(7.2)MiCA Whitepaper
(7.2)MiCA Whitepaper
Last updated: 20th February 2026
This crypto-asset white paper complies with Regulation (EU) 2023/1114 (MiCA).
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(7.2.1)Table of Contents
(7.2.1)Table of Contents
| Field | Field Name | Content to be Reported |
|---|---|---|
| 00 | Table of contents | 00 Table of contents |
| 01 Date of notification | ||
| 02 Statement in accordance with Article 6(3) of Regulation (EU) 2023/1114 | ||
| 03 Compliance statement in accordance with Article 6(6) of Regulation (EU) 2023/1114 | ||
| 04 Statement in accordance with Article 6(5), points (a), (b), (c), of Regulation (EU) 2023/1114 | ||
| 05 Statement in accordance with Article 6(5), point (d), of Regulation (EU) 2023/1114 | ||
| 06 Statement in accordance with Article 6(5), points (e) and (f), of Regulation (EU) 2023/1114 | ||
| SUMMARY | ||
| 07 Warning in accordance with Article 6(7), second subparagraph, of Regulation (EU) 2023/1114 | ||
| 08 Characteristics of the crypto-asset | ||
| 09 Information about the quality and quantity of goods or services to which the utility tokens give access and restrictions on the transferability | ||
| 10 Key information about the offer to the public or admission to trading | ||
| Part A - Information about the offeror or the person seeking admission to trading | ||
| Part B - Information about the issuer, if different from the offeror or person seeking admission to trading | ||
| Part C - Information about the operator of the trading platform in cases where it draws up the crypto-asset white paper and information about other persons drawing the crypto-asset white paper pursuant to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114 | ||
| Part D - Information about the crypto-asset project | ||
| Part E - Information about the offer to the public of crypto-assets or their admission to trading | ||
| Part F - Information about the crypto-assets | ||
| Part G - Information on the rights and obligations attached to the crypto-assets | ||
| Part H - Information on the underlying technology | ||
| Part I - Information on risks | ||
| Part J - Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts |
| Field | Field Name | Content to be Reported |
|---|---|---|
| 01 | Date of notification | 2025-07-31 |
| 02 | Statement in accordance with Article 6(3) of Regulation (EU) 2023/1114 | This crypto-asset white paper has not been approved by any competent authority in any Member State of the European Union. The offeror of the crypto-asset is solely responsible for the content of this crypto-asset white paper. |
| 03 | Compliance statement in accordance with Article 6(6) of Regulation (EU) 2023/1114 | This crypto-asset white paper complies with Title II of Regulation (EU) 2023/1114 of the European Parliament and of the Council and, to the best of the knowledge of the management body, the information presented in the crypto-asset white paper is fair, clear and not misleading and the crypto-asset white paper makes no omission likely to affect its import. |
| 04 | Statement in accordance with Article 6(5), points (a), (b), (c), of Regulation (EU) 2023/1114 | The crypto-asset referred to in this crypto-asset white paper may lose its value in part or in full, may not always be transferable and may not be liquid. |
| 05 | Statement in accordance with Article 6(5), point (d), of Regulation (EU) 2023/1114 | The utility token referred to in this white paper may not be exchangeable against the good or service promised in this white paper, especially in the case of a failure or discontinuation of the crypto-asset project. |
| 06 | Statement in accordance with Article 6(5), points (e) and (f), of Regulation (EU) 2023/1114 | The crypto-asset referred to in this white paper is not covered by the investor compensation schemes under Directive 97/9/EC of the European Parliament and of the Council or the deposit guarantee schemes under Directive 2014/49/EU of the European Parliament and of the Council. |
| 07 | Warning in accordance with Article 6(7), second subparagraph, of Regulation (EU) 2023/1114 | Warning - This summary should be read as an introduction to the crypto-asset white paper. The prospective holder should base any decision to purchase this crypto-asset on the content of the crypto-asset white paper as a whole and not on the summary alone. The offer to the public of this crypto-asset does not constitute an offer or solicitation to purchase financial instruments and any such offer or solicitation can be made only by means of a prospectus or other offer documents pursuant to the applicable national law. This crypto-asset white paper does not constitute a prospectus as referred to in Regulation (EU) 2017/1129 of the European Parliament and of the Council or any other offer document pursuant to Union or national law. |
| 08 | Characteristics of the crypto-asset | ALKIMI is a utility token that enables participation in Alkimi's decentralised advertising exchange ecosystem. The token operates on the Sui blockchain and serves as the primary mechanism for accessing Alkimi's complete suite of services related to the buying and selling of digital ads online, in app and on connected TVs. The services include: Buying Display Advertising, Buying Video Advertising, Buying Connected TV Advertising, Selling Display Advertising, Selling Video Advertising, Selling Connected TV Advertising, Accessing liquidity to purchase advertising, Accessing liquidity for the accrued revenue from selling advertising. |
| 09 | Information about the quality and quantity of goods or services to which the utility tokens give access and restrictions on the transferability | The quantity of goods is proportional to the number of tokens held. The proportion varies by product. The types of products are all digital in nature. Holders get access to the various Alkimi platforms and can use the suite of products and services available on the platforms. There are no restrictions on transfer at an Alkimi or Sui level. |
| 10 | Key information about the offer to the public or admission to trading | XSM Limited (BVI) seeks admission of the ALKIMI token on trading platforms operating within the European Union ("EU") or the European Economic Area ("EEA") ("Trading Platforms"). In seeking admission to trading, the Company complies with its obligations under article 5 of Regulation (EU) 2023/1114 ("MiCA"). With regard to the listing on Bitpanda: Bitpanda GmbH acts as placement provider on behalf of the Offeror and does not provide any underwriting commitment. |
Part A - Information about the offeror or the person seeking admission to trading
| Field | Field Name | Content to be Reported |
|---|---|---|
| A.1 | Name | XSM Limited (BVI) |
| A.2 | Legal form | Limited |
| A.3 | Registered address | Trinity Chambers, PO Box 4301, Road Town, Tortola, British Virgin Islands |
| A.4 | Head office | See A.3 |
| A.5 | Registration date | 2021-08-25 |
| A.6 | Legal entity identifier | N/A |
| A.7 | Another identifier required pursuant to applicable national law | 2073719 (BVI) |
| A.8 | Contact telephone number | +44 7980933229 |
| A.9 | E-mail address | hello@alkimi.org |
| A.10 | Response time (Days) | 5 business days |
| A.11 | Parent company | N/A |
| A.12 | Members of the management body | The three individuals named below are all directors of XSM Limited (BVI): Julian Chorley - Director, Andrew Scrymgeour - Director, Naresh Pai - Director. All at Trinity Chambers, PO Box 4301, Road Town, Tortola, British Virgin Islands. |
| A.13 | Business activity | XSM Limited (BVI) business activity involves serving as the issuer of the ALKIMI token to implement and decentralise the Alkimi Ad Exchange, an innovative decentralized ad exchange spearheading the adoption of web3 in the digital advertising sector. Subject to certain restrictions (namely to persons or entities located in jurisdictions subject to comprehensive sanctions, as well as those listed on sanctions lists maintained by the EU, UN, UK, or US), the Walrus Network is intended to operate globally. |
| A.14 | Parent company business activity | Alchemy VC Limited (located in the United Kingdom) operates as a strategic holding entity with a focus on the digital advertising and blockchain technology sectors. It holds and manages equity interests in subsidiaries that develop and operate innovative platforms at the intersection of digital marketing, data monetization, and decentralized technologies. One of its key subsidiaries acts as the issuer of a blockchain-based utility token, which serves as a core component within an ecosystem designed to enhance transparency, user engagement, and value exchange in digital advertising. The offeror provides strategic direction, financial oversight, and governance, while fostering innovation and long-term growth across its portfolio. |
| A.15 | Newly established | False |
| A.16 | Financial condition for the past three years | XSM Limited (BVI) generates revenue primarily through fees associated with token operations and ecosystem activities. The entity maintains a contractual arrangement with Alchemy Exchange Limited, the UK-based operating subsidiary, whereby management fees are charged for operational services and platform maintenance. This structure ensures XSM Limited (BVI) benefits from the underlying advertising exchange's proven business model while maintaining appropriate corporate separation. The company maintains a healthy balance sheet with adequate capital reserves to support ongoing token operations, strategic initiatives, and buyback activities. Financial management focuses on maintaining liquidity for operational requirements while supporting broader ecosystem development through the Sui migration and infrastructure expansion. |
| A.17 | Financial condition since registration | See A.16. |
Part B - Information about the issuer, if different from the offeror or person seeking admission to trading
| Field | Field Name | Content to be Reported |
|---|---|---|
| B.1 | Issuer different from offeror or person seeking admission to trading | False |
| B.2 | Name | Not applicable |
| B.3 | Legal form | Not applicable |
| B.4 | Registered address | Not applicable |
| B.5 | Head office | Not applicable |
| B.6 | Registration date | Not applicable |
| B.7 | Legal entity identifier | Not applicable |
| B.8 | Another identifier required pursuant to applicable national law | Not applicable |
| B.9 | Parent company | Not applicable |
| B.10 | Members of the management body | Not applicable |
| B.11 | Business activity | Not applicable |
| B.12 | Parent company business activity | Not applicable |
Part C - Information about the operator of the trading platform
| Field | Field Name | Content to be Reported |
|---|---|---|
| C.1 | Name | Not applicable |
| C.2 | Legal form | Not applicable |
| C.3 | Registered address | Not applicable |
| C.4 | Head office | Not applicable |
| C.5 | Registration date | Not applicable |
| C.6 | Legal entity identifier | Not applicable |
| C.7 | Another identifier required pursuant to applicable national law | Not applicable |
| C.8 | Parent company | Not applicable |
| C.9 | Reason for crypto-asset white paper Preparation | Not applicable |
| C.10 | Members of the management body | Not applicable |
| C.11 | Operator business activity | Not applicable |
| C.12 | Parent company business activity | Not applicable |
| C.13 | Other persons drawing up the crypto-asset white paper according to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114 | Not applicable |
| C.14 | Reason for drawing the white paper by persons referred to in Article 6(1), second subparagraph, of Regulation (EU) 2023/1114 | Not applicable |
Part D - Information about the crypto-asset project
| Field | Field Name | Content to be Reported |
|---|---|---|
| D.1 | Crypto-asset project name | Alkimi |
| D.2 | Crypto-assets name | ALKIMI |
| D.3 | Abbreviation | ALKIMI |
| D.4 | Crypto-asset project description | XSM Limited (BVI) offers a utility token that enables participation in Alkimi's decentralised advertising exchange ecosystem. The token operates on the Sui blockchain and serves as the primary mechanism for accessing Alkimi's complete suite of services related to the buying and selling of digital ads online, in app and on connected TVs. The services include: Buying Display Advertising, Buying Video Advertising, Buying Connected TV Advertising, Selling Display Advertising, Selling Video Advertising, Selling Connected TV Advertising, Accessing liquidity to purchase advertising, Accessing liquidity for the accrued revenue from selling advertising. |
| D.5 | Details of all natural or legal persons involved in the implementation of the crypto-asset project | XSM Limited (BVI) |
| D.6 | Utility Token Classification | True |
| D.7 | Key Features of Goods/Services for Utility Token Projects | By Holding the ALKIMI token, ALKIMI token holders gain access to Alkimi's Ad Exchange and Labs platform for interaction with the digital ad market, more precisely: Buying Display and Video Advertising – accessing the ad exchange to buy iAB standard display and video formats for discount fees; Buying Connected TV Advertising – access the ad exchange to buy iAB standard Connected TV formats for discounted fees; Selling Display and Video Advertising – accessing the ad exchange to sell iAB standard display and video formats across respective publications capable of supporting the iAB display and video formats; Selling Connected TV Advertising – accessing the ad exchange to sell iAB standard connected tv ad formats across respective broadcasting providers capable of supporting the iAB standard connected tv advertising formats; Provisioning of liquidity to support the associated payments from buying display, video and connected tv advertising or for the revenue accrued from the selling of display, video and connected tv advertising. |
| D.8 | Plans for the token | The ALKIMI token has undergone, or is expected to undergo the following key events: August 2025 Launch token on the SUI Layer 1 Blockchain; August 2025 deploy ad exchange on the SUI Layer 1 Blockchain (As of August 2025, Alkimi's ad exchange has processed over 2 Billion ad transactions); August 2025 Listing outside the EU/EAA, on various exchanges; October 2025 Spontaneous listing by exchanges operating within the EU/EEA. |
| D.9 | Resource allocation | Many of the resources that support Alkimi, such as technical personnel, experienced management staff, appropriate facilities and infrastructure come from, Alchemy VC Limited as well as XSM Limited (BVI), and other ecosystem participants, each of whom have their own balance sheets to support these efforts. Additionally, the published Tokenomics (available at www.alkimi.org) clearly disclose that 65% of the total supply is allocated to Ecosystem Development and Community Engagement and Growth that is committed to the long-term development and growth of the Alkimi ecosystem, including community grants and programs, developer support, Alkimi core research, incentive programs, Alkimi community events, hackathons, and other ecosystem initiatives. |
| D.10 | Planned use of collected funds or crypto-assets | Not Applicable |
Part E - Information about the offer to the public of crypto-assets or their admission to trading
| Field | Field Name | Content to be Reported |
|---|---|---|
| E.1 | Public offering or admission to trading | ATTR |
| E.2 | Reasons for public offer or admission to trading | ALKIMI is the utility token powering the ad exchange. Seeking admission to trading on EU regulated exchanges is necessary to facilitate market access and broader adoption of this innovative protocols decentralised ad exchange. |
| E.3 | Fundraising target | Not applicable. The present white paper is published solely in relation to the admission to trading of the ALKIMI token. |
| E.4 | Minimum subscription goals | Not applicable. See explanation under E.3. |
| E.5 | Maximum subscription goals | Not applicable. See explanation under E.3. |
| E.6 | Oversubscription acceptance | Not applicable. See explanation under E.3. |
| E.7 | Oversubscription allocation | Not applicable. See explanation under E.3. |
| E.8 | Issue price | Not applicable. See explanation under E.3. |
| E.9 | Official currency or any other crypto-assets determining the issue price | Not applicable. See explanation under E.3. |
| E.10 | Subscription fee | Not applicable. See explanation under E.3. |
| E.11 | Offer price determination method | Not applicable. See explanation under E.3. |
| E.12 | Total number of offered/traded crypto-assets | 295,000,000 committed to trading; with a fixed maximum supply of 1 Billion ALKIMI. The circulating supply will steadily increase due to scheduled escrow releases. |
| E.13 | Targeted holders | ALL |
| E.14 | Holder restrictions | The Sui network is permissionless and decentralized. There are no holder restrictions at Sui level. The trading platforms in accordance with applicable laws and internal policies may impose restrictions to buyers and sellers of ALKIMI tokens on the trading platforms. Any checks performed to implement such restrictions, notably KYC checks, are neither conducted by the issuer nor the offeror. Sanctions and embargoes: Trading platforms may exclude persons or entities located in any jurisdiction subject to comprehensive sanctions or embargoes according to EU law, as well as anyone listed on sanctions lists maintained by the EU, UN, UK, or US ("Prohibited Persons"). Non-EU Jurisdictions: The offeror may impose additional restrictions on prospective non-EU ALKIMI holders as necessary to comply with non-EU regulatory frameworks. |
| E.15 | Reimbursement notice | Purchasers participating in the offer to the public of crypto-asset will be able to be reimbursed if the minimum target subscription goal is not reached at the end of the offer to the public, if they exercise the right to withdrawal provided for in Article 13 of Regulation (EU) 2023/1114 of the European Parliament and of the Council or if the offer is cancelled. |
| E.16 | Refund mechanism | Not applicable. See explanation under E.3. |
| E.17 | Refund timeline | Not applicable. See explanation under E.3. |
| E.18 | Offer phases | Not applicable. See explanation under E.3. |
| E.19 | Early purchase discount | Not applicable. See explanation under E.3. |
| E.20 | Time-limited offer | Not applicable. See explanation under E.3. |
| E.21 | Subscription period beginning | Not applicable. See explanation under E.3. |
| E.22 | Subscription period end | Not applicable. See explanation under E.3. |
| E.23 | Safeguarding arrangements for offered funds/crypto-assets | The proceeds from the sale are subject to protective measures taken either by the offeror itself or by appointed service providers, which must comply with the requirements of Regulation (EU) 2023/1114. |
| E.24 | Payment methods for crypto-asset purchase | The method of payment to buy and sell the ALKIMI token on the Trading Platforms are determined and set by the Trading Platforms and are not controlled, influenced, or governed by the Foundation. |
| E.25 | Value transfer methods for reimbursement | Not applicable. See explanation under E.3. |
| E.26 | Right of withdrawal | Not applicable. See explanation under E.3. |
| E.27 | Transfer of purchased crypto-assets | The purchased ALKIMI tokens will be transferred on the Sui network. The person seeking admission to trading is not responsible for this transfer. Transfers occur in accordance with the network's standard processing times and are subject to blockchain confirmation. Once completed, the transaction is immutable and permanently recorded on the used blockchain. |
| E.28 | Transfer time schedule | The transfer of the ALKIMI token from the seller's wallet or device to the buyer's wallet or device may not occur immediately. ALKIMI has no control over the timing of such transfers. |
| E.29 | Purchaser's technical requirements | Not applicable. See explanation under E.3. |
| E.30 | Crypto-asset service provider (CASP) name | N/A |
| E.31 | CASP identifier | N/A |
| E.32 | Placement form | NTAV |
| E.33 | Trading platforms name | BitPanda, Bitvavo, Crypto.com, Gate.io, HTX, Kraken, Kucoin, MEXC, Uphold. With regard to the listing on Bitpanda: Bitpanda GmbH will not set minimum or maximum subscription goals with regards to the placement, Bitpanda GmbH will place an reasonably appropriate amount of crypto-assets during the Placement Period, in line with the amount of crypto-assets it has received by the Issuer and the amount of crypto-assets it can procure from the open market, it being understood that Bitpanda GmbH does not guarantee any minimum sales. The pricing mechanism for the placed Token shall follow an open market pricing mechanism based on reference prices from other trading venues. Before, during and after the Placement Period. The fees applicable to the trading of the Token on Bitpanda's trading platform are publicly available on bitpanda.com/legal. The intended target audience are Bitpanda Spotlight users who trade similar cryptoassets on Bitpanda's trading platform. |
| E.34 | Trading platforms Market identifier code (MIC) | KRME |
| E.35 | Trading platforms access | Trading platforms are accessible via their respective website or applications for mobile devices. Investors can access ALKIMI through supported cryptocurrency trading platforms. |
| E.36 | Involved costs | The use of services offered trading platforms may involve costs, including transaction fees, withdrawal fees, and other charges, as notified to users in advance. These costs are determined and set by the respective trading platforms and are not controlled, influenced, or governed by the offeror. Consequently, any changes to initially announced fee structures or the introduction of new costs for the future are solely at the discretion of trading platforms. |
| E.37 | Offer expenses | Not applicable |
| E.38 | Conflicts of interest | No potential conflict of interest were identified. |
| E.39 | Applicable law | All legal matters will be handled in accordance with BVI law. |
| E.40 | Competent court | Competent courts in BVI will have authority over legal matters related to ALKIMI tokens. |
Part F - Information about the crypto-assets
| Field | Field Name | Content to be Reported |
|---|---|---|
| F.1 | Crypto-asset type | Utility token |
| F.2 | Crypto-asset functionality | XSM offers a utility token that enables participation in Alkimi's decentralised advertising exchange ecosystem. The token operates on the Sui blockchain and serves as the primary mechanism for accessing Alkimi's complete suite of services related to the buying and selling of digital ads online, in app and on connected TVs. The services include: Buying Display Advertising, Buying Video Advertising, Buying Connected TV Advertising, Selling Display Advertising, Selling Video Advertising, Selling Connected TV Advertising, Accessing liquidity to purchase advertising, Accessing liquidity for the accrued revenue from selling advertising. |
| F.3 | Planned application of functionalities | N/A |
| F.4 | Type of crypto-asset white paper | OTHR |
| F.5 | The type of submission | NEWT |
| F.6 | Crypto-asset characteristics | Alkimi token is a crypto-asset to be classified as a utility token which is required to Participate and Interact with the complete suite of features of Alkimi's decentralised Advertising Exchange: Access to buy digital advertising across the web, in app and connected tv devices; Access to sell digital advertising across the web, in app and connected tv devices; Provision liquidity for the buying or selling digital ads on the web, in app and connected tv devices. |
| F.7 | Commercial name or trading name | Alkimi |
| F.8 | Website of the issuer | https://www.alkimi.org/ |
| F.9 | Starting date of offer to the public or admission to trading | 2025-08-29 |
| F.10 | Publication date | 2025-08-29 |
| F.11 | Any other services provided by the issuer | Not applicable |
| F.12 | Language or languages of the crypto-asset white paper | English |
| F.13 | Digital token identifier code used to uniquely identify the crypto-asset or each of the several crypto assets to which the white paper relates, where available | N/A |
| F.14 | Functionally fungible group digital token identifier, where available | N/A |
| F.15 | Voluntary data flag | False |
| F.16 | Personal data flag | False |
| F.17 | LEI eligibility | True |
| F.18 | Home Member State | Ireland |
| F.19 | Host Member States | Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden. The above list includes the countries from the European Economic Area ("EEA"), i.e., Iceland, Liechtenstein, and Norway. At the time of the notification of the White Paper, the Regulation (EU) 2023/1114 has not yet been incorporated into the EEA Agreement. The Offer and passporting in the countries of the EEA may not be guaranteed. |
Part G - Information on the rights and obligations attached to the crypto-assets
| Field | Field Name | Content to be Reported |
|---|---|---|
| G.1 | Purchaser rights and obligations | The ALKIMI token does not confer any rights or entitlements to its holders. Instead, the ALKIMI token enables its holders to participate in and interact with the Alkimi's Ad Exchange, see D.7. |
| G.2 | Exercise of rights and obligations | Not Applicable |
| G.3 | Conditions for modifications of rights and obligations | The ALKIMI token may be adjusted to comply with future regulatory requirements or to improve functionality. The issuer will notify users of significant changes through public announcements. In the event of a major shift in token utility, users will be given a grace period to adjust or redeem tokens. |
| G.4 | Future public offers | None |
| G.5 | Issuer retained crypto-assets | The issuer will not retain any tokens for the team, the tokens will be distributed as per tokenomics. |
| G.6 | Utility token classification | True |
| G.7 | Key features of goods/services of utility tokens | See D.7 for a summary of the key features. |
| G.8 | Utility tokens redemption | As described (see D.7), ALKIMI may be used to access the complete suite of services provided by the Decentralised ad exchange to facilitate the buying and selling of digital ads on the web, in app and connected TV devices. |
| G.9 | Non-trading request | True |
| G.10 | Crypto-assets purchase or sale modalities | Not applicable |
| G.11 | Crypto-assets transfer restrictions | See E.14 |
| G.12 | Supply adjustment protocols | False |
| G.13 | Supply adjustment mechanisms | N/A |
| G.14 | Token value protection schemes | False |
| G.15 | Token value protection schemes description | N/A |
| G.16 | Compensation schemes | False |
| G.17 | Compensation schemes description | N/A |
| G.18 | Applicable law | All legal matters will be handled in accordance with BVI law. |
| G.19 | Competent court | Competent courts in BVI will have authority over legal matters related to ALKIMI tokens. |
Part H - Information on the underlying technology
| Field | Field Name | Content to be Reported |
|---|---|---|
| H.1 | Distributed ledger technology (DLT) | Sui is a Layer 1 blockchain that operates as a distributed ledger, which means it maintains a replicated, shared, and synchronized database across a decentralized network of nodes. Sui's DLT ensures: Immutability – Once transactions are recorded, they cannot be changed; Transparency – All participants have access to the same data; Decentralization – No single point of control or failure. Sui's unique approach includes object-centric data storage and parallel transaction execution, which sets it apart from traditional blockchains. Rather than storing everything in a single chain of blocks, Sui treats on-chain data as programmable objects that can evolve over time. |
| H.2 | Protocols and technical standards | Sui is built on the Move programming language, adapted into Sui Move – a variant optimized for the Sui network. Key protocols and standards include: Object-based data model: Every asset or user-defined structure is an object with ownership and type constraints; Custom token standards: Instead of using a single ERC-20-like standard, Sui allows developers to define custom logic and types for fungible and non-fungible tokens (NFTs); Access control and capabilities: Sui Move uses capability-based security, ensuring only authorized entities can modify or access certain objects. While Sui doesn't directly replicate Ethereum standards like ERC-20 or ERC-721, similar functionality can be implemented with Move modules and object types. |
| H.3 | Technology used | Sui incorporates a range of modern technologies: Move Language: Safe and secure smart contract programming language, originally developed by Meta; Parallel Execution Engine: Sui is designed to execute independent transactions concurrently, improving throughput significantly; Object-centric Model: Each object has a globally unique ID and defined ownership, enabling fine-grained control and scalability; Client SDKs: Sui offers libraries in TypeScript, Rust, and more, making it easier to integrate token and contract logic into dApps. Additionally, Sui uses cryptographic primitives like BLS and Ed25519 for signing and verification. |
| H.4 | Consensus mechanism | Sui uses a context-aware hybrid consensus model. For transactions that involve single-owner objects (for example, a user sending tokens from their own wallet), consensus is not required – these are processed using a fast and direct method that ensures instant finality. This design significantly improves performance for common operations. When a transaction involves shared objects (e.g., smart contracts or multi-user resources), it is processed through a full Byzantine Fault Tolerant (BFT) consensus protocol. Specifically, Sui uses Narwhal for data availability and Bullshark for transaction ordering and finality. This separation of concerns allows Sui to maintain both high performance and strong consistency where needed, making it one of the most scalable consensus systems among modern blockchains. |
| H.5 | Incentive mechanisms and applicable fees | N/A |
| H.6 | Use of distributed ledger technology | False |
| H.7 | DLT functionality description | Object-Centric Data Model: Unlike traditional blockchains that track account balances, Sui stores and manages data as individual, programmable objects. This allows for more efficient and flexible operations, especially for digital assets and complex interactions. Parallel Transaction Execution: Sui processes transactions concurrently, enabling higher throughput and faster transaction finality compared to blockchains that execute transactions sequentially. Delegated Proof-of-Stake (DPoS): Sui uses a DPoS consensus mechanism, where validators stake SUI tokens to secure the network and validate transactions. Move Programming Language: Sui leverages the Move language, known for its security and expressiveness, to build smart contracts and decentralized applications. |
| H.8 | Audit | True |
| H.9 | Audit outcome | See https://sui.io/security |
Part I - Information on risks
| Field | Field Name | Content to be Reported |
|---|---|---|
| I.1 | Offer-related risks | General Contractual and Counterparty Risk: The Person Seeking Admission To Trading neither operates nor controls, oversees, or manages the functioning of the Trading Platforms where the ALKIMI token will be admitted. When ALKIMI token holders buy or sell the ALKIMI token on Trading Platforms, the Person Seeking Admission To Trading is not a contractual party to these transactions. Any legal relationship between token holders and the Trading Platforms is governed solely by the terms and conditions set by each Trading Platform at its discretion. The Person Seeking Admission To Trading assumes no responsibility or liability for the operations, services, security, performance, or any outcomes – whether financial or technical – arising from transactions conducted on these Trading Platforms. Pausing and Delisting Risk: The Person Seeking Admission To Trading cannot guarantee that the ALKIMI token will remain listed or tradeable on any Trading Platforms. Delisting (or the temporary pausing of such listing) could significantly hinder the ability of ALKIMI token holders to buy, sell, or otherwise transact in ALKIMI tokens. Trading Risk: The Person Seeking Admission To Trading does not control the secondary markets. There can be no assurance as to the secondary market (if any) in the ALKIMI tokens. It cannot guarantee the depth, stability, or sustainability of any secondary market for ALKIMI tokens. Operational and Technical Risk: Trading Platforms operate interfaces that allow users to trade crypto-assets for fiat currencies or other crypto-assets. The reliance on a Trading Platform's internal system for asset storage and transfer introduces additional counterparty risk, exposing users to potential operational, technical, or human error. Unanticipated Risks: In addition to the risks outlined above, unforeseen risks may arise as unexpected variations or combinations of the risks described. |
| I.2 | Issuer-related risks | Abandonment / Lack of Success Risk: This is the risk that the activities of the Issuer must be partially or totally abandoned for several reasons including, but not limited to, lack of interest from the public, lack of funding, incapacitation of key developers and project members, force majeure (including pandemics and wars), or lack of commercial success or prospects. Project Change Risk: The project of the Issuer, for which the Protocol serves as the implementation, may evolve over time. This could involve pivoting from its original vision or modifying how that vision is executed. No Protocol Control Risk: The Protocol is neither operated nor controlled by the Issuer. Should ALKIMI token holders interact with the Protocol, they are engaging directly with the Protocol and potentially with third parties that have no relationship to the Issuer. Withdrawing Partners Risk: The implementation of the Protocol depends heavily on the collaboration and functioning of services provided by several third parties and other crucial partners. Legal and Regulatory Compliance Risk: Crypto assets and blockchain-based technologies are subject to evolving regulatory landscapes worldwide. Changes in laws or regulations may negatively impact the value, legality, or functionality of the ALKIMI token. Operational Risk: Any failure to develop or maintain effective internal control could harm the business of the Issuer. Industry Risk: The Issuer is and will be subject to all the risks and uncertainties associated with any new venture or visionary project. Reputational Risk: The Issuer faces the risk of negative publicity. Competition Risk: There are numerous existing crypto-assets and projects, and new competitors may enter the market at any time. Unsolicited Admission to Trading Risk: Third parties may choose to support ALKIMI tokens on their Trading Platforms without any request, authorization, or approval by the Issuer. |
| I.3 | Crypto-assets-related risks | Market Risk: Crypto assets, including ALKIMI tokens, are highly volatile and can experience significant price swings in short periods, increasing the risk of sudden and substantial losses. ALKIMI token holders are exposed to potential fluctuations in value, liquidity risk, and solvency and collateral risk. Custodial Risk: The method chosen to store ALKIMI tokens carries inherent risks related to the security and management of the storage solution. Scam Risk: This is the risk of loss resulting from a scam or fraud including phishing, fake giveaways, identity theft, creation of fake ALKIMI tokens, or fake airdrops. Anti-Money Laundering / Counter-Terrorism Financing Risk: Crypto-asset wallets or transactions may be flagged in AML/CTF investigations. Taxation Risk: The taxation regime depends on each holder's jurisdiction. Market Abuse Risk: The market may be exploited for abusive trading practices including front-running, spoofing, and pump-and-dump schemes. Legal and Regulatory Risk: There is currently no global regulatory harmonization for crypto assets, resulting in diverging legal frameworks and ongoing changes. |
| I.4 | Project implementation-related risks | Novel Ecosystem Risk: The ALKIMI ecosystem is built on emerging and rapidly evolving technologies, which inherently carry significant risks. The underlying software, blockchain infrastructure, smart contracts, and related technologies are still in their early stages of development. Dependency Risk: The Protocol relies on third-party technologies, infrastructures, and protocols, particularly the Sui network. Any disruptions, vulnerabilities, regulatory scrutiny, or changes in Sui network's operations could directly affect the usability and security of the Protocol. Suitability Risk: The Protocol will be deployed on an "as is" and "as available" basis without warranties of any kind. |
| I.5 | Technology-related risks | General Cybercrime Risk: The technological components supporting the ALKIMI token may be vulnerable to cyberattacks including hacking, smart contract exploits, phishing, and malware. Blockchain-Level Risk: The blockchain used for the issuance of the ALKIMI tokens could be susceptible to consensus-related attacks, including double-spend attacks, majority validation power attacks, censorship attacks, and byzantine behavior, or be subject to forks. Smart Contract-Level Risk: Smart contracts may contain vulnerabilities, coding errors, or unforeseen logic flaws that could result in unintended consequences. Protocol-Level Risk: Technical failures, malfunctions, or vulnerabilities within the Protocol could directly or indirectly impact the value of the ALKIMI token. |
| I.6 | Mitigation measures | The Person Seeking Admission To Trading has implemented various measures to mitigate the risks outlined above. These include comprehensive disclosures, rigorous technology testing and auditing, and the careful selection of personnel, management, and third-party partners. However, many of these risks are inherent to the activities and the broader ecosystem, making complete elimination impossible. Prospective ALKIMI token holders should adopt appropriate safeguards based on their chosen custody method and remain vigilant by actively monitoring publicly available news and market signals. |
Part J - Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts
| Field | Field Name | Content to be Reported |
|---|---|---|
| J.1 | Adverse impacts on climate and other environment-related adverse impacts | Information referred to Commission Delegated Regulation establishing technical standards adopted pursuant to Article 6(12), fourth subparagraph, Article 19(11), fourth subparagraph, Article 51(15), fourth subparagraph, and Article 66(6), fourth subparagraph of Regulation (EU) 2023/1114 of the European Parliament and of the Council. See below information according to Commission Delegated Regulation (EU) 2025/422. |
Mandatory information on principal adverse impacts on the climate and other environment-related adverse impacts of the consensus mechanism (Table 2 of Commission Delegated Regulation (EU) 2025/422)
| Field | Field Name | Content to be Reported |
|---|---|---|
| S.1 | Name | See field A.1. |
| S.2 | Relevant legal entity identifier | See field A.6. |
| S.3 | Name of the crypto-asset | See field D.2. |
| S.4 | Consensus Mechanism | See field H.4. |
| S.5 | Incentive Mechanisms and Applicable Fees | See field H.5. |
| S.6 | Beginning of the period to which the disclosed information relates | 2025-01-01 |
| S.7 | End of the period to which the disclosed information relates | 2025-12-31 |
| S.8 | Energy consumption | XSM Limited (BVI) is providing information on principal adverse impacts on the climate and other environment-related adverse impacts of the consensus mechanism used to validate transactions of the ALKIMI token and to maintain the integrity of the distributed ledger of transactions. The energy consumption for the validation of transactions and the maintenance of the integrity of the distributed ledger of transactions for the period is estimated to be lower than 500'000 kWh. The figure provided is intended to reference annualized amounts. |
| S.9 | Energy consumption sources and methodologies | Data provided by CCRI; all indicators are based on a set of assumptions and thus represent estimates; methodology description and overview of input data, external datasets and underlying assumptions available at: https://carbon-ratings.com/dl/whitepaper-mica-methods-2024 and https://docs.mica.api.carbon-ratings.com. |
| S.10 | Renewable energy consumption | N/A |
| S.11 | Energy intensity | N/A |
| S.12 | Scope 1 DLT GHG emissions – Controlled | N/A |
| S.13 | Scope 2 DLT GHG emissions – Purchased | N/A |
| S.14 | GHG intensity | N/A |
| S.15 | Key energy sources and methodologies | N/A |
| S.16 | Key GHG sources and methodologies | N/A |