Version 1

White paper drafted under the European Markets in Crypto-Assets Regulation (EU) 2023/1114 for FFG C4CQCGLH2

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Preamble

00. Table of Content

  1. Preamble
  2. Part A – Information about the offeror or the person seeking admission to trading
  3. Part B – Information about the issuer, if different from the offeror or person seeking admission to trading
  4. 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
  5. Part D – Information about the crypto-asset project
  6. Part E – Information about the offer to the public of crypto-assets or their admission to trading
  7. Part F – Information about the crypto-assets
  8. Part G – Information on the rights and obligations attached to the crypto-assets
  9. Part H – information on the underlying technology
  10. Part I – Information on risks
  11. Part J – Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts

01. Date of notification

2026-01-12

02. Statement in accordance with Article 6(3) of Regulation (EU) 2023/1114

This crypto-asset white paper has not been approved by any competent authority in any Member State of the European Union. The operator of the trading platform of the crypto-asset is solely responsible for the content of this crypto-asset white paper.

03. Compliance statement in accordance with Article 6(6) of Regulation (EU) 2023/1114

This crypto-asset white paper complies with Title II of Regulation (EU) 2023/1114 of the European Parliament and of the Council and, to the best of the knowledge of the management body, the information presented in the crypto-asset white paper is fair, clear and not misleading and the crypto-asset white paper makes no omission likely to affect its import.

04. Statement in accordance with Article 6(5), points (a), (b), (c), of Regulation (EU) 2023/1114

The crypto-asset referred to in this crypto-asset white paper may lose its value in part or in full, may not always be transferable and may not be liquid.

05. Statement in accordance with Article 6(5), point (d), of Regulation (EU) 2023/1114

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 service supplied solely by the issuer.

06. Statement in accordance with Article 6(5), points (e) and (f), of Regulation (EU) 2023/1114

The crypto-asset referred to in this white paper is not covered by the investor compensation schemes under Directive 97/9/EC of the European Parliament and of the Council or the deposit guarantee schemes under Directive 2014/49/EU of the European Parliament and of the Council.

Summary

07. Warning in accordance with Article 6(7), second subparagraph, of Regulation (EU) 2023/1114

Warning: This summary should be read as an introduction to the crypto-asset white paper. The prospective holder should base any decision to purchase this crypto–asset on the content of the crypto-asset white paper as a whole and not on the summary alone. The offer to the public of this crypto-asset does not constitute an offer or solicitation to purchase financial instruments and any such offer or solicitation can be made only by means of a prospectus or other offer documents pursuant to the applicable national law. This crypto-asset white paper does not constitute a prospectus as referred to in Regulation (EU) 2017/1129 of the European Parliament and of the Council or any other offer document pursuant to Union or national law.

08. Characteristics of the crypto-asset

The Aptos crypto-asset (APT) operates on the Aptos blockchain, a distributed ledger system designed to support the execution of transactions and smart contracts. The network is based on open-source software and enables participants to submit transactions, deploy and interact with smart contracts, and maintain a shared ledger state without reliance on a central intermediary.

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

Not applicable.

10. Key information about the offer to the public or admission to trading

The token has been admitted to trading to the trading platform operated by Bitstamp Europe S.A. on its own initiative.

Part A – Information about the offeror or the person seeking admission to trading

A.1 Name

Not applicable.

A.2 Legal form

Not applicable.

A.3 Registered address

Not applicable.

A.4 Head office

Not applicable.

A.5 Registration date

Not applicable.

A.6 Legal entity identifier

Not applicable.

A.7 Another identifier required pursuant to applicable national law

Not applicable.

A.8 Contact telephone number

Not applicable.

A.9 E-mail address

Not applicable.

A.10 Response time (Days)

Not applicable.

A.11 Parent company

Not applicable.

A.12 Members of the management body

Not applicable.

A.13 Business activity

Not applicable.

A.14 Parent company business activity

Not applicable.

A.15 Newly established

Not applicable.

A.16 Financial condition for the past three years

Not applicable.

A.17 Financial condition since registration

Not applicable.

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

Yes, the issuer is different from the person seeking admission to trading.

B.2 Name

At the time of drafting this white paper, no single formal issuer within the meaning of MiCAR can be clearly identified for the APT crypto-asset. Publicly available information indicates that Aptos Labs has played a significant role in the initial development and coordination of the Aptos blockchain. However, Aptos Labs is not publicly described as exercising unilateral control over the protocol or acting as an issuer with ongoing responsibility for the crypto-asset. Protocol governance and network operation are described as being conducted through protocol-defined mechanisms and decentralised participation. Accordingly, there is no central legal entity that can be clearly identified as responsible for the issuance or administration of APT in the capacity of an issuer under MiCAR.

B.3 Legal form

Not applicable.

B4. Registered address

Not applicable.

Not applicable.

Not applicable.

B.5 Head office

Not applicable.

Not applicable.

Not applicable.

B.6 Registration date

Not applicable.

B.7 Legal entity identifier

Not applicable.

B.8 Another identifier required pursuant to applicable national law

Not applicable.

B.9 Parent company

Not applicable.

B.10 Members of the management body

Identity Function Business Address
Could not be identified Not applicable Not applicable

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

Bitstamp Europe S.A.

C.2 Legal form

5GGB

C.3 Registered address

40, avenue Monterey, L-2163 Luxembourg

Grand Duchy of Luxembourg,

LU-LU

C.4 Head office

Not applicable.

C.5 Registration date

2015-05-19

C.6 Legal entity identifier

549300XIBGTJ0PLIEO72

C.7 Another identifier required pursuant to applicable national law

Bitstamp Europe S.A. is registered with the Luxembourg Trade and Companies Register under the number B196856.

C.8 Parent company

Robinhood Markets, Inc with its registered office at 85 Willow Road, Menlo Park, California 94025, USA.

C.9 Reason for crypto-Asset white paper Preparation

As a MiCAR-licensed operator of the trading platform, Bitstamp Europe S.A. shall comply with the requirements set out in Article 5 of MiCAR when admitting to trading on its own initiative a crypto-asset for which no white paper has been published in accordance with MiCAR. In such cases, including admission of the token to trading, Bitstamp Europe S.A. shall provide, notify and publishing the crypto-asset white paper in accordance with the relevant provisions of MiCAR.

C.10 Members of the Management body

Identity Function Business Address
Johann Kerbrat Director 40, Avenue Monterey, L-2163 Luxembourg, Grand Duchy of Luxembourg
Robert Caplehorn Director 40, Avenue Monterey, L-2163 Luxembourg, Grand Duchy of Luxembourg
Roger Younan Director 40, Avenue Monterey, L-2163 Luxembourg, Grand Duchy of Luxembourg
Jerome Dave Authorised Manager 40, Avenue Monterey, L-2163 Luxembourg, Grand Duchy of Luxembourg
Gillian Gallimore Authorised Manager 40, Avenue Monterey, L-2163 Luxembourg, Grand Duchy of Luxembourg

C.11 Operator business activity

Bitstamp Europe S.A. is a Crypto-Asset Service Provider authorized with the CSSF under the number N00000003 to provide the following crypto-asset services:

• providing custody and administration of crypto-assets on behalf of clients;

• operation of a trading platform for crypto-assets;

• exchange of crypto-assets for funds;

• exchange of crypto-assets for other crypto-assets;

• execution of orders for crypto-assets on behalf of clients;

• reception and transmission of orders for crypto-assets on behalf of clients; and

• providing transfer services for crypto-assets on behalf of clients.

Bitstamp Europe S.A. is a payment institution authorized with the CSSF under number Z00000012 to provide the following payment services:

3.a) execution of direct debits, including one-off direct debits,

3.b) execution of payment transactions through a payment card or a similar device,

3.c) execution of credit transfers, including standing orders and

6.) money remittance.

Bitstamp Europe S.A. has notified the cross-border provision of payment services and of crypto-asset services in all EU and EEA member states.

Bitstamp has admitted the asset to which this white paper relates to, to trading on its own initiative on its trading platform.

C.12 Parent company business activity

Robinhood Markets, Inc is the holding company for the Robinhood group.

C.13 Other persons drawing up the crypto-asset white paper according to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114

Crypto Risk Metrics GmbH, Lange Reihe 73, 20099 Hamburg

C.14 Reason for drawing the white paper by persons referred to in Article 6(1), second subparagraph, of Regulation (EU) 2023/1114

Crypto Risk Metrics GmbH, Lange Reihe 73, 20099 Hamburg, was mandated to draw up the white paper by Bitstamp Europe S.A.

Part D – Information about the crypto-asset project

D.1 Crypto-asset project name

Long Name: "Aptos Coin", Short Name: "APT" according to the Digital Token Identifier Foundation (www.dtif.org, DTI see F.13, FFG DTI see F.14 as of 2025-12-20).

D.2 Crypto-assets name

See F.13.

D.3 Abbreviation

See F.13.

D.4 Crypto-asset project description

The Aptos crypto-asset (APT) operates on the Aptos blockchain, a distributed ledger system designed to support the execution of transactions and smart contracts. The network is based on open-source software and enables participants to submit transactions, deploy and interact with smart contracts, and maintain a shared ledger state without reliance on a central intermediary.

The Aptos blockchain was initially developed by contributors who later formed Aptos Labs, which has been publicly associated with early research, development, and ecosystem coordination activities. The ongoing operation of the network is governed by protocol rules and decentralised participation.

The APT crypto-asset does not represent ownership, equity, or a claim against any legal entity. Its functionality and continued operation depend on network participation, protocol rules, and adoption of the underlying software by node operators and users.

D.5 Details of all natural or legal persons involved in the implementation of the crypto-asset project

Type of person Name of person Business address of person Domicile of company

Other person involved in implementation

Aptos Labs

US, 735, Emerson St., Palo Alto, CA 94301

United States of America

Other person involved in implementation

Aptos Foundation

Can not be found

Can not be found

Other person involved in implementation

Mo Shaikh

Can not be found

Can not be found

Other person involved in implementation

Avery Ching

Can not be found

Can not be found

Other person involved in implementation

Alin Tomescu

Can not be found

Can not be found

Other person involved in implementation

Greg Nazario

Can not be found

Can not be found

Other person involved in implementation

Josh Lind

Can not be found

Can not be found

Other person involved in implementation

Rati Gelashivili

Can not be found

Can not be found

Other person involved in implementation

Rustie Lin

Can not be found

Can not be found

Other person involved in implementation

Sasha Spiegelman

Can not be found

Can not be found

Other person involved in implementation

Sital Kedia

Can not be found

Can not be found

Other person involved in implementation

Zekun Li

Can not be found

Can not be found

Other person involved in implementation

Alex Mittendorf

Can not be found

Can not be found

Other person involved in implementation

Ariana Gianacopoulos

Can not be found

Can not be found

Other person involved in implementation

Pranav Raval

Can not be found

Can not be found

Other person involved in implementation

Solomon Tesfaye

Can not be found

Can not be found

Other person involved in implementation

Investors

Can not be found

Can not be found

D.6 Utility Token Classification

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 service supplied solely by the issuer.

D.7 Key Features of Goods/Services for Utility Token Projects

Not applicable.

D.8 Plans for the token

This section provides an overview of the historical developments related to the Aptos Coin 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. Past developments cannot be assumed to continue, and changes may affect token holders.

Past milestones:

- Project origination and early development (2021–2022):

Public sources indicate that development work on the Aptos blockchain originated from prior research into distributed ledger technology and smart contract execution environments. Early development activities focused on protocol design, tooling, and test network deployments.

- Mainnet launch (12 October 2022):

According to public disclosures, the Aptos mainnet was launched on 12 October 2022. At launch, the APT crypto-asset was introduced with an initial total supply of 1 billion units, allocated across predefined categories and subject to vesting and lock-up arrangements.

- Post-launch protocol operation and updates (2022 onward):

Following mainnet launch, the Aptos network entered ongoing operation. Publicly documented activities include software updates, validator participation, and continued development of protocol components and developer tooling, implemented through publicly released code and network participation.

Future milestones:

- Protocol maintenance and upgrades:

Public communications indicate an intention to continue maintaining and updating the Aptos protocol software. Such updates may relate to protocol parameters, software implementations, or compatibility and are subject to governance processes and adoption by network participants.

- Token distribution and vesting progression:

Based on publicly disclosed tokenomics information, portions of the APT supply allocated at genesis remain subject to vesting and scheduled distribution over an extended period. The gradual release of these tokens is expected to continue in accordance with predefined schedules.

- Ecosystem-related activities:

Public materials reference ongoing or planned activities related to ecosystem support, including grants, incentives, or other programmes intended to support network usage. The scope, timing, and outcome of such activities remain dependent on governance decisions and resource availability.

All described future developments represent intended or potential milestones only. They remain dependent on technological feasibility, resource allocation, regulatory considerations, and general project priorities. There is no certainty that these developments will occur, occur as described, or be maintained in the long term. Deviations from the roadmap may occur without prior notice, and changes may negatively affect the usability or relevance of the token.

D.9 Resource allocation

According to publicly available tokenomics disclosures, the Aptos mainnet was launched on 12 October 2022 with an initial total supply of 1,000,000,000 APT. At genesis, this initial supply was allocated across several predefined categories, reflecting a one-time distribution framework rather than an ongoing discretionary allocation process.

Based on public disclosures, the initial allocation comprised approximately:

- 51.02% of the initial supply allocated to a community category intended for ecosystem-related purposes,

- 19.00% allocated to core contributors,

- 16.50% allocated to a foundation-related category, and

- 13.48% allocated to investors.

The portion allocated to the community and foundation-related categories was designated for ecosystem-related uses such as grants, incentives, and other protocol-supporting activities. Public materials indicate that a substantial part of these tokens was held by entities commonly referred to as the Aptos Foundation and Aptos Labs, with distribution intended to occur progressively over an extended period, reportedly spanning up to ten years. The release of these tokens is subject to predefined schedules and conditions rather than discretionary allocation decisions.

Allocations to core contributors and investors were likewise subject to vesting and lock-up arrangements defined at the outset. The timing and availability of such tokens are determined by these predefined arrangements and may affect the circulating supply as vesting milestones are reached.

Beyond the initial distribution, resource allocation within the Aptos ecosystem occurs primarily through protocol-level mechanisms, including predefined emission schedules that govern the creation of new APT units. These mechanisms operate according to protocol parameters and are not managed through a centralised project budget or issuer-controlled treasury comparable to that of a traditional corporate structure.

D.10 Planned use of Collected funds or crypto-Assets

Not applicable, as this white paper was drawn up for the admission to trading and not for collecting funds for the crypto-asset-project.

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

The white paper concerns the admission to trading on the initiative of Bitstamp Europe S.A. as the operator of the MiCAR-regulated trading platform.

E.2 Reasons for public offer or admission to trading

Bitstamp Europe S.A. has admitted the token to trading based on its market considerations.

E.3 Fundraising target

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

E.4 Minimum subscription goals

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

E.5 Maximum subscription goals

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

E.6 Oversubscription acceptance

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

E.7 Oversubscription allocation

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

E.8 Issue price

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

E.9 Official currency or any other crypto-assets determining the issue price

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

E.10 Subscription fee

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

E.11 Offer price determination method

Once the token is admitted to trading its price will be determined by demand (buyers) and supply (sellers).

E.12 Total number of offered/traded crypto-assets

According to publicly available on-chain and secondary market data as of the date of drafting, the total supply of the APT crypto-asset is approximately 1.19 billion APT, while the circulating supply is approximately 750 million APT. These figures reflect the supply recorded in December 2025 and are derived from publicly accessible market data aggregators and blockchain-based information.

The total supply of APT is not fixed and may change over time. The Aptos protocol provides for the issuance of additional APT units in accordance with predefined emission schedules. At the same time, portions of the total supply remain subject to lock-up and vesting arrangements established at the time of initial allocation.

As a result, the circulating supply may differ materially from the total supply at any given time and may fluctuate due to emissions, vesting unlocks, or other protocol-defined conditions. Consequently, the total number of APT units available to the public or admitted to trading is subject to ongoing change and does not represent a permanently fixed quantity.

E.13 Targeted holders

ALL

E.14 Holder restrictions

Bitstamp Europe S.A. offers trading of the token to all its clients without restrictions on services or account functionalities. However, Bitstamp Europe S.A. does not provide access to trading or related services to individuals or entities located in restricted jurisdictions, subject to sanctions, or otherwise limited in their use of its services.

E.15 Reimbursement notice

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

E.16 Refund mechanism

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

E.17 Refund timeline

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

E.18 Offer phases

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

E.19 Early purchase discount

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

E.20 Time-limited offer

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

E.21 Subscription period beginning

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

E.22 Subscription period end

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

E.23 Safeguarding arrangements for offered funds/crypto- Assets

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

E.24 Payment methods for crypto-asset purchase

The token will be available for trading on Bitstamp Europe S.A. trading platform. The token can be purchased there by using deposited funds or any other valid form of payment available on the trading platform.

E.25 Value transfer methods for reimbursement

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

E.26 Right of withdrawal

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

E.27 Transfer of purchased crypto-assets

When a client purchases a token on the Bitstamp Europe S.A.'s trading platform, the crypto-asset will be credited to their Bitstamp account. If a client wants to hold the token in their own wallet, they will need to (i) provide an external blockchain wallet address, where the crypto-assets will be sent if a withdrawal is initiated and (ii) satisfy all other requirements applicable to a withdrawal in line with the Regulation (EU) 2023/1113 of the European Parliament and of the Council of 31 May 2023 on information accompanying transfers of funds and certain crypto-assets.

E.28 Transfer time schedule

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

E.29 Purchaser's technical requirements

When a client purchases a token on the Bitstamp Europe S.A.'s trading platform, the crypto-asset will be credited to their Bitstamp account and a client does not need to fulfill any other technical requirement to hold the crypto-assets on their Bitstamp account, apart from have either a computer or phone with an internet connection and appropriate software in order to interact with the Bitstamp services.

E.30 Crypto-asset service provider (CASP) name

Not applicable, as Bitstamp Europe S.A. has admitted the token to trading on its platform on its own initiative and is neither the offeror nor in charge of placing the token.

E.31 CASP identifier

Not applicable, as Bitstamp Europe S.A. has admitted the token to trading on its platform on its own initiative and is neither the offeror nor in charge of placing the token.

E.32 Placement form

Not applicable, as Bitstamp Europe S.A. has admitted the token to trading on its platform on its own initiative and is neither the offeror nor in charge of placing the token.

E.33 Trading platforms name

Bitstamp Europe S.A.

E.34 Trading platforms Market identifier code (MIC)

BESA

E.35 Trading platforms access

Investors can access the trading platform through https://www.bitstamp.net or via the Bitstamp applications.

E.36 Involved costs

There are no costs involved in creating an account on the trading platform, however trading fees and other costs apply in accordance with the fee schedule available at https://www.bitstamp.net/fee-schedule.

E.37 Offer expenses

Not applicable, as Bitstamp Europe S.A. has only admitted token to trading on its platform on its own initiative and has not been involved in offering the token to the public.

E.38 Conflicts of interest

There are no conflicts of interest of the persons involved in the admission to trading. Bitstamp Group has a strict Code of Conduct and Trading Policy in place. They both mitigate the possibility of conflicts of interest.

In accordance with the Code of Conduct all officers, directors, employees, agents, representatives, contractors and consultants (and other persons, regardless of job or position), are required to report any situation where there is the potential for conflict of interest between their interests and interests of Bitstamp. The Trading Policy that is in place within the Bitstamp Group prohibits all forms of market manipulation and has been designed to prevent insider trading.

E.39 Applicable law

Not applicable, as this point pertains to an "offer to the public," whereas this white paper relates to admission to trading.

E.40 Competent court

Not applicable, as this point pertains to an "offer to the public," whereas this white paper relates to admission to trading.

Part F – Information about the crypto-assets

F.1 Crypto-asset type

The crypto-asset described in the white paper is classified as a crypto-asset under the Markets in Crypto-Assets Regulation (MiCAR) but does not qualify as an electronic money token (EMT) or an asset-referenced token (ART). It is a digital representation of value that can be stored and transferred using distributed ledger technology (DLT) or similar technology, without embodying or conferring any rights to its holder. The asset does not aim to maintain a stable value by referencing an official currency, a basket of assets, or any other underlying rights. Instead, its valuation is entirely market-driven, based on supply and demand dynamics, and not supported by a stabilization mechanism. It is neither pegged to any fiat currency nor backed by any external assets, distinguishing it clearly from EMTs and ARTs. Furthermore, the crypto-asset is not categorized as a financial instrument, deposit, insurance product, pension product, or any other regulated financial product under EU law. It does not grant financial rights, voting rights, or any contractual claims to its holders, ensuring that it remains outside the scope of regulatory frameworks applicable to traditional financial instruments.

F.2 Crypto-asset functionality

APT is a cryptographic token used within the Aptos blockchain to interact with protocol-level functions. Transactions on the network are recorded on the distributed ledger and executed in accordance with protocol rules.

APT may be used in connection with transaction execution, participation in protocol governance mechanisms, and other protocol-defined processes. Transfers of APT occur directly between blockchain addresses and are validated by network participants operating nodes.

The functionality of APT is limited to what is enabled by the Aptos protocol and compatible software. No assurance is given that any specific function will remain available or unchanged over time.

F.3 Planned application of functionalities

See D.8.

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

The white paper type is "other crypto-assets" (i. e. "OTHR").

F.5 The type of submission

The white paper submission type is "NEWT", which stands for new token.

F.6 Crypto-asset characteristics

The crypto-assets are crypto-assets other than EMTs and ARTs, which are available on the Aptos blockchain. The crypto-assets are fungible. Investors should note that there is no permanently fixed maximum supply. The crypto-asset is subject to an ongoing emission framework, under which additional tokens may be issued in the future for liquidity incentives and ecosystem development.

The tokens are a digital representation of value, and have no inherent rights attached as well as no intrinsic utility.

F.7 Commercial name or trading name

See F.13.

F.8 Website of the issuer

No formal issuer can be identified for the crypto-asset. Further information regarding the crypto-asset project is available at: https://aptoslabs.com/

F.9 Starting date of offer to the public or admission to trading

2026-02-11

F.10 Publication date

2026-02-10

F.11 Any other services provided by the issuer

It is not possible to exclude a possibility that the issuer of the token provides or will provide other services not covered by Regulation (EU) 2023/1114 (i.e. MiCAR).

F.12 Language or languages of the crypto-asset white paper

EN

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

SSFZXXTDD; SMB9ZBCGN

F.14 Functionally fungible group digital token identifier

C4CQCGLH2

F.15 Voluntary data flag

Mandatory.

F.16 Personal data flag

The white paper does contain personal data.

F.17 LEI eligibility

The issuer should be eligible for a Legal Entity Identifier.

F.18 Home Member State

Luxembourg

F.19 Host Member States

The token is available for trading to clients of Bitstamp Europe S.A. residing in any EU or EEA country.

Part G – Information on the rights and obligations attached to the crypto-assets

G.1 Purchaser rights and obligations

No legally binding real or contractual obligations are linked to the crypto-asset. The technically possible governance participations and functionalities described in F.2 cannot be independently verified and it cannot be guaranteed that these promises have legal binding force that an investor can enforce.

G.2 Exercise of rights and obligations

As the token grants no legal binding rights nor obligations, there are no procedures and conditions for the exercise of these rights applicable.

The promise of governance participation is based on technical circumstances and relies on smart contract functionalities and voting platforms. It is not certain whether this infrastructure will be available for use of these governance functions on a permanent basis.

G.3 Conditions for modifications of rights and obligations

As the token grants no legal binding rights nor obligations, there are no procedures and conditions for the exercise of these rights applicable.

An adjustment of the technical infrastructure necessary to exercise the promised governance rights, declining functionality due to dilution, changing rights within the voting platforms, and all other adverse effects for investors may occur at any time.

G.4 Future public offers

Information on the future offers to the public of crypto-assets were not available at the time of writing this white paper (2025-12-21).

G.5 Issuer retained crypto-assets

Publicly available tokenomics disclosures indicate that, at the time of the initial distribution of APT, a significant portion of the initially issued units was allocated to categories associated with ecosystem-related purposes, foundations or foundation-like structures, core contributors, and early investors. These allocations were implemented as part of the initial distribution framework and were subject to predefined vesting and lock-up arrangements.

However, these retained or project-associated allocations do not constitute issuer-retained crypto-assets in the classical sense, as no identifiable issuer within the meaning of Regulation (EU) 2023/1114 (MiCAR) can be clearly determined for the APT crypto-asset. There is no single legal entity exercising ongoing control over the protocol or holding crypto-assets in a capacity comparable to that of a traditional issuer.

Nevertheless, the concentration of APT holdings linked to early project participants, foundation-related structures, or ecosystem-associated addresses may give rise to distribution- and concentration-related risks for market participants, including potential impacts on liquidity, governance dynamics, or market behaviour as vesting or release milestones are reached.

The exact number of APT units that may be considered retained by such persons or structures cannot be determined with precision on the basis of publicly available information alone. Due to the limited and formal scope of this field, which focuses on issuer-retained crypto-assets rather than a comprehensive analysis of project-associated allocations, the number of issuer-retained crypto-assets is therefore considered not applicable.

G.6 Utility token classification

No

G.7 Key features of goods/services of utility tokens

Not applicable.

G.8 Utility tokens redemption

Not applicable.

G.9 Non-trading request

This white paper was prepared to be able to admit the crypto-asset to trading.

G.10 Crypto-assets purchase or sale modalities

Not applicable, as the token is admitted to trading on the trading platform operated by Bitstamp Europe S.A.

G.11 Crypto-assets transfer restrictions

The crypto-assets as such do not have any transfer restrictions and are generally freely transferable. Bitstamp will employ the same restrictions to the token as to the other crypto-assets listed on their trading platform and strictly abide by the applicable laws in the European Union.

G.12 Supply adjustment protocols

As of the date of drafting, the Aptos protocol does not include protocol-level mechanisms that dynamically increase or decrease the supply of APT in direct response to changes in market demand or price signals. The protocol does not implement discretionary, algorithmic, or demand-responsive supply adjustment mechanisms.

G.13 Supply adjustment mechanisms

Although the Aptos protocol does not implement demand-responsive supply adjustment protocols, it includes protocol-defined mechanisms that affect the total and circulating supply of APT over time.

According to publicly available tokenomics disclosures, new APT units may be issued through staking reward mechanisms associated with the proof-of-stake consensus process. Validators and token holders who delegate APT for staking purposes may receive rewards in newly issued APT, with reward levels determined by protocol parameters. The maximum staking reward rate is defined at the protocol level and is subject to periodic evaluation, with a predefined long-term declining schedule toward a lower bound. These reward mechanisms increase the total supply of APT but operate independently of market demand.

In parallel, the Aptos protocol provides that transaction fees are currently burned, resulting in the permanent removal of APT units from circulation. This mechanism may reduce the circulating supply but is not designed to respond dynamically to demand conditions. Public documentation indicates that fee-burning parameters may be subject to modification through on-chain governance processes.

All emission rates, reward parameters, and fee-related mechanisms are governed by protocol rules and may be modified through decentralised governance. These mechanisms do not constitute automated supply expansion or contraction in response to market demand, but rather predefined and governance-modifiable processes affecting supply over time.

G.14 Token value protection schemes

No, the token does not have value protection schemes.

G.15 Token value protection schemes description

Not applicable.

G.16 Compensation schemes

No, the token does not have compensation schemes.

G.17 Compensation schemes description

Not applicable.

G.18 Applicable law

The token is not subject to any predetermined applicable law. Applicable law likely depends on the location of any particular party and/or the location of any particular transaction with the token.

G.19 Competent court

The token is not subject to any predetermined court jurisdiction. Competent court likely depends on the location of any particular party and/or the location of any particular transaction with the token.

Part H – information on the underlying technology

H.1 Distributed ledger technology (DTL)

Bitstamp Europe S.A. is not involved either in maintenance or in development of the distributed ledger technology used to issue the token or to validate its transfers. The description below is based on information publicly available at the time of preparation of this white paper.

The crypto-asset in scope is implemented on the Aptos network 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 the Aptos network.

The following applies to Aptos:

The Aptos blockchain operates on publicly documented protocol specifications that define ledger structure, transaction processing, and validation rules. The protocol is implemented in open-source software, and nodes communicate using peer-to-peer networking standards defined in the protocol documentation.

Protocol updates are implemented through software changes adopted by network participants in accordance with governance processes.

H.3 Technology used

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

The following applies to Aptos:

The network is based on distributed ledger technology that records transactions in blocks linked sequentially. Cryptographic methods are used to secure transactions, manage accounts, and verify authenticity.

Smart contracts are executed within a virtual machine environment based on the Move programming language. Account access is controlled through cryptographic key pairs, and ledger data is replicated across participating nodes.

H.4 Consensus mechanism

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

The following applies to Aptos:

The Aptos blockchain utilises a proof-of-stake-based consensus mechanism. Validators participate in block proposal and validation in accordance with protocol-defined rules.

Validator selection, participation, and block finalisation are governed by staking and consensus parameters defined at the protocol level, which may be modified through governance processes.

H.5 Incentive mechanisms and applicable fees

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

The following applies to Aptos:

The protocol includes incentive mechanisms for validators participating in transaction validation and consensus activities. Validators may receive protocol-defined rewards in the form of newly issued APT units.

Transactions consume protocol-defined resources and may require the payment of fees denominated in APT. Fee levels and reward parameters are set by protocol rules and may be adjusted through governance mechanisms.

H.6 Use of distributed ledger technology

No, DLT not operated by the issuer, offeror, a person seeking admission to trading or a third-party acting on the issuer’s their behalf.

H.7 DLT functionality description

Not applicable.

H.8 Audit

Since the question of “technology” is understood in a broad sense, the answer to the question of whether an examination of the “technology used” has been carried out is “no, we cannot guarantee that all parts of the technology used have been examined.” This is because this report focuses on risks and we cannot guarantee that every part of the technology used has been examined.

H.9 Audit outcome

Not applicable.

Part I – Information on risks

I.1 Offer-related risks

1. Regulatory and Jurisdictional Risks: This white paper has been prepared with utmost caution; however, future changes in regulatory frameworks could potentially impact the token's legal status and its tradability.

Jurisdictional Limitations: Investors are required to ensure that their transactions comply with the laws applicable in their jurisdictions, as the regulatory landscape for crypto-assets varies significantly across different regions.

2. Market and Liquidity Risks:

Volatility: The token will most likely be subject to high volatility and market speculation. Price fluctuations could be significant, posing a risk of substantial losses to holders.

Liquidity Risk: Low trading volumes may restrict the buying and selling capabilities of the tokens. Liquidity of the token can vary. This could result in high slippage when trading a token.

3. Operational and Technical Risks:

Blockchain Dependency: As of now, the token is entirely dependent on the blockchains described above. Any issues like downtime, congestion, or security vulnerabilities within the networks could adversely affect the token's functionality.

Smart Contract Risks: Smart contracts governing the token may contain hidden vulnerabilities or bugs that could disrupt the token offering or distribution processes.

Human errors: Due to the irrevocability of blockchain-transactions, approving wrong transactions or using incorrect networks/addresses will most likely result in funds not being accessibly anymore.

4. Lack of Intrinsic Value: The token does not possess inherent utility, functioning solely as a speculative asset. Its valuation is predominantly influenced by community engagement, speculative activities, and overall market sentiment, which presents considerable challenges to sustaining long-term value stability.

5. Delisting Risks: Bitstamp Eurpe S.A. might remove the token from trading in line with Bitstamp Markets Trading Rules.

I.2 Issuer-related risks

1. Insolvency

As with every other commercial endeavor, the risk of insolvency of the issuer is given. This could be caused by but is not limited to lack of interest from the public, lack of funding, incapacitation of key developers and project members, force majeure (including pandemics and wars) or lack of commercial success or prospects.

2. Counterparty

In order to operate, the issuer has most likely engaged in different business relationships with one or more third parties on which it strongly depends on. Loss or changes in the leadership or key partners of the issuer and/or the respective counterparties can lead to disruptions, loss of trust, or project failure. This could result in a total loss of economic value for the crypto-asset holders.

3. Legal and Regulatory Compliance

Cryptocurrencies and blockchain-based technologies are subject to evolving regulatory landscapes worldwide. Regulations vary across jurisdictions and may be subject to significant changes. Non-compliance can result in investigations, enforcement actions, penalties, fines, sanctions, or the prohibition of the trading of the crypto-asset impacting its viability and market acceptance. This could also result in the issuer to be subject to private litigation. The beforementioned would most likely also lead to changes with respect to trading of the crypto-asset that may negatively impact the value, legality, or functionality of the crypto-asset.

4. Operational

Failure to develop or maintain effective internal control, or any difficulties encountered in the implementation of such controls, or their improvement could harm the issuer's business, causing disruptions, financial losses, or reputational damage.

5. Industry

The issuer is and will be subject to all of the risks and uncertainties associated with a crypto-project. History has shown that most of this projects resulted in financial losses for the investors and were only set-up to enrich a few insiders with the money from retail investors.

6. Reputational

The issuer faces the risk of negative publicity, whether due to, without limitation, operational failures, security breaches, or association with illicit activities, which can damage the issuer reputation and, by extension, the value and acceptance of the crypto-asset.

7. Competition

There are numerous other crypto-asset projects in the same realm, which could have an effect on the crypto-asset in question.

8. Unanticipated Risk

In addition to the risks included in this section, there might be other risks that cannot be foreseen. Additional risks may also materialize as unanticipated variations or combinations of the risks discussed.

I.3 Crypto-assets-related risks

1. Market Volatility Risks: High Volatility: The value of the token is expected to be highly volatile, influenced by speculation and overall market sentiment. Significant price fluctuations could lead to substantial losses for holders.

2. Speculative Nature: The token lacks intrinsic utility or underlying value, functioning solely as a speculative asset. Its valuation is wholly dependent on market demand and community interest.

3. Liquidity Risks: Some crypto-assets suffer from limited liquidity, which can present difficulties when executing large trades without significantly impacting market prices. This lack of liquidity can lead to substantial financial losses.

4. Blockchain Risks: Network Dependency: The token operates on the blockchains described above as of now. Issues such as network downtime, congestion, or security vulnerabilities could impair the token’s transferability, trading, or overall functionality. Although the networks is known for low transaction fees, network congestion or technical issues could lead to increased costs or delays.

5. Security Risks - Smart Contract Vulnerabilities: The smart contract for the token may contain vulnerabilities or exploits that jeopardize token security or distribution.

6. Security Risks - Private Key Management: It is critical for holders to secure their wallet private keys and recovery phrases. Losing wallet credentials can result in the irreversible loss of tokens.

7. Scams: The irrevocability of transactions executed using blockchain infrastructure, as well as the pseudonymous nature of blockchain ecosystems, attracts scammers. Therefore, investors in crypto-assets must proceed with a high degree of caution when investing in if they invest in crypto-assets. Typical scams include – but are not limited to – the creation of fake crypto-assets with the same name, phishing on social networks or by email, fake giveaways/airdrops, identity theft, among others.

8. Dependence on Community Interest: The success and market value of the token heavily rely on community support.

9. Evolving Legal Frameworks: Future changes in regulations or their interpretations could affect the classification, trading availability, or usability of the tokens. Jurisdictional Restrictions: Users in certain areas may encounter legal restrictions or obligations concerning the possession or trading of crypto-assets like the token in question.

10. Technological Obsolescence: The rapid evolution of the crypto-asset landscape means new technologies or platforms could make the networks or the tokens design less competitive, potentially affecting adoption and value. Participants are advised to recognize the speculative and volatile nature of the token and be prepared for these risks.

11. Reputational concerns: Crypto-assets are often subject to reputational risks stemming from associations with illegal activities, high-profile security breaches, and technological failures. Such incidents can undermine trust in the broader ecosystem, negatively affecting investor confidence and market value, thereby hindering widespread adoption and acceptance.

12. Taxation: The taxation regime that applies to the trading of the crypto-asset by individual holders or legal entities will depend on the holder’s jurisdiction. It is the holder’s sole responsibility to comply with all applicable tax laws, including, but not limited to, the reporting and payment of income tax, wealth tax, or similar taxes arising in connection with the appreciation and depreciation of the crypto-asset.

13. Anti-Money Laundering/Counter-Terrorism Financing: It cannot be ruled out that crypto-asset wallet addresses interacting with the crypto-asset have been, or will be used for money laundering or terrorist financing purposes, or are identified with a person known to have committed such offenses.

14. Market Abuse: It is noteworthy that crypto-assets are potentially prone to increased market abuse risks, as the underlying infrastructure could be used to exploit arbitrage opportunities through schemes such as front-running, spoofing, pump-and-dump, and fraud across different systems, platforms, or geographic locations. This is especially true for crypto-assets with a low market capitalization and few trading venues, and potential investors should be aware that this could lead to a total loss of the funds invested in the crypto-asset.

I.4 Project implementation-related risks

As this white paper relates to the "Admission to trading" of the crypto-asset, the implementation risk is referring to the risks on the Crypto Asset Service Providers side. These can be, but are not limited to, typical project management risks, such as key-personal-risks, timeline-risks, and technical implementation-risks.

I.5 Technology-related risks

1. Blockchain Dependency Risks

Network Downtime: Potential outages or congestion on the blockchains could interrupt on-chain token transfers, trading, and other functions.

Scalability Challenges: Despite the blockchains comparatively high throughput design, unexpected demand or technical issues might compromise its performance.

2. Smart Contract Risks

Vulnerabilities: The smart contract governing the token could contain bugs or vulnerabilities that may be exploited, affecting token distribution or vesting schedules.

3. Wallet and Storage Risks

Private Key Management: Token holders must securely manage their private keys and recovery phrases to prevent permanent loss of access to their tokens, which includes Trading-Venues, who are a prominent target for dedicated hacks.

Compatibility Issues: The tokens require network-compatible wallets for storage and transfer. Any incompatibility or technical issues with these wallets could impact token accessibility.

4. Network Security Risks

Attack Risks: The blockchains may face threats such as denial-of-service (DoS) attacks or exploits targeting its consensus mechanism, which could compromise network integrity.

Centralization Concerns: Although claiming to be decentralized, the networks relatively smaller number of validators/concentration of stakes within the network compared to other blockchains and the influence of the Foundations might pose centralization risks, potentially affecting network resilience.

5. Evolving Technology Risks: Technological Obsolescence: The fast pace of innovation in blockchain technology may make the networks and token standards appear less competitive or become outdated, potentially impacting the usability or adoption of the token.

6. Bridges: The crypto assets are transferred between the ecosystems using the so-called Bridge. Bridges have, in the past, been very sensitive to malfunctions and hacks. Their usage is connected to additional technical risk. The bridge poses an additional source for adverse effects on the investor as it retains the right to release, burn and mint portions of the token supply.

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

Bitstamp Europe S.A.

S.2 Relevant legal entity identifier

549300XIBGTJ0PLIEO72

S.3 Name of the cryptoasset

Aptos Coin

S.4 Consensus Mechanism

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

The following applies to Aptos:

The Aptos blockchain utilises a proof-of-stake-based consensus mechanism. Validators participate in block proposal and validation in accordance with protocol-defined rules.

Validator selection, participation, and block finalisation are governed by staking and consensus parameters defined at the protocol level, which may be modified through governance processes.

S.5 Incentive Mechanisms and Applicable Fees

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

The following applies to Aptos:

The protocol includes incentive mechanisms for validators participating in transaction validation and consensus activities. Validators may receive protocol-defined rewards in the form of newly issued APT units.

Transactions consume protocol-defined resources and may require the payment of fees denominated in APT. Fee levels and reward parameters are set by protocol rules and may be adjusted through governance mechanisms.

S.6 Beginning of the period to which the disclosure relates

2024-12-21

S.7 End of the period to which the disclosure relates

2025-12-21

S.8 Energy consumption

262800.00000 kWh/a

S.9 Energy consumption sources and methodologies

The energy consumption of this asset is aggregated across multiple components: For the calculation of energy consumptions, the so called 'bottom-up' approach is being used. The nodes are considered to be the central factor for the energy consumption of the network. These assumptions are made on the basis of empirical findings through the use of public information sites, open-source crawlers and crawlers developed in-house. The main determinants for estimating the hardware used within the network are the requirements for operating the client software. The energy consumption of the hardware devices was measured in certified test laboratories. When calculating the energy consumption, we used - if available - the Functionally Fungible Group Digital Token Identifier (FFG DTI) to determine all implementations of the asset of question in scope and we update the mappings regulary, based on data of 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 with best effort 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. making higher estimates for the adverse impacts.

S.10 Renewable energy consumption

31.3817462059 %

S.11 Energy intensity

0.00011 kWh

S.12 Scope 1 DLT GHG emissions – Controlled

0.00000 tCO2e/a

S.13 Scope 2 DLT GHG emissions – Purchased

87.46328 tCO2e/a

S.14 GHG intensity

0.00005 kgCO2e

S.15 Key energy sources and methodologies

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

S.16 Key GHG sources and methodologies

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