White paper drafted under the European Markets in Crypto-Assets Regulation (EU) 2023/1114 for FFG QH1GF1J5H
Preamble
00. Table of Contents
- Preamble
- 01. Date of notification
- 02. Statement in accordance with Article 6(3) of Regulation (EU) 2023/1114
- 03. Compliance statement in accordance with Article 6(6) of Regulation (EU) 2023/1114
- 04. Statement in accordance with Article 6(5), points (a), (b), (c), of Regulation (EU) 2023/1114
- 05. Statement in accordance with Article 6(5), point (d), of Regulation (EU) 2023/1114
- 06. Statement in accordance with Article 6(5), points (e) and (f), of Regulation (EU) 2023/1114
- Summary
- 07. Warning in accordance with Article 6(7), second subparagraph, of Regulation (EU) 2023/1114
- 08. Characteristics of the crypto-asset
- 09. Information about the quality and quantity of goods or services to which the utility tokens give access and restrictions on the transferability
- 10. Key information about the offer to the public or admission to trading
- Part A – Information about the offeror or the person seeking admission to trading
- A.1 Name
- A.2 Legal form
- A.3 Registered address
- A.4 Head office
- A.5 Registration date
- A.6 Legal entity identifier
- A.7 Another identifier required pursuant to applicable national law
- A.8 Contact telephone number
- A.9 E-mail address
- A.10 Response time (Days)
- A.11 Parent company
- A.12 Members of the management body
- A.13 Business activity
- A.14 Parent company business activity
- A.15 Newly established
- A.16 Financial condition for the past three years
- A.17 Financial condition since registration
- Part B – Information about the issuer, if different from the offeror or person seeking admission to trading
- B.1 Issuer different from offeror or person seeking admission to trading
- B.2 Name
- B.3 Legal form
- B.4 Registered address
- B.5 Head office
- B.6 Registration date
- B.7 Legal entity identifier
- B.8 Another identifier required pursuant to applicable national law
- B.9 Parent company
- B.10 Members of the management body
- B.11 Business activity
- B.12 Parent company business activity
- Part C – Information about the operator of the trading platform in cases where it draws up the crypto-asset white paper and information about other persons drawing the crypto-asset white paper pursuant to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114
- C.1 Name
- C.2 Legal form
- C.3 Registered address
- C.4 Head office
- C.5 Registration date
- C.6 Legal entity identifier
- C.7 Another identifier required pursuant to applicable national law
- C.8 Parent company
- C.9 Reason for crypto-asset white paper preparation
- C.10 Members of the management body
- C.11 Operator business activity
- C.12 Parent company business activity
- C.13 Other persons drawing up the crypto-asset white paper according to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114
- C.14 Reason for drawing the white paper by persons referred to in Article 6(1), second subparagraph, of Regulation (EU) 2023/1114
- Part D – Information about the crypto-asset project
- D.1 Crypto-asset project name
- D.2 Crypto-assets name
- D.3 Abbreviation
- D.4 Crypto-asset project description
- D.5 Details of all natural or legal persons involved in the implementation of the crypto-asset project
- D.6 Utility Token Classification
- D.7 Key Features of Goods/Services for Utility Token Projects
- D.8 Plans for the token
- D.9 Resource allocation
- D.10 Planned use of collected funds or crypto-assets
- Part E – Information about the offer to the public of crypto-assets or their admission to trading
- E.1 Public offering or admission to trading
- E.2 Reasons for public offer or admission to trading
- E.3 Fundraising target
- E.4 Minimum subscription goals
- E.5 Maximum subscription goals
- E.6 Oversubscription acceptance
- E.7 Oversubscription allocation
- E.8 Issue price
- E.9 Official currency or any other crypto-assets determining the issue price
- E.10 Subscription fee
- E.11 Offer price determination method
- E.12 Total number of offered/traded crypto-assets
- E.13 Targeted holders
- E.14 Holder restrictions
- E.15 Reimbursement notice
- E.16 Refund mechanism
- E.17 Refund timeline
- E.18 Offer phases
- E.19 Early purchase discount
- E.20 Time-limited offer
- E.21 Subscription period beginning
- E.22 Subscription period end
- E.23 Safeguarding arrangements for offered funds/crypto-assets
- E.24 Payment methods for crypto-asset purchase
- E.25 Value transfer methods for reimbursement
- E.26 Right of withdrawal
- E.27 Transfer of purchased crypto-assets
- E.28 Transfer time schedule
- E.29 Purchaser's technical requirements
- E.30 Crypto-asset service provider (CASP) name
- E.31 CASP identifier
- E.32 Placement form
- E.33 Trading platforms name
- E.34 Trading platforms Market identifier code (MIC)
- E.35 Trading platforms access
- E.36 Involved costs
- E.37 Offer expenses
- E.38 Conflicts of interest
- E.39 Applicable law
- E.40 Competent court
- Part F – Information about the crypto-assets
- F.1 Crypto-asset type
- F.2 Crypto-asset functionality
- F.3 Planned application of functionalities
- A description of the characteristics of the crypto asset, including the data necessary for classification of the crypto-asset white paper in the register referred to in Article 109 of Regulation (EU) 2023/1114, as specified in accordance with paragraph 8 of that Article
- F.4 Type of crypto-asset white paper
- F.5 The type of submission
- F.6 Crypto-asset characteristics
- F.7 Commercial name or trading name
- F.8 Website of the issuer
- F.9 Starting date of offer to the public or admission to trading
- F.10 Publication date
- F.11 Any other services provided by the issuer
- F.12 Language or languages of the crypto-asset white paper
- F.13 Digital token identifier code used to uniquely identify the crypto-asset or each of the several crypto assets to which the white paper relates
- F.14 Functionally fungible group digital token identifier
- F.15 Voluntary data flag
- F.16 Personal data flag
- F.17 LEI eligibility
- F.18 Home Member State
- F.19 Host Member States
- Part G – Information on the rights and obligations attached to the crypto-assets
- G.1 Purchaser rights and obligations
- G.2 Exercise of rights and obligations
- G.3 Conditions for modifications of rights and obligations
- G.4 Future public offers
- G.5 Issuer retained crypto-assets
- G.6 Utility token classification
- G.7 Key features of goods/services of utility tokens
- G.8 Utility tokens redemption
- G.9 Non-trading request
- G.10 Crypto-assets purchase or sale modalities
- G.11 Crypto-assets transfer restrictions
- G.12 Supply adjustment protocols
- G.13 Supply adjustment mechanisms
- G.14 Token value protection schemes
- G.15 Token value protection schemes description
- G.16 Compensation schemes
- G.17 Compensation schemes description
- G.18 Applicable law
- G.19 Competent court
- Part H – information on the underlying technology
- H.1 Distributed ledger technology (DLT)
- H.2 Protocols and technical standards
- H.3 Technology used
- H.4 Consensus mechanism
- H.5 Incentive mechanisms and applicable fees
- H.6 Use of distributed ledger technology
- H.7 DLT functionality description
- H.8 Audit
- H.9 Audit outcome
- Part I – Information on risks
- I.1 Offer-related risks
- I.2 Issuer-related risks
- I.3 Crypto-assets-related risks
- I.4 Project implementation-related risks
- I.5 Technology-related risks
- I.6 Mitigation measures
- Part J – Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts
- J.1 Adverse impacts on climate and other environment-related adverse impacts
- S.1 Name
- S.2 Relevant legal entity identifier
- S.3 Name of the crypto-asset
- S.4 Consensus Mechanism
- S.5 Incentive Mechanisms and Applicable Fees
- S.6 Beginning of the period to which the disclosure relates
- S.7 End of the period to which the disclosure relates
- S.8 Energy consumption
- S.9 Energy consumption sources and methodologies
- S.10 Renewable energy consumption
- S.11 Energy intensity
- S.12 Scope 1 DLT GHG emissions – Controlled
- S.13 Scope 2 DLT GHG emissions – Purchased
- S.14 GHG intensity
- S.15 Key energy sources and methodologies
- S.16 Key GHG sources and methodologies
01. Date of notification
02. Statement in accordance with Article 6(3) of Regulation (EU) 2023/1114
03. Compliance statement in accordance with Article 6(6) of Regulation (EU) 2023/1114
04. Statement in accordance with Article 6(5), points (a), (b), (c), of Regulation (EU) 2023/1114
05. Statement in accordance with Article 6(5), point (d), of Regulation (EU) 2023/1114
06. Statement in accordance with Article 6(5), points (e) and (f), of Regulation (EU) 2023/1114
Summary
07. Warning in accordance with Article 6(7), second subparagraph, of Regulation (EU) 2023/1114
08. Characteristics of the crypto-asset
The crypto-asset Mantle (MNT) referred to in this white paper is a crypto-asset other than EMTs and ARTs and is implemented on the Ethereum network as a token under the ERC-20 token standard, according to the DTI FFG shown in section F.14, as of 2026-09-16. It is also the native asset of Mantle Network. The supply is not fixed by the protocol. Further units can be created only by a decision taken through the governance process. The first activity of the crypto-asset can be viewed on 2023-06-20, when the token contract was created on Ethereum (transaction hash: 0x8f7867724cfba4b9b1b19ca140711809b40dda9ae245caf7bcff9473a5a7e45e, source: https://etherscan.io/tx/0x8f7867724cfba4b9b1b19ca140711809b40dda9ae245caf7bcff9473a5a7e45e, accessed 2026-09-16), and on 2023-07-02 on the Mantle network (source: https://mantlescan.xyz/tx/0x406af377ea93d459721d73c9c7409a6c5d7af45ac744b8390478308500e12981, accessed 2026-09-16).
Mantle is a layer 2 network operated on top of Ethereum, on which decentralised applications are run. Transactions are processed on the Mantle network and settled on Ethereum, with the aim of lower transaction costs and higher throughput than processing them on Ethereum directly. The network is compatible with the Ethereum Virtual Machine, so applications written for Ethereum can be operated on it without modification. Development of the network and the deployment of its treasury are directed through a token-based governance process that descends from the earlier BitDAO structure, in which holders of the crypto-asset submit and vote on proposals.
The crypto-asset is used to pay transaction fees on the Mantle network, carries an equal vote weight per unit in that governance process and may be used as a collateral asset for network nodes (source: https://docs.mantle.xyz/governance/parameters/tokenomics, accessed 2026-09-16). Holding the crypto-asset does not confer an ownership interest, a participation in profits or a claim to redemption against any person.
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.
09. Information about the quality and quantity of goods or services to which the utility tokens give access and restrictions on the transferability
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.
10. Key information about the offer to the public or admission to trading
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.
Part A – Information about the offeror or the person seeking admission to trading
A.1 Name
A.2 Legal form
A.3 Registered address
A.4 Head office
A.5 Registration date
A.6 Legal entity identifier
A.7 Another identifier required pursuant to applicable national law
A.8 Contact telephone number
A.9 E-mail address
A.10 Response time (Days)
A.11 Parent company
A.12 Members of the management body
| Identity | Function | Business Address |
|---|---|---|
A.13 Business activity
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.
A.14 Parent company business activity
A.15 Newly established
A.16 Financial condition for the past three years
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.
A.17 Financial condition since registration
Part B – Information about the issuer, if different from the offeror or person seeking admission to trading
B.1 Issuer different from offeror or person seeking admission to trading
B.2 Name
B.3 Legal form
B.4 Registered address
B.5 Head office
B.6 Registration date
B.7 Legal entity identifier
B.8 Another identifier required pursuant to applicable national law
B.9 Parent company
B.10 Members of the management body
| Identity | Function | Business Address |
|---|---|---|
B.11 Business activity
Not applicable.
B.12 Parent company business activity
Not applicable.
Part C – Information about the operator of the trading platform in cases where it draws up the crypto-asset white paper and information about other persons drawing the crypto-asset white paper pursuant to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114
C.1 Name
C.2 Legal form
C.3 Registered address
C.4 Head office
C.5 Registration date
C.6 Legal entity identifier
C.7 Another identifier required pursuant to applicable national law
C.8 Parent company
C.9 Reason for crypto-asset white paper preparation
C.10 Members of the management body
C.11 Operator business activity
C.12 Parent company business activity
C.13 Other persons drawing up the crypto-asset white paper according to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114
C.14 Reason for drawing the white paper by persons referred to in Article 6(1), second subparagraph, of Regulation (EU) 2023/1114
Part D – Information about the crypto-asset project
D.1 Crypto-asset project name
D.2 Crypto-assets name
D.3 Abbreviation
D.4 Crypto-asset project description
According to publicly available information (sources: https://www.mantle.xyz/, https://docs.mantle.xyz/governance and https://group.mantle.xyz/treasury, accessed 2026-09-16), Mantle is a crypto-asset project whose stated objective is to provide infrastructure for financial services settled on a public blockchain. It distinguishes between Mantle, the ecosystem as a whole, and Mantle Network, the blockchain on which that ecosystem operates.
Mantle Network is a layer 2 network settling on Ethereum. It is compatible with the Ethereum Virtual Machine, so applications written for Ethereum can be operated on it without modification, and the validity of the transactions it processes is established by cryptographic proofs submitted to Ethereum rather than by a challenge period. The project also operates further products within the ecosystem, which are separate from the network and are not the subject of this white paper.
The project originated in 2022 within BitDAO, a decentralised autonomous organisation. In May 2023 its community approved the consolidation of the two names, BitDAO governance became Mantle governance, and the BIT crypto-asset was converted into the crypto-asset that is the subject of this white paper at a ratio of one to one, with the treasury carried across. Development of the network and the deployment of that treasury are directed through a governance process in which holders who have delegated their units vote on proposals. A vote does not execute automatically; it is implemented by contributors working on the project, and treasury expenditure is authorised in budget cycles.
The crypto-asset does not represent a share in, a claim against, or an entitlement to the assets of any person or structure connected to the project, including the treasury. 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.
D.5 Details of all natural or legal persons involved in the implementation of the crypto-asset project
| Name of person | Type of person | Business address of person | Domicile of company |
|---|---|---|---|
D.6 Utility Token Classification
D.7 Key Features of Goods/Services for Utility Token Projects
D.8 Plans for the token
This section provides an overview of the historical developments related to the MNT 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 project publishes a roadmap in its technical documentation and communicates developments through its governance forum and its own announcements (sources: https://docs.mantle.xyz/network/system-information/roadmap, https://forum.mantle.xyz and https://group.mantle.xyz/blog, accessed 2026-09-15).
Past milestones:
- Project proposed (2022): a layer 2 network settling on Ethereum was proposed within the BitDAO community, approved by vote, and introduced under the Mantle name in November 2022.
- Public test network (January 2023): released for developers to test the design and its compatibility with applications written for Ethereum.
- Consolidation approved (May 2023): the BitDAO community approved the consolidation of the two names under Mantle, BitDAO governance became Mantle governance, and the BIT crypto-asset was to be converted into the crypto-asset at a ratio of one to one.
- Crypto-asset created (2023-06-20): the token contract was created on the Ethereum network with a genesis issuance of 10,000,000,000 units, reduced before launch under governance proposal MIP-23.
- Mainnet launch (July 2023): the network entered operation, with the first activity recorded on 2023-07-02.
- Liquid staking protocol launched (January 2024): a protocol for staking ether, renamed mETH in August 2024.
- Tectonic upgrade (March 2024): a network upgrade introducing support for the Ethereum fee-market transaction type, among other changes.
- Bitcoin yield platform launched (2024): the Function platform and its FBTC asset, making bitcoin usable in on-chain applications.
- Index fund launched (April 2025): the Mantle Index Four fund, offering exposure to a basket of crypto-assets, with the treasury as anchor investor.
- Payment application launched (June 2025): UR, offering accounts and a payment card through a regulated financial institution, settling on the network.
- Advisers appointed (August 2025): two executives of a crypto-asset trading platform were appointed as advisers to the network.
- Skadi upgrade (August 2025): a network upgrade adding support for the then-current Ethereum protocol version and introducing an interface for faster generation of cryptographic proofs.
- Arsia upgrade (first half of 2026): the fee model was restructured into separate execution, data and operator components, and the publication of transaction data was migrated from a third-party service to the Ethereum network's own data transactions.
Future milestones:
- Completion of the work begun in the first half of 2026: validation of a new execution client, delivery of the cryptographic proof module adapted to the Arsia upgrade, a distributed network for generating those proofs at lower cost, and the second version of the bridge between the two networks.
- Migration of the network's sequencing and access services to that new execution client, with the existing client retained as a fallback.
- Alignment of the network's software with the next Ethereum protocol upgrade.
- Protocol-level support for account abstraction, and a mechanism intended to allow a single account to submit transactions concurrently.
- A privacy mechanism based on cryptographic proofs, and a proof of concept for it in the settlement of tokenised securities.
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 MNT crypto-asset for its holders.
D.9 Resource allocation
According to publicly available information (sources: https://docs.mantle.xyz/governance/parameters/tokenomics and https://forum.mantle.xyz/t/passed-mip-33-mantle-core-budget-for-third-budget-cycle/9312, accessed 2026-09-17), the crypto-asset was not offered for sale and no funds were raised through its issuance. It came into existence through the conversion of a predecessor crypto-asset at a ratio of one to one, approved through the governance process, and the resources available to the project are those of the treasury that passed across at that conversion. No public offering, seed round or venture funding has been identified in relation to the crypto-asset itself.
At the initial distribution recorded on 2023-07-07, the total supply was 6,219,316,768 units, of which 3,046,328,614 units, 49.0 per cent, were held in the treasury and 3,172,988,154 units, 51.0 per cent, were in circulation. No vesting or lock-up arrangement applied. The project treats units held in the treasury as not in circulation, and they are released only where a proposal authorising their use is approved through the governance process.
Expenditure is authorised in annual budget cycles. The budget approved for the period from July 2025 to June 2026 permits spending of up to 200,000,000 units of the crypto-asset and 52,000,000 units of dollar-denominated crypto-assets across five categories: ecosystem and builder programmes, up to 120,000,000 units of the crypto-asset; workforce, up to 50,000,000 units; marketing, up to 20,000,000 units; infrastructure and security, up to 10,000,000 units; and general and administrative expenditure, which is authorised in dollar-denominated crypto-assets only. These are limits rather than commitments, and reported spending in the preceding cycle was materially below them.
The token distribution can be traced on-chain on Ethereum: https://etherscan.io/token/0x3c3a81e81dc49a522a592e7622a7e711c06bf354#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 natural persons, legal persons, undertakings, organised development teams, governance arrangements or other structures connected to the Mantle crypto-asset project have not independently confirmed the occurrence, precise amounts or current status of these reported allocations and fundraising figures. 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.
D.10 Planned use of collected funds or crypto-assets
Part E – Information about the offer to the public of crypto-assets or their admission to trading
E.1 Public offering or admission to trading
E.2 Reasons for public offer or admission to trading
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.
E.3 Fundraising target
E.4 Minimum subscription goals
E.5 Maximum subscription goals
E.6 Oversubscription acceptance
E.7 Oversubscription allocation
E.8 Issue price
E.9 Official currency or any other crypto-assets determining the issue price
E.10 Subscription fee
E.11 Offer price determination method
E.12 Total number of offered/traded crypto-assets
E.13 Targeted holders
E.14 Holder restrictions
E.15 Reimbursement notice
E.16 Refund mechanism
E.17 Refund timeline
E.18 Offer phases
E.19 Early purchase discount
E.20 Time-limited offer
E.21 Subscription period beginning
E.22 Subscription period end
E.23 Safeguarding arrangements for offered funds/crypto-assets
E.24 Payment methods for crypto-asset purchase
E.25 Value transfer methods for reimbursement
E.26 Right of withdrawal
E.27 Transfer of purchased crypto-assets
E.28 Transfer time schedule
E.29 Purchaser's technical requirements
E.30 Crypto-asset service provider (CASP) name
E.31 CASP identifier
E.32 Placement form
E.33 Trading platforms name
E.34 Trading platforms Market identifier code (MIC)
E.35 Trading platforms access
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.
E.36 Involved costs
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.
E.37 Offer expenses
Not applicable, as this white paper is written to seek admission to trading, not for the initial offer to the public.
E.38 Conflicts of interest
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.
E.39 Applicable law
Not applicable, as this white paper is written to seek admission to trading, not for the initial offer to the public.
E.40 Competent court
Not applicable, as this white paper is written to seek admission to trading, not for the initial offer to the public.
Part F – Information about the crypto-assets
F.1 Crypto-asset type
F.2 Crypto-asset functionality
The crypto-asset has been transferable since June 2023 and has three functions at protocol level: the payment of transaction fees on the Mantle network, participation in the governance process for that network, and use as a collateral asset for network nodes (sources: https://docs.mantle.xyz/governance/parameters/tokenomics and https://docs.mantle.xyz/governance, accessed 2026-09-16). Transaction fees on the Mantle network are payable in the crypto-asset, in an amount that varies with the transaction and with demand on the network.
Each unit of the crypto-asset carries an equal vote weight in the governance process. A holder must first delegate the units held, which neither transfers them nor locks them, and may then vote on proposals concerning changes to the protocol, allocations from the treasury and other matters put to the holders. A proposal requires 200,000 units to be submitted and 100,000,000 units voting to reach quorum, with a minimum of seven days for discussion and a minimum of seven days for voting. The process is conducted primarily off the blockchain, votes are recorded on a third-party voting service, and the outcome of a vote does not execute automatically: changes to the protocol and movements of treasury assets are implemented separately by contributors working on the project. These are technical and organisational possibilities and do not constitute enforceable rights.
The crypto-asset may also be allocated through the governance process to incentive and liquidity programmes, and holders have in the past received distributions of other crypto-assets held by the treasury under such programmes. Each such programme requires its own governance approval, the assets distributed are not the crypto-asset that is the subject of this white paper, and no programme, rate or distribution is assured or recurring. Holding the crypto-asset confers no entitlement to any distribution, to any yield, or to any share of the fees or revenues of the network or of the other products operated within the ecosystem, and the crypto-assets issued by those other products are separate crypto-assets which are not the subject of this white paper.
The Mantle 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 Mantle protocol environment. The actual usability of the crypto-asset depends on factors such as system stability, governance decisions, development progress and the operational conditions of the Mantle blockchain, which are outside the control of token holders.
F.3 Planned application of functionalities
Future milestones:
- Completion of the work begun in the first half of 2026: validation of a new execution client, delivery of the cryptographic proof module adapted to the Arsia upgrade, a distributed network for generating those proofs at lower cost, and the second version of the bridge between the two networks.
- Migration of the network's sequencing and access services to that new execution client, with the existing client retained as a fallback.
- Alignment of the network's software with the next Ethereum protocol upgrade.
- Protocol-level support for account abstraction, and a mechanism intended to allow a single account to submit transactions concurrently.
- A privacy mechanism based on cryptographic proofs, and a proof of concept for it in the settlement of tokenised securities.
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 MNT crypto-asset for its holders.
A description of the characteristics of the crypto asset, including the data necessary for classification of the crypto-asset white paper in the register referred to in Article 109 of Regulation (EU) 2023/1114, as specified in accordance with paragraph 8 of that Article
F.4 Type of crypto-asset white paper
F.5 The type of submission
F.6 Crypto-asset characteristics
The crypto-asset referred to herein is a crypto-asset other than EMTs and ARTs, and is available on the Mantle and Ethereum networks. The crypto-asset is fungible up to 18 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.
F.7 Commercial name or trading name
F.8 Website of the issuer
F.9 Starting date of offer to the public or admission to trading
F.10 Publication date
F.11 Any other services provided by the issuer
Based on the available information, the crypto-asset does not appear to be issued through a traditional corporate, foundation, or comparable legal entity structure. Therefore, no other services provided by a registered legal-entity issuer have been identified.
It cannot be excluded that natural persons, organised development teams, or other structures connected to the crypto-asset project provide or may provide additional services outside the scope of Regulation (EU) 2023/1114.
F.12 Language or languages of the crypto-asset white paper
F.13 Digital token identifier code used to uniquely identify the crypto-asset or each of the several crypto assets to which the white paper relates
F.14 Functionally fungible group digital token identifier
F.15 Voluntary data flag
F.16 Personal data flag
F.17 LEI eligibility
F.18 Home Member State
F.19 Host Member States
Part G – Information on the rights and obligations attached to the crypto-assets
G.1 Purchaser rights and obligations
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.
G.2 Exercise of rights and obligations
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.
G.3 Conditions for modifications of rights and obligations
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.
G.4 Future public offers
Information on future offers to the public of crypto-assets was not available at the time of writing this white paper (2026-09-16).
G.5 Issuer retained crypto-assets
G.6 Utility token classification
G.7 Key features of goods/services of utility tokens
G.8 Utility tokens redemption
G.9 Non-trading request
G.10 Crypto-assets purchase or sale modalities
G.11 Crypto-assets transfer restrictions
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.
G.12 Supply adjustment protocols
G.13 Supply adjustment mechanisms
Not applicable.
G.14 Token value protection schemes
G.15 Token value protection schemes description
G.16 Compensation schemes
G.17 Compensation schemes description
G.18 Applicable law
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.
G.19 Competent court
Any disputes arising in relation to this white paper or the admission to trading may be brought before the competent courts in Hamburg, Germany.
Part H – information on the underlying technology
H.1 Distributed ledger technology (DLT)
The crypto-asset in scope is implemented on the Mantle and Ethereum networks following the standards described below.
H.2 Protocols and technical standards
The crypto asset that is the subject of this white paper is available on multiple DLT networks. These include: Ethereum and Mantle.
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 Mantle:
Mantle is a layer 2 network that settles on Ethereum and is built on a widely used open-source rollup framework. It is compatible with the Ethereum Virtual Machine, so contracts, addresses, signature schemes and developer tooling built for Ethereum can be used on the network without modification, and token standards such as ERC-20 apply in the same way.
Transaction data is compressed and published to Ethereum in blob-carrying transactions under the data availability standard introduced for that purpose, and the commitments recorded on Ethereum are the canonical reference for that data. The correctness of the network's state transitions is established by zero-knowledge validity proofs, which are submitted to and verified by a contract deployed on Ethereum. Transactions follow the Ethereum transaction types, including the fee-market type in which a base fee is combined with an optional priority fee.
H.3 Technology used
The crypto asset that is the subject of this white paper is available on multiple DLT networks. These include: Ethereum and Mantle.
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 Mantle:
Mantle uses a modular design in which the three principal functions of the network are separated: execution, where transactions are run and the state is updated; data availability, where the data needed to reconstruct that state is published; and settlement, where the result is recorded on Ethereum. Separating them allows each to be changed independently, and the network has changed its data availability and proving arrangements more than once since it launched.
Execution is performed by a client derived from the standard Ethereum execution client. Transactions submitted to the network are ordered into blocks by a sequencer. A batching component periodically aggregates those blocks, compresses the data and publishes it to Ethereum. A proposing component generates validity proofs over the resulting state transitions and submits them, with the corresponding state root, to a contract on Ethereum, where they are verified.
The sequencing, proposing, batching and data availability roles are operated by the project and are not open to third parties. Verifier nodes, which independently re-derive the state from the published data and compare it with what has been submitted, can be run by anyone.
H.4 Consensus mechanism
The crypto asset that is the subject of this white paper is available on multiple DLT networks. These include: Ethereum and Mantle.
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 Mantle:
Mantle does not operate a consensus mechanism of its own. The order of transactions is determined by the network's sequencer rather than by agreement among a set of validators. The network derives its security from Ethereum: the transaction data is published there, the validity proofs over the resulting state are verified by a contract there, and a state becomes final when the Ethereum transaction recording it is itself final under Ethereum's consensus mechanism.
H.5 Incentive mechanisms and applicable fees
The crypto asset that is the subject of this white paper is available on multiple DLT networks. These include: Ethereum and Mantle.
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 Mantle:
Transactions on the Mantle network are paid for in MNT, the network's own asset. The fee for a transaction is made up of the cost of executing it on the network, a share of the cost of publishing the associated data to Ethereum, and a component paid to the operators of the network's infrastructure. These fees are what compensate the parties that order transactions, publish the data and submit the proofs. The way each component is calculated is set at protocol level and is published by the project, and the rates are subject to change.
Assets are moved between Ethereum and the Mantle network through contracts deployed on each. Assets sent to the network are held by a contract on Ethereum and a corresponding balance is made available on the network. A withdrawal is initiated on the Mantle network and completed by a separate claim on Ethereum, which can be made once the state recording the withdrawal has been established on Ethereum.
H.6 Use of distributed ledger technology
H.7 DLT functionality description
The crypto-asset was issued, and its supply is recorded, on the Ethereum network, which is a public permissionless network operated by no identified person and not operated by any person or structure connected to the crypto-asset project. The crypto-asset is also recorded on the Mantle network, a layer 2 network settling on Ethereum, and the operation of that network is not open in the same way. This section describes the Mantle network.
Based on the available information, the crypto-asset does not appear to be issued through a traditional corporate, foundation, or comparable legal entity structure, and no registered legal-entity issuer has been identified. The roles that operate the Mantle network are performed by structures connected to the crypto-asset project, which may be relevant for the assessment of issuer-like functions, to the extent such persons or structures can be identified from available information.
The following describes how the Mantle network functions. Transactions submitted to the network are ordered into blocks by a single sequencer, and transactions must be submitted to that sequencer rather than distributed among independent participants. A batching component publishes the transaction data to Ethereum, and a proposing component generates cryptographic validity proofs over the resulting state and submits them to a contract on Ethereum, where they are verified. The sequencing, proposing, batching and data availability roles are not open to third parties. Verifier nodes, which independently re-derive the state from the published data and compare it with what has been submitted, can be operated by anyone, but a verifier does not produce blocks and cannot order transactions.
Two consequences follow for holders. The party operating the sequencer determines whether and in what order transactions are included, and can therefore delay a transaction, decline to include it, or order transactions to its own advantage. It cannot, however, alter balances or create units, because a state transition is accepted on Ethereum only if the accompanying validity proof is verified.
The contracts that implement the network on Ethereum, including those through which assets are moved between the two networks, are upgradeable. An administrative contract holds the authority to upgrade them. A change made through that authority can alter how the network and the bridging arrangements function, including in ways that affect holders' ability to transfer the crypto-asset or to move it between the two networks.
The information in this section is based on the project's published technical documentation and should be considered indicative only.
H.8 Audit
H.9 Audit outcome
Part I – Information on risks
I.1 Offer-related risks
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.
I.2 Issuer-related risks
Interpretative note for this section: The risk factors set out in this Part I.2 follow the structure of the applicable MiCA white paper template for crypto-assets other than asset-referenced tokens or e-money tokens under Title II of MiCA, including references to issuer-related risks. For the purposes of this Part I.2, references to an “issuer”, “issuer-related risks” or similar terms should be read in line with the definition of “issuer” under MiCA, including any natural or legal person, or other undertaking, that issues crypto-assets.
Based on the available information, the crypto-asset does not appear to be issued through a traditional corporate, foundation, or comparable legal entity structure. Accordingly, the risk descriptions in this Part I.2 should be understood as referring, as applicable, to any natural persons, legal persons, undertakings, organised development teams, governance arrangements, or other project-related structures that may materially influence the crypto-asset or the related project, to the extent such persons or structures can be identified from available information.
1. Absence or insolvency of an identifiable issuer
Where an identifiable issuer exists, that issuer may face insolvency risks. These may result from insufficient funding, low market interest, mismanagement, legal or regulatory developments, or external shocks, including pandemics or armed conflicts. In such a case, ongoing development, support, communication, or governance of the crypto-asset project may be reduced, suspended, or discontinued, potentially affecting the viability, availability, market acceptance, or 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.
I.3 Crypto-assets-related risks
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.
I.4 Project implementation-related risks
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 person seeking admission to trading is not involved in the implementation of the crypto-asset project and does not assume responsibility for its governance, funding, development, maintenance, operation, or execution.
The principal project implementation-related risks for the crypto-asset are as follows:
1. Key-contributor and concentration risk: The continued development, maintenance, and upgrading of the crypto-asset and the related network may depend on a limited number of core protocol contributors, client-software development teams, and supporting organisations such as foundations. The departure, incapacity, loss of funding, or strategic misalignment of such contributors or organisations, or an over-reliance on a dominant client implementation, may delay, fragment, or otherwise adversely affect the implementation and ongoing evolution of the crypto-asset.
2. Timeline and milestone risk: Protocol upgrades, feature releases, scaling improvements, or other initiatives set out in any public roadmap or technical documentation may not be delivered as announced, may be delayed, or may be abandoned. Such delays or changes can undermine market confidence and affect the adoption, use, or perceived value of the crypto-asset.
3. Delivery risk: Even where an upgrade or feature is delivered as planned, it may not perform as intended, may introduce unintended effects, or may be scaled back during or after deployment, which may limit the practical functionality or expected benefits of the crypto-asset.
I.5 Technology-related risks
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.
I.6 Mitigation measures
None.
Part J – Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts
J.1 Adverse impacts on climate and other environment-related adverse impacts
S.1 Name
S.2 Relevant legal entity identifier
S.3 Name of the crypto-asset
S.4 Consensus Mechanism
The crypto asset that is the subject of this white paper is available on multiple DLT networks. These include: Ethereum and Mantle.
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 Mantle:
Mantle does not operate a consensus mechanism of its own. The order of transactions is determined by the network's sequencer rather than by agreement among a set of validators. The network derives its security from Ethereum: the transaction data is published there, the validity proofs over the resulting state are verified by a contract there, and a state becomes final when the Ethereum transaction recording it is itself final under Ethereum's consensus mechanism.
S.5 Incentive Mechanisms and Applicable Fees
The crypto asset that is the subject of this white paper is available on multiple DLT networks. These include: Ethereum and Mantle.
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 Mantle:
Transactions on the Mantle network are paid for in MNT, the network's own asset. The fee for a transaction is made up of the cost of executing it on the network, a share of the cost of publishing the associated data to Ethereum, and a component paid to the operators of the network's infrastructure. These fees are what compensate the parties that order transactions, publish the data and submit the proofs. The way each component is calculated is set at protocol level and is published by the project, and the rates are subject to change.
Assets are moved between Ethereum and the Mantle network through contracts deployed on each. Assets sent to the network are held by a contract on Ethereum and a corresponding balance is made available on the network. A withdrawal is initiated on the Mantle network and completed by a separate claim on Ethereum, which can be made once the state recording the withdrawal has been established on Ethereum.
S.6 Beginning of the period to which the disclosure relates
S.7 End of the period to which the disclosure relates
S.8 Energy consumption
S.9 Energy consumption sources and methodologies
The energy consumption of this asset is aggregated across multiple components: to determine the energy consumption of a token, the energy consumption of the networks Mantle and Ethereum is calculated first. For the energy consumption of the token, a fraction of the energy consumption of the network is attributed to the token, which is determined based on the activity of the crypto-asset within the 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 network is based on assumptions that are verified on a best-effort basis using empirical data. In general, participants are assumed to be largely economically rational. As a precautionary principle, we make assumptions on the conservative side when in doubt, i.e. by making higher estimates of the adverse impacts.
S.10 Renewable energy consumption
S.11 Energy intensity
S.12 Scope 1 DLT GHG emissions – Controlled
S.13 Scope 2 DLT GHG emissions – Purchased
S.14 GHG intensity
S.15 Key energy sources and methodologies
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
S.16 Key GHG sources and methodologies
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.