White Paper Report


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

	Digital Token Identifier:	HW5V1GSQ7
	Offeror or person seeking admission to trading:	9845004A4F8CFBC38A09 - Pons Labs LLC
	Type of submission:	New

Table of content
General information
SUMMARY
Part A - Information about offeror or person seeking admission to trading
Part B - Information about issuer, if different from offeror or person seeking admission to trading
Part C - Information about the operator of the trading platform in cases where it draws up the crypto-asset white paper and information about other persons drawing the crypto-asset white paper pursuant to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114
Part D - Information about other token project
Part E - Information about offer to public of other tokens or their admission to trading
Part F - Information about other tokens
Part G - Information on rights and obligations attached to other tokens
Part H – Information on underlying technology
Part I - Information on risks
Part J - Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts




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

Template for white papers for crypto-assets other than asset-referenced tokens or e-money tokens [abstract]
General information
00 Table of content	boolean true	true
01 Date of notification	date	2026-09-23
02 Statement in accordance with Article 6(3) of Regulation (EU) 2023/1114	boolean true	This crypto-asset white paper has not been approved by any competent authority in any Member State of the European Union. The person seeking admission to trading of the crypto-asset is solely responsible for the content of this crypto-asset white paper.
03 Compliance statement in accordance with Article 6(6) of Regulation (EU) 2023/1114	boolean true	This crypto-asset white paper complies with Title II of Regulation (EU) 2023/1114 of the European Parliament and of the Council and, to the best of the knowledge of the management body, the information presented in the crypto-asset white paper is fair, clear and not misleading and the crypto-asset white paper makes no omission likely to affect its import.
04 Statement in accordance with Article 6(5), points (a), (b), (c), of Regulation (EU) 2023/1114	boolean true	The crypto-asset referred to in this crypto-asset white paper may lose its value in part or in full, may not always be transferable and may not be liquid
05 Statement in accordance with Article 6(5), point (d), of Regulation (EU) 2023/1114	boolean true	Not applicable
06 Statement in accordance with Article 6(5), points (e) and (f), of Regulation (EU) 2023/1114	boolean true	The crypto-asset referred to in this white paper is not covered by the investor compensation schemes under Directive 97/9/EC of the European Parliament and of the Council or the deposit guarantee schemes under Directive 2014/49/EU of the European Parliament and of the Council.
SUMMARY
07 Warning in accordance with Article 6(7), second subparagraph, of Regulation (EU) 2023/1114	boolean true	Warning This summary should be read as an introduction to the crypto-asset white paper. The prospective holder should base any decision to purchase this crypto –asset on the content of the crypto-asset white paper as a whole and not on the summary alone. The offer to the public of this crypto-asset does not constitute an offer or solicitation to purchase financial instruments and any such offer or solicitation can be made only by means of a prospectus or other offer documents pursuant to the applicable national law. This crypto-asset white paper does not constitute a prospectus as referred to in Regulation (EU) 2017/1129 of the European Parliament and of the Council or any other offer document pursuant to Union or national law.
08 Characteristics of the crypto-asset	textBlock	PONS (the 'Token') is an ERC-20 token deployed on Robinhood Chain ('Robinhood'). The Token is the crypto-asset associated with Pons (the 'Platform'), a non-custodial token launch and trading platform on which users can create fixed-supply tokens and trade them, with each token trading in its own on-chain liquidity pool. The Token was launched on 13 July 2026 by a community member through the Platform and was subsequently adopted by the Platform as its own. The Token does not perform any governance or protocol-utility function. It serves solely as a memecoin through which holders take part in the Platform's community, including the community forum associated with the Token. Token holders can freely hold, transfer, and trade the Token through their own non-custodial wallets. The Token is deflationary. Trading of tokens launched through the Platform generates liquidity fees, a share of which the Platform retains as protocol revenue. Through the Platform's smart contract architecture, that share is automatically split, and part of it is used to buy the Token on the open market and send it to a burn address, permanently reducing the Token's circulating supply from its fixed initial supply of 1,000,000,000 units. As at the date of this whitepaper, more than 30% of the Token's total supply has been sent to the burn address and removed from circulation. Any changes to the Token's rights, obligations, or features are implemented by the Platform's team. Any such modification is communicated to the community through the Platform's official channels and documentation.
09 Further information about utility tokens	textBlock	Not applicable
10 Key information about the offer to the public or admission to trading	textBlock	Pons Labs LLC (the 'Person Seeking Admission to Trading') is seeking admission to trading of the Token across multiple trading platforms within the European Union, which have been outlined in greater detail within E.33 of this whitepaper. This approach is structured around second market facilitation rather than primary issuance. No public offering will accompany the trading platform admissions. The focus is rather on promoting market liquidity and price discovery mechanisms for the Token.
Part A - Information about offeror or person seeking admission to trading
A.1 Name	text	Pons Labs LLC
A.2 Legal form	text	Limited Liability Company
A.3 Registered address
Registered addess	text	1521 Concord Pike Suite 201 Wilmington DE 19803
Country	enumeration	United States of America
Sub-division	text	US-DE
A.4 Head office
Head office	text	1521 Concord Pike Suite 201 Wilmington DE 19803
Country	enumeration	United States of America
Sub-division	text	US-DE
A.5 Registration date	date	2026-07-15
A.6 Legal entity identifier	LEI	9845004A4F8CFBC38A09
A.7 Another identifier required pursuant to applicable national law	text	10699059
A.8 Contact telephone number	text	+1 301 852 1200
A.9 E-mail address	text	Carl@ponsfamily.com
A.10 Response time (days)	integer	10
A.11 Parent company	text	Not applicable
A.12 Members of the management body
Member #1	id	1
Identity	text	Ozan Aydin
Business address	text	1521 Concord Pike Suite 201 Wilmington DE 19803, United States of America
Function	text	Director - CEO - Co-founder
Member #2	id	2
Identity	text	Matthew Gergen
Business address	text	1521 Concord Pike Suite 201 Wilmington DE 19803, United States of America
Function	text	Director- COO - Co-founder
A.13 Business activity	textBlock	The Person Seeking Admission to Trading is responsible for the development and operation of the Platform. It adopted the Token as the Platform's memecoin and administers the buyback-and-burn mechanism through which the Token's circulating supply is progressively reduced. Additionally, it is responsible for entering into exchange and market-making agreements for the Token.
A.14 Parent company business activity	textBlock	Not applicable
A.15 Newly established	boolean	true
A.16 Financial condition for the past three years	textBlock	Not applicable
A.17 Financial condition since registration	textBlock	Since its registration, the Person Seeking Admission to Trading has been engaged in the development and operation of the Platform, which it has funded on a bootstrapped, self-financed basis without recourse to external investment, and from which it derives operating revenue through the share of trading fees that the Platform retains as protocol revenue in respect of tokens launched through it. Additionally, it raised no proceeds from the launch of the Token, which a community member fair-launched from a zero starting supply and which the Person Seeking Admission to Trading subsequently adopted. The Person Seeking Admission to Trading is financially sound and profitable, and no material adverse change in its financial condition has occurred since the date of its registration.
Part B - Information about issuer, if different from offeror or person seeking admission to trading
B.1 Issuer different from offerror or person seeking admission to trading	boolean	true
B.2 Name	text	The Token was launched by a community member on 13 July 2026 through the Platform. Later on, the Platform adopted the Token as its own. Therefore, no issuing entity can be determined in a formal legal sense.
B.3 Legal form	text	Given the explanation provided on B.2, the Token's issuer does not have a legal form as referred to in Article 6(1)(b) of Regulation (EU) 2023/1114.
B.4 Registered address
Registered addess	text	Given the explanation given in field B.3, the crypto-asset issuer does not have a registered address. The country indicated is that of the Person Seeking Admission to Trading, which adopted the Token, and is included solely because the field is required in the machine-readable version of this whitepaper.
Country	enumeration	United States of America
Sub-division	text	Not applicable
B.5 Head office
Head office	text	As no issuing entity can be determined in a formal legal sense as of the date of this white paper, no head office address can be specified. The country indicated is that of the Person Seeking Admission to Trading, which adopted the Token, and is included solely because the field is required in the machine-readable version of this whitepaper.
Country	enumeration	United States of America
Sub-division	text	Not applicable
B.6 Registration date	date	0001-01-01
B.7 Legal entity identifier	LEI
B.8 Another identifier required pursuant to applicable national law	text	Not applicable
B.9 Parent company	text	Given the explanation provided on B.3, no parent company can be specified.
B.10 Members of the management body
Member #1	id	1
Identity	text	Given the explanation provided on B.3, no management body can be specified.
Business address	text	Not applicable
Function	text	Not applicable
B.11 Business activity	textBlock	Given the explanation provided on B.3, no business activity can be specified.
B.12 Parent company business activity	textBlock	Given the explanation provided on B.3, no parent company business activity can be specified.
Part C - Information about the operator of the trading platform in cases where it draws up the crypto-asset white paper and information about other persons drawing the crypto-asset white paper pursuant to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114
C.1 Name	N/A		.
C.2 Legal form	N/A		.
C.3 Registered address
Registered address	N/A		.
Country	N/A		.
Sub-division	N/A		.
C.4 Head office
Head office	N/A		.
Country	N/A		.
Sub-division	N/A		.
C.5 Registration date	N/A		.
C.6 Legal entity identifier	N/A		.
C.7 Another identifier required pursuant to applicable national law	N/A		.
C.8 Parent company	N/A		.
C.9 Reason for crypto-asset white paper preparation	N/A		.
C.10 Members of the management body
Member #1	N/A		.
Identity	N/A		.
Business address	N/A		.
Function	N/A		.
C.11 Operator business activity	N/A		.
C.12 Parent company business activity	N/A		.
C.13 Other persons drawing up the crypto-asset white paper according to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114	N/A		.
C.14 Reason for drawing the white paper by persons referred to in Article 6(1), second subparagraph, of Regulation (EU) 2023/1114	N/A		.
Part D - Information about other token project
D.1 Crypto-asset project name	text	Pons
D.2 Crypto-asset name	text	Pons
D.3 Abbreviation	text	PONS
D.4 Crypto-asset project description	textBlock	The Platform is a non-custodial token launch and trading platform deployed on Robinhood. It enables users to create fixed-supply tokens and trade them, with each token ultimately trading in its own on-chain liquidity pool. The Platform does not take custody of user funds; every launch and trade is executed as a transaction submitted from the user's own wallet. The Platform has been released in two versions, a first version ('V1') and a subsequent second version ('V2'), both of which remain in use, with tokens launched under V1 continuing to rely on V1 mechanisms. Under V1, the creation of a token deploys the token and its trading pool in a single transaction; each token is minted with a fixed supply of 1,000,000,000 units, its liquidity pool goes live in the same transaction, and the pool's liquidity is locked automatically. Each V1 token trades against wETH in its own pool, and a token 'graduates' (a status change only) once the wETH paired in its pool reaches a set threshold, which defaults to 4.2 ETH. Trading generates liquidity fees, of which 70% is paid to the token's creator, as its developer and deployer, and the remainder is retained by the Platform as its protocol share; of that share, the Platform directs 80% towards buying the Token on the open market and sending it to a burn address. The split and distribution of these fees are automatically handled by the Platform's smart contract architecture. Under V2, the entire token supply is instead placed on a bonding curve that holds the supply, quotes a price, and both sells and buys back the token, with the price rising as more of the supply is bought. Once the curve sells out, the token graduates and a Uniswap V4 pool is created from the proceeds, with its liquidity permanently locked. V2 additionally allows a creator to pair a launch against an approved asset other than ETH and to set an optional creator tax on trading in the token, applies a decaying opening buy tax to deter front-running of a launch, and supports migration, a mechanism enabling an active community to move an abandoned external token onto a new replacement token in a fresh Platform pool. Trading under V2 is subject to the same fee split as under V1 and likewise funds the buyback-and-burn of the Token through the Platform's protocol share, with the optional creator tax applying in addition. The Platform is complemented by two further sections: Memestock, the Platform's community forum in which every launched token has an associated community, and Analytics, a page providing independent on-chain reporting on the Platform's markets. The community takeover is a further mechanism that applies where a token launched on the Platform is abandoned by its creator: an active community may assume the creator's role, which redirects the creator's entitlement to trading fees to that community without altering the token, its supply, or its locked liquidity. The Token itself was launched through V1 and later adopted by the Platform; within this architecture, its role is that of the Platform's memecoin and the asset targeted by the buyback-and-burn mechanism. The Platform does not rely on a token-based or otherwise decentralised governance. Administrative decisions, such as the review and approval of such community takeovers, are taken by the Platform's team, and the Token carries no voting or governance rights.
D.5 Details of all natural or legal persons involved in implementation of crypto-asset project
Person #1	id	1
Type of person	enumeration	Development team
Name of person	text	Ozan Aydin
Business address of person	text	1521 Concord Pike Suite 201 Wilmington DE 19803.
Domicile of company	enumeration	United States of America
D.6 Utility token classification	boolean	false
D.7 Key features of goods or services for utility token projects	text	Not applicable
D.8 Plans for the token
Description of past milestones	textBlock	The Platform was launched on Robinhood. On 13 July 2026, the Token was launched as an ERC-20 token on Robinhood by a community member through V1 of the Platform, being minted with a fixed supply of 1,000,000,000 units and paired into a wETH-denominated liquidity pool whose liquidity was locked at launch. The Platform subsequently adopted the Token as its own. The Token has since graduated, its pool having passed the graduation threshold, and continues to trade in that same pool. The Platform also released its V2, introducing the bonding-curve launch model, custom pairing assets, opening snipe protection, and token migration. As at the date of this whitepaper, more than 30% of the Token's total supply has been sent to the burn address.
Description of future milestones	textBlock	Rendering the buyback-and-burn mechanism immutable and decentralised. Continued reduction of the Token's circulating supply through the ongoing buyback-and-burn mechanism.
D.9 Resource allocation	text	Not applicable
D.10 Planned use of collected funds or other tokens	text	The Person Seeking Admission to Trading did not collect any funds or other crypto-assets in connection with the Token, which was fair-launched by a community member with no proceeds raised. The operating revenue that the Platform derives from its retained share of trading fees is applied to the continued development of the Platform and to the support of its community.
Part E - Information about offer to public of other tokens or their admission to trading
E.1 Public offering or admission to trading	enumeration	Admission to trading
E.2 Reasons for public offer or admission to trading	textBlock	The Person Seeking Admission to Trading is seeking admission to trading of the Token across multiple trading platforms within the European Union, which have been outlined in greater detail within E.33 of this whitepaper. This approach is structured around second market facilitation rather than primary issuance. No public offering will accompany the trading platform admissions. The focus is rather on promoting market liquidity and price discovery mechanisms for the Token.
E.3 Fundraising target
Target expressed in currency	monetary	0	EUR
Target expressed in units	decimal	0
Target expressed in digital token identifier	text	Not applicable
E.4 Minimum subscription goals
Goals expressed in currency	monetary	0	EUR
Goals expressed in units	decimal	0
Goals expressed in digital token identifier	text	Not applicable
E.5 Maximum subscription goals
Goasl expressed in currency	monetary	0	EUR
Goals expressed in units	decimal	0
Goals expressed in digital token identifier	text	Not applicable
E.6 Oversubscription acceptance	boolean	false
E.7 Oversubscription allocation	text	Not applicable
Issue price details
E.8 Issue price	decimal	0
E.9 Official currency determining issue price	enumeration
E.9 Any other tokens determining issue price	text	Not applicable
E.10 Subscription fee
Fee expressed in currency	monetary	0	EUR
Fee expressed in units	decimal	0
Fee expressed in digital token identifier	text	Not applicable
E.11 Offer price determination method	text	Not applicable
E.12 Total number of offered or traded other tokens	integer	684320736
E.13 Targeted holders	enumeration	All types of investors
E.14 Holder restrictions	text	The purchase of the Token from EU-regulated Exchanges will be available to all users of such Exchanges. Most trading and exchange services offered by Exchanges are open to retail holders, and may be subject to the compliance requirements of the respective Exchange. The Exchanges may impose restrictions on holders of Tokens on their respective Exchanges, in accordance with applicable laws and internal policies.
E.15 Reimbursement notice	boolean true	Not applicable
E.16 Refund mechanism	textBlock	Not applicable
E.17 Refund timeline	text	Not applicable
E.18 Offer phases	textBlock	Not applicable
E.19 Early purchase discount	textBlock	Not applicable
E.20 Time-limited offer	boolean	false
E.21 Subscription period beginning	date
E.22 Subscription period end	date
E.23 Safeguarding arrangements for offered funds or other tokens	textBlock	Not applicable
E.24 Payment methods for other token purchase	textBlock	Not applicable
E.25 Value transfer methods for reimbursement	textBlock	Not applicable
E.26 Right of withdrawal	textBlock	Not applicable
E.27 Transfer of purchased other tokens	textBlock	Not applicable
E.28 Transfer time schedule	text	Not applicable
E.29 Purchaser's technical requirements	textBlock	Technical requirements will be specified by the exchange and may include the following: A compatible digital wallet or account on supported exchanges; Internet access; A device (computer or mobile) to manage a digital wallet/private key and/or account on an exchange to carry out transactions
Other token services provider characteristics
E.30 Other token service provider (CASP) name	text	Not applicable
E.31 CASP identifier	LEI
E.32 Placement form	enumeration	Not applicable
Trading platforms characteristics
E.33 Trading platforms name	text	The Person Seeking Admission to Trading is seeking admission to trading of the Token on several Exchanges, including but not limited to the following: - Kraken - Gate.io - OKX - Crypto.com - MEXC - Poloniex
E.34 Trading platforms market identifier code (MIC)	text	Not applicable
E.35 Trading platforms access	text	The Exchanges are accessible via their respective websites.
E.36 Involved costs	textBlock	The use of services offered by Exchanges may involve costs, including transaction fees, withdrawal fees, and other charges. These costs are determined and set by the respective Exchanges and are not controlled, influenced, or governed by the Person Seeking Admission to Trading. Consequently, any changes to fee structures or the introduction of new costs are solely at the discretion of these platforms.
E.37 Offer expenses	textBlock	Not applicable
E.38 Conflicts of interest	textBlock	Not applicable
E.39 Applicable law	textBlock	The laws of Delaware, United States of America
E.40 Competent court	textBlock	The competent courts of Delaware, United States of America
Part F - Information about other tokens
F.1 Crypto-asset type	text	The Token is classified as a "crypto-asset other than asset-referenced token or e-money token" under Title II of the Markets in Crypto-Assets Regulation (EU) 2023/1114.
F.2 Other token functionality	textBlock	According to the article 3(1)(5) of MiCA, a crypto-asset is a digital representation of a value or of a right that is able to be transferred and stored electronically using distributed ledger technology or similar technology. As reminded by the European Banking Authority ("EBA"), the term 'right' should be interpreted broadly in accordance with recital (2) of MiCA. The Token qualifies as a crypto-asset within the meaning of MiCA, as it is a digital representation of value that allows its holders to participate in the Platform's community as a memecoin. The Token can be transferred and stored using the distributed ledger technology ("DLT"). The Token facilitates Token holders' interaction with the Platform by displaying the following functionalities: - Community participation: the Token enables its holders to take part in the Platform's community, including the community forum associated with the Token.
F.3 Planned application of functionalities	textBlock	The Token's sole functionality is already available to its holders.
A description of the characteristics of the other token, including the data necessary for classification of the crypto-asset white paper in the register referred to in Article 109 of Regulation (EU) 2023/1114, as specified in accordance with paragraph 8 of that Article
F.4 Type of crypto-asset white paper	enumeration	Other crypto-asset token white paper
F.5 Type of submission	enumeration	New
F.6 Other token characteristics	textBlock	The Token is an ERC-20 token deployed on Robinhood. The Token is the crypto-asset associated with the Platform, a non-custodial token launch and trading platform on which users can create fixed-supply tokens and trade them, with each token trading in its own on-chain liquidity pool. The Token was launched on 13 July 2026 by a community member through the Platform and was subsequently adopted by the Platform as its own. The Token does not perform any governance or protocol-utility function. It serves solely as a memecoin through which holders take part in the Platform's community, including the community forum associated with the Token. Token holders can freely hold, transfer, and trade the Token through their own non-custodial wallets. The Token is deflationary. Trading of tokens launched through the Platform generates liquidity fees, a share of which the Platform retains as protocol revenue. Through the Platform's smart contract architecture, that share is automatically split, and part of it is used to buy the Token on the open market and send it to a burn address, permanently reducing the Token's circulating supply from its fixed initial supply of 1,000,000,000 units. As at the date of this whitepaper, more than 30% of the Token's total supply has been sent to the burn address and removed from circulation. Any changes to the Token's rights, obligations, or features are implemented by the Platform's team. Any such modification is communicated to the community through the Platform's official channels and documentation.
F.7 Commercial name or trading name	text	PONS
F.8 Website of the issuer	text	Not applicable
F.9 Starting date of offer to the public or admission to trading	date	2026-10-23
F.10 Publication date	date	2026-10-22
F.11 Any other services provided by the issuer	textBlock	Not applicable
F.12 Language or languages of white paper	text	English
F.13 Digital token identifier code used to uniquely identify the crypto-asset or each of the several crypto assets to which the white paper relates, where available	text	HW5V1GSQ7
F.14 Functionally fungible group digital token identifier, where available	text	F5V1Z6TC2
F.15 Voluntary data flag	boolean	false
F.16 Personal data flag	boolean	true
F.17 LEI eligibility	boolean	true
F.18 Home member state	enumeration	Malta
F.19 Host member states #1	enumerationSet	Austria
F.19 Host member states #2	enumerationSet	Belgium
F.19 Host member states #3	enumerationSet	Bulgaria
F.19 Host member states #4	enumerationSet	Croatia
F.19 Host member states #5	enumerationSet	Cyprus
F.19 Host member states #6	enumerationSet	Czechia
F.19 Host member states #7	enumerationSet	Denmark
F.19 Host member states #8	enumerationSet	Estonia
F.19 Host member states #9	enumerationSet	Finland
F.19 Host member states #10	enumerationSet	France
F.19 Host member states #11	enumerationSet	Germany
F.19 Host member states #12	enumerationSet	Greece
F.19 Host member states #13	enumerationSet	Hungary
F.19 Host member states #14	enumerationSet	Iceland
F.19 Host member states #15	enumerationSet	Ireland
F.19 Host member states #16	enumerationSet	Italy
F.19 Host member states #17	enumerationSet	Latvia
F.19 Host member states #18	enumerationSet	Liechtenstein
F.19 Host member states #19	enumerationSet	Lithuania
F.19 Host member states #20	enumerationSet	Luxembourg
F.19 Host member states #21	enumerationSet	Netherlands
F.19 Host member states #22	enumerationSet	Norway
F.19 Host member states #23	enumerationSet	Poland
F.19 Host member states #24	enumerationSet	Portugal
F.19 Host member states #25	enumerationSet	Romania
F.19 Host member states #26	enumerationSet	Slovakia
F.19 Host member states #27	enumerationSet	Slovenia
F.19 Host member states #28	enumerationSet	Spain
F.19 Host member states #29	enumerationSet	Sweden
Part G - Information on rights and obligations attached to other tokens
G.1 Purchaser rights and obligations	textBlock	The Token is related to the following rights and features: - Community participation: the Token allows its holders to take part in the Platform's community.
G.2 Exercise of rights and obligations	textBlock	To exercise the rights mentioned in G.1, Token holders must: - Community participation: access the Platform's community forum and post or discuss within the community associated with the Token.
G.3 Conditions for modifications of rights and obligations	textBlock	Any changes to the Token's rights, obligations, or features are implemented by the Platform's team. Any such modification is communicated to the community through the Platform's official channels and documentation.
G.4 Future public offers	textBlock	Not applicable
G.5 Issuer retained other token	integer	0
G.6 Utility token classification	boolean	false
G.7 Key features of goods or services utility tokens	text	Not applicable
G.8 Utility tokens redemption	text	Not applicable
G.9 Non-trading request	boolean	true
G.10 Other tokens purchase or sale modalities	text	Not applicable
G.11 Other tokens transfer restrictions	text	The Exchanges may impose restrictions on holders of Tokens on their respective Exchanges, in accordance with applicable laws and internal policies.
G.12 Supply adjustment protocols	boolean	false
G.13 Supply adjustment mechanisms	text	Not applicable
Other token schemes details
G.14 Token value protection schemes	boolean	false
G.15 Token value protection schemes description	textBlock	Not applicable
G.16 Compensation schemes	boolean	false
G.17 Compensation schemes description	textBlock	Not applicable
G.18 Applicable law	textBlock	The laws of Delaware, United States of America
G.19 Competent court	textBlock	The competent courts of Delaware, United States of America
Part H – Information on underlying technology
H.1 Distributed ledger technology (DTL)	text	The Token was launched on Robinhood, an Ethereum Virtual Machine-compatible Layer 2 ('L2').
H.2 Protocols and technical standards	text	The Token was launched on Robinhood under the ERC-20 standard, guaranteeing industry-standard compatibility.
H.3 Technology used	textBlock	As an ERC-20 token, the Token was deployed as a smart contract on Robinhood. Users are able to manage the Token through their own non-custodial wallet software provided by third parties, or by directly interacting with the Token's smart contract through a third-party API.
H.4 Consensus mechanism	text	Robinhood is an L2 introduced by Robinhood Markets, Inc. and built on Arbitrum's modular L2 framework. As an L2, Robinhood has no independent consensus mechanism of its own. Transactions are executed by Robinhood's sequencer, which orders them on a first-come, first-served basis according to their time of arrival, so that no transaction can gain priority over another by paying a higher fee. The sequencer soft-confirms each transaction within sub-second latency and subsequently bundles transactions into batches, which it posts to Ethereum, the underlying layer-1 network (the 'L1'). Transaction finality is reached in stages. A transaction is first soft-confirmed by the sequencer within sub-second latency; its ordering then becomes fixed once the sequencer posts the batch to the L1; and full finality is reached when the L1 block containing that batch is finalised on Ethereum, approximately thirteen minutes after posting, at which point the transaction inherits the security of Ethereum's Proof-of-Stake ('PoS') consensus mechanism and becomes irreversible. Separately, Arbitrum's fraud-proof system imposes a seven-day challenge period on the withdrawal of assets from Robinhood back to Ethereum; that period applies to withdrawals only and is distinct from the transaction finality described above, as noted in H.5.
H.5 Incentive mechanisms and applicable fees	text	Transactions submitted to Robinhood are ordered and executed by its sequencer, which periodically bundles them into batches and posts each batch to Ethereum. By offloading transaction processing from the Ethereum mainnet in this way, Robinhood aims to achieve cost efficiency and faster finality. Transactions are ordered strictly by their time of arrival at the sequencer, on a first-come, first-served basis, so that priority cannot be obtained by paying a higher fee. Robinhood uses ETH as its native gas token, and transaction fees are denominated in ETH. Every transaction incurs two fee components: - L2 execution fee, which covers the computational cost of executing the transaction on Robinhood itself and is calculated as the gas used multiplied by the L2 gas price; this component is typically low and stable; and - L1 data fee, which covers the cost of posting the transaction's data to Ethereum for data availability. This component varies with Ethereum network congestion and is proportional to the size of the transaction's calldata. Both components are bundled into the gas that the transaction pays and are not charged separately. The movement of crypto-assets between Ethereum and Robinhood is handled by a canonical bridge that requires no third-party validators and inherits its security directly from Ethereum. A user seeking to withdraw assets from Robinhood to Ethereum must first initiate the withdrawal on Robinhood, then wait for a challenge period of seven days, a requirement of Arbitrum's fraud-proof system described in H.4, before claiming the assets through a final transaction on Ethereum, which incurs L1 gas costs.
H.6 Use of distributed ledger technology	boolean	false
H.7 DLT functionality description	textBlock	Not applicable
Other token audit details
H.8 Audit	boolean	true
H.9 Audit outcome	textBlock	As of the date of this whitepaper, the Platform's audit has not yet been completed. The outcome of the audit will be disclosed once available. Updates and details regarding the audits can be found here: https://docs.ponsfamily.com/v2#audits.
Part I - Information on risks
I.1 Offer-related risks	textBlock	The Person Seeking Admission to Trading neither operates, controls, oversees, nor manages the functioning of the Exchanges where the Token will be admitted to trading. Additionally, the Token's underlying protocol may evolve due to ongoing technical, regulatory, and industry developments. Unforeseen risks may arise, and new challenges or opportunities may necessitate changes in the Platform's strategies, goals, and structure. The risks outlined below highlight regulatory uncertainty, liquidity limitations, governance risks, network centralisation concerns, security vulnerabilities, and potential adjustments to fees or token supply that could impact the offer and trading of the Token. - Regulatory Compliance Risks: Although the Token is designed to comply with existing regulations (such as MiCA), evolving regulatory landscapes could impact its classification, trading status, or market/ community acceptance. Changes in regulatory requirements may necessitate modifications to the Platform's operation, structure, or governance. Token holders must ensure compliance with local laws, as regulatory treatment of crypto-assets varies across jurisdictions. - Market Volatility: The Token is subject to extreme price fluctuations, influenced by market speculation, investor sentiment, and broader industry trends. External factors, such as regulatory announcements or technological developments, may further contribute to volatility, potentially leading to financial losses for holders. - Liquidity Risks: The ability to buy, sell or otherwise transact Tokens depends on activity on decentralised exchanges ("DEXs") and, if applicable, centralised exchanges ("CEXs"). Limited liquidity may result in difficulties executing large trades without significant price impact, increasing the risk of loss. - Risk of Trading Platforms: When Token holders trade on Exchanges, the Person Seeking Admission to Trading does not act as a contractual party to these transactions. All legal relationships regarding these trading platforms are subject to their respective terms and conditions, with no responsibility assumed by the Person Seeking Admission to Trading for their operations, services, or outcomes. - Risk of Delisting: There is no guarantee that the Token will remain listed on any exchange. Delisting could significantly hinder the ability to trade Tokens, reducing liquidity and market value. - Risk of Bankruptcy: The Exchanges or trading platforms where the Token is listed may become insolvent or cease operations, potentially resulting in a loss of access to funds or Tokens. - Blockchain and Smart Contract Dependency: The Token relies entirely on its blockchain infrastructure. Any network downtime, congestion, security vulnerabilities, or smart contract failures could negatively impact its functionality, accessibility, or security. Additionally, the network may initially operate under a centralised or permissioned model, where specific providers or node operators manage the network. This structure presents centralisation risks, including the potential for censorship or data monetisation. - Operational Risks: Risks associated with the Token issuer/offeror's internal processes, personnel, and technologies may impact the ability to manage the Token's operations effectively. Failures in operational integrity could lead to disruptions, financial losses, or reputational damage. - Financial Risks: The Token issuer/offeror may face financial risks, including liquidity shortages, credit risks, or market fluctuations, which could affect its ability to continue operations, meet obligations, or sustain the stability and value of the Token. - Legal Risks: Uncertainties in legal frameworks, regulatory changes, potential lawsuits, or adverse legal rulings could pose significant risks, affecting the legality, usability, or value of the Token. - Fraud and Mismanagement Risks: The risk of fraudulent activity or mismanagement within the Token issuer/offeror's operations may impact the credibility of the project and the usability or value of the Token. - Reputational Risks: Negative publicity – whether due to operational failures, security breaches, or associations with illicit activities – could damage the Token issuer/offeror's reputation and, by extension, impact the value and acceptance of the Token. - Technology Management Risks: Inadequate management of technological updates or failure to keep pace with advancements may result in security vulnerabilities, inefficiencies, or obsolescence of the Token and its supporting infrastructure. - Dependency on Key Individuals: The success of the Token and its ecosystem may be highly dependent on key individuals. Loss or changes in project leadership could lead to operational disruptions, a loss of trust, or potential project failure. - Conflicts of Interest: Misalignment of interests between the Token issuer/offeror and Token holders may lead to governance decisions that are not in the best interests of the community, potentially affecting the value of the Token or damaging the credibility of the project. - Counterparty Risks: The Token issuer/offeror's reliance on external partners, service providers, and collaborators introduces risks related to non-fulfilment of obligations, which may affect the Token's operations, liquidity, or overall ecosystem stability. - Industry Competition Risks: The Token issuer/offeror faces competition from other projects, including larger and well-funded ventures that may attract more users and liquidity, potentially diminishing the viability of the Token. - Speculative Nature of the Token: Other than its role as a memecoin as described herein, the Token has no inherent utility beyond market sentiment and community-driven interest. Its value is highly speculative and subject to fluctuations based on external perceptions. - Unanticipated Risks: There may be additional risks that cannot be foreseen. Some risks may materialise as unexpected variations or combinations of the factors discussed in this section.
I.2 Issuer-related risks	textBlock	For the purposes of this Part I.2, references to an "issuer", "issuer-related risks", or similar terms are to be read in line with the definition of "issuer" under MiCA, including any natural or legal person, or other undertaking, that issues crypto-assets. Since this whitepaper does not specify a issuing entity that can be determined in a formal legal sense, the relevant risk descriptions should be understood as referring, as applicable, to persons, entities, undertakings, arrangements, or governance structures that may materially influence the Token or the Platform. This may include, for example, foundations, core contributor entities, developers, maintainers, governance participants, or other relevant project-related actors, to the extent such information is available. - Absence or insolvency of an identifiable issuer: Where an identifiable issuer exists, that issuer may face insolvency risks. These may result from insufficient funding, low market interest, mismanagement, legal or regulatory developments, or external shocks, including pandemics or armed conflicts. In such a case, ongoing development, support, communication, or governance of the crypto-asset project may be reduced, suspended, or discontinued, potentially affecting the viability, availability, market acceptance, or tradability of the crypto-asset. - Legal and regulatory risks: The issuer operates in a dynamic and evolving regulatory environment. Failure to comply with applicable laws or regulations in relevant jurisdictions may result in enforcement actions, penalties, or restrictions on the project's operations. These may negatively impact the Token's availability, market acceptance, or legal status. - Operational risks: The issuer may fail to implement adequate internal controls, risk management, or governance processes. This can result in operational disruptions, financial losses, delays in updating the whitepaper, or reputational damage. - Governance and decision-making: The issuer's management body is responsible for key strategic, operational, and disclosure decisions. Ineffective governance, delays in decision-making, or lack of resources may compromise the stability of the project and its compliance with MiCA requirements. High concentration of decision-making authority or changes in ownership/control can amplify these risks. - Reputational risks: The issuer's reputation may be harmed by internal failures, external accusations, or association with illicit activity. Negative publicity can reduce trust in the issuer and impact the perceived legitimacy or value of the Token. - Counterparty dependence: The issuer may depend on third-party providers for certain core functions, such as technology development, marketing, legal advice, or infrastructure. If these partners discontinue their services, change ownership, or underperform, the issuer's ability to operate the project or maintain investor communication may be impaired. This could disrupt project continuity or undermine market confidence, ultimately affecting the crypto-asset's value.
I.3 Other tokens-related risks	textBlock	Market Volatility Risks: The Token's value is highly volatile and may fluctuate due to market speculation, investor sentiment, regulatory developments, and technological advancements. External factors, such as shifting trends in the crypto industry, changing demand for blockchain services, or macroeconomic conditions, could contribute to extreme price fluctuations, potentially leading to total depreciation. - Speculative Nature: No assurances of future value, performance, or rewards are made regarding the Token. Other than its role as a memecoin as described herein, the Token has no inherent or guaranteed utility, and its valuation depends entirely on user adoption, demand, and community engagement. If adoption of the Platform fails to grow as expected, the Token's value may be significantly impacted. - Liquidity Risks: The ability to trade the Token depends on the level of activity on DEXs and, where applicable, CEXs. Low trading volume may result in difficulties executing large transactions without significant price impact. Limited demand for the Token or the underlying protocol may further reduce liquidity, making it difficult to acquire, sell or otherwise transact with the Token. - Adoption and Platform Demand Risks: The long-term success of the Token is dependent on widespread adoption of the Platform. Adoption is influenced by various external factors, including user demand, competitive economic conditions, and organic community-driven expansion. The Person Seeking Admission to Trading has no control over the pace of adoption, and there is no guarantee that the Platform will gain sufficient traction to sustain its economic model. If demand is too low, obtaining services through the Platform may be difficult, while an inadequate supply may lead to delays in accessing services. - Blockchain Dependency Risks: The Token operates exclusively on its underlying blockchain network. Any disruptions, such as network congestion, downtime, or security vulnerabilities, could impact the ability to transfer, store, or trade the Token. Changes to blockchain infrastructure, governance, or transaction fees may also influence the Token's usability and cost-effectiveness. - Transaction Costs: While blockchain fees are generally low, network congestion, high demand, or changes in blockchain fee structures may increase transaction costs, potentially reducing the economic viability of using the Token within the network. Security Risks: - Smart Contract Vulnerabilities: Despite security audits and best practices, unforeseen vulnerabilities in smart contracts could lead to security breaches, impacting Token security or functionality. - Private Key Management: Token holders are solely responsible for safeguarding their private keys and recovery phrases. Loss of wallet credentials will result in the permanent loss of Tokens, as blockchain transactions are irreversible. - Scam and Fraud Risks: Token holders are exposed to risks associated with scams, phishing attacks, fake giveaways, impersonation of the Token issuer/offeror or its team, counterfeit Tokens, and fraudulent airdrops. Engaging with unverified third-party platforms or unofficial communications increases the risk of fraud. - Quantum Computing Risk: A significant breakthrough in quantum computing could weaken or break the cryptographic schemes that secure blockchain networks. If the encryption protecting user wallets and exchange accounts were compromised, holdings of the Token held on-chain or on centralised exchanges could be exposed to theft, and any resulting large-scale loss of funds could cause severe price volatility in the Token. - Community and Narrative Risks: The Token's success is closely tied to community interest and the broader crypto narrative. Macroeconomic trends, emerging competitors, or declining community engagement may negatively impact the Token's perceived value and adoption. Regulatory and Compliance Risks: - Evolving Legal Frameworks: Regulations governing crypto-assets differ across jurisdictions and are subject to change. New legal requirements may impact the Token's classification, availability, or functionality. - Jurisdictional Restrictions: Some jurisdictions may impose restrictions or prohibitions on the trading or use of the Token, limiting its accessibility for certain users. - Regulatory Harmonisation Risks: A lack of global regulatory alignment may create uncertainty, with some authorities potentially classifying the Token as a security or financial instrument, leading to increased compliance costs and legal obligations. - Regulatory Enforcement Risks: Government agencies may take enforcement actions against the Token issuer/offeror if the Token is deemed an unregistered security or if other financial laws are found to have been violated. Such actions could negatively impact the Token's availability, appeal, and value. - Anti-Money Laundering ("AML") & Counter-Terrorism Financing ("CTF") Risks: Crypto transactions may be scrutinised for potential links to illicit activities. Authorities may take action against wallets or platforms suspected of facilitating money laundering or terrorist financing, affecting the ability of Token holders to use or trade their assets. - Taxation Risks: The tax treatment of the Token varies by jurisdiction, and Token holders are solely responsible for understanding and complying with applicable tax laws. Any appreciation, conversion, or sale of the Token may trigger tax obligations that differ depending on the regulatory environment. - Technological Obsolescence Risks: The blockchain and crypto industries evolve rapidly. The emergence of new technologies, changes in market demand, or advancements in competing protocols could render the Token or its underlying blockchain infrastructure less competitive, reducing adoption and utility. - Software Weakness Risks: The Token's infrastructure relies on relatively new blockchain technologies, which may contain undiscovered bugs, vulnerabilities, or inefficiencies. There is no guarantee that the process of transacting, storing, or interacting with the Token will be uninterrupted or error-free. - Unanticipated Risks: Beyond the risks outlined above, additional unforeseen risks may emerge due to changes in regulatory, technological, or macroeconomic conditions, potentially affecting the Token's security, functionality, or value.
I.4 Project implementation-related risks	textBlock	The Person Seeking Admission to Trading neither operates, controls, oversees, nor manages the technology underlying the Platform. While efforts are made to ensure security and stability, blockchain-based technologies are still evolving, and various risks exist. Additionally, the success and sustainability of the project rely on various external factors, including macroeconomic conditions, regulatory developments, and technological advancements. Technical Development Risks: - Smart Contract Issues: Despite robust security measures, unforeseen vulnerabilities or bugs in the smart contracts could disrupt Token transfers or the buyback-and-burn mechanism. - Blockchain Dependency: The Token operates exclusively on its underlying blockchain. Any network congestion, downtime, or security breaches could impact the project's implementation and functionality. - Risk of Security Weaknesses in Core Infrastructure: The project relies on open-source software, which may be modified by third parties not directly affiliated with the Issuer. Weaknesses or bugs introduced into the core infrastructure could compromise security and lead to the loss of digital assets. Furthermore, malfunctions or inadequate maintenance of the network may negatively impact the Token's usability. - Bugs in Core Blockchain Code: Even with rigorous testing, unknown bugs may exist in the blockchain protocol, potentially leading to disruptions, incorrect transaction processing, or security vulnerabilities. Regulatory and Compliance Risks: - Regulatory Actions in One or More Jurisdictions: The Token and the underlying network could be impacted by regulatory inquiries or actions, which may restrict further development, implementation, or usage. - Evolving Laws and Regulations: New and changing laws related to financial securities, consumer protection, data privacy, cybersecurity, and intellectual property could impact the project. Compliance with these laws may require significant resources and could impose additional operational constraints. - Governance Risk: Decision-making mechanisms in blockchain governance may be inefficient, slow, or disproportionately influenced by specific stakeholders, leading to potential centralisation or unfavourable network changes. Operational Risks: - Resource Allocation: The project's success depends on the issuer of the Token and its core team allocating sufficient resources (both financial and non-financial) to ensure timely development and deployment. Poor resource management could lead to delays or failure to achieve key milestones. Market Adoption Risks: - Competitive Environment: The crypto industry is highly competitive and trend-driven. There is a risk that the Token may fail to capture sufficient interest, limiting its adoption. - Community Engagement Risks: The success of the Token depends heavily on community-driven sentiment and engagement. Failure to build or sustain an active community could hinder growth and long-term tradability Timeline and Milestone Risks: - Delayed Milestones: Key deliverables such as Token distribution and liquidity access may face delays due to technical, operational, or funding challenges. - CEX Listing Risks: Listings on centralised exchanges depend on securing the necessary funding for listing fees and meeting platform-specific requirements. Delays or insufficient resources could postpone broader market/ community access. Ecosystem Risks: - Dependence on External Partners: The project relies on partnerships with infrastructure providers, liquidity providers/ market makers, exchanges and other third-party service providers. Any failure or delay from these partners could disrupt implementation plans. - Risk of Withdrawing Partners: The Token holder understands that the feasibility of the project depends strongly on the collaboration of service providers and other key stakeholders. A loss of critical partnerships could impact project sustainability. Technology and Software Risks: - Risk of Software Weakness: The Token holder acknowledges that blockchain and smart contract technologies are still evolving. There is no guarantee that Token usage will be uninterrupted or error-free. Vulnerabilities in the underlying blockchain, smart contracts, or supporting technologies could lead to the complete loss of Tokens or their functionality. – Dependency on Underlying Technology: The Platform relies on blockchain infrastructure, hardware, and network connectivity, all of which may be subject to failures, outages, or vulnerabilities. - Risk of Technological Disruption: The emergence of new technology, such as quantum computing, could undermine the security of blockchain encryption and compromise the integrity of digital assets. Network Security Risks: - Network Attacks and Cybersecurity Threats: Blockchain networks can be vulnerable to cyberattacks such as 51% attacks, Sybil attacks, or distributed denial-of-service ("DDoS") attacks. These threats could disrupt network operations and compromise security. - Blockchain Network Attacks: The network may be subject to validation attacks, including double-spend attacks, reorganisations, majority mining power attacks, "vampire" attacks and work race condition attacks. Successful attacks could compromise the proper execution of transactions and smart contracts. Privacy and Anonymity Risks: - Public Ledger Transparency: Blockchain transactions are recorded on a public ledger, which may expose transaction history and financial activity. Certain transactions could be linked to specific wallet addresses, making users vulnerable to fraud, phishing attacks, or targeted scams. Economic and Governance Risks: - Consensus Failures or Forks: Errors in the consensus mechanism could lead to forks, where multiple versions of the ledger coexist, or network halts, reducing trust in the network. Software Weakness Risks: - Unforeseen Bugs and Security Vulnerabilities: The Token and its supporting infrastructure rely on blockchain technologies that may still be evolving. There is no guarantee that Token transactions will be uninterrupted or error-free. Software vulnerabilities, weaknesses in smart contracts, or infrastructure issues may result in loss of assets, security breaches, or unexpected network failures. Unanticipated Risks: - Unforeseen Regulatory, Technological, or Economic Challenges: In addition to the risks identified, new threats may emerge due to changes in legal, technological, or economic conditions. Developments such as regulatory crackdowns, unforeseen network vulnerabilities, or disruptive innovations could impact the usability, security, or value of the Token in ways not currently foreseeable.
I.5 Technology-related risks	textBlock	The Person Seeking Admission to Trading neither operates, controls, oversees, nor manages the technology underlying the Platform. While efforts are made to ensure security and stability, blockchain-based technologies are still evolving, and various risks exist. Blockchain Dependency Risks: - Network Downtime and Congestion: The Token relies entirely on its underlying blockchain network, which may experience outages, congestion, or downtime. Such events could disrupt Token transfers, trading, or other functionalities. - Scalability Challenges: As transaction volume grows, the blockchain network may face scaling limitations. Increased congestion could lead to slower transaction processing times and higher fees, reducing efficiency and usability. - Settlement and Transaction Finality Risks: Blockchain transactions are designed to be irreversible; however, under exceptional circumstances such as network forks or consensus failures, there remains a theoretical risk that transactions could be reversed, or multiple competing ledger versions could persist. Transactions sent to an incorrect address are not recoverable, leading to permanent loss of assets. Smart Contract Risks: - Vulnerabilities: While smart contracts are developed with security measures, undiscovered vulnerabilities or exploits may impact Token security, distribution, or access. Bugs in the contract code may lead to unintended loss of Tokens, unauthorised transactions, or exposure to external attacks. - Immutability Risks: Once deployed, some smart contracts cannot be altered. Errors or security flaws in the code could result in operational failures without the possibility of corrections. - Security Exploits: Bugs or vulnerabilities in smart contracts may expose the Token ecosystem to potential hacks, allowing attackers to manipulate transactions, drain liquidity, or disrupt contract execution. Network Security Risks: - Risk of Attacks and Forks: The blockchain may be susceptible to consensus-related attacks, such as double-spend attacks, majority validation power takeovers, censorship attacks, or forks. These risks could affect Token transactions, balance integrity, and overall network security. - Cybercrime and Theft Risks: Despite security efforts, blockchain-based assets and services may be exposed to cyberattacks, including hacking, phishing, or malware threats. Compromised wallets, exchanges, or smart contracts could lead to asset theft, loss of funds, or disruptions in Token functionality. - Data Corruption Risks: The reliability of blockchain data could be compromised due to software bugs, human error, or deliberate tampering. Such incidents may affect transaction records, network integrity, and user confidence in the system. Wallet and Storage Risks: - Private Key Management: Token holders are solely responsible for securing their private keys and recovery phrases. The loss of private keys results in irreversible loss of Tokens, as blockchain transactions are final and cannot be undone. - Compatibility Issues: The Token is supported only by blockchain-compatible wallets. Incompatibility with specific wallet software, network malfunctions, or wallet provider shutdowns may affect access to and usability of the Token. Ecosystem Dependency Risks: - DEX and CEX Integration Issues: The Token's availability depends on integration with DEXs and CEXs. Technical failures, security breaches, or delisting from these platforms could limit liquidity, disrupt trading, and reduce the Platform's accessibility. – Reliance on Third-Party Services: Many blockchain services, including wallets, bridges, and oracles, depend on third-party providers. Failures, security breaches, or regulatory actions against these services could negatively affect the functionality of the Token. - Centralisation Concerns: Although blockchain networks are designed to be decentralised, a small number of validators or node operators could introduce centralisation risks. This may lead to potential censorship, control over transactions, or increased vulnerability to governance attacks. Software and Protocol Risks: - Bugs in Core Blockchain Code: Despite rigorous testing, undiscovered bugs in the core blockchain protocol could lead to network failures, incorrect transaction processing, or security vulnerabilities. A failure to address such issues promptly could result in loss of user confidence and network instability. - Risk of Technological Disruption: Emerging technologies, such as quantum computing, could potentially compromise blockchain encryption, making networks vulnerable to attacks that could compromise data integrity or enable unauthorised asset transfers. - Dependency on Underlying Technology: The stability of the Token ecosystem relies on underlying technical infrastructures, including internet connectivity, computing hardware, and cryptographic algorithms. Disruptions in these foundational technologies may impact network security and operational efficiency. Privacy and Anonymity Risks: –Public Ledger Transparency: Blockchain transactions are recorded on a publicly accessible ledger, which may expose sensitive transaction data. While addresses do not directly reveal identities, sophisticated data analysis could potentially link certain transactions to specific individuals or entities. - Exposure to Fraud and Targeted Attacks: Increased transparency may lead to risks such as phishing, fraud, or unauthorised tracking of user activity by malicious actors. Individuals with significant Token holdings may be targeted for scams or social engineering attacks. Software Weakness Risks: - Unforeseen Bugs and Security Vulnerabilities: The Token and its supporting infrastructure rely on blockchain technologies that may still be evolving. There is no guarantee that Token transactions will be uninterrupted or error-free. Software vulnerabilities, weaknesses in smart contracts, or infrastructure issues may result in loss of assets, security breaches, or unexpected network failures. Unanticipated Risks: - Unforeseen Regulatory, Technological, or Economic Challenges: In addition to the risks identified, new threats may emerge due to changes in legal, technological, or economic conditions. Developments such as regulatory crackdowns, unforeseen Platform vulnerabilities, or disruptive innovations could impact the usability, security, or value of the Token in ways not currently foreseeable.
I.6 Mitigation measures	textBlock	While the risks described above cannot be eliminated, the following measures are in place to mitigate them: To help mitigate the smart contract management risks described in I.5, administrative control over the Platform's contracts is exercised through a multisig arrangement, with the signing keys held on dedicated devices reserved solely for this purpose and no other applications installed. To help limit the price impact of large transactions, the Person Seeking Admission to Trading has entered into agreements with market makers.
Part J - Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts
J.1 Adverse impacts on climate and other environment-related adverse impacts	textBlock	Robinhood is an L2 on Ethereum, developed using Arbitrum's modular L2 framework. It has no independent consensus mechanism; transactions are sequenced and bundled by Robinhood's sequencer before being secured by Ethereum's proof-of-stake consensus. By offloading transaction processing from the Ethereum mainnet, Robinhood aims to achieve cost efficiency. Estimated energy consumption for the disclosed period is 1.96037 kWh. Calculations are based on data provided by CCRI using a conservative bottom-up methodology; further detail is available at carbon-ratings.com/dl/whitepaper-mica-methods-2024 and docs.mica.api.carbon-ratings.com.
Mandatory information on principal adverse impacts on the climate and other environment-related adverse impacts of the consensus mechanism
General information about adverse impacts
S.1 Name	text	Pons Labs LLC
S.2 Relevant legal entity identifier	text	9845004A4F8CFBC38A09
S.3 Name of the crypto-asset	text	PONS
S.4 Consensus mechanism	text	Robinhood is an L2 introduced by Robinhood Markets, Inc. and built on Arbitrum's modular L2 framework. As an L2, Robinhood has no independent consensus mechanism of its own. Transactions are executed by Robinhood's sequencer, which orders them on a first-come, first-served basis according to their time of arrival, so that no transaction can gain priority over another by paying a higher fee. The sequencer soft-confirms each transaction within sub-second latency and subsequently bundles transactions into batches, which it posts to Ethereum, the underlying L1. Transaction finality is reached in stages. A transaction is first soft-confirmed by the sequencer within sub-second latency; its ordering then becomes fixed once the sequencer posts the batch to the L1; and full finality is reached when the L1 block containing that batch is finalised on Ethereum, approximately thirteen minutes after posting, at which point the transaction inherits the security of Ethereum's PoS consensus mechanism and becomes irreversible. Separately, Arbitrum's fraud-proof system imposes a seven-day challenge period on the withdrawal of assets from Robinhood back to Ethereum; that period applies to withdrawals only and is distinct from the transaction finality described above, as noted in S.5.
S.5 Incentive mechanisms and applicable fees	text	Transactions submitted to Robinhood are ordered and executed by its sequencer, which periodically bundles them into batches and posts each batch to Ethereum. By offloading transaction processing from the Ethereum mainnet in this way, Robinhood aims to achieve cost efficiency and faster finality. Transactions are ordered strictly by their time of arrival at the sequencer, on a first-come, first-served basis, so that priority cannot be obtained by paying a higher fee. Robinhood uses ETH as its native gas token, and transaction fees are denominated in ETH. Every transaction incurs two fee components: - L2 execution fee, which covers the computational cost of executing the transaction on Robinhood itself and is calculated as the gas used multiplied by the L2 gas price; this component is typically low and stable; and - L1 data fee, which covers the cost of posting the transaction's data to Ethereum for data availability. This component varies with Ethereum network congestion and is proportional to the size of the transaction's calldata. Both components are bundled into the gas that the transaction pays and are not charged separately. The movement of crypto-assets between Ethereum and Robinhood is handled by a canonical bridge that requires no third-party validators and inherits its security directly from Ethereum. A user seeking to withdraw assets from Robinhood to Ethereum must first initiate the withdrawal on Robinhood, then wait for a challenge period of seven days, a requirement of Arbitrum's fraud-proof system described in S.4, before claiming the assets through a final transaction on Ethereum, which incurs L1 gas costs.
S.6 Beginning of period to which disclosed information relates	date	2026-08-28
S.7 End of period to which disclosed information relates	date	2026-09-10
Mandatory key indicator
S.8 Energy consumption	energy (kWh)	1.96037
Sources and methodologies
S.9 Energy consumption sources and methodologies	textBlock	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: carbon-ratings.com/dl/whitepaper-mica-methods-2024 and docs.mica.api.carbon-ratings.com. We do not account for any offsetting of energy consumption or other market-based mechanism as of today.
Supplementary information on principal adverse impacts on climate and other environment-related adverse impacts of consensus mechanism
Supplementary key indicators
S.10 Renewable energy consumption	percent	0%
S.11 Energy intensity	energy (kWh)	0
S.12 Scope 1 DLT GHG emissions - controlled	GHG emissions (tCO2e)	0
S.13 Scope 2 DLT GHG emissions - purchased	GHG emissions (tCO2e)	0
S.14 GHG intensity	GHG emissions (tCO2e)	0
Sources and methodologies
S.15 Key energy sources and methodologies	textBlock	Not applicable
S.16 Key GHG sources and methodologies	textBlock	Not applicable
Optional information on principal adverse impacts on the climate and on other environment-related adverse impacts of the consensus mechanism
Optional indicators
S. 17 Energy mix	percent	0%
S.18 Energy use reduction
Energy use reduction target (absolute value)	energy (kWh)	0
Energy use reduction target (percentage)	percent	0%
S.19 Carbon intensity (kgCO2e/kWh)	decimal	0
S.20 Scope 3 DLT GHG emissions - value chain	GHG emissions (tCO2e)	0
S.21 GHG emissions reduction targets or commitments	textBlock	0
S.22 Generation of waste electrical and electronic equipment (WEEE)	mass (tonnes)	0
S.23 Non-recycled WEEE ratio	percent	0%
S.24 Generation of hazardous waste	mass (tonnes)	0
S.25 Generation of waste (all types)	mass (tonnes)	0
S.26 Non-recycled waste ratio (all types)	percent	0%
S.27 Waste intensity (all types)	mass (tonnes)	0
S.28 Waste reduction targets or commitments (all types)	textBlock	0
S.29 Impact of use of equipment on natural resources	textBlock	0
S.30 Natural resources use reduction targets or commitments	textBlock	0
S.31 Water use	volume (m3)	0
S.32 Non recycled water ratio	percent	0%
Sources and methodologies
S.33 Other energy sources and methodologies	textBlock	Not applicable
S.34 Other GHG sources and methodologies	textBlock	Not applicable
S.35 Waste sources and methodologies	textBlock	Not applicable
S.36 Natural resources sources and methodologies	textBlock	Not applicable