Commercial Practices Policy
Commercial Policy
Introduction
The purpose of this policy is to set out the main objective and non-discriminatory rules adopted by Tilvest to determine its priority market, identify its “core market”, its target audience and, consequently, the clients with whom it agrees to enter into business relationships.
It further sets out the principles governing the relationships between Tilvest and its prospects or clients for the purpose of providing its products and services in compliance with the applicable regulations.
This policy applies to all services offered by Tilvest.
1. General Principles
1.1 Non-discrimination
Tilvest shall provide its services on an objective, fair and non-discriminatory basis.
No prospect or client shall be subject to differential treatment, in particular on the grounds of 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 legitimately entitled to require its prospects and clients to provide complete, accurate and consistent information.
Furthermore, no client may use Tilvest’s services for the purpose of causing harm, by any means whatsoever, to Tilvest, to third parties, or to their respective rights, interests or reputation.
1.3 Rights, registrations, authorisations, certifications or approvals
Tilvest’s commercial positioning is necessarily determined by the scope of its rights to carry out its activities, as well as by any registrations, authorisations, certifications or approvals that are useful or required for the marketing of its products and services.
1.4 Risks and Tilvest’s contractual freedom
Without prejudice to, or incompatibility with, the other principles set out above, and in particular the principle of non-discrimination, Tilvest remains at all times free to decide whether or not to enter into a relationship with a prospect, and whether or not to continue an existing contractual relationship.
Such decisions, whether at the initiation of the business relationship or during its subsequent performance, result from Tilvest’s assessment of opportunity based on its financial, material and human resources, its risk appetite, the legal and regulatory requirements applicable to it, and the quality of its interactions with each prospect or client.
Furthermore, a decision taken by Tilvest at a given point in time shall not prevent it from subsequently identifying new elements (provided that they comply with the principles set out herein) that may lead to the termination of a business relationship, whether long-standing or not.
Beyond this, Tilvest’s Management and its commercial or client relationship teams seek to share a common, coherent, non-discriminatory and fair overall approach.
2. Relationships between Tilvest and its prospects or clients
2.1 Commercial positioning and target audience
2.1.1 General description
Tilvest offers its products and services to end clients, whether natural persons or legal entities. For the marketing of its offerings, it most often works with partners or business introducers.
Tilvest’s core target market is the French market.
Depending on the arrangements that may be implemented in the future (in particular in light of applicable legal and regulatory opportunities and/or constraints), Tilvest may consider expanding its activities internationally, initially within the European Union.
2.1.2 Prudential and commercial exclusions
In order to safeguard the security of its operations and that of its prospects, and taking into account the specific characteristics of crypto-assets (volatility, complexity, technological risks, potential misuse, gradual acculturation of the general public, etc.), Tilvest is not in a position to reasonably accommodate every request to enter into a business relationship or to provide services.
In particular, and on a prudential basis, Tilvest excludes potential clients falling into one or more of the following situations:
- minority or legal protection measures affecting legal capacity;
- occasional clients;
- persons qualifying as politically exposed persons or equivalent under the applicable regulations;
- persons qualifying as “US Persons” within the meaning of the applicable regulations.
Finally, Tilvest’s offerings, products and services are not intended to be used by its clients to pay for products or services provided by third parties, nor, more generally, to transfer, directly or indirectly, ownership of crypto-assets or funds to third parties.
2.2 Fair treatment of prospects and clients
All requests from Tilvest’s prospects and clients are handled fairly by its teams, without unjustified preferential treatment.
Decisions affecting them (for example: service limitations, handling of complaints, terminations, etc.) are based on objective and harmonised criteria and are communicated in the clearest and most transparent manner possible.
2.3 Pricing transparency
The pricing conditions applied by Tilvest are defined in its Pricing Policy, which is available on its website (www.tilvest.com
and, more specifically, at https://www.tilvest.com/legal/politique-tarifaire
).
3. Review
This policy is reviewed at least annually under the responsibility of Tilvest’s Management, in particular in light of changes in the applicable regulations, Tilvest’s commercial strategy, or, more generally, as part of a continuous improvement process, taking into account feedback from its various stakeholders (prospects, clients, partners, etc.).
4. Amendments
The version of this policy in force is permanently available on Tilvest’s website.
As this framework constitutes information provided to the public and, by extension and as a matter of best practice, pre-contractual information provided to prospects, any amendment to this policy should not require the prior consent of Tilvest’s clients. Nevertheless, Tilvest reserves the right, where relevant and appropriate, to notify its clients of any material amendment to this policy.
Last updated: 12 December 2025