Index

General information	Page 3
Part A - Information about the offeror or the person seeking admission to trading	Page 4
Part B - Information about the issuer, if different from the offeror or person seeking admission to trading	Page 5
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	Page 6
Part D - Information about the crypto-asset project	Page 7
Part E - Information about the offer to the public of crypto-assets or their admission to trading	Page 8
Part F - Information about the crypto-assets	Page 9
Part G - Information on the rights and obligations attached to the crypto-assets	Page 10
Part H – Information on underlying technology	Page 11
Part I - Information on risks	Page 12
Part J - Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts	Page 13

General information

N	Field	Content
00	Table of contents	General Information Part A: Information about the offeror or the person seeking admission to trading Part B: Information about the issuer, if different from the offeror or person seeking admission to trading 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 Part D: Information about the crypto-asset project Part E: Information about the offer to the public of crypto-assets or their admission to trading Part F: Information about the crypto-assets Part G: Information on the rights and obligations attached to the crypto-assets Part H: Information on the underlying technology Part I: Information on the risks 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	2026-02-27
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 person seeking admission to trading 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	FALSE
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.
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 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 SBP is an environmental commodity issued alongside Bitcoin to represent verified clean energy use or equivalent renewable energy financing. It does not alter Bitcoin’s Proof of Work, but incentivises miners to use renewable energy in line with recognised sustainability frameworks. Each SBP token is generated exclusively based on verified environmental benefits and is not pre-minted or pre-allocated. Like bitcoin, each SBP token is divisible into 100 million units, referred to as “Kyotos”, and has a capped supply of 21 million. The total SBP supply is currently around 5,250 tokens, or 525 billion Kyotos.This is aligned with Bitcoin’s remaining mining rewards, and depends on clean-energy mining and allocation of the associated energy attributes. In order to complement the existing approximately 20 million supply of BTC, additional SBPs can be minted via investments in renewable energy instruments such as energy attribute certificates (EACs) or equivalent credits, allowing the supply to expand. SBPs are only created through demonstrated positive environmental impact, and no SBPs are issued absent such verified contributions. Holding SBPs does not confer any ownership, equity interest, debt claim, profit-sharing entitlement, voting rights in a legal entity, or contractual right to revenues or distributions. SBPs do not grant legal rights or impose legal obligations on holders beyond those arising from the technical functioning of the underlying protocol. SBP token holders and any prospective investors may access investor reports, market updates, and clean energy data. This is a new submission and this whitepaper is classified as “OTHR” pursuant to Regulation (EU) 2023/1114.
09	Further information about utility tokens	This field does not apply as 05 is False
10	Key information about the offer to the public or admission to trading	The SBP is intended to be admitted to trading on the regulated Kraken exchange, with a tentative listing date starting from 26 March 2026, enabling eligible participants to buy and sell SBP tokens in accordance with the trading platforms rules and applicable regulatory requirements. Admission to trading will allow SBP holders and prospective buyers to transact through regulated EU venues, ensuring transparent price discovery, providing secondary market access and stronger market depth; in addition to direct transactions between miners, investors, and companies.

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

N

Field

Content

A.1

Name

Sustainable Digital Solutions Limited (SDS Ltd)

A.2

Legal form

N/A as LEI is provided in A.6

A.3

Registered address

N/A as LEI is provided in A.6

A.4

Head office

N/A as LEI is provided in A.6

A.5

Registration date

2025-02-25

A.6

Legal entity identifier

9845007BB086A966CC97

A.7

Another identifier required pursuant to applicable national law

N/A as LEI is provided in A.6

A.8

Contact telephone number

+971 50 883 8579

A.9

E-mail address

info@sustainablebtc.org

A.10

Response time (Days)

021

A.11

Parent company

N/A as LEI is provided in A.6

A.12

Members of the management body

Identity	Business Address	Functions
Bradford Van Voorhees	651 N Broad St, Suite 206, Middletown, 19709, New Castle County, Delaware	Co-Founder and CEO
Matthew Twomey	651 N Broad St, Suite 206, Middletown, 19709, New Castle County, Delaware	Co-Founder and Head of Institutional
John Lilic	651 N Broad St, Suite 206, Middletown, 19709, New Castle County, Delaware	Board Member and Advisor

A.13

Business activity

SDS Ltd , the incorporated entity within Abu Dhabi Global Market (ADGM), operates as the international subsidiary of its parent company, SDS Inc.

A.14

Parent company business activity

SDS Inc., a Delaware-incorporated C-corporation, is an emerging technology company focused on driving innovation in clean energy digital solutions. It manages the Sustainable Bitcoin Protocol project, including its website and related decentralised applications (dApps).

A.15

Newly established

TRUE

A.16

Financial condition for the past three years

This field does not apply as A.15 is true.

A.17

Financial condition since registration

Since the start of its activities in 2025, SDS Ltd) has benefited from strategic investment from Mubadala, the Abu Dhabi sovereign wealth fund and was selected to join Hub71, the Abu Dhabi global tech ecosystem. In December 2025, the company generated approximately USD 88,000 in revenue, exceeding its monthly operating expenses and resulting in a cash flow–positive month.
As SDS Ltd was launched from SDS Inc., which was incorporated in 2022, an adequate financial standing was maintained since then. It was supported in particular by a USD 1.6 million pre-seed round raised in 2022 and a USD 1.6 million bridge round raised in November 2024. These financings supported the development of the group’s technology, operations, and market entry prior to the launch of SDS Ltd.
SBP is finalising its first public token listing on a tier-1 digital assets exchange. The growth in liquidity of the SBP token will drive significant revenue to SDS Ltd, our clean energy mining partners, and new renewable energy development.
SBP has established a revenue stream by operating as a validator to develop a wrapped Bitcoin (wBTC) and clean wrapped Bitcoin (cwBTC) on the Canton Network. Additionally, upon the public listing of the SBP token, the project is co-developing with a leading ETF Issuer the first Clean Energy Bitcoin ETP in Europe. The project anticipates leveraging its treasury assets to support ongoing financial management and strategic growth.

Part B - Information about the issuer, if different from the offeror or person seeking admission to trading

N	Field	Content
B.1	Issuer different from offerror or person seeking admission to trading	FALSE
B.2	Name	N/A
B.3	Legal form	N/A
B.4	Registered address	N/A
B.5	Head office	N/A
B.6	Registration date	N/A
B.7	Legal entity identifier	N/A
B.8	Another identifier required pursuant to applicable national law	N/A
B.9	Parent company	N/A
B.10	Members of the management body	N/A
B.11	Business activity	N/A
B.12	Parent company business activity	N/A

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

N	Field	Content
C.1	Name	N/A
C.2	Legal form	N/A
C.3	Registered address	N/A
C.4	Head office	N/A
C.5	Registration date	N/A
C.6	Legal entity identifier	N/A
C.7	Another identifier required pursuant to applicable national law	N/A
C.8	Parent company	N/A
C.9	Reason for crypto-asset white paper Preparation	N/A
C.10	Members of the management body	N/A
C.11	Operator business activity	N/A
C.12	Parent company business activity	N/A
C.13	Other persons drawing up the crypto-asset white paper according to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114	N/A
C.14	Reason for drawing the white paper by persons referred to in Article 6(1), second subparagraph, of Regulation (EU) 2023/1114	N/A

Part D - Information about the crypto-asset project

N

Field

Content

D.1

Crypto-asset project name

Sustainable Bitcoin Protocol

D.2

Crypto-asset name

SBP Token

D.3

Abbreviation

SBP

D.4

Crypto-asset project description

SBP framework is designed to incentivise the use of verifiable clean energy in Bitcoin mining without altering Bitcoin’s underlying Proof of Work consensus. It operates through the issuance of a crypto-asset called SBP token, which represents the verified use or financing of renewable energy in proportion to the Bitcoin network’s energy consumption.
The protocol records and verifies miners’ energy usage data on a granular basis down to the Megawatt-Hour (MWh), ensuring transparency and auditability. SBPs are transferable digital assets that allow investors and institutions to demonstrate climate-positive Bitcoin exposure while directing capital into renewable energy markets. By linking certificate creation to actual network energy use, SBP establishes a self-reinforcing “climate financing flywheel” that scales with Bitcoin adoption.
Aligned with SFDR Article 9 and the Greenhouse Gas Protocol Scope 2 Guidelines for market-based accounting, SBP relies on EACs to ensure that miners make unique and exclusive claims about their clean energy use. This mechanism prevents double-counting in environmental reporting, thereby extending Bitcoin’s security logic into climate accountability.

D.5

Details of all natural or legal persons involved in implementation of crypto-asset project

Name of person	Type of person	Business address	Domicile
Sustainable Digital Solutions Limited	Development team	Floor 16, Al Khatem Tower,WeWork Hub71, Abu Dhabi Global Market Square, Al Maryah Island, AE-AZ	United Arab Emirates
Sustainable Digital Solutions, Inc	Development team	651 N Broad St, Suite 206, Middletown, 19709, New Castle County, Delaware	United States of America

D.6

Utility Token Classification

False

D.7

Key Features of Goods/Services for Utility Token Projects

N/A

D.8

Description of past milestones

Past Milestones
SBP’s commercial and operational visibility journey began in Q1 2023 with the execution of its first SBP transaction between CleanSpark (NASDAQ: $CLSK), a leading U.S. sustainable Bitcoin miner, and Melanion Digital, a French Bitcoin-focused investment firm. This was followed by additional SBP OTC transactions between verified clean energy-powered bitcoin miners and institutional investors in 2023 and 2024.
Building on this milestone, Q2 2023 saw SBP develop a waste-gas methodology in collaboration with Crusoe Energy and climate experts, demonstrating how stranded methane emissions could be converted into electricity for Bitcoin mining under the SBP framework in an additional manner. Despite the development of this methodology, SBP tokens have not yet been issued for the use of waste methane. SBP tokens have only been issued for bitcoin mining utilising clean energy under the Greenhouse Gas Protocol Scope 2 framework.
By 2024, around 20% of the Bitcoin network’s global hashrate was signed onto the protocol, primarily led by publicly traded miners.
Institutional adoption accelerated in Q3 2023 through a partnership with leading institutional custodian Copper.co, enabling institutional investors to demonstrate climate-positive Bitcoin holdings via SBP integration. In parallel, custody partnerships with BitGo and Zodia Custody (Standard Chartered) reinforced SBP’s institutional-grade custody and operational infrastructure. In 2024, SBP was interviewed by Bloomberg at NASDAQ alongside public miner and technology company Bitdeer.
A major international expansion was achieved in Q1 2025, when SBP joined Hub71’s Digital Assets Cohort in Abu Dhabi Global Markets, marking a strategic entry into the UAE and the wider MENA region. This milestone strengthened institutional connectivity alongside key ecosystem partners, including Coinbase Asset Management and NASDAQ-listed bitcoin mining firm Bitfarms. This was further proven by the sovereign bitcoin miner of Abu Dhabi auctioning a number of their SBP tokens on the ADGM-regulated institutional platform Coinbase Project Diamond.
During 2025, SBP had onboarded mining partners representing approximately 25% of global Bitcoin hashrate, reflecting a level of adoption that substantially exceeds pilot or niche participation. This network spans five continents and more than 25 countries and includes publicly listed miners such as CleanSpark, Bitdeer, Bitfarms, and Phoenix Group, as well as sovereign entities including Zero Two in Abu Dhabi and Green Digital Limited (Kingdom of Bhutan).
SBP’s infrastructure footprint extends across the European Union, supporting bitcoin miners with data centre operations in Norway, Sweden, Finland, Italy, Germany, and Iceland, supporting regulatory alignment and operational resilience across key markets. In parallel, SBP is engaging with leading liquidity providers and market makers, including DRW Cumberland, GSR, and Wincent, to support robust secondary market development.
During the last quarter of 2025, the protocol underwent a rebranding process that resulted in changes, including the renaming of the crypto-asset from Sustainable Bitcoin Certificate (SBC) to SBP Token, as well as a change in the associated smart contract.

D.8

Description of future milestones

Future Milestones
In 2026, SBP will focus strategically on strengthening the adoption of climate-aligned Bitcoin finance. A central priority will be the refinement of SBP’s messaging framework to enhance investor understanding, transparency, and market confidence, while simultaneously deepening engagement with regulators through evidence-based dialogue.
Operational expansion will remain a core focus, with SBP targeting adoption beyond 40% of global Bitcoin hashrate. This scale will enable more advanced network-level data insights, while continuing to prioritise strict confidentiality standards and the protection of commercially sensitive information belonging to mining partners. In parallel, SBP will advance Measurement, Reporting, and Verification (MRV) standards aligned with institutional due diligence and capital markets expectations, including the development of robust methodologies for sustainable methane-based mining.
The SBP token is in the final stages of preparation for listing on Kraken, pending the completion of MiCA compliance requirements.
SBP is actively developing a wrapped Bitcoin (wBTC) and clean wrapped Bitcoin (cwBTC) product designed for integration with the Canton Network, with the technical and strategic support of their ecosystem. SBP has been formally approved to operate a validator node on the Canton Network.
Institutional Credit Integration: Coinbase has expressed interest in enabling Bitcoin miners to collateralise SBP tokens as part of their existing BTC-backed credit facilities, enhancing capital efficiency within the mining sector and synthesising sustainable finance with bitcoin lending
SBP is currently co-developing a Clean Energy Bitcoin ETP in partnership with a leading ETF issuer. The product is being structured to qualify under SFDR Article 8, targeting environmentally conscious institutional capital within the EU regulatory framework. To support these developments, SBP has received verbal seed commitments for USD 50 million in BTC/SBP tokens. The project is targeting an additional USD 50 million in seed funding and aims to secure USD 25 million in Letters of Intent (LOIs) prior to launch.

D.9

Resource allocation

Most of the resources already allocated to the project have been directed toward operational expenditures, including salaried employees, engineering development, ongoing technical operations, and marketing for the public token listing.

D.10

Planned use of Collected funds or crypto-Assets

SBP has secured, or is in the process of securing, significant financial and strategic resources to support the development of the project and the associated token ecosystem. This includes a tentative commitment of approximately USD 50 million, comprising BTC/SBP tokens These funds are intended to be allocated toward the creation of an institutional grade sustainable Bitcoin investment product such as a trust or exchange-traded product (ETP) designed to support institutional interest in sustainability-aligned digital asset infrastructure and expand access to climate-relevant Bitcoin transparency tools. This product specifically targets the EUR 5 trillion SFDR-aligned market in Europe, where an estimated 40% of investors currently remain unexposed to Bitcoin due to environmental concerns.
SBP will develop the first institutional-grade Sustainable Wrapped BTC. This product will combine Bitcoin and SBP tokens backed by granular, verified clean-energy mining data. The Sustainable Wrapped BTC is designed to be a versatile instrument enabling the launch of clean energy Bitcoin ETFs, ETPs, and trusts, or to be held directly on corporate balance sheets, particularly in jurisdictions with climate-aligned capital mandates. The initiative is expected to unlock previously sidelined institutional capital and channel it into the broader digital asset ecosystem through a climate-aligned framework. Listing SBP on regulated exchanges also facilitates broader access and visibility but the Protocol does not intervene to influence token liquidity, price, or valuation.

Part E - Information about the offer to the public of crypto-assets or their admission to trading

N	Field	Content
E.1	Public offering or admission to trading	ATTR
E.2	Reasons for public offer or admission to trading	The admission to trading of SBP is to enhance market visibility and broader investor participation to strengthen the credibility and recognition of SBP. Listing SBP on exchanges will increase liquidity and improved price discovery make SBP a more attractive asset, enhancing market confidence and valuation. The listing supports stronger incentives for miners aligned with institutional and ESG objectives, positioning SBP as a recognised sustainability solution and protocol growth and new revenue opportunities arise through trading activity and exchange listings.
E.3	Fundraising target	N/A
E.4	Minimum subscription goals	N/A
E.5	Maximum subscription goals	N/A
E.6	Oversubscription acceptance	N/A
E.7	Oversubscription allocation	N/A
E.8	Issue price	N/A
E.9	Official currency or any other crypto-assets determining the issue price	N/A
E.9	Official currency or any other crypto-assets determining the issue price	N/A
E.10	Subscription fee	N/A
E.11	Offer price determination method	N/A
E.12	Total number of offered/traded crypto-assets	5215 - The upper bound in the asset count is given by SBP’s total supply, which is set at 21 million SBP. At the time of writing this white paper, the circulating supply is at 5,215 SBP.
E.13	Targeted holders	ALL
E.14	Holder restrictions	Access to the website and dApps is restricted to individuals who are 18 years of age or older. Users are prohibited from accessing or using the website or dApps if they are subject to economic sanctions, trade restrictions, or are otherwise barred under applicable laws and regulations. The availability of certain products or services may be restricted or unavailable in specific jurisdictions, subject to local legal and regulatory requirements. Access may be denied where such offerings are not permitted by law.
E.15	Reimbursement notice	N/A
E.16	Refund mechanism	N/A
E.17	Refund timeline	N/A
E.18	Offer phases	N/A
E.19	Early purchase discount	N/A
E.20	Time-limited offer	False
E.21	Subscription period beginning	N/A
E.22	Subscription period end	N/A
E.23	Safeguarding arrangements for offered funds/crypto-Assets	N/A
E.24	Payment methods for crypto-asset purchase	N/A
E.25	Value transfer methods for reimbursement	N/A
E.26	Right of withdrawal	N/A
E.27	Transfer of purchased crypto-assets	N/A
E.28	Transfer time schedule	N/A
E.29	Purchaser's technical requirements	N/A
E.30	Crypto-asset service provider (CASP) name	Not Available
E.31	CASP identifier	N/A
E.32	Placement form	NTAV
E.33	Trading platforms name	Kraken
E.34	Trading platforms Market identifier code (MIC)	PESL
E.35	Trading platforms access	Investors can access trading on Kraken by registering an account through the website or mobile application. Account creation requires completion of identity verification (KYC/AML) and compliance with age and jurisdictional eligibility criteria. Once verified, investors may fund their accounts and trade through the trading platform’s spot market infrastructure.
E.36	Involved costs	Exchanges may apply a service fee calculated as a percentage of each transaction, with the exact amount disclosed to the user prior to execution. Deposits and withdrawals involving fiat currency may also be subject to additional commissions imposed by external payment service providers. Kraken applies a fixed 1% trading fee for instant buy, sell, or convert transactions executed via its standard interface, with spreads incorporated into the quoted execution price. Additional payment processing fees may apply depending on the selected funding method (e.g. card payments, bank transfers), and deposit and withdrawal fees vary according to the currency and payment rail used.
E.37	Offer expenses	This field does not apply, as there is no offer to the public.
E.38	Conflicts of interest	There are no conflicts of interest arising at the moment of writing the white paper in relation to admission to trading.
E.39	Applicable law	Ireland
E.40	Competent court	Ireland

Part F - Information about the crypto-assets

N	Field	Content
F.1	Crypto-asset type	Crypto-assets other than asset-referenced tokens or e-money tokens
F.2	Crypto-asset functionality	SBPs connect the Bitcoin network with the global renewable energy market. Unlike traditional energy credits, which expire after use, SBPs tokenise renewable energy data from sustainably mined Bitcoin and function as perpetual assets linked to Bitcoin’s decentralised energy infrastructure. SBP token provides transparent, data-backed environmental information, enabling users to assess and track the climate impact associated with their participation. SBP offers a simplified and intuitive framework for environmental accounting using Greenhouse Gas Protocol standards and ensures no double-counting of renewable energy claims, allowing investors to easily understand, track, and report the sustainability impact of their holdings. SBPs are digital certificates that represent verified clean energy usage associated with Bitcoin mining. While the market may assign value to these attributes, SBPs do not confer financial rights or investment returns, and their price is determined solely by market participants. This mechanism happens by anchoring an intrinsic value to Bitcoin’s average per-BTC energy consumption (X MWh) multiplied by the prevailing price of high-quality EACs ($Y/MWh), so the cost to create an SBP rises, as the network energy consumption rises, directing more capital into clean-energy markets.
F.3	Planned application of functionalities	To ensure integrity and scalability, SBP is working toward automating the verification of miners’ energy usage. The planned MRV system will use direct API integrations, smart meters, and third-party audits to confirm that Bitcoin was mined using verified clean energy sources. The Protocol states that this data will be tied to global standards such as the GHG Protocol Scope 2, and when possible will be aggregated, anonymised, and published for public benefit.
F.4	Type of crypto-asset white paper	OTHR
F.5	The type of submission	NEWT
F.6	Crypto-asset characteristics	SBP is an ERC-20 tokenised environmental commodity issued on Base, an Ethereum Layer 2. Designed to represent measurable climate-positive impact in Bitcoin mining, SBPs are valued based on market demand for clean energy attribution and do not guarantee appreciation or financial performance. SBPs are created in two ways: either when miners prove that they use clean energy to mine Bitcoin, or when the protocol purchases and retires EACs equivalent to the energy (MWh) used in Bitcoin mining in present time. In both cases, issuance ensures that each certificate represents a measurable and verifiable clean energy claim, thereby directing capital into renewable energy markets and reinforcing a self-sustaining cycle of climate-positive impact. SBPs are transferable through Ethereum-compatible wallets, decentralised applications, regulated centralised exchanges and OTC platforms. By backing renewable energy in Bitcoin mining, SBP holders actively support the clean energy transition. As an environmental commodity tied directly to Bitcoin, SBPs constitute a digital asset class that combines innovation in crypto-assets with sustainability objectives. SBPs have a partially fixed supply. Tokens issued to Bitcoin miners are limited by the remaining coinbase rewards, currently less than 1.6 million, creating a natural cap. Nevertheless, additional SBPs can be created by purchasing and retiring RECs or other environmental credits, with each extra SBP representing a specific amount of clean energy. This mechanism designated ‘Protocol-Initiated Issuance’ or ‘Synthetic Minting’ allows the overall SBP supply to grow beyond miner-issued tokens while remaining linked to an equivalent bound based on Bitcoin’s 21 million cap, making it flexible enough to meet investor demand while offsetting the historical energy footprint of the Bitcoin network. In its previous phase, the crypto-asset operated under the name SBC. During that period, the crypto-assets were issued and operated through the smart contract deployed at address 0x6A781A8A7DCBc99223F130EbaA4dec6e93C5C130. Following the rebranding to SBP Token, SBC tokens were permanently burned and an equivalent number of SBP Tokens were re-minted. This transition involved the deployment of a new smart contract. The SBP Token is currently deployed on the BASE Mainnet under the contract address 0x7d5411Da3a86395397369e94Aff65f4b77Ad4112. This was a name change only, the underlying methodology and verification framework remained unchanged.
F.7	Commercial name or trading name	Sustainable Bitcoin Protocol
F.8	Website of the issuer	https://www.sustainablebtc.org/
F.9	Starting date of offer to the public or admission to trading	2026-03-28
F.10	Publication date	2026-03-27
F.11	Any other services provided by the issuer	SDS limited does not currently provide any other services.
F.12	Language or languages of the crypto-asset white paper	English
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, where available	Not Available
F.14	Functionally fungible group digital token identifier, where available	Not Available
F.15	Voluntary data flag	FALSE
F.16	Personal data flag	TRUE
F.17	LEI eligibility	TRUE
F.18	Home Member State	Ireland
F.19	Host Member States	Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Iceland, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden

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

N	Field	Content
G.1	Purchaser rights and obligations	Not applicable as there is no legal or smart-contract governing how the asset-holders may hold or use the crypto assets. Regulatory Disclaimer The SBP Token is not a financial instrument, security, or investment product. It does not offer profit-sharing, capital guarantees, dividends, or ownership rights. References to market value or demand relate to environmental certificate attributes and do not imply any investment return.
G.2	Exercise of rights and obligations	This field does not apply as the token confers no ownership or financial claims.
G.3	Conditions for modifications of rights and obligations	This field does not apply as the token confers no ownership or financial claims.
G.4	Future public offers	There are no future public offerings planned at the moment of writing the white paper.
G.5	Issuer retained crypto-assets	0
G.6	Utility Token Classification	FALSE
G.7	Key features of goods/services of utility tokens	N/A
G.8	Utility tokens redemption	N/A
G.9	Non-trading request	TRUE
G.10	Crypto-assets purchase or sale modalities	N/A
G.11	Crypto-assets transfer restrictions	None. Trading platforms may of their own accord impose restrictions on buyers and sellers of these tokens.
G.12	Supply adjustment protocols	TRUE
G.13	Supply adjustment mechanisms	SBP Tokens may be issued through two distinct mechanisms: 1. Primary Issuance: Based on verified clean energy use in Bitcoin mining. 2. Protocol-Initiated Issuance: Where third parties finance the retirement of certified Renewable Energy Certificates (RECs) equivalent to the energy used to mine one Bitcoin, based on a transparent methodology and governance framework. Protocol-Initiated Issuance is not triggered by price, liquidity, or trading conditions, and does not constitute a stabilisation mechanism. It is designed to accommodate verified climate-positive demand that cannot be met by the miner issuance pipeline, without reference to market valuations. All issuance events are subject to approval, REC verification, public disclosure, and issuance caps. SBP Tokens issued via either pathway are fungible and carry identical characteristics. The calculation of the REC quantity per token follows a five step methodology based on Bitcoin network energy consumption data from the Cambridge Centre for Alternative Finance Bitcoin Electricity Consumption Index. For example, as of 23 January 2026, the annualised Bitcoin network energy consumption is 196 TWh, which converts to 196,000,000 MWh. Dividing this by 365 gives a daily network consumption of 536,986 MWh. With 450 BTC currently mined per day, each Bitcoin requires 1,193 MWh of energy, which determines the REC requirement per SBP Token. This calculation is updated daily to reflect current network energy usage and adjusted for Bitcoin halving events, which reduce daily BTC issuance and proportionally increase the REC requirement for synthetic minting. All RECs used for Protocol-Initiated Issuance must meet recognised certification standards, be generated within 24 months prior to retirement, and not have been previously used for any other environmental claim, carbon offset, or regulatory compliance obligation. To maximise environmental impact, RECs are sourced from grids with the highest carbon intensity, and all retired certificates are publicly recorded with detailed information including registry serial number, generation facility, location, grid region, carbon intensity, quantity retired, and the corresponding number of SBP Tokens minted. SBP Tokens issued through Protocol-Initiated Issuance are fully fungible with miner-issued tokens, carrying identical rights and environmental claims. For transparency, aggregate statistics are published distinguishing primary issuance from Protocol-Initiated Issuance, and on-chain metadata records the issuance pathway for each token batch. This mechanism allows SBP to respond to market demand while maintaining environmental integrity and transparency, ensuring both orderly trading and alignment with sustainable investment expectations.
G.14	Token value protection schemes	FALSE
G.15	Token value protection schemes description	Not applicable. The SBP Protocol does not implement any value protection, price stabilisation, redemption mechanism, or liquidity facility. SBP Tokens are issued either: through the verification of clean energy usage in Bitcoin mining, or through ProtocolInitiated Issuance, whereby third parties finance the retirement of eligible Renewable Energy Certificates (RECs) based on publicly disclosed environmental criteria. This issuance mechanism does not aim to influence token price, market liquidity, or valuation. It is not triggered by market conditions such as trading volume, bid-ask spreads, volatility, or market-maker demand. SBP does not guarantee a price floor, redemption right, or backstop liquidity for SBP Tokens under any circumstances. The issuance of new SBP Tokens, whether through miner verification or REC retirement, is solely determined by environmental and governance criteria and does not constitute a token value protection scheme as defined under Article 6(5)(d) of Regulation (EU) 2023/1114.
G.16	Compensation schemes	FALSE
G.17	Compensation schemes description	This field does not apply as G.16 is false.
G.18	Applicable law	There is no written legal agreement between the issuer and the crypto asset holder that sets out the laws that govern the legal relationship between those two parties. In the absence of such an agreement, the laws that govern that relationship will depend on the location of the issuer and the given crypto asset holder and characteristic performance of the legal relationship, and any agreed intention of the issuer and crypto asset holder.
G.19	Competent court	There is no written legal agreement between the issuer and the crypto asset holder that sets out which jurisdiction's courts will have authority to deal with a dispute between the crypto asset holder and the issuer. In the absence of such an agreement, the laws that competent court will depend on the location of the issuer and the given token-holder and characteristic performance of the legal relationship, and any agreed intention of the issuer and crypto asset holder.

Part H – Information on underlying technology

N	Field	Content
H.1	Distributed ledger technology	SBP token is recorded and transferred on Base Mainnet, an Ethereum Layer-2 built on the OP Stack. Base batches transactions and posts state commitments to Ethereum Layer-1 using an optimistic-rollup design. The network is public: anyone can read chain data and submit transactions via standard RPC endpoints. Transaction ordering is handled by Base’s sequencer, while final settlement is anchored to Ethereum. Base uses the EVM’s account-based model. SBP balances are stored inside the token smart contract for each address; transfers update that on-chain state and emit ERC-20 events that provide an auditable history. Transactions execute in the EVM with deterministic, gas-metered semantics. SBP token transfers pay gas in ETH on Base. Additionally, transactions and logs are publicly readable; addresses use the standard Ethereum format and work with common EVM wallets.
H.2	Protocols and technical standards	Token interface (primary standard) SBP follows the ERC-20 standard. Wallets and exchanges can read balances, send tokens, and manage spend approvals using the usual functions (balanceOf, transfer, approve, transferFrom). Transfers and approvals emit the standard Transfer and Approval events so tools can track activity. Execution environment (Base, EVM-equivalent) All SBP calls execute on Base Mainnet’s Ethereum Virtual Machine (EVM) (chainId 8453). Transactions are deterministic and gas-metered; users pay gas in ETH on Base. Addresses use the standard Ethereum format and signatures follow the usual Ethereum/EIP-155 rules. External interfaces and tooling Interaction uses standard EVM JSON-RPC endpoints and ABI encoding, so SBP works with common wallets, custodians, explorers, indexers, and analytics. Event logs provide an auditable history that indexers can consume without custom adapters. Execution environment Smart contracts and token logic for SBP execute within the EVM. The EVM is described as a decentralised virtual environment that runs consistently across all Ethereum nodes, treating the blockchain as a state machine whose evolution is determined by a well-specified state transition function. Contracts have persistent storage organised as Merkle-Patricia tries associated with their account, and execution is driven by opcodes that operate on a 256-bit stack, transient memory and storage. Because Base is an EVM-equivalent rollup, the same execution rules apply on Base as on Ethereum, so SBP can use standard ERC-style token contracts and tooling, and any node implementing the Ethereum execution specification can, in principle, validate SBP token transactions on Base once it understands the rollup data. Networking and serialisation Base operates as an Ethereum layer-2 network, exposing standard JSON-RPC endpoints and chain identifiers so that wallets and applications can connect using the same client stacks they use for Ethereum. Ethereum, which underpins Base, maintains its global state as a large data structure organised as a modified Merkle Patricia trie. In this model, all accounts are linked by hashes and reducible to a single state root stored on-chain, providing a compact commitment to the full set of account balances and contract storage entries. State transitions are described in terms of a function that takes a prior state and a set of transactions and deterministically produces a new state, with the tree structure ensuring that any change in underlying data yields a different root. Cryptography and key formats EVM executes smart-contract code as a stack machine where each item on the stack is a 256-bit word. The word size is chosen for compatibility with 256-bit cryptographic primitives such as Keccak-256 hashes and secp256k1 signatures. This implies that externally owned accounts interacting with SBP contracts on Base use Ethereum-style elliptic-curve cryptography for transaction signing, with addresses derived from public keys and expressed as hexadecimal values. These cryptographic primitives provide message authentication for transactions and form the basis for the account model that SBP relies on when issuing, transferring and retiring SBP tokens on Base.
H.3	Technology used	Implementation and architecture SBP’s technology stack separates the verification of clean-energy Bitcoin mining from on-chain representation, while using Base and Ethereum as the settlement infrastructure. On the environmental and data side, SBP invites miners or mining pools to submit operational data, including energy-consumption information and evidence of clean-energy sourcing, together with access to mining-pool APIs that expose realised Bitcoin rewards. The protocol cross-checks these data feeds and applies its rules so that SBP tokens are issued proportionally to the share of a miner’s rewards that are backed by verified clean energy. SBP token balances can reflect fractional Bitcoin production down to eight decimal places, and each SBP itself is divisible into one hundred million 'Kyotos', so that climate-aligned production can be represented at satoshi-level granularity. The on-chain component of this architecture uses Base, as the primary execution environment for the SBP token. The execution client hosts EVM, maintains state and transaction pools, while the consensus client maintains the proof-of-stake beacon-chain state, runs the fork-choice algorithm, and gossips blocks and attestations across its own peer-to-peer network. These two clients communicate locally via the Engine API so that consensus drives block inclusion while execution enforces state transition rules. Base builds on this model by running OP Stack components that sit on top of Ethereum, allowing SBP token contracts deployed on Base to inherit Ethereum’s consensus and data-availability guarantees once Base batches are posted to Ethereum L1. Node roles in this stack reflect the different responsibilities on Ethereum and Base. On Ethereum, a full node combines an execution client with a consensus client, and operators who also run validator software and stake ETH can participate directly in block proposal and attestation, thereby contributing to consensus and earning rewards or penalties under proof-of-stake rules. On Base, a node likewise consists of a consensus client, such as op-node, and an execution client that processes user transactions, constructs blocks, and serves RPC calls. Block construction on Base is driven by the sequencer stack, which uses these OP Stack components to order transactions and produce layer-2 blocks, while other Base nodes focus on validating chain data and providing RPC access rather than proposing new blocks in the Ethereum-validator sense. The Base core team currently treats Geth as the canonical OP Stack execution client, while also supporting Reth and Nethermind, and is working towards a multi-execution-client design for both sequencing and validation. This creates some client diversity on Base while still remaining within the OP Stack family of implementations. Runtime and build characteristics SBP’s contract runtime follows the EVM execution model as implemented on Base, so that the SBP token behaves like any other EVM-based asset from an application perspective. The EVM is responsible for executing smart contracts deterministically across all nodes. It operates as a stack-based virtual machine that processes bytecode instructions, maintains a global state of accounts and contracts, and charges “gas” for each operation to bound computation and storage usage. These characteristics ensure that SBP token contracts deployed on Base execute under the same deterministic state-transition rules as other EVM contracts, with balances, transfers, and event logs updated as part of the standard block-processing pipeline. As a result, SBP can use common Ethereum tooling such as Solidity compilers, testing frameworks, and deployment scripts to build, test, and deploy its contracts on Base without requiring a bespoke virtual machine or execution environment. Base introduces rollup-specific runtime behaviour on top of this EVM model while keeping application-level semantics close to Ethereum. Transactions sent to Base pass through a four-stage lifecycle for finality. First, they are included in a preconfirmation block known as a Flashblock by the Base sequencer, typically after roughly 200 milliseconds; this stage provides rapid feedback with a very low probability of reorganisation. Second, after around two seconds, the sequencer builds the transaction into an L2 block and distributes it to validator nodes, further reducing reorg risk. Third, after roughly two minutes, a batch of Base L2 blocks containing the transaction is posted to Ethereum L1, providing an effectively irreversible record under normal conditions. Finally, once the batch has aged beyond two Ethereum epochs, it is treated as practically final from a security perspective. Flashblocks and the associated preconfirmation RPC endpoints allow applications to observe near-real-time transaction ordering, while the later stages tie SBP token activity on Base into Ethereum’s proof-of-stake finality.
H.4	Consensus Mechanism	SBP does not introduce a separate consensus mechanism; instead, the SBP token inherits its ordering, execution and finality properties from Base and, by extension, from Ethereum’s proof-of-stake consensus. Ethereum uses a Proof-of-Stake consensus mechanism implemented by the beacon chain and specified in the Ethereum consensus specifications. Time on the consensus layer is divided into slots and epochs. In each slot, a validator is selected to propose a block, while a committee of other validators is responsible for attesting to its validity. Selection is pseudo-random and weighted by each validator’s effective stake, which is ETH deposited into the consensus system. This structure provides Sybil resistance and ensures that validators have economic exposure to the consequences of their behaviour. At each slot, the selected proposer assembles a block that includes references to the head of the canonical chain according to the fork-choice rule, along with attestations and, where applicable, execution-layer payloads. Attesters in the assigned committee evaluate the block and vote for it by signing an attestation that includes the block root and source and target checkpoints. These attestations are aggregated and included in subsequent blocks, providing evidence of the validator set’s support for specific chain heads. The fork-choice rule, based on the Latest Message Driven Greediest Heaviest Observed SubTree (LMD-GHOST) algorithm, selects the chain head that has accumulated the highest weight of attester votes. Finality is provided by a separate overlay known as Casper Friendly Finality Gadget (Casper FFG). In Casper FFG, epochs serve as the unit for finality, and validators vote on pairs of checkpoint blocks. When sufficient votes are received for a checkpoint pair, the target checkpoint becomes justified, and once a justified checkpoint is followed by another justified checkpoint, it becomes finalised. Finalised checkpoints are extremely unlikely to be reverted, except under conditions where a large portion of the stake behaves maliciously and is subject to slashing. Safety thresholds are set so that reverting a finalised block requires at least one-third of the total stake to violate protocol rules, which would result in significant economic penalties.
H.5	Incentive Mechanisms and Applicable Fees	Network-level fees Each Base transaction involving SBP, whether a simple token transfer or a more complex contract interaction, comprises two distinct fee components: an L2 execution fee and an L1 security fee. The L2 execution fee reflects the cost of executing the transaction within Base’s EVM environment. The L1 security fee reflects the estimated cost of publishing the transaction on Ethereum mainnet as part of an aggregated batch. This two-part structure explicitly prices computation on the L2 and data publication on the L1 separately. In practice, the L1 security fee is typically higher than the L2 execution fee, because writing data to Ethereum is often more expensive than computing it on Base. The L1 component varies with congestion and gas prices on Ethereum, while the L2 component varies with activity on Base itself. Participants can lower the total cost of SBP-related transactions by submitting them during periods of lower Ethereum gas prices, which directly reduces the L1 security-fee component, while the L2 component continues to track load on the Base network. In combination, these mechanics ensure that SBP activity bears both the cost of computation on Base and the cost of anchoring that activity to Ethereum’s security and data-availability layer. Miner Incentives SBPs serve as the primary protocol-level incentive for Bitcoin miners to adopt and use verified clean energy in their operations. Miners voluntarily submit data to SBP, including granular energy consumption, hashrate and mining pool earnings, and evidence of clean energy use such as through the procurement of renewable energy certificates. SBP then verifies and analyses this data to confirm that every MWh of energy used is backed by unique and exclusive clean energy claims, in line with SBP's requirements. Upon successful verification, miners are issued 1 SBP for each Bitcoin mined with verified clean energy, or equivalently 1 Kyoto per satoshi. This issuance is proportional to the verified clean portion of the miner's Bitcoin rewards, ensuring SBPs are only created for measured positive environmental impacts from clean mining. To earn SBPs, miners must undergo an audit of their energy use to prove compliance with clean energy standards. SBPs provide a financial incentive because miners can sell them separately to ESG-driven investors or companies seeking climate-positive Bitcoin exposure, in addition to retaining their mined BTC. This creates a dual-asset balance sheet for miners, where SBPs act as a monetisable proof of sustainable mining without compromising Bitcoin's fungibility. Protocol-level fees Base introduced a minimum base fee with the Jovian upgrade, establishing a lower bound for the L2 base fee so that it does not fall to negligible levels during periods of low network utilisation. On Base mainnet, this minimum base fee is set to 500,000 wei, equivalent to 0.0005 gwei. Base provides an illustrative reference indicating that, at an ETH price of USD 3,000, this level of base fee contributes roughly 0.015 US cents to the cost of a typical transaction. By enforcing a non-zero minimum, the mechanism improves transaction inclusion times, makes L2 fees more predictable in quiet periods and reduces the economic incentive to submit spam or other abusive transaction patterns. For SBP users, this implies that even low-value operations, such as straightforward SBP token transfers, are subject to at least this minimum L2 fee, while remaining inexpensive in absolute terms. The minimum base fee applies only to the L2 component; the L1 security fee remains an additional element of the total cost and can dominate overall transaction expense when Ethereum gas prices are elevated. In addition, the SBP protocol applies a 5% issuance fee upon minting SBP tokens for verified clean-energy mining rewards. For example, if a miner verifies 10 BTC mined with clean energy, the protocol retains 0.5 SBP tokens (or equivalent Kyotos), while the miner receives the remaining 9.5 SBP tokens. This retained portion supports protocol operations and sustainability. There are no additional protocol-level fees charged to miners for submitting data or receiving SBPs; the incentive is derived solely from the value and salability of the issued SBPs. The total SBP supply is constrained by Bitcoin's remaining coinbase rewards, with SBPs only issuable for clean-energy-mined portions.
H.6	Use of distributed ledger technology	FALSE
H.7	DLT functionality description	N/A
H.8	Audit	TRUE
H.9	Audit outcome	Hacken’s SBP Token smart contract audit 2026 The SBP Token smart contract underwent an independent Smart Contract Code Review and Security Analysis conducted by Hacken OU, completed on 17 February 2026. The audit covered the deployed Base Mainnet contract (SBPToken.sol), including: - ERC-20 capped supply implementation (21,000,000 token cap, 8 decimals) - Owner-controlled minting logic and Bitcoin block height association. - Burn functionality - ERC20Permit (EIP-2612) implementation - Access control and ownership mechanics - Data structure integrity relating to Bitcoin block height tracking. The final audit report identified: - 0 Critical findings - 0 High findings - 0 Medium findings - 1 Low-severity finding (resolved) - 6 Informational findings (resolved) All findings were remediated prior to finalisation of the audit. The remediation was verified by Hacken and incorporated in commit bed633f of the public repository which can be found here: [https://github.com/SustainableBTC-org/sbc-token]. No outstanding vulnerabilities were identified in the final audited version. The full audit report is attached as Annex I.

Part I - Information on risks

N	Field	Content
I.1	Offer-related risks	Standard trading risks Pricing volatility: SBPs may experience substantial price fluctuations. While there is a highlight of the link between SBP token value and Bitcoin’s energy consumption, this also means SBP tokens valuations are exposed to Bitcoin price volatility, hash rate variability, regulatory shifts in energy or crypto markets, and broader macroeconomic/geopolitical factors. SBP relies on EAC markets, to validate clean energy usage. This dependency may create a risk that crossliquidity or settlement issues in these markets could disrupt the verification process and, in turn, affect the issuance of SBPs. Liquidity conditions: Market liquidity may be limited, particularly in early adoption phases. This could result in difficulty buying or selling SBPs without price concessions. Liquidity may also be affected by clustered issuance linked to miner data submissions and verification cycles. The most common issuance occurs monthly due to the standardisation of electric utility invoice data, potentially causing liquidity spikes, though this is addressed through more granular data ingestion Irreversibility of transactions SBPs are issued and transferred on Base. As with other blockchain-based assets, transactions are generally immutable once confirmed, meaning they cannot easily be reversed or modified. While legal or regulatory remedies may exist in certain circumstances, technical constraints and reliance on private key control can limit the practical ability to reverse specific transactions, similar to the characteristics of other digital or cash-based payment systems. Market demand The adoption of SBPs depends on miners submitting verified energy data and institutional investors seeking ESG-aligned Bitcoin exposure. If adoption is slower than expected, market depth and long-term utility could be negatively affected. Impact of large transactions Large transfers or disposals of SBPs, particularly by major miners or institutional holders, could materially impact market pricing and stability. Broader economic conditions Global economic downturns, energy price fluctuations, or instability in crypto markets may reduce demand for SBPs and limit capital inflows to the protocol. Exchange access and listing risk Access to secondary markets depends on the policies and operational frameworks of centralised exchanges (CEXs) and over-the-counter (OTC) venues. Listing decisions, trading pairs, and geographic availability may change over time, which could influence liquidity, price discovery, and user access. Platform requirements related to onboarding, custody, and compliance procedures may also affect participation. Key custody and operational security Loss or compromise of private keys leads to permanent loss of control over assets and rewards.
I.2	Issuer-related risks	Operational integrity The reliability of SBP tokens is supported by SBP’s internal frameworks for energy data collection, verification, and issuance. These processes are designed to promote accuracy and robustness, although continuous monitoring and refinement are important to adapt to evolving operational and technological requirements. Governance practices SBP operates under a governance structure involving a board of directors, shareholders, and appointed officers. This framework aims to ensure oversight, accountability, and strategic alignment, while also recognising the importance of balanced decision-making, transparency, and resilience to organisational and operational challenges. Regulatory Risks The regulatory environment for crypto-assets is developing and subject to rapid change. New laws or enforcement actions could materially impair the use, liquidity, or legality of SBP.
I.3	Crypto-assets-related risks	Liquidity Risks SBPs are tradable via CEX/OTC markets, but secondary-market liquidity may be limited, especially in early phases. This may result in difficulty buying or selling SBPs without incurring significant price concessions. Uninsured Losses Tokens held on the protocol are not protected by any deposit insurance or public guarantee schemes. Holders bear the full risk of loss from custody failures, hacks, or insolvencies. Private Key Management Risks SBPs are ERC-20 tokens minted on Base. Like other Ethereum-based assets, access depends on the secure management of private keys. Loss, theft, or mismanagement of these keys may result in the permanent loss of access to SBPs. This also applies to miners who previously used Stacks wallets linked directly to Bitcoin addresses, as the migration to Base requires adapting to new wallet infrastructure and managing Ethereum-compatible credentials, which may involve an initial learning curve for some users. Custodial Risks Holders may rely on third-party custodians for private key management. While custodians provide convenience and compliance, they introduce failures, hacks, or mismanagement at the custodian level that could lead to loss of SBPs.
I.4	Project implementation-related risks	Development and Operational Risks - Technology integration and change risk: SBP relies on the interaction of several technical components: off-chain data collection and verification of miners’ energy and operations data, systems that translate this information into SBPs, and on-chain infrastructure on Base for representing and transferring the SBP token. Any substantial upgrade to these components, or to the underlying Base and Ethereum infrastructure, may require non-trivial smart-contract changes, data-pipeline adjustments, or integration of additional services. Such work can introduce the risk of project delays, increased development and operational expenditure, or unforeseen technical failures during deployment or subsequent updates. - Quality Assurance: Despite testing, software bugs, security vulnerabilities, or oracle malfunctions could emerge in the smart contracts or supporting dApp infrastructure. These risks may compromise SBP issuance, verification accuracy, or token-holder access. Dependency on third parties risks The SBP ecosystem relies on participation from miners for energy data provision, on EAC registries for certificate validation, and on CEX and OTC venues to support secondary market liquidity. Changes in the operational frameworks, technical capabilities, or policies of these counterparties may influence issuance, market access, and adoption dynamics. Market Penetration risks SBP’s growth is linked to achieving visibility within sustainability-oriented crypto and digital asset markets. Competitive dynamics, regulatory developments, and communication strategies may influence adoption trajectories. As SBP token represents an innovative approach to linking environmental attributes with Bitcoin-related activity, market reception and valuation may evolve over time as participants become more familiar with the model.
I.5	Technology-related risks	Owner-key exposure on minting SBP token uses owner-gated minting; compromise or misuse of the ownership key could enable unauthorised mints up to the hard cap, undermining supply integrity and market trust. Supply-cap and decimals correctness Bugs in cap enforcement or 8-decimal arithmetic could corrupt supply/accounting or break integrator assumptions about balances and totals. ERC-20 allowance race Replacing a non-zero allowance can be front-run, allowing a spender to transfer more than the holder intended. Immutable implementation A non-proxy contract avoids upgrade risks but cannot be patched in place; a defect would require migration to a new contract. Event/log reliance for provenance Explorers and indexers reconstruct history from events. Log gaps, reorg handling, or third-party outages can slow reconciliation even when on-chain state is correct. L2 withdrawal finality and delay On Base, withdrawals are proven on L1 then finalised only after a fixed challenge period. Users may misinterpret “proven” as “final,” creating settlement risk during the waiting window. Sequencer downtime or censorship If the L2 sequencer stalls or censors transactions, inclusion can be delayed until forced-inclusion paths are used. Forced-inclusion operational complexity Submitting transactions via forced paths during sequencer incidents requires specific steps and timing; operator error can prolong inclusion. Fault-proof and rollup-security assumptions Fault proofs improve security but withdrawals still depend on correct proof operation and challenge-window configuration; implementation or configuration bugs could affect finality. Canonical bridge and portal-contract dependency Deposits and withdrawals depend on OP Stack bridge and portal contracts; upstream defects or unexpected upgrades could affect users’ ability to move assets. L1 dependency and posting cadence Delays posting L2 outputs to Ethereum can extend the time to prove/finalise withdrawals, disrupting operational timelines. RPC/indexer/explorer outages Public endpoints can fail or lag, making balances appear stale or interrupting user experience even when chain state is healthy. Relayer liveness in withdrawal proving The L1 proving step relies on relayers; if no relayer submits proofs promptly, withdrawals take longer. Tooling and library assumptions on OP Stack SDKs, wallets, or bots that assume Ethereum-mainnet semantics can mis-handle OP Stack specifics (challenge windows, forced paths), causing integration errors. Smart Contract Risk While the SBP Token smart contract has been independently audited by Hacken OU and no critical, high, or medium-severity vulnerabilities were identified in the audited version, no audit can guarantee the complete absence of vulnerabilities, bugs, or unforeseen design limitations. The audit reflects the state of the code at the time of review. Any subsequent modifications may require additional review. Interaction with blockchain-based smart contracts carries inherent technological and operational risks.
I.6	Mitigation measures	Offer-Related Risks Volatility: In the event of significant price volatility, the protocol may algorithmically adjust SBP issuance by allocating additional verified clean energy, helping to maintain a balanced supply and stabilise the asset’s market dynamics. Key custody and operational security: SBP’s partnership with Zodia Custody, DRW Cumberland, and other institutionalgrade digital asset custodians, in addition to the planned listing of SBP tokens on Kraken, both MiCAregulated CASPs offering cryptoasset custodial services, provides SBP holders with robust key management and operational support solutions. Issuer-Related Risks Decentralisation: The migration of SBP tokens from Stacks to Base broadened the project’s infrastructure from a more specialised ecosystem to Ethereum’s global Layer 2 environment. This transition enhances decentralisation by leveraging a widely distributed network with deeper liquidity, broader developer participation, and increased user adoption. Governance Practices: SBP embeds safeguards within its corporate structure to mitigate concentration risks and promote accountability. These include shareholder rights to convene special meetings, quorum and consent mechanisms, the ability of shareholders and directors to amend bylaws. Collectively, these measures aim to reduce unilateral decisionmaking risks while anchoring SBP token within a decentralised technical and institutional framework. Partnership Diversification: SBP has expanded its network to include private, publiclytraded, and sovereign mining operators, to broaden the sources of verified cleanenergy data and supports the scalability and resilience of SBP token issuance. In parallel, SBP’s participation in Hub71’s Digital Assets Cohort in Abu Dhabi expands its institutional footprint, facilitating engagement with ecosystem partners such as Coinbase, Standard Chartered Ventures, and Mubadala, and strengthening access to the MENA region. Regulatory engagement: SBP manages crossborder regulatory considerations by actively pursuing admission to trading on EUregulated venues such as Kraken. This process ensures that SBP issuance and trading are aligned with evolving EU cryptoasset regulations. In parallel, SBP anchors its sustainability claims in widely accepted international frameworks, the Greenhouse Gas Protocol Scope 2, SFDR Article 9, and RE100, which strengthens compatibility with EU disclosure requirements and mitigates the risk of regulatory pushback. Crypto-Assets-Related Risks Market Education: SBP provides transparent reporting by immutably collecting miners’ energy usage data and SBP issuance records, in addition to providing learning sources publicly available on website and on demand to help holders and investors understand the link between SBPs and verifiable clean energy and risks related such as those specific to ProtocolInitiated Issuance mechanism. Private key and custody management: SBP has partnered with Fireblocks, Zodia Custody, DRW Cumberland, Wincent, and other institutionalgrade digital asset custodians and prime brokerage platforms. These platforms provide segregated custody, secure wallet infrastructure, and compliancegrade processes, reducing the risk of loss from mismanagement or cyberattacks. Project Implementation-Related Risks Dependency on third parties: The strategic partnership and investment from Wincent helps SBP strengthen resilience against minerrelated disruptions to token issuance and verifiable cleanenergy data supply by enhancing miners’ financial stability and operational capabilities. The partnership provides miners with liquidity solutions, cashflow management tools, and marketcycleresilient treasury strategies. This support enables SBP to maintain a more reliable issuance process and broader investor confidence, while fostering alignment with sustainable investment standards. Community Engagement: Expansion with institutional partners through membership in the Hub71 Digital Assets Cohort, signal intent to strengthen market community links and support broader community exposure and institutional dialogue. Transparency: SBP communicates material changes to users through email, SBP website postings, and dApps, with user consent required for continued access. Technology-Related Risks Code Review Process: Migration to Solidity contracts offers access to broader developer tooling, supporting stronger code review practices. Data Ingestion and Verification Upgrades: SBP is updating its offchain data architecture to include power meter APIs, expanded mining pool API functions, and EAC settlement integrations. This counters risks like clustered issuance delays by enabling nearrealtime verification and more predictable token minting, improving reconciliation during Base chain reorgs or explorer outages. FaultProof and Security Assumptions on Base: SBP inherits Base's multiclient execution support for sequencing and validation, promoting client diversity to prevent bugs in faultproof systems or challenge windows. This addresses withdrawal finality delays by tying SBP activity to Ethereum's proofofstake safety thresholds, where reverting finalised blocks requires slashing at least onethird of staked ETH. Interoperability and Scalability: Migration to Base improves access to Ethereum’s ecosystem, enhancing interoperability and liquidity. Oracle integration for BTC verification is a critical step in addressing crosschain functionality.

Part J - Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts

N

Field

Content

S.1

Name

Sustainable Bitcoin Solutions Limited

S.2

Relevant legal entity identifier

9845007BB086A966CC97

S.3

Name of the crypto-asset

SBP Token

S.4

Consensus Mechanism

Proof-of-Stake (PoS)

S.5

Incentive Mechanisms and Applicable Fees

See H.4

S.6

Beginning of the period to which the disclosed information relates

2025-04-03

S.7

End of period to which disclosed information relates

2025-12-31

S.8

Energy consumption

0.00017

S.9

Energy consumption sources and methodologies

Data provided by the MiCA Crypto Alliance as a third party, with no deviations from the calculation guidance of Commission Delegated Regulation (EU) 2025/422, Article 6(5).
Full methodology available at : www.micacryptoalliance.com/methodology

S.10

Renewable energy consumption

37.2601719

S.11

Energy intensity

0.0000001807

S.12

Scope 1 DLT GHG emissions – Controlled

0

S.13

Scope 2 DLT GHG emissions – Purchased

0.0000000508

S.14

GHG intensity

0.0000000553

S.15

Key energy sources and methodologies

Data provided by the MiCA Crypto Alliance as a third party, with no deviations from the calculation guidance of Commission Delegated Regulation (EU) 2025/422, Article 6(5).
Full methodology available at: www.micacryptoalliance.com/methodologies

S.16

Key GHG sources and methodologies

Data provided by the MiCA Crypto Alliance as a third party, with no deviations from the calculation guidance of Commission Delegated Regulation (EU) 2025/422, Article 6(5).
Full methodology available at: www.micacryptoalliance.com/methodologies

S.17

Energy mix

Energy Source	Percentage
Bioenergy	3.3175198225
Coal	15.5583761812
Flared Methane	0
Gas	30.9704575331
Hydro	9.6450138865
Nuclear	13.7673534759
Other Fossil	2.4436409066
Other Renewables	0.4611344337
Solar	4.8759866667
Vented Methane	0
Wind	18.9605170939

S.18

Energy use reduction

N/A

S.19

Carbon intensity

0.30627

S.20

Scope 3 DLT GHG emissions – Value chain

N/A

S.21

GHG emissions reduction targets or commitments

N/A

S.22

Generation of waste electrical and electronic equipment (WEEE)

0.0000000004

S.23

Non-recycled WEEE ratio

61.19774417

S.24

Generation of hazardous waste

0.00000

S.25

Generation of waste (all types)

0.0000000004

S.26

Non-recycled waste ratio (all types)

61.19774417

S.27

Waste intensity (all types)

0.0000004553

S.28

Waste reduction targets or commitments (all types)

N/A

S.29

Impact of the use of equipment on natural resources

Land use: 0.0000040326 m²

S.30

Natural resources use reduction targets or commitments

FALSE

S.31

Water use

0.0000007199

S.32

Non recycled water ratio

73.38888755

S.33

Other energy sources and methodologies

Data provided by the MiCA Crypto Alliance as a third party, with no deviations from the calculation guidance of Commission Delegated Regulation (EU) 2025/422, Article 6(5).
Full methodology available at: www.micacryptoalliance.com/methodologies

S.34

Other GHG sources and methodologies

Data provided by the MiCA Crypto Alliance as a third party, with no deviations from the calculation guidance of Commission Delegated Regulation (EU) 2025/422, Article 6(5).
Full methodology available at: www.micacryptoalliance.com/methodologies

S.35

Waste sources and methodologies

Data provided by the MiCA Crypto Alliance as a third party, with no deviations from the calculation guidance of Commission Delegated Regulation (EU) 2025/422, Article 6(5).Estimates on individual node weight, hazardous components and depreciation rate are used.
Full methodology available at: www.micacryptoalliance.com/methodologies

S.36

Natural resources sources and methodologies

Data provided by the MiCA Crypto Alliance as a third party, with no deviations from the calculation guidance of Commission Delegated Regulation (EU) 2025/422, Article 6(5). Usage of natural resources is approximated through land use metrics. Land use, water use and water recycling are calculated based on energy mix-specific estimates of purchased electricity land intensity, purchased electricity water intensity, and water recycling rates. Full methodology available at: www.micacryptoalliance.com/methodologies

Disclaimer: This document is made available by the MiCA Crypto Alliance Limited ("MiCA Crypto Alliance"), trading as “The MiCA Crypto Alliance”. MiCA Crypto Alliance does not provide any warranty of any kind, express or implied, including but not limited to warranties of accuracy, fitness for a particular purpose, compliance with any laws and/or non-infringement. MiCA Crypto Alliance also assumes no responsibility for any errors, defects, or omissions in the document. To the maximum extent permitted by applicable laws, MiCA Crypto Alliance will not be liable for any direct, indirect, incidental, special, consequential, or exemplary damages, including but not limited to, damages for loss of profits, goodwill, data, or other intangible losses arising out of or relating to any use and/or reliance on the information in this document, however arising, including negligence.