Commercial Practices Policy

‍Introduction

The purpose of this policy is to reiterate the main objective and non-discriminatory rules that Tilvest has established to define its priority market, identify its “core market,” its target audience, and consequently, the clients with whom it agrees to conduct business.

It further outlines the principles governing the relationship between Tilvest and its prospects or clients with a view to providing crypto-asset services within the meaning of Regulation (EU) 2023/1114 (“MiCA”).

This policy applies to all services offered by Tilvest.

1. General Principles

1.1. Non-discrimination

Tilvest must provide its services on an objective, fair, and non-discriminatory basis.

No prospect or client shall be treated differently, for example, on the grounds of their origin, nationality, beliefs, or any other irrelevant criteria.

1.2. Accuracy of Information Provided by Prospects and Clients

In line with the above principle, Tilvest is entitled to require complete, accurate, and thus consistent information from its prospects and clients.

Consequently, no client may use Tilvest’s services with the intent to harm, in any manner whatsoever, Tilvest, third parties, or their rights, interests, or reputation.

1.3. Rights, Registrations, Authorizations, Certifications, or Licenses

Tilvest’s commercial positioning is necessarily guided by the scope of its rights to carry out its business, and by any registrations, authorizations, certifications, or licenses that are useful or required for the provision of its crypto-asset services.

1.4. Risk and Tilvest’s Contractual Freedom

Without this principle being interpreted as overriding or inconsistent with the above—particularly the principle of non-discrimination—Tilvest retains full discretion to accept or refuse to enter into a business relationship with a prospect, as well as to continue or terminate an existing contractual relationship.

This position, whether at the initiation of the business relationship or throughout its continuation, is based on Tilvest’s assessment of its own financial, material, and human resources, its risk appetite, applicable legal and regulatory requirements, and the quality of its interactions with each prospect or client.

Furthermore, a decision taken by Tilvest at a given time does not prevent it from later discovering elements (in compliance with the principles set out herein) that could result in the termination of a previously established business relationship, whether longstanding or not.

Moreover, Tilvest’s Management and its commercial and client relationship teams strive to share a common, coherent, non-discriminatory, and fair vision.

2. Relationship Between Tilvest and Its Prospects or Clients

2.1. Commercial Positioning and Target Audience

2.1.1. General Description

Tilvest offers its crypto-asset products and services primarily to end clients, whether individuals or legal entities. In distributing this offering, Tilvest generally collaborates with partners or business introducers.

Given the specific nature of its open-architecture offering, Tilvest’s clients may also include independent financial advisors, wealth management firms, or institutional investors.

In all cases, Tilvest’s core target market is the French market.

Depending on the applicable legal and regulatory possibilities and/or constraints, Tilvest also considers future international development, starting with the European Union.

2.1.2. Prudential Exclusions

In order to safeguard the security of its operations and that of its prospects—particularly considering the specific nature of crypto-assets (volatility, complexity, technological risks, misuse, ongoing public familiarization, etc.)—Tilvest may reasonably decline to establish or maintain a relationship in certain cases.

In this respect, Tilvest prudentially excludes potential clients who fall into one or more of the following categories:

• Minors or individuals subject to legal protection measures affecting legal capacity;
• Politically Exposed Persons (PEPs) and equivalent categories as defined by applicable regulations;
• “U.S. Persons” as defined by the applicable regulation.

2.2. Fair Treatment of Prospects and Clients

All requests from Tilvest’s prospects and clients are handled fairly by its teams, without unjustified favoritism.

Decisions affecting them (e.g., service limitations, handling of complaints, terminations, etc.) are based on objective and consistent criteria, and are communicated as clearly and transparently as possible.

2.3. Pricing Transparency

The pricing conditions applied by Tilvest are defined in its Pricing Policy, available on its website (www.tilvest.com).

3. Review

This policy is reviewed at least annually under the responsibility of Tilvest’s Management, in particular in light of changes in applicable regulations, Tilvest’s commercial strategy, or, more generally, as part of a continuous improvement process that incorporates feedback from stakeholders (prospects, clients, etc.).

4. Amendments

The current version of this policy is permanently available on Tilvest’s website.

Given that the scope of this policy constitutes information that must be made available to the public—and potentially, by extension and best practice, to prospects as part of pre-contractual disclosure—any update to this policy does not, in principle, require the prior consent of Tilvest’s clients.

However, Tilvest reserves the right, where appropriate and relevant, to notify its clients of any material change to this policy.

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Updated on June 16th 2025

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