Index

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

2026-08-18

This crypto-asset whitepaper 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.

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.

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.

FALSE

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.

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 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.

The SBT token is a fungible crypto-asset issued by Sbarter Association and deployed on Solana, a public Proof-of-Stake blockchain network. The SBT token constitutes a crypto-asset within the meaning of Article 3(1)(5) of Regulation (EU) 2023/1114 (MiCA) and is classified as an “other crypto-asset” under Title II of that Regulation.

SBT does not qualify as:

• an electronic money token (EMT) under Article 3(1)(7) MiCA, as it does not seek to maintain a stable value by referencing one official currency;
• an asset-referenced token (ART) under Article 3(1)(6) MiCA, as it does not reference any asset, basket of assets, or rights;
• a financial instrument within the meaning of Directive 2014/65/EU (MiFID II);
• a deposit, structured product, securitisation instrument, or collective investment scheme participation;
• a payment instrument within the meaning of Directive (EU) 2015/2366 (PSD2).

SBT functions enable SBT holders to interact with the Sbarter protocol. The Sbarter protocol is a blockchain-based coordination and automated settlement infrastructure that enables eligible users, subject to applicable law, jurisdictional restrictions, product availability, and compliance requirements, to create and participate in peer-to-peer, performance-based digital challenges within integrated third-party video games. In practical terms, this enables players to play skill-based games with one another, where results are determined solely by player performance.

Within this ecosystem, SBT has the following functions:

Entry and Participation Function

SBT is required for creating or joining an eligible skill-based video game challenge (“Challenge”). When a Challenge is confirmed by participants, the specified quantity of SBT is programmatically locked for the duration of the challenge.

Automated Outcome Redistribution Function

Following completion of the relevant Challenge, authenticated match outcome data is transmitted to the Sbarter protocol by the relevant Video Game Provider (“VGP”). Once validated outcome data is received, the Sbarter protocol executes predetermined settlement rules and automatically redistributes the locked SBT between participants in accordance with those rules.

Protocol Service Fee Function

SBT are used to pay Sbarter protocol fees and oracle verification service fees associated with infrastructure maintenance, match-result verification processes, smart contract execution, and network operations.

Governance Participation Function

Governance rights of Members of the Association Sbarter are,among others,weighted by the amount of SBT a member locked and the duration of the lock. Holding SBT alone confers neither membership nor any governance right, nor any right to participate in the management of Sbarter Ltd.

SBT do not give any relative right or claim (e.g. profit, dividends, revenue) against the Association or any other third party.
SBT do not give any (partial or full) claim for redemption of the contributed amounts. SBT is not pegged to any underlying asset or currency, or basket of currencies or assets.

Not applicable

This white paper is published by Sbarter Ltd. exclusively in connection with the admission of SBT to trading on crypto-asset trading platforms authorised or registered under Regulation (EU) 2023/1114, in accordance with Article 5 of Regulation (EU) 2023/1114. No offer to the public of SBT is being made by Sbarter Ltd. or Sbarter Association by means of this white paper. The distribution of SBT tokens has been conducted exclusively through private placement arrangements by Sbarter Association, independently of this white paper.

1. Token Generation Event (TGE) and Initial Market Availability

On 4 June 2026, the TGE,Sbarter Association conducted the Token Generation Event (“TGE”) whereby all 25,000,000,000 were minted on the Solana blockchain network.

2. Future Admission to Centralised Exchanges (CEXs)

Sbarter Ltd. intends to seek admission of SBT to trading on one or more centralised crypto-asset trading platforms following the Token Generation Event. No formal listing agreement has been executed with any trading platforms as at the date of this white paper and no timeline for admission to trading on any centralised exchange is guaranteed.

Admission to trading on any centralised platform is subject to independent third-party approval, due diligence, technical integration requirements, and applicable regulatory considerations.

Any admission to trading on centralised platforms will be announced via the official communication channels of Sbarter Ltd. and Sbarter Association.

Sbarter Association and Sbarter Ltd. do not operate any trading venue and do not provide exchange services, brokerage services, or multilateral trading facilities.

3. Maximum Token Supply

The maximum total supply is fixed at 25,000,000,000 (twenty-five billion) tokens. The supply of SBT is capped and no additional SBT may be minted beyond this amount. The token does not implement inflationary issuance or deflationary mechanisms.

4. Token Allocation Structure

The total supply is allocated across the following categories (“Tokenomics Framework”). The Tokenomics Framework reflects the allocation currently envisaged by the Sbarter Association, intended to support long-term ecosystem development, operational sustainability, and gradual market participation. It is provided for illustrative and informational purposes only and may be amended, adjusted, or reallocated by the Sbarter Association from time to time.

Token Supply and Allocation Overview

The total fixed supply of SBT is 25,000,000,000 tokens, allocated as follows:

4.1 Pre-seed

• Allocation: 8.0%
• Tokens: 2,000 MM
• Cliff: 12
• Vesting: 24
• Monthly release: 4.17%

4.2 Seed

• Allocation: 4.0%
• Tokens: 1,000 MM
• Cliff: 6
• Vesting: 18
• Monthly release: 5.56%

4.3 Institutional investors

• Allocation: 24.0%
• Tokens: 6,000 MM
• Cliff: 12
• Vesting: 24
• Monthly release: 4.17%

4.4 Video Game Providers

• Allocation: 20.0%
• Tokens: 5,000 MM
• Cliff: 12
• Vesting: 24
• Monthly release: 4.17%

4.5 Marketing

• Allocation: 8.0%
• Tokens: 2,000 MM
• Cliff: 6
• Vesting: 36
• Monthly release: 2.64%

4.6 Team & Founders

• Allocation: 16.8%
• Tokens: 4,200 MM
• Cliff: 12
• Vesting: 24
• Monthly release: 4.17%

4.7 Reserve

• Allocation: 11.7%
• Tokens: 2,925 MM
• Vesting: 48
• Monthly release: 2.08%

4.8 Liquidity

• Allocation: 7.5%
• Tokens: 1,875 MM
• Vesting: 12
• Monthly release: 4.17%

Initial circulating supply at TGE: 1,037,500,000 SBT (4.15% of total supply).

5. Vesting and Lock-Up Mechanisms

Certain allocation categories are subject to structured vesting arrangements and lock-up periods. These mechanisms may include:

• Initial cliff periods during which tokens remain non-transferable;
• Progressive linear monthly release schedules;
• Extended release timelines for reserve allocations;
• Conditional release structures where applicable.

Vesting applies in particular to:

• Team and founder allocations;
• Advisor allocations;
• Strategic allocations;
• Ecosystem and reserve allocations;
• Certain partnership allocations.

The purpose of these mechanisms is to:

• Promote long-term alignment of stakeholders;
• Provide predictability in circulation supply growth;
• Reduce abrupt expansion of transferable supply in early operational phases.

6. Circulating Supply at TGE

The initial circulating supply at TGE is 1,037,500,000 SBT, representing approximately 4.15% of the maximum total supply, reflecting the application of vesting and lock-up restrictions described above. This limited initial circulation is by design, to moderate early supply expansion and align token availability with progressive ecosystem adoption. Circulating supply will increase progressively over time in accordance with vesting schedules.

7. Secondary Market Considerations

Following TGE and admission to trading:

• Market prices may fluctuate significantly;
• Liquidity may be limited or fragmented across venues;
• Trading access may be restricted in certain jurisdictions;
• Exchanges may suspend or discontinue trading;
• Regulatory developments may impact availability.

Neither Sbarter Association nor Sbarter Ltd. undertake to maintain any minimum market value or trading volume. The market value of SBT, if any, is determined exclusively by supply and demand in secondary markets.

Sbarter Ltd.

2025-12-15

984500947BA6N54CE210

+356 79001201

corporate@sbarter.com

Sbarter Ltd. is an entity operating under the laws of Malta. Sbarter Ltd. is the publisher of this white paper and the person seeking admission to trading under MiCA.

Sbarter Ltd.’s business activity consists of the development, deployment, and operation of the Sbarter protocol, a blockchain-based infrastructure enabling peer-to-peer, skill based digital challenges within third-party video games.

Its activities include:

• Development and maintenance of the protocol’s application-layer infrastructure;
• Smart contract deployment and technical management;
• Integration of VGPs, which act solely as technical data providers (oracles) transmitting authenticated match results;
• Implementation of compliance mechanisms where required;
• Management of protocol-level service fee structures;
• Coordination of token distribution and market access arrangements.

Sbarter Ltd. does not operate video games, does not determine game outcomes, does not operate a crypto-asset trading platform, and does not provide crypto-asset services within the meaning of Regulation (EU) 2023/1114. Sbarter Association, a Swiss non-profit association, is the issuer of the SBT token and the owner of the protocol's intellectual property. It does not conduct operational platform activities.

Sbarter Association is a blockchain-focused organisation whose principal activity is the development and promotion of a blockchain-based ecosystem for the video game industry, providing infrastructure and tools to support its members. Its principal market is the global video gaming and digital entertainment sector.

FALSE

Sbarter Ltd. was incorporated in Malta on 15 December 2025 and, as of the date of this white paper, has not yet commenced commercial operations. Consequently, Sbarter Ltd. has not generated revenues and no operating financial history is available since its incorporation.

Since its establishment, Sbarter Ltd. has been engaged primarily in organizational and preparatory activities, including corporate structuring, technical development planning, and preparations for the operational rollout of the Sbarter protocol infrastructure. As a result of this early-stage development phase, no audited financial statements have yet been prepared and the Sbarter Ltd. has not recorded material operating income or expenses.

Sbarter Ltd. operates as the operational entity within the broader Sbarter ecosystem, while Sbarter Association, a Swiss association, acts as the issuer of the SBT token and the coordinating entity responsible for the development and governance framework of the Sbarter protocol.

The initial financial inflows supporting the development of the Sbarter ecosystem have primarily originated from the private placement of SBT tokens conducted by Sbarter Association prior to the publication of this white paper. The proceeds of such private placements are intended to support the development of the Sbarter protocol, the expansion of the ecosystem, and the operational activities required for its rollout.

As part of this ecosystem structure, Sbarter Ltd. is financially supported by Sbarter Association, which has confirmed its intention to make funds available to Sbarter Ltd. to support the development and operational deployment of the Sbarter protocol and related technical infrastructure.

Prospective holders of SBT should nevertheless note that Sbarter Ltd. is a recently incorporated entity with no operating history, no revenue generation to date, and no audited financial statements, and that the future financial position of Sbarter Ltd. will depend on several factors including, but not limited to, the continued development and adoption of the Sbarter protocol.

TRUE

Sbarter Association

2024-03-27

5067003BIJLUXXWI4920

Sbarter Association is a non-profit association incorporated under Article 60 et seq. of the Swiss Civil Code and having its registered office in Switzerland. The Association acts as the issuer of the SBT token and is the legal owner of the intellectual property (IP) relating to the Sbarter protocol, including but not limited to protocol architecture specifications, branding, and related technical documentation.

The Association’s activities are limited to:

• Issuance of SBT;
• Stewardship, protection and further development of protocol-related intellectual property;
• Definition of governance principles in accordance with its statutes;
• Oversight of long-term ecosystem objectives and sustainability.

The Association does not:

• Operate the Sbarter protocol infrastructure;
• Manage user-facing platform activities;
• Provide crypto-asset services within the meaning of Regulation (EU) 2023/1114;
• Operate a trading venue;
• Provide investment, payment, custody, or gambling services.

All operational, technical, commercial, and compliance activities relating to the Sbarter protocol are conducted by Sbarter Ltd., a separate legal entity incorporated in Malta.

The separation between the Association (issuer and IP owner) and Sbarter Ltd. (operator and offeror) is designed to ensure structural clarity between token issuance, intellectual property ownership, and operational management.

The Association does not guarantee token value, secondary market liquidity, financial returns, or profit participation.

Sbarter

SBT

SBT

The Sbarter project introduces a technical infrastructure protocol designed exclusively for performance-based digital challenges between users. The protocol operates with strict structural neutrality: it does not host games, set odds, determine outcomes, hold user funds, act as a counterparty, mediate challenge outcomes, or derive revenue from player losses or challenge results. Its sole function is to provide a secure, compliant, and transparent coordination layer for challenge publication, result validation, and automated on-chain settlement.

The system operates on a player-versus-player basis, where outcomes are determined solely by the measurable performance of participants within the underlying video game environment. The protocol does not introduce elements of randomness, probabilistic mechanics, or outcome determination independent of player skill. It functions as an automated infrastructure layer that formalises and settles predefined challenge conditions between users. This therefore enables users to set up and participate in skill-based challenges between players.

The project consists of a blockchain-integrated architecture that operates independently from the underlying game software. It enables users to define structured challenges by specifying parameters such as game title, format, participation conditions, and entry amount denominated in SBT. These parameters are encoded into a smart contract or Solana program deployed on a public blockchain.

Once confirmed by participating users, the relevant quantity of SBT is programmatically locked for the duration of the challenge. The relevant on-chain program autonomously enforces the predefined conditions and manages the locked tokens without discretionary human intervention.

Upon completion of the relevant game session, authenticated match outcome data is transmitted to the protocol through a secure integration interface. The Video Game Provider (VGP) acts strictly as a technical data provider (oracle), supplying verified result data derived from its own game servers. The oracle function is limited to data transmission and does not modify, interpret, or influence redistribution logic. VGPs are compensated in SBT for each instance of verified result data transmitted to the protocol. This compensation constitutes a new, protocol-native revenue stream for VGPs that scales directly with the volume of challenge activity occurring within their game title, without requiring any modification to gameplay mechanics or game economies.

After validation of the transmitted outcome, the relevant on-chain program executes the predefined redistribution logic and transfers the locked tokens in accordance with the challenge parameters. All transfers occur on-chain and are immutably recorded on the blockchain.

The protocol architecture combines:

• on-chain smart contracts and Solana programs governing token locking, vesting, and redistribution;
• off-chain application infrastructure facilitating user interaction;
• secure API integrations with VGP systems; and
• deterministic execution logic triggered exclusively by authenticated performance data.

The Sbarter protocol is architecturally independent from the underlying game software. It does not require Video Game Providers to modify their game mechanics, alter game economies, or disrupt the player experience. Integration is achieved through a single, lightweight API interface that enables VGPs to transmit authenticated match result data to the protocol. This low-friction integration model allows the Sbarter infrastructure to operate across existing game titles without requiring additional development investment from VGPs.

Only challenge formats and product configurations that have been assessed as skill-based and lawful for the relevant market may be made available. Certain games, challenge formats, user categories, or jurisdictions may be restricted, disabled, or geo-blocked where legal, regulatory, or compliance considerations so require. The protocol does not operate games of chance, betting services, or house-managed prize pools.

FALSE

Past milestones

The Sbarter project is implemented through a structured, multi-dimensional roadmap addressing technological development, ecosystem adoption, geographic expansion, token accessibility, and governance evolution.

Future milestones

The future milestones described below are based on Sbarter Association’s current plans and expectations only. They are provided for illustrative purposes and do not constitute a representation, warranty, commitment or guarantee that any such milestone will be achieved or achieved within any particular timeframe.

1. Technical Roadmap

The Sbarter protocol has been designed as a scalable technical standard for competitive digital gaming. Its development roadmap focuses on continuous enhancement of functionality, fairness mechanisms, and system resilience.

1.1 Expansion of Competitive Formats

The protocol architecture allows progressive integration of additional competitive structures beyond initial one-on-one challenges, including:

• Multi-round tournament models
• Bracket-based elimination structures
• League-based competition systems
• Time-based competitive events
• Hybrid competition formats

The technical framework is modular, allowing new tournament models to be embedded without altering the deterministic settlement core.

1.2 Evolution of Ranking and Leaderboard Systems

The protocol aims to continuously enhance leaderboard and ranking mechanisms in order to ensure competitive transparency and fairness.

Planned developments include:

• Multi-dimensional ranking methodologies;
• Integrity-weighted scoring systems;
• Performance consistency modelling;
• Anti-collusion detection parameters;
• Reputation-based integrity scoring.

These mechanisms are designed to create a fair competitive environment based on measurable performance metrics.

1.3 Fairness and Integrity Framework

The protocol is structured to support long-term competitive integrity through:

• Deterministic smart contract execution;
• Oracle-based authenticated match validation;
• Structured challenge parameter locking;
• Transparent redistribution logic.

In future development phases, AI-assisted analytical tools may be implemented to:

• Analyse behavioural anomalies;
• Detect suspicious patterns of gameplay;
• Support integrity scoring models;
• Strengthen fraud prevention mechanisms.

Such tools are intended to enhance ecosystem fairness and security without interfering with game mechanics or deterministic settlement logic. The protocol also incorporates a structured dispute resolution framework applicable to challenge outcomes. The framework is designed to progress through successive operational phases, beginning with on-chain result submission and community-based verification, and evolving toward a comprehensive dispute resolution system with player integrity scoring mechanisms. Access to the dispute resolution process is available to all participants in accordance with the protocol rules published on the Sbarter platform.

1.4 Adaptive Development Model

The technical roadmap is designed to evolve based on user feedback, VGP integration requirements, scalability demands, regulatory considerations.

Protocol enhancements will follow structured deployment processes prioritising stability, security, and compliance.

2. Adoption Roadmap

The growth strategy of the Sbarter ecosystem is centred on progressive integration of VGPs.

The objective is to expand participation among VGPs seeking to offer their user base:

• A structured, compliant competitive environment;
• Performance-based challenge infrastructure;
• Transparent and automated settlement mechanisms;
• An alternative monetisation model integrated at the protocol level.

Adoption efforts focus on onboarding VGPs that align with regulatory standards and technical integration requirements.

3. Geographic Expansion

The protocol is designed to operate across multiple jurisdictions, subject to legal and regulatory compatibility.

Geographic expansion will follow a phased approach:

• Initial availability in jurisdictions assessed as compatible with the protocol model;
• Ongoing legal assessment prior to entering new markets;
• Implementation of jurisdiction-specific access controls where required.

Expansion decisions will prioritise regulatory compliance, operational feasibility, and ecosystem stability.

4. Token Accessibility and Market Infrastructure

To facilitate broader access to SBT, the roadmap includes:

• Initial availability on a decentralised exchange;
• Pursuit of admission to trading on one or more centralised exchanges;
• Progressive enhancement of market accessibility subject to regulatory and exchange approval processes.

Token availability strategies aim to ensure accessibility for users participating in the protocol while maintaining transparency and market integrity.

5. Governance Evolution

The governance model of the Sbarter ecosystem is structured to evolve over time.

At present, governance control of Sbarter Association, which oversees the intellectual property and token issuance, is exercised by its founders.

The strategic plan contemplates a progressive transition toward broader governance participation by integrated VGPs and other eligible ecosystem contributors, subject to ecosystem maturity, operational readiness, and regulatory compatibility.

This transition is intended to:

• Align protocol governance with industry stakeholders;
• Support long-term ecosystem stability;
• Encourage broad adoption by granting governance participation to operational contributors;
• Ensure that control progressively reflects the competitive gaming industry itself.

The transition will be structured and conditional upon ecosystem maturity, operational stability, and regulatory compatibility.

Since its establishment on 27 March 2024, Sbarter Association has raised financial resources primarily through the private placement of SBT tokens to selected participants prior to the publication of this white paper.

Following the Token Generation Event (TGE), the Association may continue the private placement of a portion of the tokens allocated to investors under the Sbarter Tokenomics Framework. These placements are intended to foster the Sbarter ecosystem, including, in particular, the development of the protocol and the support of the adoption of the Sbarter infrastructure within the video game industry.

The resources raised by the Association have been allocated across several key areas required for the development and deployment of the Sbarter protocol.

A significant portion of the resources has been dedicated to the design and development of the Sbarter protocol, including the creation of the technical architecture, smart contract framework, backend infrastructure, and integration mechanisms required to interact with external video game platforms acting as technical data providers. These activities also include the development of application interfaces and other technological components necessary for the operation of the protocol.

Part of the resources has also been allocated to legal, regulatory, and compliance activities, including regulatory assessments across relevant jurisdictions, legal structuring of the ecosystem, and the preparation of technical and regulatory documentation. This includes independent security audits of the smart contracts and associated technical infrastructure, as well as legal reviews required to ensure the protocol’s regulatory positioning.

In addition, resources have been allocated to ecosystem development and market adoption activities, including partnerships with video game providers, community development, and other initiatives intended to support the progressive adoption of the Sbarter protocol.

Sbarter Association has been responsible for the initial development of the protocol and holds the intellectual property rights associated with the Sbarter technology.

In preparation for the launch of the protocol and the Token Generation Event, Sbarter Ltd. has been established as the operational entity responsible for the technical deployment and day-to-day operation of the Sbarter protocol infrastructure.

Within the ecosystem structure, Sbarter Association continues to act as the coordinating and governance entity, while Sbarter Ltd. operates the operational infrastructure and the rollout of the protocol.

Resource allocation decisions may evolve over time depending on the development stage of the protocol and the needs of the ecosystem.

The proceeds of the private placement of SBT tokens conducted by Sbarter Association prior to and independently of this white paper are received and managed exclusively by Sbarter Association, as the legal entity responsible for the issuance of SBT and the stewardship of the Sbarter protocol. No proceeds are raised by Sbarter Ltd. through the publication of this white paper, which is issued exclusively in connection with admission to trading under Article 5 of Regulation (EU) 2023/1114.

The funds collected will be primarily allocated to the development of the Sbarter technology, including technical advancements, infrastructure improvements, and other activities supporting its continued evolution. Funds may also be used to promote ecosystem adoption and integration, as well as to cover legal, regulatory, and compliance assessments, where deemed necessary. All funds are deployed exclusively to support the mission, development, and operation of the Sbarter ecosystem.

This white paper is published by Sbarter Ltd. exclusively in connection with the intended admission of SBT to trading pursuant to Article 5 of Regulation (EU) 2023/1114.

No offer to the public of SBT within the meaning of Regulation (EU) 2023/1114 is being made by means of this white paper.

Any distributions of SBT completed prior to the publication of this white paper were carried out separately from this white paper through private placement arrangements conducted by Sbarter Association and are described in this white paper solely for transparency purposes.

The purpose of this white paper is to provide the disclosures required for the intended admission of SBT to trading on eligible third-party trading venues, subject in each case to separate due diligence, technical integration, listing approval, and applicable legal and regulatory requirements.

SBT does not qualify as an asset-referenced token, an e-money token, or a financial instrument. It is classified as an “other crypto-asset” under Title II of Regulation (EU) 2023/1114.

Not applicable. No offer to the public of SBT is being made by means of this white paper. This white paper is published exclusively in connection with admission to trading pursuant to Article 5 of Regulation (EU) 2023/1114.

For transparency purposes only, the nominal private placement reference price used by Sbarter Association in earlier private placement arrangements was EUR 0.01 per SBT token before the application of any bonus allocations and subject to the vesting and lock-up arrangements described in this white paper.

Following admission to trading, the market price of SBT, if any, will be determined solely by supply and demand on secondary markets.

No restriction is imposed on the category of persons who may hold SBT on secondary markets following admission to trading. SBT may be freely transferred on the Solana blockchain subject to applicable law, the vesting restrictions encoded in the Solana vesting program, and any applicable compliance requirements.

With respect to the private placement of SBT tokens conducted by Sbarter Association prior to the publication of this white paper, participation was subject to applicable KYC and AML compliance requirements under the Swiss Anti-Money Laundering Act (AMLA) and Sbarter Association’s applicable compliance framework.

Neither Sbarter Ltd. nor Sbarter Association exercises ongoing monitoring or control over secondary market transfers of SBT following admission to trading. Holders are responsible for ensuring compliance with applicable laws in their respective jurisdictions, including any restrictions on the holding or trading of crypto-assets.

TRUE

Not applicable. No offer to the public of SBT is being made by means of this white paper. This white paper is published exclusively in connection with admission to trading under Article 5 of Regulation (EU) 2023/1114.

The following information is provided for transparency purposes and in accordance with the disclosure requirements of Regulation (EU) 2023/1114 (MiCA). Prior to the publication of this white paper, Sbarter Association conducted private placement allocations of SBT to selected strategic counterparties, including institutional participants and video game providers. These allocations were carried out independently of this white paper and do not constitute a public offer of SBT within the meaning of Article 3(1)(12) of Regulation (EU) 2023/1114.

During these early allocation phases, the nominal subscription price for SBT was set at EUR 0.01 per token. However, early participants received additional token allocations in the form of bonus tokens, resulting in an effective acquisition price lower than the nominal subscription price. The incentive structure was implemented through a bonus token mechanism rather than a reduction of the nominal subscription price, ensuring consistency of the reference price across allocation phases.

1. Pre-Seed Allocation

Participants in the pre-seed phase subscribed for SBT at EUR 0.01 per token and received a 150% bonus allocation. For each token subscribed, participants received an additional 1.5 tokens, resulting in a total allocation of 2.5 tokens per subscribed token. This corresponds to an effective acquisition price of approximately EUR 0.004 per token.

Pre-seed tokens are subject to a 12-month cliff period followed by a 24-month vesting period, with tokens released progressively on a monthly basis thereafter.

2. Seed Allocation

Participants in the seed phase subscribed for SBT at EUR 0.01 per token and received a 100% bonus allocation, resulting in a total allocation of two tokens for each subscribed token. This corresponds to an effective acquisition price of approximately EUR 0.005 per token.

Seed tokens are subject to a 6-month cliff followed by an 18-month vesting period, with progressive monthly releases thereafter.

3. Institutional Allocation

Institutional participants subscribed for SBT at EUR 0.01 per token and received a 50% bonus allocation, resulting in a total of 1.5 tokens per subscribed token. This corresponds to an effective acquisition price of approximately EUR 0.0067 per token.

These tokens are subject to a 12-month cliff followed by a 24-month vesting period, with tokens released progressively thereafter.

4. Video Game Provider Allocation

Video game providers participating in the ecosystem subscribed for SBT at the nominal price of EUR 0.01 per token without bonus allocation. These tokens are subject to a 12-month cliff followed by a 24-month vesting schedule, reflecting the long-term strategic alignment expected from integrated ecosystem partners.

5. Rationale for the Incentive Structure

The bonus allocation mechanism was designed to reflect the development stage of the project at the time of commitment and the higher level of uncertainty assumed by early participants.

At the time of the earliest allocations:

• the protocol infrastructure had not yet been deployed,
• no operational ecosystem existed,
• no secondary market liquidity was available,
• and participants accepted extended vesting constraints.

The progressive reduction of bonus allocations from the pre-seed phase to later institutional allocations reflects the decreasing level of project risk as development progressed and the ecosystem matured.

The existence of early purchase incentives does not constitute a guarantee of financial return or capital appreciation. The market value of SBT following issuance will be determined exclusively by supply and demand dynamics on secondary markets.

The following information relates to the payment methods accepted by Sbarter Association in connection with the private placement of SBT tokens conducted prior to the publication of this white paper.

1. Primary Payment Method

Payments for SBT tokens under the private placement were accepted by Sbarter Association in EUR or CHF via bank transfer from verified subscriber accounts, subject to applicable KYC and AML compliance procedures under the Swiss Anti-Money Laundering Act (AMLA) and Sbarter Association’s applicable compliance framework.

2. Crypto-Asset Payments

In limited cases, Sbarter Association accepted payment in crypto-assets, subject to the same KYC and AML requirements. Any crypto-asset consideration was converted to a fiat-equivalent value for the purpose of determining the applicable token allocation.

3. Secondary Market Purchases

Purchases of SBT on secondary markets, including any decentralised exchanges and/or any future centralised exchanges on which SBT will be admitted to trading, are subject to the payment mechanisms, terms and conditions, and compliance requirements of the relevant trading platform. Neither Sbarter Ltd. nor Sbarter Association is responsible for the payment processes of independent trading platforms.

At the TGE, the SBT token was created on the Solana blockchain through execution of a dedicated Solana program.

1. Condition Precedent to Token Transfer

Token transfers to pre-sale participants were executed upon satisfaction of applicable KYC requirements. Each pre-sale participant was required to complete a KYC procedure in accordance with Sbarter Association's updated compliance framework. Tokens were transferred to the participant's designated Solana wallet address promptly upon successful completion of the KYC procedure and validation of the wallet address provided.

2. Minting and Supply Finalisation

At the Token Generation Event:

• The total token supply was minted in accordance with the predefined maximum supply cap;
• The mint authority was revoked following issuance;
• No further tokens may be created after revocation.

Revocation of the mint authority ensures that the total supply of SBT cannot be increased beyond the fixed maximum cap defined in this white paper.

3. Vesting Program and Custody Mechanism

Following minting, allocated tokens were not immediately transferred to recipients where vesting conditions apply.
Instead:

• Tokens subject to cliff and vesting schedules were transferred to accounts controlled exclusively by a dedicated Solana vesting program;
• The vesting program holds the tokens in a program-controlled account;
• Neither Sbarter Association nor Sbarter Ltd. can unilaterally access or transfer tokens held within the vesting program.

The release of tokens occurs automatically in accordance with the predefined cliff and vesting schedule applicable to the relevant allocation category.

4. Cliff and Linear Release

For allocations subject to vesting:

• No tokens are released during the cliff period;
• After expiry of the cliff period, tokens are released progressively according to a linear schedule;
• Releases occur automatically through execution of the Solana program logic.

Upon each vesting event, the corresponding amount of SBT is transferred:

• To the wallet address designated by the relevant purchaser; or
• To the designated Association wallet, where applicable.

The vesting logic is encoded in the smart contract and operates deterministically.

5. Security Audit

The Solana token and vesting program have been subject to an independent security audit conducted by CertiK, an established blockchain security auditing firm.

The audit assessed the smart contract logic, minting mechanism, authority revocation, and vesting implementation to identify potential vulnerabilities.

Audit reports are available upon request or published as indicated in this white paper.

6. Finality of Transfers

All token transfers occur on-chain and are recorded immutably on the Solana blockchain.

Once transferred to a recipient’s wallet, SBT is fully controlled by the holder, subject to any remaining vesting conditions embedded in the program logic.

1. Pre-Sale Participants

Pre-sale participants who received SBT token allocations through the private placement conducted by Sbarter Association are required to maintain a non-custodial Solana-compatible wallet that supports SPL tokens in order to receive their token allocation. Participants are solely responsible for the security of their wallet, including the safekeeping of private keys and seed phrases. Neither Sbarter Ltd. nor Sbarter Association provides custody services or has the ability to recover lost or stolen private keys or access credentials.

Pre-sale participants must ensure their wallet address is correctly registered with Sbarter Association prior to the token transfer date. Sbarter Ltd. and Sbarter Association accept no liability for tokens transferred to an incorrectly provided wallet address.

During the applicable vesting period, participants must maintain access to their designated wallet in order to receive vested token releases through the Solana vesting program. Network transaction fees (gas fees) on the Solana blockchain are the responsibility of the participant.

2. Secondary Market Purchasers

Persons acquiring SBT on secondary markets must comply with the technical requirements and terms and conditions of the relevant trading platform. The technical requirements for holding SBT on a centralised exchange are determined by the exchange. For self-custody of SBT acquired on secondary markets, a non-custodial Solana-compatible SPL token wallet is required.

Neither Sbarter Ltd. nor Sbarter Association provides technical support to secondary market purchasers

Sbarter Ltd. intends to seek admission of SBT to trading on one or more third-party centralised trading platforms, subject in each case to separate due diligence, technical integration, listing approval, and applicable regulatory requirements.

No formal listing agreement with any centralised trading platform has been executed as at the date of this white paper, and no specific timeline for admission to trading on any centralised platform is guaranteed.

Any admission to trading on an EU or EEA authorised platform will be announced through the official communication channels of Sbarter Ltd. and Sbarter Association.

Not applicable

Access to SBT on any crypto-asset trading platform to which it is admitted will be subject to the onboarding procedures, technical conditions and contractual terms of that platform.

Challenge escrow, vesting, and automated redistribution within the Sbarter protocol are executed through autonomous Solana programs. Neither Sbarter Association nor Sbarter Ltd. can unilaterally access, transfer, manage, or instruct escrowed or vested SBT.

If SBT is later admitted to trading on a centralised third-party platform, access will be subject to the onboarding procedures, AML/KYC requirements, technical conditions, and contractual terms of that third-party platform.

Access to and trading of SBT tokens may be subject to the fee structure and pricing policies of the respective trading platforms.

Purchasers are responsible for reviewing and complying with the applicable fees, commissions, or transaction costs set by each platform.

Not applicable

The following conflicts of interest have been identified in connection with the admission of SBT to trading. Persons involved in the Sbarter project are advised that these conflicts exist and appropriate measures have been taken to manage them.

1. Relationship Between the Issuer and the Person Seeking Admission to Trading

Sbarter Association is the issuer of SBT and controls Sbarter Ltd., which acts as the publisher of this white paper and the person seeking admission to trading. Given this structural relationship:

• Decisions relating to token issuance, ecosystem development, and exchange admission may involve overlapping governance interests;
• Strategic decisions may indirectly affect the value and adoption of SBT.

2. Founder and Early Participant Token Holdings

Founders, early contributors, pre-seed participants, seed participants, and institutional investors hold SBT under allocation categories described in this white paper. These participants:

• Acquired tokens at earlier stages;
• May have received bonus allocations;
• Are subject to vesting and lock-up arrangements.

Following expiry of applicable vesting schedules, these holders may decide to transfer or sell their tokens on secondary markets, which could affect market price and liquidity.

3. Governance Control

At the time of publication of this white paper, governance of Sbarter Association is exercised by its founders.

Although a planned transition of governance to VGPs is envisaged, current governance concentration may create potential conflicts between founding members and other ecosystem participants.

4. Admission to Trading

Sbarter Ltd. intends to pursue admission of SBT to trading on decentralised venues and, where available, centralised third-party trading platforms.

As of the date of this white paper, no listing agreement has been executed with any centralised trading platform.

Any decision to admit SBT to trading on a third-party platform is made independently by the relevant platform operator and may be influenced by commercial, technical, compliance, and regulatory considerations.

Neither Sbarter Association nor Sbarter Ltd. controls secondary market pricing, liquidity, trading volume, or the timing of any admission to trading.

5. Operational and Economic Incentives

Persons involved in the development and management of the Sbarter protocol may hold SBT directly or indirectly.

Such holdings may create incentives aligned with ecosystem growth but may also create potential conflicts where operational decisions could indirectly affect token market dynamics.

6. Absence of Fiduciary Relationship with Token Holders

Holding SBT does not establish a fiduciary relationship between token holders and Sbarter Association or Sbarter Ltd.

Neither the issuer nor the offeror undertakes to prioritise token market performance over operational, regulatory, or strategic considerations.

This white paper and any matter arising in connection with the admission to trading of the SBT token in the EEA shall be governed by and interpreted in accordance with the laws of Malta (“Applicable Laws”), being the jurisdiction where the white paper has been notified in accordance with Regulation (EU) 2023/1114.

Any dispute arising in connection with this crypto-asset white paper or the admission to trading of the SBT token shall be brought exclusively in the Court of Malta except where prohibited by Applicable Laws.

The SBT token is classified as a crypto-asset other than e-money token and asset-referenced token within the meaning of Regulation (EU) 2023/1114.

SBT has the following functions:

Entry and Participation Function

SBT is required for creating or joining an eligible skill-based video game challenge (“Challenge”). When a Challenge is confirmed by participants, the specified quantity of SBT is programmatically locked for the duration of the challenge.

Automated Outcome Redistribution Function

Following completion of the relevant Challenge, authenticated match outcome data is transmitted to the Sbarter protocol by the relevant Video Game Provider (“VGP”). Once validated outcome data is received, the Sbarter protocol executes predetermined settlement rules and automatically redistributes the locked SBT between participants in accordance with those rules.

Protocol Service Fee Function

SBT are used to pay Sbarter protocol fees and oracle verification service fees associated with infrastructure maintenance, match-result verification processes, smart contract execution, and network operations.

Governance Participation Function

Governance rights of Members of the Association Sbarter are – among others – weighted by the amount of SBT a member locked and the duration of the lock. Holding SBT alone confers neither membership nor any governance right, nor any right to participate in the management of the Association.

SBT do not give any relative right or claim (e.g. profit, dividends, revenue) against the Association or any other third party. SBT do not give any (partial or full) claim for redemption of the contributed amounts. SBT is not pegged to any underlying asset or currency, or basket of currencies or assets.

The SBT and the functionalities described in Section F.02 will be fully functional and accessible at the time of the TGE.

While further functionalities may be introduced in the future, there is no commitment or guarantee that such functionalities will be implemented.

The SBT token is not classified as an asset-referenced token or electronic money token under MiCA, as it does not purport to maintain a stable value by referencing another value or right or a combination thereof, including one or more official currencies, and it does not purport to maintain a stable value by referencing the value of one official currency.

See F.13.

https://sbarter.com/

2026-09-16

2026-09-15

Sbarter Association, in its capacity as issuer of SBT, does not provide crypto-asset services within the meaning of Regulation (EU) 2023/1114.

The activities of Sbarter Association are limited to:

• Issuance of the SBT token;
• Ownership and stewardship of the intellectual property relating to the Sbarter protocol;
• Governance oversight in accordance with its statutes;
• Allocation of funds received in connection with token issuance for the development and promotion of the protocol’s mission.

Sbarter Association does not provide:

• Custody or administration of crypto-assets on behalf of third parties;
• Operation of a trading platform;
• Exchange of crypto-assets for funds or other crypto-assets;
• Execution of orders on behalf of third parties;
• Investment advice or portfolio management;
• Payment services;
• Lending or credit services;
• Gambling or betting services.

All operational, technical, and commercial activities relating to deployment and management of the Sbarter protocol are conducted by Sbarter Ltd., a separate legal entity.

Accordingly, Sbarter Association does not provide additional services to token holders beyond those expressly described in this white paper.

English

9807B4GJ4

QKM436BPX

FALSE

TRUE

TRUE

SBT do not give any relative right or claim (e.g. profit, dividends, revenue) against the Association or any other third party. SBT do not give any (partial or full) claim for redemption of the contributed amounts. SBT is not pegged to any underlying asset or currency, or basket of currencies or assets.

SBT is a crypto-asset designed solely to enable access to and interaction with the Sbarter protocol having the following functions:

Entry and Participation Function

SBT is required for creating or joining an eligible skill-based video game challenge (“Challenge”). When a Challenge is confirmed by participants, the specified quantity of SBT is programmatically locked for the duration of the challenge.

Automated Outcome Redistribution Function

Following completion of the relevant Challenge, authenticated match outcome data is transmitted to the Sbarter protocol by the relevant VGP. Once validated outcome data is received, the Sbarter protocol executes predetermined settlement rules and au-tomatically redistributes the locked SBT between participants in accordance with those rules.

Protocol Service Fee Function

SBT are used to pay Sbarter protocol fees and oracle verification service fees associated with infrastructure maintenance, match-result verification processes, smart contract execution, and network operations.

Governance Participation Function

Governance rights of Members of the Association Sbarter are – among others – weighted by the amount of SBT a member locked and the duration of the lock. Holding SBT alone confers neither membership nor any governance right, nor any right to participate in the management of the Association.

SBT token holders do not acquire any obligations by holding tokens.

The ability to use SBT functionalities of is not subject to any additional conditions beyond compliance with applicable laws and protocol rules. Such functionalities relate exclusively to the use of SBT within the Sbarter protocol, including access to protocol features and, where eligibility requirements are met, participation in governance.

The most up-to-date rights are always available on the Sbarter Association website https://sbarter.com/association/

The functionalities attached to SBT may be amended only in accordance with applicable law, this white paper, the statutes of Sbarter Association, and the governance and decision-making procedures validly applicable to the relevant matter.

No statement by any third party may amend the functionalities attached to SBT unless such amendment has been validly adopted in accordance with the documents and procedures referred to above.

Any material modification to the rights attached to SBT shall be disclosed in accordance with the notification and disclosure obligations applicable under Regulation (EU) 2023/1114.

No modification shall create equity rights, redemption rights, repayment rights, or financial claims for token holders unless required by applicable law.

Not applicable

FALSE

TRUE

SBT is transferable on the Solana blockchain, subject to:

• Applicable laws;
• Vesting restrictions encoded in the Solana program;
• Compliance requirements where applicable.

Transfer of tokens does not automatically transfer membership status in the Association.

FALSE

Not applicable

FALSE

FALSE

This white paper and any matter arising in connection with the admission to trading of SBT in the EEA shall be governed by and interpreted in accordance with the laws of Malta (“Applicable Law”), being the jurisdiction where the white paper has been notified in accordance with Regulation (EU) 2023/1114.

The SBT token does not give rise to obligations or direct rights enforceable against the Sbarter Association. The Token is governed by the applicable laws of Switzerland where the Sbarter Association is incorporated.

Nothing in this whitepaper shall deprive any consumer located in the European Union or European Economic Area of the mandatory rights conferred on that consumer by the consumer-protection legislation of his or her country of habitual residence, if applicable.

Any dispute arising in connection with this crypto-asset white paper or the admission to trading of the SBT token shall be brought exclusively in the Court of Malta except where prohibited by Applicable Law.

The courts of Zug constitute a proper and convenient forum for disputes, claims or proceedings related to the creation of SBT as the issuer is incorporated in Switzerland, Zug.

EU or EEA consumers may be able to bring any judicial proceedings before the competent court of their place of residence.

Solana distributed-ledger technology (public Proof-of-Stake blockchain using Proof-of-History as a sequencing mechanism).

The SBT token is based on the Solana network, which utilizes decentralized Distributed-Ledger Technology. This protocol provides the foundation for secure transactions and smart contracts. SPL Token-2022 Token Standard: The SPL standard is a technical protocol for issuing and managing tokens, ensuring that the SBT token is compatible with most wallets, exchanges, and decentralized applications (DApps).

The SBT token uses the existing SPL Token-2022 token standard on Solana

Solana uses Proof-of-Stake with Tower BFT and Proof-of-History, where leaders are pre-selected by stake and transactions, including SBT transfers, receive sub-second confirmation and high throughput.

The Sbarter protocol relies on a combination of token-based incentives, vesting mechanisms, and network-level fees to secure transactions and promote long-term, aligned participation.

SBT tokens allocated to participants, including strategic counterparties, team members, and ecosystem contributors, are subject to defined cliff and vesting schedules, which incentivise sustained engagement and reduce short-term speculative behaviour. Governance participation is further incentivised through token-locking mechanisms, whereby eligible members may increase their governance influence by locking SBT tokens for extended periods, aligning decision-making power with long-term commitment to the protocol.

Protocol transactions, including challenge participation, escrow, settlement, and governance interactions, are executed via smart contracts deployed on the Solana blockchain. As such, users incur standard Solana network transaction fees, which incentivise validators to process transactions and secure the underlying network. The Sbarter protocol itself does not impose additional protocol-level transaction fees on SBT transfers.

Where applicable, oracle fees payable in SBT compensate Video Game Providers acting as independent result verifiers, ensuring accurate outcome reporting and the integrity of challenge settlement. Any fees associated with fiat conversion or secondary market trading arise from independent third-party on-ramp providers or decentralised exchanges and are external to the protocol.

FALSE

SBT is issued as an SPL token-2022 on the Solana blockchain. Token issuance, transfers, vesting releases, and challenge-related on-chain settlement events are recorded on Solana. Smart contracts and Solana programs are used to lock tokens for eligible challenges, apply vesting conditions, and execute deterministic token redistribution after authenticated match outcome data is submitted by the relevant technical oracle.

TRUE

CertiK security audit of the SBT smart contract and SPL vesting program has been performed on 26 March 2026.

Based on the CertiK security assessment, the outcome of the audit is highly positive. The most significant takeaway is that CertiK found zero Critical, Major, or Medium security vulnerabilities in the Sbarter smart contracts. The full audit report is publicly available on the CertiK Skynet platform at: https://skynet.certik.com/projects/sbarter

In total, the audit identified 12 findings, which break down by severity as follows:

• 0 Critical, 0 Major, and 0 Medium risks.
• 1 Centralization Risk (SBA-05): CertiK flagged that certain privileged roles had authority over key functions, such as initiating the Token Generation Event (TGE) and changing investor wallets. The outcome for this was officially classified as "Multi-Sig," because Sbarter mitigated the risk by placing these functions behind a 2-of-4 multi-signature wallet controlled by the Sbarter Association, ensuring no single point of failure.
• 1 Minor Risk (SBA-07): A potential vulnerability where initialization could be permanently blocked (DoS'd). The Sbarter team successfully Resolved this issue by updating the codebase.
• 10 Informational Findings: These were minor logical or design notes (such as integer-division rounding creating "dust" or theoretical edge cases with token claims).

Regarding the final resolution status of all 12 findings:

• 4 were Resolved by the Sbarter team.
• 7 were Acknowledged (the team reviewed the informational feedback and accepted the minor operational trade-offs without needing to change the core code).
• 1 was secured via Multi-Sig.
• 0 were Declined.

Overall, the outcome demonstrates that the Sbarter protocol's code is secure and structurally sound, with all identified issues successfully addressed, mitigated through decentralized governance, or acknowledged as harmless edge cases.

The admission to trading of the SBT token involves risks related to market volatility, liquidity, regulatory uncertainties, and trading conditions.

The crypto-asset market is highly dynamic, and the price of the SBT token may experience significant fluctuations due to market sentiment, macroeconomic trends, and speculative activity.

There is no guarantee of sustained liquidity or that an active secondary market for the SBT token will develop or remain stable over time. Regulatory changes may impact trading conditions, exchange availability, or compliance requirements, potentially restricting access to the SBT token in certain jurisdictions or imposing additional obligations on holders.

Sbarter Association, the issuer of the SBT token, is a non-profit association incorporated under Swiss law. The following risks relate specifically to Sbarter Association in its role as issuer and governance entity of the Sbarter ecosystem. These risks are distinct from those associated with Sbarter Ltd., which acts as the operational entity responsible for the technical deployment and operation of the Sbarter protocol.

1. Governance Concentration Risk

During the initial phase of the governance model, decision-making authority over the Sbarter protocol and the activities of Sbarter Association is primarily exercised by the founding team and designated governing bodies of the Association.

As a result, holders of SBT have limited ability to influence governance decisions during this initial phase, including decisions that may affect the development, functionality, or utility of the Sbarter protocol.

The governance framework of the Sbarter ecosystem contemplates a progressive transition toward broader community participation. However, the timing, scope, and mechanisms of such a transition may evolve over time, and there is no guarantee that governance arrangements will develop exactly as currently envisaged.

2. Financial Dependency Risk

Sbarter Association is structured as a non-profit entity and does not currently generate independent commercial revenues. Its ability to fund the development of the Sbarter protocol and related ecosystem activities depends primarily on financial resources obtained through private placement allocations of SBT and other ecosystem funding mechanisms.

If available financial resources prove insufficient, or if additional funding cannot be secured when required, Sbarter Association may face limitations in its ability to execute its development roadmap, support ecosystem expansion, or fulfil its functions as issuer of the SBT token.

3. Key Person Risk

The development and strategic direction of the Sbarter ecosystem depend in part on the continued involvement of its founders and key contributors. The loss, unavailability, or reduced involvement of key individuals could adversely affect the development of the Sbarter protocol, the implementation of its strategic roadmap, or the coordination of ecosystem activities.

4. Legal Form and Regulatory Risk (Swiss Association)

Sbarter Association is established as a Swiss association pursuant to Articles 60–79 of the Swiss Civil Code. This legal form imposes certain governance and operational constraints, including member participation and voting requirements for significant organizational decisions.

Changes to applicable Swiss law governing associations, or changes to the interpretation of such laws by competent authorities, could affect the governance structure or operational framework of Sbarter Association.

Sbarter Association is based in Switzerland and is subject to applicable Swiss legal and regulatory frameworks, including financial market regulations where relevant. Although the SBT token has been structured with the intention of complying with applicable regulatory requirements, future regulatory developments or reinterpretations by Swiss authorities, including FINMA, could affect the regulatory treatment of the SBT token or the activities of Sbarter Association.

Any such regulatory changes could require modifications to the operational structure of the ecosystem or could otherwise affect the activities of the Association.

The SBT token is a crypto-asset with no enforceable obligations or financial claims against Sbarter Association or any third party. Its value and the ability for SBT holders to make use of the SBT’s functionalities are dependent on network adoption, platform development, and ecosystem growth, rather than intrinsic financial guarantees.

1. Market & Liquidity Risk

The price of the SBT token is subject to market fluctuations, market sentiment and trading activity , and macroeconomic factors. There is no guarantee of sustained liquidity or that an active secondary market will remain stable.

2. Blockchain & Transaction Risk

The SBT token operates on Solana, making it subject to Solana gas fees, network congestion, and potential disruptions, which may impact transaction costs and settlement times.

3. Smart Contract & Security Risks

As an on-chain asset, the SBT token relies on smart contract functionality, which may be exposed to vulnerabilities, exploits, or unforeseen technical failures.

4. Regulatory Risk

Changes in crypto regulations, taxation, or trading laws could impact the availability, usability, or trading conditions of the SBT token in different jurisdictions.

Regulatory and Legal Risk

The Sbarter project operates in a legally sensitive environment spanning crypto-assets, platform operations, consumer protection, AML/KYC compliance, advertising restrictions, and the regulation of skill-based digital competitions.

The legal treatment of skill-based digital challenges, crypto-assets, and related application-layer services differs across jurisdictions and may change or be reinterpreted over time. Only challenge formats assessed as lawful for the relevant market may be made available, and certain jurisdictions, games, or features may be restricted or excluded.

Sbarter Ltd. and Sbarter Association have obtained jurisdiction-specific legal analyses for selected markets and continue to monitor legal and regulatory developments. Swiss counsel has analysed the current SBT structure, and prior correspondence with FINMA exists in relation to earlier project iterations.

However, no assurance can be given that competent authorities, including Swiss authorities, will maintain the same interpretation for the current or future structure, or that future changes in law, guidance, or enforcement practice will not require modifications to the project or restrict operations in one or more jurisdictions.

The following risks relate to the technology underlying the Sbarter protocol and SBT:

1. Blockchain and Smart Contract Risk

The Sbarter protocol relies on smart contracts deployed on the Solana blockchain for the locking and automated redistribution of SBT in connection with skill-based challenges and for the enforcement of vesting schedules. Smart contracts, once deployed, are generally immutable and execute automatically without human intervention. Any errors, vulnerabilities, or unintended behaviors in the smart contract code could result in the loss of funds, incorrect challenge settlements, or exploitation by malicious actors.

The Sbarter smart contract and vesting program have been audited by CertiK, a leading blockchain security firm. However, a security audit does not guarantee the complete absence of vulnerabilities, and previously undetected errors or novel attack vectors may be identified following deployment. Sbarter Ltd. and Sbarter Association cannot guarantee that the smart contracts will operate free of error in all circumstances.

2. Solana Blockchain Risk

SBT is deployed on the Solana blockchain. The availability and performance of the Sbarter protocol are therefore dependent on the continued operation, security, and stability of the Solana network. The Solana network has experienced periods of degraded performance and outages in the past. Any future network outages, forks, protocol upgrades, or security incidents affecting the Solana blockchain could disrupt the operation of the Sbarter protocol, delay challenge settlements, or prevent token transfers.

Sbarter Ltd. and Sbarter Association have no control over the development or governance of the Solana blockchain and cannot guarantee its continued availability or performance.

3. Oracle and Data Integrity Risk

The Sbarter protocol relies on video game providers acting as oracles to submit verified challenge outcome data to the smart contracts. The accuracy and integrity of challenge settlements depend on the reliability and honesty of these oracles. Any failure, manipulation, or compromise of the oracle function, whether through technical error, dishonest conduct, or external attack, could result in incorrect challenge settlements and loss of funds for participants.

The Sbarter protocol has been designed to ensure that video game providers act exclusively as technical data submitters with no economic interest in challenge outcomes. However, the protocol cannot guarantee against all forms of oracle failure or manipulation.

4. Scalability and Infrastructure Risk

Rapid growth in user activity could stress the Sbarter platform's infrastructure, potentially leading to service degradation, downtime, or delayed transaction processing. The platform's Web3 components rely on the Solana blockchain, which provides high throughput and low latency. Web2 infrastructure is hosted on Amazon Web Services (AWS), providing on-demand scalability and global availability. Backend systems are designed with redundancy and load-balancing capabilities, and the architecture is modular to support progressive integration with additional video game providers.

However, no infrastructure design can guarantee uninterrupted availability under all operating conditions. Unexpected demand spikes, AWS service disruptions, or unforeseen technical failures could adversely affect the user experience and platform reliability.

5. Cybersecurity Risk

The Sbarter platform, its backend infrastructure, and the wallets and private keys of participants are potential targets for cyberattacks, including hacking, phishing, distributed denial-of-service attacks, and social engineering. A successful attack could result in loss of funds, theft of user data, or disruption of platform operations. While Sbarter Ltd. has implemented security measures within its infrastructure, no cybersecurity framework can provide absolute protection against all attack vectors.

6. Private Key and Wallet Risk

Participation in the Sbarter protocol requires the use of a non-custodial Solana-compatible wallet. The security of a participant's SBT tokens is dependent on the security of their private keys and seed phrases. Sbarter Ltd. and Sbarter Association have no ability to recover lost or stolen private keys. Loss of access to a wallet, whether through loss of private keys, hardware failure, or theft, may result in the permanent loss of SBT tokens.

7. Technology Obsolescence Risk

The blockchain and crypto-asset technology landscape is evolving rapidly. Technologies, protocols, and standards that are currently considered best practice may become outdated or be superseded by superior alternatives. There is no guarantee that the Sbarter protocol will remain technologically competitive over its intended operational lifetime, or that Sbarter Ltd. and Sbarter Association will have the resources to upgrade the protocol in response to technological developments.

Governance concentration

Two-phase governance model, voting concentration limits, and eligibility-based governance within Sbarter Association are designed to reduce concentration over time; however, no mitigation can eliminate concentration risk entirely during early phases.

Financial dependency

Private placement proceeds, treasury planning, reserve allocations, and structured vesting schedules are intended to support development over a multi-year horizon; however, additional funding may still be required.

Key person risk

Operational, technical, and governance responsibilities are distributed across multiple persons and entities, and the governance framework is intended to reduce reliance on any single individual over time.

Regulatory and legal risk

Jurisdiction-specific legal analyses have been obtained for selected markets, regulatory developments are monitored on an ongoing basis, and product availability may be restricted by market, game, format, or user category where required by law or compliance considerations.

Market adoption risk

The protocol is designed for API-based integration without requiring changes to core gameplay, with low integration friction and no commitment by video game providers to adopt the protocol at scale.

Token demand and valuation risk

SBT is designed as the native token of the Sbarter protocol, with vesting and lock-up structures intended to moderate supply release; however, market price and liquidity remain entirely dependent on user adoption and secondary-market conditions.

Fraud and verification risk

KYC/AML controls, fraud detection tools, transparent on-chain settlement, and dispute-handling procedures are intended to reduce fraud risk, but cannot eliminate it completely.

Competition risk

The project seeks differentiation through skill-based challenge architecture, authenticated result submission, and deterministic settlement, but faces competition from both traditional and blockchain-based alternatives.

Smart contract risk

Security reviews and audits may be conducted prior to or following deployment, and code architecture is intended to reduce operational vulnerabilities; however, no audit or code review can guarantee the absence of defects or exploits.

Solana blockchain risk

Solana has been selected for throughput, latency, and ecosystem compatibility, but Sbarter remains dependent on the continued availability, performance, and governance of the underlying Solana network.

Oracle integrity risk

VGPs are structured as technical data submitters only, with deterministic on-chain settlement logic and no intended economic participation in challenge outcomes, but incorrect or compromised data inputs may still affect settlements.

Scalability and infrastructure risk

The application-layer infrastructure uses modular architecture, redundancy, load-balancing, and scalable hosting arrangements, but unexpected demand spikes or third-party outages may still impair service availability.

Cybersecurity risk

Security measures, infrastructure monitoring, access controls, and periodic security reviews are intended to reduce cybersecurity risk but cannot provide absolute protection against all attack vectors.

Private key risk

Users are required to use non-custodial wallets and remain solely responsible for safeguarding private keys, seed phrases, and wallet access credentials. Neither Sbarter Association nor Sbarter Ltd. can recover lost credentials.

Technology obsolescence risk

The protocol architecture is intended to remain modular and upgradeable at the application layer, but technological change may still reduce competitiveness or require significant future adaptations.

Sbarter Ltd.

984500947BA6N54CE210

SBT

Solana uses Proof-of-Stake with Tower BFT and Proof-of-History, where leaders are pre-selected by stake and transactions, including SBT transfers, receive sub-second confirmation and high throughput.

The Sbarter protocol relies on a combination of token-based incentives, vesting mechanisms, and network-level fees to secure transactions and promote long-term, aligned participation.

SBT tokens allocated to participants, including strategic counterparties, team members, and ecosystem contributors, are subject to defined cliff and vesting schedules, which incentivise sustained engagement and reduce short-term speculative behaviour. Governance participation is further incentivised through token-locking mechanisms, whereby eligible members may increase their governance influence by locking SBT tokens for extended periods, aligning decision-making power with long-term commitment to the protocol.

Protocol transactions, including challenge entry, escrow, settlement, and governance interactions, are executed via smart contracts deployed on the Solana blockchain. As such, users incur standard Solana network transaction fees, which incentivise validators to process transactions and secure the underlying network. The Sbarter protocol itself does not impose additional protocol-level transaction fees on SBT transfers.

Where applicable, oracle fees payable in SBT compensate Video Game Providers acting as independent result verifiers, ensuring accurate outcome reporting and the integrity of challenge settlement. Any fees associated with fiat conversion or secondary market trading arise from independent third-party on-ramp providers or decentralised exchanges and are external to the protocol.

2026-01-01

2026-08-14

Data provided by the MiCA Crypto Alliance as a third party, with no deviations from the calculation guidance of Commission Delegated Regulation (EU) 2025/422, Article 6(5).
Full methodology available at: http://micacryptoalliance.com/methodologies/esg

Data provided by the MiCA Crypto Alliance as a third party, with no deviations from the calculation guidance of Commission Delegated Regulation (EU) 2025/422, Article 6(5).

As the token studied does not have activity at the time of the study, its energy intensity is approximated through the calculation of a market cap-weighted average of the peer crypto asset activities, compared to the SBT's market capitalisation estimated through the product of its issue price and total supply. The peer group is defined as other SPL tokens whose market capitalisation falls within ±25% of SBT's market cap at issue are included, to ensure only similar peers are used for estimations.

Full methodology available at: http://micacryptoalliance.com/methodologies/esg

Data provided by the MiCA Crypto Alliance as a third party, with no deviations from the calculation guidance of Commission Delegated Regulation (EU) 2025/422, Article 6(5).
Full methodology available at: http://micacryptoalliance.com/methodologies/esg

Land use: 1.85125 m²

Data provided by the MiCA Crypto Alliance as a third party, with no deviations from the calculation guidance of Commission Delegated Regulation (EU) 2025/422, Article 6(5).
Full methodology available at: http://micacryptoalliance.com/methodologies/esg

Data provided by the MiCA Crypto Alliance as a third party, with no deviations from the calculation guidance of Commission Delegated Regulation (EU) 2025/422, Article 6(5).
As the token studied does not have activity at the time of the study, its carbon intensity per transaction is approximated through the calculation of a market cap-weighted average of the peer crypto asset activities, compared to the SBT's market capitalisation estimated through the product of its issue price and total supply. The peer group is defined as other SPL tokens whose market capitalisation falls within ±25% of SBT's market cap at issue are included, to ensure only similar peers are used for estimations.
Full methodology available at: http://micacryptoalliance.com/methodologies/esg

Data provided by the MiCA Crypto Alliance as a third party, with no deviations from the calculation guidance of Commission Delegated Regulation (EU) 2025/422, Article 6(5). As the base layer is a decentralised network, estimates on individual node weight, hazardous components and depreciation rate are used.
As the token studied does not have activity at the time of the study, its waste intensity is approximated through the calculation of a market cap-weighted average of the peer crypto asset activities, compared to the SBT's market capitalisation estimated through the product of its issue price and total supply. The peer group is defined as other SPL tokens whose market capitalisation falls within ±25% of SBT's market cap at issue are included, to ensure only similar peers are used for estimations.
Full methodology available at: http://micacryptoalliance.com/methodologies/esg

Data provided by the MiCA Crypto Alliance as a third party, with no deviations from the calculation guidance of Commission Delegated Regulation (EU) 2025/422, Article 6(5). Usage of natural resources is approximated through land use metrics. Land use, water use and water recycling are calculated based on energy mix-specific estimates of purchased electricity land intensity, purchased electricity water intensity, and water recycling rates.
As the token studied does not have activity at the time of the study, its land intensity and waste intensity are approximated through the calculation of a market cap-weighted average of the peer crypto asset activities, compared to the SBT's market capitalisation estimated through the product of its issue price and total supply. The peer group is defined as other SPL tokens whose market capitalisation falls within ±25% of SBT's market cap at issue are included, to ensure only similar peers are used for estimations.
Full methodology available at: http://micacryptoalliance.com/methodologies/esg