| [Table 2] Template for white papers for crypto-assets other than asset-referenced tokens or e-money tokens | |||||
| Template for white papers for crypto-assets other than asset-referenced tokens or e-money tokens [abstract] | |||||
| General information | |||||
| 00 Table of content | boolean true | ||||
| 01 Date of notification | date | ||||
| 02 Statement in accordance with Article 6(3) of Regulation (EU) 2023/1114 | boolean true | ||||
| 03 Compliance statement in accordance with Article 6(6) of Regulation (EU) 2023/1114 | boolean true | ||||
| 04 Statement in accordance with Article 6(5), points (a), (b), (c), of Regulation (EU) 2023/1114 | boolean true | ||||
| 05 Statement in accordance with Article 6(5), point (d), of Regulation (EU) 2023/1114 | boolean true | ||||
| 06 Statement in accordance with Article 6(5), points (e) and (f), of Regulation (EU) 2023/1114 | boolean true | ||||
| SUMMARY | |||||
| 07 Warning in accordance with Article 6(7), second subparagraph, of Regulation (EU) 2023/1114 | boolean true | This summary should be read as an introduction to the crypto-asset white paper. The prospective holder should base any decision to purchase this crypto –asset on the content of the crypto-asset white paper as a whole and not on the summary alone. The offer to the public of this crypto-asset does not constitute an offer or solicitation to purchase financial instruments and any such offer or solicitation can be made only by means of a prospectus or other offer documents pursuant to the applicable national law. This crypto-asset white paper does not constitute a prospectus as referred to in Regulation (EU) 2017/1129 of the European Parliament and of the Council or any other offer document pursuant to Union or national law. |
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| 08 Characteristics of the crypto-asset | textBlock | The Token does not represent nor confer any ownership, equity interest, participation, corporate governance rights, or any rights beyond the programmatic functionalities expressly described herein, nor any entitlement to business revenues, profit sharing, or other similar economic benefits in relation to the Protocol, the Company (as further defined below), or any other entity or individual of the Zama ecosystem. |
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| 09 Further information about utility tokens | textBlock | ▪ Access the Services: The Token is required for the encryption, decryption, and bridging of data via the Protocol. ▪ Interact with the Protocol: The Token is necessary to become an Operator (as defined in D.04) of the Protocol. Token holders are also able to delegate ("Delegators") (as defined in D.04) some or all of their Tokens to an Operator. The Tokens to be admitted to trading (see E.12) are freely transferable |
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| 10 Key information about the offer to the public or admission to trading | textBlock | ||||
| Part A - Information about offeror or person seeking admission to trading | |||||
| A.1 Name | text | ||||
| A.2 Legal form | text | ||||
| A.3 Registered address | |||||
| Registered addess | text | 6300 Zug Switzerland |
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| Country | enumeration | ||||
| Sub-division | text | ||||
| A.4 Head office | |||||
| Head office | text | ||||
| Country | enumeration | ||||
| Sub-division | text | ||||
| A.5 Registration date | date | ||||
| A.6 Legal entity identifier | LEI | ||||
| A.7 Another identifier required pursuant to applicable national law | text | ||||
| A.8 Contact telephone number | text | ||||
| A.9 E-mail address | text | ||||
| A.10 Response time (days) | integer | ||||
| A.11 Parent company | text | ||||
| A.12 Members of the management body | |||||
| Member #1 | id | 1 | |||
| Identity | text | ||||
| Business address | text | 6300 Zug Switzerland |
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| Function | text | ||||
| Member #2 | id | 2 | |||
| Identity | text | ||||
| Business address | text | Gubelstrasse 11 6300 Zug |
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| Function | text | ||||
| A.13 Business activity | textBlock | For the business activity as entered into the commercial register: see https://zg.chregister.ch/cr-portal/auszug/auszug.xhtml?uid=CHE-186.971.062 |
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| A.14 Parent company business activity | textBlock | ▪ Tools, support and services for developers building on the Zama technology and Protocol ▪ Running validator nodes for various protocol, including but not limited to the Zama Protocol |
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| A.15 Newly established | boolean | ||||
| A.16 Financial condition for the past three years | textBlock | ||||
| A.17 Financial condition since registration | textBlock | The treasury primarily holds approximately 1,000,000 CHF in fiat. The Company also controls approximately 30% of the initial total Token supply. This percentage may evolve over the lifetime of the Company. As of the date of the present notification, the total operating expenses since registration have amounted to 500,000 CHF, primarily covering expenses around project development / marketing / engineering, and operations related to its activities. The Company has no outstanding liabilities, debts, or financial commitments and does not face any financial risks or uncertainties impacting its long-term sustainability |
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| Part B - Information about issuer, if different from offeror or person seeking admission to trading | |||||
| B.1 Issuer different from offerror or person seeking admission to trading | boolean | ||||
| B.2 Name | N/A | . | |||
| B.3 Legal form | N/A | . | |||
| B.4 Registered address | |||||
| Registered addess | N/A | . | |||
| Country | N/A | . | |||
| Sub-division | N/A | . | |||
| B.5 Head office | |||||
| Head office | N/A | . | |||
| Country | N/A | . | |||
| Sub-division | 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 | |||||
| Member #1 | N/A | . | |||
| Identity | N/A | . | |||
| Business address | N/A | . | |||
| Function | 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 | |||||
| C.1 Name | N/A | . | |||
| C.2 Legal form | N/A | . | |||
| C.3 Registered address | |||||
| Registered address | N/A | . | |||
| Country | N/A | . | |||
| Sub-division | N/A | . | |||
| C.4 Head office | |||||
| Head office | N/A | . | |||
| Country | N/A | . | |||
| Sub-division | 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 | |||||
| Member #1 | N/A | . | |||
| Identity | N/A | . | |||
| Business address | N/A | . | |||
| Function | 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 other token project | |||||
| D.1 Crypto-asset project name | text | ||||
| D.2 Crypto-asset name | text | ||||
| D.3 Abbreviation | text | ||||
| D.4 Crypto-asset project description | textBlock | The Protocol consists of a set of Coprocessors ("Coprocessors") performing the FHE computation, a decentralized Key Management System ("KMS") based on a threshold MPC protocol, a Gateway ("Gateway"), and a set of smart contracts deployed on various other blockchains. ▪ KMS: The KMS is responsible for generating FHE keys and Common Reference Strings (CRS), and for decrypting ciphertexts. The key shards are needed by the nodes of the MPC Protocol ("MPC Nodes") to decrypt encrypted information. ▪ Coprocessors: The Coprocessors are responsible for verifying ZK proofs of encrypted inputs, performing FHE computation and storing ciphertexts that are marked as bridgeable or decryptable. The ZK proofs are necessary to make transactions that include encrypted values. MPC Nodes fetch ciphertexts from Coprocessors when they need to decrypt them to ensure that the data that they encrypt has not been tampered with. There are 3 Coprocessors running the computation ("Coprocessor Nodes"). ▪ Gateway: The Gateway is an optimistic rollup acting as an orchestrator of the Protocol, a frontend to the Coprocessors and MPC Nodes and as a payment layer for input validation, decryption and bridge requests, and possibly as a staking layer. Protocol Participants - People may assume the following roles within the Protocol: ▪ Developers: Individuals or legal entities who use the Protocol to deploy their confidential application. ▪ Operators: Individuals or legal entities that operate the MPC Nodes, Coprocessor Nodes as well as the Gateway. They must stake the Token to participate and receive staking rewards in proportion of their stake. Token holders can delegate stake to operators ("Delegators"). The Crypto-Asset - Please refer to (D.07) below. |
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| D.5 Details of all natural or legal persons involved in implementation of crypto-asset project | |||||
| Person #1 | id | 1 | |||
| Type of person | enumeration | ||||
| Name of person | text | ||||
| Business address of person | text | ||||
| Domicile of company | enumeration | ||||
| Person #2 | id | 2 | |||
| Type of person | enumeration | ||||
| Name of person | text | ||||
| Business address of person | text | 6300 Zug Switzerland |
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| Domicile of company | enumeration | ||||
| D.6 Utility token classification | boolean | ||||
| D.7 Key features of goods or services for utility token projects | text | ▪ Access the Services: The Token is required for the encryption, decryption, and bridging of data via the Protocol. ▪ Interact with the Protocol: The Token is necessary to become an Operator of the Protocol. Token holders are also able to become Delegators. |
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| D.8 Plans for the token | |||||
| Description of past milestones | textBlock | ▪ Public Testnet of the Protocol: July 1st, 2025 ▪ Ethereum Mainnet: December 30, 2025. ▪ Token Generation Event; December 30, 2025. |
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| Description of future milestones | textBlock | ▪ Admission on Trading Platforms operating within the EU / EEA (expected date): February 2, 2026 ▪ Support for other chains (expected date): In 2026. |
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| D.9 Resource allocation | text | The financial resources will be primarily allocated to human and technical resources for the development, operation, and expansion of the Protocol. This includes financing core engineering, infrastructure provisioning, and ongoing security audits. Additional funds may be directed towards ecosystem growth initiatives, such as supporting developers and educational efforts to expand community participation. |
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| D.10 Planned use of collected funds or other tokens | text | ||||
| Part E - Information about offer to public of other tokens or their admission to trading | |||||
| E.1 Public offering or admission to trading | enumeration | ||||
| E.2 Reasons for public offer or admission to trading | textBlock | ||||
| E.3 Fundraising target | |||||
| Target expressed in currency | monetary | EUR | |||
| Target expressed in units | decimal | ||||
| Target expressed in digital token identifier | text | ||||
| E.4 Minimum subscription goals | |||||
| Goals expressed in currency | monetary | EUR | |||
| Goals expressed in units | decimal | ||||
| Goals expressed in digital token identifier | text | ||||
| E.5 Maximum subscription goals | |||||
| Goasl expressed in currency | monetary | EUR | |||
| Goals expressed in units | decimal | ||||
| Goals expressed in digital token identifier | text | ||||
| E.6 Oversubscription acceptance | boolean | ||||
| E.7 Oversubscription allocation | text | ||||
| Issue price details | |||||
| E.8 Issue price | decimal | ||||
| E.9 Official currency determining issue price | enumeration | ||||
| E.9 Any other tokens determining issue price | text | ||||
| E.10 Subscription fee | |||||
| Fee expressed in currency | monetary | EUR | |||
| Fee expressed in units | decimal | ||||
| Fee expressed in digital token identifier | text | ||||
| E.11 Offer price determination method | text | ||||
| E.12 Total number of offered or traded other tokens | integer | ||||
| E.13 Targeted holders | enumeration | ||||
| E.14 Holder restrictions | text | ||||
| E.15 Reimbursement notice | boolean true | ||||
| E.16 Refund mechanism | textBlock | ||||
| E.17 Refund timeline | text | ||||
| E.18 Offer phases | textBlock | ||||
| E.19 Early purchase discount | textBlock | ||||
| E.20 Time-limited offer | boolean | ||||
| E.21 Subscription period beginning | date | ||||
| E.22 Subscription period end | date | ||||
| E.23 Safeguarding arrangements for offered funds or other tokens | textBlock | ||||
| E.24 Payment methods for other token purchase | textBlock | ||||
| E.25 Value transfer methods for reimbursement | textBlock | ||||
| E.26 Right of withdrawal | textBlock | ||||
| E.27 Transfer of purchased other tokens | textBlock | ||||
| E.28 Transfer time schedule | text | ||||
| E.29 Purchaser's technical requirements | textBlock | ▪ A compatible digital wallet or account on supported Trading Platforms; and ▪ Internet access. |
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| Other token services provider characteristics | |||||
| E.30 Other token service provider (CASP) name | text | ||||
| E.31 CASP identifier | LEI | ||||
| E.32 Placement form | enumeration | ||||
| Trading platforms characteristics | |||||
| E.33 Trading platforms name | text | ||||
| E.34 Trading platforms market identifier code (MIC) | text | ||||
| E.35 Trading platforms access | text | ||||
| E.36 Involved costs | textBlock | ||||
| E.37 Offer expenses | textBlock | ||||
| E.38 Conflicts of interest | textBlock | ||||
| E.39 Applicable law | textBlock | Once the Tokens are trading, the legal relationship and applicable law between the Trading Platforms and their users shall be determined on the basis of the law governing the contract between them and the applicable mandatory provisions of EU law. Nothing in this white paper shall deprive any consumer located in the EU or EEA of the mandatory rights conferred on that consumer by the consumer-protection legislation of his or her country of habitual residence, if applicable |
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| E.40 Competent court | textBlock | Any disputes arising in connection with the seeking of admission to trading of the Token that are between the Company and the respective Trading Platform for crypto-assets shall be determined by the respective competent court depending on the contractual arrangement (if any) between the parties and the mandatory provisions of applicable law. The competent court for any disputes between Trading Platforms and their users shall be determined on the basis of the contract between them and the applicable EU law. If you are an EU or EEA consumer, you may bring any judicial proceedings before the competent court of your place of residence. |
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| Part F - Information about other tokens | |||||
| F.1 Crypto-asset type | text | ||||
| F.2 Other token functionality | textBlock | ▪ Access the Services: The Token is required for the encryption, decryption, and bridging of data via the Protocol. ▪ Interact with the Protocol: The Token is necessary to become an Operator of the Protocol. Token holders are also able to become Delegators. |
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| F.3 Planned application of functionalities | textBlock | ||||
| A description of the characteristics of the other token, including the data necessary for classification of the crypto-asset white paper in the register referred to in Article 109 of Regulation (EU) 2023/1114, as specified in accordance with paragraph 8 of that Article | |||||
| F.4 Type of crypto-asset white paper | enumeration | ||||
| F.5 Type of submission | enumeration | ||||
| F.6 Other token characteristics | textBlock | ||||
| F.7 Commercial name or trading name | text | ||||
| F.8 Website of the issuer | text | ||||
| F.9 Starting date of offer to the public or admission to trading | date | ||||
| F.10 Publication date | date | ||||
| F.11 Any other services provided by the issuer | textBlock | ||||
| F.12 Language or languages of white paper | text | ||||
| 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 | text | ||||
| F.14 Functionally fungible group digital token identifier, where available | text | ||||
| F.15 Voluntary data flag | boolean | ||||
| F.16 Personal data flag | boolean | ||||
| F.17 LEI eligibility | boolean | ||||
| F.18 Home member state | enumeration | ||||
| F.19 Host member states #1 | enumerationSet | ||||
| F.19 Host member states #2 | enumerationSet | ||||
| F.19 Host member states #3 | enumerationSet | ||||
| F.19 Host member states #4 | enumerationSet | ||||
| F.19 Host member states #5 | enumerationSet | ||||
| F.19 Host member states #6 | enumerationSet | ||||
| F.19 Host member states #7 | enumerationSet | ||||
| F.19 Host member states #8 | enumerationSet | ||||
| F.19 Host member states #9 | enumerationSet | ||||
| F.19 Host member states #10 | enumerationSet | ||||
| F.19 Host member states #11 | enumerationSet | ||||
| F.19 Host member states #12 | enumerationSet | ||||
| F.19 Host member states #13 | enumerationSet | ||||
| F.19 Host member states #14 | enumerationSet | ||||
| F.19 Host member states #15 | enumerationSet | ||||
| F.19 Host member states #16 | enumerationSet | ||||
| F.19 Host member states #17 | enumerationSet | ||||
| F.19 Host member states #18 | enumerationSet | ||||
| F.19 Host member states #19 | enumerationSet | ||||
| F.19 Host member states #20 | enumerationSet | ||||
| F.19 Host member states #21 | enumerationSet | ||||
| F.19 Host member states #22 | enumerationSet | ||||
| F.19 Host member states #23 | enumerationSet | ||||
| F.19 Host member states #24 | enumerationSet | ||||
| F.19 Host member states #25 | enumerationSet | ||||
| F.19 Host member states #26 | enumerationSet | ||||
| F.19 Host member states #27 | enumerationSet | ||||
| F.19 Host member states #28 | enumerationSet | ||||
| F.19 Host member states #29 | enumerationSet | ||||
| Part G - Information on rights and obligations attached to other tokens | |||||
| G.1 Purchaser rights and obligations | textBlock | ||||
| G.2 Exercise of rights and obligations | textBlock | ||||
| G.3 Conditions for modifications of rights and obligations | textBlock | ||||
| G.4 Future public offers | textBlock | ||||
| G.5 Issuer retained other token | integer | ||||
| G.6 Utility token classification | boolean | ||||
| G.7 Key features of goods or services utility tokens | text | ▪ Access the Services: The Token is required for the encryption, decryption, and bridging of data via the Protocol. ▪ Interact with the Protocol: The Token is necessary to become an Operator of the Protocol. Token holders are also able to become Delegators. |
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| G.8 Utility tokens redemption | text | ||||
| G.9 Non-trading request | boolean | ||||
| G.10 Other tokens purchase or sale modalities | text | ||||
| G.11 Other tokens transfer restrictions | text | ||||
| G.12 Supply adjustment protocols | boolean | ||||
| G.13 Supply adjustment mechanisms | text | ||||
| Other token schemes details | |||||
| G.14 Token value protection schemes | boolean | ||||
| G.15 Token value protection schemes description | textBlock | ||||
| G.16 Compensation schemes | boolean | ||||
| G.17 Compensation schemes description | textBlock | ||||
| G.18 Applicable law | textBlock | Nothing in this whitepaper shall deprive any consumer located in the European Union or European Economic Area of the mandatory rights conferred on that consumer by the consumer-protection legislation of his or her country of habitual residence, if applicable. |
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| G.19 Competent court | textBlock | EU or EEA consumers may be able to bring any judicial proceedings before the competent court of their place of residence. |
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| Part H – Information on underlying technology | |||||
| H.1 Distributed ledger technology (DTL) | text | The Token is issued under the ERC-20 standard on the Ethereum blockchain. As a decentralized blockchain where transactions are validated and recorded by a distributed set of nodes through a consensus mechanism, Ethereum qualifies as a DLT under MiCA. As such, Ethereum provides the infrastructure for the issuance, transfer and storage of the Token |
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| H.2 Protocols and technical standards | text | ▪ For the Protocol: See D.04 |
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| H.3 Technology used | textBlock | ||||
| H.4 Consensus mechanism | text | ||||
| H.5 Incentive mechanisms and applicable fees | text | Operators can be excluded out or slashed if they don't run the Protocol honestly. Furthermore, Token holders can delegate Tokens to Operators to further strengthen the economic security of the Protocol, with each Operator deciding how to reward their delegators. Users of the Protocol pay fees in Tokens each time they encrypt and decrypt data. These fees are variable and depend on several factors such as usage volume. Fees are burnt by the protocol in their entirety. |
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| H.6 Use of distributed ledger technology | boolean | ||||
| H.7 DLT functionality description | textBlock | ||||
| Other token audit details | |||||
| H.8 Audit | boolean | ||||
| H.9 Audit outcome | textBlock | Audits found a number of low and medium severity issues, which do not impact the Protocol security or user funds. Some high and critical severity issues were found as well and have been fully patched prior to mainnet launch. Audit reports will be made available on Zama's website (https://www.zama.org) and/or Github (github.com/zama-ai). |
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| Part I - Information on risks | |||||
| I.1 Offer-related risks | textBlock | ▪ General Contractual and Counterparty Risk: The Company does not operate, control, oversee, or manage the functioning of crypto-asset services providers as defined under MiCA ("CASP") operating within the EU/EEA and Trading Platforms (together with CASPs, the "Exchanges"), where the Token will be admitted for trading or listed. ▪ Multiple White Paper Risk: Token holders understand that any third party can decide to draft and publish a MiCA white paper about the Token ("Spontaneous White Paper"). The publication of these Spontaneous White Papers does not imply any endorsement by the Company that the Spontaneous White Papers are complete, correct, fair, clear and not misleading. ▪ Spontaneous Admission to Trading Risk by Trading Platform: Third parties can elect to admit the Token on their Trading Platforms without any request, authorization or approval by the Company or anyone else. Pursuant to article 5 (2) of MiCA, Trading Platforms are responsible for ensuring compliance with all applicable laws, especially MiCA requirements with respect to the spontaneous admission of the Token to trading. The Company, its affiliates, directors, agents and officers shall not be held liable for these spontaneous admissions to trading. ▪ Exchanges Risk: When Token holders buy or sell Token on the Exchanges, the Company does not serve as a contractual party or counterparty to the transaction. Consequently, any legal relationship concerning these Exchanges is subject to their own terms and conditions. The Company, and its service providers, assume no responsibility for the operations, services, or outcomes associated with any transactions or activity on the Exchanges. The Company makes no representations or warranties regarding any Exchange itself and disclaims all responsibility or liability for any regulatory, compliance, operational, financial, technical, or reputational failures that may adversely affect its activities. ▪ Pausing and Delisting Risk: The Company cannot and does not guarantee that the Token will remain listed or tradeable on any of the Exchanges. Delisting (or the temporary pausing of such listing) on any of the Exchanges could significantly hinder the ability of Token holders to buy, sell, or otherwise transact in Token. In the event of delisting, Token holders may face challenges in finding alternative markets or counterparties willing to trade or transact in the Token, which could impact the liquidity and market value of Token. The Company, its affiliates, directors, agents and officers shall not be held liable for for any losses or damages arising from the suspension, removal, or delisting of the Token from any Exchange. ▪ Trading Risk: The Company does not control the secondary markets. There can be no representations nor warranties as to the secondary market (if any) in Token. It cannot and does not guarantee the depth, stability, or sustainability of any secondary market for Token. Limited market depth or trading activity may result in reduced liquidity, increased price volatility, and challenges in buying or selling the Token at desired prices. The Company also cannot and does not guarantee the healthy and consistent availability of buying or selling opportunities for the Token or the integrity of the market price. Trading activity may be affected by manipulative practices such as wash trading, front-running, and similar schemes. While Exchanges and other Trading Platforms may be subject to varying regulatory frameworks that may or may not prohibit such practices and impose oversight to detect and deter them, the Company assumes no responsibility or liability for their effective prevention or enforcement. ▪ Operational and Technical Risk: The Exchanges operate interfaces that allow users to trade crypto-assets for or other crypto-assets. The reliance on any Exchanges' internal system for asset storage and transfer adds an additional layer of counterparty risk, as users are exposed to potential operational, technical, or human errors during these processes, including the following (i)trades on an Exchange may be executed based on a centralized matching algorithm and are often recorded off-chain, meaning they are not directly related to transparent on-chain transfers of crypto-assets, and could dissimulate detrimental trade matching or rogue practices. The traded assets are recorded solely on the Exchange's internal ledger, with each internal ledger entry corresponding to an offsetting trade involving either government currency or another crypto asset; (ii) funds deposited by users for trading may be co-mingled by the Exchanges, rather than stored in unique wallet addresses for each user. This practice results in the centralization of a large volume of assets in a single location, which in turn increases the potential risk of damage or theft, particularly in the event of a hack or security breach; and (iii) furthermore, users who wish to trade or withdraw their Token may be required to deposit them into the Exchange, increasing the risk of loss in the event of a failure of the deposit or withdrawal Token processes set up by an Exchange. ▪ Unanticipated Risks: In addition to the risks outlined in this Section, unforeseen risks may arise. Additionally, new risks could emerge as unexpected variations or combinations of the risks discussed in these Sections I.01 to I.05 |
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| I.2 Issuer-related risks | textBlock | ▪ Abandonment/Lack of Success Risk: The Protocol and the activities of the Company may be partially or totally abandoned for several reasons including, but not limited to, the lack of interest from the public, incapacitation or withdrawal of Token key developers and project supporters, force majeure (including pandemics and wars) or lack of commercial success or prospects. ▪ Change Risk: The Protocol may evolve over time. This could involve pivoting from the original vision of the Protocol or modifying how the vision and objectives of the project are executed. Such changes may be driven by market conditions, regulatory development, technological advancements, or strategic decisions by Protocol contributors. While adaptation and change can foster innovation, it also introduces risks, including shifts in value proposition and potential misalignment with prior expectations. ▪ Decentralization Risk: The Protocol is neither operated nor controlled by the Company or any of its affiliates. Should Token holders interact with the Protocol, they are engaging directly with the Protocol and potentially with third parties that might have no affiliation or relationship with the Issuer. This means that the Issuer does not oversee or manage these interactions, and neither of them does assume responsibility for any outcomes that may arise. ▪ Partner Risk: The implementation of the Protocol depends strongly on the collaboration and functioning of services provided by several third parties, core contributors, activities of the legal entities associated with the project and other crucial ecosystem partners. Loss or changes in the project's leadership, key partners, and other service providers can lead to disruptions, loss of trust, reputational damage, or even complete project failure. The Company cannot and does not guarantee that the Protocol will be successfully developed, deployed and remain operational in perpetuity. ▪ Legal and Regulatory Compliance Risk: Crypto-assets and blockchain technologies are subject to an evolving regulatory landscape worldwide. Regulations vary widely across jurisdiction and may be subject to significant changes, which would lead to changes with respect to the trading of the Token. Changes in laws or regulations may negatively impact the value, legality, or functionality of the Token. Non-compliance with changing or newly formed regulations can result in investigations, enforcement actions, penalties, fines, sanctions, or the prohibition of trading of Token, impacting the Protocol's viability and market acceptance. The Company, core contributors, or other ecosystem partners could be subject to private litigation. Additionally, any legal uncertainties, potential lawsuits, or adverse legal rulings can pose significant risks to the project. Legal challenges may ultimately affect the legality, usability, or value of the Token. ▪ Reputational Risk: There could be a risk of negative publicity related to the Protocol and its affiliated legal entities, whether due, without limitation to operational failures, security breaches, or association with illicit activities, all of which can damage the Protocol ecosystem reputation and, by extension, the value and usability of the Token. ▪ Operational Risk: Any failure to develop or maintain effective internal control or any difficulties encountered in the implementation of such controls could harm the operations of the Company, causing disruptions, financial losses, or reputational damage. ▪ Competition Risk: New competitors may enter the market at any time. The effect of existing, new or additional competition on the Token or its market price cannot be predicted or quantified. Competitors may have significantly greater financial, legal, and technical resources than the Company and there is no guarantee that the project will be able to compete successfully, or at all, with such competitors. ▪ Unanticipated Risks: In addition to the risks outlined in this Section, unforeseen risks may arise. Additionally, new risks could emerge as unexpected variations or combinations of the risks discussed in these Sections I.01 to I.05 |
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| I.3 Other tokens-related risks | textBlock | ▪ Custodial Risk: The method chosen to store the Token, like any crypto-asset, carries inherent risks related to the security and management of the storage solution. The chosen storage method - whether hot or cold wallets, or centralized custody - can significantly impact the safety, liquidity, and accessibility of the Token, with direct consequences for the holder's ability to access, trade, or retain their assets. ▪ Scam Risk. Token holders may be subject to the risk of loss resulting from a scam or fraudulent schemes perpetrated by malicious actors targeting Token holders. These scams include, but are not limited to, phishing or social engineering on social protocols or by email, fake giveaways, identity theft or impersonation of key contributors to the Protocol, creation of fake Tokens, offering fake Token airdrops, among others. Token holders, recipients and purchasers should always verify and confirm that they are interfacing with legitimate websites, personnel, and other assets associated with the Protocol. ▪ Anti-Money Laundering / Counter-Terrorism Financing (AML/CTF) Risk: Crypto-asset wallets holding Token or transactions in Token may be used for money laundering or terrorist financing purposes or attributed to a person or entity known to have committed or is associated with such offenses. Consequently, there is a risk that a public wallet address holding Token could be flagged in relation to AML/CTF efforts. In such cases, receiving Tokens could result in a holder's address being flagged by relevant authorities, Exchanges, or other service providers, which may lead to restrictions on transaction or the freezing of a holder's assets. Token holders may thus face legal or regulatory challenges if their address becomes associated with illicit activities, impacting their ability to freely access, trade, or transfer their tokens. ▪ Taxation Risk: The taxation regime that applies to the trading of Tokens by either individual holders or legal entities will depend on each Token holder's jurisdiction. The Company cannot and does not guarantee that the holding of the Token, the receipt of the Token, conversion of fiat currency against the Token, or other conversion of other crypto assets against the Token, will not incur tax consequences. It is the Token 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, capital gains tax, or other similar taxes arising in connection with the appreciation and depreciation of the Token. ▪ Market Abuse Risk: The market for crypto-assets is rapidly evolving, spanning local, national, and international protocols with an expanding range of assets and participants. Any market abuse, along with a potential loss of confidence among holders, could adversely impact the value and stability of the Token. Notably (i) significant trading activity may take place on systems and protocols with limited oversight and predictability. Sudden and rapid changes in the supply or demand of a crypto-asset, particularly those with low market capitalization or low unit prices, can result in extreme price volatility; (ii) additionally, the inherent characteristics of crypto-assets and their underlying infrastructure may be exploited by certain market participants to engage in abusive trading practices such as front-running, spoofing, pump-and-dump schemes, and fraud across different protocols, systems, or jurisdictions; ▪ Legal and Regulatory Risk: There is a lack of regulatory harmonization globally, which results in diverging regulatory frameworks. Regulations related to crypto-assets remain in flux globally with possible further regulatory evolution in the future. Divergent and shifting regulation could negatively impact the value, utility and overall viability of the Token. Specifically (i) while Token is characterized as a token used to access and interact with the Protocol, certain non-EU regulators may nevertheless classify the Token as a security, financial instrument, or payment instrument under their respective legal frameworks. Such classifications could impose specific regulatory constraints, leading to significant changes in how the Token is structured, purchased, or traded; (ii) evolving regulations could substantially increase compliance costs and operational burdens relating to facilitating transactions in the Token; (iii) new or restrictive regulations could result in Token losing functionality, depreciating in value, or even becoming illegal or impossible to use, buy or sell in certain jurisdictions; (iv)regulators could take enforcement action against the Company, if they determine that the Token constitutes a regulated instrument that has been issued in a non-compliant manner or that the activities of the project, its core contributors or other ecosystem partners violate existing laws. Such actions could expose such parties to legal and financial penalties, including civil and criminal liability. ▪ Unanticipated Risks: In addition to the risks outlined in this Section, unforeseen risks may arise. Additionally, new risks could emerge as unexpected variations or combinations of the risks discussed in these Sections I.01 to I.05 |
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| I.4 Project implementation-related risks | textBlock | ▪ Dependency Risk: The Protocol relies on third-party technologies, infrastructures, and protocols, which could impact its functionality, security, and long-term sustainability. Any disruptions, vulnerabilities, regulatory scrutiny or changes in the Protocol may result in a negative effect on the Token. This reliance on external infrastructure increases systemic risk, as unforeseen issues in third-party infrastructure could cascade into disruptions in the ecosystem. ▪ Reliability Risk: There is a risk that the key features and services of the Protocol may not always function properly, negatively affecting the community's perception of the Protocol and its underlying technology and in turn, affecting the value of the Token. The Protocol will be deployed strictly on an "as is" and "as available" basis without any representations, warranties or guarantees of any kind, whether express or implied. The Company cannot and does not warrant that the Token, the software code of the Token, or the Protocol are reliable current or error-free, free of viruses or other harmful components. ▪ Unanticipated Risks: In addition to the risks outlined in this Section, unforeseen risks may arise. Additionally, new risks could emerge as unexpected variations or combinations of the risks discussed in these Sections I.01 to I.05 |
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| I.5 Technology-related risks | textBlock | ▪ Cybersecurity Risk: The Token - including the Protocol infrastructure, underlying technology such as smart contracts, wallets and other components - may be vulnerable to cyberattacks. Malicious actors may exploit software vulnerabilities, attack consensus mechanisms, or compromise private keys to gain unauthorized access to the Token. Risks include hacking attempts on the Protocol, smart contract exploits, phishing attacks, malware infections, and other forms of cybercrime that could result in the theft, loss, or unauthorized transfer of the Token. Since digital assets exist entirely in a technological environment, they are inherently exposed to evolving cyber threats, some of which may be undetectable or irreparable until after significant damage has occurred. ▪ Blockchain Risk: The Protocol could be susceptible to consensus-related attacks, including but not limited to double-spend attacks, majority validation power attacks, censorship attacks, and sybil attacks. Any successful attack presents a risk to execution of transactions associated with the Token. ▪ Smart Contract Risk: Transactions associated with the Token rely on smart contracts deployed on a blockchain Protocol. Smart contracts are susceptible to coding vulnerabilities, bugs, or security flaws that could be exploited by malicious actors. A breach in the smart contract could result in unauthorized transactions, token loss, or manipulation of staking mechanism, negatively impacting the Token's security and trust among Token holders. Even though independent security audits are routinely conducted, unforeseen vulnerabilities may still pose a risk. ▪ Private Key Management Risk and Loss of Access to Crypto-Assets: The security of the Token holding heavily relies on the management of private keys, which are used to access and control crypto-assets. The Token holders are responsible for the custody of their Tokens in a compatible cryptographic wallet and for the security of their private keys. Poor management practices, loss, or theft of private keys, or respective credential, can lead to irreversible loss of access to the Tokens. If a Token holder connects their wallet to malicious applications or protocols, they also risk unauthorized access to their assets and their Token holdings. ▪ Protocol-Level Risk: It cannot be excluded that any technical failure, malfunction, or vulnerability within the Protocol could directly or indirectly impact the value of the Token. (i)The Protocol could be subject to critical exploits, such as reentrancy attacks, logic errors, or oracle manipulation, which could lead to unintended token transfers, assets being drained from the system, or tokens being irretrievably lost. Fixing such issues may require significant coordination, governance approval, or even disruptive measures such as protocol migrations or forks, none of which are guaranteed to be successful; and (ii) any security breach, or governance deadlock affecting the Protocol could have cascading effects, including depreciation of the Token's value, reduced market confidence, and potential loss of funds for Token holders. ▪ Settlement Finality and Irrevocability of Transactions: Transactions in Token may be irreversible. Holders sending Tokens to nonexistent or incorrect addresses may irrevocably lose their Tokens and be unable to reverse the transaction or recover their Tokens. ▪ Unanticipated Risks: In addition to the risks outlined in this Section, unforeseen risks may arise. Additionally, new risks could emerge as unexpected variations or combinations of the risks discussed in these Sections I.01 to I.05. |
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| I.6 Mitigation measures | textBlock | To further reduce exposure to these risks, prospective Token holders should adopt appropriate safeguards based on their chosen custody method and remain vigilant by actively monitoring publicly available news and market signals, enabling them to respond swiftly to significant developments which may result in the materialization of specific risks. In addition, the Protocol does not offer end-user features directly, but rather provides developers or applications a way to add confidentiality to their own applications. As such, the Company, its affiliates, directors, agents and officers cannot be held responsible for any issue arising from the use of third-party applications built on top of the Protocol. Users are strongly invited to conduct their own research, thoroughly analyze any application or smart contract they interact with. |
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| Part J - Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts | |||||
| J.1 Adverse impacts on climate and other environment-related adverse impacts | textBlock | The energy consumption for the validation and finality of transactions and the maintenance of the integrity of the distributed ledger of transactions for the period is estimated to be lower than 500'000 kWh. (see S.08).The total estimated energy consumption for the operation and validation of the Protocol and the Token related activity on Ethereum from S.07 to S.08, is approximately 270 000 kWh yearly. As the Protocol is in an early stage and the Token has not yet been issued, these calculations are based on our estimations at date of the notification of the present white paper for the first year. Should the actual energy consumption after one year change significantly and exceed 500,000 kWh, this section will be amended accordingly. |
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| Mandatory information on principal adverse impacts on the climate and other environment-related adverse impacts of the consensus mechanism | |||||
| General information about adverse impacts | |||||
| S.1 Name | text | ||||
| S.2 Relevant legal entity identifier | text | ||||
| S.3 Name of the crypto-asset | text | ||||
| S.4 Consensus mechanism | text | ||||
| S.5 Incentive mechanisms and applicable fees | text | ||||
| S.6 Beginning of period to which disclosed information relates | date | ||||
| S.7 End of period to which disclosed information relates | date | ||||
| Mandatory key indicator | |||||
| S.8 Energy consumption | energy (kWh) | ||||
| Sources and methodologies | |||||
| S.9 Energy consumption sources and methodologies | textBlock | ||||
| Supplementary information on principal adverse impacts on climate and other environment-related adverse impacts of consensus mechanism | |||||
| Supplementary key indicators | |||||
| S.10 Renewable energy consumption | percent | ||||
| S.11 Energy intensity | energy (kWh) | ||||
| S.12 Scope 1 DLT GHG emissions - controlled | GHG emissions (tCO2e) | ||||
| S.13 Scope 2 DLT GHG emissions - purchased | GHG emissions (tCO2e) | ||||
| S.14 GHG intensity | GHG emissions (tCO2e) | ||||
| Sources and methodologies | |||||
| S.15 Key energy sources and methodologies | textBlock | ||||
| S.16 Key GHG sources and methodologies | textBlock | ||||
| Optional information on principal adverse impacts on the climate and on other environment-related adverse impacts of the consensus mechanism | |||||
| Optional indicators | |||||
| S. 17 Energy mix | percent | ||||
| S.18 Energy use reduction | |||||
| Energy use reduction target (absolute value) | energy (kWh) | ||||
| Energy use reduction target (percentage) | percent | ||||
| S.19 Carbon intensity (kgCO2e/kWh) | decimal | ||||
| S.20 Scope 3 DLT GHG emissions - value chain | GHG emissions (tCO2e) | ||||
| S.21 GHG emissions reduction targets or commitments | textBlock | ||||
| S.22 Generation of waste electrical and electronic equipment (WEEE) | mass (tonnes) | ||||
| S.23 Non-recycled WEEE ratio | percent | ||||
| S.24 Generation of hazardous waste | mass (tonnes) | ||||
| S.25 Generation of waste (all types) | mass (tonnes) | ||||
| S.26 Non-recycled waste ratio (all types) | percent | ||||
| S.27 Waste intensity (all types) | mass (tonnes) | ||||
| S.28 Waste reduction targets or commitments (all types) | textBlock | ||||
| S.29 Impact of use of equipment on natural resources | textBlock | ||||
| S.30 Natural resources use reduction targets or commitments | textBlock | ||||
| S.31 Water use | volume (m3) | ||||
| S.32 Non recycled water ratio | percent | ||||
| Sources and methodologies | |||||
| S.33 Other energy sources and methodologies | textBlock | ||||
| S.34 Other GHG sources and methodologies | textBlock | ||||
| S.35 Waste sources and methodologies | textBlock | ||||
| S.36 Natural resources sources and methodologies | textBlock | ||||