Anti-Circumvention & Zero-Bypass Policy

HALBEX invests in verified sourcing, compliance, escrow and logistics for every trade. The purpose of this policy is to prevent a Buyer or Seller from using HALBEX to identify a counterparty and then trading around the platform. It applies to every registered user and to any person acting on their behalf.

For a period of 24 months from the later of (a) the date of first introduction through the platform or (b) the date of the most recent transaction between the parties through HALBEX, neither party will, directly or indirectly, solicit, contract with, or otherwise transact with the counterparty (or any affiliate or related entity first identified through HALBEX) outside the platform in respect of the goods, categories or business introduced through HALBEX.

The following conduct is prohibited and treated as circumvention or attempted bypass:

• Off-platform communication — contacting the counterparty outside HALBEX channels, or attempting to identify or reach the counterparty through documents, labels, carrier data or other means.
• Direct settlement — making or receiving any payment, deposit or credit outside the platform escrow.
• Identity disclosure — sharing or soliciting counterparty identity, pricing, or margin information.
• Indirect bypass — completing a trade through a third party, affiliate or broker to avoid the platform.

HALBEX enforces this policy using automated and manual detection, including contact-sharing and off-platform routing detection, communication monitoring through platform channels, and review of settlement patterns. Suspected breaches are investigated and documented before any enforcement action.

A breach of this policy may result in, at HALBEX's discretion, one or more of the following: immediate suspension of platform access, termination of the account, withholding of escrow funds pending investigation, and removal from the verified buyer or seller network.

If a party breaches the non-circumvention covenant, HALBEX is entitled to liquidated damages equal to the greater of (a) 30% of the gross value of the bypassed transaction(s) or (b) INR 5,00,000 (Indian Rupees five lakh), as a genuine pre-estimate of the loss to HALBEX of its platform, compliance and escrow investment. This is without prejudice to HALBEX's right to seek injunctive relief and further damages where the actual loss exceeds the liquidated amount.

Users may report suspected circumvention through the security or trust surface in the portal. HALBEX may audit account activity, communications and settlement records to verify compliance, and will retain audit evidence in the trade vault.

If any provision of this policy is held unenforceable, the remainder continues in full force. Questions about this policy may be directed to legal@halbex.com.