Participant Code of Conduct

This Participant Code of Conduct (“Code”) defines and reaffirms the values, principles and internal controls that Participant must follow in receiving the Platform Services. The Code is intended to complement the internal principles and practices of Participant and to guide Participant as it receives the Platform Services. Compliance with the Code allows Participant to assure Zero Hash Hash Liquidity Services LLC ("ZHLS"), regulators, the public and other market participants that its business activities on the Platform are, and will continue to be, conducted with integrity. In addition, Participant gives assurance that unlawful and unethical trading practices are not tolerated, that public disclosures of trading information are accurate, and that it will abide by these ethical standards and maintain sound trading practices.

Participant acknowledges that violations of this Code can incur penalties including, but not limited to, temporary or permanent loss of rights to receive the Platform Services.

Ethical Standards

Conducting trading activities with integrity is the essence of ethical conduct. Integrity means conducting these activities in an honorable and principled manner consistent with the ethical standards and sound trading practices set forth herein.
On the Platform, Participant will:

  • Conduct its business in accordance with all applicable laws, regulations, tariffs and rules, and in good faith, and with a commitment to honest dealing.
  • Not engage in fraudulent behavior.
  • Honor the terms and conditions of this Agreement.
  • Engage only in Transactions with legitimate business purposes, such as managing business risk or that otherwise have economic substance. In no event will Participant engage in any Transactions intended to boost revenues or volumes artificially, or intended to manipulate market prices.
  • Not collude with other market Participants to affect the price or supply of any commodity, allocate territories, Participants or products, or otherwise unlawfully restrain competition.
  • Adopt, adhere to, and enforce risk management and other policies and structures that are designed to ensure that trading activities are conducted in accordance with this Code.
  • Not use ZHLS Services in any manner that could interfere with, disrupt, negatively affect, or inhibit other users from fully enjoying such services, or that could damage, disable, overburden, or impair the functioning of our Services in any manner.
  • Not use any robot, spider, crawler, scraper, or other automated means or interface not provided by us to access ZHLS Services or to extract data.
  • Not use or attempt to use another user’s account without authorization.
  • Not attempt to circumvent any content filtering techniques ZHLS employs, or attempt to access any service or area of ZHLS Services that Participant is not authorized to access.
  • Not introduce to ZHLS Services any malware, virus, trojan worms, logic bombs, or other harmful material.

Sound Trading Practices

Markets reflect the constantly changing dynamics of supply and demand. Efficient business operations in such an environment demand practices that can manage risk and discover market prices. Such practices must be consistent with the guiding Ethical Standards of this Code.
Participant will act in accordance with these standards of sound trading practices with regard to its receipt of ZHLS Services.

  • Participant will not arrange and execute simultaneous offsetting buy and sell trades, i.e. with the same counterparty and price, commodity, location and quantity terms, with an intent to artificially affect reported revenues, trading volumes, or prices.
  • Participant will not conduct trading for the purpose of misrepresenting the financial condition of the organization.
  • Agree to comply with trade practice rules that may be adopted by ZHLS and with trade practice rules that are consistent with those generally adopted by DCMs, SEFs or NSEs.
  • Consent to ZHLS' jurisdiction with regard to any investigation of Participant for any rule violation that ZHLS is undertaking.

Information Disclosure and Documentation

Markets depend on trust in the accuracy of market information provided by Participant and in the transparency of market behavior of all market participants.
With regard to its Platform activity, Participant will:

  • Provide Transaction information to regulators in compliance with all applicable rules and requirements and continue to cooperate with regulators as reasonably necessary to assist in their understanding of the markets.
  • Ensure that any information disclosed to ZHLS is accurate and consistent.
  • Maintain and adhere to internal procedures designed to ensure that all Transactions are properly documented in a timely fashion and that no Transactions are concealed or misrepresented when providing market information to ZHLS or any of its affiliates.
  • Promptly notify ZHLS of any Transaction cancellation or reversing trade with the same counterparty for the explicit purpose of effecting cancellation (an equal, but opposite offsetting trade), mutually agreed to by Participant and Counterparty, of a Transaction executed or confirmed on the Platform.
  • Maintain documentation on all Transactions for an appropriate period of time as required under applicable laws and regulations.
  • Make deliveries that conform to government regulations in force at the time of delivery, if applicable.


  • Each Participant will have a compliance program commensurate with the size and scope of its trading activity on the Platform and designed to ensure appropriate, timely and ongoing review of trading practices and compliance with this Code.
  • Participant will:
    • Provide for proper training of personnel on the provisions of this Code.
    • Maintain internal policies and procedures to promote compliance with this Code.
    • Promptly disclose to ZHLS the details of any violations of this Code involving Participant’s receipt of ZHLS Services or provision of market information to Zero Hash or any of its affiliates.
    • Provide an environment that encourages employees within the trading organization to engage in safe and confidential discussions and to disclose to senior management any trading practices that might violate this Code.
    • Establish clear lines of accountability for the company’ s trading practices, including provisions relating to the responsibilities of corporate officers, with appropriate oversight by the Board of Directors or other senior corporate management committee.