Operating Rules

Version 2.0 - 18th December 2025

1. Introduction

Welcome to TOD Markets, the premier Trading System for Over the Counter (OTC) trading in Electricity Financial Derivatives. This document serves as an integral part of the service agreement and is essential for all customers seeking to commence trading on our Trading System. By engaging with our services, Market Participants acknowledge and commit to adhering to the rules outlined herein.

Purpose of This Document:

• Guidelines for Access: This document provides guidance on how to access the TOD Markets Trading System and engage in trading activities. It defines the eligibility criteria for Market Participants, details the registration process, and describes the management of approved counterparties.

• Operational Procedures: It outlines the operational standards for order handling within the Trading System, including the processes for order creation, updates, cancellation, and matching. This ensures that all Market Participants understand their responsibilities and the mechanisms for executing transactions effectively and securely.

• Market Integrity and Security: The document specifies the trading rules essential for maintaining market integrity and security. It highlights the controls implemented to prevent errors and unauthorised activities and the operational actions the Trading System may take in response to market disruptions or security breaches.

• Definition of Terms: To ensure clarity and prevent misunderstandings, the document provides definitions for key terms and concepts used throughout, facilitating a uniform understanding among all Market Participants.

By acknowledging this document as part of the service agreement, customers affirm their understanding and acceptance of these conditions as fundamental to their trading activities on TOD Markets. This framework is designed to ensure secure, efficient, and transparent market operations, upholding the highest standards of integrity and compliance.

2. Market Access

This section outlines the prerequisites and processes required for entities to gain access to the Trading System as recognised Market Participants. The guidelines ensure that all Market Participants meet the necessary financial and regulatory standards, fostering a secure and compliant trading environment.

2.1 Market Participant Eligibility

To participate in trading on the Trading System, entities must qualify as Wholesale Clients under the relevant financial regulations. Additionally, Market Participants must meet the Approved Counterparty criteria as set by the Operator, which includes financial robustness and good standing in market compliance.

Market Participant Eligibility:

Market Participants registration requirements: 

• Wholesale Client Qualification 

• Approved Counterparty Threshold Requirement: Market Participant has established OTC Bilateral Agreements  

• Participant Agreement and Registration Form

Market Participants are required to ensure the accuracy of their company details, including: 

• Prompt updates to company information: 

• Registration and deregistration of Approved Traders

Trading Account Threshold Requirement:

• Market Participants require three Reciprocal Counterparties (RC) in order to have an active trading account.

• For Market Participants with less than three RC’s, the account will be in Read-Only status.

2.2 Registration Process

To begin the registration process, prospective Market Participants must execute the Market Participant Agreement and Registration Form.

Steps for Registration:

1. Submission of Initial Documentation:

   • Entities must comply with Financial Services Law.

2. Completion of KYC/AML/CTF Forms:

   • Detailed company information and personal information of the entity’s key personnel is required.

   • Verification and compliance checks completed. Company information confirmed against ASIC/AER Registers. Additional checks complete where necessary, as per KYC Program.

3. Approval Notification:

   • Once compliance and due diligence processes are completed, the entity is notified of their market access status and allocated a trading account.

4. User Onboarding & System Training

   • When an entity is registered, the trading manager OR another nominated account administrator(s) will be established by the Operator. This user(s) is called an ‘Account Admin’.

   • The Account Admin will establish their Approved Traders' and read-only users' permissions or notify the Operator of any changes to a users' access.

   • System training available to all users upon request.

2.3 Approved Counterparty List Management

Registered Market Participants must actively manage and update their list of Approved Counterparties to reflect current and accurate trading relationships. This management is critical for maintaining compliance and ensuring the integrity of all market transactions.

Responsibilities include:

• Regular Review and Updates:

  • Conduct regular reviews to ensure that all Approved Counterparties meet the ongoing eligibility criteria.

  • Update the list to add or remove Approved Counterparties as relationships change or if compliance issues arise.

• Notification of Changes:

  • Notify the Operator of any significant changes to the list in a timely manner.

  • Ensure that all updates are reflected in the trading system to prevent unauthorised transactions.

2.4 Ongoing Requirements for Market Participants

2.4.1 Standards of Conduct

Market Participants must at all times act honestly, fairly and in good faith in their dealings on the Market; comply with these Operating Rules and Operators directions; ensure information provided to the Operator is accurate, complete and not misleading; and ensure that only Approved Traders submit Orders on their behalf.

2.4.2 Prohibited Conduct

Without limiting 2.4.1, a Market Participant must not engage in conduct that undermines market integrity or fair practice, including without limitation:

2.4.3 Operational Obligations

A Market Participant must maintain appropriate internal controls over access credentials, keep its Approved Counterparty list current, and promptly notify the Operator of any unauthorised access.

2.4.4 Market Participant Eligibility & Representations

The Market Participant represents and warrants that each time an Order is entered into the Trading System, that the Market Participant:

3. Market Operations

This section delineates the operational procedures for handling orders within the Trading System, ensuring that all Market Participants understand their responsibilities and the mechanisms for executing trades effectively and securely.

The Trading System is an order matching facility only. A Trade effected on the Trading System will become legally binding only after confirmation is exchanged with the relevant Reciprocal Counterparty. If a Trade fails to become binding due to the absence of a confirmation, the Market Participant must use reasonable endeavours to promptly report this to the Operator. Such a Trade will be considered void unless otherwise agreed between the parties involved. The Market Participant is responsible for the execution, settlement, and management of credit exposures to Approved Counterparties. The Operator is not responsible for the execution or settlement of Trades, or for any losses or credit exposures arising from bilateral arrangements between Market Participants.

3.1 Approved Counterparties and Reciprocal Counterparties

The Operator permits price matching exclusively with Reciprocal Counterparties. 

A Reciprocal Counterparty is a counterparty that both Market Participants have mutually listed as an Approved Counterparty. The Trading System provides all bid/offer spread information and identifies pricing available for matching with Reciprocal Counterparties. 

The Trading System provides a Global Toggle Button that allows Market Participants to switch between the best market pricing and reciprocal pricing. 

Market Participants must ensure that their list of Approved Counterparties is accurate at all times. When two Market Participants list each other as Approved Counterparties, they become Reciprocal Counterparties. Once an Approved Counterparty has been disconnected there is a 4-hour delay before it can be reconnected.  

Trades are confirmed and settled based on the terms agreed upon under the bilateral agreements between the Market Participants. These bilateral agreements include ISDAs (International Swaps & Derivatives Association) and CSAs (Credit Support Annex). The Operator holds no responsibility for settlement activities of Trades matched on the Trading System. 

Not all Market Participants have bilateral agreements, and therefore not all Market Participants can match with each other’s orders.  

As not all Market Participants can match with each other it is possible that orders entered may cause a “Choice” or “Inverted” market to occur.

3.2 Order Management

The Trading System is designed to support the lifecycle of an order efficiently, from creation and validation to matching and execution. The Trading System ensures a fair and transparent trading environment, supported by a well-structured order-matching algorithm and performance-optimised execution flow. 

• Order Creation:

  • Initiation: Traders initiate orders by entering the required mandatory fields for an Order on the Trading System, specifying type (buy or sell), asset, price, persistence and quantity.

  • Validation: The system automatically validates entered Orders against market rules and the Market Participant’s status to ensure only valid orders are stored and processed.

  • Submission: Validated orders are logged with a unique ID and timestamp and entered into the market.

• Order Updates:

  • Modification Process: Market Participants may modify orders that have not yet been fully filled. Modifications are subject to validation similar to new orders.

  • Restrictions: Order updates are restricted during certain market conditions or phases of trading to ensure market stability.

• Order Cancellation:

  • Cancellation Rights: Market Participants can cancel orders, provided they have not been fully filled. Cancellations of an unfilled or residual Order has an immediate effect on an open Order.

  • Impact Analysis: The Operator will conduct regular audits of cancellation activities to identify patterns that could indicate manipulative behaviour or system issues.

3.3 Order Matching

The Order matching system is designed to operate transparently and anonymously, ensuring that all Market Participants have an equal opportunity under fair market conditions. By systematically applying these rules, the Operator maintains the integrity and reliability of the trading environment. 

Process Overview:

1. Searching for Matching Orders:

   • The system searches for existing Orders that match the new Order's criteria based on:

     • The Order type (buy or sell) and price overlap. The Order type determines whether the system looks for higher buy prices or lower sell prices to match.

     • The system will only find Orders from Market Participants that are on the new order owner’s Reciprocal Counterparties list at the time of processing.

   • Where no matching Order is found, the matching process stops and the Order joins the pool of open Orders, waiting to be filled by new Orders in price time priority.

2. Matching of Trades:

   • When a matching order is identified, a Trade is executed at the price of the matching Order and quantity.

   • If the submitted Order quantity exceeds that of the first matched Order, the system continues to search for the next oldest Order with a matching price.

   • This process repeats until the entire quantity of the submitted Order is matched or no more matching Orders are available.

3. Order Priority and Price Sorting:

   • The system sorts available Orders primarily by price to ensure the best possible trade for the submitting party. Within the same price level, Orders are prioritised based on their submission time, adhering to a "first in, first out" (FIFO) principle. This approach guarantees that earlier Orders have priority over those submitted later, promoting fairness and temporal efficiency in Order handling.

3.4 Trade Reporting

Effective reporting is essential for transparency and for Market Participants to make informed decisions.

• Real-Time Order & Trade Reporting:

  • Real-Time Trade Broadcast: As trades are matched, the Trading System UI will place a record of the Trade in the Market Trades Report table. As well as adjusting the displayed price in the UI to show any changes to the available price and quantity.

  • Data Included: The reports include Asset ID, quantity, price, and timestamp immediately upon matching.

  • Access: Real-time reports are accessible through the Trading System, enabling Market Participants to monitor market activity continuously.

  • History: Changes to Orders are logged and viewable in the detailed order view, to provide a history of changes made by users and market system processes.

  • On Platform: The Trading System provides both a Trades and Orders filter view to generate their own reports.

  • API Endpoints: The Trading System provides the same report data via a REST API.

• End-of-Day Trade Reporting:

  • Summary Report: A comprehensive summary of all trading activities, including volume, price, and trade IDs, is provided at the close of each trading day.

  • Distribution: Reports are emailed to all Market Participants and available for download from the Trading System.

  • The Daily report is laid out as follows:

• Custom Reports & Data Analysis:

  • Where the reporting needs of a Market Participant are outside the Trading System features provided, the Operator can scope, run and provide customised reports to Market Participants.

3.5 Settlement

The Operator connects buyers and sellers on price and volume, The Operators responsibilities end at the trade report. Post Trade Matching bilateral confirmations and settlements are the responsibility of the Market Participants to a trade.  

It is market convention that the Seller issues the confirmation to the buyer. 

3.6 Market Data

a) Market data generated by or made available through the Trading System is provided to Market Participants for the purpose of facilitating trading activities in accordance with these Operating Rules.

b) A Market Participant and Data Subscriber must not copy, reproduce, repackage, distribute, publish, transmit or otherwise make available any Market data to any third party, including other Market Participants except:

c) A Market Participant and Data Subscriber must not permit any third party to access Market data other than through authorised access to the Trading System in accordance with these Operating Rules.

d) Market data may include information provided to the Operator by Market Participants or generated by the Trading System. The Operator does not warrant the accuracy, completeness or timeliness of any Market data.

e) Market Participants and Data Subscribers remain responsible for their own assessment and use of Market data, including any reliance placed on such data for trading or risk management purposes.

3.7 Limitation of Liability

The Trading System is provided on an ‘as-is’ basis by the Operator. The Operator provides no representation or warranty in relation to the Trading System, service levels or availability of the Trading System. To the maximum extent permitted by law, the Operator will not be liable for:

This limitation applies regardless of the form of action, whether in contract, tort (including negligence), strict liability, or otherwise, and even if the Operator has been advised of the possibility of such damages.

If, for any reason, the Operator is found liable for any Claims in above clause, the total amount recoverable from the Operator in aggregate for all Claims will be limited to the Fees paid by the Market Participant to the Operator for the 6 month period immediately prior to the Claim arising.

4. Trading Rules

The following measures are in place to maintain the integrity and security of the trading environment within the Trading System. It specifies the procedures to prevent errors or unauthorized activities and outlines the Trading System’s authority to respond effectively to any market disruptions or security breaches. 

4.1 Market Integrity Controls

The Operator employs several advanced controls to uphold the integrity of the market, which include comprehensive pre-trade checks and dynamic error prevention protocols:

• Pre-trade Validation:

  • User-Confirmation: Before submission, each Order requires user confirmation to ensure accuracy. This step acts as a final check where traders verify the details of their Orders.

  • Automated Checks: Orders must pass automated validation that examines adherence to market rules such as price thresholds and quantity limits. This includes checking Orders against current market prices to prevent errors that could arise from data entry or outdated price information.

  • Rule-Based Filters: Orders are screened through rule-based filters that check for abnormalities like significant deviations from market norms or potential compliance issues.

• Error Prevention Protocols:

  • Bid/Offer Spread Controls: To maintain market liquidity and prevent market manipulation, Orders that would result in a bid/offer spread narrower than $0.01 are automatically rejected.

  • Order Entry Confirmation: Traders are provided with a summary of Order details for confirmation before final submission. This step serves as a redundancy to verify that all entered information is correct and intended, reducing the likelihood of misentries.

  • Threshold Warnings: If an Order is entered at a price that deviates 15% from the Last Trade or Close Price, a warning is displayed to the trader, prompting a review before proceeding. This helps maintain pricing consistency and prevents disruptive market entries.

These controls are designed to minimise errors and unauthorised activities by combining automatic system checks with mandatory trader verifications, thereby reinforcing the overall market integrity.

API Order entry is outside these parameters and should be reviewed with care prior to order submission.

4.1.1 Trade Confirmation and Binding Status 

(a) All Trades on the Trading System are non-binding until Market Participants exchange confirmations in accordance with applicable market conventions. 

(b) If no confirmation is exchanged and signed between Counterparties to a trade, the Trade is automatically void. 

4.1.2 Error Trades 

(a) If a Trade deviates by more than 20% from the Last Market Price, the Operator may void the Trade if the error is reported within 15 minutes.  

(b) Market Participants must notify the Operator immediately to request an error trade void. 

4.1.3 Trade Disputes (Non-error Trades) 

(a) For all other disputes (deviations less than 20%), Market Participants are responsible for resolving the issue.  

(b) The Operator may assist with communication but will not resolve the dispute unless it meets the Error Trade criteria. 

4.1.4 Reporting Timeframes 

 (a) A Market Participant must notify the Operator of any suspected Error Trade or Trade Dispute as soon as practicable and in any event within one (1) Business Day of the relevant Trade. 

(b) Where a suspected Error Trade is not reported within the timeframe specified in paragraph (a), the Trade may not be reviewed or voided under clause 4.1.2. 

(c) Where a Trade Dispute does not meet the Error Trade criteria or is not reported within the timeframe specified in paragraph (a), the Trade will be treated as final once confirmed between the relevant Market Participants in accordance with their bilateral arrangements. 

4.2 Security

The Operator is committed to maintaining the highest level of security:

• Two-Factor Authentication (2FA): A standard feature and mandatory for all users to access the Trading System, 2FA reduces the likelihood of unauthorised individuals accessing the system via a compromised device or credentials.

• Encryption and Data Protection: All data transmitted between traders and the Trading System is encrypted by HTTPS or other protocols to prevent interception and unauthorised access.

• Regular Security Audits: Conduct thorough security audits to identify and rectify vulnerabilities in the system.

4.3 Permitted Use of the Trading System 

All Intellectual Property Rights related to the Trading System and its services are owned exclusively by the Operator.  

Each Market Participant acknowledges that access to the Trading System is granted subject to the following conditions:  

(i) The Market Participant must use the Intellectual Property only for entering Orders and Trades in accordance with the Operating Rules;  

(ii) The Market Participant must not copy, modify, distribute, reverse-engineer, or sublicense the Trading System or Intellectual Property without the Operator’s prior written consent;  

(iii) The Operator may terminate the Market Participant’s access to the Trading System and Intellectual Property at its discretion. 

4.4 Operational Actions

In the event of market disruptions or security issues, the Operator reserves the right to take necessary actions to protect Market Participants and maintain market integrity:

• Halt Market Trading: Trading on the Trading System may be temporarily halted to prevent errors or abuses from affecting the market's stability.

• Cancel Trades: The Operator may cancel trades that result from clear errors, fraudulent activities, or system malfunctions, with notifications sent to affected parties.

• Access Restrictions: The Trading System may adjust or limit access to trading functionalities for participants found in violation of trading rules or involved in suspicious activities.

• Compliance and Enforcement: Enforcement of compliance with all Operating Rules and the immediate implementation of corrective measures when breaches occur.

4.5 Enforcement, Suspension and Expulsion

4.5.1 Enforcement Action

Where the Operator reasonably considers that a Market Participant has breached these Operating Rules (or any procedures or directions issued under the Operating Rules), or that its continued access poses an unacceptable risk to market integrity or orderly operation, the Operator may take one or more of the following actions (having regard to the circumstances and any response provided by the Market Participant):

4.5.2 Immediate Protective Action

The Operator may suspend access with immediate effect without prior notice where the Operator considers this reasonably necessary to protect market integrity, or respond to a material system or control failure.

4.5.3 Reinstatement

A Market Participant whose access has been suspended or whose participation has been terminated may apply for reinstatement. The Operator may reinstate access if satisfied the underlying cause has been remedied and may impose reasonable conditions on reinstatement.

4.5.4 Regulatory Liaison

Nothing in this section limits the Operator’s ability to notify or liaise with ASIC or any other relevant authority where required or appropriate.

4.6 Conflicts Management and Independent Oversight 

(a) Conflicts arrangements 

The Operator must maintain written arrangements to identify, assess, manage and, where necessary, mitigate conflicts between: 

    (i) the Operator’s commercial interests (including the interests of any Related Body Corporate); and 
    (ii) the Operator’s obligation to operate the market in a fair, orderly and transparent manner. 

(b) Independent oversight appointment 

Without limiting paragraph (a), the Operator must appoint, and maintain the appointment of, an independent compliance oversight provider, which may be: 

(i) an independent compliance consultant; or 

(ii) a related entity that is operationally independent of the Operator’s commercial decision-making and has separate reporting lines for compliance oversight. 

(c) Independence and Access 

The Independent Compliance Oversight Provider must: 

1. Have unrestricted access to information, systems, personnel, records and premises reasonably required to perform its role; 

2. Be engaged on terms that protect its independence, including protection from removal or limitation of scope because of the content of its findings; and 

3. Report its findings directly to the Operator’s governing body (or a committee of it) at least quarterly, and promptly if urgent. 

(d) Monitoring compliance with these Operating Rules 

The Independent Compliance Oversight Provider’s role includes monitoring and testing the Operator’s compliance with these Operating Rules, including by: 
(i) conducting periodic compliance testing against a documented compliance plan; 
(ii) reviewing incidents, complaints and suspected breaches; and 
(iii) verifying that remediation actions are implemented and effective.  

(e) Enforcement and escalation 
The Operator must maintain arrangements to enforce these Operating Rules, including: 
(i) procedures for investigation and determination of suspected breaches; 
(ii) documented escalation to senior management and the governing body for material breaches or recurring issues; and 
(iii) applying the enforcement measures available under these Operating Rules . 

(f) Conflicts escalation 
If the Independent Compliance Oversight Provider identifies a conflict that cannot be adequately managed within existing controls, the Operator must escalate the matter to the governing body (or its committee) and implement additional mitigation measures (which may include ring-fencing decision-making, independent review/approval, or changes to governance).  

(g) Operator accountability 
Responsibility for compliance with these Operating Rules and applicable regulatory obligations remains with the Operator. However, the Operator must consider and respond to findings and recommendations of the Independent Compliance Oversight Provider within a reasonable timeframe and record the response and any remediation. 

5. Definitions

Objective: Provide concise definitions for key terms and concepts used throughout the document to ensure clarity and uniform understanding among all Market Participants.

This section defines the terms essential for interpreting the rules and procedures governing the operations of Trading System:

• AEMO (Australian Energy Market Operator): The governmental body responsible for operating Australia’s national electricity market and power systems. AEMO oversees the electricity and gas systems and markets, ensuring reliable, secure, and efficient energy supply to Australian consumers.

• AFSL (Australian Financial Services Licence): A mandatory license required by any Australian business that offers financial services, including trading in financial and commodity-based derivative instruments and electricity contracts.

• Asset: refers to each of the products offered, defined in Product Specification. Also referred to as a ‘Product’.

• Approved Counterparty: An entity that has been vetted and approved by a Market Participant.

• Approved Trader(s): An individual authorised by a Market Participant to execute trades on behalf of the organisation. 

• Bid: an order to Buy an Asset as entered into the Trading System.

• Bid/Offer Spread: The difference between the highest price a buyer is willing to pay (bid) and the lowest price a seller is willing to accept (offer). It reflects the liquidity and depth of the market for a particular asset.

• Business Day: A day that is not a Saturday, Sunday, or a public holiday. 

• CTF (Counter-Terrorism Financing): Legal and regulatory measures put in place to prevent, detect, and disrupt the flow of funds intended to support terrorist activities.

• Corporations Act: The Corporations Act 2001 (Cth). 

• Data Subscriber: An entity that is authorised by the Operator to access Market data generated by or made available through the Trading System, solely for information purposes.

• Error Trade: A Trade resulting from a manifest error, including a pricing error, system error, or input error.

• Financial Services Law: As defined in the Corporations Act 2001 (Cth).

• Operating Rules: Operating Rules are the latest Operating Rules as published by the Operator from time to time.

• Inverted Market: A market situation where bid prices are higher than offer prices due to liquidity issues or non-reciprocal counterparty relationships. 

• KYC (Know Your Customer): A component of AML (Anti-Money Laundering) practices required by financial institutions to verify the identity of their clients. The process aims to prevent fraud and money laundering activities.

• Market / The Market: Refers to the Wholesale Electricity Market, as represented by the TOD Markets platform, further defined below.

• Market Data: Any information relating to Orders, Trades, prices, volumes, timestamps, market depth, product identifiers, and other trading-related data that is generated by, derived from, or made available through the Trading System, whether in real time, delayed, historical, aggregated, or in report form, and whether displayed via the Trading System user interface, provided through reports, or accessed via API.

• Market Marking: The process or activity of providing liquidity to the market by being willing to buy and sell at publicly quoted prices. 

• Market Participant: Any entity authorised to engage in trading activities on the Trading System. This includes electricity retailers, generators, and wholesale traders who meet specific regulatory and operational criteria.

• Market Participant Agreement: The agreement between the Operator and the Market Participant. 

• NEM (National Electricity Market): The wholesale electricity market in Australia that facilitates the physical exchange of electricity between suppliers (generators) and consumers (via retailers).

• NEM Settlement Weeks: The settlement periods within the National Electricity Market. 

• Offer: An Order to sell the Asset as entered into the Trading System.

• Operator: TOD Markets Pty Ltd.

• Order: An order that is submitted to the Trading System.

• Order Matching Algorithm: The algorithm used to match and sell Orders in accordance with the Operating Rules.

• Partial Execution: An Order that has been partially matched with a residual quantity of the Order to be filled.

• Price: The fixed price at which an order is made for a given Product. 

• Product: Each of the products offered through the Trading System, defined in Product Specification. Also referred to as an ‘Asset’, as defined here.

• Product Code: A unique identifier for a specific product traded on the market, indicating features like geographical area, time frame, and product type.  Defined in Product Specification. 

• Real-Time Notification System: A communication system within the Trading System that immediately informs Market Participants of important events such as trade confirmations, market updates, and system alerts.

• Reciprocal Counterparty: Two entities that have mutually agreed upon terms to recognise each other as eligible trading partners under specific conditions outlined in their bilateral agreements.

• Suspension Event: Halt in Trading Activity or access to the Trading System.

• Ticker Quantity: The quantity of an order displayed in MW. 

• Time References: References in this agreement to a time of day are to Australian Eastern Standard Time (not adjusted for daylight saving time in any jurisdiction). 

• Time Stamp: Identifies the time and date when data is transmitted, received, or created by the Trading System. 

• Trade: an order is matched with an opposing bid or offer in the market. A trade represents the parameters of an agreement, which is later confirmed by its parties after the fact. Also referred to as ‘Transaction’.

• Trade Dispute: means any disagreement, claim or issue between Market Participants relating to a Trade that does not meet the criteria for an Error Trade, including disputes regarding pricing, quantity, intention, confirmation, or bilateral settlement terms, and which is to be resolved between the relevant Market Participants in accordance with their bilateral arrangements.

• Trading Halt: A suspension by the Operator of a Member’s access to or use of the Trading System. 

• Trader: An individual authorised to act on behalf of their company on the Trading System.

• Trading Hours: The trading days and hours during which the Trading System is normally available for access and use, and Transactions can be formed. 

• Trading Participant: A type of Market Participant that has been specifically registered and authorized to trade directly in the market, rather than through intermediaries.

• Trading System: The electronic infrastructure provided by the Operator for the placement, matching, and execution of orders. It includes both the hardware and software components necessary for the secure and efficient operation of market transactions.