Best Execution Policy

Last updated: November 2025.

1. Introduction

Aplo SAS (Aplo) provides its customers (Client) a service for buying and selling digital assets against legal tender and for exchanging digital assets for other digital assets.

Regulations governing the digital asset market impose rules aimed at achieving the best possible outcome when executing orders (Orders) of Clients (Article 78 of the MiCA Regulation). These rules are intended, in particular, to guarantee the prompt and fair execution and delivery of Orders.

This implementation policy (Policy) defines the principles applied by Aplo towards its Clients as well as their practical implementation methods.

It constitutes a basis in accordance with applicable regulations and may, where appropriate, be supplemented by specific contractual provisions between Aplo and a Client, provided that they do not contradict regulatory requirements.

This Policy applies to all orders initiated by Aplo’s professional clients. It provides, in particular, for the prompt, fair and diligent execution of Orders, as well as the protection and appropriate use of information relating to these Orders (see also the conflicts of interest policy).

Aplo is committed to implementing the necessary measures to ensure optimal execution of Orders, in compliance with standards of transparency, security, and regulatory compliance. Submitting an Order to Aplo constitutes acceptance of this Policy, which is also published on the website  www.sheeldmatch.com (Portal).

Upon request or according to contractual terms, Aplo provides the Client with the necessary information to justify the choices made regarding execution.

2. Scope of application

2.1. Services provided

Aplo provides the services (Services) the purchase and sale of digital assets against legal tender and the exchange of digital assets for other digital assets.

The activity consists of receiving orders from the client and searching for one or more trading platforms (Platform) where the assets are tradable and to complete the trading process, then select the Platform(s) offering the best execution conditions. By accepting the proposed execution conditions, Aplo thus provides order execution on behalf of third parties.

To ensure this execution under the best conditions, Aplo acts as the primary counterparty (riskless principal) by carrying out a simultaneous transaction “back-to-back” between its Client and one or more Liquidity Platforms. Furthermore, Aplo does not have proprietary trading activity and does not provide investment advice services and the Services or information provided by Aplo cannot under any circumstances be considered as investment advice services.

2.2. Order type covered

Aplo offers its clients a range of order types, which can be classified into two categories: directed orders and non-directed orders.

Directed orders are those for which clients specify the exact and complete execution conditions, such as price, execution venue, execution type, and all other characteristics. Therefore, if an order is executed, only one outcome is possible, and this Policy does not apply because Aplo does not have the necessary flexibility to change the decision-making factors related to the handling of such orders.

These orders include direct market access orders or Direct Market Access (DMA, all of whose characteristics are specified by the client).

Non-directed orders are subject to this Policy and executed via our intelligent routing tool Smart Order Router (SOR) according to the criteria and factors described elsewhere.

These orders include:

  • SOR order with limit price;
  • Fill-Or-KiIl order (FOK) with a price limit;
  • Market order (MKT) without limit price.

2.3. Covered instruments

The Policy applies to all crypto-assets, called spot that Aplo offers in its systems.

2.4. Customer base covered

Aplo offers its services only to clients classified as professionals, thus excluding retail clients.

3. Principles of the implementation policy

3.1. Selection criteria for trading platforms

Aplo does not believe it is economically justified to become a member of all trading platforms without first ensuring their ability to provide a significant improvement in execution results.

That is why Aplo implements all reasonable measures to best evaluate the different trading platforms available and selects those which seem to offer the best possible results for the execution of its Clients’ Orders.

The selection of external trading platforms is based on a specific qualification procedure, rigorously applied. The evaluation is primarily based on several key areas:

  • Compliance and risk management: Verification of the service provider’s regulatory status, assessment of its reliability (financial stability) and reputation (absence of scandals, legal sanctions, etc.). The compliance department conducts thorough due diligence including AML/CTF checks, verification of international sanctions, and overall risk assessment.
  • Technical and operational qualities: The technology department ensures the technical feasibility of the integration, covering compatibility (protocols, APIs, latency), system reliability in the face of extreme volatility, and compliance with security and asset management procedures (SOC, PASSI audit). Operational aspects such as support responsiveness and service fees are also considered.
  • Market coverage: Monitoring the actual liquidity available on the proposed assets.

All of these criteria are subject to an evaluation report by the operations department and require validation by the compliance team before formal approval by the risk committee.

The list of trading platforms selected for the execution of its Clients’ Orders is reviewed at least once a year.

The main trading platforms on which Aplo executes Orders are listed in the Appendix 1.

3.2. Performance-related criteria

For the execution of its Clients’ Orders, Aplo takes into consideration the following execution factors:

  • the price;
  • the impact of execution on the market;
  • the probability of execution;
  • the probability of settlement and delivery;
  • the cost;
  • the speed of processing;
  • the size and nature of the order;
  • any other determining consideration in the execution.

These criteria are applicable regardless of the type of Client, as they are all classified as professionals.

3.3. Fairness criteria

Aplo’s systems are automated and process Customer Orders identically without discrimination.

Orders are processed in the order they are received by Aplo.

Aplo does not aggregate its clients’ orders. Therefore, there is no favoritism when allocating grouped executions.

3.4. Conflicts of interest

Aplo receives no remuneration, discounts or benefits for executing Orders on trading platforms.

Aplo does not own any business and therefore cannot favor its own professional orders over those of its clients. Furthermore, Aplo employees sign the group Code of Ethics and must declare any significant buying and selling activity involving digital assets.

3.5. Order processing outside of a trading platform

Aplo does not execute its Clients’ Orders outside of the trading platforms listed in Appendix 1.

4. Exemptions

4.1. Directed orders

Directed Orders are those for which Clients specify the exact and complete execution conditions, such as price, execution venue, execution type, and all other characteristics. Aplo does not have the necessary freedom to change the decision-making factors related to the management of these orders and therefore cannot apply the Policy.

4.2. Specific instructions

For each order, Aplo accepts any specific instructions. For example, a client can instruct Aplo to prioritize speed of execution over the best possible price.

When the Client’s Order is accompanied by specific instructions contrary to its selection criteria, Aplo applies the Client’s instructions, which may lead to partial adherence to the Policy.

4.3. Unusual order size

When an Order is substantially larger than the liquidity typically available, Aplo may, in the interest of the orderly execution of such an Order, deviate from its usual selection and execution criteria in order to minimize the market impact in the interest of its Client.

4.4. Failing trading platforms

In the event of failure of one or more Platforms, Aplo may be unable to comply with all the principles of the Policy but will make every effort to adhere to them.

4.5. Exceptional market conditions

In the event of severe market disruptions, Aplo may be unable to comply with all the principles of the Policy but will make every effort to adhere to them.

4.6. Service malfunction

In the event of a malfunction of an internal system, Aplo has put in place a degraded operating procedure which allows Clients to manage their risk while still being able to cancel open Orders.

In this case, customers are notified by a message displayed on the website.www.sheeldmatch.com.

4.7. Customer notification in case of execution obstacles

The execution of an order may be delayed, partial or impossible, particularly in the event of insufficient liquidity or market disruptions.

In these situations, and more generally in the event of a major difficulty affecting execution, Aplo will inform the Client without delay.

5. Recording, tracking and control

The following measures ensure Aplo’s compliance with Article 78 of the MiCA regulation.

5.1. Recording of order and transaction data

All new orders, as well as all crypto-asset purchase and sale transactions from orders, are recorded in accordance with Delegated Regulation 2025/1140 on technical data retention standards. Information relating to orders and transactions is recorded in the formats specified in the annex to that regulation.

5.2. Internal monitoring and control

In accordance with Article 78(6) of MiCA, Aplo ensures regular monitoring of the efficiency of its chain of execution and its policy are monitored through automated controls. Each executed order generates a report that can be viewed by the client.

Aplo has implemented continuous monitoring tools that alert, for example, in the event of unusual results, such as when a price deviates abnormally from its reference.

As described in its Liquidity Provider Addition Policy, Aplo also conducts regular checks of the Platform selection process. To this end, criteria are examined by dedicated teams (operations, compliance).

Due to its current size, Aplo classifies all its employees as initiated. The Code of Ethics and its associated controls prohibit the misuse of customer order information by employees.

The Policy is reviewed at least once a year and whenever there are regulatory or material changes that may affect its ability to provide the best possible result to our Clients. In the event of a substantial change, an immediate update is made. Customers are notified by email of any updates to the Policy.

Aplo archives each step of a Customer Order for a period of five years, in accordance with its Retention and Archiving Policy.

Aplo makes available to its Clients and the relevant authorities the supporting documents for the measures implemented to comply with the Policy. These documents are provided upon request at the following address: support@aplo.io.

5.3. External control

Furthermore, this Policy is also subject to oversight established by an external auditor in order to assess the compliance of the system and the correct application of the execution criteria.

6. Contacts

 

Appendix 1. List of main MiCA or MiCA transition trading platforms available for France as of November 25, 2025

  • Binance: Binance France SAS, DASP in France;
  • Bitstamp: Bitstamp Europe S.A., CASP in Luxembourg;
  • Coinbase: Coinbase Luxembourg S.A., CASP in Luxembourg;
  • Gate: Gate Technology Ltd, CASP in Malta;
  • Kraken: Payward Europe Solutions Limited, CASP in Ireland;
  • OKX: OKCoin Europe Limited, CASP in Malta.