DPB Commercial Policy

Introduction 

For its Digital assets prime brokerage (“DPB”) service, Hidden Road Partners CIV NL B.V. (“HRP NL”) has implemented this Commercial Policy (the “Policy”) in accordance with the requirements pursuant to the relevant sections of MiCAR. This Policy provides details on eligible clients for HRP NL’s services, the pricing methodology and finality of trades, and the availability of public post trade aggregated transaction related data. 

The DPB services covered by this Policy are:

• Clients using HRP NL to trade crypto-assets on crypto-asset exchanges (“DPB on exchange”);
• Clients using HRP NL to trade crypto-assets bilaterally through an ECN (“DBP ECN”);
• Clients using HRP NL to trade crypto-assets bilaterally OTC (“DPB OTC”);
• Clients using HRP NL’s spot prime brokerage model (“DPB Route 28 spot”).

As part of the DPB services, HRP NL and the client may exchange fiat for crypto-assets or vice versa for the purpose of exchanging collateral between HRP NL and the client (“collateral conversions”). 

Client relationship 

HRP NL only services per-se Professional Clients and Eligible Counterparties as defined in MiFID II. All (prospective) clients are subject to extensive checks at onboarding and during the relationship, which cover – amongst other things – AML, CFT and sanctions. Based on factors including but not limited to credit status, risk management considerations, contractual, regulatory or legal obligations, security or technology implications, the rules of the exchanges HRP supports, HRP NL reserves the right to discontinue the client relationship or restrict access to certain services. 

Pricing methodology and finality of trades

• DPB on exchange – Trades are automatically deemed to have been created between HRP NL and the client at the point that the client enters into a trade as HRP NL’s agent on a digital assets exchange – HRP NL settles on the exchange price – HRPNL is not involved in price formation;
• DBP ECN – Trades are automatically deemed to have been created between HRP NL and the client at the point that the client enters into a trade on the ECN – HRP NL settles on the agreed price – HRPNL is not involved in price formation;
• DPB OTC – Trades are considered final when they’re matched and do not constitute a breach of an HRP-established limit and/or are not executed at an off-market price. Matching is considered to have occurred when the material terms (price and quantity) of both sides of the trades have been provided to HRP NL by either a single elected party reporting on behalf of both clients or individually by both parties separately. HRP NL settles on the agreed price by the clients. HRP NL is not involved in price formation;
• DPB Route 28 spot – HRP NL acts as principal in all trades executed under the Route 28 Prime Brokerage model, intermediating between liquidity providers (“Makers”) and clients consuming liquidity (“Takers”). Prices streamed to Takers are derived from executable Maker quotes, adjusted by HRP NL’s controlled markup to reflect its role and risk as principal.
  
  Maker clients continuously stream bid and ask prices for supported instruments to HRP NL. These quotes are validated against contract specifications, including defined tick sizes, minimum quantities, and acceptable price ranges. HRP NL then determines the most competitive available quotes and generates “all-in” prices by applying its predefined markup or markdown. These prices are streamed in real time to Taker clients via HRP NL’s Crossover infrastructure.

  
  When a Taker executes at a streamed price, HRP NL enters a principal trade with the Taker and an offsetting trade with the relevant Maker, assuming temporary principal risk for any latency or slippage.

Post trade public data

HRP NL undertakes to publish aggregated information on transaction volumes and prices on its website here: https://hiddenroad.com/disclosures/hrp-civ-nl-bv/ in accordance with industry practice.

Last Updated: November 05, 2025