White paper drafted under the European Markets in Crypto-Assets Regulation (EU) 2023/1114 for FFG W0746TPZW

The crypto-asset Lighter (LIT) referred to in this white paper is a crypto-asset other than EMTs and ARTs, and is issued on the Ethereum network as of 2026-01-08 and according to DTI FFG shown in F.14. The maximum supply of the crypto-asset is fixed at 1,000,000,000 units. The first activity in Ethereum can be viewed on 2025-10-27 (transaction hash: 0x8f563a79fb4f436407126bcef8662b0b2b73683026f44f54f4ae24101f3b796f, source https://etherscan.io/tx/0x8f563a79fb4f436407126bcef8662b0b2b73683026f44f54f4ae24101f3b796f, accessed 2026-01-08).

The Lighter project is a blockchain-based initiative focused on the development of decentralized trading infrastructure within the Ethereum ecosystem. It is designed as an application-specific zero-knowledge rollup that enables off-chain processing of trading activity while relying on on-chain cryptographic proofs to verify the correctness of state transitions. The project’s stated objective is to support non-custodial trading of digital assets, with an initial emphasis on order book–based spot and perpetual trading. By separating execution from settlement, the protocol seeks to address scalability and efficiency constraints commonly associated with fully on-chain decentralized exchanges.

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

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

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

Based on publicly available information, the business model of the company associated with Lighter appears to be centered on the development, operation, and ongoing maintenance of the Lighter project. This includes the provision of technical infrastructure, protocol development, and related support activities for the Lighter ecosystem. However, detailed disclosures regarding revenue generation, cost structures, or contractual arrangements connected to these activities are not publicly available.

Elliot Technologies, Inc. does not have a parent company. Accordingly, no business activity of a parent company is to be reported in this section.

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.

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.

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

Crypto Risk Metrics GmbH, Lange Reihe 73, 20099 Hamburg

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

The Lighter project is a blockchain-based initiative focused on the development of decentralized trading infrastructure within the Ethereum ecosystem. It is designed as an application-specific zero-knowledge rollup that enables off-chain processing of trading activity while relying on on-chain cryptographic proofs to verify the correctness of state transitions. The project’s stated objective is to support non-custodial trading of digital assets, with an initial emphasis on order book–based spot and perpetual trading. By separating execution from settlement, the protocol seeks to address scalability and efficiency constraints commonly associated with fully on-chain decentralized exchanges.

From a technical perspective, Lighter processes core trading functions such as order matching, margin accounting, and liquidation logic outside the Ethereum base layer. The resulting state changes are periodically committed to Ethereum using zero-knowledge proofs, which are intended to allow independent verification that protocol rules have been followed. Users interact with the system through smart contracts and retain control over their crypto-assets, without transferring custody to a centralized intermediary. The project documentation emphasizes transparency and verifiability of execution, while acknowledging reliance on complex cryptographic systems and smart contract infrastructure.

The crypto-asset associated with the Lighter project is intended to support the functioning of the protocol and its surrounding ecosystem. Public information indicates that the project has received external financial backing; however, detailed disclosures regarding the issuer structure, token distribution mechanics, and economic arrangements are limited. As a result, certain aspects of governance, resource allocation, and long-term operational sustainability cannot be fully assessed based solely on currently available information. The project should therefore be understood in the context of ongoing technical development and evolving disclosures, with inherent uncertainties typical for early-stage decentralized infrastructure initiatives.

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.

This section provides an overview of historical developments related to the Lighter project and a description of planned or anticipated milestones as publicly communicated by the project. All forward-looking statements are subject to significant uncertainty. They do not constitute commitments, assurances, or guarantees, and may be modified, delayed, or discontinued at any time. The completion of past milestones does not imply that future milestones will be achieved as described, and future developments may have adverse effects for users or holders of the crypto-asset.

There is no formally published, binding, or multi-year roadmap for the Lighter project. Information regarding past and potential future developments is derived solely from publicly accessible project communications, including website materials and documentation, and remains limited in scope.

Past milestones (based on public information):

- Private beta launch (January 2025): The project publicly communicated the start of a private beta phase with restricted, invite-only access, intended to test core protocol functionality.

- Conclusion of private beta phase (September 30, 2025): According to project statements, the private beta testing period concluded after several months of limited operation.

- Public mainnet launch (October 2, 2025): The project announced the launch of a public mainnet following the private testing phase, marking the transition to broader user accessibility.

These milestones are based on issuer communications and have not been independently audited or certified by third parties.

Future milestones (indicative and non-binding):

- Continuation of incentive or points-based programs: The project has publicly referenced the continuation or initiation of further incentive mechanisms following earlier testing phases.

- Token-related events: Public materials reference an expected token generation event and potential admission to trading; however, no binding timeline, technical specifications, or legal conditions have been formally disclosed.

- Ongoing protocol development: The project documentation describes continued work on additional technical features and extensions to existing functionality, without fixed implementation dates.

All future milestones are based exclusively on publicly stated intentions of the issuer or project contributors. It is not possible to determine whether, when, or in what form such milestones will occur, as they remain subject to technical feasibility, governance decisions, regulatory considerations, and other external factors.

Based on publicly accessible information, the Lighter project is reported to have received external financial support from third parties, as referenced on various external data aggregation and information portals. These disclosures indicate the existence of capital contributions from venture capital firms and other investors; however, such information is derived exclusively from secondary sources and not from comprehensive, primary issuer disclosures.

The specific conditions of these capital contributions are not publicly verifiable. In particular, there is no publicly available, independently confirmed information regarding the total amount of funds raised, the number or structure of financing rounds, the valuation(s) applied, the financial instruments used (e.g. equity, token-based arrangements or other forms), vesting schedules, preferential rights, or any allocation of proceeds to specific operational or development activities. The project has not published detailed, auditable statements on how financial resources are allocated or deployed within the project.

Based on the project’s own public statements and promotional materials, the Lighter project reports that the following venture capital firms and strategic investors have been involved in its financing: Founders Fund, Ribbit Capital, Haun Ventures, Coinbase, Robinhood, Andreessen Horowitz, Coatue, Lightspeed Venture Partners, SV Angel, 8VC, Abstract Ventures

The project further states that additional venture capital firms and angel investors may be involved.

Accordingly, while external capitalisation of the project is asserted in public sources, the scope, structure and allocation of financial resources remain unclear and cannot be independently assessed based on currently available public information.

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

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

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.

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

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.

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.

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.

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

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

Based on publicly available information, the crypto-asset associated with the Lighter project is designed to interact with the protocol’s smart contract infrastructure within the Ethereum ecosystem. Its technical functionality is limited to those features that are implemented and described in the protocol’s publicly disclosed documentation. The crypto-asset can be used within the Lighter system to support defined on-chain and off-chain interactions as specified by the protocol rules encoded in smart contracts.

The crypto-asset may be used to enable certain protocol-level operations, such as participation in designated mechanisms or processes that are technically enforced by the Lighter smart contracts. All interactions involving the crypto-asset are subject to the deterministic execution of smart contract logic and, where applicable, the verification of zero-knowledge proofs submitted to the Ethereum base layer. No functionality beyond what is explicitly implemented in the deployed smart contracts can be assumed.

The functionality of the crypto-asset does not imply any claim to ownership, profit participation, repayment, or governance rights, unless such rights are expressly and technically encoded in the protocol. Any use of the crypto-asset is constrained by the current state of the protocol’s codebase and may change only through future software updates, which are not guaranteed and are outside the scope of the presently verifiable functionality.

Based on publicly available information, the issuer has outlined certain areas of intended or potential future development of the Lighter protocol. These statements are primarily derived from high-level technical documentation and public communications and do not constitute a formally adopted or binding development roadmap. As a result, the scope, timing, and implementation of future functionalities remain uncertain.

While future protocol enhancements may include extensions to existing trading mechanisms, additional financial primitives, or broader computational capabilities, the issuer has not provided detailed, technically binding descriptions of how such developments would be implemented at the smart contract level. In particular, the specific technical interactions between any future protocol features and the crypto-asset have not been clearly defined or communicated in a manner that allows independent verification.

Accordingly, the precise effects of any planned or anticipated functionalities on the crypto-asset cannot be determined with certainty. Any future changes to the protocol or its associated crypto-asset are subject to technical feasibility, governance processes, and external factors, and may differ materially from current expectations or may not be implemented at all.

The crypto-asset referred to herein is a crypto-asset other than EMTs and ARTs, and is available on the Ethereum network. The crypto-asset is fungible up to 18 digits after the decimal point. The crypto-asset constitutes a digital representation recorded on distributed-ledger technology and does not confer ownership, governance, profit participation, or any other legally enforceable rights. Any functionalities associated with the token are limited to potential technical features within the relevant platform environment. These functionalities do not represent contractual entitlements and may depend on future development decisions, technical design choices, and operational conditions. The crypto-asset does not embody intrinsic economic value; instead, its value, if any, is determined exclusively by market dynamics such as supply, demand, and liquidity in secondary markets.

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

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

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

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

As the crypto-asset does not establish any legally enforceable rights or obligations, there are no applicable procedures or conditions for their exercise.

Any interaction or functionality that may be available within the technical infrastructure of the project – such as participation mechanisms or protocol-level features – serves operational purposes only and does not create or constitute evidence of any contractual or statutory entitlement.

As the crypto-asset does not confer any legally enforceable rights or obligations, there are no conditions or mechanisms under which such rights could be modified.

Adjustments to the technical protocol, smart contract logic, or related systems may occur in the ordinary course of development or maintenance.

Such changes do not alter the legal position of holders, as no contractual or regulatory rights exist. Holders should not interpret technical updates or governance-related changes as amendments to legally binding entitlements.

Information on the future offers to the public of crypto-assets were not available at the time of writing this white paper (2026-01-07).

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

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.

For the crypto-asset in scope, the supply is limited to 1,000,000,000 units according to public information. Investors should note that changes in the supply of the crypto-asset can have a negative impact.

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.

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.

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

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

The following applies to Ethereum:

The crypto-asset operates on a well-defined set of protocols and technical standards that are intended to ensure its security, decentralization, and functionality. It is running on the Ethereum blockchain. Below are some of the key ones:

1. Network Protocols

The crypto-asset follows a decentralized, peer-to-peer (P2P) protocol where nodes communicate over the crypto-asset's DevP2P protocol using RLPx for data encoding.

- Transactions and smart contract execution are secured through Proof-of-Stake (PoS) consensus.

- Validators propose and attest blocks in Ethereum’s Beacon Chain, finalized through Casper FFG.

- The Ethereum Virtual Machine (EVM) executes smart contracts using Turing-complete bytecode.

2. Transaction and Address Standards

crypto-asset Address Format: 20-byte addresses derived from Keccak-256 hashing of public keys.

Transaction Types:

- Legacy Transactions (pre-EIP-1559)

- Type 0 (Pre-EIP-1559 transactions)

- Type 1 (EIP-2930: Access list transactions)

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

The Pectra upgrade introduces EIP-7702, a transformative improvement to account abstraction. This allows externally owned accounts (EOAs) to temporarily act as smart contract wallets during a transaction. It provides significant flexibility, enabling functionality such as sponsored gas payments and batched operations without changing the underlying account model permanently.

3. Blockchain Data Structure & Block Standards

- the crypto-asset's blockchain consists of accounts, smart contracts, and storage states, maintained through Merkle Patricia Trees for efficient verification.

Each block contains:

- Block Header: Parent hash, state root, transactions root, receipts root, timestamp, gas limit, gas used, proposer signature.

- Transactions: Smart contract executions and token transfers.

- Block Size: No fixed limit; constrained by the gas limit per block (variable over time). In line with Ethereum’s scalability roadmap, Pectra includes EIP-7691, which increases the maximum number of "blobs" (data chunks introduced with EIP-4844) per block. This change significantly boosts the data availability layer used by rollups, supporting cheaper and more efficient Layer 2 scalability.

4. Upgrade & Improvement Standards

Ethereum follows the Ethereum Improvement Proposal (EIP) process for upgrades.

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

The following applies to Ethereum:

1. Decentralized Ledger: The Ethereum blockchain acts as a decentralized ledger for all token transactions, with the intention to preserving an unalterable record of token transfers and ownership to ensure both transparency and security.

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

3. Cryptographic Integrity: Ethereum employs elliptic curve cryptography to validate and execute transactions securely, intended to ensure the integrity of all transfers. The Keccak-256 (SHA-3 variant) Hashing Algorithm is used for hashing and address generation. The crypto-asset uses ECDSA with secp256k1 curve for key generation and digital signatures. Next to that, BLS (Boneh-Lynn-Shacham) signatures are used for validator aggregation in PoS.

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

The following applies to Ethereum:

The crypto-asset's Proof-of-Stake (PoS) consensus mechanism, introduced with The Merge in 2022, replaces mining with validator staking. Validators must stake at least 32 ETH every block a validator is randomly chosen to propose the next block. Once proposed the other validators verify the blocks integrity. The network operates on a slot and epoch system, where a new block is proposed every 12 seconds, and finalization occurs after two epochs (~12.8 minutes) using Casper-FFG. The Beacon Chain coordinates validators, while the fork-choice rule (LMD-GHOST) ensures the chain follows the heaviest accumulated validator votes. Validators earn rewards for proposing and verifying blocks, but face slashing for malicious behavior or inactivity. PoS aims to improve energy efficiency, security, and scalability, with future upgrades like Proto-Danksharding enhancing transaction efficiency.

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

The following applies to Ethereum:

The crypto-asset's PoS system secures transactions through validator incentives and economic penalties. Validators stake at least 32 ETH and earn rewards for proposing blocks, attesting to valid ones, and participating in sync committees. Rewards are paid in newly issued ETH and transaction fees. Under EIP-1559, transaction fees consist of a base fee, which is burned to reduce supply, and an optional priority fee (tip) paid to validators. Validators face slashing if they act maliciously and incur penalties for inactivity. This system aims to increase security by aligning incentives while making the crypto-asset's fee structure more predictable and deflationary during high network activity.

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

Not applicable, as no comprehensive audit of the technology used has been conducted or can be confirmed.

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.

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.

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.

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.

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.

None.

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

The following applies to Ethereum:

The crypto-asset's Proof-of-Stake (PoS) consensus mechanism, introduced with The Merge in 2022, replaces mining with validator staking. Validators must stake at least 32 ETH every block a validator is randomly chosen to propose the next block. Once proposed the other validators verify the blocks integrity. The network operates on a slot and epoch system, where a new block is proposed every 12 seconds, and finalization occurs after two epochs (~12.8 minutes) using Casper-FFG. The Beacon Chain coordinates validators, while the fork-choice rule (LMD-GHOST) ensures the chain follows the heaviest accumulated validator votes. Validators earn rewards for proposing and verifying blocks, but face slashing for malicious behavior or inactivity. PoS aims to improve energy efficiency, security, and scalability, with future upgrades like Proto-Danksharding enhancing transaction efficiency.

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

The following applies to Ethereum:

The crypto-asset's PoS system secures transactions through validator incentives and economic penalties. Validators stake at least 32 ETH and earn rewards for proposing blocks, attesting to valid ones, and participating in sync committees. Rewards are paid in newly issued ETH and transaction fees. Under EIP-1559, transaction fees consist of a base fee, which is burned to reduce supply, and an optional priority fee (tip) paid to validators. Validators face slashing if they act maliciously and incur penalties for inactivity. This system aims to increase security by aligning incentives while making the crypto-asset's fee structure more predictable and deflationary during high network activity.

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

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

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

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

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