Trading Rules and Code of Conduct

‍

I. Purpose

This Trading rules and Code of Conduct Policy outlines the principles, systems, and measures implemented by WB Fintech Development FZE and/or Digifort FZE (hereinafter referred to as the ‘Company,’ ‘WhiteBIT,’ ‘We,’ or ‘Us’) to govern the behavior and responsibilities of participants on our trading venues. This Policy ensures compliance with the UAE Virtual Asset Regulatory Authority (VARA) guidelines and international standards, promoting integrity, transparency, and accountability in trading operations.

This Policy applies to all participants interacting with the Company's trading venues. It establishes clear standards of conduct, outlines the enforcement mechanisms available to address non-compliance, and provides for the implementation of disciplinary actions to maintain the integrity of the trading venue. 

The objectives of this Policy are to: 

1. Ensure participants on the trading venue adhere to applicable regulations, rules, and directives. 
2. Equip the Company with the necessary rights and powers to enforce compliance, including issuing warnings, imposing penalties, suspending trading privileges, and reporting breaches to VARA. 
3. Protect market participants and ensure fair, orderly, and transparent trading activities. 
4. Foster a secure, compliant, and ethical trading environment by holding participants accountable for their actions.  

Through the implementation of this Policy, the Company reinforces its commitment to upholding high standards of compliance and professionalism on its trading venues while safeguarding the interests of all participants.

The Company guarantees fair disclosure of all rules mentioned in this Policy governing the behavior of users to all relevant participants. Users must provide confirmation of their agreement to these rules, in accordance with applicable laws.

‍

II. Verification procedures 

A Natural persons

Only users who have successfully completed the Know Your Customer (KYC) verification process, and who meet all other eligibility criteria established by the Company, are authorized to access and engage in trading activities. This process ensures users’ compliance with applicable local, national, and international legal and regulatory requirements, including but not limited to AML/CFT regulations.

Users from countries, territories, or regions that are subject to economic or trade sanctions, embargoes, or other legal restrictions imposed by the United Nations, European Union, United States, or other relevant regulatory authorities, are strictly prohibited from accessing the Platform or engaging in any trading or related activities. The Company will also comply with the UAE's National Terrorist List and other local regulatory restrictions as issued by the UAE Sanctions Committee and relevant authorities. 

The Company undertakes regular reviews and updates to its compliance protocols to ensure that users from restricted jurisdictions are accurately identified and prevented from accessing the Company in accordance with applicable international sanctions regimes and other relevant laws. 

B. Legal entities 

Legal entities seeking to access and engage in trading activities must provide comprehensive information about their business structure, ownership, operations, and other relevant details. This includes, but is not limited to, legal documents pertaining to directors, shareholders, and ultimate beneficial owners.

All legal entities undergo a rigorous Know Your Business (KYB) verification process, which includes: 

1. Sanctions Screening Protocols: Legal entities and their associated individuals are screened against global and local watch lists, including sanctions lists issued by the United Arab Emirates, United Nations, European Union, United States and other relevant regulatory authorities.

2. Adverse Media Screening: Checks for negative media or public records to identify potential reputational risks, such as links to financial crimes, fraud, or other illicit activities.

3. Watch List Monitoring: Ongoing checks to ensure compliance with updated sanctions and regulatory requirements.

Only users who have successfully completed the Know Your Business (KYB) verification process, and who meet all other eligibility criteria established by the Company, are authorized to access and engage in trading activities. 

‍

II. Trading Rules

A. Orders 

Users can place an order in various ways within the permitted market types, including:

• For Spot trading: a Limit Order, a Market Order, a Stop Limit Order, a Stop Market Order, and a specialized type the Multi Limit Order.

The Company is obligated to ensure that its fee structure is transparent, fair, and non-discriminatory, and does not create incentives for placing, modifying, or canceling orders, or executing transactions that disrupt the fair and orderly functioning of the market.

B. Digital assets listing rules 

Only digital assets that meet the Company’s criteria for security, liquidity, and demand are eligible for trading. These criteria are subject to the Company’s regular review and may be adjusted to align with industry standards and regulatory requirements.

All digital assets undergo a thorough review, including risk assessment and compliance checks in accordance with the Fourth Anti-Money Laundering Directive (4AMLD) – Directive (EU) 2015/849 and other legal acts. This evaluation includes but is not limited to, AML/CFT checks and due diligence measures. The approval process for admitting crypto-assets to trading is subject to the Company’s final discretion. 

The digital assets that are listed by Us are regularly monitored for compliance with regulatory standards and adherence to the Company’s criteria.

C. Digital assets delisting rules

Those digital assets that fail to meet the Company’s criteria or breach Our internal rules and policies will be subject to delisting procedures, in accordance with Our internal rules and policies. Additionally, if VARA requires the suspension of trading for any digital asset, it may impose conditions for the procedure to lift the suspension as it deems appropriate. 

The Company complies with VARA requirements, including the suspension of trading of any virtual assets upon VARA's request, as well as fulfilling the conditions for lifting the suspension, which may be set by VARA. In the event of a trading suspension, the Company will take all necessary measures to comply with VARA's conditions.

‍

III. Market Manipulation and Fraudulent Activities

A. Prohibition of Market Manipulation and Fraudulent Activities

Users are prohibited from engaging in Market Manipulation and Fraudulent Activities of any kind. The Company strictly prohibits all forms of Market Manipulation and Fraudulent Activities, including any conduct designed to distort the natural price or trading volume of digital assets. Such manipulation undermines market integrity and harms other users. The following terms of Policy apply to all users, and any violations may result in the suspension or termination of accounts, as well as legal action where applicable.

Market Manipulation involves any activity designed to artificially affect the supply or demand for a digital asset, or to create a false or deceptive impression of such activity. Common examples of manipulation include, but are not limited to, spreading false or misleading information, and manipulating quotes, prices, or trades to create a misleading perception of market activity. 

Under the term ‘Market Manipulation’, the Company understands the following actions, including but not limited to:

• Spreading False or Misleading Information: Any activity involving the dissemination of inaccurate or deceptive information to influence the price of a digital asset;
• Artificial Price Movements: Placing trades or orders with no legitimate economic purpose, but instead to create a false impression of supply, demand, or price levels;
• Using Deceptive Devices: Engaging in fictitious transactions or employing any other forms of deception to distort market outcomes. 

For the purposes of these Policy, Market Manipulation and Fraudulent Activities include, but are not limited to, the following prohibited behavior of the users: 

• ‘Price or Volume Distortion’: any actions intended to distort prices or trading volumes, or to create a false demand for a token with the intent to mislead other users into entering or exiting a trade at an artificially favorable price.
• ‘False or Misleading Information’: spreading false or misleading information about a token or market conditions, with the intent to influence the decisions of other users or the price of a digital asset, without legitimate economic grounds.
• ‘Deceptive Trading Practices’: placing orders or conducting trades that have no genuine intent to be executed or completed, but are meant to mislead other market participants about the true level of demand, supply, or price of a digital asset.
• ‘Coordinated Manipulation’: engaging in collusion or coordinating with other parties to engage in any of the aforementioned activities with the aim of manipulating the market.
• ‘Support of Manipulative Conduct’: directly or indirectly supporting, endorsing, or facilitating any form of Market Manipulation or Fraudulent Activities, including encouraging others to engage in such practices. 

Market Manipulation of any kind is strictly prohibited. It is defined as actions taken by any market participant, or a person acting in concert with a participant, intended to: 

• cause harm to users of the Platform; 
• hinder open and competitive trading on the Platform; 
• and/or produce prices and trading volumes that do not accurately reflect legitimate market forces and conditions.

B. Specific trade practice violations

The following list provides examples and descriptions of specific trade practice violations that are deemed to be major infractions. This list is not exhaustive, and additional forms of trade practice violations may be identified by Our specialists. For the purposes of this section:

• ‘Abusive Squeeze’ shall refer to the practice whereby a group of users engages in actions that create conditions compelling other market participants to purchase or sell digital assets at unfavorable prices. Such circumstances arise when a collective of users accumulates a significant position in a digital asset, resulting in an artificial increase in the price and exerting pressure on short sellers to cover their positions.  
• ‘Momentum Ignition’ shall denote the actions of the user aimed at instigating a rapid price movement in a digital asset with the intention of inducing further buying or selling activity from other market participants. This practice seeks to create a misleading sense of urgency, thereby amplifying price volatility from which the initiating User intends to profit.
• ‘Painting the Tape’ shall refer to the practice in which a user or group of users conducts mutual buying and selling of the same digital asset to fabricate the appearance of elevated trading volume or price movement. This deceptive maneuver misleads other market participants regarding genuine interest in the digital asset, potentially influencing their trading behaviors and decisions.
• ‘Phishing’ shall signify the use of fraudulent communications, including but not limited to emails or messages, intended to deceive individuals into disclosing sensitive information, such as login credentials. Such practices undermine the integrity and may facilitate unauthorized access to user accounts. 
• ‘Ramping’ shall refer to the practice of artificially inflating the price of a digital asset through coordinated buying or other means. This tactic aims to create a false perception of demand, thereby enticing unwitting investors to purchase the digital asset, enabling the orchestrators to liquidate their positions at inflated prices. 
• ‘Spoofing/Layering’ shall encompass manipulative trading practices in which a trader places large orders with the intent to create a false impression of market supply or demand, subsequently canceling those orders prior to execution. Such strategies mislead other market participants regarding the true depth of the market and may influence price movements.
• ‘Wash Trading’ shall be defined as the simultaneous buying and selling of the same digital asset by a user with the intent to create the illusion of increased trading activity without any actual change in beneficial ownership.
• ‘Churning’ shall refer to the excessive buying and selling of digital assets in a user's account executed for the primary purpose of generating commissions for the broker rather than serving the best interests of the client. 
• ‘Quote stuffing’ shall denote the practice of rapidly placing and canceling a significant number of orders to inundate the market with quotes.
• ‘Insider trading’ refers to the act of using or disclosing material, non-public information—referred to as ‘inside information’ — that could have a significant impact on the price, value, or volume of a crypto-asset or any other asset class if made public. This includes the unauthorized use of confidential information to gain an unfair advantage in trading or to influence market conditions.
• ‘Trading on non-public information’ shall refer to the use of information in transactions that is not publicly available and may have any influence on the value of digital assets. Engaging in transactions involving digital assets based on such information violates this Policy and may result in legal actions.

Non-public information includes but is not limited to, the following list: financial results and forecasts; corporate changes such as mergers and acquisitions; changes in key management; new products or services; legal and regulatory issues; dividends and capital structure changes; financing, funding and investment plans; negotiations with potential partners; terms of financial agreements; results of research and development, as well as results of internal or external audits; and other similar data. 

All users are subject to the oversight of Our specialists and may be subject to various controls and monitoring measures designed to ensure compliance and maintain market integrity. 

C. Preventive actions 

We collect only the minimum amount of user information necessary to facilitate effective market oversight and to mitigate any potential violations. We strive to automate transaction processing with minimal human intervention to enhance operational efficiency and ensure compliance with applicable regulations. 

If Our automated monitoring system detects any unauthorized/abnormal operations or activities, or Our blockchain data analysis technologies or other applicable monitoring tools employed by Us track any form of manipulation, We reserve the right to take the following actions*:

• Account Suspension: The user's account may be temporarily suspended while we investigate the issue. 
• Limited Access: The user may lose access to certain or all features until the investigation is completed. 
• Transaction Reversal: Any suspicious trades or transactions may be reversed or adjusted.
• Report to Authorities: If necessary, We will report the issue to the VARA or other regulatory authorities. 
• Penalties: Depending on the findings, penalties may include permanent suspension of the user's account, charging a full amount of Funds from the balances of such user, and potential legal action.

*Please be aware that any attempt at Market Manipulation or breach of this Policy will result in swift and severe consequences from Our side.

D. Investigation process and penalties 

We provide user support services by enabling users to report potential manipulations and implementing measures to prevent such activities, including: 

• Maintaining accessible and responsive channels for users to seek assistance or raise concerns; and
• Resolving users promptly and fairly, following established procedures and regulatory requirements.

In the event of violations, We reserve the right to apply disciplinary measures against users, which may include but not limited to: issuing warnings, reprimands, conducting training, implementing remediation plans, compliance audits, and other penalties. 

The Company shall have the authority to pursue additional remedies or disciplinary measures against participants of its trading venue, as determined by VARA. In its sole discretion, VARA may delegate to the Company the power to enforce such additional remedies or disciplinary actions, subject to its written consent.

In the event that further information is deemed necessary following a review of an alert, market observation, or one or more customer complaints, Our specialists will initiate the process of gathering additional data. This may include requesting specific information from users, who are required to comply with such requests and cooperate fully with the investigation. 

Cooperation may involve actions such as winding down, altering, or closing a particular trade or position. Failure by a user to provide the requested information or otherwise comply with Our specialists may result in formal actions against the user.

Upon completion of the investigation, a detailed investigative summary will be prepared, outlining the relevant rule(s) in question or other identified abusive behavior, and the findings that may indicate a rule violation. We determine whether formal action is warranted to address the identified violation(s).

Users must comply with all applicable laws and regulations concerning market manipulation. Any attempts to manipulate market conditions, prices, or trading volumes are strictly prohibited and may result in significant penalties under applicable law, including suspension from the platform and further legal consequences. 

Sanctions available under this Policy may include reporting to government, law enforcement, or other authorities without providing prior notice to the user; freezing or confiscating funds, property, proceeds, or digital assets; and suspending or terminating the user's access to the Company services or to such digital assets. 

The Company is obligated to provide VARA with information for supervisory and disciplinary purposes and to develop mechanisms for transmitting data regarding major risks in interconnected markets. In the event of suspected Market Manipulation, the Company must provide VARA with the following information:

• details of a user’s positions, in particular details of any large positions held, including on-exchange, related “over-the-counter” derivatives, and physical market positions;
• digital asset inventory levels;
• delivery mode and forms of service;
• action taken to implement position management powers;
• changes to position limits;
• additional margin calls;
• Other action taken by the Company.

We also reserve the sole and absolute discretion to seize and deliver a user’s property to any relevant government, law enforcement, or other authorities, as warranted by the circumstances or in compliance with applicable laws.

‍

IV. Trading Systems Resilience and Business Continuity

A. Trading Systems Resilience
‍

The Company is committed to implementing effective systems, procedures, and mechanisms to ensure the resilience of Our trading systems, including: 

• Ensuring sufficient capacity for orderly trading under conditions of high uncertainty and extreme volatility; 
• The ability to reject orders that exceed pre-determined volume and price thresholds or are clearly erroneous;
• Comprehensive testing of trading systems to ensure compliance with all necessary conditions;
• Ensuring the continuity of trading systems, including backup and disaster recovery systems, resources, and facilities, to ensure the uninterrupted provision of services and reporting in the event of a system failure.

B. Business Continuity  

The Company has developed and implemented business continuity plans, including measures for the recovery and backup of trading systems, to ensure uninterrupted services and reporting capabilities in the event of a trading system failure. 

The Company guarantees that these measures have already been implemented and are fully operational.

C. Policy Review 

We commit to conducting an annual review of this Trading Venue Participants and Code of Conduct Policy to ensure it remains aligned with regulatory changes, industry best practices and operational insights.