1. Introduction

1.1. This Order Execution Policy (“Policy”) govern the procedures, requirements and conditions for Users to trade Crypto Assets on https://www.gate.tr (“Platform”) operated by GATE KRİPTO VARLIK ALIM SATIM PLATFORMU A.Ş (“Gate TR”), a company established in Turkey and regulated by the Capital Markets Board of Turkey (“CMB”).

1.2. This Policy, as amended from time to time, apply to, and is binding on, all Users of Gate TR. Users are required to:

1.2.1. read, understand, agree to and abide by (a) this Policy (as amended from time to time) to have access to and continued use of the Platform; (b) any rules, requirements, conditions and procedures issued by Gate TR under this Policy; (c) the provisions of any notice issued by Gate TR; (d) requirement, decision or direction of Gate TR made in accordance with this Policy, subject always to Gate TR’s Complaints Handling Policy.

1.2.2. Read, acknowledge and agree to the Risk Disclosure Statement, User Agreement and Terms of Use, and other policies and procedures which can be accessed on Gate TR’s website, before being allowed to trade on the Platform;

1.3. A User who does not agree to the Risk Disclosure Statement is not permitted to trade on the Platform.

1.4. This Policy forms part of the User Agreement and Terms of Use entered into by each User with Gate TR and in the event of any conflict between this Policy and the User Agreement and Terms of Use, this Policy shall prevail.

1.5. This Policy along with the User Agreement, and Terms of Use, and other policies and procedures which can be accessed on Gate TR’s website constitute a binding contract between Gate TR and each User. A User’s continued use of the Platform will be considered as an agreement to abide by this Policy and the User Agreement and Terms of Use.

2. Defined Terms

2.1. In this Policy, the following words and phrases have the meanings shown next to them, unless the context requires otherwise. 

Term	Definition
Account	Means an account held with Gate TR in the name of the User.
AML	Means Anti-Money Laundering which should be construed to include counter terrorist financing.
Applicable Laws and Regulations	Means provisions of laws, statutes, ordinances, rules, regulations, permits, certificates, judgments, decisions, decrees or orders of any Competent Authority applicable to Gate TR or the Users.
Applicant	Means a natural or a legal person who makes an application to open an Account with Gate TR.
User	A natural or legal person who has satisfied the on-boarding requirements of Gate TR and has been authorised to undertake trading in Crypto Assets on the Platform.
User Agreement and Terms of use	The agreement entered into between Gate TR and a User for the provision of services as provided for under such agreement.
Direct - Access Model	An access model where Users can directly trade on the Platform without the need of any intermediaries.
Competent Authority	CMB and any other regulatory, judicial or law enforcement authority that has jurisdiction over the activities of Gate TR, the Platform, or the Users.
Downtime	Any scheduled or unscheduled period during which the Platform is inaccessible or any material functionality of the Platform does not function as intended.
Execute, Executed, Executing and Execution	Effecting a trade where Orders have been matched by debiting and crediting the relevant quantities of Crypto Assets and/or amount of fiat currency, that have been put on hold in accordance to Section 9.36, in the relevant Users’ Accounts.
Fill, Filling, Filled	The complete or partial matching of two Orders which results in a trade.
Financial Crime	"Any kind of criminal conduct relating to money, financial services or markets, including any offence involving: (a) fraud or dishonesty; (b) misconduct in, or misuse of information relating to, a financial market; (c) handling the proceeds of crime; (d) the financing of terrorism; or (e) other activities intended to gain or protect financial benefits through deceitful and unethical means."
Force Majeure	Event(s) which is reasonably beyond the control of Gate TR, including, but not limited to, acts of God, fire, acts of terrorism, natural disasters, infectious diseases, war, civil commotion, embargo, labour dispute, prevention from obtaining raw materials, power failure, acts of government, etc.
Inside information	Inside Information refers to non-public, precise information that could reasonably impact the price of a Crypto Asset or the investment judgment of a reasonable individual or User in relation to that Crypto Asset.
Insider Dealing	"Insider Dealing refers to the situation where any User or third party possesses Inside Information and uses that information by carrying out a transaction, for its own account or for the account of a third party, directly or indirectly, in relation to a Crypto Asset to which the Inside Information relates. Insider Dealing also includes the utilization of Inside Information to cancel or modify a transaction or order related to a Crypto Asset to which the Inside Information relates where transaction or order was placed before the relevant User possessed the Inside Information."
Limit Order	An Order to buy or sell a specified quantity of a Crypto Asset at a specified price or a better price.
Maker Order	"An Order to buy or sell a Crypto Asset at a different price to all existing Orders, and which will remain open at that price on the Order Book until: 1. It is cancelled by the User; 2. It expires due to a time-in-force Instruction; or 3. It is completely Filled by one or more Taker Orders placed by another User at the same price."
Market Abuse	Market Abuse refers to the events which have been described under Section 14 of this Policy.
Market Order	An Order where a User places an Order to be Filled at the current market price of the relevant Crypto Asset.
Open Order	An Order that has not yet been Filled.
Order	An instruction from the User placed on the Platform to buy or sell a Crypto Asset.
Order Book	The live electronic record of Open Orders for trading pairs.
Pre-Open Session	The period of time specified by Gate TR before the start of a new trading session following a Trading Suspension or before the admission of a new Crypto Asset for trading. It is the Order accumulation period during which all Orders entered by Users are automatically recorded in the Order Book without being Executed, and Orders can be cancelled.
Risk Disclosure	The risk disclosure document accessible at https://gimg2.gateimg.com/gatetr/doc/1732157707773135914-Risk_notice_tr.pdf
Suspension of Trading	The period of time during which trading activity for a Crypto Asset on the Platform is suspended by Gate TR.
Taker Order	An Order to buy or sell a Crypto Asset that is posted to the Order Book at the same price as one or more existing Orders, which will result in an immediate Fill at that price, to the extent of the total quantity of those existing Orders.
Crypto asset	Intangible assets that can be electronically created and stored using distributed ledger technology or similar technology, distributed via digital networks, and represent value or rights.

3. Applicability

3.1. This Policy shall be applicable to all Users and to all transactions facilitated on the Platform.

3.2. This Policy and amendments thereto shall be effective from the date of the publication.

3.3. This Policy shall continue to apply to a User for a period of 12 months following the User’s termination, as provided for under the User Agreement and Terms of Use.

4. Openıng Account, User Access and Code of Conduct

4.1. Gate TR adopts a Direct - Access Model, where all Users can directly trade with Gate TR without any intermediary (such as a broker-dealer). Gate TR will carry out due diligence of a new User before onboarding such User and will also monitor the User’s ongoing compliance with the Applicable Laws and Regulations.

4.2. In order to become a User of Gate TR, Applicants must:

4.2.1. complete the online application form;

4.2.2. agree and accept the User Agreement and Terms of Use;

4.2.3. read, understand, and agree to abide by this Policy and other policies and procedures,

4.2.4. meet the eligibility criteria in the User Agreement and Terms of Use;

4.2.5. provide such additional information as Gate TR may require in the online application form or for the purposes of customer due diligence (“CDD”), AML/ KYC checks, or compliance; and

4.2.6. complete all the onboarding procedures including but not limited to AML / KYC procedures, to the satisfaction of Gate TR.

4.3. Gate TR shall undertake CDD measures in accordance with Applicable Laws and Regulations to verify the identity of the User. As part of the onboarding procedure, Applicants must provide Gate TR with certain information and documentation associated with identity verification and the screening procedures that Gate TR employs- a process known as Know Your Client (“KYC”). Based on MASAK requirements and Gate TR’s risk assessment, Gate TR reserves the right, at any time and its sole discretion, to demand any additional documents / information from a User. Gate TR shall, on an ongoing basis, review CDD records to ensure that it is up-to-date and that no identification documents provided have expired.

4.4. Gate TR may, in its absolute discretion, accept the Applicant as a User, if an Applicant complies with Section 4.2 and Section 4.3, and satisfies the eligibility criteria in the User Agreement and Terms of Use. Each application is vetted by Gate TR’s AML/KYC Team.

4.5. Gate TR reserves the right, in its absolute discretion and without liability or an obligation to provide reason, to restrict, suspend or terminate the User’s access to, and the use of, the Platform in accordance with the terms of the User Agreement and Terms of Use or this Policy (See the User Agreement and Terms of Use). Gate TR will endeavour to notify the User by email of such suspension or termination of access.

4.6. Gate TR will undertake ongoing monitoring of the Users transactions on the Platform and retains the right to demand any additional documents / information from a User in relation to any transaction on the Platform at its sole discretion. 

5. Notification obligations

5.1. A User must notify Gate TR as soon as practicable:

5.1.1. if they have or may have committed a breach of this Policy, the User Agreement and Terms of User or any relevant Applicable Laws and Regulations;

5.1.2. if a Competent Authority is investigating or instituting any investigation, disciplinary or enforcement proceedings against the User;

5.1.3. the receipt of an injunction, or the imposition of a sanction against the User by any of the Competent Authority relating to the User’s activities on the Platform or which may otherwise be material in the context of the User’s obligations under this Policy;

5.1.4. the occurrence of any Default Event;

5.1.5. if they discover or suspect any unauthorized access or use of their Account or any security breaches related to their Account;

5.1.6. any material change in the User’s ability to comply with this Policy or any relevant Applicable Laws and Regulations;

5.1.7. any changes or prospective changes affecting its ability to meet the criteria set out any matter which results in the User being unable to comply with the eligibility criteria under the User Agreement and Terms of Use or its continuing obligations under the User Agreement and Terms of Use; and

5.1.8. if there is a need to report a material incident in relation to their Account, including any material operational problems or security concerns related to their Account.

5.2. The aforementioned notifications must be made using the appropriate means as notified by Gate TR to the User from time to time, including through the user interface.

6. Communications with Users

6.1. All communications, agreements, documents, notices and disclosures that Gate TR provides under this Policy and in connection to a User’s Account, in the absence of any express agreement to the contrary, shall be deemed to be to be duly notified to the User if:

6.1.1. posted on Gate TR’s website; or

6.1.2. sent to the User’s last known registered email address.

6.2. All communications between a User and Gate TR shall be in Turkish. This includes every document or information provided or required to be provided by a User to Gate TR.

7. Listing of Crypto Assets

7.1. Gate TR will list Crypto Assets in accordance with the Coin Listing Policy and the Coin Listing Standards which are in line with the regulatory requirements of the CMB and can be accessed on Gate TR’s website.

7.2. Subject to Section 7.1, the decision to admit a Crypto Asset for trading on the Platform is at the sole discretion of Gate TR. Gate TR shall publish a notice pertaining to the admission of a new Crypto Asset which shall comprise of details including, inter-alia, the effective date of such admission and the duration of the Pre-Open Session.

8. Delisting or suspension of Crypto Assets

8.1. Without prejudice to the Listing Policy and the Listing Standards, Gate TR shall delist a listed Crypto Asset or have Suspension of Trading for a listed Crypto Asset if:

8.1.1. such delisting or suspension has been approved by the CMB; or

8.1.2. such delisting or suspension is required for Gate TR to comply with Applicable Laws and Regulations;

8.1.3. such delisting or suspension is required to protect the fair and orderly operation of the Platform;

8.1.4. Any Crypto Asset exceeds or is likely to exceed any specific parameters published on the Platform, including where, in Gate TR’s discretion, a Crypto Asset, is exhibiting unusual or excessive price volatility;

8.1.5. a Crypto Asset no longer complies with the terms and conditions, and requirements of the Platform (unless such Suspension of Trading or delisting would likely cause significant damage to the User’s interests or the orderly functioning of the market);

8.1.6. such delisting or suspension is required as a result of a hard fork affecting the relevant Crypto Asset; and/or

8.1.7. such delisting or suspension is required in connection with a Downtime.

8.2. The decision to delist, or impose a Suspension of Trading for, a listed Crypto Asset is at the sole discretion of Gate TR. Gate TR shall delist, or impose a Suspension of Trading for, listed Crypto Assets:

8.2.1. where the specific Crypto Asset no longer complies with this Policy, the Coin Listing Policy and the Coin Listing Standards, unless such suspension or delisting would likely cause significant damage to the Users’ interests or the orderly functioning of the market;

8.2.2. when it deems such action is necessary for maintaining a fair and orderly market, the protection of Gate TR or any Users and otherwise in public interest;

8.2.3. where Gate TR reasonably believes that the specific Crypto Asset poses and is likely to pose actual or potential risks to Gate TR, the Platform, any Users, the market or public;

8.2.4. where Gate TR reasonably believes that it is obliged to do so;

8.2.5. where the CMB or a Competent Authority has required Gate TR to take such actions; and/or

8.2.6. whether Gate TR reasonably believes that it has reasonable grounds to do so.

8.3. Where Gate TR decides to delist a listed Crypto Asset, it shall:

8.3.1. publish a notice pertaining to the delisting of a listed Crypto Asset which shall contain the effective date of such delisting, in order to ensure that Users are able to close out any balances in their Account by the stipulated date;

8.3.2. cancel any Open Orders in relation to such delisted Crypto Assets from the effective date of delisting;

8.3.3. not allow Users to enter any Orders in relation to such delisted Crypto Assets from the effective date of delisting; and

8.3.4. not allow Users to deposit the delisted Crypto Assets from the date of notice mentioned under Section 8.3.1.

8.4. Where Gate TR decides to impose a Suspension of Trading for a listed Crypto Asset, it shall:

8.4.1. publish a notice pertaining to the Suspension of Trading of a listed Crypto Asset which shall contain the effective date of such suspension and the duration of such suspension (if known by Gate TR);

8.4.2. not allow Users to enter any Orders in relation to such suspended Crypto Assets from the effective date of Suspension of Trading; and

8.4.3. not allow any Open Orders to be Filled during the period of Suspension of Trading.

8.5. Gate TR will resume trading as reasonably practicable and when Gate TR deems it is appropriate in its sole discretion to do so. Gate TR shall not assume any responsibility or liability or be held liable to the Users or any third parties for the costs, damages or consequences of any such actions.

8.6. Following a Suspension of Trading and before the resumption of trading, Gate TR will publish a notice that shall specify the duration of the Pre-Open Session. During such a Pre-Open Session:

8.6.1. Users may only enter Limit Orders and may cancel Open Orders; and

8.6.2. Open Orders will not be matched.

8.7. Following the Pre-Open Session mentioned in Section 8.6 and on the resumption of trading thereafter, matching of Orders will occur in accordance with this Policy.

9. Trading Rules

Trading hours

9.1. Barring any Downtime (See Sections 9.2 – 9.4) or Suspension of Trading (See the User Agreement and Terms of Use), the Platform is intended to be open 24 hours a day, 7 days a week, each day of the year.

Downtime and maintenance

9.2. From time to time, Gate TR may halt trading on the Platform or restrict Users’ access to the Platform or their Accounts to conduct maintenance, upgrade systems or in case of any emergency situations or unforeseen technical issues.

9.3. Scheduled Downtime will be communicated in advance to the Users via email or notice on Gate TR’s website.

9.4. In the event of any unscheduled Downtime caused due to emergency situations (See Section 15.3) or technical issues (See Section 15.4), Gate TR shall identify and notify each User affected by such situations of the nature and effects of such situations.

9.5. In addition to the actions that Gate TR may undertake as provided in this Policy and/or in the User Agreement and Terms of Use, Users acknowledge and agree that Gate TR reserves the right (without any liability resulting of Gate TR or any Gate TR’s affiliates involved in the provision of the Gate TR services) to disable, update, cancel, restrict or otherwise modify any content, components or features of the Platform.

Types of Orders and Conditions on Trading

9.6. A User may place the following types of Orders on the Platform:

9.6.1. a Market Order where User can purchase or sell a Crypto Asset at the market price. The market Order is executed immediately at the best available current market price but slippage losses could occur for large orders;

9.6.2. a Limit Order where a User can place an order to buy or sell at a given price or better. A limit order may get executed instantly only if there is a corresponding offer or it is parked in the order book till there’s a corresponding price, but is not guaranteed to be executed; or

9.6.3. a Stop-Limit Order where the User can only place an order with present limit price, amount and direction when the last price reaches the stop price.

9.7. Gate TR does not warrant that a Market Order will Fill at the specified price. A Market Order may Fill at a number of different prices, based on the quantity of the relevant Crypto Asset of the Order and the quantities of the existing Orders on the Order Book at the time.

9.8. A valid Market Order will be immediately posted to the Order Book.

9.9. A Limit Order shall be Filled at the specified price or a better price.

9.10. A Limit Order may result in a Taker Order or Maker Order, or even be partially both.

9.11. A Limit Order that is not Executed immediately will remain in the Order Book until it is Filled by a Taker Order or cancelled by the User or Gate TR (See Section 9.40 -9.41).

9.12. Once the Crypto Asset’s price reaches the predetermined stop price in a Stop-Limit Order, the stop order transmutes into a Limit Order, seeking execution at the predetermined limit price or better one.

Crypto Asset Deposits and Withdrawals

9.13. Users are solely responsible for ensuring that deposits involved only supported Crypto Assets and are directed to compatible wallet addresses;

9.14. Deposits of unsupported or incorrectly sent Crypto Assets may be lost and are non-recoverable, and Gate TR shall not be liable for any losses or damages arising from such deposits;

9.15. Deposits will not be credited to the User’s account with Gate TR, if they fail to pass the compliance and security checks of Gate TR;

9.16. Withdrawals of Crypto Assets must be carefully verified by Users before execution;

9.17. Gate TR bears no liability for any losses or damages incurred or to be incurred due to incorrect withdrawal details (e.g., wrong blockchain address ) provided by the Users;

9.18. Once a transaction is broadcast to the blockchain, the transaction cannot be reversed;

9.19. Withdrawals of Crypto Assets will also be subject to compliance and security checks before execution;

9.20. When depositing or withdrawal any Crypto Assets, Users may be required to provide additional identity information, details of the originator and beneficiary of Crypto Asset transactions, and other necessary information to Gate TR for compliance with Travel Rule related requirements

9.21. Gate TR may impose minimum and/or maximum Crypto Asset deposit and/or withdrawal limits. The User acknowledges and agrees that Gate TR unilaterally determines in its sole and absolute discretion the daily, weekly and monthly Crypto Asset deposit and withdrawal limits based on economic situation and risk assessment. Said limits may be increased or decreased without prior notice to the User. The User cannot make any claims against or impose any responsibility on Gate TR in connection with or relating to the aforementioned limits determined or imposed by Gate TR and accepts and declares that he/she irrevocably releases and waives any rights he/she may have in advance;

9.22. Gate TR does not undertake to deposit or withdraw any Crypto Assets to or from the Platform instantly. Gate TR carries out the instructions of the User regarding the transactions, depending on the software and hardware technical infrastructure on its Platform. Gate TR will endeavor to fulfil the instructions regarding the said transactions in a reasonable time, except for technical failures or unforeseen circumstances. Gate TR will not be liable for any direct or indirect damages that may arise in the event that Crypto Asset deposit and withdrawal transactions are not realized in a part or at all or are realized delayed, due to the high volume in the markets or the Force Majeure circumstances.

9.23. The User acknowledges and agrees that the processing times for withdrawals depend on network congestion and compliance and security reviews;

9.24. Gate TR reserves the right to delay, reject or cancel Crypto Asset deposit and withdrawal requests if it has any concerns on the security and/or compliance of the related transactions.

Fiat Deposits and Withdrawals

9.25. Gate TR only accepts fiat currencies in Turkish Lira sent from bank accounts in Turkey.

9.26. The User will only be able to use the bank accounts registered in his name. The User can make a deposit or withdrawal from the bank account registered with the same name as the account in Gate Turkey. If the user tries to send money from bank accounts belonging to other people, he is responsible for the delay or the non-realization of the transaction and therefore shall be liable for all losses (whether direct or consequential) and damages arising from hereof.

9.27. Deposits will not be credited to the User’s account with Gate TR, if they fail to pass the compliance and security checks of Gate TR;

9.28. Withdrawals of fiat currencies must be carefully verified by Users before execution;

9.29. Gate TR bears no liability for any losses or damages incurred or to be incurred due to incorrect withdrawal details (e.g., wrong bank account details ) provided by the Users;

9.30. The User should not attempt to deposit money using ATMs.

9.31. Gate TR may impose minimum and/or maximum fiat currency deposit and/or withdrawal limits. The User acknowledges and agrees that Gate TR unilaterally determines in its sole and absolute discretion the daily, weekly and monthly Crypto Asset deposit and withdrawal limits based on economic situation and risk assessment. Said limits may be increased or decreased without prior notice to the User. The User cannot make any claims against or impose any responsibility on Gate TR in connection with or relating to the aforementioned limits determined or imposed by Gate TR and accepts and declares that he/she irrevocably releases and waives any rights he/she may have in advance;

9.32. Processing times for fiat withdrawals vary depending on the chosen withdrawal method, related banks and banking hours.

9.33. The User accepts and declares that Gate Turkey cannot be held responsible if the deposit is unsuccessful due to any reason attributable to the bank he is dealing through and himself

9.34. Gate TR reserves the right to delay, reject or cancel fiat deposit and withdrawal requests if it has any concerns on the security and/or compliance of the related transactions.

Placing of Orders

9.35. Users can place Orders by accessing the Platform either through Gate TR’s website or mobile application.

9.36. Users must have an available balance of the relevant Crypto Asset, and fiat currency (if applicable) in their Account which is sufficient to cover the total value of the Order plus any applicable fees (i.e., all Orders are pre-funded). When a User places an Order, the quantity of the relevant Crypto Asset (including any applicable fees), and amount of fiat currency (if applicable), relating to the Order is placed on hold in the Account until the Order Fills, expires, or is cancelled. Unfilled portions of User Orders will remain on hold until it Fills, expires, or is cancelled.

9.37. Gate TR records each User’s balance of Crypto Assets and fiat currencies. In the event that a User has an insufficient balance of the relevant Crypto Asset or fiat currency in their Account for an Order, the Order shall be automatically rejected, and shall not be entered into the Order Book.

9.38. Users will receive an email confirmation every time they have placed an Order and when that Order is partially or completely Filled.

9.39. A binding contract between Users is created when an Order is Filled and the User must bear the consequences of any errors made in the placing of an Order. The User is responsible for all obligations and liabilities arising from the entry, cancelation and Execution of all Orders placed by the User.

Cancellation of Orders

9.40. Users may cancel an Order only before it is Executed (including, in case of partial Execution, in relation to any part that remains to be Executed).

9.41. Gate TR reserves the right to cancel Orders where in the opinion of Gate TR, the Order is not in the best interests of a fair and orderly market, is required as a disciplinary action for Defaulters, or if the Order appears to be:

9.41.1. contrary to Applicable Laws and Regulations;

9.41.2. indicative of Market Abuse;

9.41.3. unauthorised;

9.41.4. an erroneous trade.

9.42. Users will receive an email notice every time an Order is cancelled.

Trade reversals

9.43. Gate TR reserves the right, in its sole discretion, to review and (where practicable) reverse any Order that has been Executed where:

9.43.1. Gate TR is required to do so under Applicable Laws and Regulations;

9.43.2. Gate TR is required to do so by the order of CMB or any other Competent Authority;

9.43.3. the Fill resulted from a technical failure (malicious or otherwise) or is in breach of this Policy.

9.43.4. The trade was Executed at a price which Gate TR reasonably considers to be substantially inconsistent with the prevailing market levels at the time of Execution and which reasonably appears to Gate TR, to have been entered in error or with malicious or illegitimate purposes;

9.43.5. a Trade which Gate TR reasonably considers to be substantially inconsistent with the normal trading size of that pair, and which reasonably appears to Gate TR to have been entered in error or with malicious or illegitimate purposes; and

9.43.6. a Trade determined by Gate TR to have been an error trade following receipt of a written request from a User in accordance with this Policy;

9.43.7. extraordinary circumstances not originating from Gate TR but arising from the system or its associated applications, and the applicable procedures for handling such cases;

9.43.8. other material factors that may necessitate the suspension of trading for listed crypto assets, such as internet or telecommunication outages, cyberattacks, significantly low trading activities or insufficient liquidity with respect to the crypto assets etc.

9.44. Where a trade has been reversed, Gate TR shall provide the pertinent parties to the trade a notice which shall consist of the reasons for such reversal.

9.45. A User, who believes that a trade has been entered in error way, within 30 minutes after Execution, initiate reversal of such trade by sending a written request to customer support team, specifying the details of the trade and reasons for why the trade has been entered in error. Gate TR may review such request, however, Gate TR may in its sole discretion, decline (without an obligation to provide a reason) to review the request that does not satisfy Gate TR’s requirements. The User acknowledges and agrees that Gate TR acts as a facilitating party to match orders between users and shall seek prior written consent from the counterparty of the related error transaction before reversing such transaction.

9.46. Gate TR shall match Orders on “Price-Time Priority” (“PTP”) basis.

9.47. PTP means that each time a Taker Order is placed:

9.47.1. the Taker Order is matched with the Maker Order placed earliest in time and at the best price available on the Order Book;

9.47.2. if the Taker Order is not completely Filled by that Maker Order, it is matched with any subsequent Maker Orders at that price, in the sequence those Maker Orders were posted; and

9.47.3. if the Taker Order is not completely Filled by one or more Maker Orders described above, it is matched with one or more Maker Orders at the next best price, in the sequence those Maker Orders were posted.

9.48. The process mentioned under Section 9.47 is repeated until the Taker Order is completely Filled, cancelled or becomes a Maker Order.

9.49. A Fill occurs when a Maker Order is matched with a Taker Order, thereby resulting in a trade.

Gate TR may engage with market makers and/or liquidity providers (“Provider”) under the following principles and contractual terms:

9.50. Providers are selected based on a due diligence process which evaluates (1) legal and regulatory standing (including licensing status, if applicable); (2) technical capacity to integrate with Gate TR’s trading infrastructure; (3) financial robustness and risk controls; (4) clean history of trading behavior and absence of market manipulation.

9.51. All Providers must execute a written agreement with Gate TR prior to commencing any market making and/or liquidity provision activities.

9.52. Upon request by Gate TR, the Providers shall provide market making implementation plan with comprehensive risk control protocols and other information and documents that Gate TR at its sole discretion considers appropriate to evaluate their eligibilities as a Provider on Gate TR at the onboarding of the Providers and afterwards.

9.53. The Providers shall quote continuous buy and/or sell orders within specific price spreads and volume ranges as agreed in the agreement with Gate TR. Upon request by Gate TR, the Providers shall submit performance metrics or compliance attestations to Gate TR.

9.54. Gate TR may exempt the Providers from its quotation obligations under the following circumstances during a designated period of time on and after the occurrence of such circumstances:

• when the market moves sharply to one side;
• when the market making or liquidity provision cannot continue due to any force majeure events, accidents or technical failures, provided that the Providers promptly notify Gate TR of such event; and
• other circumstances as deemed appropriate by Gate TR

9.55. The Providers and their personnel shall not engage in any of the following conducts:

• Using non-public information in making investment decisions and transactions;
• Using non-public information and/or advantages in accessing capital to create abnormal price fluctuations, either alone or colluding with any other entities (including in colluding with any entity operated by the Providers);
• Conduct malicious or complicit acts against other Providers or Gate TR;
• Seeking illegitimate gains by colluding with any other Providers by fabricating artificial quotations or exchanging market making strategies with any other Providers;
• Where any of its market making personnel seeks any interest transfer to itself or any other interested party;
• In the absence of due authorization, sharing with any third party the special services exclusively reserved for the Providers;
• Carrying out any activities in breach of any provisions of this Policy or the agreements with Gate TR; and
• Other behaviors manipulating or disturbing the market.

9.56. Gate TR may at its sole discretion take prompt actions in case of suspicious or manipulative conducts by the Providers.

9.57. Gate TR reserves the right to terminate or suspend the relationship with any Provider (1) upon breach of contract or any rules of this Policy, User Agreement and Terms of Use, and other policies and procedures which can be accessed on Gate TR’s website, or misconduct; (2) where market integrity is at risk; (3) as instructed by competent authorities; (4) where the continuance of the relationship with the Provider may damage the reputation of Gate TR.

Record keeping and reporting

9.58. Gate TR shall record all received orders, including those cancelled, unexecuted or modified. Such records shall include User number or Account number, Crypto Assets involved in the transaction, order type, whether the order is a buy or sell order, price information of the order, order quatity, date and time the order was received and transmitted, order validity period, order sequence number, as well as transaction currency or trading pair.

9.59. Gate TR shall issue a transaction confirmation form for all executed transactions to the User, detailing the type, quantity, and price of the traded Crypto Assets, as well as any commissions and fees charged by the Platform to the User. The platform must send this form to the User’s declared email address by the end of the trading day or provide electronic access to account statements.

9.60. Gate TR shall send monthly account statements to the User no later than five business days after the end of the relevant period, either via email or by providing electronic access. If no transactions occur during the period, a statement may not be required.

9.61. All records under this Policy are maintained for minimum period of 10 years.

Central Securities Depository (CSD)

9.62. For each User, Gate TR shall obtain a registration number from the Central Securities Depository (“CSD”) prior to accepting any orders from such User or transmitting any order placed on behalf of the User. The obtained registration number shall be matched with the User number. If a registration number has already been obtained previously, Gate TR shall ensure that it is matched with the User number.

9.63. Users shall be able to compare the records of their own assets that have been reported to the CSD system via the CSD’s E-Investor (E-Yatırımcı) application.

9.64. Gate TR ensures full integration with the CSD system, which maintains institutional registry records for User crypto asset balances in accordance with CSD’s technical and procedural specifications and any further instructions communicated through the official CSD guideline.

9.65. Reports submitted by both Gate TR and its authorized custodian to the CSD must be consistent and yield identical results. Discrepancies between the submitted data will be automatically identified by CSD and escalated to the CMB without delay.

9.66. All User-level transactions maintained in the institutional registry for each crypto asset must be reconciled daily. A reconciliation report shall be generated, and when deemed necessary pursuant to Applicable Law and Regulations, transfers between the Platform’s wallet and the custodian’s wallet shall be executed accordingly.

9.67. Reconciliation-based asset transfers between the Platform and Gate TR’s custodian shall be executed at 23:59 (UTC+3) each day, unless otherwise required by Applicable Law and Regulations.

9.68. The control of errors or issues that may arise during these processes, are as follows:

Potential Issues or Errors	Controls
Missing CSD registration number for a User	Implement scheduled synchronization with the CSD system to ensure each User has a valid CSD registration number; otherwise, reject any order from such User.
Change in User’s CSD registration number	Periodically synchronize registration data with the CSD system. Upon detecting a change, update all relevant transaction records accordingly
Network timeout when reporting to CSD	Implement retry mechanism with exponential backoff. Continue attempting until network issue is resolved; trigger alert notification for persistent failures.
Slow CSD service response impacting synchronization	Queue unsent data and retry once the CSD system becomes responsive; monitor latency and notify system administrators if delay exceeds acceptable thresholds.
Reconciliation report not generated	Implement automated monitoring to check reconciliation task completion. If failed, re-initiate reconciliation process and send failure alerts to relevant teams.
Blockchain congestion delaying asset transfers	Monitor network congestion metrics; use dynamic fee adjustment to prioritize transfers or delay non-urgent transfers until congestion clears.
Inconsistent reports between Gate TR and custodian	Run pre-submission data validation and reconciliation checks. Investigate and resolve discrepancies before submission to CSD.
Duplicate or missing transaction records in CSD report	Add integrity verification mechanisms (e.g., hash validation) before submission. In case of error, resubmit corrected transaction batch to CSD.
CSD API changes without prior notice	Subscribe to official CSD notifications and monitor for schema/endpoint changes; maintain versioned API integration and conduct regular testing.
Clock/time discrepancies affecting daily cut-off (23:59 execution)	Synchronize system clocks with an NTP server. Schedule asset transfers slightly before cut-off time with retry buffers.
Unauthorized modification of registry data	Implement strict access controls, audit logs, and periodic integrity verification for all registry-related operations.
Failure in wallet-to-wallet transfer	Monitor transfer jobs with automatic retry logic. In case of failure, alert both technical and compliance teams and rerun after resolution.

10. Settlement

10.1. All partially or fully Filled Orders are settled in real-time by debiting and crediting the relevant quantities of Crypto Assets and/or amount of fiat currency, that have been put on hold in accordance with Section 9.36, in the relevant Users’ Accounts. Settlement is final once the Accounts have been debited and credited.

10.2. Trades that are settled are reflected in the User’s transaction history.

10.3. The abovementioned process occurs off-chain.

10.4. The settlement of a trade is effected on a bilateral basis between the relevant Users and each User shall place Orders as principal and be the counterparty of the other in respect of the relevant trade.

11. Transparency

Pre-trade transparency

11.1. Gate TR shall make available, on a continuous basis while the Platform is in operation, details of current bid and offer prices and an indication of trading interest at those prices.

Post-trade transparency

11.2. Gate TR shall make available, as close to real-time as technically possible on a non-discretionary basis, details of the price, volume and time of each trade Executed on the Platform. 

12. Fees

12.1. A User must pay to Gate TR all applicable charges or other sums set out in the relevant fee schedule from time to time published on the Platform. Gate TR shall provide reasonable advance notice to Users of any changes to any such fee, or the imposition of any new fee or charges.

12.2. Every trade will be subject to a fee. Gate TR will charge Users a maker fee for each Maker Order and a taker fee for each Taker Order that is posted to the Order Book.

12.3. Gate TR will display the applicable fee to Users on the user interface prior to each transaction, and this transaction fee is stated in each confirmation that is issued to Users.

13. Pre-trade risk controls

13.1. Gate TR shall implement pre-trade risk controls for all Orders, both on receipt and prior to Execution, to:

13.1.1. provide appropriate protection for Users against fraud, misconduct, recklessness, negligence or errors by Gate TR and/or other Users;

13.1.2. detect activities that might reasonably be considered to be or to involve any element of Market Abuse;

13.1.3. mitigate risks and prevent entering potential Orders into the Order Book that may:

a) create false and misleading appearance of trading activity; and

b) execute any trade for improper purposes.

13.2. In an effort to protect the market integrity, mitigate the overall market risk and guard against trading errors and disruptive Orders such as “fat finger” mistakes and other sources of extreme market volatility in trading, Gate TR has implemented a trading control functionality that validates a Limit Order’s price against the most recent snapshot of the resting best bid/ask for a given Crypto Asset within the Order Book. Limit Orders that fall outside a prescribed pre-trade risk limit, as determined by Gate TR for each trading pair, will trigger a warning message.

14. Market Abuse, Market offences, Financial Crimes, monitoring and suspicious transactions

14.1. The User shall not engage in any type of Market Abuse, Financial Crime, Market Manipulation or other offences, crimes or unlawful activities including but not limited to Insider Dealing, money laundering, Unlawful Disclosures, misuse of any information including Inside Information, manipulating transactions, manipulating devices, misleading behaviour and distortion of prices.

14.2. Orders placed on the Platform, and trades Executed on the Platform must be made in good faith for the purpose of entering into bona fide transactions.

14.3. The User may only transfer fiat currency between their Account and pre-registered bank accounts under their name and registered with Gate TR. The User must comply with relevant Financial Crime and AML legislation in force in Turkey, and in any other jurisdiction to the extent that such legislation applies to the User. The User must comply with any request for information made by Gate TR.

14.4. Gate TR is committed to ensuring that its markets trade fairly and orderly, and will take all necessary steps to identify, monitor, deter, and prevent any conduct which may amount to Market Abuse and Financial Crime through Gate TR’s facilities. Gate TR uses proprietary and third-party software applications for market surveillance to monitor for Market Abuse, Financial Crime, and other suspicious activities on a real-time basis and reserves the right to cancel any trades or Orders that it reasonably deems suspicious.

14.5. Where Gate TR suspects Market Abuse or Financial Crimes on part of any User, it shall immediately report such suspicions to the Competent Authorities.

15. Measures to maintain Fair and Orderly Trading

Control measures

15.1. In order to preserve market integrity, maintain fair and orderly trading, and to secure compliance with this Policy, Gate TR may take any action, including market control measures, such as:

15.1.1. imposing a Suspension of Trading (See Section 8);

15.1.2. modifying risk mitigating measures (See Section 13);

15.1.3. suspension or termination of User access to the Platform (See the User Agreement and Terms of Use);

15.1.4. cancelling Open Orders (See Section 9.40);

15.1.5. reversal of Orders that have been Executed (Section 9.43); or

15.1.6. any other actions deemed by Gate TR to be in the best interest of its Users and the Platform or to preserve fair and orderly trading.

Exceptional situations

15.2. Gate TR may implement the control measures mentioned under Section 15.1, in situations that are deemed by Gate TR to be exceptional, including:

15.2.1. major price volatility of a Crypto Asset;

15.2.2. decisions or information which are to be published imminently and which might have a significant influence on the price of a Crypto Asset;

15.2.3. changes in Applicable Laws and Regulations which affect Gate TR’s ability to provide services or require remedial action before they can be resumed; or

15.2.4. other situations that Gate TR deems may compromise fair and orderly trading.

Emergency situations

15.3. Gate TR may implement the control measures mentioned under Section 13, in emergency situations such as:

15.3.1. failure of the Platform, including its access infrastructure or parts thereof;

15.3.2. failure of a User’s access to the Platform;

15.3.3. failure of Gate TR’s custody or settlement infrastructure or systems;

15.3.4. a Force Majeure event; or

15.3.5. other emergencies that Gate TR deems may compromise fair and orderly trading.