Webot EU Operating Rules for Trading Platform

Operating Company: Pionew Ireland Limited (trading as Webot)

Regulatory Framework: Markets in Crypto-Assets Regulation (MiCAR Regulation (EU) 2023/1114)

1. Introduction & Purpose

Welcome to Webot EU. These Platform Operating Rules outline the operational, trading, and conduct standards governing the services provided by Pionew Ireland Limited (“PIL”, “Webot”, “we”, or “us”).

Our objective is to provide a secure, transparent, fair, and resilient environment for crypto-asset trading, custody, and transfer services. All activities on the Webot EU platform operate in full compliance with applicable EU regulations, including MiCAR, Anti-Money Laundering / Countering the Financing of Terrorism (AML/CFT) frameworks, the Digital Operational Resilience Act (DORA), and consumer protection requirements.

2. Account Registration & User Verification (KYC)

To access services on Webot EU, all clients must register for an official Webot Account and successfully complete our identity verification process.

Account Types & Eligibility

Individual Accounts: Designed strictly for personal use. Funds must originate from and be withdrawn to bank accounts in the exact legal name of the individual user.

Verification Requirements (KYC)

During onboarding, clients are required to provide verified information, including:

Full legal name and residential/registered address
National identification or passport details
Proof of wallet address ownership
Verification of source of funds / source of wealth

Note: Incoming deposits or outgoing transfers from third-party bank accounts or unverified third-party wallets are strictly prohibited. Name matching between payment accounts and your Webot profile is mandatory.

3. Overview of Webot EU Services

Webot EU provides the following core crypto-asset services under MiCAR

Service Category	Description
Custody & Administration	Safekeeping and segregation of client crypto-assets in dedicated Webot client wallets
Trading Platform Operation	Central Limit Order Book (CLOB) enabling peer-to-peer buying and selling of crypto-assets.
Fiat On-Ramp / Off-Ramp	Conversion of EUR funds into e-money tokens / stablecoins (e.g., USDC) and vice-versa.
Crypto-Asset Transfers	Facilitation of on-chain crypto transfers to external crypto-asset service provider (CASP) wallets.

4. Platform Operations & Trading Rules

4.1 Hours of Operation

The Webot EU trading platform operates 24 hours a day, 7 days a week, 365 days a year.

4.2 Order Book & Execution Model

Webot operates a matching-only trading model. All trades executed on the platform take place directly between platform clients. Webot does not trade as principal against its users.

Orders are matched strictly based on Price-Time Priority:

Price Priority: The highest bid (buy) price and lowest ask (sell) price take absolute precedence.
Time Priority: Where multiple orders exist at the same price, the order submitted earliest is executed first.

4.3 Supported Order Types

Market Orders: Executed immediately at the best available market price in the order book.
Limit Orders: Executed only at the specified maximum buy price, minimum sell price, or better.

4.4 Order Modification & Cancellation

Unfilled Orders: Open limit orders may be cancelled at any time prior to matching via the platform interface.
Partially Filled Orders: Unexecuted portions of an order may be cancelled; executed portions are final and non-reversible.
Executed Trades: Fully matched trades are immediately final, binding, and cannot be cancelled or reversed.

4.5 Trade Settlement & Timelines

Off-Chain Internal Settlement: As a centralized platform, trades executed on Webot EU settle on our internal secure ledger. Under standard market conditions, settlement occurs within 10 seconds of execution. During extreme high-volatility spikes, settlement will complete within a maximum window of 10 minutes.
Finality of Settlement: Settlement is considered final once Webot’s internal ledger is updated to reflect asset balances in client accounts, requiring no further validation or right of reversal.

5. Risk Controls & Market Integrity

To ensure orderly trading, market fairness, and system stability, Webot enforces automated pre-trade risk checks and real-time surveillance.

5.1 Pre-Trade Risk Limits

Risk Control	Mechanism & Threshold
Maximum Order Size	Capped at 1% of the 24-hour average daily volume for the target pair
Price Deviation Filter	Orders deviating by more than ±5% from the current best bid/ask are automatically rejected
Account Rate Limits	Restricts API requests to ≤ 50 trading calls per second to prevent order spamming
Duplicate Order Filter	Filters out identical limit orders placed within 2 seconds
Self-Trade Prevention	Prevents orders from matching against resting orders submitted by the same account

5.2 Market Abuse Detection

Webot continuously screens order flow using automated surveillance tools to detect and stop manipulative trading practices, including:

Spoofing & Layering: Placing non-bona fide orders to create false depth signals.
Wash Trading: Simultaneous buy/sell activity between associated accounts to artificialize volume.
Momentum Simulation & Order Fading.

6. USDC Stablecoin De-Peg Contingency Protocol

The primary quote asset on Webot EU is USDC, an Electronic Money Token (EMT) issued by Circle under MiCA authorisation. While USDC is backed 1:1 by segregated reserves, Webot maintains a formal contingency framework to address potential de-peg scenarios.

De-Peg Trigger Condition

A formal stress protocol is activated if USDC deviates from USD parity by more than 5% for a sustained period of 2 hours or longer, or upon notice of material issuer stress.

Client Protections During De-Peg Events

Trading Controls: New USDC trading pairs may be temporarily paused to prevent disorderly order books.
Fee-Waived Off-Ramp: Conversion fees for USDC to EUR will be immediately waived (0%) to allow unhindered fiat exits.
Continuous Withdrawal Access: Client USDC reserves remain fully segregated; clients retain the right to withdraw USDC to external wallets or convert balances to alternative supported assets (such as EUR or BTC) at prevailing market rates.
EUR Base Pairs Expansion: Webot is actively expanding direct EUR-denominated trading pairs to eliminate single-asset reliance.

7. Asset Listing & Delisting Standards

Webot EU applies rigorous due diligence before introducing any crypto-asset to the platform catalog.

7.1 Key Listing Criteria

Assessment of asset issuer credibility, governance structure, and technology architecture.
Verification that the asset is actively traded across top regulated exchanges in the European Union].
Comprehensive legal analysis ensuring compliance under MiCA and local EU legal frameworks.
Adequate order book liquidity, developer community backing, and technical code security.

7.2 Delisting Triggers

Webot reserves the right to suspend or delist any crypto-asset to protect users if:

The asset or issuer violates legal, regulatory, or ethical standards.
Severe depletion of trading volume or market liquidity occurs.
Underlying blockchain technology becomes insecure, compromised, or obsolete.
There is evidence of fraudulent activity, market manipulation, or financial crime risks.

Advance public notice will be provided to clients wherever feasible to allow orderly position settlement and asset withdrawals.

8. Safeguarding & Segregation of Client Assets

Client safety is built into Webot EU’s structural design:

Crypto Asset Segregation: Client digital assets are held in dedicated, segregated wallet structures separate from Webot corporate treasury assets.
Fiat Reserve Segregation: Client fiat funds (EUR) are deposited into segregated client asset bank accounts with regulated credit institutions no later than the business day following receipt.
No Rehypothecation: Webot does not lend, stake, pledge, or rehypothecate client assets or funds under any circumstances.

9. Fee Schedule

At Webot EU, we are committed to complete transparency, fair conduct, and straightforward pricing. Our fee structure is built so you always know your transaction costs upfront with no hidden charges.

Key Summary:

Simple Trading Fees: A flat 0.50% fee applies across all trade executions, whether you are trading Crypto-to-Fiat, Fiat-to-Crypto, or Crypto-to-Crypto.
Zero Maintenance or Custody Fees: Account setup, onboarding, ongoing maintenance, and asset custody are completely free of charge.
Transparent Transfers: We charge no platform fees for deposits or fiat withdrawals. For crypto withdrawals, you pay only the actual underlying blockchain network gas fee.

Please see below for full details across all service categories:

Service Category	Service Description	Fee Type	Fee Amount / Basis	Frequency / Trigger
Trading & Execution	Crypto-to-Fiat trades	Percentage of transaction value	0.50%	Per transaction
	Fiat-to-Crypto trades	Percentage of transaction value	0.50%	Per transaction
	Crypto-to-Crypto trades	Percentage of transaction value	0.50%	Per transaction
	Minimum trade fee	N/A	N/A	N/A
Custody & Administration	Crypto asset custody	N/A	N/A	N/A
Deposits & Withdrawals	Fiat deposits	N/A	N/A	N/A
	Fiat withdrawals	N/A	N/A	N/A
	Crypto deposits	N/A	N/A	N/A
	Crypto withdrawals	Network-based Gas fee	Variable (network fee)	Per transaction
Account Setup & Maintenance	Account opening and onboarding	N/A	N/A	N/A
Account Setup & Maintenance	Ongoing account maintenance	N/A	N/A	N/A

10. Governance, Transparency & Complaints

10.1 Transparency Reports & Statements

Periodic Account Statements: Clients are provided with a quarterly account statement detailing all recorded crypto positions, transactions, balances, and valuations.
Real-Time Data: Pre-trade depth and post-trade execution metrics are published continuously on the Webot EU platform interface in real time.

10.2 Conflicts of Interest

Webot maintains strict organizational barriers and independence controls between operational teams, trading infrastructure, and senior management to ensure conflicts of interest are prevented or transparently disclosed to clients.

10.3 Client Complaints Process

Webot EU is committed to resolving client concerns promptly and fairly.

Submission: Complaints can be submitted via the dedicated Complaints Portal on the Webot EU website or via email to complaintform
Timelines: All submitted complaints receive formal acknowledgment within 3 business days. A comprehensive investigation response and resolution statement will be delivered within 15 business days.

11. Amendments to Operating Rules

Webot EU may update these Operating Rules to reflect legal changes, regulatory guidance under MiCA, or platform enhancements. Clients will be notified of material changes in advance via email and platform announcements. Continued use of Webot EU services following effective updates constitutes acceptance of the amended rules.