White paper drafted under the European Markets in Crypto-Assets Regulation (EU) 2023/1114 for FFG B41HCBXWK

The crypto-asset DeepBook (DEEP) referred to in this white paper is a crypto-asset other than EMTs and ARTs, and is issued on the Sui network as of 2026-02-25 and according to DTI FFG shown in F.14. The maximum supply of the crypto-asset is fixed at 10,000,000,000 tokens. The first activity in Sui can be viewed on 2024-03-28 (transaction hash: 0xdeeb7a4662eec9f2f3def03fb937a663dddaa2e215b8078a284d026b7946c270, source: https://suivision.xyz/package/0xdeeb7a4662eec9f2f3def03fb937a663dddaa2e215b8078a284d026b7946c270, accessed 2026-02-25).

DeepBook is a decentralised central limit order book protocol built natively on the Sui blockchain. It is designed to function as a shared on-chain trading infrastructure layer that can be integrated by third-party decentralised applications, including decentralised exchanges, wallets, and other trading interfaces. Rather than operating a standalone front-end, the protocol provides order book functionality and matching logic directly on-chain, enabling market participants to submit, match, and settle orders within the Sui network environment, subject to network conditions and technical constraints.

Within this framework, the DEEP crypto-asset serves as the native governance and incentive token of the DeepBook protocol. It may be used to pay trading fees and liquidity pool creation fees associated with the operation of DeepBook pools. According to publicly available documentation, the use of DEEP for fee payments may result in reduced fee rates compared to payments made in other supported tokens, subject to protocol-defined parameters. Holders may also stake DEEP tokens in specific DeepBook liquidity pools. Staking may entitle participants to reduced taker fees, volume-based fee discounts, and token-denominated incentive distributions for providing liquidity, in accordance with the rules encoded in the relevant smart contracts.

The crypto-asset does not grant any legally enforceable or contractual rights or obligations to its holders or purchasers. Any functionalities accessible through the underlying technology are purely technical or operational in nature and do not confer rights comparable to ownership, profit participation, governance, or similar entitlements known from traditional financial instruments.

As defined in Article 3(9) of Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on Markets in Crypto-Assets – amending Regulations (EU) No 1093/2010 and (EU) No 1095/2010 and Directives 2013/36/EU and (EU) 2019/1937 – a utility token is “a type of crypto-asset that is only intended to provide access to a good or a service supplied by its issuer”. This crypto-asset does not qualify as a utility token, as its intended use goes beyond providing access to a good or a service supplied solely by the issuer.

Crypto Risk Metrics GmbH is seeking admission to trading on the Payward Global Solutions LTD (“Kraken”) platform in the European Union in accordance with Article 5 of Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on Markets in Crypto-Assets, amending Regulations (EU) No 1093/2010 and (EU) No 1095/2010 and Directives 2013/36/EU and (EU) 2019/1937. The admission to trading is not accompanied by a public offer of the crypto-asset.

Crypto Risk Metrics GmbH is a technical service provider that supports regulated entities in fulfilling their regulatory requirements. Among other services, Crypto Risk Metrics GmbH acts as a data provider for ESG data under Article 66(5). In light of the requirements set out in Articles 4(7), 5(4) and 66(3) of Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on Markets in Crypto-Assets, and amending Regulations (EU) No 1093/2010 and (EU) No 1095/2010 and Directives 2013/36/EU and (EU) 2019/1937, Crypto Risk Metrics GmbH aims to provide central services for crypto-asset white papers.

Crypto Risk Metrics GmbH, founded in 2018 and based in Hamburg (HRB 154488), has undergone several strategic shifts in its business focus since incorporation. Due to these changes in business model and operational direction over time, the financial figures from earlier years are only comparable to a limited extent with the company’s current commercial activities. The present business model – centred on regulatory technology and risk analytics in the context of the MiCA framework – has been developed progressively and can realistically be considered fully operational since approximately 2024.

The company’s financial trajectory over the past three years reflects the transition from exploratory development towards market-ready product delivery. Profit or loss after tax for the last three financial years is as follows:

2024 (unaudited): loss of EUR 50,891.81

2023 (unaudited): loss of EUR 27,665.32

2022: profit of EUR 104,283.00

The profit in 2022 resulted primarily from legacy consulting activities, which were discontinued as part of the company’s repositioning.

The losses in 2023 and 2024 resulted from strategic investments in the development of proprietary software infrastructure, regulatory frameworks, and compliance technology for the MiCA ecosystem. During those periods, no substantial commercial revenues were expected, as resources were directed towards preparing the platform for market entry in a regulated environment.

A fundamental repositioning of the company occurred in 2023 and especially in 2024, when the focus shifted towards providing risk management, regulatory reporting, and supervisory compliance solutions for financial institutions and crypto-asset service providers. This marked a material shift in business operations and monetisation strategy.

Based on the current business development in Q4 2025, revenues exceeding EUR 550,000 are expected for the fiscal year 2025, with an anticipated net profit of approximately EUR 100,000. These figures are neither audited nor based on a finalised annual financial statement; they are derived from the company’s current pipeline, client development, and active commercial engagements. Accordingly, they are subject to future risks and market fluctuations.

With the regulatory environment now taking shape and the platform commercially validated, it is assumed that the effects of the strategic developments will continue to materialise in 2026. The company foresees further scalability of its technology and growing market demand for regulatory compliance tools in the European crypto-asset sector.

No public subsidies or governmental grants have been received to date; all operations have been financed through shareholder contributions and internally generated resources. Crypto Risk Metrics has never accepted any payments in tokens from projects it has worked with and – due to its internal Conflicts of Interest Policy – never will.

Not applicable. The company has been established for more than three years and its financial condition over the past three years is provided in Part A.16 above.

Mysten Labs, Inc. develops and maintains software infrastructure intended to support the development and operation of decentralised applications and distributed-ledger-based systems. The company’s activities focus on the design and implementation of technical components that may include distributed systems architecture, cryptographic mechanisms, and programming tools.

Not applicable.

According to public information (source: https://www.deepbook.tech/, accessed 2026-02-25), the DeepBook project is a crypto-asset initiative concerned with the development and operation of a decentralised, fully on-chain central limit order book protocol built on the Sui blockchain and intended to function as a foundational liquidity layer within the Sui ecosystem. The protocol enables permissionless creation of trading pairs, on-chain order submission and matching, and liquidity coordination through self-executing smart contracts. Rather than operating a dedicated user interface, the protocol is designed to be integrated by third-party decentralised exchanges, wallets, and applications that access its shared liquidity infrastructure.

The technical core of the project is the DeepBook protocol, an open smart-contract system deployed natively on the Sui network and structured to provide low-latency order matching and high-performance trading directly on-chain. The protocol facilitates the placement and execution of limit and market orders within liquidity pools and incorporates configurable parameters such as taker fees, maker rebates, and minimum staking thresholds within predefined bounds. Fee flows and incentive mechanisms are embedded at the protocol level, and unused fee surpluses may be subject to automated burn mechanisms on a periodic basis, depending on the applicable epoch configuration and governance parameters.

The DEEP crypto-asset functions as an element within this broader technical framework. It is intended to interact with specific components of the protocol’s internal logic, including fee-payment mechanisms, staking-based configurations, incentive distribution structures, and pool-level governance procedures. DEEP may be used to pay trading and pool-creation fees, and certain fee discounts may apply where fees are settled in DEEP. The token may further be distributed as an incentive to liquidity providers and market participants under predefined programme rules. Holders who stake DEEP may participate in pool-level governance decisions, including voting on parameters such as maker and taker fee levels and minimum staking requirements, subject to technical constraints and governance design. Certain functionalities, including staking configurations, incentive parameters, burn mechanics, and governance frameworks, remain subject to ongoing technical development and future governance determinations.

The project does not involve the granting of ownership, profit-participation rights, or legal claims against the project entity or its contributors. Instead, it centres on the creation of a technical environment in which the DEEP crypto-asset may serve as a governance and utility input for certain protocol processes. The long-term evolution of the DeepBook system, including the scope of available features, the decentralisation roadmap, governance procedures, and the operational continuity of the infrastructure, may vary based on technical, economic, and regulatory considerations. All future developments remain subject to change.

This section provides an overview of the historical developments related to the DEEP crypto-asset and a description of planned or anticipated project milestones as publicly communicated. All forward-looking elements are subject to significant uncertainty. They do not constitute commitments, assurances, or guarantees, and may be modified, delayed, or discontinued at any time. The implementation of past milestones cannot be assumed to continue in the future, and future changes may have adverse effects for token holders.

There is no formally published multi-year roadmap for the DEEP crypto-asset. Based on public information (sources: https://www.deepbook.tech/, https://x.com/DeepBookonSui; accessed 2026-02-25), several protocol upgrades, ecosystem initiatives, and crypto-asset-related developments have been communicated that affect the evolution of the DeepBook protocol and the role of the DEEP crypto-asset.

Past milestones:

- DB Claim NFT Airdrop Announcement (28 March 2024): An airdrop mechanism was announced granting eligible wallets the right to claim DEEP tokens, establishing an initial distribution framework for a portion of the token supply.

- DeepBook V3 and DEEP Token Mainnet Launch (14 October 2024): DeepBook V3 and the DEEP crypto-asset were launched on the Sui mainnet. Approximately 10 percent of the total supply was made claimable by the community. Trading functionality and on-chain governance mechanisms were activated. The V3 upgrade introduced, inter alia, flash-loan functionality, pool-level governance features concerning fees and staking parameters, and an updated matching engine architecture.

- DeepBook V3.1 Upgrade (2024): A subsequent protocol iteration referred to as V3.1 was introduced, focusing on refining arbitrage-related mechanisms and enhancing the efficiency and accessibility of the liquidity engine.

- DeepBook Margin Introduction (February 2026): Documentation indicates the planned introduction of “DeepBook Margin,” intended to incorporate leverage-based functionality and provide additional tools for protocol integrators and builders.

Future milestones:

- Request for Proposals Programme (Ongoing): The protocol maintains a Request for Proposals programme under which external contributors may submit proposals for new features, integrations, or enhancements, reflecting a governance-driven development process.

- Continued Ecosystem Integration (Ongoing): Public communications indicate an intention to further integrate DeepBook as a foundational liquidity layer within the Sui decentralised finance ecosystem, including continued collaboration with aggregators and decentralised exchange interfaces.

Note: All future milestones are subject to significant uncertainty, including but not limited to technical feasibility, regulatory developments, market adoption, and community governance decisions. The project may modify, delay, or discontinue any of these initiatives at any time. Past implementation or performance outcomes do not constitute an indication of future results, and any such changes may materially affect the characteristics, availability, or perceived value of the DEEP crypto-asset for its holders.

Based on information from various third-party and industry sources, it is reported that the crypto-asset project associated with the DEEP token has attracted participation from early-stage venture capital investors. Public references indicate that SPARTAN GROUP is described as having invested in the DeepBook project. In addition, Raptor Digital, identified as an early-stage venture capital firm, lists DeepBook within its publicly disclosed portfolio. The amounts, timing, structure, and contractual terms of any such investments have not been publicly disclosed.

However, this information is derived exclusively from public announcements, portfolio disclosures, and third-party publications. The project, its issuer, or affiliated entities have not independently confirmed within the context of this white paper the precise occurrence, amounts, structure, legal classification, or contractual terms of any venture capital investments. It cannot be independently verified whether such investments were structured as token purchases, equity participations, strategic partnerships, or other arrangements. As a result, any reported investor participation should be considered indicative only.

The maximum supply of the DEEP token is reported to be 10,000,000,000 tokens. At genesis, 25% of the total supply was unlocked. According to publicly available information, 28.43% of the total supply was allocated to core contributors and early backers, including investors and team members, subject to vesting arrangements.

While certain allocations reference Mysten Labs, which is identified as the issuer of the token, this section focuses exclusively on allocations to contributors and early backers and does not assess issuer-retained tokens beyond publicly available disclosures.

The exact distinction between token-based financing and private equity participation, including corresponding rights and obligations, cannot be independently verified for the purposes of this disclosure. As a result, the reported funding amounts, investor participation, structural details, and cumulative funding figures cannot be independently verified and should be considered indicative only.

Not applicable, as this white paper serves the purpose of admission to trading and is not associated with any fundraising activity for the crypto-asset project.

The purpose of seeking admission to trading is to enable the crypto-asset to be listed on a regulated platform in accordance with the applicable provisions of Regulation (EU) 2023/1114 and Commission Implementing Regulation (EU) 2024/2984. The white paper has been drawn up to comply with the transparency requirements applicable to trading venues.

Holder restrictions are subject to the rules applicable to the Crypto-Asset Service Provider, as well as to any additional restrictions such provider may impose.

The token is intended to be listed on the trading platform operated by Payward Global Solutions LTD ("Kraken"). Access to this platform depends on regional availability and user eligibility under Kraken’s terms and conditions. Investors should consult Kraken’s official documentation to determine whether they meet the requirements for account creation and token trading.

The costs involved in accessing the trading platform depend on the specific fee structure and terms of the respective crypto-asset service provider. These may include trading fees, deposit or withdrawal charges, and network-related gas fees. Investors are advised to consult the applicable fee schedule of the chosen platform before engaging in trading activities.

Not applicable, as this white paper is written to seek admission to trading, not for the initial offer to the public.

MiCA-compliant crypto-asset service providers shall have strong measures in place in order to manage conflicts of interests. Due to the broad audience this white paper is addressing, potential investors should always check the conflicts-of-interest policy of their respective counterparty.

Crypto Risk Metrics GmbH has established, implemented, and documented comprehensive internal policies and procedures for the identification, prevention, management, and documentation of conflicts of interest in accordance with applicable regulatory requirements. These internal measures are actively applied within the organisation. For the purposes of this specific assessment and the crypto-asset covered by this white paper, a token-specific review has been conducted by Crypto Risk Metrics GmbH. Based on this individual review, no conflicts of interest relevant to this crypto-asset have been identified at the time of preparation of this white paper.

Not applicable, as this white paper is written to seek admission to trading, not for the initial offer to the public.

Not applicable, as this white paper is written to seek admission to trading, not for the initial offer to the public.

The DEEP token is designed to facilitate protocol-level coordination, economic alignment, and decentralised decision-making within the DeepBook protocol on the Sui network. Token holders who stake DEEP in a specific liquidity pool may participate in pool-level governance, including proposing and voting on adjustments to certain technical parameters such as taker baseline fees, maker fees, and minimum staking requirements for subsequent epochs. Voting power is determined in accordance with a square root voting mechanism, resulting in sub-linear increases in influence relative to the amount staked. Governance rights relate exclusively to technical and pool-specific protocol parameters and do not extend to decisions regarding the operation, management, or assets of any legal entity.

Within the DeepBook ecosystem, DEEP functions as the primary asset for the payment of protocol fees, including trading fees and pool creation fees. Payment of fees in DEEP may provide defined fee reductions compared to other settlement assets, and additional volume-based fee discounts may apply to participants who meet specified staking thresholds. Staking DEEP in a pool for the duration of an epoch may also entitle liquidity providers to receive protocol-defined maker incentives, subject to applicable parameters and liquidity conditions. Residual fees not distributed as incentives may be programmatically burned in accordance with protocol rules. These functionalities depend on the continued operation of the Sui blockchain, the correct execution of smart contracts, governance-defined parameters, oracle availability where applicable, and the overall technical integrity of the DeepBook protocol infrastructure.

The DEEP token does not confer ownership, profit participation, governance rights over the issuer or any related entity, or any form of economic entitlement. All functionalities are technical in nature and relate exclusively to interactions within the DeepBook protocol environment. The actual usability of DEEP depends on factors such as system stability, smart-contract execution, development progress, governance decisions, and the operational conditions of the Sui blockchain and any other distributed-ledger networks on which DEEP is deployed or bridged, which are outside the control of token holders.

Future milestones:

- Request for Proposals Programme (Ongoing): The protocol maintains a Request for Proposals programme under which external contributors may submit proposals for new features, integrations, or enhancements, reflecting a governance-driven development process.

- Continued Ecosystem Integration (Ongoing): Public communications indicate an intention to further integrate DeepBook as a foundational liquidity layer within the Sui decentralised finance ecosystem, including continued collaboration with aggregators and decentralised exchange interfaces.

Note: All future milestones are subject to significant uncertainty, including but not limited to technical feasibility, regulatory developments, market adoption, and community governance decisions. The project may modify, delay, or discontinue any of these initiatives at any time. Past implementation or performance outcomes do not constitute an indication of future results, and any such changes may materially affect the characteristics, availability, or perceived value of the DEEP crypto-asset for its holders.

The crypto-asset referred to herein is a crypto-asset other than EMTs and ARTs, and is available on the Sui network. The crypto-asset is fungible up to 6 digits after the decimal point. The crypto-asset constitutes a digital representation recorded on distributed-ledger technology and does not confer ownership, governance, profit participation, or any other legally enforceable rights. Any functionalities associated with the token are limited to potential technical features within the relevant platform environment. These functionalities do not represent contractual entitlements and may depend on future development decisions, technical design choices, and operational conditions. The crypto-asset does not embody intrinsic economic value; instead, its value, if any, is determined exclusively by market dynamics such as supply, demand, and liquidity in secondary markets.

No such services are currently known to be provided by the issuer. However, it cannot be excluded that additional services exist or may be offered in the future outside the scope of Regulation (EU) 2023/1114.

The crypto-asset does not grant any legally enforceable or contractual rights or obligations to its holders or purchasers.

Any functionalities accessible through the underlying technology are of a purely technical or operational nature and do not constitute rights comparable to ownership, profit participation, governance, or similar entitlements known from traditional financial instruments.

Accordingly, holders do not acquire any claim capable of legal enforcement against the issuer or any third party.

As the crypto-asset does not confer any legally enforceable rights or obligations, there are no applicable procedures or conditions for their exercise. Any interaction or functionality that may be available within the project’s technical infrastructure – such as participation mechanisms or protocol-level features – serves operational purposes only and does not create, evidence, or constitute any contractual or statutory entitlement.

As the crypto-asset does not confer any legally enforceable rights or obligations, there are no conditions or mechanisms for modifying such rights or obligations. Adjustments to the technical protocol, smart contract logic, or related systems may occur in the ordinary course of development or maintenance. Such changes do not alter the legal position of holders, as no contractual rights exist and no rights arise under applicable law or regulation. Holders should not interpret technical updates or governance-related changes as amendments to legally binding entitlements.

Information on the future offers to the public of crypto-assets were not available at the time of writing this white paper (2026-02-25).

The crypto-assets themselves are not subject to any technical or contractual transfer restrictions and are generally freely transferable. However, crypto-asset service providers may impose restrictions on buyers or sellers in accordance with applicable laws, internal policies or contractual terms agreed with their clients.

For the crypto-asset in scope, the supply is limited to 10,000,000,000 tokens according to public information (Source: https://www.deepbook.tech/deep-token, 2026-02-25). Investors should note that changes in the supply of the crypto-asset can have a negative impact.

This white paper is submitted in the context of an application for admission to trading on a trading platform established in the European Union. Accordingly, this white paper shall be governed by the laws of the Federal Republic of Germany.

Any disputes arising in relation to this white paper or the admission to trading may fall under the jurisdiction of the competent courts in Hamburg, Germany.

The crypto-asset in scope is implemented on the SUI network following the standards described below.

The crypto-asset that is the subject of this white paper is available on the SUI network.

The following applies to SUI:

The Sui protocol is based on the Move programming language and an object-centric data model. These standards provide a distinct framework for transaction handling and smart contract design but are relatively new and not yet widely adopted across blockchain ecosystems. The limited maturity of these standards may affect interoperability, availability of developer tools, and long-term support compared to more established protocols.

The crypto-asset that is the subject of this white paper is available on the SUI network.

The following applies to SUI:

The network applies an object-based storage architecture that allows parallel execution of independent transactions. This differs from the account-based model used in most blockchain systems and is intended to improve throughput and latency. While this approach may enhance scalability, it introduces technical uncertainties, including potential integration challenges, limited external audit experience, and reliance on a comparatively small developer community familiar with the Move language.

The crypto-asset that is the subject of this white paper is available on the SUI network.

The following applies to SUI:

Sui employs a hybrid structure: independent transactions are processed using Narwhal & Bullshark, while more complex interactions rely on Delegated Proof-of-Stake (DPoS). This dual system seeks to optimize efficiency, but also increases system complexity. DPoS concentrates decision-making among validators and their delegators, which may expose the network to centralization risks, governance disputes, or validator collusion.

The crypto-asset that is the subject of this white paper is available on the SUI network.

The following applies to SUI:

The incentive structure is based on a DPoS staking model, where validators stake SUI tokens and delegators can participate through delegation. Rewards are distributed according to stake, which may favor large holders. Transaction fees are determined dynamically and include additional charges for long-term storage of on-chain data. This design is intended to align incentives and control resource use, but fee levels and staking distribution could affect accessibility and participation over time. SUI also offers sponsored transactions, where one address pays the gas for another addresse's transaction. This feature is intended to facilitate easier adoption by new users but potentially affects incentives.

Not applicable, as the DLT is not operated by the issuer, the offeror, the person seeking admission to trading, or any third-party acting on their behalf.

1. Regulatory and Compliance

Regulatory frameworks applicable to crypto-asset services in the European Union and in third countries are evolving. Supervisory authorities may introduce, interpret, or enforce rules that affect (i) the eligibility of this crypto-asset for admission to trading, (ii) the conditions under which a crypto-asset service provider may offer trading, custody, or transfer services for it, or (iii) the persons or jurisdictions to which such services may be provided. As a result, the crypto-asset service provider admitting this crypto-asset to trading may be required to suspend, restrict, or terminate trading or withdrawals for regulatory reasons, even if the crypto-asset itself continues to function on its underlying network.

2. Trading venue and connection risk

Trading in the crypto-asset depends on the uninterrupted operation of the trading venues on which it is listed and, where applicable, on its technical connections to external liquidity sources or venues. Interruptions such as system downtime, maintenance, faulty integrations, API changes, or failures at an external venue can temporarily prevent order placement, execution, deposits, or withdrawals, even when the underlying blockchain is functioning. In addition, trading platforms in emerging markets may operate under differing governance, compliance, and oversight standards, which can increase the risk of operational failures or disorderly market conditions.

3. Market formation and liquidity conditions

The price and tradability of the crypto-asset depend on actual trading activity on the venues to which the service provider is connected, whether centralised exchanges (CEXs) or decentralised exchanges (DEXs). Trading volumes may at times be low, order books thin, or liquidity concentrated on a single venue. In such conditions, buy or sell orders may not be executed in full or may be executed only at a less favourable price, resulting in slippage.

Volatility: The market price of the crypto-asset may fluctuate significantly over short periods, including for reasons that are not linked to changes in the underlying project or protocol. Periods of limited liquidity, shifts in overall market sentiment, or trading on only a small number of CEXs or DEXs can amplify these movements and lead to higher slippage when orders are executed. As a result, investors may be unable to sell the crypto-asset at or close to a previously observed price, even where no negative project-specific event has occurred.

4. Counterparty and service provider dependence

The admission of the crypto-asset to trading may rely on several external parties, such as connected centralised or decentralised trading venues, liquidity providers, brokers, custodians, or technical integrators. If any of these counterparties fail to perform, suspend their services, or apply internal restrictions, the trading, deposit, or withdrawal of the crypto-asset on the listing crypto-asset service provider can be interrupted or halted.

Quality of counterparties: Trading venues and service providers in certain jurisdictions may operate under regulatory or supervisory standards that are lower or differently enforced than those applicable in the European Union. In such environments, deficiencies in governance, risk management, or compliance may remain undetected, which increases the probability of abrupt service interruptions, investigations, or forced wind-downs.

Delisting and service suspension: The crypto-asset’s availability may depend on the internal listing decisions of these counterparties. A delisting or suspension on a key connected venue can materially reduce liquidity or make trading temporarily impossible on the admitting service provider, even if the underlying crypto-asset continues to function.

Insolvency of counterparties: If a counterparty involved in holding, routing, or settling the crypto-asset becomes insolvent, enters restructuring, or is otherwise subject to resolution measures, assets held or processed by that counterparty may be frozen, become temporarily unavailable, or be recoverable only in part or not at all, which can result in losses for clients whose positions were maintained through that counterparty. This risk applies in particular where client assets are held on an omnibus basis or where segregation is not fully recognised in the counterparty’s jurisdiction.

5. Operational and information risks

Due to the irrevocability of blockchain transactions, incorrect transaction approvals or the use of wrong networks or addresses will typically make the transferred funds irrecoverable. Because trading may also rely on technical connections to other venues or service providers, downtime or faulty code in these connections can temporarily block trading, deposits, or withdrawals even when the underlying blockchain is functioning. In addition, different groups of market participants may have unequal access to technical, governance, or project-related information, which can lead to information asymmetry and place less informed investors at a disadvantage when making trading decisions.

6. Market access and liquidity concentration risk

If the crypto-asset is only available on a limited number of trading platforms or through a single market-making entity, this may result in reduced liquidity, greater price volatility, or periods of inaccessibility for retail holders.

1. Insolvency of the issuer

As with any commercial entity, the issuer may face insolvency risks. These may result from insufficient funding, low market interest, mismanagement, or external shocks (e.g. pandemics, armed conflicts). In such a case, ongoing development, support, and governance of the project may cease, potentially affecting the viability and tradability of the crypto-asset.

2. Legal and regulatory risks

The issuer operates in a dynamic and evolving regulatory environment. Failure to comply with applicable laws or regulations in relevant jurisdictions may result in enforcement actions, penalties, or restrictions on the project’s operations. These may negatively impact the crypto-asset’s availability, market acceptance, or legal status.

3. Operational risks

The issuer may fail to implement adequate internal controls, risk management, or governance processes. This can result in operational disruptions, financial losses, delays in updating the white paper, or reputational damage.

4. Governance and decision-making

The issuer’s management body is responsible for key strategic, operational, and disclosure decisions. Ineffective governance, delays in decision-making, or lack of resources may compromise the stability of the project and its compliance with MiCA requirements. High concentration of decision-making authority or changes in ownership/control can amplify these risks.

5. Reputational risks

The issuer’s reputation may be harmed by internal failures, external accusations, or association with illicit activity. Negative publicity can reduce trust in the issuer and impact the perceived legitimacy or value of the crypto-asset.

6. Counterparty dependence

The issuer may depend on third-party providers for certain core functions, such as technology development, marketing, legal advice, or infrastructure. If these partners discontinue their services, change ownership, or underperform, the issuer’s ability to operate the project or maintain investor communication may be impaired. This could disrupt project continuity or undermine market confidence, ultimately affecting the crypto-asset’s value.

1. Valuation risk

The crypto-asset does not represent a claim, nor is it backed by physical assets or legal entitlements. Its market value is driven solely by supply and demand dynamics and may fluctuate significantly. In the absence of fundamental value anchors, such assets can lose their entire market value within a very short time. Historical market behaviour has shown that some types of crypto-assets – such as meme coins or purely speculative tokens – have become worthless. Investors should be aware that this crypto-asset may lose all of its value.

2. Market volatility risk

Crypto-asset prices can fluctuate sharply due to changes in market sentiment, macroeconomic conditions, regulatory developments, or technology trends. Such volatility may result in rapid and significant losses. Holders should be prepared for the possibility of losing the full amount invested.

3. Liquidity and price-determination risk

Low trading volumes, fragmented trading across venues, or the absence of active market makers can restrict the ability to buy or sell the crypto-asset. In such situations, it is not guaranteed that an observable market price will exist at all times. Spreads may widen materially, and orders may only be executable under unfavourable conditions, which can make liquidation costly or temporarily impossible.

4. Asset security risk

Loss or theft of private keys, unauthorised access to wallets, or failures of custodial or exchange service providers can result in the irreversible loss of assets. Because blockchain transactions are final, recovery of funds after a compromise is generally impossible.

5. Fraud and scam risk

The pseudonymous and irreversible nature of blockchain transactions can attract fraudulent schemes. Typical forms include fake or unauthorised crypto-assets imitating established ones, phishing attempts, deceptive airdrops, or social-engineering attacks. Investors should exercise caution and verify the authenticity of counterparties and information sources.

6. Legal and regulatory reclassification risk

Legislative or regulatory changes in the European Union or in the Member State where the crypto-asset is admitted to trading may alter its legal classification, permitted uses, or tradability. In third countries, the crypto-asset may be treated as a financial instrument or security, which can restrict its offering, trading, or custody.

7. Absence of investor protection

The crypto-asset is not covered by investor-compensation or deposit-guarantee schemes. In the event of loss, fraud, or insolvency of a service provider, holders may have no access to recourse mechanisms typically available in regulated financial markets.

8. Counterparty risk

Reliance on third-party exchanges, custodians, or intermediaries exposes holders to operational failures, insolvency, or fraud of these parties. Investors should conduct due diligence on service providers, as their failure may lead to the partial or total loss of held assets.

9. Reputational risk

Negative publicity related to security incidents, misuse of blockchain technology, or associations with illicit activity can damage public confidence and reduce the crypto-asset’s market value.

10. Community and sentiment risk

Because the crypto-asset’s perceived relevance and expected future use depend largely on community engagement and the prevailing sentiment, a loss of public interest, negative coverage or reduced activity of key contributors can materially reduce market demand.

11. Macroeconomic and interest-rate risk

Fluctuations in interest rates, exchange rates, general market conditions, or overall market volatility can influence investor sentiment towards digital assets and affect the crypto-asset’s market value.

12. Taxation risk

Tax treatment varies across jurisdictions. Holders are individually responsible for complying with all applicable tax laws, including the reporting and payment of taxes arising from the acquisition, holding, or disposal of the crypto-asset.

13. Anti-money-laundering and counter-terrorist financing risk

Wallet addresses or transactions connected to the crypto-asset may be linked to sanctioned or illicit activity. Regulatory responses to such findings may include transfer restrictions, reporting obligations, or the freezing of assets on certain venues.

14. Market-abuse risk

Due to limited oversight and transparency, crypto-assets may be vulnerable to market-abuse practices such as spoofing, pump-and-dump schemes, or insider trading. Such activities can distort prices and expose holders to sudden losses.

15. Legal ownership and jurisdictional risk

Depending on the applicable law, holders of the crypto-asset may not have enforceable ownership rights or effective legal remedies in cases of disputes, fraud, or service failure. In certain jurisdictions, access to exchanges or interfaces may be restricted by regulatory measures, even if on-chain transfer remains technically possible.

16. Concentration risk

A large proportion of the total supply may be held by a small number of holders. This can enable market manipulation, governance dominance, or sudden large-scale liquidations that adversely affect market stability, price levels, and investor confidence.

As this white paper relates to admission to trading of the crypto-asset, the risk description below reflects general implementation risks typically associated with crypto-asset projects and relevant for the crypto-asset service provider. The party admitting the crypto-asset to trading is not involved in the project’s implementation and does not assume responsibility for its governance, funding, or execution.

Delays, failures, or changes in the implementation of the project as outlined in its public roadmap or technical documentation may negatively impact the perceived credibility or usability of the crypto-asset. This includes risks related to project governance, resource allocation, technical delivery, and team continuity.

Key-person risk: The project may rely on a limited number of individuals for development, maintenance, or strategic direction. The departure, incapacity, or misalignment of these individuals may delay or derail the implementation.

Timeline and milestone risk: Project milestones may not be met as announced. Delays in feature releases, protocol upgrades, or external integrations can undermine market confidence and affect the adoption, use, or value of the crypto-asset.

Delivery risk: Even if implemented on time, certain functionalities or integrations may not perform as intended or may be scaled back during execution, limiting the crypto-asset’s practical utility.

As this white paper relates to admission to trading of the crypto-asset, the following risks concern the underlying distributed ledger technology (DLT), its supporting infrastructure, and related technical dependencies. Failures or vulnerabilities in these systems may affect the availability, integrity, or transferability of the crypto-asset.

1. Blockchain dependency risk

The functionality of the crypto-asset depends on the continuous and stable operation of the blockchain(s) on which it is issued. Network congestion, outages, or protocol errors may temporarily or permanently disrupt on-chain transactions. Extended downtime or degradation in network performance can affect trading, settlement, or the usability of the crypto-asset.

2. Smart contract vulnerability risk

The smart contract that defines the crypto-asset’s parameters or governs its transfers may contain coding errors or security vulnerabilities. Exploitation of such weaknesses can result in unintended token minting, permanent loss of funds, or disruption of token functionality. Even after external audits, undetected vulnerabilities may persist due to the immutable nature of deployed code.

3. Wallet and key-management risk

The custody of crypto-assets relies on secure private key management. Loss, theft, or compromise of private keys results in irreversible loss of access. Custodians, trading venues, or wallet providers may be targeted by cyberattacks. Compatibility issues between wallet software and changes to the blockchain protocol (e.g. network upgrades) can further limit user access or the ability to transfer the crypto-asset.

Outdated or vulnerable wallet software:

Users relying on outdated, unaudited, or unsupported wallet software may face compatibility issues, security vulnerabilities, or failures when interacting with the blockchain. Failure to update wallet software in line with protocol developments can result in transaction errors, loss of access, or exposure to known exploits.

4. Network security risks

Attack risks: Blockchains may be subject to denial-of-service (DoS) attacks, 51% attacks, or other exploits targeting the consensus mechanism. These can delay transactions, compromise finality, or disrupt the accurate recording of transfers.

Centralisation concerns: Despite claims of decentralisation, a relatively small number of validators or a high concentration of stake may increase the risk of collusion, censorship, or coordinated network downtime, which can affect the resilience and operational reliability of the crypto-asset.

5. Bridge and interoperability risk

Where tokens can be bridged or wrapped across multiple blockchains, vulnerabilities in bridge protocols, validator sets, or locking mechanisms may result in loss, duplication, or misrepresentation of assets. Exploits or technical failures in these systems can instantly impact circulating supply, ownership claims, or token fungibility across chains.

6. Forking and protocol-upgrade risk

Network upgrades or disagreements among node operators or validators can result in blockchain “forks”, where the blockchain splits into two or more incompatible versions that continue separately from a shared past. This may lead to duplicate token representations or incompatibilities between exchanges and wallets. Until consensus stabilises, trading or transfers may be disrupted or misaligned. Such situations may be difficult for retail holders to navigate, particularly when trading platforms or wallets display inconsistent token information.

7. Economic-layer and abstraction risk

Mechanisms such as gas relayers, wrapped tokens, or synthetic representations may alter the transaction economics of the underlying token. Changes in transaction costs, token demand, or utility may reduce its usage and weaken both its economic function and perceived value within its ecosystem.

8. Spam and network-efficiency risk

High volumes of low-value (“dust”) or automated transactions may congest the network, slow validation times, inflate ledger size, and raise transaction costs. This can impair performance, reduce throughput, and expose address patterns to analysis, thereby reducing network efficiency and privacy.

9. Front-end and access-interface risk

If users rely on centralised web interfaces or hosted wallets to interact with the blockchain, service outages, malicious compromises, or domain expiries affecting these interfaces may block access to the crypto-asset, even while the blockchain itself remains fully functional. Dependence on single web portals introduces a critical point of failure outside the DLT layer.

10. Decentralisation claim risk

While the technical infrastructure may appear distributed, the actual governance or economic control of the project may lie with a small set of actors. This disconnect between marketing claims and structural reality can lead to regulatory scrutiny, reputational damage, or legal uncertainty – especially if the project is presented as ‘community-governed’ without substantiation.

None.

The crypto-asset that is the subject of this white paper is available on the SUI network.

The following applies to SUI:

Sui employs a hybrid structure: independent transactions are processed using Narwhal & Bullshark, while more complex interactions rely on Delegated Proof-of-Stake (DPoS). This dual system seeks to optimize efficiency, but also increases system complexity. DPoS concentrates decision-making among validators and their delegators, which may expose the network to centralization risks, governance disputes, or validator collusion.

The crypto-asset that is the subject of this white paper is available on the SUI network.

The following applies to SUI:

The incentive structure is based on a DPoS staking model, where validators stake SUI tokens and delegators can participate through delegation. Rewards are distributed according to stake, which may favor large holders. Transaction fees are determined dynamically and include additional charges for long-term storage of on-chain data. This design is intended to align incentives and control resource use, but fee levels and staking distribution could affect accessibility and participation over time. SUI also offers sponsored transactions, where one address pays the gas for another addresse's transaction. This feature is intended to facilitate easier adoption by new users but potentially affects incentives.

The energy consumption associated with this crypto-asset is aggregated of multiple contributing components, primarily the underlying blockchain network and the execution of token-specific operations. To determine the energy consumption of a token, the energy consumption of the underlying blockchain network Sui is calculated first. A proportionate share of that energy use is then attributed to the token based on its activity level within the network (e.g. transaction volume, contract execution).

The Functionally Fungible Group Digital Token Identifier (FFG DTI) is used to determine all technically equivalent implementations of the crypto-asset in scope.

Estimates regarding hardware types, node distribution, and the number of network participants are based on informed assumptions, supported by best-effort verification against available empirical data. Unless robust evidence suggests otherwise, participants are assumed to act in an economically rational manner. In line with the precautionary principle, conservative estimates are applied where uncertainty exists – that is, estimates tend towards the higher end of potential environmental impact.

To determine the proportion of renewable energy usage, the locations of the nodes are to be determined using public information sites, open-source crawlers and crawlers developed in-house. If no information is available on the geographic distribution of the nodes, reference networks are used which are comparable in terms of their incentivization structure and consensus mechanism. This geo-information is merged with public information from Our World in Data, see citation. The intensity is calculated as the marginal energy cost wrt. one more transaction. Ember (2025); Energy Institute - Statistical Review of World Energy (2024) - with major processing by Our World in Data. “Share of electricity generated by renewables - Ember and Energy Institute” [dataset]. Ember, “Yearly Electricity Data Europe”; Ember, “Yearly Electricity Data”; Energy Institute, “Statistical Review of World Energy” [original data]. Retrieved from https://ourworldindata.org/grapher/share-electricity-renewables.

To determine the GHG Emissions, the locations of the nodes are to be determined using public information sites, open-source crawlers and crawlers developed in-house. If no information is available on the geographic distribution of the nodes, reference networks are used which are comparable in terms of their incentivization structure and consensus mechanism. This geo-information is merged with public information from Our World in Data, see citation. The intensity is calculated as the marginal emission wrt. one more transaction. Ember (2025); Energy Institute - Statistical Review of World Energy (2024) - with major processing by Our World in Data. “Carbon intensity of electricity generation - Ember and Energy Institute” [dataset]. Ember, “Yearly Electricity Data Europe”; Ember, “Yearly Electricity Data”; Energy Institute, “Statistical Review of World Energy” [original data]. Retrieved from https://ourworldindata.org/grapher/carbon-intensity-electricity Licenced under CC BY 4.0.