• Glossary

1. All capitalised terms used in this Policy shall have the following meaning:
   
   
   1. Applicant Crypto-Asset Service Provider (CASP): means the entity applying for authorization to provide crypto-asset exchange services, including the exchange of crypto-assets for funds or other crypto-assets.
   2. Crypto-Assets: means digital representations of value or rights that can be transferred, stored, or traded electronically, including cryptocurrencies, utility tokens, and stablecoins.
   3. Funds: means legal tender or fiat money that is recognized by a government and used as a medium of exchange.
   4. Clients: means individuals or entities that utilize the services of the CASP to exchange crypto-assets for funds or other crypto-assets.
   5. MiCA (Markets in Crypto-Assets Regulation): means a regulatory framework established by the European Union to ensure transparency, consumer protection, and market integrity in the crypto-assets sector.
   6. Non-Discriminatory: means a principle requiring that all clients be treated fairly and equally, without unjust or prejudicial distinctions.

2. Other terms shall have the meaning given to them in the body of this Policy.

• Introduction

1. This policy outlines the commercial practices of UAB Teroxx Worldwide ("the Company"), in compliance with Article 62 of the Markets in Crypto-Assets Regulation (MiCA). The Company is committed to maintaining a transparent, fair, and non-discriminatory relationship with its clients when providing services for the exchange of crypto-assets for funds or other crypto-assets, transfer service of crypto-assets. This policy is designed to ensure that all clients have equal access to the services offered by the Company, and that their rights are respected throughout their engagement with the platform.
2. This Policy is prepared in accordance with the Art. 77(1) of Markets in Crypto-Assets Regulation.
3. If any discrepancies between this Policy and the applicable laws and regulations are identified, the legal acts must be followed until such discrepancies are properly eliminated. 

• Purpose and Objectives

1. Ensure Compliance: Align the Company’s commercial practices with the requirements set forth in Article 77(1) of MiCA.
2. Promote Fairness: Establish a non-discriminatory framework governing the relationship between the Company and its clients.
3. Enhance Transparency: Provide clear and accessible information to clients regarding the terms and conditions of the services offered by the Company.
4. Safeguard Consumer Rights: Protect the interests of clients by ensuring that the Company’s practices do not unjustly disadvantage any client.
5. Support Market Integrity: Foster a competitive and equitable market environment in the crypto-assets sector.

• Main Principles

• Fairness:

1. The Company is committed to ensuring that all clients are treated equitably, with no client receiving preferential or discriminatory treatment based on subjective or arbitrary criteria.
2. All services, including pricing, access, and support, are provided based on transparent, objective standards that apply equally to all clients.

• Transparency:

1. The Company operates with full transparency, providing clear and comprehensive information about its services, fees, and policies.
2. Clients are informed in a timely manner about any changes to the Company’s terms of service, or pricing structures.

• Non-Discrimination:

1. The Company ensures that no client is discriminated against based on nationality, residence, or any other characteristic unrelated to the service criteria.
2. Access to services and benefits is provided on a first-come, first-served basis, or according to transparent and pre-defined criteria that apply equally to all clients.

• Consumer Protection:

1. The Company prioritizes the protection of client rights, ensuring that all practices comply with applicable legal and regulatory standards.
2. Mechanisms are in place to safeguard clients from unfair practices, fraud, and exploitation.

• Accountability:

1. The Company holds itself accountable for adhering to this policy, with internal processes in place to monitor compliance and address any deviations.
2. Employees and representatives of the Company are trained and held accountable for upholding the principles outlined in this policy.

• Accessibility:

1. The Company is dedicated to ensuring that its platform and services are accessible to all clients, including those with disabilities.
2. Efforts are made to continuously improve the accessibility of the Company’s platform, aligning with global accessibility standards.

• Client Empowerment:

1. The Company empowers its clients by providing them with the knowledge and tools necessary to make informed decisions about their engagements with the platform.
2. Clients have access to educational resources, clear communication channels, and responsive customer support to address their needs and concerns.

• Methods Used to Fulfill Purpose and Objectives

• Compliance with Legal and Regulatory Standards:

1. Legal Consultation: The Company engages with legal experts to regularly review its policies and practices to ensure they align with MiCA and other applicable regulations. This includes periodic audits of its legal framework.
2. Regulatory Monitoring: The Company monitors changes in regulatory requirements to promptly update its policies and ensure ongoing compliance. This includes participation in industry forums and regulatory consultations.

• Implementation of Non-Discriminatory Practices:

1. Standardized Service Offering: All clients are offered the same service levels and options, with no preferential treatment based on nationality, wealth, or other factors. This is implemented through automated processes that ensure uniformity in service provision.
2. Automated Fairness Checks: The Company uses automated systems to regularly check for and correct any disparities in the treatment of clients, including pricing and service access.

• Client Onboarding and Accessibility:

1. Uniform KYC/AML Procedures: The Company uses standardized KYC and AML procedures for all clients to ensure fair and equal access to the platform. This process is supported by advanced verification technologies that apply consistent criteria to all clients.
2. Accessibility Audits: The Company conducts regular audits to ensure that its platform is accessible to all clients, including those with disabilities. This includes testing for compliance with international accessibility standards (e.g., WCAG).

• Transparency in Operations:

1. Clear Communication Channels: The Company maintains multiple channels for communicating with clients, including a dedicated customer support team, regular newsletters, and a comprehensive FAQ section on the website. Clients are informed of any changes in policies or services well in advance.
2. Publicly Available Documentation: All terms and conditions, including fee structures and service agreements, are made publicly available on the Company's website. This documentation is regularly updated and written in clear, non-technical language.

• Consumer Protection and Dispute Resolution:

1. User-Friendly Dispute Resolution Mechanism: The Company has implemented a clear and accessible dispute resolution process. Clients can easily lodge complaints via an online form, and a dedicated team is responsible for resolving issues in a timely and impartial manner.
2. Third-Party Mediation: In cases where disputes cannot be resolved internally, the Company offers access to third-party mediation services to ensure fair outcomes for all parties involved.

• Market Integrity and Fair Competition:

1. Fair Pricing Algorithms: The Company employs algorithms designed to prevent price manipulation and ensure that all clients receive fair pricing based on market conditions. These algorithms are described in the internal document “Description of the Pricing Methodology” and is regularly reviewed to prevent any form of discrimination.
2. Anti-Fraud Measures: Advanced fraud detection systems are in place to identify and prevent market abuses. This includes monitoring for wash trading, market manipulation, and other activities that could harm market integrity.

• Monitoring and Continuous Improvement:

1. Regular Policy Reviews: The Company conducts quarterly reviews of its commercial policy to ensure it remains aligned with regulatory requirements and industry best practices. These reviews involve feedback from clients, regulators, and industry experts.
2. Internal Audits: The Company performs regular internal audits to assess compliance with this policy. Any identified issues are promptly addressed through corrective actions and process improvements.
3. Employee Training: The Company provides ongoing training for employees on the principles of non-discrimination, transparency, and fairness. This ensures that all staff understand and adhere to the policy in their daily operations.

• Enforcement and Accountability:

1. Disciplinary Measures: Any violations of this policy by employees or representatives are subject to disciplinary actions, including potential termination. This ensures accountability at all levels of the organization.
2. Client Feedback Mechanism: The Company has established a client feedback mechanism that allows clients to report any perceived unfairness or discrimination. Feedback is reviewed by a dedicated team and used to improve service delivery.

• General Provisions

• Non-Discriminatory Practices:

1. The Company shall treat all clients equally, regardless of their nationality, residence, or any other characteristic. Services shall be provided on a first-come, first-served basis, ensuring that no client receives preferential treatment unless explicitly stated in the terms and conditions.
2. Pricing structures, fees, and access to services shall be applied uniformly across all clients. Any variations in pricing or fees must be based on transparent, objective criteria, such as transaction volume or membership tier, and must be clearly communicated to clients in advance.

• Client Onboarding:

1. The Company shall implement a standardized onboarding process that is applied consistently to all prospective clients. This process includes Know Your Customer (KYC) and Anti-Money Laundering (AML) checks, which are necessary to ensure compliance with applicable laws and regulations.
2. No client shall be denied access to services based on arbitrary criteria. However, the Company reserves the right to refuse service to any client who fails to meet the legal and regulatory requirements necessary for onboarding.

• Service Availability and Accessibility:

1. The Company shall ensure that its platform is accessible to all clients at all times, subject to maintenance, technical upgrades, or force majeure events. Any planned downtime or service interruptions will be communicated to clients in advance.
2. The Company shall not impose any barriers that would unfairly limit or restrict a client's ability to use its services. This includes ensuring that the platform is accessible to clients with disabilities, in compliance with applicable accessibility standards.

• Transparency and Communication:

1. The Company shall provide clear, accurate, and timely information regarding its services, including but not limited to, the terms and conditions, fees, transaction processes, and dispute resolution mechanisms. This information will be readily available on the Company's website and communicated to clients as needed.
2. The Company commits to transparent communication practices, ensuring that any changes to its commercial policy or service offerings are promptly communicated to all clients.

• Dispute Resolution:

1. The Company shall establish and maintain a fair and accessible dispute resolution process. Clients shall have the right to raise complaints or disputes, which will be addressed in a timely and impartial manner.
2. The Company shall ensure that clients are informed of their rights and the procedures available for dispute resolution, including the right to seek redress through external regulatory bodies if necessary.

• Compliance and Monitoring:

1. The Company shall regularly review and update this policy to ensure ongoing compliance with MiCA and any other applicable regulations.
2. The Company shall monitor its practices to ensure adherence to the principles of non-discrimination and fairness, and will conduct regular audits to identify and address any potential issues.

• Enforcement:

1. Any violation of this policy by employees or representatives of the Company will be subject to disciplinary action, up to and including termination of employment or contractual relationships.
2. The Company reserves the right to take legal action against any client or third party that engages in activities that are contrary to the principles of this policy or that undermine the Company’s compliance with MiCA.
3. This commercial policy reflects the Company's commitment to upholding the highest standards of fairness, transparency, and non-discrimination in its dealings with clients. By adhering to the guidelines set forth in this document, the Company aims to foster trust and integrity in the crypto-assets market, ensuring that all clients can participate on an equal footing. The Company will continue to evolve this policy in response to regulatory developments and market conditions, maintaining its dedication to ethical business practices.
4. The Policy has been reviewed and approved by the Management Board. 
5. The Policy shall be reviewed by the Head of Compliance and Risk at least once a year, as well as upon changes in applicable laws and regulations related to the Policy or otherwise needed. 
6. Any modifications and amendments to the Policy shall be made in writing and become effective once approved by the Management Board. 
7. Any discrepancies, issues or concerns regarding the Policy, should be raised to the Head of Compliance and Risk, who will escalate the issue further or take appropriate actions to eliminate it as necessary.