White paper drafted under the European Markets in Crypto-Assets Regulation (EU) 2023/1114 for FFG CMQ8JCV3S

The crypto-asset STRATO (STRATO) referred to in this white paper is a crypto-asset other than EMTs and ARTs, will be available as the native token on the STRATO network and will be redeemable for currently existing Ethereum-STRATO which exists as an ERC-20 redemption token with the smart contract address 0x4c93B9FbF7Fd1777CCBcBc538B1d0a8b58fB1ad6 (“ERC-20 STRATO”), according to the DTI FFG shown in Section F.14, as of 2026-10-01. The ERC-20 STRATO will be redeemable on a 1:1 basis for native STRATO tokens once they are issued on the STRATO network, a Layer-1 blockchain that was launched on 2025-10-31. The maximum supply of STRATO will be 100,000,000 tokens.

The STRATO project is a protocolized network for credit backed by real-world assets. Users deposit collateral, such as tokenized gold and silver, other real-world assets or crypto-assets, and borrow USDST, a USD-denominated stablecoin, against it without selling the underlying position. Repaying the loan releases the collateral, and USDST can be used within the network for savings, lending, swaps and liquidity provision. The network earns fees from this borrowing, lending and swap activity, which are directed to validators and the protocol treasury. STRATO tokens are intended to be used on the STRATO network to pay transaction fees, to be staked by validators as a condition of taking part in block production, to be delegated by other holders to validators in return for a share of validator rewards, to reduce certain fees payable by borrowers when minting USDST and to support tokenholder participation. Transaction fees are currently paid in USDST. Fee payment in STRATO tokens, borrower fee benefits and tokenholder participation are planned and depend on future technical implementation and governance decisions.

Other than the entitlement to receive STRATO tokens on a 1:1 basis in exchange for ERC-20 STRATO once native STRATO are issued on the network, neither native STRATO nor ERC-20 STRATO grants 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.

STRATO Foundation is seeking admission to trading on the Payward Global Solutions LTD (“Kraken”), and may pursue admission to trading on additional platforms 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.

STRATO Foundation is the ecosystem parent for the STRATO Protocol, a permissionless blockchain enabling peer-to-peer vault-backed tokenization of precious metals. The Foundation's activities consist principally of governance and ecosystem support. The Foundation may also purchase and hold gold and silver bullion for its own account in support of its ecosystem activities.

STRATO Foundation was incorporated on 4 June 2026 and therefore has a limited financial and operating history. Since incorporation, its activities have principally related to governance and ecosystem support for the STRATO Protocol. The Foundation is the sole shareholder of STRATO Nexus Inc., holding 100% of its issued share capital.

In June 2026, STRATO Nexus, Inc. completed a pre-TGE Community ICO through a Uniswap Continuous Clearing Auction on Ethereum, which attracted more than 1,016 ETH in committed bids across 577 bids from 292 unique wallets. The offering proceeds have been managed through STRATO Nexus Inc., the issuer of $STRATO and the Foundation's wholly owned subsidiary, including through its digital-asset treasury wallet.

The Foundation is well capitalized, and expects to manage a significant STRATO ecosystem treasury on an ongoing basis, following the public issuance of STRATO.

STRATO Nexus Inc. is the issuer of STRATO and operator of the STRATO interface at https://strato.nexus/.

STRATO Foundation is the ecosystem parent for the STRATO Protocol, a permissionless blockchain enabling peer-to-peer vault-backed tokenization of precious metals. The Foundation's activities consist principally of governance and ecosystem support. The Foundation also purchases and holds gold and silver bullion for its own account in support of its ecosystem activities.

STRATO is a Layer-1 blockchain built for credit backed by real-world assets. The project's objective is to make gold, silver and other hard assets usable in decentralized finance, so that holders can borrow against them, transfer them and put them to work without selling them. The project refers to this approach as HardFi.

Users deposit collateral into collateralized debt positions and mint USDST, a USD-denominated stablecoin, against it. Accepted collateral includes tokenized gold and silver (GOLDST and SILVST), which are each backed 1:1 by physical metal held in vaults and are physically redeemable, as well as crypto-assets, yield-bearing stablecoins, tokenized equities and other tokenized real-world assets. Each position carries a collateralization ratio, and USDST is overcollateralized: every unit in circulation is backed by collateral worth more than its dollar value. If a position falls below its minimum ratio, third-party liquidators repay the debt and acquire the collateral at a discount. Repaying the USDST and the accrued stability fee releases the collateral. Once minted, USDST can be swapped, lent, borrowed, held in a savings vault or supplied to liquidity pools within the network. The network earns fees from borrowing, lending and swap activity, and these fees are directed to validators and the protocol treasury.

The STRATO token is intended to be used for staking, tokenholder participation, transaction fees and borrower fee benefits on the STRATO network. ERC-20 STRATO will be redeemable for native STRATO on a 1:1 basis. ERC-20 STRATO is not currently, and will not be, tradable, and functions purely as a redemption token for native STRATO once issued on the STRATO network.

The long-term evolution of the project depends on governance outcomes and technical, economic and regulatory considerations, and all future developments remain subject to change.

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

Past milestones:

- Mainnet launch (2025-10-31): the STRATO Layer-1 network was launched, together with the protocol functionality for real-world-asset-backed credit, including tokenized precious-metal products and USDST-related functionality for lending, swaps and savings.

- Pre-TGE Community ICO (June 2026): a Community ICO was completed through a Uniswap Continuous Clearing Auction on Ethereum. ERC-20 STRATO offered through the sale is a redemption token and will be redeemable on a 1:1 basis for STRATO tokens at the token generation event of STRATO on the STRATO network. Until then, ERC-20 STRATO is not transferable and can only be staked and unstaked on the STRATO platform.

Future milestones:

- Token generation event (Q4 2026): native STRATO tokens are to be issued on the STRATO network and ERC-20 STRATO becomes redeemable for them on a 1:1 basis.

- Validator participation and governance: staged expansion of validator participation and progressive decentralization, moving towards a more dispersed validator set, external validator participation and ultimately a broadly distributed validator set with tokenholder participation.

- Stake-weighted consensus is scheduled to become active on the mainnet.

- Token functions: payment of transaction fees in STRATO tokens, fee benefits for borrowers holding STRATO tokens and tokenholder participation, as described for the token.

Note: All future milestones are subject to significant uncertainty, including but not limited to technical feasibility, regulatory developments, market adoption and community participation and foundation governance decisions.

The development of the software underlying the STRATO protocol has been financed through equity funding associated with the development of the STRATO project. More than USD 41,000,000 in total has been raised across multiple funding rounds involving investors including Fenbushi Capital, ConsenSys Mesh, Bloccelerate, Galaxy Ventures, Morgan Creek Capital and Liberty City Ventures. The dates and individual amounts of these rounds are not disclosed.

In June 2026, STRATO Nexus, Inc. offered a pre-TGE Community ICO through a Uniswap Continuous Clearing Auction on Ethereum, in which the entitlement to receive native STRATO tokens on a 1:1 basis was offered in the form of ERC-20 STRATO. The auction received bids totaling more than 1,016 ETH, placed in 577 bids by 292 unique wallets. This figure is the gross amount committed in bids and does not represent net proceeds.

Not applicable, as this white paper serves the purpose of admission to trading and is not associated with any fundraising activity for the crypto-asset project.

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 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.

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 should have robust measures for managing conflicts of interest. Given the broad audience addressed by this white paper, prospective investors should review their counterparty’s conflicts-of-interest policy.

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.

STRATO is the native token of the STRATO network, a Layer-1 blockchain. Native STRATO tokens will be issued on the STRATO network at the token generation event, which is anticipated in Q4 2026. Until then, ERC-20 STRATO represents the entitlement to receive STRATO tokens on a 1:1 basis and will be redeemable for native STRATO once they are issued. ERC-20 STRATO is not transferable until the token generation event, and the only activity permitted with it before then is staking and unstaking on the STRATO platform. Because ERC-20 STRATO is not transferable, it cannot be traded. Admission to trading is sought for native STRATO tokens as issued on the STRATO network at the token generation event. The functions of STRATO tokens set out in this section are functions on the STRATO network and apply to STRATO tokens once they are issued.

Transaction fees on the STRATO network are currently paid in USDST as a flat amount per transaction. Payment of transaction fees in STRATO tokens is part of the planned design, under which fees would be paid to the protocol and governance would set the fee parameters over time.

STRATO tokens can be staked to secure the network. Validators stake STRATO tokens to take part in block production, and other holders can delegate their STRATO tokens to validators and share in the rewards those validators earn, net of a validator commission. Staking is implemented in the network's smart contracts and is scheduled to become active on the mainnet. Before the token generation event, holders can stake and unstake ERC-20 STRATO on the STRATO platform.

Holding STRATO tokens is intended to reduce the stability fees that borrowers pay when minting USDST. The discount would depend on the balance held in the wallet and would not require staking. This benefit is not yet implemented.

Tokenholder participation is not yet in operation. The realization of these intended functions depends on technical implementation and governance decisions, and no binding assurance can be given that all intended uses will be realized as described.

The supply of STRATO tokens is allocated as follows: team 14.0%, advisors 0.5%, investors 30.3%, sales before the token generation event 12.5%, airdrop 5.0%, ecosystem rewards 24.0%, ecosystem fund 7.7% and ecosystem development 6.0%. The sales before the token generation event, the airdrop and the ecosystem rewards, ecosystem fund and ecosystem development allocations together account for 55.2% of the supply and form the community allocation. Approximately 21.7% of the supply is expected to be in circulation at the token generation event. This consists of the sales before the event, the airdrop, 25% of the advisors allocation, 0.2% of the supply from the ecosystem rewards allocation and 50% of the ecosystem fund allocation.

The remaining allocations are released as follows. The team allocation is reserved for the core team and is locked for a cliff of 12 months after the token generation event, followed by linear monthly vesting over 24 months, so that it is fully vested 36 months after the event. The advisors allocation vests linearly each month over 12 months, with 25% unlocked at the event. The investors allocation vests linearly each month over 24 months from the event, with nothing unlocked at the event. The ecosystem rewards allocation funds programmes for total value locked, user incentives, referrals, partner co-incentives and emissions to validators, and is released through ongoing programmes and emissions until year 10. Emissions to validators amount to 8% of the supply over 10 years and are paid from this allocation. The ecosystem fund allocation covers listing costs, launchpool, market-maker loans, DEX liquidity and ecosystem commitments at the event, and the balance after the 50% unlocked at the event vests linearly each month over 24 months. The ecosystem development allocation funds grants, integrations and ecosystem development and vests linearly each month over 24 months from the event, with nothing unlocked at the event.

Apart from staking rewards, STRATO tokens do not entitle holders to any dividend, interest, share of protocol revenue, redemption right or claim on the assets of any person. Transaction fees are not currently paid in STRATO tokens. Before the token generation event, ERC-20 STRATO can only be staked and unstaked and does not confer the other functions set out in this section.

Other than the entitlement to receive STRATO tokens in exchange for ERC-20 STRATO, the STRATO token and ERC-20 STRATO do not confer ownership, profit participation, governance rights over the issuer or any related entity in a corporate-law sense, or any form of legally enforceable economic entitlement. All functionalities are technical in nature and relate exclusively to interactions within the STRATO protocol environment. The actual usability of STRATO depends on factors such as system stability, governance decisions, development progress and the operational conditions of the STRATO blockchain, which are outside the control of token holders.

Future milestones:

- Token generation event (Q4 2026): native STRATO tokens are to be issued on the STRATO network and ERC-20 STRATO becomes redeemable for them on a 1:1 basis.

- Validator participation and governance: staged expansion of validator participation and progressive decentralization, moving towards a more dispersed validator set, external validator participation and ultimately a broadly distributed validator set with tokenholder participation.

- Stake-weighted consensus is scheduled to become active on the mainnet.

- Token functions: payment of transaction fees in STRATO tokens, fee benefits for borrowers holding STRATO tokens and tokenholder participation, as described for the token.

Note: All future milestones are subject to significant uncertainty, including but not limited to technical feasibility, regulatory developments, market adoption and community participation and foundation governance decisions.

The crypto-asset referred to herein is a crypto-asset other than EMTs and ARTs. An ERC-20 redemption token (i.e., ERC-20 STRATO) was issued on the Ethereum network and will be redeemable for native STRATO on the 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 such services are currently provided by the issuer.

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.

Public offers of STRATO tokens are planned in connection with the token generation event, including a token sale through centralized exchanges or launchpools. Their terms, timing and execution have not been finalized and are subject to change.

ERC-20 STRATO is not transferable until the token generation event, and the only activity permitted with it before then is staking and unstaking on the STRATO platform. STRATO tokens allocated to the team, advisors, investors and ecosystem programmes are subject to lock-up and vesting periods and cannot be transferred before they are released. 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.

Not applicable, as the crypto-asset in scope does not have any value protection scheme in place.

Not applicable, as the crypto-asset in scope does not have any compensation scheme in place.

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 native to the STRATO blockchain. ERC-20 STRATO was issued as a redemption token for native STRATO, but is otherwise not freely available on the Ethereum network. The crypto-asset follows the standards described below.

The crypto-asset in scope is native to the STRATO blockchain. ERC-20 STRATO was issued as a redemption token for native STRATO, but is otherwise not freely available on the Ethereum network. The crypto-asset follows the standards described below.

The following applies to STRATO:

STRATO is a Layer-1 blockchain with its own consensus mechanism, secured by a set of validators that agree on blocks through a Byzantine fault-tolerant protocol. Smart contracts are written in Solidity syntax and run on SolidVM, the network's own virtual machine, not on the Ethereum Virtual Machine. The network accepts Ethereum-format signed transactions and serves the standard Ethereum JSON-RPC interface, so common Ethereum wallets can be used with it. Changes to the consensus rules take effect at a block height fixed in the node software, which every node must adopt together. Platform contracts are upgraded by replacing the logic behind a proxy contract, on a vote of the network's administrators.

The following applies to Ethereum:

Ethereum operates on a defined set of protocols and technical standards that are intended to ensure its security, decentralization, and functionality. Key items are set out below.

1. Network protocols

Ethereum operates as a decentralized, peer-to-peer network. Nodes communicate using the DevP2P networking stack, with RLPx as the encrypted transport layer for peer-to-peer messages.

Transaction ordering and finality are secured through a Proof-of-Stake (PoS) consensus mechanism. Validators on the Beacon Chain propose blocks, attest to them, and finalize them through Casper-FFG operating on top of the LMD-GHOST fork-choice rule. Smart contract execution is performed by the Ethereum Virtual Machine (EVM), which interprets EVM bytecode within the gas limits set by the protocol and by the transaction sender.

2. Transaction and address standards

Ethereum addresses are 20-byte identifiers, derived as the last 20 bytes of the Keccak-256 hash of the uncompressed elliptic-curve public key (excluding the 0x04 prefix). They are commonly represented as 40-character hexadecimal strings with a 0x prefix and an optional EIP-55 mixed-case checksum.

The protocol currently supports the following transaction types:

- Type 0: legacy transactions (pre-EIP-1559).

- Type 1: access-list transactions (EIP-2930).

- Type 2: dynamic-fee transactions with base-fee burning (EIP-1559).

- Type 3: blob-carrying transactions (EIP-4844), introduced with the Dencun upgrade on 2024-03-13.

- Type 4: set-code transactions (EIP-7702), introduced with the Pectra upgrade on 2025-05-07, allow externally owned accounts (EOAs) to authorize delegated code execution during transactions, without permanently converting the account into a smart contract. This enables features such as transaction batching, sponsored gas payments and delegated signing.

3. Blockchain data structure and block standards

The Ethereum state consists of accounts (externally owned accounts and smart contracts) together with their associated storage and code, organized in Modified Merkle Patricia Tries to allow efficient verification.

Each block contains:

- a block header, comprising the parent hash, state root, transactions root, receipts root, timestamp, gas limit and gas used, among other fields;

- the ordered list of transactions, including smart-contract executions and value transfers; and

- blob commitments, where applicable, referring to data published to the data availability layer under EIP-4844.

Block size is not fixed in bytes. It is constrained by a per-block gas limit, which is adjustable within protocol-defined bounds and is currently set at approximately 60 million gas following EIP-7935 (Fusaka, activated on 2025-12-03). EIP-7825 (Fusaka) also introduces a per-transaction gas cap of 16,777,216 gas to improve block composability and resilience against denial-of-service patterns.

The data availability layer used by Layer 2 rollups, introduced through EIP-4844, was further developed by EIP-7691 (Pectra, 2025-05-07), which raised the maximum number of blob commitments per block, and by EIP-7594 (Fusaka, 2025-12-03), which introduced Peer Data Availability Sampling (PeerDAS). PeerDAS enables nodes to verify that blob data has been published by sampling small portions of it, rather than downloading every blob in full. Following PeerDAS, Ethereum uses Blob Parameter Only (BPO) forks, introduced by EIP-7892, to adjust blob targets and maxima between major upgrades.

4. Upgrade and improvement standards

Ethereum protocol upgrades are coordinated through the Ethereum Improvement Proposal (EIP) process. EIPs are published openly, reviewed by core developers and the wider community, and bundled into named hard-fork upgrades. The most recent network upgrades are the Pectra upgrade (2025-05-07) and the Fusaka upgrade (2025-12-03). The next named upgrade currently under preparation by the Ethereum core developers is referred to as Glamsterdam.

The crypto-asset in scope is native to the STRATO blockchain. ERC-20 STRATO was issued as a redemption token for native STRATO, but is otherwise not freely available on the Ethereum network. The crypto-asset follows the standards described below.

The following applies to STRATO:

1. Distributed ledger: STRATO maintains a ledger of all transactions and balances, replicated across the nodes of the network. Every node executes each committed block and holds the resulting state.

2. Execution: contracts run on SolidVM only. Contracts that consist of EVM bytecode are not accepted.

3. Wallets and keys: accounts are controlled by cryptographic key pairs. Users can sign transactions with MetaMask, with wallets that support WalletConnect or with a wallet extension provided by the project.

4. Token standards: fungible tokens follow the ERC-20 standard and non-fungible tokens follow the ERC-721 standard.

The following applies to Ethereum:

1. Decentralized Ledger: The Ethereum blockchain acts as the decentralized ledger and execution environment for ETH transactions and smart-contract operations, including ERC-20 token transfers, maintaining an append-only record of transfers and account balances to support transparency and verifiable settlement.

2. Account Model: Ethereum uses two account types: externally owned accounts (EOAs), which are controlled through private keys, and contract accounts, which are controlled through deployed smart contract code. Following the Pectra upgrade on 2025-05-07, EOAs can additionally authorize delegated code execution through EIP-7702 transactions without permanently converting the account into smart contracts.

3. Private Key Management: Users must securely store the private keys and recovery material associated with their wallets. Loss or compromise of a private key may result in irreversible loss of access to the associated ETH or ERC-20 token balance.

4. Cryptographic Integrity: Ethereum uses ECDSA over the secp256k1 elliptic curve for key generation and digital signatures on the execution layer. Keccak-256 hashing is used for transaction hashing, state hashing and address derivation. Ethereum addresses are derived from the last 20 bytes of the Keccak-256 hash of the public key. On the consensus layer, BLS (Boneh-Lynn-Shacham) signatures are used to aggregate validator attestations under the Proof-of-Stake consensus mechanism.

The crypto-asset in scope is native to the STRATO blockchain. ERC-20 STRATO was issued as a redemption token for native STRATO, but is otherwise not freely available on the Ethereum network. The crypto-asset follows the standards described below.

The following applies to STRATO:

STRATO uses a Practical Byzantine Fault Tolerant (PBFT) consensus protocol based on Istanbul BFT. A proposer broadcasts each block, validators vote on it, and the block is committed and final once validators holding more than two thirds of the voting weight have signed it. The protocol tolerates faulty validators holding less than one third of the weight. The validator set is recorded in an on-chain governance contract. Where stake-weighted consensus is not active, all validators carry equal weight and the set is changed by a vote of network administrators. The node software also supports stake-weighted consensus, switched on for each network at a block height fixed in advance. Where it is active, voting weight and proposer selection follow the stake bonded to each validator, entry to the set requires a minimum stake and the size of the set is capped. Validators that repeatedly miss their turn to propose can be removed temporarily. Stake is not slashed.

The following applies to Ethereum:

Ethereum uses a Proof-of-Stake (PoS) consensus mechanism introduced with The Merge on 2022-09-15, which replaced the previous Proof-of-Work consensus model. The PoS mechanism is implemented through Gasper, combining Casper-FFG for finality with the LMD-GHOST fork-choice rule for chain selection. Validators participate in consensus by staking ETH through the Beacon Chain. Validators are pseudo-randomly selected to propose new blocks, while other validators attest to the validity of proposed blocks. The network operates using 12-second slots grouped into epochs of 32 slots. Under normal network conditions, finality is typically achieved after two epochs, approximately 12.8 minutes, through Casper-FFG. The LMD-GHOST fork-choice rule determines the canonical chain based on the accumulated weight of validator attestations. Validators that engage in certain malicious behavior, such as equivocation or contradictory attestations, may be subject to slashing penalties, while offline validators may incur inactivity penalties. Subsequent network upgrades, including Dencun (2024-03-13), Pectra (2025-05-07) and Fusaka (2025-12-03), introduced protocol changes affecting Ethereum’s consensus mechanism and Layer 2 functionality.

The crypto-asset in scope is native to the STRATO blockchain. ERC-20 STRATO was issued as a redemption token for native STRATO, but is otherwise not freely available on the Ethereum network. The crypto-asset follows the standards described below.

The following applies to STRATO:

Every transaction pays a flat fee before it is executed: one fee voucher issued by the network or, if the sender holds none, 0.01 USDST, a US dollar stablecoin native to the network. There is no gas price, and the fee is kept even if the transaction fails. Fees are collected by a protocol fee contract. Where the network's fee router contract is in use, a share of each fee is credited to the block proposer's validator and its delegators and the remainder goes to the protocol. The staking contracts also provide for block rewards to proposers, for validators to charge a commission on delegators' rewards up to a maximum set by governance, and for delegated stake to be withdrawn after an unbonding period.

The following applies to Ethereum:

Ethereum’s Proof-of-Stake (PoS) mechanism secures the network through validator incentives and protocol-defined penalties. Validators are required to stake ETH in order to participate in block proposal and attestation activities. A minimum of 32 ETH is required to activate a validator. Following the Pectra upgrade on 2025-05-07, EIP-7251 increased the maximum effective balance per validator from 32 ETH to 2,048 ETH. Validators may receive protocol-defined rewards for proposing blocks, attesting to valid blocks and participating in sync committees. Rewards consist of newly issued ETH and transaction-related fees. Transaction fees on Ethereum follow the mechanism introduced by EIP-1559, under which each transaction includes a base fee that is burned at the protocol level and an optional priority fee paid to the validator proposing the relevant block. Validators that engage in certain malicious behavior, including equivocation or contradictory attestations, may be subject to slashing penalties. Validators that fail to participate correctly in consensus activities may also incur inactivity penalties. These mechanisms are intended to support validator participation and the economic security of the Ethereum network.

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.

Not applicable.

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 centralized exchanges (CEXs) or decentralized 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 centralized or decentralized 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 recognized 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. These can include hacks, data breaches or technical compromises of critical protocol infrastructure affecting the safekeeping and transmission of units of value on the protocol, which could include collateral assets, USDST and STRATO tokens, among other things.

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 behavior 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, unauthorized 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 unauthorized 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, disproportionate influence, 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.

Centralization concerns: Despite claims of decentralization, 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 stabilizes, 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 centralized 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. Decentralization 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 native to the STRATO blockchain. ERC-20 STRATO was issued as a redemption token for native STRATO, but is otherwise not freely available on the Ethereum network. The crypto-asset follows the standards described below.

The following applies to STRATO:

STRATO uses a Practical Byzantine Fault Tolerant (PBFT) consensus protocol based on Istanbul BFT. A proposer broadcasts each block, validators vote on it, and the block is committed and final once validators holding more than two thirds of the voting weight have signed it. The protocol tolerates faulty validators holding less than one third of the weight. The validator set is recorded in an on-chain governance contract. Where stake-weighted consensus is not active, all validators carry equal weight and the set is changed by a vote of network administrators. The node software also supports stake-weighted consensus, switched on for each network at a block height fixed in advance. Where it is active, voting weight and proposer selection follow the stake bonded to each validator, entry to the set requires a minimum stake and the size of the set is capped. Validators that repeatedly miss their turn to propose can be removed temporarily. Stake is not slashed.

The following applies to Ethereum:

Ethereum uses a Proof-of-Stake (PoS) consensus mechanism introduced with The Merge on 2022-09-15, which replaced the previous Proof-of-Work consensus model. The PoS mechanism is implemented through Gasper, combining Casper-FFG for finality with the LMD-GHOST fork-choice rule for chain selection. Validators participate in consensus by staking ETH through the Beacon Chain. Validators are pseudo-randomly selected to propose new blocks, while other validators attest to the validity of proposed blocks. The network operates using 12-second slots grouped into epochs of 32 slots. Under normal network conditions, finality is typically achieved after two epochs, approximately 12.8 minutes, through Casper-FFG. The LMD-GHOST fork-choice rule determines the canonical chain based on the accumulated weight of validator attestations. Validators that engage in certain malicious behavior, such as equivocation or contradictory attestations, may be subject to slashing penalties, while offline validators may incur inactivity penalties. Subsequent network upgrades, including Dencun (2024-03-13), Pectra (2025-05-07) and Fusaka (2025-12-03), introduced protocol changes affecting Ethereum’s consensus mechanism and Layer 2 functionality.

The crypto-asset in scope is native to the STRATO blockchain. ERC-20 STRATO was issued as a redemption token for native STRATO, but is otherwise not freely available on the Ethereum network. The crypto-asset follows the standards described below.

The following applies to STRATO:

Every transaction pays a flat fee before it is executed: one fee voucher issued by the network or, if the sender holds none, 0.01 USDST, a US dollar stablecoin native to the network. There is no gas price, and the fee is kept even if the transaction fails. Fees are collected by a protocol fee contract. Where the network's fee router contract is in use, a share of each fee is credited to the block proposer's validator and its delegators and the remainder goes to the protocol. The staking contracts also provide for block rewards to proposers, for validators to charge a commission on delegators' rewards up to a maximum set by governance, and for delegated stake to be withdrawn after an unbonding period.

The following applies to Ethereum:

Ethereum’s Proof-of-Stake (PoS) mechanism secures the network through validator incentives and protocol-defined penalties. Validators are required to stake ETH in order to participate in block proposal and attestation activities. A minimum of 32 ETH is required to activate a validator. Following the Pectra upgrade on 2025-05-07, EIP-7251 increased the maximum effective balance per validator from 32 ETH to 2,048 ETH. Validators may receive protocol-defined rewards for proposing blocks, attesting to valid blocks and participating in sync committees. Rewards consist of newly issued ETH and transaction-related fees. Transaction fees on Ethereum follow the mechanism introduced by EIP-1559, under which each transaction includes a base fee that is burned at the protocol level and an optional priority fee paid to the validator proposing the relevant block. Validators that engage in certain malicious behavior, including equivocation or contradictory attestations, may be subject to slashing penalties. Validators that fail to participate correctly in consensus activities may also incur inactivity penalties. These mechanisms are intended to support validator participation and the economic security of the Ethereum network.

The energy consumption of this asset is aggregated across multiple components: to determine the energy consumption of a token, the expected energy consumption of the networks STRATO and Ethereum is calculated first. For the energy consumption of the token, a fraction of the energy consumption of the network is attributed to the token, which is determined based on the expected activity of the crypto-asset within the network. When calculating the energy consumption, the Functionally Fungible Group Digital Token Identifier (FFG DTI) is used, if available, to determine all implementations of the asset in scope. The mappings are updated regularly, based on data from the Digital Token Identifier Foundation. The information regarding the hardware used and the number of participants in the network is based on assumptions that are verified on a best-effort basis using empirical data. In general, participants are assumed to be largely economically rational. As a precautionary principle, we make assumptions on the conservative side when in doubt, i.e. by making higher estimates of the adverse impacts.

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 incentivization 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 incentivization 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.