Order Execution Policy
Last Update: 27 June 2025
1.PURPOSE AND SCOPE
This Order Execution Policy (“Policy”) sets forth the general principles regarding the receipt, processing, and execution of client orders in relation to crypto asset trading, initial sales or distributions, clearing, transfers, custody operations necessitated by such transactions, and other activities that may be defined within the scope of the Capital Markets Law No. 6362 (“Law”), the Communiqué on the Principles Regarding the Establishment and Operation of Crypto Asset Service Providers No. III-35/B.1 (“Establishment Principles Communiqué”), the Communiqué on the Working Principles and Capital Adequacy of Crypto Asset Service Providers No. III-35/B.2 (“Operational Principles Communiqué”), and other relevant capital markets legislation as carried out through the OKX TR Kripto Varlık Alım Satım Platformu Anonim Şirketi (“OKX TR” or “Company”).
The Company executes client orders in accordance with the principles set out in this Policy and the framework agreement executed with the client.
Pursuant to Article 24/2 of the Establishment Principles Communiqué, this Policy is published on the Company’s website.
2.GENERAL PROVISIONS REGARDING CLIENT ORDERS
a.Assignment of User ID
A unique user ID shall be assigned to each client who enters into a framework agreement with the Company. A client number assigned to one client shall not be re-assigned to another client unless ten years have elapsed since the termination date of the relevant framework agreement.
Before accepting any orders from clients, a registration number shall first be obtained for each client from the Central Registry Agency Joint Stock Company (“CRA”), and this registration number shall be matched with the client number. If a registration number has already been obtained previously, the client number shall be matched with that existing registration number. The process of obtaining a registration number and matching it with the client number on behalf of the client shall be carried out through the electronic systems designated by the CRA.
Orders shall not be accepted from accounts without a registration number or from those not matched with a client number. (This rule shall become applicable following the completion of CRA announcements and integration.)
b.Order Receipt Channels and Trading Environment
It is essential that the Company receives all client orders through its own websites and mobile applications, registered in its name operated by its own operations personnel. Client orders shall not be accepted via other means or through different social media channels. A client claiming that no transaction has been executed despite placing a buy or sell order shall bear the burden of proving that the order was submitted. In this context, the Company is generally accessed through the following channels:
Website,
Application software (“OKX TR Application”),
Application Programming Interfaces (APIs).
Client orders related to crypto assets on the Company are matched within the trading environment. The counterparty to a client order may not always be another client of the Company. Matching client orders in the trading environment can also occur through counterparties that are domestic or foreign entities.
When client orders are executed in the trading environment by the Company, it is possible for entities or clients of entities located abroad to submit orders into the trading environment. Opening the trading environment to foreign entities does not absolve the Company of its responsibilities.
Additionally, client orders may be executed directly by the Company as the counterparty. The Company’s ability to act as a counterparty to client orders by entering orders into the trading environment shall be conducted within the framework of the principles set out in Article 18 of the Operational Principles Communiqué and in a manner that does not create a conflict of interest between the client and the Company. Except for transactions carried out within the scope of liquidity provision and market-making activities, it is fundamental that sales in transactions where the Company is the counterparty to its client are limited to the amount of crypto assets held in the Company’s wallets. Balances arising from transactions under this article shall be netted as of 23:59, as specified in Article 33/2 of the Operational Principles Communiqué.
In cases where client orders are executed with the Company as the counterparty, it is possible for the client’s loss to result in profit for the Company.
c.Restrictions on Orders Sent via API
In line with the principles of fair and orderly operations, the Company may impose reasonable limits on the number of orders that can be submitted via APIs. Such reasonable grounds include, but are not limited to, the following:
Protection of the API against denial-of-service attacks,
Prevention of order book abuse,
Improvement of the overall trading experience on the Company.
Furthermore, it is essential that API users conduct their transactions for legitimate commercial purposes. In cases of repeated violations of order rate limits or similar circumstances, the client’s account may be suspended or terminated.
d.Records Related to Orders
Records of all received orders, including canceled, unexecuted, and modified orders, must contain the following information:
Customer number or account number;
The crypto asset subject to the transaction;
Order type;
Whether the order is a buy or sell order;
Price information of the order;
Amount of the order;
Date and time the order was received and transmitted;
Validity period of the order;
Order sequence number;
Total Fee
Filled Amount
The currency or pair to trade.
The Company records electronic logs containing date, time, quantity, price, client, and IP information for all client orders received via the internet or other electronic environments, including those that are unexecuted, canceled, or modified. These records are maintained in a manner that allows immediate and written submission to the Board upon request. They are retained for ten years in accordance with Article 82 of the Turkish Commercial Code No. 6102. Additionally, documents subject to disputes are preserved without any time limitation until the resolution of the dispute.
3.PRINCIPLES OF ORDER AND TRANSFER EXECUTION
a.General
The Company is obliged to execute orders in a manner that provides the best possible result for the client within the scope of this Policy, considering the client’s preferences regarding price, cost, speed, likelihood of execution, settlement, size, custody, and similar factors.
The Company establishes principles for order and transaction execution to ensure that transactions are conducted reliably, transparently, efficiently, consistently, fairly, honestly, and competitively. These principles also aim to detect, prevent, and avoid the recurrence of market-disruptive actions and transactions.
When matching orders recorded in the Company’s system, the priority rules of price and time shall be applied sequentially as a primary rule. The price priority rule means that sell orders with lower prices are matched before sell orders with higher prices; likewise, buy orders with higher prices are matched before buy orders with lower prices. The time priority rule means that if prices are equal, the order that was entered into the system earlier in time shall be matched first.
b.Order Entry
The principles regarding the entry of the order are as follows:
*Order Entry Methods: Orders may be submitted through various channels such as the Company’s website, mobile application, or API interface. Orders are generally entered electronically, and all accepted orders are recorded in the system for processing.
*Automatic Order Matching: The Company may use automated systems to match incoming orders. The matching process is conducted according to criteria such as price and time priority, ensuring a fair and efficient execution process.
*System Acceptance: Orders are accepted into the Company’s trading system only if there is no technical failure (e.g., system outage or connection problem) at the time the order is placed.
c.Order Types and Validity Periods
i.Order Types
The order types that customers can submit on the Company are as follows:
1.Market Order: An order type that enables the immediate purchase or sale of a specified amount of crypto assets at the best available price in the market at that moment.
2.Limit Order: An order type that allows the purchase or sale of a specified amount of crypto assets only at the price level specified by the customer or at a more favorable price; this order remains valid until it is fully executed or canceled by the customer.
3.Post-Only Limit Order: A limit order that must be placed so as not to match with existing orders immediately in the market; if it is determined that it will match with existing orders at the time of placement, it is automatically canceled.
4.Fill or Kill (FOK) Limit Order: An order type that requires the entire quantity of the order to be executed at the specified price level or better without delay; if any part of the order cannot be fulfilled, the entire order is canceled.
5.Immediate or Cancel (IOC) Limit Order: An order type that allows immediate execution of the portion of the order that can be matched at the specified price level or better, while the unfilled portion is canceled.
6.Take Profit Order: An order type that enables the customer to set a specific profit target, triggering the order automatically and submitting it to the order book when the market price reaches that level; the order remains valid until canceled.
7.Stop Loss Order: An order type created to limit the customer's loss or initiate a trade at a specified market level, which triggers and is added to the order book when the market price reaches the designated level; it remains valid until canceled.
8.Trailing Stop Order: An order type that dynamically updates the trigger price based on changes in the market price; it becomes active and is submitted to the order book when the market price reaches the specified trigger level.
ii.Order Validity Periods
The basic order validity periods applied on the Company are as follows:
1.Good-Till-Canceled (GTC) Orders: These orders remain on the order book until they are canceled by the customer.
2.Time-Limited Orders: These orders remain visible on the order book for the duration specified by the customer, and any unexecuted portion is automatically canceled when the specified time expires.
The Company may define new order validity periods in line with principles of fairness, security, and speed, while safeguarding customer rights.
iii.Order Acceptance and Cancellation Principles
Orders are not accepted on the Company unless there is sufficient balance in the customer’s account. When an order is placed, the relevant amount is blocked in the account until the order is executed, expires, or is canceled.
When placing, canceling, or modifying an order, the customer must confirm the following information prior to the transaction:
Name of the cryptocurrency pair involved in the transaction,
Buy or sell price,
Quantity and transaction value,
Fees and charges to be borne by the customer,
Warning that the transaction cannot be reversed after execution.
An order can always be canceled before execution. However, once the order is executed, the transaction cannot be reversed.
The Company performs certain checks regarding the validity of the order before processing the transaction. Based on the results of these checks, the Company may determine that the order is invalid. These checks include the following:
1.Pre-Trade Approval: Before order transmission, to prevent incorrect entries in price, quantity, or time parameters (e.g., in market or limit order types), confirmation is obtained from the customer via a pop-up window. All transaction details must be reviewed and confirmed by the customer before the order is submitted.
2.Maximum Order Volume Controls: Parameters limiting the total order volume a customer can submit within a specific time interval are implemented on the Company. These controls prevent submission of unusually large orders.
3.Maximum Order Value Controls: Orders with excessively high transaction values directed to the market are rejected by the system to prevent possible market imbalances.
4.Price Collars (Pre-Trade Price Limits): Based on the current market price and order book depth, price limits are applied to block orders exceeding reasonable price ranges, and orders outside these limits are automatically prevented from execution.
5.Execution Throttling: Submission of multiple orders with similar characteristics within a certain time frame is limited to ensure healthy market functioning.
6.Message Throttling: The maximum number of customer messages related to order submission, cancellation, or modification allowed within a certain time interval is restricted to reduce system load and prevent potential manipulative behavior.
7.Conflict of Interest Management: Within the Company, various measures are implemented to prevent conflicts of interest and preserve fair market conditions, as detailed in the Conflict of Interest Policy.
Additionally, the Company performs certain post-trade checks. These controls involve comprehensive market surveillance to ensure a fair, transparent, and efficient trading environment, aimed at preventing illegal activities or unfair commercial practices.
d.Market Makers and Liquidity Providers
The Company cooperates (or will cooperate) with various market makers and liquidity providers to ensure liquidity. Market makers/liquidity providers working with the Company are dependent or independent service providers. The Company will exercise due diligence regarding the market makers it collaborates with. This due diligence may include, but is not limited to, factors such as experience and references, the structure of management and investment teams, performance history, financial adequacy, and any adverse information.
The Company will enter into a service agreement with market makers/liquidity providers, compliant with applicable regulations, which will define their obligations, performance indicators (KPIs), and payments where applicable.
i.Appointment Principles
The Company appoints market makers and liquidity providers based on defined criteria to ensure market integrity and efficiency. Appointed entities must demonstrate sufficient financial stability, operational capacity, and expertise in cryptocurrency markets. Appointments are made pursuant to agreements executed in accordance with Turkish Law. To support the continuity of market operations, performance expectations are explicitly stated in these agreements.
ii.Rights
Market makers and liquidity providers are granted certain rights under the agreements they enter with the Company. These rights may include fee incentives to encourage participation, such as discounts or rebates on transaction fees. Additionally, subject to the terms of the agreements, they may be granted access to certain Company features, such as advanced trading tools or priority access to data feeds. Any additional benefits provided are determined in alignment with the Company’s goal of establishing a robust and competitive trading environment and based on mutual agreement between the parties.
iii.Obligations
Under the agreements, market makers and liquidity providers are obliged to support market stability and liquidity. These obligations include continuously providing bid and ask quotes during trading hours, maintaining specified minimum trading volumes, and adhering to standards that promote market fairness. These entities are expected to act in compliance with the Company’s policies and all applicable regulations in Turkey, contributing to a regular and transparent trading ecosystem through their activities.
e.Principles for Modification and Cancellation of Orders or Executed Trades
Once an order is placed, the customer cannot modify it. If the "modify order" option is selected via the Company's website or mobile application, and the order has not yet been executed, the system automatically cancels the original order and processes a new order in its place.
However, the customer may request the Company to cancel the order. An order can only be canceled if it has not yet been executed by the matching engine (i.e., it has not been matched). The system removes the canceled order from the order book and makes the relevant asset (cryptocurrency or fiat currency) available again in the customer’s account.
i.Extraordinary Events Beyond the Company’s Control
Extraordinary events beyond the control of the Company may occur, which could affect orders or transactions.
The Company takes reasonable measures to address such extraordinary events. However, unless otherwise required by mandatory legal provisions, the Company shall not be held liable for delays or errors arising from these extraordinary events.
(a)Extraordinary Events
The main extraordinary events include the following:
Network Interruptions: Issues such as internet connection problems, server failures, or connectivity disruptions may impair the operation of the order system.
Cybersecurity Breaches: Cyberattacks may affect market stability and trading activities.
Service Disruptions by Third Parties: Service interruptions caused by third parties in contractual relationship with the Company may impact trading activities.
The Company continuously monitors these risks and takes reasonable measures to minimize disruptions. However, unless otherwise required by mandatory legal provisions, the Company shall not be held liable for transaction delays or order errors resulting from such external factors.
(b)Principles of Implementation Regarding Extraordinary Events
The Company acts in accordance with certain principles to effectively manage extraordinary events, ensure transparency, and guarantee fair execution of transactions:
i.Identification and Assessment
Extraordinary events such as system failures, network interruptions, regulatory interventions, or extreme market fluctuations are promptly detected and assessed. The Company analyzes the impact of these events on trading activities and determines the necessary actions.
ii.Order Execution and Suspension
In case of a disruption, order executions may be modified, delayed, or suspended to prevent unfair trading conditions. During extraordinary events, trading may be temporarily halted to preserve market integrity.
iii.Customer Communication
The Company informs customers about all disruptions through communication channels (website, email, in-app notifications). Estimated resolution times and subsequent steps are shared clearly and timely with customers.
iv.Risk Management Measures
Protective measures may be implemented during extreme volatility, for example, price limits, automatic order cancellations, or circuit breakers. Additionally, liquidity management strategies are used to maintain trading stability.
v.Post-Disruption Operations
Once normal operations resume, affected orders may be reactivated, canceled, or adjusted according to pre-defined rules. Necessary reconciliations are conducted transparently.
vi.Legal Compliance
All measures taken shall comply with applicable financial regulations and market practices. The Company cooperates with relevant authorities when necessary to maintain trust and ensure legal compliance.
By applying the above principles, the Company aims to minimize interruptions during extraordinary events, protect user interests, and maintain the integrity of trading activities.
(c) Definition
An erroneous order refers to orders that are placed incorrectly due to technical malfunctions, user errors, or system failures, orders executed at incorrect prices, or orders causing abnormal market behavior.
(d) Examples
Typing Error: A user mistakenly places a buy order at 10,000 USD instead of 1,000 USD.
Algorithm Errors: A malfunctioning trading bot submits numerous orders causing market disruption.
Delay or System Failure: A delayed system executes an order at an incorrect price that is no longer valid.
(e) Effects
Erroneous orders may cause sudden price fluctuations, liquidity imbalances, and unexpected market disruptions. This can result in customers facing unforeseen losses.
(f)Corrective Measures
The Company reserves the right to review at its sole and absolute discretion and, if necessary, cancel erroneous transactions to preserve market integrity. Customers affected by erroneous orders may submit a review request within a specified timeframe. In cases of significant market disruption, the Company may temporarily halt trading or reverse affected transactions. Strict monitoring and automated error detection mechanisms are employed to minimize the risk of erroneous orders.
ii.Other Material Factors Leading to Suspension of Trading of Traded Assets
The suspension of trading for traded assets may also occur in the event of the following circumstances, without being limited to them:
The project having low liquidity for a certain period.
The presence of a security issue in the project’s technology.
The project having ceased operations or the possibility of ceasing operations.
The project having ended or the possibility of ending its business activities.
The risk of the project team disbanding.
The project being on the verge of bankruptcy or the initiation of liquidation, bankruptcy, or similar legal proceedings regarding the project or its significant assets, or decisions being made to that effect.
Suspicions of the project engaging in malicious actions or behaviors.
Any member of the project or project team (including founders but not limited to them) or its advisors being under investigation for suspected violations of applicable laws, regulations, or rules, or having been found to have violated such laws and penalized.
The project engaging in wash trading (creating artificial trading volume), market manipulation, or insider trading.
The project being assessed as high risk by the Company’s audit, legal, and technical teams.
The project failing to provide the Company with requested important information within the specified time frame, including development processes, team members, listed assets, or other required details.
Any other situation that may be assessed as risky by customers or the Company.
The emergence of other material factors that would warrant the suspension of trading for the traded assets.
e.Price in Orders
The Company aims to provide a fair, competitive, and transparent trading environment for all customers within the framework of the principles outlined below.
i.Pricing Principles
The main pricing principles applied by the Company are as follows:
(a)Market- Based Pricing
Asset prices on the Company are determined according to supply and demand dynamics within the Company’s trading environment. The Company does not set prices arbitrarily; rather, prices reflect market-based valuations.
(b)Order Book Mechanism
Prices are determined through an open order book where buy and sell orders are matched based on price-time priority. The current market price is defined by the highest bid and lowest ask orders.
(c)Price Accuracy and Updates
Prices are updated in real-time to reflect current market conditions. The Company makes reasonable efforts, where appropriate, to aggregate various liquidity sources to ensure the accuracy of price data.
(d)Price Spread and Fees
The price spread is the difference between the highest bid and the lowest ask prices and may fluctuate depending on market conditions and liquidity. Transaction fees may affect the final execution price and are communicated transparently to the customer.
(e)External/Global Market Influences
The Company may reference prices from centralized cryptocurrency trading platforms located abroad; however, the final transaction price is determined according to its own order book. Significant market events, regulatory changes, and macroeconomic factors may influence price trends.
(f)Prevention of Price Manipulation
The Company actively monitors trading activities to detect and prevent price manipulation attempts (such as spoofing or wash trading). Unusual price movements may trigger automatic or manual reviews to maintain market integrity.
ii.Pricing Increments in Orders
The Company defines specific price increment intervals to ensure orderly price movements and maintain market stability. These increments determine the minimum allowable price changes between successive orders and trades. The pricing increments may vary depending on the asset type, price level, and prevailing market conditions. The Company reserves the right to adjust these increments as necessary to promote fair and efficient trading.
(a)Definition of Pricing Increments
The pricing increment is the smallest allowable price change for an asset listed on the Company. These increments are important to ensure orderly trading and support fair market practices.
(b)Impact on Order Submission
Orders must be placed in accordance with the Company’s defined pricing increments. For example, if the increment for an asset is 0.01 TRY, a price of 10.005 TRY is invalid; the user must select 10.00 or 10.01 TRY. Orders with inappropriate prices may be rejected or automatically adjusted to the nearest valid price.
(c)Determination of Pricing Increments
Increments are set based on the asset’s characteristics, trading volume, and liquidity. Highly liquid assets may have smaller increments, while volatile or less liquid assets may have larger increments to limit price fluctuations.
Example: For Bitcoin (BTC), if the increment is 0.01 TRY, valid order prices might be 10,000.01 or 10,000.02 TRY.
(d)Impact on Liquidity
Pricing increments regulate price sensitivity and prevent fragmentation of the order book. Very small increments may overcrowd the order book with numerous small orders, while very large increments can cause price gaps and reduce liquidity.
(e)Adjustment of Increments
The Company may adjust pricing increments in response to market conditions, regulatory requirements, or changes in liquidity. Users will be informed prior to any changes.
(f)Enforcement
The Company monitors compliance with these rules. Customers bear the responsibility to comply; otherwise, orders may be rejected or adjusted to valid prices.
These principles aim to provide a transparent, efficient trading environment aligned with market standards.
iii.Price Display Rules for Listed Assets
By applying structured pricing increments, the Company promotes orderly price formation, increases liquidity, and maintains trading efficiency.
1.Minimum Price Movement (Tick Size)
Orders must be placed in accordance with predefined minimum price steps (tick size) for each trading pair. The tick size may vary depending on the asset’s price level and market liquidity.
2.Asset-Specific Increments
Pricing increments differ for each asset to reflect market characteristics. Higher-value assets may have larger increments, while lower-value assets allow for finer adjustments.
3.Order Entry Validation
The Company enforces tick size standardduring order submission. Orders submitted at non-standard prices will be rejected or adjusted to the nearest valid price.
4.Dynamic Adjustments
Tick size values may be updated based on market conditions, volatility, or liquidity changes. Users will be notified in advance of such changes.
4.REGULAR REVIEW AND APPROVAL
This Policy will be reviewed annually, or more frequently if necessary, by the Document Owner or the Document Author to ensure it remains up-to-date with regulatory changes and business practices. If deemed necessary (e.g., for the purpose of aligning with current industry practices or complying with new legislative requirements), it will be updated accordingly.
The Document Approver's approval is required at least once every year or when major and significant revisions are made, whichever precedes. Minor and limited revisions may be approved by the Document Owner, unless the Document Owner is also the Author.
5.RECORD KEEPING
A copy of this Policy will be retained for a minimum of ten (10) years or longer, in accordance with applicable legislation.