White paper drafted under the European Markets in Crypto-Assets Regulation (EU) 2023/1114 for FFG HZ9HHNPLG

The TRON crypto-asset is a cryptographic token designed to operate within the TRON blockchain network, a distributed ledger system that supports the creation, deployment, and execution of decentralised applications and smart contracts.

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.

Not applicable.

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

Not applicable.

Not applicable.

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 TRON crypto-asset is a cryptographic token designed to operate within the TRON blockchain network, a distributed ledger system that supports the creation, deployment, and execution of decentralised applications and smart contracts.

The TRX token functions primarily as a crypto-asset within the TRON ecosystem. It is used, inter alia, to pay for transaction execution, to allocate network resources such as bandwidth and computational capacity, and to participate in on-chain governance mechanisms. Token holders may interact with protocol-level features according to predefined consensus and governance rules implemented at the protocol layer.

The operation of the TRON network relies on a delegated proof-of-stake consensus mechanism, under which network participants may support validators responsible for block production and transaction validation. The protocol rules governing issuance, transferability, and network participation are implemented in publicly available software code.

The TRX crypto-asset does not represent ownership, voting rights in a legal entity, or a claim against any issuer or promoter. Its value, functionality, and usage depend on market adoption, network participation, and the continued operation of the underlying open-source protocol.

Not applicable.

This section provides an overview of the historical developments related to the TRON crypto-asset and a description of planned or anticipated project milestones as publicly communicated. All forward-looking elements are subject to significant uncertainty. They do not constitute commitments, assurances, or guarantees and may be modified, delayed, or discontinued at any time. Past developments cannot be assumed to continue, and changes may affect token holders. Sources:

https://tron.network/, accessed 2025-12-15.

Past milestones:

- Initial Network Launch and Token Introduction (2017–2018):

Public materials indicate that the TRON project originated in 2017, with early development activities and the introduction of the TRX crypto-asset. In 2018, TRON launched its own main network, and TRX transitioned from an ERC-20 representation to operation on the native TRON blockchain.

- Mainnet Operation and Protocol Evolution (2018–2020):

Following the mainnet launch, the TRON network entered a phase of ongoing operation, including incremental protocol updates, expansion of network participants, and the introduction of on-chain governance and consensus-related mechanisms as described in public technical documentation.

- Ecosystem and Infrastructure Developments (2020 onward):

Publicly available sources reference continued development of network infrastructure, tooling, and interoperability features, as well as increased use of smart contracts and decentralised applications deployed on the TRON blockchain.

Future milestones:

- Protocol Maintenance and Incremental Upgrades:

Public communications indicate an intention to continue maintaining and updating the TRON protocol software. Such updates may relate to performance, security, or compatibility, subject to technical feasibility and network governance processes.

- Governance and Network Participation Adjustments:

TRON-related materials reference potential adjustments to governance parameters and participation mechanisms over time. Any such changes depend on protocol rules and the actions of network participants and are not guaranteed.

- Ecosystem-Oriented Initiatives:

Public statements suggest a continued focus on supporting broader ecosystem activity on the TRON network, including developer engagement and infrastructure enhancements. The scope, timing, and outcome of such initiatives remain uncertain.

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

Publicly available information indicates that the initial distribution of the TRX crypto-asset was structured across several categories at the time of the project’s early launch. According to secondary sources summarising historical allocation data, portions of the initially issued TRX units were distributed to private sale and early participants, to participants in a public sale, and to addresses associated with ecosystem-related purposes. These allocations reflected an initial distribution framework rather than an ongoing commitment or entitlement.

Following the initial distribution phase, the availability and allocation of TRX units are determined primarily through protocol-level mechanisms. New TRX units may be created through block production and voting-related reward mechanisms defined by the TRON protocol and allocated to network participants involved in block validation and related consensus processes. The parameters governing such allocations are implemented at the protocol level and may be adjusted through network governance procedures.

In parallel, the protocol includes mechanisms through which TRX units may be permanently removed from circulation, including burning processes associated with transaction execution and resource consumption. As a result, the overall allocation and availability of TRX units evolve dynamically over time as a function of network activity, protocol parameters, and decentralised governance decisions.

No central entity allocates financial or other resources in a discretionary manner comparable to a traditional project budget. The allocation of TRX units and related network resources occurs through automated, protocol-defined rules and decentralised participation, rather than through unilateral decisions of an issuer or managing body. Consequently, the distribution and effective allocation of resources associated with the crypto-asset may change over time and cannot be regarded as fixed or guaranteed.

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

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

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.

The TRON crypto-asset (TRX) is a cryptographic token that operates on the TRON blockchain, a distributed ledger network designed to support the recording, validation, and execution of transactions and programmable instructions through smart contracts.

Within the TRON network, TRX is used as a protocol-level asset that enables interaction with core network functions. This includes its use in connection with transaction processing, allocation of network resources, and participation in protocol-defined mechanisms that govern how transactions are prioritised, validated, and recorded on the distributed ledger. The precise manner in which these functions operate is determined by the technical rules embedded in the protocol software and may change over time through network-driven processes.

TRX may also be involved in mechanisms that allow network participants to signal preferences or support for certain protocol parameters or validator roles, in accordance with the consensus and governance logic implemented at the protocol level. Such participation is governed by predefined rules and does not confer legal rights, ownership interests, or claims against any person or entity.

Transfers of TRX are recorded on the TRON blockchain and can occur directly between network addresses without reliance on a central intermediary. The execution, finality, and reversibility of transactions depend on the technical characteristics of the network, including consensus processes and network participation.

The functionality of TRX is limited to what is technically enabled by the TRON protocol and compatible software interfaces. There is no assurance that any specific function will remain available, unchanged, or supported over time. Modifications to protocol rules, network usage patterns, or supporting infrastructure may affect how the crypto-asset can be used or accessed.

See D.8.

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

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

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

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

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

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

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

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

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

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.

Although the TRON protocol does not implement demand-responsive supply adjustment protocols, it provides for protocol-defined mechanisms that affect total and circulating supply over time.

New TRX units may be created through block production and voting-related reward mechanisms allocated to network participants involved in consensus activities. The parameters governing such minting, including reward levels, are defined at the protocol level and may be modified through decentralised governance procedures. These mechanisms operate independently of market demand and do not constitute algorithmic supply control.

In addition, the TRON protocol enables the permanent removal of TRX units from circulation through burning mechanisms. TRX units may be destroyed in connection with transaction execution and resource consumption when users elect to burn TRX. Tokens transferred to burn addresses become permanently non-transferable. This process may reduce the circulating supply but is not triggered automatically in response to demand conditions.

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.

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

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

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

The following applies to Tron:

The TRON blockchain operates on a publicly documented protocol that defines the structure of the distributed ledger, transaction formats, block composition, and validation rules. The protocol specifications are implemented in open-source software maintained by network participants and contributors.

The protocol supports the execution of programmable instructions through smart contracts, with contract logic executed in accordance with predefined virtual machine rules. Communication between network nodes follows standard peer-to-peer networking principles as specified in the protocol documentation. Updates to protocol rules are subject to governance processes defined within the network and are reflected through software version changes adopted by participating nodes.

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

The following applies to Tron:

The TRON network is based on distributed ledger technology that records transactions in sequentially linked blocks. The system uses cryptographic techniques to secure transactions, manage account balances, and authenticate network participants.

Smart contracts on the TRON network are executed within a virtual machine environment designed to process deterministic code. The network supports account-based state management and uses cryptographic key pairs to control access to accounts. Data relating to transactions and smart contract execution is stored and replicated across participating nodes in accordance with protocol rules.

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

The following applies to Tron:

TRON uses a Delegated Proof-of-Stake (DPoS) consensus mechanism in which holders of the native crypto-asset stake their units to obtain voting rights. These votes determine the 27 Super Representatives (SRs) that take turns proposing and validating blocks. A new block is produced approximately every three seconds, following the slot schedule assigned at the beginning of each six-hour epoch. If an SR misses its slot, the network moves to the next validator without delay.

Blocks become irreversible once more than 70% of SRs (at least 19 of 27) build subsequent blocks on top of them, providing economic finality. Governance and parameter changes are implemented through an on-chain proposal system, with only SRs eligible to vote. DPoS is intended to provide rapid block production, low energy consumption, and predictable finality through an elected validator set.

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

The following applies to Tron:

Super Representatives earn 8 units of the native crypto-asset for each block they produce, while an additional 128 units per block are shared among all SRs and SR partners based on votes received. Voters obtain rewards through staking and voting, with SRs deducting a commission before distributing payouts. This incentive structure is intended to maintain active participation and reliable block production.

Transactions and smart-contract executions consume Bandwidth and Energy. Users can obtain these resources by staking or, if insufficient, by burning the native crypto-asset at fixed rates. Certain protocol actions such as becoming an SR candidate, issuing assets, creating accounts, or updating permissions carry dedicated execution fees, and optional costs apply for multi-signature transactions or memos.

While the protocol does not use slashing, resource-based penalties apply. Failed contract executions may result in increased Energy deductions, and the dynamic Energy model raises future costs for contracts that heavily consume network resources. These measures are intended to preserve system stability and prevent resource abuse.

Not applicable.

Not applicable.

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 Tron network.

The following applies to Tron:

TRON uses a Delegated Proof-of-Stake (DPoS) consensus mechanism in which holders of the native crypto-asset stake their units to obtain voting rights. These votes determine the 27 Super Representatives (SRs) that take turns proposing and validating blocks. A new block is produced approximately every three seconds, following the slot schedule assigned at the beginning of each six-hour epoch. If an SR misses its slot, the network moves to the next validator without delay.

Blocks become irreversible once more than 70% of SRs (at least 19 of 27) build subsequent blocks on top of them, providing economic finality. Governance and parameter changes are implemented through an on-chain proposal system, with only SRs eligible to vote. DPoS is intended to provide rapid block production, low energy consumption, and predictable finality through an elected validator set.

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

The following applies to Tron:

Super Representatives earn 8 units of the native crypto-asset for each block they produce, while an additional 128 units per block are shared among all SRs and SR partners based on votes received. Voters obtain rewards through staking and voting, with SRs deducting a commission before distributing payouts. This incentive structure is intended to maintain active participation and reliable block production.

Transactions and smart-contract executions consume Bandwidth and Energy. Users can obtain these resources by staking or, if insufficient, by burning the native crypto-asset at fixed rates. Certain protocol actions such as becoming an SR candidate, issuing assets, creating accounts, or updating permissions carry dedicated execution fees, and optional costs apply for multi-signature transactions or memos.

While the protocol does not use slashing, resource-based penalties apply. Failed contract executions may result in increased Energy deductions, and the dynamic Energy model raises future costs for contracts that heavily consume network resources. These measures are intended to preserve system stability and prevent resource abuse.

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

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.