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Effective Date: September 9, 2026
Newton Crypto Ltd. (“Newton”), as a Dealer Member of the Canadian Investment Regulatory Organization (“CIRO”), is required under CIRO Dealer Member Rules to establish, maintain, and ensure compliance with written policies and procedures that are reasonably designed to achieve best execution when acting for a client. This Best Execution Policy has been prepared in accordance with CIRO Dealer Member Rule 3129.
“Best execution” means obtaining for our clients the most advantageous execution terms reasonably available under the circumstances, taking into account prevailing market conditions. This policy explains how Newton seeks to achieve best execution for clients when facilitating trades in crypto assets, and is intended to provide a clear, concise, and client-focused summary of the protections and processes we have in place.
Newton uses one or more liquidity providers (“LPs”) to complete client trades and may also use Newton’s proprietary crypto asset inventory as part of this process. Depending on the circumstances, Newton may use an external LP, proprietary inventory, or a combination of both to settle the exposure arising from a client trade.
Newton deploys a request for quote (“RFQ”) process to obtain pricing from each of the LPs supporting the applicable Crypto Asset. For each client trade order of a particular Crypto Asset, Newton submits a corresponding RFQ for the order to each of its LPs which support that Crypto Asset and routes the client order to the LP that provides best pricing at the time the RFQ is sent.
For certain eligible Crypto Assets, Newton may use its proprietary inventory to settle all or a portion of the exposure arising from a client trade, using the best available pricing obtained through the RFQ process. Where proprietary inventory is used, whether alone or together with external LP liquidity, Newton continues to reference available external market pricing and applies the same Best Execution principles described in this Policy.
Engaging a diverse group of LPs helps reduce reliance on any single counterparty and ensures consistent access to liquidity.
Newton only engages LPs that support our commitment to best execution and fair outcomes for clients. In selecting LPs, we consider:
Newton performs ongoing monitoring and periodic reassessment of its LPs to ensure they continue to meet expectations for execution quality. This includes:
If an LP is found to consistently underperform or fails to meet our standards, Newton may deprioritize or remove the LP from our network to protect client interests and preserve pricing competitiveness.
Newton executes eligible client trades with external LPs, and may offset all or a portion of a trade through its proprietary crypto asset inventory.
We do not receive payments, rebates, or other incentives from LPs in exchange for directing order flow. Routing decisions are made in accordance with Newton’s Best Execution obligations and are based on the most advantageous execution terms reasonably available under circumstances, taking into account relevant factors including price, liquidity, speed of execution, certainty of execution, and overall cost of the transaction.
In the event that multiple LPs return identical best quotes, Newton uses a randomized selection process to determine which LP receives the order. This approach ensures fairness and maintains competitive pressure among LPs.
The determination of whether best execution has been achieved is subject to reasonable efforts and should be interpreted in the context of the following broad factors:
For crypto asset trades on Newton’s platform, these broad factors are applied together with the OTC fair pricing considerations outlined in IDPC Rule 3122, including the asset’s fair market value, related transaction expenses, Newton’s profit entitlement, and the total dollar amount of the transaction. These considerations are applied when determining the price before execution and are reviewed after execution to help ensure fairness and competitiveness.
Newton facilitates crypto asset trades through a Request for Quote (RFQ) trading model. Under this model, Newton acts as principal on all trades, meaning we are your direct counterparty - not another Newton customer or a third party. When you buy or sell crypto on the Newton platform, you are transacting directly with Newton. Under this model:
Order Types Supported:
Newton applies a defined spread range to compensate for operational costs and market risk. Spreads are applied transparently and are designed to be competitive in the Canadian crypto market. Newton applies tiered spreads based on the liquidity and volatility of the crypto asset being traded. Our spread tiers are published at newton.co/prices.
We continuously compare our all-in execution prices (LP quote + spread) to independent benchmark rates from reputable data providers to ensure prices remain competitive.
For all order types, Newton:
We continuously monitor executed prices against benchmark rates from reputable data providers to ensure they remain competitive. Benchmarks are reviewed regularly to ensure accuracy and relevance to market conditions. Newton also periodically reviews the pricing policy of each LP.
Crypto asset pricing can be volatile and, when priced in Canadian dollars, can experience rapid price changes, and available liquidity can vary across markets and with Newton’s LPs. In extreme market conditions, LPs may widen their pricing to reflect risk or to allow for them to continue to support an asset during stressed market conditions.
Newton remains committed to providing clients with access to crypto markets at all times, including these periods of significant volatility; however, as Newton is not an exchange, we are subject to the pricing provided by our LPs to complete trades on our platform. As part of our best execution controls, we continually monitor and compare the executed client trade prices on our platform against trusted global benchmark prices.
To account for short-term market fluctuations during periods of market stress, Newton applies a volatility tolerance band above the normal spread range for each asset tier:
During periods of significant market stress, where quoted benchmark prices move rapidly or LP spreads widen to a level that exceeds this volatility tolerance band, Newton may temporarily operate within widened deviation bands to maintain client access and fair execution.
If the all-in execution price on Newton’s platform for client executed trades is at risk of exceeding the maximum allowable range for the asset tier:
If the all-in execution price exceeds the maximum allowable variance from the benchmark price for the asset’s tier, the trade is flagged for internal review.
In certain limited circumstances, where trades fall substantially outside the maximum allowable range and execute at a price far outside the quoted price, Newton may consider reimbursement to you in the amount equal to the difference between the spread we actually collected and the spread we would have collected had the trade executed at the maximum allowable all-in price under stressed market conditions; however, reimbursements are only issued if the portion of Newton’s spread collected on the excess above the allowable range is greater than $5 CAD for a given trade.
Newton’s monitoring systems are designed to protect clients from poor execution outcomes (i.e., disadvantaged pricing) by:
These measures help protect you from paying materially more than the prevailing market rate and ensure that our execution process remains competitive. If we detect that your trade executed at a materially worse price than benchmarks without valid market justification, we will reimburse you according to our defined criteria.
These controls apply regardless of whether Newton settles the resulting exposure using an external LP, Newton’s proprietary inventory, or a combination of both.
Newton does not operate a marketplace or engage in market making. We act as principal in client trades and source liquidity from third-party providers, including our specified affiliate, DV Chain (Canada) Inc.
To manage potential conflicts of interest:
Order Processing Principles:
For additional details on how Newton addresses conflicts of interest, please refer to Newton’s Relationship Disclosure Information available at: https://www.newton.co/relationship-disclosure.
In the event that you require assistance, you can reach out to Newton’s support team via the in-app help chat function or on the Newton website, or by email at support@newton.co. Support is available weekdays and weekends from 8 AM - 12 AM EST.
During normal operations, all client-initiated trading activity on Newton is conducted through the Newton app or website. However, in the event of a platform disruption that results in clients being unable to access their account or place an order due to platform disruption, Newton offers a contingency channel to ensure continuity of trading access during specific business hours.
If clients are unable to trade using the platform, they may place an order by speaking directly with a Newton Investment Representative, who are available during 9:30 AM to 4:00 PM ET on business days, excluding statutory holidays). Customers can contact a Newton Investment Representative at +1 (855) 639-8662.
To place a manual order, clients must:
Only same-day market orders will be accepted; limit, conditional, or special-instruction orders are not permitted. Investment Representatives do not provide investment advice, and will not process any trade instruction submitted by email, chat, or support ticket.
All trades executed through this contingency process are subject to the same best execution standards described in this policy.
Newton conducts periodic reviews of this Best Execution Policy as market conditions dictate, but in any event, this policy will be reviewed at least annually. These reviews ensure that the policy remains effective, relevant, and compliant with CIRO requirements.
Should you have any questions regarding this Best Execution Policy or any policy it describes, please email our support team at support@newton.co.