White paper drafted under the European Markets in Crypto-Assets Regulation (EU) 2023/1114 for FFG 3XVWCVFSX

The WLFI crypto-asset referred to in this white paper is a crypto-asset other than EMTs and ARTs and is implemented on the Ethereum, BNB Smart Chain (BSC) and Solana networks, according to the DTI FFG shown in section F.14, as of 2026-09-07. On Ethereum, WLFI is a token under the ERC-20 token standard at the contract address 0xda5e1988097297dcdc1f90d4dfe7909e847cbef6; its deployment can be viewed on 2024-09-29 (transaction hash: 0x707e076245ca1860a063879615d9b4e924fb33d6f5f39c78416037a16735f4cc, source: https://etherscan.io/tx/0x707e076245ca1860a063879615d9b4e924fb33d6f5f39c78416037a16735f4cc, accessed 2026-09-07). On the BSC network, WLFI is a token under the BEP-20 token standard at the contract address 0x47474747477b199288bf72a1d702f7fe0fb1deea; its deployment can be viewed on 2025-08-30 (transaction hash: 0x0313b6f79713eba4d277bcd7c2f71fbd53c0f9a952e9f312ba5df2e34f6a5c5c, source: https://bscscan.com/tx/0x0313b6f79713eba4d277bcd7c2f71fbd53c0f9a952e9f312ba5df2e34f6a5c5c, accessed 2026-09-07). On the Solana network, WLFI is a token created under the Solana Program Library at the token address WLFinEv6ypjkczcS83FZqFpgFZYwQXutRbxGe7oC16g; its first mint can be viewed on 2025-08-30 (transaction hash: 26p3hu4QBbrLZtgsh8okuhtxfJf2JS2DDNZiWYGCXoayPKn6gXzPYJQayrnmE15zc36v88CmpBTo5Pm7aGe9Ttuf, source: https://solscan.io/tx/26p3hu4QBbrLZtgsh8okuhtxfJf2JS2DDNZiWYGCXoayPKn6gXzPYJQayrnmE15zc36v88CmpBTo5Pm7aGe9Ttuf, accessed 2026-09-07). The maximum supply of WLFI is 100,000,000,000 tokens, all of which were created at the initial issuance.

According to publicly available information (sources: https://docs.worldlibertyfinancial.com/, accessed 2026-09-07), World Liberty Financial is a decentralised finance project that states its objective as bridging traditional finance and decentralised finance, with a focus on stablecoin infrastructure and accessible capital markets. Its publicly documented products include the USD1 stablecoin, a non-custodial lending interface, tools for bridging and converting tokens and developer tools for automated payments.

The WLFI token is a governance token. It is used to participate in governance of the World Liberty Financial Protocol through the project's governance platform, where holders may submit, discuss and vote on governance proposals (source: https://docs.worldlibertyfinancial.com/wlfi-token/wlfi-governance, accessed 2026-09-07). Voting takes place off-chain and recorded outcomes are verifiable on-chain. Voting power is capped at 5% of the total token supply per address and tokens held in treasury are not votable.

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, and 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 preliminary unaudited management information for the financial year 2025, revenues are expected to have exceeded EUR 800,000, while preliminary net profit is expected to exceed EUR 100,000.

These figures are not audited and are not based on a finalised annual financial statement. Accordingly, they remain subject to finalisation and may differ from the figures ultimately reported in the annual financial statements.

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 GmbH has never accepted any payments in tokens from projects it has worked with and – due to its internal Conflicts of Interest Policy – never will.

Could not be found while drafting this white paper (2026-09-07).

WLF Holdco LLC acts as a holding company.

World Liberty Financial (“WLFI”) is presented by its promoters as a decentralised finance (DeFi) initiative designed to integrate elements of traditional financial infrastructure with blockchain-based governance. According to publicly accessible project materials, including the “Gold Paper” and the website https://worldlibertyfinancial.com (accessed 2026-09-07), the ecosystem is built around two core components: the WLFI governance token, intended to enable participation in protocol-level decision-making, and USD1, a U.S. dollar-denominated stablecoin intended to facilitate transactions within the network.

The project documentation suggests that WLFI aims to create a hybrid financial environment connecting traditional markets and digital assets through tokenised governance and asset issuance mechanisms. These are stated objectives and have not been independently verified.

The project has attracted significant public attention through its association with politically exposed persons (PEPs) and entities linked to prominent public figures. The issuer states that World Liberty Financial, the WLF Protocol and the WLFI token are not political and have no affiliation with any political campaign.

From a functional perspective, WLFI is a governance token that grants holders the ability to vote on ecosystem-related proposals. These governance rights do not confer any enforceable legal entitlements or ownership interests. Participation in governance is therefore discretionary and dependent on the issuer’s continued operation of the governance platform.

As at the date of this white paper, there is no single formally published roadmap for the project. Project history and plans are communicated through the project’s documentation, its governance forum and the project website. No audited financial data in respect of the issuer has been published.

The description in this section is based on information published by the project. Publicly available information may be incomplete, outdated, or subject to material change without prior notice, and prospective holders should take this into account when assessing the project. The long-term evolution of the project depends on governance outcomes and technical, economic and regulatory considerations, and all future developments remain subject to change.

This section provides an overview of the historical developments related to the WLFI 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.

There is no single formally published roadmap for the WLFI token. Project history and plans are communicated through the project's documentation, its governance forum and the project website (sources: https://docs.worldlibertyfinancial.com/get-started/, https://docs.worldlibertyfinancial.com/wlfi-token/, https://docs.worldlibertyfinancial.com/wlfi-token/, https://docs.worldlibertyfinancial.com/wlfi-token/, https://governance.worldlibertyfinancial.com, accessed 2026-09-07).

Past milestones:

- Public token sale (from approximately 2024-10-14): WLFI tokens were offered in a public token sale at prices equivalent to USD 15 per 1,000 tokens and USD 50 per 1,000 tokens, running until approximately 2025-03-14. Approximately 25,000,000,000 WLFI were sold in the public rounds.

- Initial token lock-up (2024 to 2025): tokens from the sale rounds were initially non-transferable and held in participants' wallets, subject to later unlocking.

- Additional network deployments (2025-08-30): WLFI representations were created on the Solana and BNB Smart Chain (BSC) networks, with first observed transfer activity on BNB Smart Chain (BSC) on 2025-09-01.

- First unlock phase (on or about 2025-09-01): an initial 20% of early-supporter tokens became available for unlocking, subject to a token unlock agreement and activation process.

- Governance proposal on unlocking (2026-05-06): the WLFI community passed a governance proposal covering 62,282,252,205 WLFI of locked tokens across two cohorts. Locked early-supporter tokens of 17,043,666,558 WLFI are subject to a two-year cliff followed by a two-year linear vest, with full distribution by year four from the proposal date, and no tokens are burned under that schedule. Locked founder, team, advisor and partner tokens of 45,238,585,647 WLFI are subject to less favourable terms: on election, 10% of that allocation, being 4,523,858,565 WLFI, is permanently burned and removed from the total supply, and the remaining 40,714,727,082 WLFI are subject to a two-year cliff followed by a three-year linear vest, with full distribution by year five. Acceptance is opt-in for both cohorts, and the tokens of holders who do not accept remain locked indefinitely

- Structured unlock phase (from 2026-05-06): eligible early supporters may activate the structured unlock schedule, with tokens claimable after the cliff period according to the published schedule.

Dates given for network deployments refer to the deployment or first mint transaction recorded on the relevant ledger, as cited in section 08. Where a separate date for first observed transfer activity is given, it is identified as such.

Future plans, as publicly communicated:

- Continued operation of the project's governance platform, with proposals, voting and treasury exclusions subject to the published governance mechanics and possible adjustment of voting mechanics over time through governance.

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 WLFI crypto-asset for its holders.

According to publicly available information (sources: https://docs.worldlibertyfinancial.com/wlfi-token/, https://docs.worldlibertyfinancial.com/get-started/, accessed 2026-09-07), the development of the project has been funded primarily through token sales. A public token sale ran between approximately 2024-10-14 and 2025-03-14 at prices equivalent to USD 15 and USD 50 per 1,000 tokens and raised a total of approximately USD 550,000,000, of which 20,000,000,000 WLFI were sold in the first round and 5,000,000,000 WLFI in the second round. The project's documentation further states that the remaining tokens of the token-sale allocation were sold to other parties, including strategic investors and institutional participants, without publishing per-round amounts.

The project's published allocation divides the total supply of 100,000,000,000 WLFI across four categories: 33,893,000,000 WLFI, equal to approximately 34%, for token sales; 32,600,000,000 WLFI, equal to approximately 33%, for community growth and incentives, including ecosystem development and partnerships, liquidity provision, marketing and treasury reserves; 30,000,000,000 WLFI, equal to 30%, allocated to the project's co-founder entities; and 3,507,000,000 WLFI, equal to approximately 4%, for the team and advisors. The co-founder and team allocations were locked at launch. A governance proposal passed on 2026-05-06 established a vesting schedule for these allocations, as described in section D.8. A reserve of USD 15,000,000 of initial net protocol revenue was retained to cover operating expenses, indemnities and obligations, according to project materials (source: https://static.worldlibertyfinancial.com/docs/intl/gold-paper.pdf, accessed 2026-09-07).

The token distribution can be traced on-chain on Ethereum: https://etherscan.io/token/0xda5e1988097297dcdc1f90d4dfe7909e847cbef6#balances. The investor must be aware that a public address cannot necessarily be assigned to a single person or entity, which limits the ability to determine exact economic influence or future actions.

The current beneficial ownership, custody and status of the reported allocations cannot be independently verified on the basis of publicly available information. As a result, the referenced allocation figures cannot be independently verified and should be considered indicative only. Token distribution changes can negatively impact the investor.

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.

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 transaction 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 interest. Due to the broad audience this white paper addresses, 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.

According to publicly available information (sources: https://docs.worldlibertyfinancial.com/wlfi-token/wlfi-governance, https://docs.worldlibertyfinancial.com/wlfi-token/trade-wlfi, accessed 2026-09-07), the WLFI token is described as a governance token within the World Liberty Financial ecosystem. Tokens purchased in the project's early supporter sale rounds were initially non-transferable; transferability has been progressively enabled through the project's unlock arrangements, subject to agreements and eligibility checks.

The current functionality of WLFI is participation in governance of the World Liberty Financial Protocol. Holders may submit governance proposals, discuss them on the project's public forum and vote on them through the project's Snapshot instance. Voting takes place off-chain and results are recorded and verifiable on-chain. Voting power is proportional to the WLFI held by a participant, capped at 5% of the total token supply per address, and tokens held in treasury by the project are not votable. A proposal requires a minimum quorum of 1,000,000,000 WLFI voted and approval by a majority of the tokens cast. Approval of a governance proposal does not guarantee implementation: execution is subject to technical feasibility, security review, legal considerations and operational constraints, and outcomes are not binding in all circumstances. The contract additionally allows the exclusion of a specified address from voting power. An excluded address retains its balance but cannot exercise governance participation.

The project's documentation also describes a trading interface through which unlocked WLFI can be converted against supported stablecoins on Ethereum. This functionality is provided through a third-party decentralised exchange protocol and requires a compatible self-custodied wallet; it is a use of the token rather than a protocol-level function of it.

Beyond governance and transferability, WLFI has no further protocol-level functionality as of the date of this white paper. It is not used to pay transaction fees on any network, it is not required for staking or for the operation or security of a network, and it plays no role in the consensus mechanism of any network on which it is implemented. Holding WLFI does not entitle the holder to any yield, fee share, reward, redemption or other form of income.

The WLFI token does not confer ownership, profit participation, governance rights over the issuer or any related entity in a corporate-law sense, or any form of legally enforceable economic entitlement. All functionalities are technical in nature and relate exclusively to interactions within the World Liberty Financial protocol environment. The actual usability of WLFI depends on factors such as system stability, governance decisions, development progress and the operational conditions of the networks on which it is implemented, which are outside the control of token holders.

Future plans, as publicly communicated:

- Continued operation of the project's governance platform, with proposals, voting and treasury exclusions subject to the published governance mechanics and possible adjustment of voting mechanics over time through governance.

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 WLFI crypto-asset for its holders.

The crypto-asset referred to herein is a crypto-asset other than EMTs and ARTs and is available on multiple networks. The crypto-asset is fungible up to 18 digits after the decimal point on the Ethereum and BNB Smart Chain (BSC) networks and up to 6 digits after the decimal point on the Solana network. 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. Such 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 legally enforceable claim against the issuer of the crypto-asset 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 future offers to the public of crypto-assets was not available at the time of writing this white paper (2026-09-07).

The crypto-asset is technically freely transferable by default. Crypto-assets obtained directly from the issuer prior to publication are subject to lock-up, which limits circulating supply but does not affect the transferability of crypto-assets acquired on the secondary market. However, the token contract includes an issuer-controlled blacklist function that allows designated administrator addresses to freeze the transfer, sale, or protocol interaction of tokens held at specified wallet addresses. This capability was introduced by contract upgrade after the original deployment and has been exercised. Affected balances remain visible on-chain but cannot be moved while a restriction is active. In addition, crypto-asset service providers may impose restrictions on buyers or sellers in accordance with applicable laws, internal policies, or contractual terms.

Not applicable.

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 be brought before the competent courts in Hamburg, Germany.

The crypto-asset in scope is implemented on the BNB Smart Chain (BSC), Ethereum, and Solana networks following the standards described below.

The crypto-asset in scope is implemented on the BNB Smart Chain (BSC), Ethereum and Solana networks following the standards described below.

The following applies to BNB Smart Chain (BSC):

BNB Smart Chain (BSC) is a Layer-1 blockchain that utilises a Proof-of-Staked-Authority (PoSA) consensus mechanism. This mechanism combines elements of Proof-of-Authority (PoA) and Delegated-Proof-of-Stake (DPoS) and is intended to secure the network and validate transactions. In PoSA, validators are selected based on their stake and authority, with the goal of providing fast transaction times and low fees while maintaining network security through staking.

The following applies to Ethereum:

The crypto-asset operates on a defined set of protocols and technical standards that are intended to ensure its security, decentralisation, and functionality. Key items are set out below.

1. Network protocols

Ethereum operates as a decentralised, peer-to-peer network. Nodes communicate using the DevP2P networking stack, with RLPx as the encrypted transport layer for peer-to-peer messages.

Transaction ordering and finality are secured through a Proof-of-Stake (PoS) consensus mechanism. Validators on the Beacon Chain propose blocks, attest to them, and finalise them through Casper FFG operating on top of the LMD-GHOST fork-choice rule. Smart contract execution is performed by the Ethereum Virtual Machine (EVM), which interprets EVM bytecode within the gas limits set by the protocol and by the transaction sender.

2. Transaction and address standards

Ethereum addresses are 20-byte identifiers, derived as the last 20 bytes of the Keccak-256 hash of the uncompressed elliptic-curve public key (excluding the 0x04 prefix). They are commonly represented as 40-character hexadecimal strings with a 0x prefix and an optional EIP-55 mixed-case checksum.

The protocol currently supports the following transaction types:

- Type 0: legacy transactions (pre-EIP-1559).

- Type 1: access-list transactions (EIP-2930).

- Type 2: dynamic-fee transactions with base-fee burning (EIP-1559).

- Type 3: blob-carrying transactions (EIP-4844), introduced with the Dencun upgrade on 2024-03-13.

- Type 4: set-code transactions (EIP-7702), introduced with the Pectra upgrade on 2025-05-07, allow externally owned accounts (EOAs) to authorise delegated code execution during transactions, without permanently converting the account into a smart contract. This enables features such as transaction batching, sponsored gas payments and delegated signing.

3. Blockchain data structure and block standards

The Ethereum state consists of accounts (externally owned accounts and smart contracts) together with their associated storage and code, organised in Modified Merkle Patricia Tries to allow efficient verification.

Each block contains:

- a block header, comprising the parent hash, state root, transactions root, receipts root, timestamp, gas limit and gas used, among other fields;

- the ordered list of transactions, including smart-contract executions and value transfers; and

- blob commitments, where applicable, referring to data published to the data availability layer under EIP-4844.

Block size is not fixed in bytes. It is constrained by a per-block gas limit, which is adjustable within protocol-defined bounds and currently targets approximately 60 million gas following EIP-7935 (Fusaka, activated on 2025-12-03). EIP-7825 (Fusaka) also introduces a per-transaction gas cap of 16,777,216 gas to improve block composability and resilience against denial-of-service patterns.

The data availability layer used by Layer 2 rollups, introduced through EIP-4844, was further developed by EIP-7691 (Pectra, 2025-05-07), which raised the maximum number of blob commitments per block, and by EIP-7594 (Fusaka, 2025-12-03), which introduced Peer Data Availability Sampling (PeerDAS). PeerDAS enables nodes to verify that blob data has been published by sampling small portions of it, rather than downloading every blob in full. Following PeerDAS, Ethereum uses Blob Parameter Only (BPO) forks, introduced by EIP-7892, to adjust blob targets and maxima between major upgrades.

4. Upgrade and improvement standards

Ethereum protocol upgrades are coordinated through the Ethereum Improvement Proposal (EIP) process. EIPs are published openly, reviewed by core developers and the wider community, and bundled into named hard-fork upgrades. The most recent network upgrades are the Pectra upgrade (2025-05-07) and the Fusaka upgrade (2025-12-03). The next named upgrade currently under preparation by the Ethereum core developers is referred to as Glamsterdam.

The following applies to Solana:

The crypto-asset is implemented on the Solana blockchain, a decentralised distributed-ledger network designed to support transaction processing and the execution of on-chain programs. The network relies on a set of technical protocols, cryptographic standards, and program frameworks intended to enable secure transaction validation, deterministic execution of instructions, and interoperability across the Solana ecosystem. The most relevant technical standards and protocols are outlined below.

1. Network Architecture and Core Protocols

The Solana network is structured as a peer-to-peer validator network in which independent nodes maintain the distributed ledger and process transactions.

- Solana uses Proof-of-History (PoH) as a cryptographic timing and ordering mechanism, while validator participation and voting are stake-weighted under its Proof-of-Stake model and Tower BFT consensus process.

- Tower BFT: A Byzantine fault tolerant consensus mechanism, derived from PBFT, that governs validator voting and block confirmation.

- Turbine: A block propagation protocol that distributes blocks across the validator network by splitting them into smaller data fragments (“shreds”) and transmitting them through a layered tree-based structure.

- Gulf Stream: A transaction forwarding mechanism that routes transactions directly to upcoming block producers and thereby limits the need for a global transaction mempool.

- Sealevel: A parallel transaction execution engine that enables non-conflicting transactions and programs to execute simultaneously across multiple processing threads.

Together, these mechanisms support transaction processing while maintaining a synchronised and verifiable ledger state across participating validator nodes.

2. Address and Cryptographic Standards

Accounts and transactions on the Solana network rely on defined cryptographic primitives and address formats.

- Account Addresses: Accounts are identified by 32-byte addresses. Externally controlled accounts typically use Ed25519 key pairs, while program-derived addresses (PDAs) are deterministically derived off-curve addresses that do not correspond to a private key.

- Transaction Signatures: Transactions are authorised through Ed25519 signatures associated with the account owner’s keypair.

- Hashing: Sequential SHA-256 hashing is used within the Proof-of-History mechanism to generate a verifiable ordering of events.

- Program Derived Addresses (PDAs): Deterministically generated addresses derived through hashing procedures that ensure the resulting address does not correspond to a private key, thereby enabling secure program-controlled accounts.

These cryptographic mechanisms provide the basis for transaction authentication, deterministic account control, and verifiable execution of on-chain instructions.

3. Networking and Data Transmission Standards

Communication between validator nodes and network participants follows defined networking protocols and technical constraints.

- QUIC is used for transaction ingress and TPU-related forwarding paths on Solana validators, alongside other networking channels used across the cluster.

- UDP-based propagation: Utilised for distributing block fragments (“shreds”) across the network through the Turbine protocol.

- Transaction size limits: The maximum transaction size of approximately 1,232 bytes is aligned with the IPv6 minimum transmission unit (MTU) after accounting for network headers, and is intended to enable atomic transmission without fragmentation.

- JSON-RPC interfaces: Standardised APIs used by wallets, applications, and infrastructure providers to submit transactions and query blockchain state.

These standards support interoperability between network nodes, developer infrastructure, and user-facing applications interacting with the Solana ledger.

4. Token and Program Standards (Solana Program Library)

Tokens on Solana are commonly implemented using either the original Token Program or the Token Extension Program (Token-2022), each of which defines standardised token behaviour through on-chain program logic.

Within this framework:

- A token type is represented by a mint account, which defines parameters such as total supply and mint authority.

- Individual token balances are stored in token accounts, which hold balances associated with a specific mint and owner address.

- Interactions with tokens occur through instructions executed by the relevant token program rather than through separate token-specific smart contracts.

These programmatic standards enable consistent token management across the Solana ecosystem. Projects may also integrate metadata functionality, for example through the Metaplex Token Metadata Program or, where applicable, through Token-2022 metadata extensions.

5. Protocol Development and Improvement Standards

Technical changes to the Solana protocol may be proposed and discussed through Solana Improvement Documents (SIMDs). These proposals document suggested modifications to protocol behaviour, economic parameters, or technical limits. Accepted changes may be implemented through updates to validator software and related developer tooling used by network participants.

The crypto-asset in scope is implemented on the BNB Smart Chain (BSC), Ethereum and Solana networks following the standards described below.

The following applies to BNB Smart Chain (BSC):

1. BSC-compatible wallets

Tokens on BSC are supported by wallets compatible with the Ethereum Virtual Machine (EVM), such as MetaMask. These wallets can be configured to connect to the BSC network and are designed to interact with BSC using standard Web3 interfaces.

2. Decentralised Ledger

BSC maintains its own decentralised ledger for recording token transactions. This ledger is intended to ensure transparency and security, providing a verifiable record of all activities on the network.

3. BEP-20 token standard

BSC supports tokens implemented under the BEP-20 standard, which is tailored for the BSC ecosystem. This standard is designed to facilitate the creation and management of tokens on the network.

4. Scalability and transaction efficiency

BSC is designed to handle high volumes of transactions with low fees. It leverages its PoSA consensus mechanism to achieve fast transaction times and efficient network performance, making it suitable for applications requiring high throughput.

The following applies to Ethereum:

1. Decentralised Ledger: The Ethereum blockchain acts as the decentralised ledger and execution environment for ETH transactions and smart-contract operations, including ERC-20 token transfers, maintaining an append-only record of transfers and account balances to support transparency and verifiable settlement.

2. Account Model: Ethereum uses two account types: externally owned accounts (EOAs), which are controlled through private keys, and contract accounts, which are controlled through deployed smart contract code. Following the Pectra upgrade on 2025-05-07, EOAs can additionally authorise delegated code execution through EIP-7702 transactions without permanently converting the account into smart contracts.

3. Private Key Management: Users must securely store the private keys and recovery material associated with their wallets. Loss or compromise of a private key may result in irreversible loss of access to the associated ETH or ERC-20 token balance.

4. Cryptographic Integrity: Ethereum uses ECDSA over the secp256k1 elliptic curve for key generation and digital signatures on the execution layer. Keccak-256 hashing is used for transaction hashing, state hashing and address derivation. Ethereum addresses are derived from the last 20 bytes of the Keccak-256 hash of the public key. On the consensus layer, BLS (Boneh-Lynn-Shacham) signatures are used to aggregate validator attestations under the Proof-of-Stake consensus mechanism.

The following applies to Solana:

1. Solana-Compatible Wallets: The tokens are generally supported by wallets compatible with Solana’s token programs.

2. Decentralised Ledger: The Solana blockchain acts as a decentralised ledger for all token transactions, with the intention of preserving a tamper-resistant record of token transfers and ownership in order to ensure both transparency and security.

3. SPL Token Program: Tokens on Solana are commonly implemented using either the original Token Program or the Token Extension Program (Token-2022), which provide standardised on-chain logic for token creation, issuance, transfer, and account management. Unlike the ERC-20 model on Ethereum, where a project typically deploys its own token contract, Solana tokens generally rely on shared token-program infrastructure, which promotes a high degree of standardisation across the ecosystem.

4. Blockchain Scalability: Solana is designed to support high transaction throughput and comparatively low transaction fees, with the intention of enabling efficient token transfers and related on-chain operations.

Security Protocols for Asset Custody and Transactions:

1. Private Key Management: To safeguard their token holdings, users must securely store their wallet’s private keys and recovery phrases.

2. Cryptographic Integrity: Solana uses Ed25519 digital signatures to authenticate transactions submitted by authorised signers, thereby supporting the integrity and verifiability of token transfers.

The crypto-asset in scope is implemented on the BNB Smart Chain (BSC), Ethereum and Solana networks following the standards described below.

The following applies to BNB Smart Chain (BSC):

BNB Smart Chain (BSC) uses a hybrid consensus mechanism called Proof-of-Staked-Authority (PoSA), which combines elements of Delegated-Proof-of-Stake (DPoS) and Proof-of-Authority (PoA). This method is intended to support fast block times and low fees while maintaining a level of decentralisation and security.

Core components

1. Validators (Cabinet and Candidates): Validators are responsible for producing blocks, validating transactions, and maintaining network security. The validator set consists of up to 45 validators, including 21 “Cabinet” validators and 24 “Candidate” validators, selected based on bonded stake. A subset of validators is selected per epoch to participate in block production.

2. Delegators: Token holders may delegate BNB to validators to support their selection. Delegators share in the rewards generated by validators, providing an economic incentive to participate in staking.

3. Candidates: Validator candidates are nodes that have staked BNB but are not part of the primary validator subset for a given epoch. They may be selected into the active set based on staking rank and can participate in block production with lower probability.

Consensus process

4. Validator selection: Validators are ranked based on the amount of bonded BNB and are updated periodically (approximately every 24 hours). The highest-ranked validators form the active validator set, with Cabinet validators having a higher probability of participating in block production.

5. Block production: Validators take turns producing blocks in a PoA-like manner. For each epoch, a subset of validators is selected to produce and validate blocks sequentially, ensuring high throughput and low latency.

6. Transaction finality: BSC achieves short block times (approximately 0.45 seconds) and fast finality. With Fast Finality enabled, blocks are typically finalised within approximately one second, subject to validator participation.

7. Staking: Validators must stake BNB as collateral and may be subject to slashing in cases of misbehaviour, including double-signing, malicious voting, or prolonged downtime.

8. Delegation and rewards: Validators and delegators are rewarded through transaction fees collected in each block. Validators may share rewards with delegators to attract stake.

9. Transaction fees: BSC does not rely on inflationary block rewards; instead, validators are compensated primarily through transaction fees paid in BNB, aligning incentives with network usage.

The following applies to Ethereum:

Ethereum uses a Proof-of-Stake (PoS) consensus mechanism introduced with The Merge on 2022-09-15, which replaced the previous Proof-of-Work consensus model. The PoS mechanism is implemented through Gasper, combining Casper-FFG for finality with the LMD-GHOST fork-choice rule for chain selection. Validators participate in consensus by staking ETH through the Beacon Chain. Validators are pseudo-randomly selected to propose new blocks, while other validators attest to the validity of proposed blocks. The network operates using 12-second slots grouped into epochs of 32 slots. Under normal network conditions, finality is typically achieved after two epochs, approximately 12.8 minutes, through Casper-FFG. The LMD-GHOST fork-choice rule determines the canonical chain based on the accumulated weight of validator attestations. Validators that engage in certain malicious behaviour, such as equivocation or contradictory attestations, may be subject to slashing penalties, while offline validators may incur inactivity penalties. Subsequent network upgrades, including Dencun (2024-03-13), Pectra (2025-05-07) and Fusaka (2025-12-03), introduced protocol changes affecting Ethereum’s consensus mechanism and Layer 2 functionality.

The following applies to Solana:

Solana uses a combination of Proof-of-History (PoH) and Proof-of-Stake (PoS). The core concepts of the mechanism are intended to work as follows:

Core Concepts

1. Proof-of-History (PoH):

PoH is a cryptographic ordering and timing mechanism that provides evidence that data existed in a particular sequence and that time passed between proofs.

Verifiable Delay Function (VDF): PoH relies on a sequential hash-based proof process that Solana describes as VDF-like. This sequence of hashes provides a verifiable order of events, enabling the network to efficiently agree on the sequence of transactions.

2. Proof-of-Stake (PoS):

Validator Selection: Leader slots are assigned through the network’s leader schedule, which is stake-weighted. The more SOL staked, the higher the chance of being selected to validate transactions and produce new blocks.

Delegation: Token holders can delegate their SOL tokens to validators, earning rewards proportional to their stake while contributing to the network's security.

Consensus Process

1. Transaction Validation:

Transactions are broadcasted to the network and collected by validators. Each transaction is validated to ensure it meets the network’s criteria, such as having correct signatures and sufficient funds.

2. PoH Sequence Generation:

A validator generates a sequence of hashes using PoH, each containing a timestamp and the previous hash. This process creates a historical record of transactions, establishing a cryptographic clock for the network.

3. Block Production:

The network uses PoS to select a leader validator based on their stake. The leader is responsible for bundling the validated transactions into a block. The leader validator uses the PoH sequence to order transactions within the block, ensuring that all transactions are processed in the correct order.

4. Consensus and Finalisation:

Other validators vote on the ledger state associated with the block. A block may first become confirmed and later finalised once it reaches the network’s strongest confirmation state.

Security and Economic Incentives

1. Incentives for Validators:

Block Rewards: Validators earn rewards for producing and validating blocks. These rewards are distributed in SOL tokens and are proportional to the validator’s stake and performance.

Transaction Fees: Validators also earn transaction fees from the transactions included in the blocks they produce. These fees provide an additional incentive for validators to process transactions efficiently.

2. Security:

Staking: Staking provides economic alignment, and Solana documentation notes that slashing has been discussed as a future mechanism for intentional malicious behaviour, but is not implemented yet.

Delegated Staking: Token holders can delegate their SOL tokens to validators, intended to enhance network security and decentralisation. Delegators share in the rewards and are incentivised to choose reliable validators.

3. Economic Penalties:

Slashing (planned): Validators can be penalised for malicious behaviour, such as double-signing or producing invalid blocks. This penalty, known as slashing, results in the loss of a portion of the staked tokens, discouraging dishonest actions.

The crypto-asset in scope is implemented on the BNB Smart Chain (BSC), Ethereum and Solana networks following the standards described below.

The following applies to BNB Smart Chain (BSC):

BNB Smart Chain (BSC) uses the Proof-of-Staked-Authority (PoSA) consensus mechanism to support network security and incentivise participation from validators and delegators.

Incentive mechanisms

1. Validators: Validators must self-delegate BNB in order to participate in the validator system. Validator selection is staking-based, and validators that rank highly enough enter the active set and participate in block production and transaction validation. Validators are rewarded from transaction fees collected on the network. When a block is produced, most of the block fee is allocated to the validator that proposed the block. A portion is retained as validator commission, while the remainder is allocated for distribution through the validator credit structure.

2. Delegators: BNB holders may delegate BNB to validators. This increases the validator’s total stake and may improve its position in the validator ranking. Delegators share in the rewards earned by the validator they support, after deduction of the validator’s commission.

3. Candidates: BSC distinguishes between Cabinet, Candidate and Inactive validators. The current model provides that the top 21 validators form the Cabinet, while the validators ranked from 22 to 45 are Candidates. Candidate validators have a smaller chance of producing blocks, but they remain part of the broader validator structure and support network resilience. Validator roles are updated every 24 hours based on the latest staking information.

4. Economic Security: Validators may be penalised for misconduct or poor performance. Slashable events include double signing, malicious fast-finality voting and unavailability. Depending on the violation, consequences may include removal from the validator set, loss of staking rewards and slashing of part of the validator’s self-delegated BNB. The staking model therefore creates an economic incentive for validators and delegators to support reliable validator performance.

Fees on the Binance Smart Chain

5. Transaction fees: Transaction fees on BSC are paid in BNB and are intended to compensate validators for maintaining the network. BSC is designed as a comparatively low-fee network, and smart-contract transactions and transfers require gas fees in BNB.

6. Validator rewards: BSC does not rely on a separate protocol-level block reward. Instead, staking rewards are derived from transaction fees. Most of the block fee is allocated to the proposing validator, then split between validator commission and delegator-linked reward distribution.

7. System-level fee allocation: Part of transaction-fee revenue is collected through the System Reward Contract and used for designated system purposes, including fast-finality rewards.

8. Smart contract fees: Deploying and interacting with smart contracts on BSC requires payment of gas fees in BNB. These fees depend on the computational resources required and form part of the network’s overall fee and validator-incentive model.

The following applies to Ethereum:

Ethereum’s Proof-of-Stake (PoS) mechanism secures the network through validator incentives and protocol-defined penalties. Validators are required to stake ETH in order to participate in block proposal and attestation activities. A minimum of 32 ETH is required to activate a validator. Following the Pectra upgrade on 2025-05-07, EIP-7251 increased the maximum effective balance per validator from 32 ETH to 2,048 ETH. Validators may receive protocol-defined rewards for proposing blocks, attesting to valid blocks and participating in sync committees. Rewards consist of newly issued ETH and transaction-related fees. Transaction fees on Ethereum follow the mechanism introduced by EIP-1559, under which each transaction includes a base fee that is burned at the protocol level and an optional priority fee paid to the validator proposing the relevant block. Validators that engage in certain malicious behaviour, including equivocation or contradictory attestations, may be subject to slashing penalties. Validators that fail to participate correctly in consensus activities may also incur inactivity penalties. These mechanisms are intended to support validator participation and the economic security of the Ethereum network.

The following applies to Solana:

1. Validators:

Validators participate in block production and voting under Solana’s stake-weighted model. They may receive staking-related rewards and a share of transaction-fee income. Under Solana’s fee model, the base fee is split between burn and validator compensation, while any prioritisation fee is paid to the validator.

Transaction Fees: Validators earn a portion of the transaction fees paid by users for the transactions they include in the blocks. This is intended to provide an additional financial incentive for validators to process transactions efficiently and maintain the network's integrity.

2. Delegators:

Delegated Staking: Token holders who do not wish to run a validator node can delegate their SOL tokens to a validator. In return, delegators share the rewards earned by the validators. This is intended to encourage widespread participation in securing the network and to support decentralisation.

3. Economic Security:

Solana staking documentation notes slashing as a possible future mechanism for intentional malicious conduct, but states that slashing is not implemented in the protocol today. Economic alignment instead currently arises primarily from staking participation, validator performance incentives, and the opportunity cost of locking capital in staking positions.

Fees Applicable on the Solana Blockchain

1. Transaction Fees:

Solana transactions require fees in SOL. The fee model consists of a base fee and, where used, an optional prioritisation fee. The base fee compensates signature verification work and is split between burn and validator compensation, while any prioritisation fee is paid to the validator.

2. Rent Fees:

Solana accounts that store on-chain state must satisfy the rent-exemption threshold, which is linked to the amount of data stored. This mechanism is intended to support efficient use of network state and account storage resources.

3. Program Execution Costs:

Deploying and interacting with on-chain programs may involve transaction fees and, where relevant, compute-related prioritisation fees and account-storage requirements. These mechanisms are intended to allocate network resources in proportion to use.

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 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. Crypto-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.

17. Administrative control risk

The smart contract and the applicable terms permit the issuer to suspend or block access to a holder's tokens. A holder may therefore lose the ability to transfer or dispose of the crypto-asset without any failure of the underlying network. This capability has been exercised.

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.

11. Upgradeability and administrator key risk

The crypto-asset is implemented through an upgradeable proxy contract, which has been upgraded multiple times since deployment. The behaviour of the crypto-asset, including its administrative functions, can therefore be changed without holder consent.

None.

The crypto-asset in scope is implemented on the BNB Smart Chain (BSC), Ethereum and Solana networks following the standards described below.

The following applies to BNB Smart Chain (BSC):

BNB Smart Chain (BSC) uses a hybrid consensus mechanism called Proof-of-Staked-Authority (PoSA), which combines elements of Delegated-Proof-of-Stake (DPoS) and Proof-of-Authority (PoA). This method is intended to support fast block times and low fees while maintaining a level of decentralisation and security.

Core components

1. Validators (Cabinet and Candidates): Validators are responsible for producing blocks, validating transactions, and maintaining network security. The validator set consists of up to 45 validators, including 21 “Cabinet” validators and 24 “Candidate” validators, selected based on bonded stake. A subset of validators is selected per epoch to participate in block production.

2. Delegators: Token holders may delegate BNB to validators to support their selection. Delegators share in the rewards generated by validators, providing an economic incentive to participate in staking.

3. Candidates: Validator candidates are nodes that have staked BNB but are not part of the primary validator subset for a given epoch. They may be selected into the active set based on staking rank and can participate in block production with lower probability.

Consensus process

4. Validator selection: Validators are ranked based on the amount of bonded BNB and are updated periodically (approximately every 24 hours). The highest-ranked validators form the active validator set, with Cabinet validators having a higher probability of participating in block production.

5. Block production: Validators take turns producing blocks in a PoA-like manner. For each epoch, a subset of validators is selected to produce and validate blocks sequentially, ensuring high throughput and low latency.

6. Transaction finality: BSC achieves short block times (approximately 0.45 seconds) and fast finality. With Fast Finality enabled, blocks are typically finalised within approximately one second, subject to validator participation.

7. Staking: Validators must stake BNB as collateral and may be subject to slashing in cases of misbehaviour, including double-signing, malicious voting, or prolonged downtime.

8. Delegation and rewards: Validators and delegators are rewarded through transaction fees collected in each block. Validators may share rewards with delegators to attract stake.

9. Transaction fees: BSC does not rely on inflationary block rewards; instead, validators are compensated primarily through transaction fees paid in BNB, aligning incentives with network usage.

The following applies to Ethereum:

Ethereum uses a Proof-of-Stake (PoS) consensus mechanism introduced with The Merge on 2022-09-15, which replaced the previous Proof-of-Work consensus model. The PoS mechanism is implemented through Gasper, combining Casper-FFG for finality with the LMD-GHOST fork-choice rule for chain selection. Validators participate in consensus by staking ETH through the Beacon Chain. Validators are pseudo-randomly selected to propose new blocks, while other validators attest to the validity of proposed blocks. The network operates using 12-second slots grouped into epochs of 32 slots. Under normal network conditions, finality is typically achieved after two epochs, approximately 12.8 minutes, through Casper-FFG. The LMD-GHOST fork-choice rule determines the canonical chain based on the accumulated weight of validator attestations. Validators that engage in certain malicious behaviour, such as equivocation or contradictory attestations, may be subject to slashing penalties, while offline validators may incur inactivity penalties. Subsequent network upgrades, including Dencun (2024-03-13), Pectra (2025-05-07) and Fusaka (2025-12-03), introduced protocol changes affecting Ethereum’s consensus mechanism and Layer 2 functionality.

The following applies to Solana:

Solana uses a combination of Proof-of-History (PoH) and Proof-of-Stake (PoS). The core concepts of the mechanism are intended to work as follows:

Core Concepts

1. Proof-of-History (PoH):

PoH is a cryptographic ordering and timing mechanism that provides evidence that data existed in a particular sequence and that time passed between proofs.

Verifiable Delay Function (VDF): PoH relies on a sequential hash-based proof process that Solana describes as VDF-like. This sequence of hashes provides a verifiable order of events, enabling the network to efficiently agree on the sequence of transactions.

2. Proof-of-Stake (PoS):

Validator Selection: Leader slots are assigned through the network’s leader schedule, which is stake-weighted. The more SOL staked, the higher the chance of being selected to validate transactions and produce new blocks.

Delegation: Token holders can delegate their SOL tokens to validators, earning rewards proportional to their stake while contributing to the network's security.

Consensus Process

1. Transaction Validation:

Transactions are broadcasted to the network and collected by validators. Each transaction is validated to ensure it meets the network’s criteria, such as having correct signatures and sufficient funds.

2. PoH Sequence Generation:

A validator generates a sequence of hashes using PoH, each containing a timestamp and the previous hash. This process creates a historical record of transactions, establishing a cryptographic clock for the network.

3. Block Production:

The network uses PoS to select a leader validator based on their stake. The leader is responsible for bundling the validated transactions into a block. The leader validator uses the PoH sequence to order transactions within the block, ensuring that all transactions are processed in the correct order.

4. Consensus and Finalisation:

Other validators vote on the ledger state associated with the block. A block may first become confirmed and later finalised once it reaches the network’s strongest confirmation state.

Security and Economic Incentives

1. Incentives for Validators:

Block Rewards: Validators earn rewards for producing and validating blocks. These rewards are distributed in SOL tokens and are proportional to the validator’s stake and performance.

Transaction Fees: Validators also earn transaction fees from the transactions included in the blocks they produce. These fees provide an additional incentive for validators to process transactions efficiently.

2. Security:

Staking: Staking provides economic alignment, and Solana documentation notes that slashing has been discussed as a future mechanism for intentional malicious behaviour, but is not implemented yet.

Delegated Staking: Token holders can delegate their SOL tokens to validators, intended to enhance network security and decentralisation. Delegators share in the rewards and are incentivised to choose reliable validators.

3. Economic Penalties:

Slashing (planned): Validators can be penalised for malicious behaviour, such as double-signing or producing invalid blocks. This penalty, known as slashing, results in the loss of a portion of the staked tokens, discouraging dishonest actions.

The crypto-asset in scope is implemented on the BNB Smart Chain (BSC), Ethereum and Solana networks following the standards described below.

The following applies to BNB Smart Chain (BSC):

Binance Smart Chain (BSC) uses the Proof-of-Staked-Authority (PoSA) consensus mechanism to support network security and incentivise participation from validators and delegators.

Incentive mechanisms

1. Validators: Validators must self-delegate BNB in order to participate in the validator system. Validator selection is staking-based, and validators that rank highly enough enter the active set and participate in block production and transaction validation. Validators are rewarded from transaction fees collected on the network. When a block is produced, most of the block fee is allocated to the validator that proposed the block. A portion is retained as validator commission, while the remainder is allocated for distribution through the validator credit structure.

2. Delegators: BNB holders may delegate BNB to validators. This increases the validator’s total stake and may improve its position in the validator ranking. Delegators share in the rewards earned by the validator they support, after deduction of the validator’s commission.

3. Candidates: BSC distinguishes between Cabinet, Candidate and Inactive validators. The current model provides that the top 21 validators form the Cabinet, while the validators ranked from 22 to 45 are Candidates. Candidate validators have a smaller chance of producing blocks, but they remain part of the broader validator structure and support network resilience. Validator roles are updated every 24 hours based on the latest staking information.

4. Economic Security: Validators may be penalised for misconduct or poor performance. Slashable events include double signing, malicious fast-finality voting and unavailability. Depending on the violation, consequences may include removal from the validator set, loss of staking rewards and slashing of part of the validator’s self-delegated BNB. The staking model therefore creates an economic incentive for validators and delegators to support reliable validator performance.

Fees on the Binance Smart Chain

5. Transaction fees: Transaction fees on BSC are paid in BNB and are intended to compensate validators for maintaining the network. BSC is designed as a comparatively low-fee network, and smart-contract transactions and transfers require gas fees in BNB.

6. Validator rewards: BSC does not rely on a separate protocol-level block reward. Instead, staking rewards are derived from transaction fees. Most of the block fee is allocated to the proposing validator, then split between validator commission and delegator-linked reward distribution.

7. System-level fee allocation: Part of transaction-fee revenue is collected through the System Reward Contract and used for designated system purposes, including fast-finality rewards.

8. Smart contract fees: Deploying and interacting with smart contracts on BSC requires payment of gas fees in BNB. These fees depend on the computational resources required and form part of the network’s overall fee and validator-incentive model.

The following applies to Ethereum:

Ethereum’s Proof-of-Stake (PoS) mechanism secures the network through validator incentives and protocol-defined penalties. Validators are required to stake ETH in order to participate in block proposal and attestation activities. A minimum of 32 ETH is required to activate a validator. Following the Pectra upgrade on 2025-05-07, EIP-7251 increased the maximum effective balance per validator from 32 ETH to 2,048 ETH. Validators may receive protocol-defined rewards for proposing blocks, attesting to valid blocks and participating in sync committees. Rewards consist of newly issued ETH and transaction-related fees. Transaction fees on Ethereum follow the mechanism introduced by EIP-1559, under which each transaction includes a base fee that is burned at the protocol level and an optional priority fee paid to the validator proposing the relevant block. Validators that engage in certain malicious behaviour, including equivocation or contradictory attestations, may be subject to slashing penalties. Validators that fail to participate correctly in consensus activities may also incur inactivity penalties. These mechanisms are intended to support validator participation and the economic security of the Ethereum network.

The following applies to Solana:

1. Validators:

Validators participate in block production and voting under Solana’s stake-weighted model. They may receive staking-related rewards and a share of transaction-fee income. Under Solana’s fee model, the base fee is split between burn and validator compensation, while any prioritisation fee is paid to the validator.

Transaction Fees: Validators earn a portion of the transaction fees paid by users for the transactions they include in the blocks. This is intended to provide an additional financial incentive for validators to process transactions efficiently and maintain the network's integrity.

2. Delegators:

Delegated Staking: Token holders who do not wish to run a validator node can delegate their SOL tokens to a validator. In return, delegators share the rewards earned by the validators. This is intended to encourage widespread participation in securing the network and to support decentralisation.

3. Economic Security:

Solana staking documentation notes slashing as a possible future mechanism for intentional malicious conduct, but states that slashing is not implemented in the protocol today. Economic alignment instead currently arises primarily from staking participation, validator performance incentives, and the opportunity cost of locking capital in staking positions.

Fees Applicable on the Solana Blockchain

1. Transaction Fees:

Solana transactions require fees in SOL. The fee model consists of a base fee and, where used, an optional prioritisation fee. The base fee compensates signature verification work and is split between burn and validator compensation, while any prioritisation fee is paid to the validator.

2. Rent Fees:

Solana accounts that store on-chain state must satisfy the rent-exemption threshold, which is linked to the amount of data stored. This mechanism is intended to support efficient use of network state and account storage resources.

3. Program Execution Costs:

Deploying and interacting with on-chain programs may involve transaction fees and, where relevant, compute-related prioritisation fees and account-storage requirements. These mechanisms are intended to allocate network resources in proportion to use.

The energy consumption of this asset is aggregated across multiple components. To determine the energy consumption of the token, the energy consumption of the Ethereum, Solana, and BNB Smart Chain (BSC) networks is calculated first. A fraction of the energy consumption of each network is then attributed to the token based on the activity of the crypto-asset within the respective network. When calculating the energy consumption, the Functionally Fungible Group Digital Token Identifier (FFG DTI) is used, if available, to determine all implementations of the asset in scope. The mappings are updated regularly based on data from the Digital Token Identifier Foundation. The information regarding the hardware used and the number of participants in the networks is based on assumptions that are verified on a best-effort basis using empirical data. In general, participants are assumed to act in a largely economically rational manner. In line with the precautionary principle, conservative assumptions are applied where uncertainty exists, i.e. estimates tend towards the higher end of potential adverse impacts.

To determine the proportion of renewable energy usage, the locations of the nodes are determined using public information sites, open-source and in-house-developed crawlers. Where no information is available on the geographic distribution of nodes, comparable reference networks are used, taking into account similarities in incentivisation structure and consensus mechanism. This geographic information is then combined with publicly available data from Our World in Data. The resulting intensity is calculated as the marginal energy consumption with respect to one additional 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]. Underlying sources: Ember, “Yearly Electricity Data Europe”; Ember, “Yearly Electricity Data”; Energy Institute, “Statistical Review of World Energy”. Retrieved from: https://ourworldindata.org/grapher/share-electricity-renewables

To determine GHG emissions, the locations of the nodes are determined using public information sites, open-source crawlers, and crawlers developed in-house. Where no information is available on the geographic distribution of nodes, comparable reference networks are used, taking into account similarities in incentivisation structure and consensus mechanism. This geographic information is then combined with publicly available data from Our World in Data. The resulting intensity is calculated as the marginal emission intensity with respect to one additional 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]. Underlying sources: Ember, “Yearly Electricity Data Europe”; Ember, “Yearly Electricity Data”; Energy Institute, “Statistical Review of World Energy”. Retrieved from: https://ourworldindata.org/grapher/carbon-intensity-electricity. Licensed under CC BY 4.0.