Table of Contents

Summary

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

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

Part C - Information about the operator of the trading platform

Information about the operator of the trading platform in cases where it draws up the crypto-asset white paper and information about other persons drawing the crypto-asset white paper pursuant to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114.

Part D - Information about the crypto-asset project

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

Part F - Information about the crypto-assets

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

Part H - Information on the underlying technology

Part I - Information on risks

Part J - Information on sustainability indicators

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

Detailed Information

01 Date of notification

2025-07-31

02 Statement in accordance with Article 6(3) of Regulation (EU) 2023/1114

This crypto-asset white paper has not been approved by any competent authority in any Member State of the European Union. The offeror of the crypto-asset is solely responsible for the content of this crypto-asset white paper.

03 Compliance statement in accordance with Article 6(6) of Regulation (EU) 2023/1114

This crypto-asset white paper complies with Title II of Regulation (EU) 2023/1114 of the European Parliament and of the Council and, to the best of the knowledge of the management body, the information presented in the crypto-asset white paper is fair, clear and not misleading and the crypto-asset white paper makes no omission likely to affect its import.

04 Statement in accordance with Article 6(5), points (a), (b), (c), of Regulation (EU) 2023/1114

The crypto-asset referred to in this crypto-asset white paper may lose its value in part or in full, may not always be transferable and may not be liquid.

05 Statement in accordance with Article 6(5), point (d), of Regulation (EU) 2023/1114

The utility token referred to in this white paper may not be exchangeable against the good or service promised in this white paper, especially in the case of a failure or discontinuation of the crypto-asset project.

06 Statement in accordance with Article 6(5), points (e) and (f), of Regulation (EU) 2023/1114

The crypto-asset referred to in this white paper is not covered by the investor compensation schemes under Directive 97/9/EC of the European Parliament and of the Council or the deposit guarantee schemes under Directive 2014/49/EU of the European Parliament and of the Council.

Summary

07 Warning in accordance with Article 6(7), second subparagraph, of Regulation (EU) 2023/1114

Warning

This summary should be read as an introduction to the crypto-asset white paper. The prospective holder should base any decision to purchase this crypto-asset on the content of the crypto-asset white paper as a whole and not on the summary alone. The offer to the public of this crypto-asset does not constitute an offer or solicitation to purchase financial instruments and any such offer or solicitation can be made only by means of a prospectus or other 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.

08 Characteristics of the crypto-asset

ALKIMI is a utility token that enables participation in Alkimi's decentralised advertising exchange ecosystem. The token operates on the Sui blockchain and serves as the primary mechanism for accessing Alkimi's complete suite of services related to the buying and selling of digital ads online, in app and on connected TVs. The services include:

• Buying Display Advertising
• Buying Video Advertising
• Buying Connected TV Advertising
• Selling Display Advertising
• Selling Video Advertising
• Selling Connected TV Advertising
• Accessing liquidity to purchase advertising
• Accessing liquidity for the accrued revenue from selling advertising

09 Information about the quality and quantity of goods or services to which the utility tokens give access and restrictions on the transferability

The quantity of goods is proportional to the number of tokens held. The proportion varies by product. The types of products are all digital in nature. Holders get access to the various Alkimi platforms and can use the suite of products and services available on the platforms.

There are no restrictions on transfer at an Alkimi or Sui level.

10 Key information about the offer to the public or admission to trading

XSM Limited (BVI) seeks admission of the ALKIMI token on trading platforms operating within the European Union ("EU") or the European Economic Area ("EEA") ("Trading Platforms"). In seeking admission to trading, the Company complies with its obligations under article 5 of Regulation (EU) 2023/1114 ("MiCA").

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

A.1 Name

XSM Limited (BVI)

A.2 Legal form

Limited

A.3 Registered address

Trinity Chambers, PO Box 4301, Road Town, Tortola, British Virgin Islands

A.4 Head office

See A.3

A.5 Registration date

2021-08-25

A.6 Legal entity identifier

N/A

A.7 Another identifier required pursuant to applicable national law

2073719 (BVI)

A.8 Contact telephone number

+44 7980933229

A.9 E-mail address

hello@alkimi.org

A.10 Response time (Days)

5 business days

A.11 Parent company

N/A

A.12 Members of the management body

The three individuals named below are all directors of XSM Limited (BVI):

A.13 Business activity

XSM Limited (BVI) business activity involves serving as the issuer of the ALKIMI token to implement and decentralise the Alkimi Ad Exchange, an innovative decentralized ad exchange spearheading the adoption of web3 in the digitial advertising sector.

Subject to certain restrictions (namely to persons or entities located in jurisdictions subject to comprehensive sanctions, as well as those listed on sanctions lists maintained by the EU, UN, UK, or US), the Walrus Network is intended to operate globally.

A.14 Parent company business activity

Alchemy VC Limited (located in the United Kingdom) operates as a strategic holding entity with a focus on the digital advertising and blockchain technology sectors. It holds and manages equity interests in subsidiaries that develop and operate innovative platforms at the intersection of digital marketing, data monetization, and decentralized technologies. One of its key subsidiaries acts as the issuer of a blockchain-based utility token, which serves as a core component within an ecosystem designed to enhance transparency, user engagement, and value exchange in digital advertising. The offeror provides strategic direction, financial oversight, and governance, while fostering innovation and long-term growth across its portfolio.

A.15 Newly established

False

A.16 Financial condition for the past three years

XSM Limited (BVI) generates revenue primarily through fees associated with token operations and ecosystem activities. The entity maintains a contractual arrangement with Alchemy Exchange Limited, the UK-based operating subsidiary, whereby management fees are charged for operational services and platform maintenance. This structure ensures XSM Limited (BVI) benefits from the underlying advertising exchange's proven business model while maintaining appropriate corporate separation. The company maintains a healthy balance sheet with adequate capital reserves to support ongoing token operations, strategic initiatives, and buyback activities. Financial management focuses on maintaining liquidity for operational requirements while supporting broader ecosystem development through the Sui migration and infrastructure expansion.

A.17 Financial condition since registration

See A.16.

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

B.1 Issuer different from offeror or person seeking admission to trading

False

B.2 Name

Not applicable

B.3 Legal form

Not applicable

B.4 Registered address

Not applicable

B.5 Head office

Not applicable

B.6 Registration date

Not applicable

B.7 Legal entity identifier

Not applicable

B.8 Another identifier required pursuant to applicable national law

Not applicable

B.9 Parent company

Not applicable

B.10 Members of the management body

Not applicable

B.11 Business activity

Not applicable

B.12 Parent company business activity

Not applicable

Part C - Information about the operator of the trading platform

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

Not applicable

C.2 Legal form

Not applicable

C.3 Registered address

Not applicable

C.4 Head office

Not applicable

C.5 Registration date

Not applicable

C.6 Legal entity identifier

Not applicable

C.7 Another identifier required pursuant to applicable national law

Not applicable

C.8 Parent company

Not applicable

C.9 Reason for crypto-asset white paper Preparation

Not applicable

C.10 Members of the management body

Not applicable

C.11 Operator business activity

Not applicable

C.12 Parent company business activity

Not applicable

C.13 Other persons drawing up the crypto-asset white paper according to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114

Not applicable

C.14 Reason for drawing the white paper by persons referred to in Article 6(1), second subparagraph, of Regulation (EU) 2023/1114

Not applicable

Part D - Information about the crypto-asset project

D.1 Crypto-asset project name

Alkimi

D.2 Crypto-assets name

ALKIMI

D.3 Abbreviation

ALKIMI

D.4 Crypto-asset project description

XSM Limited (BVI) offers a utility token that enables participation in Alkimi's decentralised advertising exchange ecosystem. The token operates on the Sui blockchain and serves as the primary mechanism for accessing Alkimi's complete suite of services related to the buying and selling of digital ads online, in app and on connected TVs. The services include:

• Buying Display Advertising
• Buying Video Advertising
• Buying Connected TV Advertising
• Selling Display Advertising
• Selling Video Advertising
• Selling Connected TV Advertising
• Accessing liquidity to purchase advertising
• Accessing liquidity for the accrued revenue from selling advertising

D.5 Details of all natural or legal persons involved in the implementation of the crypto-asset project

XSM Limited (BVI)

D.6 Utility Token Classification

True

D.7 Key Features of Goods/Services for Utility Token Projects

By Holding the ALKIMI token, ALKIMI token holders gain access to Alkimi's Ad Exchange and Labs platform for interaction with the digital ad market, more precisely:

• Buying Display and Video Advertising – accessing the ad exchange to buy iAB standard display and video formats for discount fees
• Buying Connected TV Advertising – access the ad exchange to buy iAB standard Connected TV formats for discounted fees
• Selling Display and Video Advertising – accessing the ad exchange to sell iAB standard display and video formats across respsective publications capable of supporting the iAB display and video formats
• Selling Connected TV Advertising – accessing the ad exchange to sell iAB standard connected tv ad formats across respective broadcasting providers capable of supporting the iAB standard connected tv advertising formats
• Provisioning of liquidity to support the associated payments from buying display, video and connected tv advertising or for the revenue accrued from the selling of display, video and connected tv advertising

D.8 Plans for the token

The ALKIMI token has undergone, or is expected to undergo the following key events:

• August 2025 Launch token on the SUI Layer 1 Blockchain
• August 2025 deploy ad exchange on the SUI Layer 1 Blockchain. As of August 2025, Alkimi's ad exchange has processed over 2 Billion ad transactions
• August 2025 Listing outside the EU/EAA, on various exchanges
• October 2025 Spontaneous listing by exchanges operating within the EU/EEA

D.9 Resource allocation

Many of the resources that support Alkimi, such as technical personnel, experienced management staff, appropriate facilities and infrastructure come from, Alchemy VC Limited as well as XSM Limited (BVI), and other ecosystem participants, each of whom have their own balance sheets to support these efforts. Additionally, the published Tokenomics (available at www.alkimi.org) clearly disclose that 65% of the total supply is allocated to Ecosystem Development and Community Engagement and Growth that is committed to the long-term development and growth of the Alkimi ecosystem, including community grants and programs, developer support, Alkimi core research, incentive programs, Alkimi community events, hackathons, and other ecosystem initiatives.

D.10 Planned use of collected funds or crypto-assets

Not Applicable

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

E.1 Public offering or admission to trading

ATTR

E.2 Reasons for public offer or admission to trading

ALKIMI is the utility token powering the ad exchange. Seeking admission to trading on EU regulated exchanges is necessary to facilitate market access and broader adoption of this innovative protocols decentralised ad exchange.

E.3 Fundraising target

Not applicable. The present white paper is published solely in relation to the admission to trading of the ALKIMI token.

E.4 Minimum subscription goals

Not applicable. See explanation under E.3.

E.5 Maximum subscription goals

Not applicable. See explanation under E.3.

E.6 Oversubscription acceptance

Not applicable. See explanation under E.3.

E.7 Oversubscription allocation

Not applicable. See explanation under E.3.

E.8 Issue price

Not applicable. See explanation under E.3.

E.9 Official currency or any other crypto-assets determining the issue price

Not applicable. See explanation under E.3.

E.10 Subscription fee

Not applicable. See explanation under E.3.

E.11 Offer price determination method

Not applicable. See explanation under E.3.

E.12 Total number of offered/traded crypto-assets

295,000,000 committed to trading; with a fixed maximum supply of 1 Billion ALKIMI. The circulating supply will steadily increase due to scheduled escrow releases.

E.13 Targeted holders

ALL

E.14 Holder restrictions

• The Sui network is permissionless and decentralized. There are no holder restrictions at Sui level.
• The trading platforms in accordance with applicable laws and internal policies may impose restrictions to buyers and sellers of ALKIMI tokens on the trading platforms. Any checks performed to implement such restrictions, notably KYC checks, are neither conducted by the issuer nor the offeror.
• Sanctions and embargoes: Trading platforms may exclude persons or entities located in any jurisdiction subject to comprehensive sanctions or embargoes according to EU law, as well as anyone listed on sanctions lists maintained by the EU, UN, UK, or US ("Prohibited Persons").
• Non-EU Jurisdictions: The offeror may impose additional restrictions on prospective non-EU ALKIMI holders as necessary to comply with non-EU regulatory frameworks.

E.15 Reimbursement notice

Purchasers participating in the offer to the public of crypto-asset will be able to be reimbursed if the minimum target subscription goal is not reached at the end of the offer to the public, if they exercise the right to withdrawal provided for in Article 13 of Regulation (EU) 2023/1114 of the European Parliament and of the Council or if the offer is cancelled.

E.16 Refund mechanism

Not applicable. See explanation under E.3.

E.17 Refund timeline

Not applicable. See explanation under E.3.

E.18 Offer phases

Not applicable. See explanation under E.3.

E.19 Early purchase discount

Not applicable. See explanation under E.3.

E.20 Time-limited offer

Not applicable. See explanation under E.3.

E.21 Subscription period beginning

Not applicable. See explanation under E.3.

E.22 Subscription period end

Not applicable. See explanation under E.3.

E.23 Safeguarding arrangements for offered funds/crypto-assets

The proceeds from the sale are subject to protective measures taken either by the offeror itself or by appointed service providers, which must comply with the requirements of Regulation (EU) 2023/1114.

E.24 Payment methods for crypto-asset purchase

The method of payment to buy and sell the ALKIMI token on the Trading Platforms are determined and set by the Trading Platforms and are not controlled, influenced, or governed by the Foundation.

E.25 Value transfer methods for reimbursement

Not applicable. See explanation under E.3.

E.26 Right of withdrawal

Not applicable. See explanation under E.3.

E.27 Transfer of purchased crypto-assets

The purchased ALKIMI tokens will be transferred on the Sui network. The person seeking admission to trading is not responsible for this transfer. Transfers occur in accordance with the network's standard processing times and are subject to blockchain confirmation. Once completed, the transaction is immutable and permanently recorded on the used blockchain.

E.28 Transfer time schedule

The transfer of the ALKIMI token from the seller's wallet or device to the buyer's wallet or device may not occur immediately. ALKIMI has no control over the timing of such transfers.

E.29 Purchaser's technical requirements

Not applicable. See explanation under E.3.

E.30 Crypto-asset service provider (CASP) name

N/A

E.31 CASP identifier

N/A

E.32 Placement form

NTAV

E.33 Trading platforms name

• BitPanda
• Bitvavo
• Crypto.com
• Gate.io
• HTX
• Kraken
• Kucoin
• MEXC
• Uphold

E.34 Trading platforms Market identifier code (MIC)

• BPND (Bitpada)
• VAVO (Bitvavo)
• KRME (Kraken)
• CXKUCO (Kucoin)

E.35 Trading platforms access

Trading platforms are accessible via their respective website or applications for mobile devices. Investors can access ALKIMI through supported cryptocurrency trading platforms.

E.36 Involved costs

The use of services offered trading platforms may involve costs, including transaction fees, withdrawal fees, and other charges, as notified to users in advance. These costs are determined and set by the respective trading platforms and are not controlled, influenced, or governed by the offeror. Consequently, any changes to initially announced fee structures or the introduction of new costs for the future are solely at the discretion of trading platforms.

E.37 Offer expenses

Not applicable

E.38 Conflicts of interest

No potential conflict of interest were identified.

E.39 Applicable law

All legal matters will be handled in accordance with BVI law.

E.40 Competent court

Competent courts in BVI will have authority over legal matters related to ALKIMI tokens.

Part F - Information about the crypto-assets

F.1 Crypto-asset type

Utility token

F.2 Crypto-asset functionality

XSM offers a utility token that enables participation in Alkimi's decentralised advertising exchange ecosystem. The token operates on the Sui blockchain and serves as the primary mechanism for accessing Alkimi's complete suite of services related to the buying and selling of digital ads online, in app and on connected TVs. The services include:

• Buying Display Advertising
• Buying Video Advertising
• Buying Connected TV Advertising
• Selling Display Advertising
• Selling Video Advertising
• Selling Connected TV Advertising
• Accessing liquidity to purchase advertising
• Accessing liquidity for the accrued revenue from selling advertising

F.3 Planned application of functionalities

N/A

Crypto-asset characteristics description

A description of the characteristics of the crypto-asset, 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

OTHR

F.5 The type of submission

NEWT

F.6 Crypto-asset characteristics

Alkimi token is a crypto-asset to be classified as a utility token which is required to participate and Interact with the complete suite of features of Alkimi's decentralised Advertising Exchange:

• Access to buy digital advertising across the web, in app and connected tv devices
• Access to sell digital advertising across the web, in app and connected tv devices
• Provision liquidity for the buying or selling digital ads on the web, in app and connected tv devices

F.7 Commercial name or trading name

Alkimi

F.8 Website of the issuer

https://www.alkimi.org/

F.9 Starting date of offer to the public or admission to trading

2025-08-29

F.10 Publication date

2025-08-29

F.11 Any other services provided by the issuer

Not applicable

F.12 Language or languages of the crypto-asset white paper

English

F.13 Digital token identifier code used to uniquely identify the crypto-asset or each of the several crypto assets to which the white paper relates, where available

N/A

F.14 Functionally fungible group digital token identifier, where available

N/A

F.15 Voluntary data flag

False

F.16 Personal data flag

False

F.17 LEI eligibility

True

F.18 Home Member State

Ireland

F.19 Host Member States

Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden.

The above list includes the countries from the European Economic Area ("EEA"), i.e., Iceland, Liechtenstein, and Norway. At the time of the notification of the White Paper, the Regulation (EU) 2023/1114 has not yet been incorporated into the EEA Agreement. The Offer and passporting in the countries of the EEA may not be guaranteed.

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

G.1 Purchaser rights and obligations

The ALKIMI token does not confer any rights or entitlements to its holders. Instead, the ALKIMI token enables its holders to participate in and interact with the Alkimi's Ad Exchange, see D.7.

G.2 Exercise of rights and obligations

Not Applicable

G.3 Conditions for modifications of rights and obligations

The ALKIMI token may be adjusted to comply with future regulatory requirements or to improve functionality. The issuer will notify users of significant changes through public announcements. In the event of a major shift in token utility, users will be given a grace period to adjust or redeem tokens.

G.4 Future public offers

None

G.5 Issuer retained crypto-assets

The issuer will not retain any tokens for the team, the tokens will be distributed as per tokenomics.

G.6 Utility token classification

True

G.7 Key features of goods/services of utility tokens

See D.7 for a summary of the key features.

G.8 Utility tokens redemption

As described (see D.7), ALKIMI may be used to access the complete suite of services provided by the Decentralised ad exchange to facilitate the buying and selling of digital ads on the web, in app and connected TV devices.

G.9 Non-trading request

True

G.10 Crypto-assets purchase or sale modalities

Not applicable

G.11 Crypto-assets transfer restrictions

See E.14

G.12 Supply adjustment protocols

False

G.13 Supply adjustment mechanisms

N/A

G.14 Token value protection schemes

False

G.15 Token value protection schemes description

N/A

G.16 Compensation schemes

False

G.17 Compensation schemes description

N/A

G.18 Applicable law

All legal matters will be handled in accordance with BVI law.

G.19 Competent court

Competent courts in BVI will have authority over legal matters related to ALKIMI tokens.

Part H - Information on the underlying technology

H.1 Distributed ledger technology (DLT)

Sui is a Layer 1 blockchain that operates as a distributed ledger, which means it maintains a replicated, shared, and synchronized database across a decentralized network of nodes.

Sui's DLT ensures:

• Immutability – Once transactions are recorded, they cannot be changed.
• Transparency – All participants have access to the same data.
• Decentralization – No single point of control or failure.

Sui's unique approach includes object-centric data storage and parallel transaction execution, which sets it apart from traditional blockchains. Rather than storing everything in a single chain of blocks, Sui treats on-chain data as programmable objects that can evolve over time.

H.2 Protocols and technical standards

Sui is built on the Move programming language, adapted into Sui Move – a variant optimized for the Sui network. Key protocols and standards include:

• Object-based data model: Every asset or user-defined structure is an object with ownership and type constraints.
• Custom token standards: Instead of using a single ERC-20-like standard, Sui allows developers to define custom logic and types for fungible and non-fungible tokens (NFTs).
• Access control and capabilities: Sui Move uses capability-based security, ensuring only authorized entities can modify or access certain objects.

While Sui doesn't directly replicate Ethereum standards like ERC-20 or ERC-721, similar functionality can be implemented with Move modules and object types.

H.3 Technology used

Sui incorporates a range of modern technologies:

• Move Language: Safe and secure smart contract programming language, originally developed by Meta.
• Parallel Execution Engine: Sui is designed to execute independent transactions concurrently, improving throughput significantly.
• Object-centric Model: Each object has a globally unique ID and defined ownership, enabling fine-grained control and scalability.
• Client SDKs: Sui offers libraries in TypeScript, Rust, and more, making it easier to integrate token and contract logic into dApps.

Additionally, Sui uses cryptographic primitives like BLS and Ed25519 for signing and verification.

H.4 Consensus mechanism

Sui uses a context-aware hybrid consensus model. For transactions that involve single-owner objects (for example, a user sending tokens from their own wallet), consensus is not required – these are processed using a fast and direct method that ensures instant finality. This design significantly improves performance for common operations.

When a transaction involves shared objects (e.g., smart contracts or multi-user resources), it is processed through a full Byzantine Fault Tolerant (BFT) consensus protocol. Specifically, Sui uses Narwhal for data availability and Bullshark for transaction ordering and finality. This separation of concerns allows Sui to maintain both high performance and strong consistency where needed, making it one of the most scalable consensus systems among modern blockchains.

H.5 Incentive mechanisms and applicable fees

N/A

H.6 Use of distributed ledger technology

False

H.7 DLT functionality description

• Object-Centric Data Model: Unlike traditional blockchains that track account balances, Sui stores and manages data as individual, programmable objects. This allows for more efficient and flexible operations, especially for digital assets and complex interactions.
• Parallel Transaction Execution: Sui processes transactions concurrently, enabling higher throughput and faster transaction finality compared to blockchains that execute transactions sequentially.
• Delegated Proof-of-Stake (DPoS): Sui uses a DPoS consensus mechanism, where validators stake SUI tokens to secure the network and validate transactions.
• Move Programming Language: Sui leverages the Move language, known for its security and expressiveness, to build smart contracts and decentralized applications.

H.8 Audit

True

H.9 Audit outcome

See https://sui.io/security

Part I - Information on risks

I.1 Offer-related risks

General Contractual and Counterparty Risk

The Person Seeking Admission To Trading neither operates nor controls, oversees, or manages the functioning of the Trading Platforms where the ALKIMI token will be admitted. When ALKIMI token holders buy or sell the ALKIMI token on Trading Platforms, the Person Seeking Admission To Trading is not a contractual party to these transactions. As a result:

Any legal relationship between token holders and the Trading Platforms is governed solely by the terms and conditions set by each Trading Platform at its discretion.

The Person Seeking Admission To Trading assumes no responsibility or liability for the operations, services, security, performance, or any outcomes – whether financial or technical – arising from transactions conducted on these Trading Platforms.

The Person Seeking Admission To Trading provides no assurances regarding any Trading Platform and assumes no responsibility or liability for any regulatory, compliance, operational, financial, technical, or reputational failures that may adversely affect its activities. This includes, but is not limited to, circumstances where such failures result in disruptions, restrictions on trading, or the Trading Platform halting or ceasing its operations entirely, due to sanctions, bankruptcy, or similar events. The foregoing may result in substantial or even total losses for the ALKIMI token holder.

Pausing and Delisting Risk

The Person Seeking Admission To Trading cannot guarantee that the ALKIMI token will remain listed or tradeable on any Trading Platforms. Delisting (or the temporary pausing of such listing) could significantly hinder the ability of ALKIMI token holders to buy, sell, or otherwise transact in ALKIMI tokens.

In the event of delisting, ALKIMI token holders may face challenges in finding alternative markets or counterparties willing to trade ALKIMI tokens, which could adversely impact the ALKIMI token's liquidity and market value. Delisting could also negatively impact the price of the ALKIMI token due to modified demand and/or reputational damage.

Trading Risk

The Person Seeking Admission To Trading does not control the secondary markets. There can be no assurance as to the secondary market (if any) in the ALKIMI tokens. Specifically:

It cannot guarantee the depth, stability, or sustainability of any secondary market for ALKIMI tokens. Limited market depth or trading activity may result in reduced liquidity, increased price volatility, and challenges in buying or selling ALKIMI tokens at desired prices.

It cannot guarantee the healthy and consistent availability of buying or selling opportunities for ALKIMI tokens or the integrity of their market price. Trading activity may be affected by manipulative practices such as wash trading, front-running, and similar schemes. While Trading Platforms are subject to varying regulatory frameworks that may or may not prohibit such practices and impose oversight to detect and deter them, the Person Seeking Admission To Trading assumes no responsibility or liability for their effective prevention or enforcement.

Operational and Technical Risk

Trading Platforms operate interfaces that allow users to trade crypto-assets for fiat currencies (such as U.S. Dollars or Euros) or other crypto-assets. The reliance on a Trading Platform's internal system for asset storage and transfer introduces additional counterparty risk, exposing users to potential operational, technical, or human error.

Accordingly:

The Person Seeking Admission To Trading assumes no responsibility or liability for any losses arising from such risks.

Trades are executed using centralized matching algorithms and are often recorded off-chain, meaning they are not directly linked to transparent on-chain transfers of crypto-assets. This may obscure harmful trade matching or internal practices. The traded assets exist only on the Trading Platform's internal ledger, where each ledger entry corresponds to a trade involving fiat or another crypto-asset.

Funds deposited by users may be co-mingled by Trading Platforms, rather than stored in separate wallet addresses. This centralization increases the risk of damage or theft, particularly in the event of a hack or security breach.

Users must deposit their ALKIMI tokens with the Trading Platform in order to trade or withdraw them, which introduces the risk of loss in the event of deposit or withdrawal process failures.

Unanticipated Risks

In addition to the risks outlined above, unforeseen risks may arise. Furthermore, new risks could emerge as unexpected variations or combinations of the risks described in Sections I.01 to I.05.

I.2 Issuer-related risks

Abandonment / Lack of Success Risk

This is the risk that the activities of the Issuer must be partially or totally abandoned for several reasons including, but not limited to, lack of interest from the public, lack of funding, incapacitation of key developers and project members, force majeure (including pandemics and wars), or lack of commercial success or prospects.

Project Change Risk

The project of the Issuer, for which the Protocol serves as the implementation, may evolve over time. This could involve pivoting from its original vision or modifying how that vision is executed. Such changes may be driven by market conditions, regulatory developments, technological advancements, or strategic decisions by the project's team. While adaptation can foster innovation and resilience, it also introduces risks, including shifts in the value proposition and potential misalignment with prior expectations.

No Protocol Control Risk

The Protocol is neither operated nor controlled by the Issuer. Should ALKIMI token holders interact with the Protocol, they are engaging directly with the Protocol and potentially with third parties that have no relationship to the Issuer. This means the Issuer does not oversee or manage these interactions, nor does it assume responsibility for any outcomes that may arise.

Withdrawing Partners Risk

This is the risk that the Issuer faces in its business relationships with one or more third parties. The implementation of the Protocol depends heavily on the collaboration and functioning of services provided by several third parties and other crucial partners. The loss or change of project leadership or key partners can lead to disruptions, loss of trust, or project failure. The Issuer cannot guarantee that the Protocol and the related project will be successfully developed and deployed.

Legal and Regulatory Compliance Risk

Crypto assets and blockchain-based technologies are subject to evolving regulatory landscapes worldwide. Regulations vary across jurisdictions and may be subject to significant changes. This could lead to changes with respect to trading of the ALKIMI token and increase the Issuer's costs and/or obligations in admitting the ALKIMI token for trading.

Changes in laws or regulations may negatively impact the value, legality, or functionality of the ALKIMI token. Non-compliance can result in investigations, enforcement actions, penalties, fines, sanctions, or the prohibition of the trading of the ALKIMI token, impacting its viability and market acceptance. The Issuer could also be subject to private litigation.

Operational Risk

Any failure to develop or maintain effective internal control or any difficulties encountered in the implementation or improvement of such controls could harm the business of the Issuer, causing disruptions, financial losses, or reputational damage.

Industry Risk

The Issuer is and will be subject to all the risks and uncertainties associated with any new venture or visionary project, including the risk that the Issuer will not be able to realize its purpose or vision with respect to the Protocol and the overall project. Other projects may pursue the same or a similar vision. Many of them are profit-oriented, substantially larger, and possess significantly greater financial, technical, and marketing resources than the Issuer, which may result in them attracting more participants than the Protocol, project, or associated ecosystem initiated by the Issuer.

Reputational Risk

The Issuer faces the risk of negative publicity, whether due to operational failures, security breaches, or associations with illicit activities. Any such incidents can harm the Issuer's reputation and, by extension, reduce the value and acceptance of the ALKIMI token.

Competition Risk

There are numerous existing crypto-assets and projects, and new competitors may enter the market at any time. The effect of such competition on the ALKIMI token and its market price cannot be predicted or quantified. Competitors may have significantly greater financial and legal resources than the Issuer. There is no guarantee that the Issuer will be able to compete successfully – or at all – with these competitors. Increased competition may also severely impact the profitability and creditworthiness of the Issuer.

Unsolicited Admission to Trading Risk

Third parties may choose to support ALKIMI tokens on their Trading Platforms without any request, authorization, or approval by the Issuer or any affiliated party. As a result, the appearance of the ALKIMI token on any third-party platform does not imply any endorsement by the Issuer or any assurance that such platforms or services are valid, legal, stable, or otherwise appropriate.

Unanticipated Risks

In addition to the risks outlined above, unforeseen risks may arise. Furthermore, new risks could emerge as unexpected variations or combinations of the risks described in Sections I.01 to I.05.

I.3 Crypto-assets-related risks

Market Risk

Crypto assets, including ALKIMI tokens, are highly volatile and can experience significant price swings in short periods, increasing the risk of sudden and substantial losses. Such valuation risk arises as the market value of a crypto asset may not always reflect its underlying utility or fundamentals and is subject to subjective assessment.

ALKIMI token holders are thus exposed to potential losses due to the ALKIMI token's:

• Potential fluctuations in value, driven by various factors such as supply and demand dynamics, investor sentiment, and broader market trends, including changes in interest rates, general movements in local and international markets, technological advancements, regulatory changes, and media coverage. Notably, momentum pricing of crypto assets has previously resulted, and may continue to result, in speculation regarding future appreciation or depreciation in the value of such assets, further contributing to volatility and potentially inflating prices at any given time.
• Liquidity risk, where a lack of depth in secondary markets – or limited trading volumes – can hinder the ability to execute trades at favorable prices, which could lead to significant losses, especially in fast-moving market conditions. As a result, holders of ALKIMI tokens may experience challenges in managing their holdings, with the value of the asset subject to unpredictable fluctuations and potential depreciation.
• Solvency and collateral risk, if the ALKIMI token is used to finance further activities, especially in leveraged positions or as collateral for loans. Significant fluctuations in the value of the ALKIMI token could adversely affect the solvency of its holder, particularly if the token is pledged as collateral. A drastic decline in its value may trigger margin calls or automatic liquidations, which could further depress the ALKIMI token's price, creating a negative feedback loop. This volatility poses the risk of forced asset sales, potentially resulting in substantial losses for the holder and amplifying downward pressure on the market price of ALKIMI tokens.

Custodial Risk

The method chosen to store ALKIMI tokens, 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 ALKIMI tokens, with direct consequences for the holder's ability to access, trade, or retain their assets.

Scam Risk

This is the risk of loss resulting from a scam or fraud suffered by ALKIMI token holders from other malicious actors. These scams include – but are not limited to – phishing on social networks or by email, fake giveaways, identity theft of the Person Seeking Admission To Trading or its management body, creation of fake ALKIMI tokens, or offering fake ALKIMI token airdrops.

Anti-Money Laundering / Counter-Terrorism Financing Risk

This is the risk that crypto-asset wallets holding ALKIMI tokens or transactions in ALKIMI tokens may be used for money laundering or terrorist financing purposes or be linked to individuals associated with such offenses. A public address holding ALKIMI tokens could be flagged in Anti-Money Laundering or Counter-Terrorism Financing investigations. In such cases, receiving ALKIMI tokens could result in the holder's address being flagged by authorities, Trading Platforms, or service providers, potentially leading to transaction restrictions or asset freezes.

As a result, holders of ALKIMI tokens may face legal or regulatory challenges if their address becomes associated with illicit activities, impacting their ability to access, trade, or transfer their tokens freely.

Taxation Risk

The taxation regime that applies to the trading of ALKIMI tokens by either individual holders or legal entities depends on the jurisdiction of each ALKIMI token holder. The Person Seeking Admission To Trading cannot guarantee that the holding, receipt, conversion, or exchange of ALKIMI tokens will not incur tax consequences.

It is the sole responsibility of each ALKIMI token holder to comply with applicable tax laws, including but not limited to the reporting and payment of income tax, wealth tax, or similar taxes related to gains or losses in the value of ALKIMI tokens.

Market Abuse Risk

The market for crypto assets is rapidly evolving, involving local, national, and international platforms with a growing range of assets and participants. Any market abuse – or a loss of confidence among token holders – could adversely affect the value and stability of ALKIMI tokens.

Notably:

• Significant trading activity may take place on systems and platforms with limited oversight and predictability. Sudden and rapid changes in the supply or demand of a crypto asset – especially those with low market capitalization – can result in extreme price volatility.
• The infrastructure of crypto assets may be exploited by certain actors to engage in abusive trading practices, including front-running, spoofing, pump-and-dump schemes, and other fraudulent behaviors across different platforms and jurisdictions.

Legal and Regulatory Risk

There is currently no global regulatory harmonization for crypto assets, resulting in diverging legal frameworks and ongoing changes. These factors may negatively impact the value, utility, and overall viability of ALKIMI tokens – and, in extreme cases, may force the Person Seeking Admission To Trading to cease certain operations.

In particular:

• While ALKIMI tokens do not create or confer any contractual or other obligations against any party, some non-EU regulators may classify them as securities, financial instruments, or payment instruments. Such classifications could trigger licensing or compliance requirements depending on how, where, and by whom the tokens are issued, purchased, or traded.
• Ongoing regulatory developments could increase the Person's Seeking Admission To Trading compliance costs and burden its ability to support or facilitate ALKIMI token transactions.
• Restrictive new regulations could lead to the ALKIMI token becoming legally unusable, losing value, or being banned in some jurisdictions.
• Authorities may take enforcement action against the Person Seeking Admission To Trading if ALKIMI tokens are deemed regulated instruments or if the Person's Seeking Admission To Trading activities are found to be non-compliant with applicable laws. Such actions could expose the Person Seeking Admission To Trading, its affiliates, and its management to financial or legal penalties, including civil or criminal liability.

Unanticipated Risks

In addition to the risks outlined above, unforeseen risks may arise. New risks may also emerge as unexpected variations or combinations of the risks described in Sections I.01 to I.05.

I.4 Project implementation-related risks

Novel Ecosystem Risk

The ALKIMI token holder understands and acknowledges that the ALKIMI ecosystem, as evolving around the Protocol, is built on emerging and rapidly evolving technologies, which inherently carry significant risks. The underlying software, blockchain infrastructure, smart contracts, and related technologies are still in their early stages of development, meaning there is no guarantee that the process of receiving, using, or holding ALKIMI tokens will be uninterrupted or error-free. As with any novel technology stack, there is an inherent risk that the underlying blockchain, smart contracts, or associated components may contain weaknesses, vulnerabilities, or bugs, despite audits being conducted. Such issues could lead to unintended behaviors, security breaches, or critical failures, potentially resulting in the partial or complete loss of ALKIMI tokens or their functionality. Additionally, unforeseen technical limitations, incompatibilities, or the emergence of superior alternatives could further impact the stability, security, and long-term viability of the ALKIMI ecosystem.

Dependency Risk

The Protocol relies on third-party technologies, infrastructures, and protocols, which could impact its functionality, security, and long-term sustainability. Specifically, it depends on Sui network for certain key elements. Any disruptions, vulnerabilities, regulatory scrutiny, or changes in Sui network's operations—such as modifications to its restaking mechanisms, governance, or economic incentives—could directly affect the usability and security of the Protocol, which may result in a negative effect for the ALKIMI tokens. If Sui network experiences technical failures, security breaches, or regulatory intervention, it could severely impact the stability and performance of the Protocol, potentially limiting its intended functionality and value. This reliance on external infrastructure increases systemic risk, as unforeseen issues in third-party protocols could cascade into disruptions within the ALKIMI token ecosystem.

Suitability Risk

The Protocol will be deployed on an "as is" and "as available" basis without warranties of any kind, and the Person Seeking Admission To Trading expressly disclaims all implied warranties as to the Protocol and the ALKIMI token including, without limitation, implied warranties of merchantability, fitness for a particular purpose, title, and non-infringement. Therefore, the Person Seeking Admission To Trading cannot and does not warrant that the ALKIMI token, the software code of the ALKIMI token issuance smart contracts, or the delivery mechanism for ALKIMI tokens or the Protocol (jointly, "Alkimi Technology") are reliable, current or error-free, free of viruses or other harmful components, meet the ALKIMI token holder's requirements, or that defects in the Alkimi Technology will be corrected.

Unanticipated Risks

In addition to the risks outlined above, unforeseen risks may arise. Additionally, new risks could emerge as unexpected variations or combinations of the risks discussed in Sections I.01 to I.05.

I.5 Technology-related risks

The Person Seeking Admission To Trading and its affiliates, directors, and officers shall not be responsible or liable for any damages, losses, costs, fines, penalties, or expenses of whatever nature—whether reasonably foreseeable by them and the ALKIMI token holder—that the ALKIMI token holder may suffer, sustain, or incur, arising out of or relating to the technical risks outlined below or a combination thereof.

General Cybercrime Risk

The ALKIMI token holder acknowledges that, despite best efforts to enhance security, the technological components supporting the ALKIMI token—including its blockchain infrastructure, smart contracts, and wallets—may be vulnerable to cyberattacks. Malicious actors may exploit software vulnerabilities, attack consensus mechanisms, or compromise private keys to gain unauthorized access to ALKIMI tokens. 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 ALKIMI tokens. 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-Level Risk

The ALKIMI token holder understands and accepts that, as with other blockchains, the blockchain used for the issuance of the ALKIMI tokens could be susceptible to consensus-related attacks, including but not limited to double-spend attacks, majority validation power attacks, censorship attacks, and byzantine behavior in the consensus algorithm, or be subject to forks. Any successful attack or fork presents a risk to the ALKIMI token, the expected proper execution and sequencing of ALKIMI token transactions, and the expected proper execution and sequencing of contract computations as well as the token balances in the wallets of ALKIMI token holders.

Smart Contract-Level Risk

The issuance and transfers of ALKIMI tokens rely on smart contracts deployed on a blockchain network, which introduce specific technical and security risks.

Smart contracts are self-executing, meaning any vulnerabilities, coding errors, or unforeseen logic flaws in the issuance contract could result in unintended consequences, such as the incorrect distribution of tokens, loss of funds, or permanent locking of tokens. Additionally, smart contracts are exposed to potential exploits, including hacking attempts, reentrancy attacks, and other forms of malicious activity that could compromise the security of the issuance process.

Once deployed, the smart contract governing the issuance of ALKIMI tokens cannot be easily altered or corrected, meaning any discovered vulnerabilities may be difficult or impossible to fix without significant coordination, community approval, or even a network fork. Furthermore, changes to the underlying blockchain protocol—such as updates to consensus mechanisms, transaction processing rules, or gas fee structures—could affect the functionality or cost-efficiency of the issuance smart contract. These risks could lead to disruptions in token issuance, security breaches, or a loss of confidence in the ALKIMI ecosystem, potentially impacting the ALKIMI token's value and usability.

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 ALKIMI token.

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.

Because the ALKIMI token's value is inherently tied to its governance functionality, any security breach or governance deadlock affecting the Protocol or the decentralized governance system could have cascading effects, including depreciation of the token's value, reduced market confidence, and potential loss of funds for token holders.

Unanticipated Risks

In addition to the risks outlined above, unforeseen risks may arise. Additionally, new risks could emerge as unexpected variations or combinations of the risks discussed in Sections I.01 to I.05.

I.6 Mitigation measures

The Person Seeking Admission To Trading has implemented various measures to mitigate the risks outlined in Sections I.01 to I.05 above. These include comprehensive disclosures, rigorous technology testing and auditing, and the careful selection of personnel, management, and third-party partners. However, many of these risks are inherent to the Person's Seeking Admission To Trading activities and the broader ecosystem, making complete elimination impossible.

To further reduce exposure to these risks, prospective ALKIMI 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.

Part J - Information on the sustainability indicators

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

Information referred to Commission Delegated Regulation establishing technical standards adopted pursuant to Article 6(12), fourth subparagraph, Article 19(11), fourth subparagraph, Article 51(15), fourth subparagraph, and Article 66(6), fourth subparagraph of Regulation (EU) 2023/1114 of the European Parliament and of the Council:

See below information according to Commission Delegated Regulation (EU) 2025/422.

Mandatory information on principal adverse impacts on the climate and other environment-related adverse impacts of the consensus mechanism

(Table 2 of Commission Delegated Regulation (EU) 2025/422)