Crypto-Asset White Paper

The main area of activity of Axenor Holdings OÜ is EMTAK 62101, computer programming activities. The company's corporate purpose is to create, develop, deploy, market and maintain digital solutions, including systems and platforms based on blockchain technology, artificial intelligence and information technology.

In the CHT project, Axenor Holdings OÜ is:

• the sole offeror of CHT and the person responsible for drawing up this white paper;
• the issuer of CHT; no separate issuing entity exists, as reflected in field B.1;
• the developer and operator of the Crypto-Holdings Platform and of the smart contracts governing issuance, price determination, transfer fees, the referral system and vouchers on the Base network;
• the supplier of the services to which CHT gives access: the Governance Programme, the Real Estate Report and the Property Inclusion Programme and, at a later stage, the planned rental services. The Offeror also operates the referral system and the Voucher Programme, which are mechanisms of acquisition and distribution of CHT, and the Participation Programme, which is an ancillary functionality of the ecosystem.

Axenor Holdings OÜ has maintained limited size and complexity and has a small organisational footprint, with no (or minimal) full-time staff.

From its registration on 2 February 2026 until the date of notification of this white paper, 10 September 2026, the company generated a turnover of approximately EUR 45 000,00.

Should the project be successful, the Offeror wishes to acquire a real estate property valued at approximately EUR 100 000,00. The location and the intended use of that property, and the choice of the property itself, are determined through the Governance Programme, in the four votes held between 17 October 2026 and 9 January 2027.

CHT is an ERC-20 token deployed on the Base network with 18 decimals and a maximum supply of 10 000 000 000 CHT, with no pre-mint or hidden issuance.

New CHT may be created only through predefined mechanisms: purchases, referrals and voucher redemption. Minting is controlled exclusively by the dedicated Emission Controller contract, and no other issuance or modification of the issuance logic is permitted.

The following milestones have already been achieved:

• the Crypto-Holdings platform has been developed, featuring an attractive and user-friendly graphic design;
• smart contracts have been developed and implemented, making the token issuance process predictable and transparent;
• mechanisms have been implemented to prevent the Offeror from manually and uncontrollably creating an artificial supply of tokens;
• an immutable economic protocol has been implemented, determining the issue price and making the token supply predictable and transparent;
• the timetable of the first four Governance votes has been set out in this white paper; the DAO Constitution will be published on the Crypto-Holdings Platform before the start of the offer to the public;
• the token's utility functions, that is the Governance Programme, the Real Estate Report and the Property Inclusion Programme, together with the referral system, the Voucher Programme and the Participation Programme, have been implemented and are ready for use from the first day of the public offering.

Once the Offeror acquires its first property, it is planned to allow holders to pay for rental services in CHT and to benefit from preferential rental terms. The services are planned to include accommodation services intended for tourism purposes. It is also planned to introduce preferential service terms, premium membership status and early access to new features, once the Offeror has set the applicable holding thresholds and the services concerned.

The first property to be acquired is selected through the Governance Programme, in the four votes held between 17 October 2026 and 9 January 2027.

Details of each utility are published on the Platform before it starts, together with the applicable terms of use.

How a retail holder withdraws

A retail holder exercises the right of withdrawal by submitting an unequivocal statement of withdrawal through the Crypto-Holdings Platform, or by e-mail to contact@crypto-holdings.io, within 14 calendar days from the date of the agreement to purchase. No reasons need to be given. A withdrawal form is made available on the Crypto-Holdings Platform.

Return of the tokens

Withdrawal unwinds the purchase agreement in full. The retail holder therefore returns to the Offeror the CHT acquired under the agreement from which the holder withdraws. CHT are returned by an ordinary ERC-20 transfer on the Base network to the return address designated by the Offeror and published on the Crypto-Holdings Platform (the "Withdrawal Return Address"), currently 0x90669C861083ec6a4849Cd881Cb13f8ef4E398C3. The Withdrawal Return Address is exempt from the transfer fee described in field E.36, so the holder returns the full number of CHT acquired and incurs no transfer fee on the return. The main sale smart contract has no programmed capability to repurchase, redeem or claw back CHT; the return is therefore effected by the holder. The Base network transaction fee (gas) on the return transfer is borne by the holder; where the return transfer is made, the Offeror reimburses the corresponding gas cost together with the purchase price.

Refund

The refund is made using the same means of payment as used by the retail holder in the original transaction, unless the retail holder expressly agrees otherwise. Where the purchase price was paid in USDC or USDT on the Base network, the reimbursement is made in the same crypto-asset, in the same nominal amount as received by the Offeror, to the wallet address from which the payment was received. The retail holder incurs no fees or costs charged by the Offeror in connection with the withdrawal or the refund.

Effect on supply and price

CHT returned to the Withdrawal Return Address are held by the Offeror and may subsequently be allocated by the Offeror to the Rewards Pool of the Participation Programme. Returned CHT are neither destroyed nor re-issued. The issue price of CHT is determined by reference to the number of CHT already distributed through the authorised issuance mechanisms; the exercise of the right of withdrawal does not reverse that count and therefore does not reduce the issue price applicable to subsequent purchases.

No separate early-purchase discount is offered. Purchase prices may vary only because of the pricing mechanism embedded in the smart contracts: the initial issue price is EUR 0,001 per CHT and increases by 0,03% after every additional 10 000 CHT distributed through the authorised issuance mechanisms. The increase is compounded, each increase being calculated on the price applicable at that moment and not on the initial issue price. Where a purchase spans multiple pricing thresholds, the respective portions of the purchase are calculated at the applicable successive price levels. This difference results automatically from the price curve and does not constitute an individually negotiated discount or preferential allocation.

The fees are a separate matter from the issue price. The acquisition of CHT from the Offeror is free of charge during the offer to the public and, after the offer has ended, is subject to a fee of 5%. Transfers of CHT between holders are subject, at all times, to a transfer fee of between 0,5% and 5% determined by the aggregate daily volume of CHT transfers. CHT received as a reward under the referral system, CHT obtained on the redemption of a voucher and CHT received from the Rewards Pool are not subject to any fee, either during the offer to the public or after it has ended. Both fees are described in field E.36.

As a result of the pricing mechanism, the acquisition price of CHT may differ among purchasers depending on the time of acquisition. The impact on other investors who also acquire CHT during the early stage of the project is expected to be minimal. The mechanism is designed to reward early investors by offering them more favourable acquisition terms than those available to investors who acquire CHT at a later stage, when the project has reached a more advanced stage of development. The negative impact on other investors will be mitigated by limiting unfair behaviour.

The results of the public offering will be published on the Crypto-Holdings website. In accordance with Article 10(2) of MiCAR, the Offeror shall publish on the Crypto-Holdings website, on an ongoing basis and at least once a month, the number of units of the crypto-asset in circulation.

The Offeror provides effective solutions for monitoring and securing cash or other crypto-assets obtained through the public offering.

During the right-of-withdrawal period, the Offeror ensures that the cash or crypto-assets raised through the public offering are held on a bank account or by a crypto-asset service provider providing custody and administration of crypto-assets on behalf of clients, selected for this purpose.

Retail holders who purchase crypto-assets other than asset-referenced tokens and e-money tokens either directly from an offeror or from a crypto-asset service provider placing crypto-assets on behalf of that offeror shall have a right of withdrawal. Retail holders shall have a period of 14 calendar days within which to withdraw from their agreement to purchase crypto-assets other than asset-referenced tokens and e-money tokens without incurring any fees or costs and without being required to give reasons. The period of withdrawal shall begin from the date of the agreement of the retail holder to purchase those crypto-assets.

All payments received from a retail holder including, if applicable, any charges, shall be reimbursed without undue delay and in any event no later than 14 days from the date on which the offeror or the crypto-asset service provider placing crypto-assets on behalf of that offeror is informed of the retail holder's decision to withdraw from the agreement to purchase those crypto-assets. Such reimbursement shall be carried out using the same means of payment as that used by the retail holder for the initial transaction, unless the retail holder expressly agrees otherwise and provided that the retail holder does not incur any fees or costs as a result of such reimbursement.

Purchased tokens are delivered directly to the user's wallet after purchase.

CHT has been created according to the ERC-20 standard, ensuring full compatibility with the existing Base infrastructure, and can be stored in popular wallets (such as MetaMask or Trust Wallet). The Offeror does not, at any time, hold users' private keys or manage their assets.

Using the Platform's functionalities, in particular purchasing tokens, requires the user to connect his or her wallet to the Platform or to use an embedded wallet. Users are fully responsible for the custody of their wallets and private keys, as CHT is stored and transferred using standard ERC-20 compatible, non-custodial wallets.

Embedded wallets allow users to create and use blockchain wallets without installing external browser extensions or manually managing private keys in the traditional manner. Embedded wallet functionality is provided by a third-party technology provider and may be subject to that provider's own terms of service and privacy policies. The Platform does not store the user's seed phrase or full private keys in a manner enabling independent access to user funds. The user is solely responsible for the security of the account, device and any authentication methods used to access the embedded wallet.

The purchaser needs a device with internet access that is suitable for using financial services. In particular, the device should enable a secure wallet (with a password and a backup of the seed phrase) and prevent private keys from being shared.

A purchaser or holder of CHT may incur the costs described below. The Offeror charges no subscription fee for participation in the offer to the public.

1. Costs of purchasing CHT

• Network fee (gas), paid in ETH. Every transaction recorded on the Base network, including a purchase of CHT and any later transfer, requires a network fee paid in ETH. The Offeror does not set, receive or influence this fee. It is set by the network and changes with network conditions; it covers the execution of the transaction on Base and the cost of securing the transaction data on Ethereum. The estimated amount is shown by the wallet or the interface before the transaction is confirmed, so no fixed amount can be given in advance.
• Acquisition fee. During the offer to the public, the acquisition of CHT from the Offeror is not subject to any fee: the purchaser pays the issue price only, together with the network fee and any commission of an external payment provider. After the end of the offer to the public, the acquisition of CHT from the Offeror is subject to a fee of 5% of the amount acquired, which is retained by the Offeror. CHT received as a reward under the referral system, CHT obtained on the redemption of a voucher and CHT received from the Rewards Pool are not subject to any fee, either during the offer to the public or after it has ended.
• Payment provider commission. Where a purchaser uses an external provider to exchange official currency for a crypto-asset accepted as payment, that provider may charge its own commission. It is charged by the provider, not by the Offeror.

2. Costs of transferring CHT

• Network fee (gas), paid in ETH, as described above.
• Transfer fee, paid in CHT. Transfers of CHT between holders are subject to a transfer fee, which is deducted from the amount transferred and is paid in CHT. This fee applies independently of the acquisition fee and applies from the first day of the offer to the public as well as after the offer has ended. The rate applies automatically and depends on the aggregate daily volume of CHT transfers, measured by reference to EUR, as it stands immediately before the transfer:

  Aggregate daily transfer volume (EUR)	Transfer fee
  up to and including EUR 10 000	5%
  above EUR 10 000 up to and including EUR 50 000	2,5%
  above EUR 50 000 up to and including EUR 100 000	1%
  above EUR 100 000	0,5%

  A transfer is settled in full at one rate, determined by the volume immediately before it; it is not split between two rates. Example: on a transfer of 100 CHT at 5%, the recipient receives 95 CHT and 5 CHT is the fee. The fee goes to an account of the Offeror. It is not burnt and not newly created, so the total supply is unaffected.
• How the aggregate daily volume is recorded. The aggregate daily volume is recorded for every transfer of CHT, including transfers which are themselves not subject to the transfer fee. The volume is recorded before it is established whether the transfer is subject to the fee, so transfers effected through the Offeror's own contracts and accounts also increase the aggregate daily volume and may therefore lower the rate applicable to the transfers of all other holders on the same day.
• How the transfer is valued. The value of each transfer is converted into EUR using the issue price resulting from the pricing mechanism described in field E.11, and not a market price obtained from a trading platform or from any external source. That price only increases and never decreases. The same number of CHT therefore represents a higher value in EUR as the project develops, the volume thresholds are reached earlier in the day, and the transfer fee rate applicable to holders tends to fall over time.
• Exemptions. The transfer fee is not charged on the return of CHT to the Withdrawal Return Address by a retail holder exercising the right of withdrawal under Article 13 of Regulation (EU) 2023/1114, or on transfers between the Offeror's own operational accounts.

3. Transfers through exchanges or trading platforms

Where CHT are transferred through an exchange or an automated trading platform, the transfer fee applies in the same way, so the other party may receive less than the amount sent.

4. Fees for Platform services

A Real Estate Report and participation in the Property Inclusion Programme are paid for in CHT. The fee for each service is set by the Offeror and published on the Crypto-Holdings Platform before the service is ordered, and the amount payable is displayed to the holder before the order is confirmed.

The Offeror has identified the following potential conflicts of interest and the measures applied to manage them.

Governance votes concerning the acquisition of property. The outcome of a Governance vote is binding on the Offeror where the participation threshold described in field D.7 is met. The Offeror is at the same time the party that acquires and operates the property. The Offeror manages this conflict by confining the subject matter of votes to the questions announced in advance in the published timetable, by publishing the options and the results of each vote, and by disclosing that the acquisition, ownership and operation of any property remain with the Offeror alone and confer no rights on holders.

Property Inclusion Programme. A holder pays the Offeror in order to have a property indicated by that holder included among the options in the fourth Governance vote. The Offeror therefore receives consideration in connection with the composition of the ballot. The Offeror manages this conflict by admitting to the ballot every property for which a Real Estate Report has been generated and the applicable fee paid, by publishing the full list of options together with the corresponding reports before the vote, and by taking no part in the vote itself.

Concentration of voting power in the early stage of the offer. Because voting power follows the number of CHT held, holders who acquire CHT early may hold a significant share of the CHT issued at the record date of the first votes. The Offeror manages this by applying the purchase limits described in field E.14 and by publishing, before each vote, the number of CHT issued at the record date.

The Offeror ensures the protection of the interests of smaller users, while still enabling participation by larger entities.

CHT is the non-native, fungible utility crypto-asset of the Crypto-Holdings project and is deployed on the Base blockchain network. It is designed exclusively to enable access to functionalities and services within the Crypto-Holdings ecosystem. Accordingly, CHT is not classified as an asset-referenced token or an electronic money token under the MiCA Regulation, but as a utility token.

Holding CHT is a necessary condition for accessing selected ecosystem utilities. Additional KYC, eligibility, activity, acceptance of programme terms and programme-specific requirements may apply.

Users are fully responsible for the custody of their wallets and private keys, as CHT is stored and transferred using standard ERC-20 compatible, non-custodial wallets.

The Platform's utility services are available to holders from the start of the offer to the public, that is from 17 October 2026: the Governance Programme, the Real Estate Report and the Property Inclusion Programme. The referral system and the Voucher Programme, which are mechanisms of acquisition and distribution of CHT, and the Participation Programme, which is an ancillary functionality of the ecosystem, are available from the same date. From that date holders may also transfer CHT to third parties in private transactions.

Rental services paid for in CHT and preferential service terms are planned and will become available at a later stage, as the Platform is developed and further ecosystem components are implemented.

The Crypto-Holdings ecosystem is a global digital platform built around the CHT utility token.

From the first day of the offer to the public, CHT gives access to the Governance Programme, the Real Estate Report and the Property Inclusion Programme. The referral system and the Voucher Programme are mechanisms of acquisition and distribution of CHT, and the Participation Programme is an ancillary functionality of the ecosystem. Premium features, preferential service terms and rental services paid for in CHT are planned for a later stage of development and are not available at the start of the offer.

CHT operates on the Base blockchain network, which is built on Ethereum and relies on Ethereum's Proof-of-Stake consensus for secure and efficient settlement. Users hold their tokens in non-custodial wallets, retaining full control over their private keys.

Purchasers are entitled to own CHT, to take part in the Governance Programme from the first day of the offer to the public, and to access the utility services of the Crypto-Holdings Platform.

They must comply with all relevant laws and follow the Regulations published on the Crypto-Holdings website. Users are solely responsible for managing their private keys and for ensuring compliance with applicable laws and regulations when transacting with CHT.

Modifications to rights and obligations may result in particular from changes in generally applicable law. They will be reflected in changes to the Regulations published on the Crypto-Holdings platform website. Each set of Regulations is marked with the date of update, and users are notified of each update via a notification on the website.

The audit found that all smart contracts are publicly verified, with no changes detected in their deployed bytecode, providing strong transparency and consistency. Administrative control has been significantly improved by transferring high-impact permissions to a secure 2-of-3 multisignature Safe, reducing single-key risk. The contracts are not upgradeable through standard proxy mechanisms, ensuring that the deployed logic cannot be modified after deployment.

No critical issues were identified by the automated static analysis, although the report emphasises that a manual security audit is still recommended. The overall verdict is MIXED, primarily because the token is still in its pre-launch state with no issued supply rather than due to any code or security weaknesses.

Buying CHT involves risk. Prospective holders should consider these risks carefully before participating and, if in doubt, seek independent financial or legal advice. The Offeror cannot guarantee that the project's objectives will be achieved or protect purchasers from all potential market threats.

Risks relating to the offer

• Regulatory risk. Crypto-asset regulation is still evolving. New rules or supervisory action, in the EU or other jurisdictions, may raise costs, delay the Platform or restrict the issuance or trading of CHT or the business model; non-compliance could bring fines, sanctions or prohibition of the offer, affecting its viability and market acceptance. The Offeror intends to comply fully, but future restrictions cannot be excluded.
• No minimum subscription goal. The offer proceeds whatever amount is raised; the funds may be insufficient for the planned development, including the first property (field D.10).
• The offer may end or be cancelled. It has no fixed end date and may be terminated early by the Offeror or cancelled (reimbursement in the event of cancellation: fields E.15 to E.17).
• Marketing constraints. The Offeror does not plan aggressive advertising and MiCA restricts crypto-asset marketing, so the offer may attract little interest and fail; the shareholders plan to fund marketing through the company's capitalisation.
• Personal data. Despite encryption and access controls, a breach of the personal data processed for KYC/AML (such as identification data), by attack or human error, could lead to GDPR sanctions and reputational loss.
• Conflicts of interest and token concentration. Concentrated holdings or actions by persons associated with the project may create conflicts between holders, and the Offeror's interests may not always align with theirs, which could lead to decisions adverse to holders and affect the value of CHT or the credibility of the project (field E.38).

Risks relating to the Offeror, Axenor Holdings OÜ (also the issuer, field B.1)

• Newly established company, registered on 2 February 2026, with no or minimal full-time staff and a limited operating and financial history (fields A.15, A.17).
• Financial risk. Liquidity, credit and market risks could affect the Offeror's ability to continue operating or meet its obligations, and the stability or value of CHT; Platform costs may increase, and the shareholders undertake to maintain the share capital at an appropriate level and to increase it gradually to bear the costs of operating and developing the Platform.
• Key individuals. Loss of the few key persons on whom the project depends could cause disruption, loss of trust or project failure.
• Operational and technology-management risk. Failures in processes, personnel or technology, or failure to keep pace with technological change, could cause disruption, losses, reputational damage or an obsolete or vulnerable Platform or token.
• Legal and reputational risk. Legal uncertainty, lawsuits or adverse rulings could affect the legality, usability or value of CHT; negative publicity, including from any association with illicit activities, or failures of unrelated crypto-asset projects, could damage the project's reputation and, by extension, the value and acceptance of CHT.

See also fields I.3 (token and issue price), I.4 (project and third parties) and I.5 (technology).

Not applicable as a separate category: the issuer of CHT is the Offeror itself, Axenor Holdings OÜ (field B.1), whose risks are disclosed in field I.1.

• CHT may lose all its value; no secondary market is guaranteed. As at the date of this white paper the Offeror is not seeking admission to trading. Outside the Platform the value of CHT may fluctuate significantly and be manipulated; a holder may be unable to sell, or only at a loss, and may lose the full amount paid.
• No market price, no repurchase, no protection scheme. The issue price results from the smart-contract formula (field E.11) and indicates no price at which the Offeror or anyone else would buy CHT. The sale contract cannot repurchase, redeem or claw back CHT; there is no value-protection or compensation scheme (fields G.14 to G.17).
• Transfer fee. 0,5% to 5% of every transfer between holders, including transfers via exchanges or trading platforms, is deducted in CHT, so the recipient receives less than the amount sent (fields E.36, G.11).
• Irreversible transactions and lost keys. Transfers made in error or through fraud or theft cannot be reversed and no other redress is available; lost or stolen private keys mean irreversible loss of access. The Offeror never holds users' keys and cannot replace or reimburse lost tokens. Some or all of a holder's CHT may be lost permanently.
• Immutable token contract. The CHT contract cannot be modified after deployment: bugs cannot be patched, features cannot be added and vulnerabilities cannot be remediated; any ecosystem changes would require separate deployments and would not affect the token contract (field I.5).
• Participation Programme rewards are voluntary. Rewards depend entirely on voluntary allocations by the Offeror, which has no obligation to allocate; holders have no claim (field D.7).
• Uncertain tax treatment. The taxation of crypto-assets is uncertain and may change, which could adversely affect the use of or transactions in CHT; holders should consult a tax adviser in their jurisdiction.
• Breaches of the terms of use, such as unauthorised exchange listings, may occur; a holder who breaches the terms may cause CHT to be designated as high-risk and harder to sell privately or on a secondary market.

• Planned utility may not be delivered. The day-one functions do not depend on acquiring any property. The planned functions, in particular rental services and preferential service terms, may never become available, for instance if no suitable property is acquired or insurmountable barriers arise; CHT would then keep its day-one functions but not attain the full planned utility.
• Real-estate plans may not materialise. The first property can be bought only once sufficient funds are allocated to project development; neither any acquisition nor the raising of any amount is guaranteed (field D.10).
• Competition and demand. Competing projects may limit user acquisition, and the Platform may not reach its planned number of users or offer attractive services; the success of CHT depends largely on actual use of the Platform.
• Third-party and counterparty dependence. Purchases and Platform functions rely on the Base network, on payment, on-ramp, embedded-wallet and IT infrastructure providers and on other partners and suppliers; their failure or non-performance may disrupt the offer or the services accessible with CHT.

Regulatory, financial, operational, legal, reputational and marketing risks and conflicts of interest: fields I.1 and E.38.

The project relies on complex IT systems. The Offeror endeavours to minimise technology risks through audits, security testing and system redundancy, but they can never be eliminated entirely.

• Smart-contract defects. The contracts have undergone technical review and preliminary assessment (field H.9), but unknown vulnerabilities may exist. They are not upgradeable, so a defect found after deployment cannot be patched and could cause loss of CHT or unauthorised access to data.
• Platform outages and breaches. Servers and databases, including those supporting issuance, may fail or be breached, causing unavailability or data loss.
• Cyberattacks on the Platform, on Base or Ethereum, or on interacting wallets and applications (malware, denial of service, consensus-based, Sybil or governance attacks, code exploits or other known or novel methods) could cause holders to lose CHT.
• Dependence on Base and Ethereum. Bugs in their core code could disrupt the network or manipulate balances; forks or consensus errors, changes to fees, governance or technical parameters, loss of economic viability or infrastructure failures could impair CHT; growing usage may raise fees and slow transactions.
• Finality and wrong addresses. Settlement is probabilistic: in exceptional cases such as forks a transaction could theoretically be reversed; normally a confirmed transaction is final, and CHT sent to a wrong address cannot be retrieved.
• Technological disruption, such as quantum computing, could make current cryptography insecure or obsolete, leading to theft or loss of CHT.
• Public ledger and data integrity. Transactions are public, so sensitive data may be exposed and linking transactions to an address may expose a holder to phishing or fraud; corruption of ledger data through bugs, error or tampering could undermine reliability.
• Third parties and fraud. Wallet providers and exchanges may suffer breaches, failures or non-compliance, causing loss or theft of CHT. Fake websites, e-mails, messages and social-media accounts impersonating the project, the Offeror or its service providers may try to steal assets; be extremely cautious with any link or request to connect a wallet.

Irreversible transactions and private keys: field I.3.

The following measures may reduce certain risks but do not eliminate them.

• KYC verification. Users must complete KYC with identity proof and, where applicable, biometric or liveness checks, reducing fake accounts, Sybil attacks and identity fraud.
• Safety Notices about scams, impersonation, phishing and misuse of the Offeror's name or trademark, and updated user-safety procedures.
• Compliance monitoring. The Offeror will ensure compliance in relation to its crypto-assets by monitoring ESMA guidelines and EU and national legislation; suspected criminal offences by token holders are reported immediately to the appropriate authority.
• Transparency: terms and risk information for new Platform features; disclosure of the key aspects of property-related activities, of successes or failures in achieving key milestones, and of conflicts of interest with measures to prevent, manage and disclose them.
• Contracts with service providers and cooperating entities of the highest quality; the Offeror warrants that contracts with providers acting on its behalf will contain sufficient confidentiality and non-competition provisions, to the extent necessary under Article 14(1)(c) of MiCAR.
• Equal treatment if the Offeror seeks a listing: should the Offeror itself apply for admission to trading, its contracts with the entities supporting that application will guarantee, as far as possible, equal treatment of all holders, thereby minimising the risk of price manipulation (third-party listings: field E.14).
• Security systems maintained in accordance with EU standards (Article 14(1)(d) of MiCAR).

Technical controls elsewhere: minting only through the Emission Controller (fields D.4, G.13); contracts not upgradeable through standard proxy mechanisms and a 2-of-3 multisignature Safe (field H.9); on-chain purchase limits (field E.14); fee-free withdrawal return address (field E.16).

Assumption on transaction volume. On the basis of the Offeror's analysis, the likely potential number of transactions within the project on an annual basis will not exceed 50 000 000. This assumption takes into account the best-case scenario and widespread popularity of CHT, considering also the average capital of participants and the potential transfer of crypto-asset values on an individual basis by users.

Allocation method. Since CHT is deployed on Base, an Ethereum Layer 2 rollup, transactions are executed on Base while security and settlement rely on Ethereum. In the absence of a widely accepted methodology for allocating Ethereum's energy consumption across Layer 2 rollups, the calculations conservatively use the Ethereum network's energy consumption divided by the total number of Ethereum transactions as a proxy for energy intensity. This approach is expected to overestimate the energy attributable to Base transactions. Coinbase, the creator of Base, provides technical documentation on how Base operates as an Optimistic Rollup and on its energy efficiency compared to Ethereum Layer 1 (https://base.org/).

Data sources. The assumptions are based on empirical findings obtained from public information sites, open-source crawlers and crawlers developed in-house. Estimated daily Ethereum network power demand was calculated on the basis of last year's data published by the University of Cambridge Blockchain Network Sustainability Index. The following sources were used (access: 2026-07-19):

• https://etherscan.io/chart/tx (Ethereum Daily Transactions Chart): 1 592 187 transactions per day (N_tx);
• https://ccaf.io/cbnsi/ethereum (University of Cambridge Blockchain Network Sustainability Index, Ethereum network power demand, updated every 24 hours): 340 kW (P).

Calculation.

Taking into account the scale of the offer and the potential users' budget, the best optimistic scenario indicates 50 000 000 CHT transactions per year, giving an estimated annual energy consumption of 256 000 kWh.