..

White paper for crypto-assets other than asset-referenced tokens or e-money tokens


Digital Token Identifier:   WCWG3WXP9

Offeror or person seeking admission to trading:   Swiss Commercial Register Number: CHE-198.483.059 - ICON Foundation

Type of submission:   New


Table of content

General information

SUMMARY

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

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

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

Part D - Information about other token project

Part E - Information about offer to public of other tokens or their admission to trading

Part F - Information about other tokens

Part G - Information on rights and obligations attached to other tokens

Part H – Information on underlying technology

Part I - Information on risks

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





[Table 2] Template for white papers for crypto-assets other than asset-referenced tokens or e-money tokens


Template for white papers for crypto-assets other than asset-referenced tokens or e-money tokens [abstract]

General information



00 Table of content
boolean true true

01 Date of notification
date 2026-03-18

02 Statement in accordance with Article 6(3) of Regulation (EU) 2023/1114
boolean true This crypto-asset white paper has not been approved by any competent authority in any Member State of the European Union. The person seeking admission to trading of the crypto-asset is solely responsible for the content of this crypto-asset white paper.

03 Compliance statement in accordance with Article 6(6) of Regulation (EU) 2023/1114
boolean true This crypto-asset white paper complies with Title II of Regulation (EU) 2023/1114 of the European Parliament and of the Council and, to the best of the knowledge of the management body, the information presented in the crypto-asset white paper is fair, clear and not misleading and the crypto-asset white paper makes no omission likely to affect its import.

04 Statement in accordance with Article 6(5), points (a), (b), (c), of Regulation (EU) 2023/1114
boolean true The crypto-asset referred to in this crypto-asset white paper may lose its value in part or in full, may not always be transferable and may not be liquid

05 Statement in accordance with Article 6(5), point (d), of Regulation (EU) 2023/1114
boolean true The utility token referred to in this white paper may not be exchangeable against the good or service promised in this white paper, especially in the case of a failure or discontinuation of the crypto-asset project.

06 Statement in accordance with Article 6(5), points (e) and (f), of Regulation (EU) 2023/1114
boolean true The crypto-asset referred to in this white paper is not covered by the investor compensation schemes under Directive 97/9/EC of the European Parliament and of the Council or the deposit guarantee schemes under Directive 2014/49/EU of the European Parliament and of the Council.

SUMMARY



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

This summary should be read as an introduction to the crypto-asset white paper.

The prospective holder should base any decision to purchase this crypto –asset on the content of the crypto-asset white paper as a whole and not on the summary alone.

The offer to the public of this crypto-asset does not constitute an offer or solicitation to purchase financial instruments and any such offer or solicitation can be made only by means of a prospectus or other offer documents pursuant to the applicable national law.

This crypto-asset white paper does not constitute a prospectus as referred to in Regulation (EU) 2017/1129 of the European Parliament and of the Council or any other offer document pursuant to Union or national law.


08 Characteristics of the crypto-asset
textBlock General. The Token is an ERC-20-compatible fungible token fungible issued on the Sonic Blockchain Network ("Network"). The Token has a fixed total supply of 1.5 billion units.
Functionality. The Token is a utility token intended to provide access to functionalities relating to SODAX Protocol ("Protocol") as further described under Section F.02. The Token serves as the primary means for
(1) accessing and interacting with the Protocol ("Access Functionality"); and
(2) enabling participation in Protocol governance through staking ("Governance Staking Functionality");
Token functionalities are purely technical: the Token does not confer any ownership, profit-sharing, or redemption rights, nor does it represent a claim against the offeror or any affiliated entity.
Token functionalities are provided "as is" by the Protocol, without any guarantees by the Person Seeking Admission to Trading.
The Protocol is subject to decentralized governance. Decisions adopted through such governance may result in changes to the token's functionalities. Any such changes are outside the control of the Person Seeking Admission to Trading.
The Token is a crypto asset as defined by article 3 (1) (5) of Regulation (EU) 2023/1114 and more specifically, it qualifies as a utility token under article 3 (1) (9) of the aforementioned regulation.
Legacy. The Token replaces the ICX token, a utility token originally native to the ICON blockchain network, which was launched in 2017 and on which parts of the infrastructure constituting the Protocol were initially deployed. In July 2025, a governance vote approved the migration of the Protocol to the Network to enhance scalability and performance. This migration is accompanied by a change of utility token from ICX to the Token ("Migration"). Migration is voluntary and is implemented at a fixed 1:1 exchange ratio.


09 Further information about utility tokens
textBlock All Token functionalities grant access to purely technical goods and services. The quality and quantity of such goods and services, which are provided exclusively by the Protocol, depend on the Protocol's technical and operational state as well as on the number of Tokens in circulation.
As Protocol and its users' engagement will evolve over time, these parameters may change. Accordingly, the extent and performance of the Token's functionalities cannot be reliably quantified at the date of publication of this White Paper.


10 Key information about the offer to the public or admission to trading
textBlock This White Paper does not relate to an offer to the public.
ICON Foundation acts as the Person Seeking Admission to Trading and seeks admission of the Token on multiple trading platforms, operating within the European Union ("EU") or the European Economic Area ("EEA") ("Trading Platforms").
The Token has also been traded on the following EU trading platforms, each of which had admitted ICX to trading prior to the Migration and subsequently replaced it with the Token following the Migration:
Binance - https://www.binance.com/
Bitvavo - https://bitvavo.com/
Bit2me - https://bit2me.com/
ByBit - https://www.bybit.com/
Crypto.com - https://crypto.com/
Kraken - https://www.kraken.com/
OKX - https://www.okx.com/
Additional listings are sought based on this White Paper but were not yet confirmed.
The up-to-date list of confirmed and available Trading Platforms is maintained on the website of the Person Seeking Admission to Trading.
In seeking admission to trading, the Person Seeking Admission to Trading complies with its obligations under article 5 of Regulation (EU) 2023/1114.


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



A.1 Name
text ICON Foundation

A.2 Legal form
text Foundation under Swiss Law

A.3 Registered address



Registered addess
text Gubelstrasse 11, 6300 Zug

Country
enumeration
Switzerland


Sub-division
text Not applicable

A.4 Head office



Head office
text Not applicable.

Country
enumeration


Sub-division
text Not applicable.

A.5 Registration date
date 2017-08-09

A.6 Legal entity identifier
LEI


A.7 Another identifier required pursuant to applicable national law
text Swiss Commercial Register Number: CHE-198.483.059

A.8 Contact telephone number
text +41 41 711 15 62

A.9 E-mail address
text icon@icon.foundation

A.10 Response time (days)
integer 5

A.11 Parent company
text Not applicable.

A.12 Members of the management body



Member #1
id 1

Identity
text Min Kim

Business address
text Gubelstrasse 11, 6300 Zug, Switzerland

Function
text President of the Council

Member #2
id 2

Identity
text Kyoung June Eee

Business address
text Gubelstrasse 11, 6300 Zug, Switzerland

Function
text Vice President of the Council

Member #3
id 3

Identity
text Pascal Schmid

Business address
text Gubelstrasse 11, 6300 Zug, Switzerland

Function
text Secretary of the Council

A.13 Business activity
textBlock The Person Seeking Admission to Trading is dedicated to supporting the long-term growth of open-source, decentralized technologies, with a particular focus on blockchain interoperability and decentralized finance (DeFi). Its primary focus is the development and promotion of SODAX, a next-generation DeFi protocol that evolved out of the previous ICON Project. In addition, the Person Seeking Admission to Trading supports a range of initiatives that advance the mission of fostering an open, accessible, and interconnected finance.
Established as a not-for-profit foundation under Swiss law, the Person Seeking Admission to Trading operates exclusively to serve its mission, not to pursue profit. All resources are directed toward advancing innovation, supporting education, and funding development in alignment with the foundation's purpose.


A.14 Parent company business activity
textBlock Not applicable.

A.15 Newly established
boolean false

A.16 Financial condition for the past three years
textBlock Supervision. The Person Seeking Admission to Trading operates under the supervision of the Swiss Federal Supervisory Authority for Foundations (ESA) and has appointed Grant Thornton as its statutory auditor in accordance with Article 83b of the Swiss Civil Code. This supervisory framework provides ongoing oversight of the governance and financial situation.

Financial statements. Although Swiss law does not require the publication of detailed financial statements, the Person Seeking Admission to Trading maintains robust financial management and internal reporting practices consistent with its supervisory obligations.

Grant Thornton has consistently issued an unqualified audit opinion (so-called "standard audit opinion" under Swiss audit practice) on the ordinary audit of the statutory financial statements, without any deviations from the standard wording used in the profession.

General Condition. Since its establishment, the Person Seeking Admission to Trading has maintained sound financial condition, with no instances of financial distress, insolvency, or going concern issues.

The Foundation has no material outstanding debt, no material issues have been identified in any audit years, and the Person Seeking Admission to Trading has not been subject to any regulatory sanctions or investigations.

The Foundation operates under a conservative financial management policy, ensuring sufficient liquidity to sustain ongoing development and operations.

Over the past three years (2023–2025), the ICON Foundation has maintained a stable financial position while fulfilling its non-profit mandate to support the growth and development of the ICON blockchain ecosystem.

Source of Funding. The Person Seeking Admission to Trading was established in 2017 and was initially financed primarily through proceeds from private and public token sales (of the ICX token) amounting to approximately 150,000 ETH, corresponding to roughly CHF 66 million at that time. These proceeds have since been strategically invested and utilized in various forms and continue to support the ongoing business activities.
Under Swiss accounting standards, such investments are recorded in the accounts at fair value rather than at their original face value and are subject to external auditor review. As a result, given the valuation methodology and the evolution of these investments over time, it is not meaningful to indicate a single precise amount of assets currently available as of the date of this White Paper.
The Foundation currently has no plans for additional fundraising activities (such as token sales), nor are there any short-term funding initiatives under consideration.

In light of the foregoing, and based on the annual financial statements and independent audit reports, the Foundation confirms that it holds sufficient financial resources to continue operations.


A.17 Financial condition since registration
textBlock Not applicable.

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



B.1 Issuer different from offerror or person seeking admission to trading
boolean false

B.2 Name
N/A
.

B.3 Legal form
N/A .

B.4 Registered address

Registered addess
N/A .

Country
N/A .

Sub-division
N/A .

B.5 Head office

Head office
N/A .

Country
N/A .

Sub-division
N/A .

B.6 Registration date
N/A .

B.7 Legal entity identifier
N/A .

B.8 Another identifier required pursuant to applicable national law
N/A .

B.9 Parent company
N/A .

B.10 Members of the management body

Member #1
N/A .

Identity
N/A .

Business address
N/A .

Function
N/A .

B.11 Business activity
N/A .

B.12 Parent company business activity
N/A .

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

C.1 Name
N/A .

C.2 Legal form
N/A .

C.3 Registered address

Registered address
N/A .

Country
N/A .

Sub-division
N/A .

C.4 Head office

Head office
N/A .

Country
N/A .

Sub-division
N/A .

C.5 Registration date
N/A .

C.6 Legal entity identifier
N/A .

C.7 Another identifier required pursuant to applicable national law
N/A .

C.8 Parent company
N/A .

C.9 Reason for crypto-asset white paper preparation
N/A .

C.10 Members of the management body

Member #1
N/A .

Identity
N/A .

Business address
N/A .

Function
N/A .

C.11 Operator business activity
N/A .

C.12 Parent company business activity
N/A .

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

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

Part D - Information about other token project



D.1 Crypto-asset project name
text SODAX

D.2 Crypto-asset name
text SODA Token

D.3 Abbreviation
text SODA

D.4 Crypto-asset project description
textBlock The Protocol referred to as Secure Onchain Digital Assets Xchange, or SODAX, is a decentralized finance (DeFi) protocol designed as a vertically integrated stack of cross-chain applications intended to bring together core DeFi primitives, including, in particular, money markets, collateralized debt position (CDP)-based stablecoins, and decentralized exchanges, within a cohesive and interoperable ecosystem.
The Protocol is designed to support cross-chain trading and liquidity provision by facilitating the aggregation and coordination of liquidity across multiple blockchains, with the objective of offering developers and users a more efficient, scalable, and interoperable DeFi experience and contributing to the evolution of decentralized, multi-chain asset management.
The Protocol comprises DeFi applications deployed by the Person Seeking Admission to Trading as well as third-party applications, whether or not they are built using the SDK made available along with the Protocol (collectively, the "Applications"). The Person Seeking Admission to Trading does not retain or exercise any administrative control over the deployed Applications, which operate independently and are subject to decentralized governance mechanisms.


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



Person #1
id 1

Type of person
enumeration
Development team


Name of person
text Hashlock

Business address of person
text  215-217 Pacific Highway, Charlestown, 2290 New South Wales

Domicile of company
enumeration
Australia


Person #2
id 2

Type of person
enumeration
Other person involved in implementation


Name of person
text Hana Tech Pty Ltd

Business address of person
text 23 Innovation Campus Squires Way, North Wollongong, 2500 New South Wales

Domicile of company
enumeration
Australia


Person #3
id 3

Type of person
enumeration
Other person involved in implementation


Name of person
text Parameta

Business address of person
text 8F, 311, Gangnam-daero, Seocho-gu, Seoul

Domicile of company
enumeration
Korea (the Republic of)


D.6 Utility token classification
boolean true

D.7 Key features of goods or services for utility token projects
text The Token grants access to the functionalities described in Section F.02 and made available on an "as is" basis.
All functionalities provide access exclusively to technical goods and services.
The scope, quantity, and quality of the goods and services accessed in the context of each functionality are thus determined, respectively, by (i) the circulating supply of the Token effectively available for use and (ii) the overall state of the Protocol providing such goods and services. As the Protocol evolves and user engagement develops, both factors are shaped by active Protocol participants at any given time and by the Protocol's ongoing development. Accordingly, they cannot be quantified at this stage.
The Protocol is subject to decentralized governance. Decisions adopted through such governance may result in modifications to the Token's functionalities and, consequently, to the technical goods and services accessible through the Token. Any such changes are outside the control of the Person Seeking Admission to Trading.
The functionalities do not confer any rights against, nor impose any legal obligations on the Person Seeking Admission to Trading or any other entity in respect of Token holders.


D.8 Plans for the token



Description of past milestones
textBlock Milestones related to the previous ICON Project, which laid the groundwork for the present Protocol through the deployment of the underlying technology and the gradual expansion of its user community, both of which continue to benefit the Protocol today.

June 2024 – U.S. District Court Rules in Favor of ICON Foundation in Exploit Related Matter
Feb 2024 – Balanced Enshrinement Goes Live
Jan 2024 – ICON Economic Policy Changes (IISS 4.0) Announced
Jul 2023 – xCall Incentivized Testnet Goes Live
Dec 2021 – ICON 2.1 Network Upgrade Completed
Nov 2021 – ICON 2.0 Mainnet Upgrade Completed
Apr 2021 – Balanced Protocol Launches on ICON
Jan 2018 – ICON Network Mainnet Genesis Block Launched
Sep 2017 – ICX ICO Conducted

Milestones related to the Protocol
Oct 2025 – SODAX Swap Launches
Sep 2025 – SODA Test Migration Goes Live
Aug 2025 – SODAX Launches Validator Node on Sonic
Jul 2025 – Solver Goes Live on SODAX
Jul 2025 – SODAX SDKs Released
May 2025 – Announcement of ICX to SODA Migration


Description of future milestones
textBlock Future milestones are subject to change depending, notably, on third-party integrations and cooperations, and will be announced on the website indicated under Section F.8

D.9 Resource allocation
text Presently, the resources of the Person Seeking Admission to Trading are used in line with its activities, as described under Section A.17.

D.10 Planned use of collected funds or other tokens
text Not applicable.

Part E - Information about offer to public of other tokens or their admission to trading



E.1 Public offering or admission to trading
enumeration
Admission to trading


E.2 Reasons for public offer or admission to trading
textBlock Admission to trading on Trading Platforms is sought to facilitate compliant access to the Token within the European market and, in doing so, enhance market liquidity, price transparency, and overall trading efficiency. Admission to trading is also intended to promote broader participation in, and accessibility to, the Token and its utility within the Protocol.

E.3 Fundraising target



Target expressed in currency
monetary
EUR

Target expressed in units
decimal


Target expressed in digital token identifier
text


E.4 Minimum subscription goals



Goals expressed in currency
monetary
EUR

Goals expressed in units
decimal


Goals expressed in digital token identifier
text


E.5 Maximum subscription goals



Goasl expressed in currency
monetary
EUR

Goals expressed in units
decimal


Goals expressed in digital token identifier
text


E.6 Oversubscription acceptance
boolean


E.7 Oversubscription allocation
text


Issue price details



E.8 Issue price
decimal


E.9 Official currency determining issue price
enumeration


E.9 Any other tokens determining issue price
text


E.10 Subscription fee



Fee expressed in currency
monetary
EUR

Fee expressed in units
decimal


Fee expressed in digital token identifier
text


E.11 Offer price determination method
text


E.12 Total number of offered or traded other tokens
integer


E.13 Targeted holders
enumeration
Professional investors


E.14 Holder restrictions
text The Network is permissionless and decentralized by design. There are thus no restrictions at chain-level.
The Trading Platforms in accordance with applicable laws, including applicable international sanctions, and internal policies may impose restrictions on buyers and sellers of Tokens. Such restrictions are not implemented by the Person Seeking Admission to Trading.


E.15 Reimbursement notice
boolean true


E.16 Refund mechanism
textBlock


E.17 Refund timeline
text


E.18 Offer phases
textBlock


E.19 Early purchase discount
textBlock


E.20 Time-limited offer
boolean


E.21 Subscription period beginning
date


E.22 Subscription period end
date


E.23 Safeguarding arrangements for offered funds or other tokens
textBlock


E.24 Payment methods for other token purchase
textBlock


E.25 Value transfer methods for reimbursement
textBlock


E.26 Right of withdrawal
textBlock


E.27 Transfer of purchased other tokens
textBlock The Tokens acquired as a result of trades shall be transferred to the compatible wallet or technical device as designated by the selected Trading Platforms.
The Person Seeking Admission to Trading bears no responsibility for any transfers of the Token between market participants on the Trading Platforms.


E.28 Transfer time schedule
text The transfer of the Tokens acquired as a result of trades conducted on the Trading Platforms may or may not occur immediately, depending on the functioning of the selected Trading Platform.
The Person Seeking Admission to Trading has no control over the timing of such transfers.


E.29 Purchaser's technical requirements
textBlock The Token holder must comply with the technical requirements specific to the Trading Platforms on which the Token is admitted to trading, which may include the following:(i) a device (computer or mobile) to manage digital wallet/private key and/or account on exchange to carry out transactions; (ii) a compatible digital wallet or account on the Trading Platform; and (iii) Internet access.

Other token services provider characteristics



E.30 Other token service provider (CASP) name
text Not applicable.

E.31 CASP identifier
LEI


E.32 Placement form
enumeration


Trading platforms characteristics



E.33 Trading platforms name
text The Token has been traded on the following Trading Platforms, each of which had admitted ICX to trading prior to the Migration and subsequently replaced it with the Token following the Migration:
Binance - https://www.binance.com/
Bitvavo - https://bitvavo.com/
Bit2me - https://bit2me.com/
ByBit - https://www.bybit.com/
Crypto.com - https://crypto.com/
Kraken - https://www.kraken.com/
OKX - https://www.okx.com/
Additional listings are sought based on this White Paper but were not yet confirmed.
The up-to-date list of confirmed and available Trading Platforms is maintained on the website of the Person Seeking Admission to Trading.


E.34 Trading platforms market identifier code (MIC)
text Not available.

E.35 Trading platforms access
text Trading platforms are accessible via their respective website or mobile device application.

E.36 Involved costs
textBlock The use of services offered by Trading Platforms may involve costs, including transaction fees, withdrawal fees, and other charges, as notified to users in advance. These costs are determined and set by the respective Trading Platforms and are not controlled, influenced, or governed by the Person Seeking Admission to Trading. Consequently, any changes to initially announced fee structures or the introduction of new costs for the future are solely at the discretion of the Trading Platforms.

E.37 Offer expenses
textBlock Not applicable.

E.38 Conflicts of interest
textBlock The Person Seeking Admission to Trading is not aware of any potential conflict of interest among its management body members or any other person within its entity with respect to the admission to trading of the Token.

E.39 Applicable law
textBlock Any dispute arising out of or in connection with the present White Paper, the Person Seeking Admission to Trading, and the admission to trading shall be governed exclusively by the laws of Switzerland, without regard to conflict of law rules or principles, except to the extent that such disputes are governed by applicable law pursuant to the terms and conditions of a Trading Platform.

E.40 Competent court
textBlock Any dispute arising out of or in connection with the present White Paper, Person Seeking Admission to Trading and the admission to trading shall be exclusively resolved by arbitration.
The arbitral proceedings shall be conducted in accordance with the Swiss Rules of International Arbitration of the Swiss Arbitration Centre in force on the date on which the Notice of Arbitration is submitted in accordance with those Rules.
The number of arbitrators shall be three.
The seat of the arbitration shall be Zürich, Switzerland.
The arbitral proceedings shall be conducted in English.
A respective arbitral award may only be challenged before the Swiss Supreme Court on the limited grounds as provided in Article 190 para. 2 Swiss Private International Law Act, i.e. (i) improper constitution of the arbitral tribunal; (ii) incorrect decision on jurisdiction; (iii) award beyond the claims submitted or failing to decide all claims submitted; (iv) violation of a party's right to be heard or of its right to equal treatment; and (v) incompatibility of the award with public policy.


Part F - Information about other tokens



F.1 Crypto-asset type
text Utility token

F.2 Other token functionality
textBlock The Token is a utility token intended to provide access to functionalities relating to the Protocol, and specifically:
Access Functionality: the Token is used for accessing and interacting with the Protocol; it is required to pay transaction fees associated with the use of the Protocol.
Each cross-chain interaction generally requires the payment of transaction fees in at least two cryptocurrencies across different networks. Against this background, the Token serves as the unified settlement and facilitation mechanism for the multi-network operations enabled by the Protocol, simplifying the process and ensuring execution efficiency.
Governance Staking Functionality: the Token enables participation in Protocol governance through staking ("Governance Staking Functionality").
The Protocol is subject to decentralized governance. Decisions adopted through such governance may result in changes to the Token's functionalities. Any such changes are outside the control of the Person Seeking Admission to Trading and thus, the Person Seeking Admission to Trading makes no commitment, representation, or warranty as to the implementation, timing, or availability of any existing or future functionalities.


F.3 Planned application of functionalities
textBlock The Access Functionality is operational and available for immediate use.
The Governance Staking Functionality is expected to be completed within three (3) months following the publication of this White Paper. This indicative timeline remains subject to change due to technical constraints or other circumstances.


A description of the characteristics of the other token, including the data necessary for classification of the crypto-asset white paper in the register referred to in Article 109 of Regulation (EU) 2023/1114, as specified in accordance with paragraph 8 of that Article



F.4 Type of crypto-asset white paper
enumeration
Other crypto-asset token white paper


F.5 Type of submission
enumeration
New


F.6 Other token characteristics
textBlock Issued on the Sonic Blockchain Network based on a ERC-20 compatible standard.
Fixed total supply of 1.5 billion units (see Section G.12)
Token issued as a utility token of the Protocol with the functionalities described under Section F.2.
Token does not carry any legally enforceable rights or entitlements against the issuer (see Section G.1).


F.7 Commercial name or trading name
text SODAX

F.8 Website of the issuer
text SODAX - https://www.sodax.com/
ICON Foundation - https://www.icon.foundation/


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


F.10 Publication date
date 2026-04-17

F.11 Any other services provided by the issuer
textBlock Not applicable.

F.12 Language or languages of white paper
text English.

F.13 Digital token identifier code used to uniquely identify the crypto-asset or each of the several crypto assets to which the white paper relates, where available
text WCWG3WXP9

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


F.15 Voluntary data flag
boolean false

F.16 Personal data flag
boolean true

F.17 LEI eligibility
boolean false

F.18 Home member state
enumeration
Ireland


F.19 Host member states #1
enumerationSet
Austria


F.19 Host member states #2
enumerationSet
Belgium


F.19 Host member states #3
enumerationSet
Bulgaria


F.19 Host member states #4
enumerationSet
Croatia


F.19 Host member states #5
enumerationSet
Cyprus


F.19 Host member states #6
enumerationSet
Czechia


F.19 Host member states #7
enumerationSet
Denmark


F.19 Host member states #8
enumerationSet
Estonia


F.19 Host member states #9
enumerationSet
Finland


F.19 Host member states #10
enumerationSet
France


F.19 Host member states #11
enumerationSet
Germany


F.19 Host member states #12
enumerationSet
Greece


F.19 Host member states #13
enumerationSet
Hungary


F.19 Host member states #14
enumerationSet
Iceland


F.19 Host member states #15
enumerationSet
Ireland


F.19 Host member states #16
enumerationSet
Italy


F.19 Host member states #17
enumerationSet
Latvia


F.19 Host member states #18
enumerationSet
Liechtenstein


F.19 Host member states #19
enumerationSet
Lithuania


F.19 Host member states #20
enumerationSet
Luxembourg


F.19 Host member states #21
enumerationSet
Malta


F.19 Host member states #22
enumerationSet
Netherlands


F.19 Host member states #23
enumerationSet
Norway


F.19 Host member states #24
enumerationSet
Poland


F.19 Host member states #25
enumerationSet
Portugal


F.19 Host member states #26
enumerationSet
Romania


F.19 Host member states #27
enumerationSet
Slovakia


F.19 Host member states #28
enumerationSet
Slovenia


F.19 Host member states #29
enumerationSet
Spain


F.19 Host member states #30
enumerationSet
Sweden


Part G - Information on rights and obligations attached to other tokens



G.1 Purchaser rights and obligations
textBlock The Tokens do not carry any legally enforceable rights or entitlements against the issuer. Instead, Tokens enable their holders to interact with the Protocol. The Protocol operates autonomously without the Person Seeking Admission to Trading having an operative role of any sort.
The Person Seeking Admission to Trading, to the fullest extent permitted by applicable laws, disclaims all warranties, whether express or implied, in relation to the Token and its functionality, as well as the Protocol. This includes,but is not limited to, implied warranties of merchantability and fitness for a particular purpose.


G.2 Exercise of rights and obligations
textBlock Not applicable.

G.3 Conditions for modifications of rights and obligations
textBlock Not applicable.

G.4 Future public offers
textBlock Not applicable.

G.5 Issuer retained other token
integer


G.6 Utility token classification
boolean true

G.7 Key features of goods or services utility tokens
text The Token grants access to the functionalities presented under Section F.02.
The quantity and quality of the technical goods and services accessed through each functionality are determined respectively, by the circulating supply of the Token available for effective use and the overall state of the Protocol. As the Protocol evolves and engagement therewith too, both factors will be shaped by effective Protocol participants at any given time and overall Protocol development, making them currently unquantifiable.


G.8 Utility tokens redemption
text The technical goods and services accessible through the Token functionalities described under F.02. can be redeemed exclusively by using the Protocol and calling the appropriate functions thereof.
In case of Protocol issues, Tokens may not be usable and effectively become irredeemable.
No fiduciary redemption exists, a user cannot redeem Tokens with the Person Seeking Admission to Trading or any other entity, for money or other assets.


G.9 Non-trading request
boolean true

G.10 Other tokens purchase or sale modalities
text Not applicable.

G.11 Other tokens transfer restrictions
text Not applicable.

G.12 Supply adjustment protocols
boolean false

G.13 Supply adjustment mechanisms
text Not applicable.

Other token schemes details



G.14 Token value protection schemes
boolean false

G.15 Token value protection schemes description
textBlock Not applicable.

G.16 Compensation schemes
boolean false

G.17 Compensation schemes description
textBlock Not applicable.

G.18 Applicable law
textBlock Any dispute arising out of or in connection with the Token shall be governed exclusively by the laws of Switzerland, without regard to conflict of law rules or principles, except to the extent that such disputes are governed by applicable law pursuant to the terms and conditions of the respective Trading Platform on which the Token has been admitted for trading.

G.19 Competent court
textBlock Any dispute relating to the Token shall be exclusively resolved shall be resolved exclusively by arbitration.
The arbitral proceedings shall be conducted in accordance with the Swiss Rules of International Arbitration of the Swiss Arbitration Centre in force on the date on which the Notice of Arbitration is submitted in accordance with those Rules.
The number of arbitrators shall be three.
The seat of the arbitration shall be Zürich, Switzerland.
The arbitral proceedings shall be conducted in English.
A respective arbitral award may only be challenged before the Swiss Supreme Court on the limited grounds as provided in Article 190 para. 2 Swiss Private International Law Act, i.e. (i) improper constitution of the arbitral tribunal; (ii) incorrect decision on jurisdiction; (iii) award beyond the claims submitted or failing to decide all claims submitted; (iv) violation of a party's right to be heard or of its right to equal treatment; and (v) incompatibility of the award with public policy.


Part H – Information on underlying technology



H.1 Distributed ledger technology (DTL)
text The SODAX Protocol primarily operates its main hub on the Sonic blockchain network, which is also the network on which the SODA Token is deployed. However, SODAX is designed as foundational infrastructure for a broader multi-chain ecosystem, unifying liquidity and enabling cross-chain interactions. Accordingly, the Protocol also operates across 12 additional blockchain networks, including Arbitrum, Avalanche, Base, BNB, Hyperliquid, ICON, Lightlink, Optimism, Polygon, Solana, Stellar, and Sui. The SODAX Protocol is designed to support future expansion, with additional blockchain integrations planned over time.
General Information on Distributed Ledger Technology and Blockchain
Distributed Ledger Technology ("DLT") describes a decentralized and distributed Network system architecture where multiple participants maintain and verify a shared database. Unlike traditional databases, DLT systems do not rely on a central authority to ensure data consistency and security.
Rather, they distribute control across a Network of computers (nodes) and require all changes to be recorded and agreed by the nodes. This distributed approach enhances the resilience and security of such a system, and transparency of the data stored in it without the need for trust between the actors of the systems.
Blockchain technology is a subset of DLT, where the distributed database maintains a continuously growing list of records, called blocks, which are linked together in chronological order and secured using cryptographic techniques. A blockchain generally has the following key characteristics:
-     Security: A blockchain employs advanced cryptographic methods to secure data. Each block contains a cryptographic hash (a "digital fingerprint") of the previous block, a timestamp, and transaction data.
-     Consensus: Blockchains rely on a predefined consensus mechanism establishing how new blocks, and the transactions included therein, are approved by nodes.
-     Immutability: once data is recorded in a block, it cannot be deleted nor altered retroactively without also changing all subsequent blocks, which would require consensus from most of the nodes.
-     Transparency: Transactions on a blockchain are usually visible to all, thereby providing transparency. Private blockchains, without or with limited transparency, however, do also exist.
-     Accessibility: Blockchains are usually permissionless, thus accessible to all, whether to act as a node or to submit transactions to be recorded thereon. Permissioned blockchains, with limited accessibility for nodes and/or users, however, do also exist.


H.2 Protocols and technical standards
text SODA is an ERC-20-compatible fungible token deployed on the Sonic Blockchain Network. Key components of the SODAX Protocol adhere to open and widely adopted technical standards, including:
Smart contract architecture - Written in Solidity
Cross-chain interoperability - Enabled through standardized messaging protocols that connect EVM and non-EVM chains.
Solver SDK - Implements standardized APIs and message formats to facilitate integration by external DeFi applications and partners.
Data and analytics access - Public blockchain data conforms to open JSON-RPC and REST API conventions for transparency and developer access.
More information can be found:
SODAX Docs - https://docs.sodax.com/
SODAX Github - https://github.com/icon-project/sodax-document


H.3 Technology used
textBlock Transfer: The token issuance smart contracts, as based on the ERC-20 standard, define the technical rules governing the transfer of Tokens. No additional technology is required to proceed with the transfer of Tokens on the Network.
Holding and Storing: No additional technology is required to hold Tokens, as they remain on the Network in accordance with its standard operation; however, users may choose to utilize additional technologies such as specific wallets, incl. multi-signature wallets, cold storage solutions, or other storage and security products and services.


H.4 Consensus mechanism
text The Network utilizes the Lachesis consensus mechanism, a leaderless, asynchronous Byzantine Fault Tolerant (aBFT) protocol built on a Proof-of-Stake (PoS) foundation and leveraging a Directed Acyclic Graph (DAG) structure.
Under this mechanism, participating validators independently create and exchange event data, which are subsequently ordered and finalized through a decentralized consensus process without reliance on a central coordinator or fixed timing assumptions. The use of a DAG structure enables parallel processing of transactions and supports resilience to network latency and validator faults, provided that the proportion of faulty or malicious stake remains below established aBFT thresholds. The PoS model requires validators to stake Tokens to participate in consensus, aligning economic incentives with network integrity and operational security.
This hybrid consensus design is meant to address the blockchain trilemma by optimizing speed, security, and decentralization, without relying on energy-intensive Proof-of-Work (PoW) mechanisms.


H.5 Incentive mechanisms and applicable fees
text Sonic includes a Proof-of-Stake (PoS) model as part of its Lachesis consensus mechanism (see above, Section H.4). Network validators are required to stake Tokens to participate in transaction validation and consensus. In return for performing validation services and contributing to network security and availability, validators may receive protocol-level rewards and transaction fees, which may be shared with delegators who stake Tokens with them. The allocation of rewards, including any parameters applicable to staking, delegation, or validator participation, is determined by the Network's rules and decentralized governance and may evolve over time. No guarantee is made as to the level, continuity, or availability of any such incentives.

Transactions executed on the Sonic network are subject to network fees, which are paid by users to compensate validators for processing and validating transactions and to prevent network congestion or abuse. Fees are generally calculated based on computational and network resource usage and may vary depending on transaction complexity and prevailing network conditions. The fee structure, including any mechanisms for fee adjustment, redistribution, or burning, is defined at the protocol level and may be modified through decentralized governance. The Person Seeking Admission to Trading does not control the level or application of such fees.


H.6 Use of distributed ledger technology
boolean false

H.7 DLT functionality description
textBlock Not applicable.

Other token audit details



H.8 Audit
boolean true

H.9 Audit outcome
textBlock Periodic third-party security audits were and continue being conducted by various firms.
In November 2025, Sherlock (https://sherlock.xyz/) completed security audits for the relay architecture forms a key component of the SODAX infrastructure, enabling secure and scalable coordination of cross-chain transaction validation, signing, and execution.
In September 2025, Hashlock (https://hashlock.com/) completed security audits for all core Solana Network contracts on the SODAX Protocol, including Relay Connection Contracts – for managing cross-chain messaging and execution, Asset Manager Contracts – for handling assets and execution flows, and Rate Limiter Contracts – for enforcing transaction and withdrawal limits.
In August 2025, Hashlock (https://hashlock.com/) completed security audits for all core Sui Network contracts on the SODAX Protocol, including Relay Connection Contracts – for managing cross-chain messaging and execution, Asset Manager Contracts – for handling assets and execution flows, and Rate Limiter Contracts – for enforcing transaction and withdrawal limits.
In August 2025, Hashlock (https://hashlock.com/) completed security audits for all core Stellar Network (Soroban) contracts on the SODAX Protocol, including Relay Connection Contracts – for managing cross-chain messaging and execution, Asset Manager Contracts – for handling assets and execution flows, and Rate Limiter Contracts – for enforcing transaction and withdrawal limits.
In July 2025, Sherlock (https://sherlock.xyz/) completed security audits for all core EVM contracts used by the SODAX protocol, including Relay Connection Contracts – for managing cross-chain messaging and execution, Wallet Abstraction Contracts – for unified wallet interaction across chains, Asset Manager Contracts – for handling assets and execution flows, Rate Limiter Contracts – for enforcing transaction and withdrawal limits, and Spoke Asset Management Contracts – for asset handling on connected chains.


Part I - Information on risks



I.1 Offer-related risks
textBlock For the Admission to Trading

No Listing Risk: The present white paper is drafted and notified by the Person Seeking Ad-mission to Trading in accordance with its obligations under Article 5 of MiCAR, in its capacity as a person seeking the admission of the Token to trading. As of the date of notification, the Person Seeking Admission to Trading has not entered into any listing agreement with any new Trading Platforms. The Person Seeking Admission to Trading its affiliates, directors, and officers shall not be held liable for any damages, losses, costs, fines, penalties, or expenses of any kind - whether or not reasonably foreseeable by the Person Seeking Admission to Trading or the Token holder - that the Token holder may suffer, sustain, or incur in connection with, or as a result of, the Token not being listed on a Trading Platform based on this White Paper.

General Contractual and Counterparty Risk: The Person Seeking Admission to Trading neither operates nor controls, oversees, or manages the functioning of crypto-asset services providers as defined under MiCAR ("CASP") operating within the EU /EEA and Trading Platforms where the Token will be admitted for trading or listed.

When Token holders buy or sell the Token on Trading Platforms, the Person Seeking Admis-sion to Trading is not a contractual party to these transactions. As a result,

(i) any legal relationship between Token holders and the Trading Platform is governed solely by the terms and conditions set by each Trading Platform at its discretion.
(ii) the Person Seeking Admission to Trading assumes no responsibility or liability for the operations, services, security, performance, or any outcomes (whether financial or technical) arising from transactions conducted on these Trading Platforms.
(iii) The Person Seeking Admission to Trading provides no assurances regarding any Trading Platform itself and assumes no responsibility or liability for any regulatory, compliance, operational, financial, technical, or reputational failures that may adversely affect its activities. This includes, but is not limited to, circumstances where such failures result in disruptions, restrictions on trading, or the Trading Platform halting or ceasing its operations entirely, due to sanctions, bankruptcy or alike. The foregoing may result in substantial or even total losses for the Token holder.

Multiple White Paper Risk: Token holders understand that any third party can decide to draft and publish a MiCA white paper about the Token ("Spontaneous White Paper"). The publication of these Spontaneous White Papers does not imply any endorsement by the issuer and/or Person Seeking Admission to Trading that the Spontaneous White Papers are complete, correct, fair, clear and not misleading.

Spontaneous Admission to Trading Risk by Trading Platform: Third parties can elect to admit the Token on their Trading Platforms without any request, authorization or approval by the Company or anyone else. Pursuant to article 5 (2) of MiCA, Trading Platforms are responsible for ensuring compliance with all applicable laws, especially MiCA requirements with respect to the spontaneous admission of the Token to trading. The Company, its affiliates, directors, agents and officers shall not be held liable for these spontaneous admissions to trading.

Pausing and Delisting Risk: The Person Seeking Admission to Trading cannot guarantee that the Token will remain listed or tradeable on any Trading Platforms. Delisting (or the temporary pausing of such listing) could significantly hinder the ability of Token holders to buy, sell, or otherwise transact in Tokens. In the event of delisting, Token holders may face chal-lenges in finding alternative markets or counterparties willing to trade Tokens, which could ad-versely impact the Token's liquidity and market value. Delisting could also negatively impact the price of the Token, due to modified demand for the Token and/or reputational impact.

Trading Risk: The Person Seeking Admission to Trading does not control the secondary markets. There can be no assurance as to the secondary market (if any) in the Tokens, and specifically:

(i) it cannot guarantee the depth, stability, or sustainability of any secondary market for Tokens. Limited market depth or trading activity may result in reduced liquidity, in-creased price volatility, and challenges in buying or selling Tokens at desired prices; and
(ii) it cannot guarantee the healthy and consistent availability of buying or selling opportu-nities for Tokens or the integrity of their market price. Trading activity may be affected by manipulative practices such as wash trading, front-running, and similar schemes.

WhileTrading Platforms are subject to varying regulatory frameworks that may or may not prohibit such practices and impose oversight to detect and deter them, the Person Seeking Admission to Trading assumes no responsibility or liability for their effective prevention or enforcement.

Operational and Technical Risk: Trading Platforms operate interfaces that allow users to trade crypto-assets for fiat currencies, such as U.S. Dollars and Euros, or other crypto-assets. The reliance on the Trading Platform's internal system for asset storage and transfer adds an additional layer of counterparty risk, as users are exposed to potential operational, technical, or human errors during these processes. As a result, the Person Seeking Admission to Trading assumes no responsibility or liability for any losses arising from these risks.

Trades on these Trading Platforms are executed based on a centralized matching algorithm and are often recorded off-chain, meaning they are not directly related to trans-parent on-chain transfers of crypto-assets, and could dissimulate detrimental trade matching or rogue practices. The traded assets are recorded solely on the Trading Platform's internal ledger, with each internal ledger entry corresponding to an offsetting trade in-volving either government currency or another crypto asset.

Additionally, funds deposited by users for trading may be comingled by the Trading Platforms, rather than stored in unique wallet addresses for each user. This practice results in the centralization of a large volume of assets in a single location, which in turn increases the potential risk of damage or theft, particularly in the event of a hack or security breach.

Furthermore, users who wish to trade or withdraw their Tokens must deposit them into the Trading Platform, increasing the risk of loss in the event of a failure of the deposit or with-drawal processes set up by the Trading Platform.

Unanticipated Risks: In addition to the risks outlined in this Section, unforeseen risks may arise. Addi-tionally, new risks could emerge as unexpected variations or combinations of the risks discussed in these Sections I.1 to I.5.     


I.2 Issuer-related risks
textBlock Abandonment / Lack of Success Risk: This is the risk that the activities of the Issuer must be partially or totally abandoned for several reasons including, but not limited to, lack of interest from the public, lack of funding, incapacitation of key developers and project members, force majeure (including pandemics and wars) or lack of commercial success or prospects.

Legal and Regulatory Compliance Risk: Crypto assets and blockchain-based technologies are subject to evolving regulatory landscapes worldwide. Regulations vary across jurisdictions and may be subject to significant changes. This could lead to changes with respect to trading of the Token and increase the Issuer's costs and/or obligations in admitting the Token for trading. Changes in laws or regulations may negatively impact the value, legality, or functionality of the Token. Non-compliance can result in investigations, enforcement actions, penal-ties, fines, sanctions, or the prohibition of the trading of the Token impacting its viability and market acceptance. The Issuer could also be subject to private litigation.

Reputational Risk: The Issuer faces the risk of negative publicity, whether due, without limi-tation, to operational failures, security breaches, or illicit activities, all of which can damage the Issuer's reputation and, by extension, the value and acceptance of the Token.

Key Individuals Risk: The success of a crypto projects can be highly dependent on the expertise and leadership of key individuals. Loss or changes in the Issuer's leadership could lead to disruptions, loss of trust, or project failure.

Internal Control Risk: Any failure by the Issuer to develop or maintain effective internal con-trols or any difficulties encountered in the implementation of such controls, or their improve-ment could harm it, causing the issuer to have to report such failures. Such failures could lead to a loss of trust and further harm the business of the Issuer, causing disruptions, finan-cial losses, or reputational damage affecting the Token. Fraudulent activity or mismanage-ment by the Issuer could directly impact the usability or value of the Token or damage the credibility of the Platform, Network and the Project at broad.

Unanticipated Risks: In addition to the risks outlined in this Section, unforeseen risks may arise. Additionally, new risks could emerge as unexpected variations or combinations of the risks discussed in these Sections I.1 to I.5.     


I.3 Other tokens-related risks
textBlock Token Admission to Trading "As Is" Risk: The Tokens are admitted to trading on an "as is" and "as available" basis without warranties of any kind, and the Person Seeking Admission to Trading and Issuer expressly disclaim all implied warranties that the Token, the software code of the programs, are free of viruses or other harmful components which may affect the To-kens.

Market Risk: Crypto assets, including Tokens, are highly volatile and can experience significant price swings in short periods, increasing the risk of sudden and substantial losses. Such valuation risk arises as the market value of a crypto asset may not always reflect its underly-ing utility or fundamentals and is subject to subjective assessment. Token holders are thus exposed to potential for losses due to the Token's potential fluctuations in value, driven by various factors such as supply and demand dynamics, investor sentiment, and broader market trends, incl. changes in interest rates, general movements in local and international markets, technological advance-ments, regulatory changes, and media coverage. Notably, momentum pricing of crypto assets has previously resulted, and may continue to result, in speculation regarding future appreciation or depreciation in the value of such assets, further contributing to volatility and potentially inflating prices at any given time. Additionally:

(i) Liquidity risk, where a lack of depth in secondary markets – if any – or limited trading volumes can hinder the ability to execute trades at favorable prices, which could lead to significant losses, especially in fast-moving market conditions. As a result, holders of Tokens may experience challenges in managing their holdings, with the value of the asset subject to unpredictable fluctuations and potential depreciation.
(ii) Solvency and collateral risk, if the Token is used to finance further activities, especially in leveraged positions or as collateral for loans. Significant fluctuations in the value of the Token could adversely affect the solvency of its holder, particularly if the Token is pledged as collateral. A drastic decline in its value may trigger margin calls or automatic liquidations, which could further depress the Token's price, creating a negative feed-back loop. This volatility poses the risk of forced asset sales, potentially resulting in substantial losses for the holder and amplifying downward pressure on the market price of Tokens.

Custodial Risk: The method chosen to store Tokens, like any crypto-asset, carries inherent risks related to the security and management of the storage solution. The chosen storage method (whether hot or cold wallets, or centralized custody) can significantly impact the safety, liquidity, and accessibility of Tokens, with direct consequences for the holder's ability to access, trade, or retain their assets.

Scam Risk. This is the risk of loss resulting from a scam or fraud suffered by Token holders from other malicious actors. These scams include, but are not limited to, phishing on social networks or by email, fake giveaways, identity theft, creation of fake Tokens, offering fake To-ken airdrops, among others.

Anti-Money Laundering/Counter-Terrorism Financing Risk: This is the risk that crypto-asset wallets holding Token or transactions in Token may be used for money laundering or terrorist financing purposes or identified to a person known to have committed such offenses. There is thus a risk that a public address holding Tokens could be flagged in relation to Anti-Money Laundering or Counter-Terrorism Financing efforts. In such cases, receiving Tokens could result in the holder's address being flagged by relevant authorities, Trading Platforms, or other service providers, which may lead to restrictions on transactions or the freezing of assets. Consequently, holders of Tokens may face legal or regulatory challenges if their ad-dress becomes associated with illicit activities, impacting their ability to freely access, trade, or transfer their Tokens.

Taxation Risk: The taxation regime that applies to the trading of Tokens by either individual holders or legal entities will depend on each Token holder's jurisdiction. The Person Seeking Admission to Trading cannot guarantee that the holding of Tokens, the reception of the Token, conversions of fiat currency against Tokens, or conversions of other crypto assets against Tokens, will not incur tax consequences. It is the Token holder's sole responsibility to comply with all applicable tax laws, including, but not limited to, the reporting and payment of income tax, wealth tax or similar taxes arising in connection with the appreciation and depreciation of the Token.

Market Abuse Risk: The market for crypto assets is rapidly evolving, spanning local, nation-al, and international networks with an expanding range of assets and participants. Any market abuse, along with a potential loss of confidence among holders, could adversely impact the value and stability of Tokens, and by extension the trading conditions on the Trading Platforms. Notably,

(i) significant trading activity may take place on systems and networks with limited over-sight and predictability. Sudden and rapid changes in the supply or demand of a crypto asset, particularly those with low market capitalization or low unit prices, can result in extreme price volatility.
(ii) the inherent characteristics of crypto assets and their underlying infrastructure may be exploited by certain market participants to engage in abusive trading practices such as front-running, spoofing, pump-and-dump schemes, and fraud across different net-works, systems, or jurisdictions.

Legal and Regulatory Risk: There is a lack of regulatory harmonization and cohesion global-ly, which results in diverging regulatory frameworks and possible further regulatory evolutions in the future. These could negatively impact the value, utility, and overall viability of Tokens and, in extreme cases, force the Person Seeking Admission to Trading to cease operations. Notably, while Tokens do not create or confer any contractual or other obligations against any party, certain non-EU regulators may nevertheless classify them as securities, financial instruments, or payment instruments under their respective legal frameworks. Such classifications could impose specific regulatory constraints, leading to significant changes in how Tokens are structured, issued, purchased, or traded. Evolving regulations could substantially increase the Person Seeking Admission to Trading's compliance costs and operational burdens related to facilitating transactions in Tokens. New or restrictive regulations could result in the Token losing functionality, depreciating in value, or even becoming illegal or impossible to use, buy, or sell in certain jurisdictions. Regulators could take enforcement action against the Person Seeking Admission to Trading if they determine that the Token constitutes a regulated instrument or that the Person Seeking Admission to Trading's activities violate existing laws. Such actions could expose the Person Seeking Admission to Trading, its affiliates, directors, and of-ficers to legal and financial penalties, including civil and criminal liability.

Unanticipated Risks: In addition to the risks outlined in this Section, unforeseen risks may arise. Additionally, new risks could emerge as unexpected variations or combinations of the risks discussed in these Sections I.1 to I.5.


I.4 Project implementation-related risks
textBlock Protocol "As Is" Risk: The Protocol and any future components were deployed on an "as is" and "as available" basis without warranties of any kind, and the Person Seeking Admission to Trading expressly disclaims all implied warranties as to the Protocol including, without limitation, implied warranties of merchantability, fitness for a particular purpose, title and non- infringement. Therefore, the Person Seeking Admission to Trading cannot and does not warrant that the Token, the programs, or the technology underlying the Tokens, Protocol and Network (jointly, "SODAX Technology") are reliable, current or error-free, free of viruses or other harmful components, meet the Token's requirements, or that defects in the SODAX Technology will be corrected. Additionally, there is a risk that Protocol functionalities may be abandoned, that no new functionalities may be added.

Decentralized Governance and Network Change Risk: The Protocol is subject to decentralized, on-chain decision-making (so-called DAO governance). Token holders are invited to participate in proposal discussions and votes concerning matters relating to the Protocol development (see Governance Staking Functionality, as described under Sections 08 and F.02). This could result in material changes to the Protocol's goals, priorities, or operating methods. While such evolution can promote innovation and strengthen adaptability, it also presents cer-tain risks, such as alterations in the value proposition and possible divergence from stake-holders' previous expectations.

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

Industry and Competition Risk: The Protocol is and will be subject to all the risks and uncertainties associated with any new venture, visionary projects, including the risk that the project cannot be realized in line with its original purpose or vision about the Protocol. Other projects may have the same or a similar vision. There are several other crypto-assets and projects, and new competitors may enter the market at any time. The effect of new or additional competition on the Token or its market price cannot be predicted or quantified. Competitors may have significantly greater financial and legal resources than the project and there is no guarantee that the Protocol will be able to compete successfully, or at all, with such competitors. Moreover, increased competition may severely impact the profitability and creditworthiness of the project and involved entities.
Dependency/Withdrawing Partners Risk: The SODAX Technology itself relies on third-party technologies, infrastructures, and protocols, which could impact its functionality, security, and long-term sustainability. Loss or changes in the key partners providing such technologies can lead to disruptions, loss of trust, or project failure. Any disruptions, vulnerabilities, regulatory scrutiny, or changes in operation of third-party technologies (such as modifications to its mechanisms, governance, or economic incentives) could directly affect the usability and security of the SODAX Technology, which may result in a negative effect for the Tokens. If the third-party technologies experience technical failures, security breaches, or regulatory intervention, it could severely impact the stability and performance of the SODAX Technology, potentially limiting its intended functionality and value. This reliance on external infrastructure in-creases systemic risk, as unforeseen issues in third-party protocols could cascade into dis-ruptions within the Token ecosystem.

Withdrawing Partners Risk: This is the risk that the Person Seeking Admission to Trading faces in its business relationships with one or more third parties. The implementation of the project depends strongly on the collaboration and functioning of services provided by several third parties and other crucial partners. The Person Seeking Admission to Trading cannot guarantee that the project and related SODAX Technology will be successfully developed further.

Unanticipated Risks: In addition to the risks outlined in this Section, unforeseen risks may arise. Additionally, new risks could emerge as unexpected variations or combinations of the risks discussed in these Sections I.1 to I.5     


I.5 Technology-related risks
textBlock The Person Seeking Admission to Trading and its affiliate, directors and officers shall not be responsible or liable for any damages, losses, costs, fines, penalties or expenses of whatever nature, whether reasonably foreseeable by them and the Token holder, and which the Token holder, may suffer, sustain, or incur, arising out of or relating to the technical risks outlined below or a combination thereof.

General Cybercrime Risk: The Token holder acknowledges that, despite best efforts to en-hance security, the technological components supporting the Token - including its blockchain infrastructure, smart contracts, wallets - may be vulnerable to cyberattacks. Malicious actors may exploit software vulnerabilities, attack consensus mechanisms, or compromise private keys to gain unauthorized access to Tokens. Risks include hacking attempts on the Protocol, smart contract exploits, phishing attacks, malware infections, and other forms of cybercrime that could result in the theft, loss, or unauthorized transfer of Tokens. Since digital assets exist entirely in a technological environment, they are inherently exposed to evolving cyber threats, some of which may be undetectable or irreparable until after significant damage has occurred.

Blockchain-Level Risk: The Token holder understands and accepts that, as with other blockchains, the blockchain used for the issuance of the Tokens (i.e the Network) could be susceptible to con-sensus-related attacks, including but not limited to double-spend attacks, majority validation power attacks, censorship attacks, and byzantine behavior in the consensus algorithm or be subject to forks. Any successful attack or fork presents a risk to the Token, the expected proper execution and sequencing of Token-transactions and the expected proper execution and sequencing of contract computations as well as the Token balances in the wallet of the Token holders.

Smart Contract-Level Risk: The issuance and transfers of Tokens rely on smart contracts deployed on a blockchain network, which introduce specific technical and security risks.
Smart contracts are self-executing, meaning any vulnerabilities, coding errors, or unforeseen logic flaws in the issuance contract could result in unintended consequences, such as the incorrect distribution of Tokens, loss of funds, or permanent locking of To-kens. Additionally, smart contracts are exposed to potential exploits, including hacking attempts, reentrancy attacks, and other forms of malicious activity that could compro-mise the security of the issuance process.

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

Protocol-Level Risk: It cannot be excluded that any technical failure, malfunction, or vulner-ability within the Protocol could directly or indirectly impact the value of the Token.
The Protocol could be subject to critical exploits, such as reentrancy attacks, logic errors, or oracle manipulation, which could lead to unintended Token transfers, assets being drained from the system, or Tokens being irretrievably lost. Fixing such issues may require significant coordination, governance approval, or even disruptive measures such as protocol migrations or forks, none of which are guaranteed to be successful.

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

Finality or Irrevocability of Transactions: There is a risk that transactions may be irre-versible, depending on the tools and service providers used to initiate them. Access to and any claim on such transactions could be lost indefinitely or permanently. For example, this could occur if (i) a blockchain address is entered incorrectly and the true owner is never iden-tified, (ii) the private key associated with the address is lost, (iii) the address belongs to an entity that will not return the crypto asset, or (iv) the address belongs to an entity that may return the asset but requires additional actions, such as identity verification.

Unanticipated Risks: In addition to the risks outlined in this Section, unforeseen risks may arise. Additionally, new risks could emerge as unexpected variations or combinations of the risks discussed in these Sections I.1 to I.5.     


I.6 Mitigation measures
textBlock Various measures to mitigate the risks outlined in Sections I.01 to I.05 above have been implemented. These include rigorous technology testing and auditing, and the careful selection of personnel, man-agement, and third-party partners. However, many of these risks are inherent to the activities with crypto assets and the broader ecosystem, making complete elimination impossible.

To further reduce exposure to these risks, prospective Token holders should adopt appropriate safeguards based on their chosen custody method and remain vigilant by actively monitoring publicly available news and market signals, enabling them to respond swiftly to significant developments which may result in the materialization of specific risks.


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



J.1 Adverse impacts on climate and other environment-related adverse impacts
textBlock The Person Seeking Admission to Trading is providing information on principal adverse impacts of Token on the climate and other environment-related adverse impacts of the consensus mechanism of the following: based on an annual forecast of over 1 million transactions and acknowledging that these estimates are forward-looking and may prove inaccurate, the total yearly energy consumption of the Token on the Network, is estimated to be less than 500,000 kWh. In any scenario, it is not expected to exceed this threshold

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



General information about adverse impacts



S.1 Name
text ICON Foundation

S.2 Relevant legal entity identifier
text CHE-198.483.059

S.3 Name of the crypto-asset
text SODA Token

S.4 Consensus mechanism
text See as further described under Section H.4.

S.5 Incentive mechanisms and applicable fees
text See description provided under Section H.5.

S.6 Beginning of period to which disclosed information relates
date 2026-03-13

S.7 End of period to which disclosed information relates
date 2026-12-31

Mandatory key indicator



S.8 Energy consumption
energy (kWh)  <500'000kWh per year

Sources and methodologies



S.9 Energy consumption sources and methodologies
textBlock The estimated energy consumption of < 500'000 kWh per year has been calculated using a set of assumptions and thus represent estimates.
The estimates did not account for any offsetting of energy consumption or other market-based mechanism as of the date of this estimation.
Sources and Methodology: Estimates follow the Crypto Carbon Ratings Institute (CCRI) and Cambridge DLT Sustainability Framework, applying standard parameters for node-level power × count × uptime.


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



Supplementary key indicators



S.10 Renewable energy consumption
percent


S.11 Energy intensity
energy (kWh)


S.12 Scope 1 DLT GHG emissions - controlled
GHG emissions (tCO2e)


S.13 Scope 2 DLT GHG emissions - purchased
GHG emissions (tCO2e)


S.14 GHG intensity
GHG emissions (tCO2e)


Sources and methodologies



S.15 Key energy sources and methodologies
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S.16 Key GHG sources and methodologies
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Optional information on principal adverse impacts on the climate and on other environment-related adverse impacts of the consensus mechanism



Optional indicators



S. 17 Energy mix
percent


S.18 Energy use reduction



Energy use reduction target (absolute value)
energy (kWh)


Energy use reduction target (percentage)
percent


S.19 Carbon intensity (kgCO2e/kWh)
decimal


S.20 Scope 3 DLT GHG emissions - value chain
GHG emissions (tCO2e)


S.21 GHG emissions reduction targets or commitments
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S.22 Generation of waste electrical and electronic equipment (WEEE)
mass (tonnes)


S.23 Non-recycled WEEE ratio
percent


S.24 Generation of hazardous waste
mass (tonnes)


S.25 Generation of waste (all types)
mass (tonnes)


S.26 Non-recycled waste ratio (all types)
percent


S.27 Waste intensity (all types)
mass (tonnes)


S.28 Waste reduction targets or commitments (all types)
textBlock


S.29 Impact of use of equipment on natural resources
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S.30 Natural resources use reduction targets or commitments
textBlock


S.31 Water use
volume (m3)


S.32 Non recycled water ratio
percent


Sources and methodologies



S.33 Other energy sources and methodologies
textBlock


S.34 Other GHG sources and methodologies
textBlock


S.35 Waste sources and methodologies
textBlock


S.36 Natural resources sources and methodologies
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