Verification Methodology

Status and authority

This document (the Methodology) sets out the procedure applied by Trading Integrity Bureau (TIB, operated by Stratinova LTD, Cyprus, HE475207) in the conduct of every verification engagement.

Binding effect

The Methodology is a description of TIB's process. It binds TIB internally and is incorporated by reference into every Engagement Agreement. It does not, of itself, create rights enforceable by any third party.

Companion documents

The Methodology should be read together with: (a) the TIB Integrity Standards (the substantive criteria applied); (b) the Terms of Service; and (c) the Legal & Disclosures.

Definitions

Capitalised terms not defined here have the meaning given in the Terms of Service, § 2. Additional terms used throughout the Methodology:

• Engagement — a verification project conducted under a written Engagement Agreement.
• Evidence Item — a discrete piece of documentary, system, or testimonial evidence collected during the Engagement.
• Reviewer — a TIB-assigned individual conducting the assessment of evidence against the Standards.
• Determination — the conclusion of an Engagement at pillar level (Pass / Conditional / Fail) and overall (Verified / Conditional / Not Verified / Revoked).
• Material Finding — a finding that affects a pillar Determination.
• Effective Date — the date of issue of the Determination, recorded in the Registry entry.

Engagement scope

Eligible firms

TIB conducts verifications of legal persons whose operations fall within the scope of the Standards: proprietary trading firms, brokers and dealers, funds, exchanges and trading venues, custodians, and infrastructure providers serving the trading industry.

Engagement types

Three formats are available; the Standards applied are identical, only scope and evidence depth vary:

Format	Coverage	Registry marker
Full verification	All six pillars and 30 criteria.	Registry entry with overall Determination and pillar-level results.
Limited-scope review	One or more named pillars only.	Registry entry marked limited-scope with named pillars listed.
Re-assessment	Periodic review of a previously verified Firm.	Registry entry updated with new Effective Date.

The four phases

Every Engagement proceeds through four sequential phases. Phase exit criteria must be met before progression.

Evidence pathway

Source hierarchy

TIB prefers evidence in descending order of probative value:

1. Primary system evidence — direct extracts from production systems (logs, ledgers, telemetry), preferably under TIB-supervised collection.
2. Contemporaneous documentation — policies, board minutes, register entries, dated and version-controlled.
3. Third-party confirmations — custodian statements, auditor letters, counterparty acknowledgements.
4. Management representations — used only to corroborate and contextualise items above; not relied upon as primary evidence for Material Findings.

Evidence chain of custody

Each Evidence Item is recorded with: source, date of collection, person collecting, hash where electronic, and link to the criterion it addresses. The chain is preserved for the retention period set out in the Privacy Policy, § 9.

Sampling

Where complete population evidence is impractical (e.g. high-volume payout records), TIB applies risk-based sampling and discloses the sampling approach in the verification report.

Two-reviewer rule

No single individual may issue, deny, or revoke a Determination. Every Determination requires the concurrence of two Reviewers, both of whom have reviewed the Evidence Items relevant to the pillar in question.

Independence of Reviewers

Reviewers must not have any commercial, personal, or financial relationship with the Firm that could reasonably impair independent judgement. Independence is confirmed by written declaration before assignment.

Resolution of disagreement

Where Reviewers reach different Determinations, the Engagement Lead convenes a structured resolution session. If disagreement persists, an additional senior Reviewer is added and a majority Determination is recorded with the dissenting position retained in the working file.

Determination scale

At pillar level:

Result	Meaning
Pass	All binding criteria within the pillar are met by sufficient and appropriate evidence.
Conditional	One or more binding criteria are not yet met but are capable of remediation within an agreed timeframe (typically 90 days).
Fail	One or more binding criteria are materially not met and remediation is not feasible within the engagement window.

At overall level:

Status	Required pillar profile
Verified	All in-scope pillars at Pass.
Conditional	All in-scope pillars at Pass or Conditional, with at least one at Conditional and a documented remediation plan.
Not Verified	One or more in-scope pillars at Fail.
Revoked	A previously Verified or Conditional Determination withdrawn after issue, per § 16.

Pillar coverage

Every Determination evaluates the six pillars set out in the Standards:

The full criteria set is published at Standards.

Materiality and weighting

Findings are weighted by their potential adverse effect on participants. A finding is treated as Material where it reasonably could:

• Cause a participant to take a different decision than they would have absent the finding;
• Result in unreimbursable financial loss to a participant;
• Constitute a breach of a binding rule or commitment to participants;
• Indicate a systemic weakness in a control function.

Non-material findings are recorded in the report as observations and do not change the Determination.

Publication

Registry entry

Each Verified or Conditional Determination produces a Registry entry containing: Firm display reference, Effective Date, Standards version, scope, pillar Determinations, next review date, and plain-language summary. Each entry has a stable canonical URL for verification by third parties.

Pre-publication notice

The Firm receives the proposed Registry entry and full report at least three (3) business days before publication, to allow exercise of the right of factual reply (see § 14).

Plain-language summary

The summary is written for non-specialist participants and avoids defined-term-only construction. Where a Determination contains technical caveats, the summary discloses them in lay terms.

Independence controls

The following structural controls operate to maintain the independence of every Engagement:

• Separation of functions. Commercial discussions (scoping, fees, timeline) are handled by personnel organisationally separated from Reviewers issuing the Determination.
• Two-reviewer rule. No single Reviewer can grant, deny, or revoke a Determination.
• Fixed criteria. A Firm cannot negotiate which criteria apply to it. Criteria are identical for every Firm under the same Engagement type.
• Right of factual reply, not editorial control. A Firm may correct factual errors before publication but cannot alter the Determination.
• Revocation authority. A Determination may be revoked at any time on Material Findings to the contrary.
• Appeal independence. Appeals are heard by Reviewers who did not participate in the original Determination.

Conflicts of interest

Reviewer declarations

Before assignment, each Reviewer signs a written declaration confirming the absence of relationships that could impair independent judgement, including: prior employment with the Firm in the preceding 24 months, financial interests in the Firm, and personal relationships with controlling persons.

Disqualification

Where a conflict is identified, the Reviewer is disqualified and replaced. The disqualification and substitution are recorded in the working file.

Engagement-level conflicts

TIB declines or terminates any engagement where TIB or its operating entity has a relationship with the Firm that extends beyond the engagement itself, including common ownership, common directors, common controlling persons, a separate commercial relationship (consulting, advisory, remediation, training, service provision), or any other circumstance that on a reasonable view could compromise independence. TIB does not operate a "related-party" carve-out. Full criteria are published at Team & Governance, § 6.

Confidentiality

All evidence and working materials are handled under the confidentiality terms of the Engagement Agreement. The verification report is confidential to the Firm and to TIB. Only the Registry entry, and any redacted extracts to which the Firm has consented, are publishable.

Right of factual reply

Before publication of an adverse Determination or Material Finding, the Firm receives the proposed report and Registry entry and is allowed a defined period (typically five business days) to identify factual errors. Errors substantiated by evidence are corrected. Disputes about characterisation, weighting, or conclusion are not corrections within this section and may be raised via the appeal procedure (§ 15).

Appeals

Grounds

A Firm may appeal a Determination on the following grounds, individually or in combination:

• Factual error — the Determination relies on a factual finding contradicted by evidence available at the time of the Determination;
• Procedural failure — a material departure from this Methodology;
• Manifestly unreasonable assessment — a Determination no reasonable Reviewer could have reached on the evidence.

Procedure

Appeals are submitted in writing within twenty (20) business days of publication. They are heard by a panel of two Reviewers who did not participate in the original Determination. The panel may uphold, vary, or substitute the Determination. The appeal outcome is recorded alongside the Registry entry.

Effect

The original Determination remains in force pending appeal unless the appeal panel orders an interim stay.

Revocation

TIB may revoke a Determination at any time where:

• Evidence subsequently received contradicts a Material Finding;
• A Conditional remediation deadline is missed without an agreed extension;
• The Firm misrepresents its TIB status or misuses the Verified Mark;
• A material change in the Firm's operations occurs that would, on the evidence, lead to a Fail Determination.

Revocation is recorded in the Registry entry, the previous status is preserved in history, and the Firm receives a reasoned notice. The Firm retains the right of appeal under § 15.

Re-assessment

Verified and Conditional Determinations are subject to scheduled re-assessment as recorded in the Registry entry. Re-assessment may be triggered earlier by:

• A material change in the Firm's operations or governance;
• Credible third-party reports indicating a possible Material Finding;
• An updated Standards version that materially changes the criteria for the Engagement type.

Methodology updates and changelog

The Methodology is reviewed at least annually and may be updated more frequently. Each version is identified by a document code (TIB-MTH-x.y) and an Effective Date. Material updates are announced in advance, and Engagements in flight at the time of an update continue under the version stated in their Engagement Agreement.

Limitations

The Methodology, however carefully applied, has inherent limitations:

• A Determination reflects evidence at the Effective Date and is not a guarantee of future conduct;
• TIB is not an auditor within the meaning of any statutory audit framework and does not express an audit opinion;
• Evidence reliance involves judgement and sampling; complete population review is not always practicable;
• The Methodology applies the Standards; matters outside the Standards are not assessed.