White paper drafted under the European Markets in Crypto-Assets Regulation (EU) 2023/1114 for FFG M7B5KL63K

The crypto-asset SRX referred to in this white paper is a crypto-asset other than EMTs and ARTs and is issued on the XDC network, according to the DTI FFG shown in Section F.14, as of 2026-06-17. An initial amount of 500,000,000 tokens was pre-minted, the total supply is not technically limited. XDC is a XRC-20 token, designed for compatibility with the XDC blockchain and all EVM-compatible blockchains. The SRX smart contract, xdc5d5f074837f5d4618b3916ba74de1bf9662a3fed, was deployed on 2021-06-01 (source: https://xdcscan.com/tx/0x0f1aecd1ad126d22c40093c6e0fa191111117e238f987fca1a135f81458aafa3, accessed 2026-06-17).

StorX is a decentralised cloud storage network designed to allow users to store data through a distributed network of independent storage node operators. The network is intended to support secure and reliable file storage by encrypting files, dividing them into smaller pieces and distributing them across multiple nodes using redundancy and erasure-coding mechanisms. This structure is designed to support data durability, availability and privacy, while making use of distributed storage capacity rather than relying on a single centralised cloud provider.

The SRX crypto-asset is intended to function as the native token of the StorX ecosystem. It may be used for payments relating to storage and retrieval services, compensation of storage node operators, staking by network participants, and incentive distribution within the network. Storage providers may be required or encouraged to hold or stake SRX as part of their participation in the network, with staking intended to support network security, discourage misconduct and contribute to provider reputation within the StorX ecosystem.

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 a service supplied solely by the issuer.

StorX Foundation is seeking admission to trading on the Payward Global Solutions LTD (“Kraken”) platform in the European Union in accordance with Article 5 of Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on Markets in Crypto-Assets, and amending Regulations (EU) No 1093/2010 and (EU) No 1095/2010 and Directives 2013/36/EU and (EU) 2019/1937. The admission to trading is not accompanied by a public offer of the crypto-asset.

StorX Foundation is engaged in the development of decentralised cloud storage infrastructure.

At the time of drafting, audited or unaudited financial statements of StorX Foundation are not publicly available. As such, this white paper cannot provide quantitative financial information, including revenue, profit or loss, and equity, for the last three financial years. Prospective holders should assume that StorX Foundation is an early-stage entity, with financial performance primarily dependent on the adoption of the StorX network and related services, and should treat the absence of published financial statements as a material issuer-related risk.

StorX is a decentralised cloud storage network designed to enable secure and cost-efficient file storage through a distributed network of independent storage node operators. The project is intended to provide an alternative to traditional centralised cloud storage services by allowing users to store data across decentralised infrastructure, while node operators may provide available storage capacity to the network.

The StorX network supports storage use cases such as backups, archiving, Web2 and Web3 asset storage, and the storage of different data formats, including audio and video files. Data stored on the network is intended to be encrypted, divided into smaller pieces and distributed across multiple storage nodes through erasure coding and related cryptographic mechanisms. This structure is designed to support data durability, redundancy, privacy and availability over time.

The SRX crypto-asset is intended to function as the native token of the StorX network. Its uses include payment for storage and retrieval services, compensation of storage providers, staking by participants, and incentive distribution within the network. Storage providers may be required or encouraged to hold or stake SRX as part of their participation in the network, with staking also intended to support network security and discourage misconduct. The project documentation also describes staking rewards, including inflationary rewards and potential participation in network spend.

The project does not grant holders ownership, profit-participation rights, redemption rights, or legal claims against the project entity or other contributors. The role of SRX is technical and economic in nature and relates to participation in the StorX ecosystem, including storage payments, provider incentives, staking and related network functions. The continued development, adoption and operation of the StorX network remain subject to technical, economic, market and regulatory considerations, and future functionality may change over time.

This section provides an overview of the historical developments related to the SRX 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. The implementation of past milestones cannot be assumed to continue in the future, and future changes may have adverse effects for token holders.

Past milestones:

- Mainnet launch announcement (Q4 2023): StorX Network announced that it planned to launch its mainnet in Q4 2023, marking a key step in the development of the StorX decentralised storage network.

- DePINHub listing and recognition (2025-01-08): StorX was included in DePINHub, reflecting recognition of the project within the broader decentralised physical infrastructure network ecosystem.

- Vault Sharing feature (Q1 2025): StorX introduced Vault Sharing within the StorX Dashboard, allowing users to securely share stored data with others while maintaining privacy and control.

- AI Tax Agent use case (Q3 2025): StorX showcased an AI-powered Tax Agent use case, demonstrating how sensitive financial data, such as invoices, receipts and tax files, can be stored using decentralised storage with a focus on user control, resilience and privacy.

- Tools page launch (Q1 2026): StorX launched a Tools page at https://tools.storx.io featuring 10 tools for community use, with the stated objective of expanding ecosystem utility and supporting users and developers.

Future milestones:

- Ongoing network and ecosystem growth (from 2026 onwards): We intend to continue expanding the StorX global node network, integrations and S3-compatible decentralised storage offering. By April 2026, the StorX network had grown to more than 1000 nodes across more than 50 countries. Future growth remains subject to adoption, technical development, market conditions and continued ecosystem participation.

In January 2021, the project completed a private funding round in the amount of USD 1,000,000. In July 2021, the project subsequently raised an additional USD 800,000 through community placements, bringing the aggregate disclosed funding amount to USD 1,800,000.

The project does not intend to raise new funds.

The purpose of seeking admission to trading is to enable the crypto-asset to be listed on a regulated platform in accordance with the applicable provisions of Regulation (EU) 2023/1114 and Commission Implementing Regulation (EU) 2024/2984. The white paper has been drawn up to comply with the transparency requirements applicable to trading venues.

Holder restrictions are subject to the rules applicable to the crypto-asset service provider, as well as any additional restrictions that provider may impose.

The token is intended to be listed on the trading platform operated by Payward Global Solutions LTD ("Kraken"). Access to this platform depends on regional availability and user eligibility under Kraken’s terms and conditions. Investors should consult Kraken’s official documentation to determine whether they meet the requirements for account creation and token trading.

The costs involved in accessing the trading platform depend on the specific fee structure and terms of the respective crypto-asset service provider. These may include trading fees, deposit or withdrawal charges, and network-related gas fees. Investors are advised to consult the applicable fee schedule of the chosen platform before engaging in trading activities.

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

MiCA-compliant crypto-asset service providers shall have strong measures in place to manage conflicts of interest. Due to the broad audience this white paper addresses, potential investors should always check the conflicts-of-interest policy of their respective counterparty.

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

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

The SRX crypto-asset is intended to function as the native technical and economic component of the StorX network. Its uses include payment for storage and retrieval services, compensation of independent storage node operators, staking by participants, and incentive distribution within the network.

Users may use SRX to pay for cloud storage services provided through the StorX network. Storage providers may receive SRX as compensation for making storage capacity available and for supporting the storage and retrieval of user data. The SRX crypto-asset may also be staked by participants as part of their involvement in the network, with staking intended to support network security, discourage misconduct and contribute to the reputation and participation framework for storage providers.

The StorX network is designed so that economic incentives support reliable data storage over time. Rewards may include staking rewards, inflationary rewards and a share of network spend generated from users paying for storage services. The use of SRX within the network is therefore operational in nature and relates to storage payments, provider compensation, staking, incentives and related network functions.

The SRX crypto-asset does not grant ownership, profit-participation rights, redemption rights, repayment rights, or any legal claim against the issuer, the StorX network, storage providers or other contributors. Any rewards or incentives depend on the functioning, adoption and continued operation of the StorX network and may be modified, reduced or discontinued over time.

Future milestones:

- Ongoing network and ecosystem growth (from 2026 onwards): We intend to continue expanding the StorX global node network, integrations and S3-compatible decentralised storage offering. By April 2026, the StorX network had grown to more than 1000 nodes across more than 50 countries. Future growth remains subject to adoption, technical development, market conditions and continued ecosystem participation.

The crypto-asset referred to herein is a crypto-asset other than EMTs and ARTs, and is available on the XDC 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 further services are currently planned.

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 legally enforceable claim against the issuer of the crypto-asset or any third party.

As the crypto-asset does not confer 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 project’s technical infrastructure – such as participation mechanisms or protocol-level features – serves operational purposes only and does not create, evidence, or constitute any contractual or statutory entitlement.

As the crypto-asset does not confer any legally enforceable rights or obligations, there are no conditions or mechanisms for modifying such rights or obligations. 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 rights exist and no rights arise under applicable law or regulation. Holders should not interpret technical updates or governance-related changes as amendments to legally binding entitlements.

No future public offers of crypto-assets are currently planned by the issuer.

The crypto-assets themselves are not subject to any technical or contractual transfer restrictions and are generally freely transferable. However, crypto-asset service providers may impose restrictions on buyers or sellers in accordance with applicable laws, internal policies or contractual terms agreed with their clients.

Not applicable.

Applicable law likely depends on the location of any particular transaction with the token.

Competent court likely depends on the location of any particular transaction with the token.

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

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

The following applies to XDC:

The XDC Network operates as a Layer-1 blockchain using a customised Ethereum-based protocol architecture. It is compatible with the Ethereum Virtual Machine (EVM), allowing smart contracts written for Ethereum-compatible environments to be deployed and executed on the XDC Network. The network uses an account-based model, gas-based transaction execution, JSON-RPC interfaces and common Ethereum-compatible development libraries, including Web3.js and Ethers.js.

The protocol is governed by the XinFin Delegated Proof-of-Stake consensus protocol 2.0 (XDPoS 2.0), which combines delegated staking, validator election and a Byzantine Fault Tolerant consensus engine. The execution layer follows Ethereum-style transaction processing and smart-contract execution, while the consensus layer applies XDC-specific validator selection, block production and finality rules.

XDC uses standard cryptographic primitives common to Ethereum-compatible networks, including Keccak-256 hashing and ECDSA signatures over the secp256k1 elliptic curve. Addresses are represented as 20-byte identifiers derived from public keys. The network also supports token standards developed for the XDC ecosystem, including XRC-20 for fungible tokens and XRC721 for non-fungible tokens. In addition, the network is designed to support interoperability with enterprise and financial infrastructure, including compatibility objectives relating to ISO 20022 messaging and integration with external systems such as R3 Corda.

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

The following applies to XDC:

The XDC Network functions as a decentralised ledger for the transfer and recording of XDC and other XDC-based crypto-assets. The ledger records transactions in an append-only blockchain structure, with blocks cryptographically linked through hashes of previous blocks. The network maintains account balances, smart-contract code and contract storage as part of its state.

The network is EVM-compatible and supports smart-contract deployment and execution using languages such as Solidity and Vyper. Transaction execution follows a gas model similar to Ethereum, under which transaction senders pay fees according to the computational and storage resources required by their transactions. The network supports public mainnet activity and also provides architecture for private or permissioned subnets. Such subnets may be used for enterprise-specific applications and may anchor state or checkpoints to the public XDC mainnet.

Users interact with the network through compatible wallets, RPC endpoints, explorers and developer tools. Users must securely manage the private keys, seed phrases and other credentials associated with their wallets. Loss or compromise of private keys may result in irreversible loss of access to the associated XDC or XDC-based crypto-assets.

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

The following applies to XDC:

The XDC Network uses the XinFin Delegated Proof-of-Stake consensus protocol 2.0 (XDPoS 2.0). Under this mechanism, token holders may stake or delegate XDC in order to support Masternode candidates. Masternode candidates are required to lock a minimum stake of 10,000,000 XDC in order to become eligible for participation. The active validator set is composed of elected Masternodes, which are responsible for proposing blocks, validating transactions and maintaining the state of the network.

XDPoS 2.0 incorporates a Byzantine Fault Tolerant consensus design based on the HotStuff state machine replication protocol. Active Masternodes participate in block production and validation, with block proposal taking place through a rotation mechanism. The validator set is refreshed or reassessed on an epoch basis, with one epoch consisting of 900 blocks. The active validator set on the XDC mainnet is generally described as consisting of 108 Masternodes.

Finality is intended to be deterministic rather than probabilistic. Once the required validator agreement is reached under the BFT consensus process, blocks are treated as final according to the protocol rules. The network also includes standby nodes, which are designed to support network availability and failover capacity but do not actively produce blocks in the same manner as Masternodes. Full nodes may verify blocks and transactions according to protocol rules, but only elected Masternodes participate directly in block production.

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

The following applies to XDC:

The XDC Network secures transaction processing and validator participation through a combination of protocol rewards, staking incentives, transaction fees and penalties. Masternode operators may receive rewards for validating transactions, signing blocks, maintaining uptime and participating in the network during each epoch. Token holders who delegate XDC to Masternodes may also receive a share of the applicable rewards, depending on the relevant delegation and reward distribution rules.

The reward mechanism is based on the staking and participation status of eligible nodes. Both Masternodes and standby nodes are described as being subject to a minimum staking requirement of 10,000,000 XDC. Masternodes are described as eligible for a fixed annual reward rate of 10%, corresponding to 1,000,000 XDC per year or approximately 83,333.33 XDC per month. Standby nodes are described as eligible for a lower fixed annual reward rate of 8%, corresponding to 800,000 XDC per year or approximately 66,666.67 XDC per month.

Rewards are also described as being distributed on an epoch basis. One epoch consists of 900 blocks, approximately 30 minutes, resulting in approximately 48 epochs per day. The total reward per epoch is described as 5,000 XDC, of which 10%, corresponding to 500 XDC, is allocated as a foundation share. The remaining 4,500 XDC is distributed among eligible nodes based on activity, including block validation by Masternodes and signature participation or availability by standby nodes. For Masternodes, the indicated reward per epoch is approximately 41.67 XDC per node, corresponding to approximately 2,000.16 XDC per day and approximately 60,000 XDC per month, subject to participation rate, network conditions and validator set size.

Transaction fees are paid by users submitting transactions to the network. Fees are calculated through a gas-based model, under which more complex transactions or smart-contract interactions require more gas than simple transfers. The XDC Network is generally designed to support low transaction costs, while maintaining a fee mechanism to compensate network participants and discourage spam or abusive usage.

The protocol also uses economic penalties to support network security. Validators that engage in malicious or improper conduct may be subject to slashing or other protocol-level consequences. These mechanisms are intended to align validator behaviour with the continued operation, consistency and security of the network. In addition to protocol-enforced incentives, ecosystem-level grants, bounties or other support programmes may exist, but such programmes are separate from the automatic consensus and fee mechanisms of the XDC protocol.

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.

1. Regulatory and Compliance

Regulatory frameworks applicable to crypto-asset services in the European Union and in third countries are evolving. Supervisory authorities may introduce, interpret, or enforce rules that affect (i) the eligibility of this crypto-asset for admission to trading, (ii) the conditions under which a crypto-asset service provider may offer trading, custody, or transfer services for it, or (iii) the persons or jurisdictions to which such services may be provided. As a result, the crypto-asset service provider admitting this crypto-asset to trading may be required to suspend, restrict, or terminate trading or withdrawals for regulatory reasons, even if the crypto-asset itself continues to function on its underlying network.

2. Trading venue and connection risk

Trading in the crypto-asset depends on the uninterrupted operation of the trading venues on which it is listed and, where applicable, on its technical connections to external liquidity sources or venues. Interruptions such as system downtime, maintenance, faulty integrations, API changes, or failures at an external venue can temporarily prevent order placement, execution, deposits, or withdrawals, even when the underlying blockchain is functioning. In addition, trading platforms in emerging markets may operate under differing governance, compliance, and oversight standards, which can increase the risk of operational failures or disorderly market conditions.

3. Market formation and liquidity conditions

The price and tradability of the crypto-asset depend on actual trading activity on the venues to which the service provider is connected, whether centralised exchanges (CEXs) or decentralised exchanges (DEXs). Trading volumes may at times be low, order books thin, or liquidity concentrated on a single venue. In such conditions, buy or sell orders may not be executed in full or may be executed only at a less favourable price, resulting in slippage.

Volatility: The market price of the crypto-asset may fluctuate significantly over short periods, including for reasons that are not linked to changes in the underlying project or protocol. Periods of limited liquidity, shifts in overall market sentiment, or trading on only a small number of CEXs or DEXs can amplify these movements and lead to higher slippage when orders are executed. As a result, investors may be unable to sell the crypto-asset at or close to a previously observed price, even where no negative project-specific event has occurred.

4. Counterparty and service provider dependence

The admission of the crypto-asset to trading may rely on several external parties, such as connected centralised or decentralised trading venues, liquidity providers, brokers, custodians, or technical integrators. If any of these counterparties fail to perform, suspend their services, or apply internal restrictions, the trading, deposit, or withdrawal of the crypto-asset on the listing crypto-asset service provider can be interrupted or halted.

Quality of counterparties: Trading venues and service providers in certain jurisdictions may operate under regulatory or supervisory standards that are lower or differently enforced than those applicable in the European Union. In such environments, deficiencies in governance, risk management, or compliance may remain undetected, which increases the probability of abrupt service interruptions, investigations, or forced wind-downs.

Delisting and service suspension: The crypto-asset’s availability may depend on the internal listing decisions of these counterparties. A delisting or suspension on a key connected venue can materially reduce liquidity or make trading temporarily impossible on the admitting service provider, even if the underlying crypto-asset continues to function.

Insolvency of counterparties: If a counterparty involved in holding, routing, or settling the crypto-asset becomes insolvent, enters restructuring, or is otherwise subject to resolution measures, assets held or processed by that counterparty may be frozen, become temporarily unavailable, or be recoverable only in part or not at all, which can result in losses for clients whose positions were maintained through that counterparty. This risk applies in particular where client assets are held on an omnibus basis or where segregation is not fully recognised in the counterparty’s jurisdiction.

5. Operational and information risks

Due to the irrevocability of blockchain transactions, incorrect transaction approvals or the use of wrong networks or addresses will typically make the transferred funds irrecoverable. Because trading may also rely on technical connections to other venues or service providers, downtime or faulty code in these connections can temporarily block trading, deposits, or withdrawals even when the underlying blockchain is functioning. In addition, different groups of market participants may have unequal access to technical, governance, or project-related information, which can lead to information asymmetry and place less informed investors at a disadvantage when making trading decisions.

6. Market access and liquidity concentration risk

If the crypto-asset is only available on a limited number of trading platforms or through a single market-making entity, this may result in reduced liquidity, greater price volatility, or periods of inaccessibility for retail holders.

1. Insolvency of the issuer

As with any commercial entity, the issuer may face insolvency risks. These may result from insufficient funding, low market interest, mismanagement, or external shocks (e.g. pandemics, armed conflicts). In such a case, ongoing development, support, and governance of the project may cease, potentially affecting the viability and tradability of the crypto-asset.

2. Legal and regulatory risks

The issuer operates in a dynamic and evolving regulatory environment. Failure to comply with applicable laws or regulations in relevant jurisdictions may result in enforcement actions, penalties, or restrictions on the project’s operations. These may negatively impact the crypto-asset’s availability, market acceptance, or legal status.

3. Operational risks

The issuer may fail to implement adequate internal controls, risk management, or governance processes. This can result in operational disruptions, financial losses, delays in updating the white paper, or reputational damage.

4. Governance and decision-making

The issuer’s management body is responsible for key strategic, operational, and disclosure decisions. Ineffective governance, delays in decision-making, or lack of resources may compromise the stability of the project and its compliance with MiCA requirements. High concentration of decision-making authority or changes in ownership/control can amplify these risks.

5. Reputational risks

The issuer’s reputation may be harmed by internal failures, external accusations, or association with illicit activity. Negative publicity can reduce trust in the issuer and impact the perceived legitimacy or value of the crypto-asset.

6. Counterparty dependence

The issuer may depend on third-party providers for certain core functions, such as technology development, marketing, legal advice, or infrastructure. If these partners discontinue their services, change ownership, or underperform, the issuer’s ability to operate the project or maintain investor communication may be impaired. This could disrupt project continuity or undermine market confidence, ultimately affecting the crypto-asset’s value.

1. Valuation risk

The crypto-asset does not represent a claim, nor is it backed by physical assets or legal entitlements. Its market value is driven solely by supply and demand dynamics and may fluctuate significantly. In the absence of fundamental value anchors, such assets can lose their entire market value within a very short time. Historical market behaviour has shown that some types of crypto-assets have become worthless. Investors should be aware that this crypto-asset may lose all of its value.

2. Market volatility risk

Crypto-asset prices can fluctuate sharply due to changes in market sentiment, macroeconomic conditions, regulatory developments, or technology trends. Such volatility may result in rapid and significant losses. Holders should be prepared for the possibility of losing the full amount invested.

3. Liquidity and price-determination risk

Low trading volumes, fragmented trading across venues, or the absence of active market makers can restrict the ability to buy or sell the crypto-asset. In such situations, it is not guaranteed that an observable market price will exist at all times. Spreads may widen materially, and orders may only be executable under unfavourable conditions, which can make liquidation costly or temporarily impossible.

4. Crypto-asset security risk

Loss or theft of private keys, unauthorised access to wallets, or failures of custodial or exchange service providers can result in the irreversible loss of assets. Because blockchain transactions are final, recovery of funds after a compromise is generally impossible.

5. Fraud and scam risk

The pseudonymous and irreversible nature of blockchain transactions can attract fraudulent schemes. Typical forms include fake or unauthorised crypto-assets imitating established ones, phishing attempts, deceptive airdrops, or social-engineering attacks. Investors should exercise caution and verify the authenticity of counterparties and information sources.

6. Legal and regulatory reclassification risk

Legislative or regulatory changes in the European Union or in the Member State where the crypto-asset is admitted to trading may alter its legal classification, permitted uses, or tradability. In third countries, the crypto-asset may be treated as a financial instrument or security, which can restrict its offering, trading, or custody.

7. Absence of investor protection

The crypto-asset is not covered by investor-compensation or deposit-guarantee schemes. In the event of loss, fraud, or insolvency of a service provider, holders may have no access to recourse mechanisms typically available in regulated financial markets.

8. Counterparty risk

Reliance on third-party exchanges, custodians, or intermediaries exposes holders to operational failures, insolvency, or fraud of these parties. Investors should conduct due diligence on service providers, as their failure may lead to the partial or total loss of held assets.

9. Reputational risk

Negative publicity related to security incidents, misuse of blockchain technology, or associations with illicit activity can damage public confidence and reduce the crypto-asset’s market value.

10. Community and sentiment risk

Because the crypto-asset’s perceived relevance and expected future use depend largely on community engagement and the prevailing sentiment, a loss of public interest, negative coverage or reduced activity of key contributors can materially reduce market demand.

11. Macroeconomic and interest-rate risk

Fluctuations in interest rates, exchange rates, general market conditions, or overall market volatility can influence investor sentiment towards digital assets and affect the crypto-asset’s market value.

12. Taxation risk

Tax treatment varies across jurisdictions. Holders are individually responsible for complying with all applicable tax laws, including the reporting and payment of taxes arising from the acquisition, holding, or disposal of the crypto-asset.

13. Anti-money-laundering and counter-terrorist financing risk

Wallet addresses or transactions connected to the crypto-asset may be linked to sanctioned or illicit activity. Regulatory responses to such findings may include transfer restrictions, reporting obligations, or the freezing of assets on certain venues.

14. Market-abuse risk

Due to limited oversight and transparency, crypto-assets may be vulnerable to market-abuse practices such as spoofing, pump-and-dump schemes, or insider trading. Such activities can distort prices and expose holders to sudden losses.

15. Legal ownership and jurisdictional risk

Depending on the applicable law, holders of the crypto-asset may not have enforceable ownership rights or effective legal remedies in cases of disputes, fraud, or service failure. In certain jurisdictions, access to exchanges or interfaces may be restricted by regulatory measures, even if on-chain transfer remains technically possible.

16. Concentration risk

A large proportion of the total supply may be held by a small number of holders. This can enable market manipulation, governance dominance, or sudden large-scale liquidations that adversely affect market stability, price levels, and investor confidence.

As this white paper relates to admission to trading of the crypto-asset, the risk description below reflects general implementation risks typically associated with crypto-asset projects and relevant for the crypto-asset service provider.

Delays, failures, or changes in the implementation of the project as outlined in its public roadmap or technical documentation may negatively impact the perceived credibility or usability of the crypto-asset. This includes risks related to project governance, resource allocation, technical delivery, and team continuity.

Key-person risk: The project may rely on a limited number of individuals for development, maintenance, or strategic direction. The departure, incapacity, or misalignment of these individuals may delay or derail the implementation.

Timeline and milestone risk: Project milestones may not be met as announced. Delays in feature releases, protocol upgrades, or external integrations can undermine market confidence and affect the adoption, use, or value of the crypto-asset.

Delivery risk: Even if implemented on time, certain functionalities or integrations may not perform as intended or may be scaled back during execution, limiting the crypto-asset’s practical utility.

As this white paper relates to admission to trading of the crypto-asset, the following risks concern the underlying distributed ledger technology (DLT), its supporting infrastructure, and related technical dependencies. Failures or vulnerabilities in these systems may affect the availability, integrity, or transferability of the crypto-asset.

1. Blockchain dependency risk

The functionality of the crypto-asset depends on the continuous and stable operation of the blockchain(s) on which it is issued. Network congestion, outages, or protocol errors may temporarily or permanently disrupt on-chain transactions. Extended downtime or degradation in network performance can affect trading, settlement, or the usability of the crypto-asset.

2. Smart contract vulnerability risk

The smart contract that defines the crypto-asset’s parameters or governs its transfers may contain coding errors or security vulnerabilities. Exploitation of such weaknesses can result in unintended token minting, permanent loss of funds, or disruption of token functionality. Even after external audits, undetected vulnerabilities may persist due to the immutable nature of deployed code.

3. Wallet and key-management risk

The custody of crypto-assets relies on secure private key management. Loss, theft, or compromise of private keys results in irreversible loss of access. Custodians, trading venues, or wallet providers may be targeted by cyberattacks. Compatibility issues between wallet software and changes to the blockchain protocol (e.g. network upgrades) can further limit user access or the ability to transfer the crypto-asset.

Outdated or vulnerable wallet software:

Users relying on outdated, unaudited, or unsupported wallet software may face compatibility issues, security vulnerabilities, or failures when interacting with the blockchain. Failure to update wallet software in line with protocol developments can result in transaction errors, loss of access, or exposure to known exploits.

4. Network security risks

Attack risks: Blockchains may be subject to denial-of-service (DoS) attacks, 51% attacks, or other exploits targeting the consensus mechanism. These can delay transactions, compromise finality, or disrupt the accurate recording of transfers.

Centralisation concerns: Despite claims of decentralisation, a relatively small number of validators or a high concentration of stake may increase the risk of collusion, censorship, or coordinated network downtime, which can affect the resilience and operational reliability of the crypto-asset.

5. Bridge and interoperability risk

Where tokens can be bridged or wrapped across multiple blockchains, vulnerabilities in bridge protocols, validator sets, or locking mechanisms may result in loss, duplication, or misrepresentation of assets. Exploits or technical failures in these systems can instantly impact circulating supply, ownership claims, or token fungibility across chains.

6. Forking and protocol-upgrade risk

Network upgrades or disagreements among node operators or validators can result in blockchain “forks”, where the blockchain splits into two or more incompatible versions that continue separately from a shared past. This may lead to duplicate token representations or incompatibilities between exchanges and wallets. Until consensus stabilises, trading or transfers may be disrupted or misaligned. Such situations may be difficult for retail holders to navigate, particularly when trading platforms or wallets display inconsistent token information.

7. Economic-layer and abstraction risk

Mechanisms such as gas relayers, wrapped tokens, or synthetic representations may alter the transaction economics of the underlying token. Changes in transaction costs, token demand, or utility may reduce its usage and weaken both its economic function and perceived value within its ecosystem.

8. Spam and network-efficiency risk

High volumes of low-value (“dust”) or automated transactions may congest the network, slow validation times, inflate ledger size, and raise transaction costs. This can impair performance, reduce throughput, and expose address patterns to analysis, thereby reducing network efficiency and privacy.

9. Front-end and access-interface risk

If users rely on centralised web interfaces or hosted wallets to interact with the blockchain, service outages, malicious compromises, or domain expiries affecting these interfaces may block access to the crypto-asset, even while the blockchain itself remains fully functional. Dependence on single web portals introduces a critical point of failure outside the DLT layer.

10. Decentralisation claim risk

While the technical infrastructure may appear distributed, the actual governance or economic control of the project may lie with a small set of actors. This disconnect between marketing claims and structural reality can lead to regulatory scrutiny, reputational damage, or legal uncertainty – especially if the project is presented as ‘community-governed’ without substantiation.

None.

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

The following applies to XDC:

The XDC Network uses the XinFin Delegated Proof-of-Stake consensus protocol 2.0 (XDPoS 2.0). Under this mechanism, token holders may stake or delegate XDC in order to support Masternode candidates. Masternode candidates are required to lock a minimum stake of 10,000,000 XDC in order to become eligible for participation. The active validator set is composed of elected Masternodes, which are responsible for proposing blocks, validating transactions and maintaining the state of the network.

XDPoS 2.0 incorporates a Byzantine Fault Tolerant consensus design based on the HotStuff state machine replication protocol. Active Masternodes participate in block production and validation, with block proposal taking place through a rotation mechanism. The validator set is refreshed or reassessed on an epoch basis, with one epoch consisting of 900 blocks. The active validator set on the XDC mainnet is generally described as consisting of 108 Masternodes.

Finality is intended to be deterministic rather than probabilistic. Once the required validator agreement is reached under the BFT consensus process, blocks are treated as final according to the protocol rules. The network also includes standby nodes, which are designed to support network availability and failover capacity but do not actively produce blocks in the same manner as Masternodes. Full nodes may verify blocks and transactions according to protocol rules, but only elected Masternodes participate directly in block production.

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

The following applies to XDC:

The XDC Network secures transaction processing and validator participation through a combination of protocol rewards, staking incentives, transaction fees and penalties. Masternode operators may receive rewards for validating transactions, signing blocks, maintaining uptime and participating in the network during each epoch. Token holders who delegate XDC to Masternodes may also receive a share of the applicable rewards, depending on the relevant delegation and reward distribution rules.

The reward mechanism is based on the staking and participation status of eligible nodes. Both Masternodes and standby nodes are described as being subject to a minimum staking requirement of 10,000,000 XDC. Masternodes are described as eligible for a fixed annual reward rate of 10%, corresponding to 1,000,000 XDC per year or approximately 83,333.33 XDC per month. Standby nodes are described as eligible for a lower fixed annual reward rate of 8%, corresponding to 800,000 XDC per year or approximately 66,666.67 XDC per month.

Rewards are also described as being distributed on an epoch basis. One epoch consists of 900 blocks, approximately 30 minutes, resulting in approximately 48 epochs per day. The total reward per epoch is described as 5,000 XDC, of which 10%, corresponding to 500 XDC, is allocated as a foundation share. The remaining 4,500 XDC is distributed among eligible nodes based on activity, including block validation by Masternodes and signature participation or availability by standby nodes. For Masternodes, the indicated reward per epoch is approximately 41.67 XDC per node, corresponding to approximately 2,000.16 XDC per day and approximately 60,000 XDC per month, subject to participation rate, network conditions and validator set size.

Transaction fees are paid by users submitting transactions to the network. Fees are calculated through a gas-based model, under which more complex transactions or smart-contract interactions require more gas than simple transfers. The XDC Network is generally designed to support low transaction costs, while maintaining a fee mechanism to compensate network participants and discourage spam or abusive usage.

The protocol also uses economic penalties to support network security. Validators that engage in malicious or improper conduct may be subject to slashing or other protocol-level consequences. These mechanisms are intended to align validator behaviour with the continued operation, consistency and security of the network. In addition to protocol-enforced incentives, ecosystem-level grants, bounties or other support programmes may exist, but such programmes are separate from the automatic consensus and fee mechanisms of the XDC protocol.

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 XDC Network is calculated first. A proportionate share of that energy use is then attributed to the token based on its expected 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 determined using public information sites, open-source and in-house-developed crawlers. Where no information is available on the geographic distribution of nodes, comparable reference networks are used, taking into account similarities in incentivisation structure and consensus mechanism. This geographic information is then combined with publicly available data from Our World in Data. The resulting intensity is calculated as the marginal energy consumption with respect to one additional 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]. Underlying sources: Ember, “Yearly Electricity Data Europe”; Ember, “Yearly Electricity Data”; Energy Institute, “Statistical Review of World Energy”. Retrieved from: https://ourworldindata.org/grapher/share-electricity-renewables

To determine GHG emissions, the locations of the nodes are determined using public information sites, open-source crawlers, and crawlers developed in-house. Where no information is available on the geographic distribution of nodes, comparable reference networks are used, taking into account similarities in incentivisation structure and consensus mechanism. This geographic information is then combined with publicly available data from Our World in Data. The resulting intensity is calculated as the marginal emission intensity with respect to one additional 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]. Underlying sources: Ember, “Yearly Electricity Data Europe”; Ember, “Yearly Electricity Data”; Energy Institute, “Statistical Review of World Energy”. Retrieved from: https://ourworldindata.org/grapher/carbon-intensity-electricity. Licensed under CC BY 4.0.