Policy for implementing the obligation to provide information on sustainability indicators relating to adverse climate impacts and other adverse environmental impacts

14/11/2025
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1. Foreword

BITSTACK SAS, having its registered office at Pepiniere Michel Caucik 100 Impasse des Houillères - Le Pontet, 13590 Meyreuil, (France), registered with the Aix-en-Provence Trade and Companies Register under the number 899 125 090 (“BITSTACK”) and registered with the French Financial Markets Authority (“AMF”) as a Digital Asset Service Provider (“DASP”) in accordance with Article 62 of Regulation 2023/1114 of 31 May 2023 on markets in crypto-assets (“MiCA”) under the number A2025-003 since 30 June 2025 for the provision of the following services:

• the safekeeping and administration of crypto-assets on behalf of customers; (Article 3 (16) (a) MiCA), i.e. "the custody or control, on behalf of customers, of crypto-assets or the means of access to these crypto-assets, where appropriate in the form of private cryptographic keys".

the exchange of crypto-assets for funds; (Article 3 (16) (b) MiCA), namely "the management of one or more multilateral systems, which bring together or facilitate the meeting of multiple buying and selling interests expressed by third parties for crypto-assets, within the system and in accordance with its rules, in a manner that results in a contract, either through the exchange of crypto-assets for funds or by the exchange of crypto-assets for other crypto-assets".

the exchange of crypto-assets for other crypto-assets; (Article 3 (16) (d) MiCA), i.e. "the conclusion, with customers, of contracts for the purchase or sale of crypto-assets for funds, using equity capital;".

the execution of orders on crypto-assets on behalf of customers: (Article 3 (16) (e) MiCA), i.e. "the conclusion, on behalf of customers, of agreements to buy or sell one or more crypto-assets, or the subscription, on behalf of customers, of one or more crypto-assets, including the conclusion of contracts for the sale of crypto-assets at the time of their public offering or admission to trading".

the service of transferring crypto-assets on behalf of customers (Article 3 (16) (e) MiCA) i.e. “ providing services transferring, on behalf of a natural or legal person, crypto-assets from one address or a distributed ledger account to another”.

The purpose of the policy for implementing the obligation to provide information on sustainability indicators relating to adverse climate impacts and other adverse environmental impacts (the “Policy”) is to ensure BITSTACK's compliance with its obligations to provide information on sustainability indicators relating to adverse climate impacts and other adverse environmental impacts.

The Policy is established in accordance with Commission Delegated Regulation (EU) 2025/422 of 17 December 2024 supplementing Regulation (EU) 2023/1114 of the European Parliament and of the Council with regard to regulatory technical standards specifying the content, methods of preparation and reporting on sustainability indicators relating to adverse climate impacts and other adverse environmental impacts (the “Delegated Regulation”).

The Policy is the responsibility of the Compliance Director and is reviewed annually.

Hereinafter in the Policy, the services provided by BITSTACK as a DASP are collectively referred to as the “Services”.

2. Introduction

BITSTACK communicates various information to its customers (the “Customers”) with respect to the Services provided through its website available at https://www.bitstack-app.com/ (the “Website”). In accordance with Article 66 (5) of the MiCA Regulations, BITSTACK makes available to the Customers, through the Website, information relating to the main adverse climate impacts and other adverse environmental impacts of the consensus mechanism used to issue each crypto-asset offered by BITSTACK in connection with the provision of the Services (the “Information”).

3. Obligation to provide Information

The Information is made available on the Website free of charge.

The Information is made available as a downloadable file and presented in a way that makes it easy to read, by using characters of a sufficient size and a writing style that facilitates understanding and is conducive to comparing information related to each of the crypto-assets for which BITSTACK provides its Services.

The date of publication of the Information and the date of the last review or update are clearly indicated on the Website.

The Information will be published in French and in English on the Website and the Application.

4. Content and format for making the Information available

The Information is published on the Website in accordance with the format provided for in Article 5 of the Delegated Regulation and reproduced in Appendix 1 of the Policy.

In the event that, for a given crypto-asset, the annual energy consumption declared in the table presented in Appendix 1, field S.8, exceeds 500,000 kilowatt-hours, the Information is also supplemented by the table reproduced in Appendix 2 of the Policy in accordance with Article 5 (2) of the Delegated Regulation.

Where appropriate and by decision of the Compliance Director, BITSTACK may make available to the public, on the Website, information on one or more of the optional indicators referred to in Table 4 of the Appendix to the Delegated Regulation, according to the format indicated therein. If such information is provided, the corresponding information on the sources and methods provided in this table shall also be provided.

The Information also includes the items referred to in Article 6 of the Delegated Regulation, including the items relating to "Sources and methods".

5. Internal procedure for publishing and verifying information

BITSTACK shall review and update the Information regularly, and at least once a year. In the event of significant changes, the Information shall be updated without undue delay and the changes made shall be clearly highlighted.

The update of the Information is carried out by the Compliance Director.

6. Annexes

Appendix 1 - Mandatory information on the main adverse climate impacts and other adverse environmental impacts of the consensus mechanism

Appendix 2 - Additional information on the main adverse climate impacts and other adverse environmental impacts of the consensus mechanism

Bitstack SAS, a company registered with the Aix-en-Provence Trade and Companies Register under number 899 125 090 and operating under the trade name Bitstack, is licenced as an agent of Xpollens — an electronic money institution authorized by the ACPR (CIB 16528 – RCS Nanterre no. 501586341, 110 Avenue de France, 75013 Paris) — with the Autorité de Contrôle Prudentiel et de Résolution (ACPR) under number 747088, and is also licensed as a Crypto-Assets Service Provider (CASP) with the French Financial Markets Authority (AMF) under number A2025-003 for the following activities: exchange of crypto-assets for funds, exchange of crypto-assets for other crypto-assets, execution of orders for crypto-assets on behalf of clients, providing custody and administration of crypto-assets on behalf of clients, and providing transfer services for crypto-assets on behalf of clients, with its registered office located at 100 impasse des Houillères, 13590 Meyreuil, France.

Investing in digital assets carries a risk of partial or total loss of the invested capital.
Past performance is not indicative of future results.