those instructions.
• Best execution standards will continue to apply to all other aspects of the order.

Clients must provide explicit consent to this Policy as a condition of accessing ClearBank Europe’s crypto‑asset services.

The Policy is made available:

• during client onboarding;
• on the ClearBank Europe website; or
• upon request at any time.

Where material changes are made, clients will be notified and may be required to provide renewed consent before further orders can be executed.

ClearBank Europe regularly reviews:

• execution quality;
• issuer performance; and
• the continued suitability of execution arrangements.

The Policy is reviewed at least annually and updated where required by regulatory, operational or market developments.

Clients with questions or concerns regarding order execution may contact ClearBank Europe through the designated client support channels. Complaints are handled in accordance with ClearBank Europe’s Complaints Policy.

This Policy is governed by applicable EU law, including MiCAR, and relevant Dutch regulatory expectations.