Alchemy Pay(ACH) Whitepaper

CRYPTO-ASSET WHITE PAPER - [ACH]

Version Number: 1.0

Document Type: White Paper

Document Author Offeror: OKX Europe Limited

Document Status: APPROVED

Language: English

TABLE OF CONTENTS

I. DATE OF NOTIFICATION II. STATEMENTS III. WARNING IV. INFORMATION ON RISKS

1. Offer-Related Risks

2. Issuer-Related Risks

3. Crypto-Assets-Related Risks

4. Project Implementation-Related Risks

5. Technology-Related Risks

6. Mitigation Measures V. GENERAL INFORMATION A. Information of the Offeror or the Person Seeking Admission to Trading B. Information of the Issuer C. Information about OKX Europe Limited ("OKX") VI. INFORMATION ABOUT THE CRYPTO-ASSET D. Information about the Crypto-Asset Project E. Information about the Offer to the Public of the Crypto-Asset or Its Admission to Trading F. Information about the Crypto-Assets G. Information about the Rights and Obligations Attached to the Crypto-Asset H. Information about the Underlying Technology I. Information on the Principal Adverse Impacts on the Climate and Other Environmental-Related Adverse Impacts of the Consensus Mechanism Used to Issue the Crypto-Asset. VII. GLOSSARY

I. DATE OF NOTIFICATION

The Date of Notification of this Crypto-Asset White Paper is [YYYY-MM-DD].

II. STATEMENTS

A. This Crypto-Asset White Paper has not been approved by any Competent Authority in any Member State of the European Union. OKX Europe Limited is solely responsible for the content of this Crypto-Asset White Paper.

B. This Crypto-Asset White Paper complies with Title II of the Regulation (EU) 2923/1114, 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.

C. The Crypto-Asset White Paper provides that ACH may not be transferable, or liquid, or lose its value, in part or in full.

D. The Utility Token referred to in this Crypto-Asset White Paper may not be exchangeable against the good or service promised in the Crypto-Asset White Paper, especially in the case of a failure or discontinuation of the Crypto-Asset Project. This statement is TRUE.

E. The Crypto-Asset referred to in this Crypto-Asset White Paper is not covered by the investor compensation schemes under the Directive 97/9/EC of the European Parliament and of the Council.

F. The Crypto-Asset referred to in this Crypto-Asset White Paper is not covered by the deposit guarantee schemes under Directive 2014/49/EU of the European Parliament and of the Council.

III. WARNING

A. The summary should be read in conjunction with the content of the Crypto-Asset White Paper.

B. 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.

C. The offer to the public of the Crypto-Asset does not constitute an offer or solicitation to purchase financial instruments and that any such offer or solicitation can be made only by means of a prospectus or other offer documents pursuant to the applicable National Law.

D. This Crypto-Asset White Paper does not constitute a prospectus as referred to in the Regulation (EU) 2017/1129 of the European Parliament and the Council or any other offer document pursuant to the European Union or National Law.

E. ACH is an ERC-20 utility token deployed on the Ethereum blockchain, with a fixed total supply of 10 billion tokens. It is also available as a BEP-20 token on the Binance Smart Chain. The token is designed to function within the Alchemy Pay ecosystem, a payment solutions platform that bridges fiat and crypto economies.

F. The ACH token provides access to the Alchemy Pay hybrid crypto-fiat payment gateway. The primary utility is for enterprise users, such as merchants and payment platforms, who are required to pledge a quantity of ACH tokens to integrate and use the platform's payment processing services. The quantity of tokens required to be pledged is determined by the anticipated transaction volume of the user, creating a tiered access system. Pledging the tokens grants the user the right to accept crypto-asset payments from customers and receive settlement in their local fiat currency. The token is also intended to be used for transaction fees within the ecosystem and for future governance rights, although the on-chain governance mechanism is not yet active. The ACH token is freely and instantly transferable, utilising the underlying blockchain network's standard processes.

G. This whitepaper is published solely in connection with the admission to trading of the ACH token on OKX Europe Limited's trading platform. There has been no offer of the crypto-asset to the public, and the crypto-asset has not been made available in exchange for fiat currency or other crypto-assets prior to its listing. The crypto-asset will be admitted to trading via OKX Europe Limited, an authorised crypto-asset service provider ("CASP") operating within the European Union. The trading admission does not involve any subscription, sale, or fundraising process. The purpose of this document is to provide key information regarding the characteristics of the crypto-asset, its governance, rights, and associated risks, to enable informed decision-making by users and market participants in the context of its admission to trading. Access to the crypto-asset on the trading platform may be subject to user verification, platform conditions, or applicable legal restrictions depending on the jurisdiction.

IV. INFORMATION ON RISKS

1. Offer-Related Risks

This whitepaper is submitted by OKX Europe Limited solely for the purpose of the assets admission to trading. No public offer of ACH tokens is being made by the issuer or OKX Europe Limited.

Risks associated with the admission to trading include:

• Service-related Interruption: Holders may be unable to access the utility due to technical, operation, or regulatory disruptions.

• Jurisdictional limitations: ACH services or token utility may not be available in all jurisdictions, potentially restricting access.

• Platform Reliance: Access depends on third-party infrastructure (wallets, platforms) and service interruptions or failures may affect token utility.

• Limited Liability: OKX Europe Limited assumes no responsibility for the issuers project continuation, and token ownership does not confer contractual rights or guarantees.

• Unexpected Risks: Beyond the risks outlined in this whitepaper, there may be additional risks that are currently unforeseen. It is imperative to note that certain risks may emerge from unforeseen events, changes, or interactions among factors that are difficult to predict. These unexpected risks may significantly and negatively impact the crypto-asset, the project, or the parties involved.

2. Issuer-Related Risks

• Operational Risks: There is a risk that the issuer may face financial or operational difficulties, including insolvency, which could impact the continued development or availability of the services associated with the ACH token.

• Counterparty Risks: Counterparty risks may arise where the issuer relies on third-party service providers or technology partners.

• Reputational Risks: Adverse media and/or damage or loss of key personnel could negatively affect the ecosystem that the ACH token lives on.

• Competition Risk: The issuer may face increased competition or changes in market conditions that affect its ability to carry out its objectives.

• Regulatory Risks: The issuer may be subject to investigations, enforcement actions, or change in regulation that affect the tokens legal status in certain jurisdictions.

• Disclosure Risks: The issuer may not be required to provide financial statements, limiting ACH token holders visibility into the financial health status of the issuer/project.

• Issuer Risks: The information provided is based solely on publicly available sources and does not constitute any form of guarantee or warranty as to its accuracy or completeness.

3. Crypto-Assets-Related Risks

• Market Volatility: The ACH token may be subject to significant volatility and could lose value rapidly, either due to market conditions or otherwise (issuer-related/technology/project implementation risks)

• Utility Risk: The ACH tokens utility depends on access to certain services, and any modification or discontinuation of those services could reduce the associated utility of the token.

• Smart Contract Risk: The ACH token may operate through smart contracts that may contain vulnerabilities, even if audited, and upgrades to the protocol or governance changes may affect functionality.

• Liquidity Risk: Periods of low/limited liquidity may occur, particularly if the demand for the token or its use case decreases, which could have adverse effects on the ACH tokens price and future use cases.

4. Project Implementation-Related Risks

• Scalability Issues: There is a risk that the project may not be implemented or scaled as intended. Technical limitations or infrastructure bottlenecks could hinder the expected scalability of the project, especially if user demand exceeds network or protocol capacity.

• Governance Risk: The project may be subject to governance processes that involve on-chain voting or community proposals. Misaligned incentives, low participation, or malicious actors may affect the outcome of governance decisions and disrupt the project's roadmap.

• Centralisation Risk: Similar to governance risks outlined above, centralisation within the governance process, or validator centralisation could lead to a lack of decentralization within the network, which carries future risks in terms of trust within the project, and also in regards to future roadmaps where plans may not reflect the interests of the broader user base.

5. Technology-Related Risks

• Blockchain Performance Risk: The Ethereum and BNB Smart Chain blockchains, on which the token is issued, may experience downtime or congestion, which could delay or prevent token transfer or utility usage.

• Consensus Failure Risk: A failure in the blockchains' consensus mechanism could result in halted transactions, unexpected behavior, or loss in network integrity.

• Smart Contract Vulnerabilities: Although the token uses audited or standard smart contract makeups (ERC-20 and BEP-20 standards), undetected bugs, exploits, or implementation errors could compromise functionality or security.

• Upgradeability Risk: If the token or related contracts are upgradeable and have designated "owner" addresses, this introduces a central point of failure, and could be misused by malicious actors.

• Third-party Infrastructure Dependency: Interaction with the token or project may rely on external infrastructure (APIs, wallet services, off-chain governance voting). Outages or attacks may interrupt access to token-related services.

• Interoperability Risk: If the token interacts with other chains, bridges, or oracles, failures or exploits in those systems could affect the tokens operations.

• Protocol-level Risk: Upgrades or forks of the protocol itself may affect the token, which could lead to compatibility issues and/or unexpected token behaviour.

• Emerging Technology Risk: Advances in computing or undiscovered vulnerabilities in cryptographic algorithms may pose long-term security risks to the blockchain or associated smart contracts.

6. Mitigation Measures

• Blockchain Performance Risk: The underlying blockchains mitigate performance risks in several ways. The Ethereum network operates on a Proof-of-Stake (PoS) consensus mechanism and is undergoing scalability upgrades. It uses a gas fee market (EIP-1559) to manage congestion and allow users to prioritise transactions. The BNB Smart Chain operates on a Proof-of-Staked Authority (PoSA) consensus mechanism, which uses a set of active validators to achieve high throughput and low transaction fees, managing congestion through its own gas fee market.

• Consensus Failure Risk: Both networks have mechanisms to ensure network integrity. Ethereum's PoS consensus relies on a large, globally distributed set of validators who stake ETH as collateral. Malicious behaviour is deterred by "slashing" penalties, and network integrity is secured by finality checkpoints. BNB Smart Chain's PoSA consensus relies on a limited set of elected validators who stake BNB. Network integrity is maintained by this validator set, which is responsible for confirming transactions and producing blocks.

• Smart Contract Vulnerabilities: This token is deployed using widely adopted standards: ERC-20 on Ethereum and BEP-20 on BNB Smart Chain. The BEP-20 standard is fully compatible with the ERC-20 standard. The security of these token standards is bolstered by their extensive use, open-source nature, and continuous community review. On both Ethereum and BNB Smart Chain, developers mitigate risks by using battle-tested libraries like OpenZeppelin. While this reduces the risk of token-level bugs, vulnerabilities could still exist in other smart contracts that interact with the token.

• Upgradeability Risk: The risk associated with upgradeable contracts is mitigated by on-chain governance and security practices. On Ethereum and BNB Smart Chain, the primary mitigation for contracts with "owner" addresses is to secure those addresses. This is typically achieved by requiring multiple signatures (a "multisig") for any change, implementing mandatory time-delays that allow users to review and react to pending upgrades, or by renouncing ownership entirely, making the contract immutable. In many cases, this control is transitioned to a token-holders' DAO.

• Third-party Infrastructure Dependency: To mitigate reliance on single, centralised service providers, the ecosystems of both chains support a diverse set of infrastructure. For Ethereum and BNB Smart Chain, decentralised indexing protocols (e.g., The Graph) and multiple independent RPC providers are available, allowing applications to avoid a single point of failure and ensuring high availability and censorship resistance.

• Interoperability Risk: This token relies on bridges to move between Ethereum and BNB Smart Chain. This risk is mitigated by the use of established and audited bridging technologies. Transfers between these networks may rely on the official BNB Chain bridge or various third-party bridges, which have their own security models (often involving multisig contracts or light client nodes) and are subject to their own extensive audits.

• Protocol-level Risk: Both blockchains manage protocol upgrades through public and transparent processes. Ethereum's roadmap and upgrades (EIPs) are subject to extensive public research, developer discussion, and testing. BNB Smart Chain's protocol development (BEPs) is managed by its core development community and validator set, with network upgrades publicly discussed, validated on testnets, and progressively rolled out to the mainnet.

• Emerging Technology Risk: Long-term threats, such as advancements in quantum computing, are actively monitored by the core development communities of both networks. The Ethereum Foundation is actively researching and developing quantum-resistant cryptographic solutions. As BNB Smart Chain is EVM-compatible, it benefits from the research and development within the wider Ethereum ecosystem. The modular architectures of both networks are designed to allow for future cryptographic upgrades if a threat becomes viable.

V. GENERAL INFORMATION

A. Information of the Offeror or the Person Seeking Admission to Trading

• A.1 Name: N/A

• A.2 Legal Entity Identifier (LEI): N/A

• A.3 Legal Form, if applicable: N/A

• A.4 Registered Office, if applicable: N/A

• A.5 Head Office, if applicable: N/A

• A.6 Date of Registration [YYYY-MM-DD]: N/A

• A.7 Legal Entity Number: N/A

• A.8 Contact Telephone Number: N/A

• A.9 E-Mail Address: N/A

• A.10 Response Time (days): N/A

• A.11 Members of Management Body: N/A

• A.12 Business Activity: N/A

• A.13 Newly Established: N/A

• A.14 Financial Condition for the past Three Years: N/A

• A.15 Financial Condition since Registration: N/A

• A.16 Parent Company, if applicable: N/A

• A.17 Parent Company Business Activity, if applicable: N/A

B. Information of the Issuer

This section shall ONLY be completed if the information is different to that listed in section 1, above.

• B.1 Is the Issuer different from an offeror or person seeking admission to trading?: TRUE

• B.2 Name: Alchemy GPS Europe UAB

• B.3 Legal Entity Identifier (LEI): No information could be identified in regards to this field at the time of drafting this whitepaper.

• B.4 Legal Form, if applicable: Private Limited Liability Company

• B.5 Registered Office, if applicable: J. Basanavičiaus g. 26, LT-03224, Vilnius, Lithuania

• B.5 Head Office, if applicable: J. Basanavičiaus g. 26, LT-03224, Vilnius, Lithuania

• B.6 Date of Registration [YYYY-MM-DD]: 2022-01-06

• B.7 Legal Entity Number: 305972625

• B.8 Members of the Management Body:

  • Line ID 1: No information could be identified in regards to this field at the time of drafting this whitepaper.

• B.9 Business Activity: The business activities of Alchemy GPS Europe UAB involve the development of software for cloud-based payment processing and other information technology services. The entity supports the technical development and operation of the Alchemy Pay platform, which provides crypto-fiat payment gateway solutions.

• B.10 Parent Company: Alchemy GPS Singapore PTE. LTD.

• B.11 Parent Company Business Activity: Alchemy GPS Singapore PTE. LTD. offers consultancy services in relation to information technology with the exclusion of cybersecurity. The Parent Company is associated with providing domestic money transfer services, merchant acquisition services, and digital payment token services.

C. Information about OKX Europe Limited ("OKX")

This section shall ONLY be completed if OKX draws up the Crypto-Asset White Paper.

• C.1 Name: OKX Europe Limited

• C.2 Legal Entity Identifier: 54930069NLWEIGLHXU42

• C.3 Legal Form, if applicable: Private Limited Company

• C.4 Registered Office, if applicable: Piazzetta Business Plaza, Office Number 4, Floor 2, Triq Ghar il-Lembi, Sliema SLM1562, Malta

• C.5 Head Office, if applicable: See C.4

• C.6 Date of Registration: 2018-09-07

• C.7 Legal Entity Registration Number: C 88193

• C.8 Members of Management Body:

  • Line ID 1: Erald Henri J. Ghoos (Belgian, See C.4, Director)

  • Line ID 2: Fang Hong (American, See C.4, Director)

  • Line ID 3: Joseph Portelli (Maltese, See C.4, Director)

  • Line ID 4: Wei Man Cheung (Dutch, See C.4, Director)

• C.9 Business Activity: OKX Europe Limited is licensed as a Crypto-Asset Service Provider by the Malta Financial Services Authority, bearing licence number OEUR-24352, to provide crypto services under the Markets in Crypto-Assets Act, Chapter 647, Laws of Malta and is the operator of a Trading Platform for Crypto Assets, in accordance with Article 3(1)(18) of Regulation (EU) 2023/1114 (MiCA).

• C.10 Reason for Crypto-Asset White Paper Preparation: This crypto-asset whitepaper has been prepared in accordance with Regulation (EU) 2023/1114 (MiCA) for the purpose of: The admission to trading of ACH on regulated platforms, starting with the OKX Exchange. OKX Europe Limited as a result of being a licenced CASP endeavours to fulfill the obligations established under MiCA and the respective MFSA guidelines to: Notify this whitepaper to the MFSA; Publish the whitepaper publicly; And ensure its registration in the MiCA register maintained by the European Securities and Markets Authority (ESMA). This whitepaper has been prepared to provide transparent, accurate, and fair information to prospective token holders and regulatory authorities in line with the principles of MiCA.

• C.11 Parent Company: OKC International Holding Company Limited

• C.12 Parent Company Business Activity: The primary business activity of the parent company is holding of investments.

Other Information

*This section shall ONLY be completed if someone, other those referenced in Section 1 to 3, compile and complete the Crypto-Asset White Paper.*

• C.13 Other Persons drawing up the Crypto-Asset White Paper: N/A

• C.14 Reason for Crypto-Asset White Paper Preparation: N/A

VI. INFORMATION ABOUT THE CRYPTO-ASSET

D. Information about the Crypto-Asset Project

• D.1 Project Name: Alchemy Pay

• D.2 Crypto-Assets Name: See F.14

• D.3 Abbreviation: See F.14

• D.4 Crypto-Asset Project Description: Alchemy Pay is a payment solutions provider that develops infrastructure to bridge the gap between fiat and crypto economies. The project offers payment gateways and on/off-ramp services that enable businesses and consumers to transact using both traditional currencies and cryptocurrencies. Its core objective is to promote the adoption of blockchain technology by providing seamless, secure, and compliant payment channels for e-commerce platforms, retail merchants, and financial institutions.

• D.5 Details of all natural or legal persons involved in the implementation of the Crypto-Asset Project:

  • Name: Shawn Shi (Role: Co-Founder, Business Address: Singapore)

  • Name: Molly Zheng (Role: COO, Business Address: United States)

  • Name: John Tan (Role: Co-Founder, Business Address: Singapore)

  • Name: Gibbs Lvy (Role: Co-Founder, Business Address: No information could be identified in regards to this field at the time of drafting this whitepaper.)

  • Name: Jonas Černius (Role: Head of Compliance, Business Address: Vilnius, Vilniaus, Lithuania)

• D.6 Utility Token Classification: TRUE

• D.7 Key Features of Goods/Services for Utility Token Projects, if applicable: The Alchemy Pay project provides a hybrid crypto-fiat payment gateway service. Its key features include enabling merchants to accept a diverse range of cryptocurrencies which are then settled in their local fiat currency, providing SDKs and APIs for easy integration into online and offline retail systems, and supporting complex payment models for large-scale commercial applications.

• D.8 Plans for the Token:

  • Past Milestones: The Alchemy Pay project was founded in 2017. The ACH token was deployed on the Ethereum mainnet on September 4, 2019. The project has established partnerships with numerous entities in the crypto and payment sectors and has been listed on several major crypto-asset trading platforms. In January 2023, the project transitioned to a committee-based management structure to oversee business operations.

  • Future Milestones: The project plans to launch its own Layer-1 public blockchain, Alchemy Chain, with a mainnet launch scheduled for Q2 2026. This blockchain is intended to specialise in stablecoin transactions and cross-border payments, with the ACH token serving as its native gas token. The project also plans to integrate Real-World Assets (RWAs) into its ecosystem, enabling users to access tokenized assets like stocks and real estate. Furthermore, a formal on-chain governance mechanism allowing ACH token holders to vote on protocol and business decisions is planned, though a specific timeline for its implementation has not been disclosed.

• D.9 Resource Allocation, if applicable: At its token generation event, 62% of the total ACH supply was allocated to utility and ecosystem incentives, including rewards for enterprise and consumer transactions (40%), DeFi transactions (11%), transaction mobility (6%), and enterprise partners (5%). The remaining 38% was allocated to stakeholders, including the team (18%), early backers (18%), and advisors (2%). These allocations were subject to various vesting schedules, most of which have since concluded.

• D.10 Planned Use of Collected Funds or Crypto-Assets, if applicable: The project's treasury, which includes tokens allocated to the team and for ecosystem rewards, is managed by a committee. These assets are intended to be used for market expansion, operational growth, and to fund ecosystem incentives such as partner rebates and community airdrop campaigns. While future plans include a decentralized governance model where token holders could vote on treasury allocations, control currently remains with the project's management committee.

E. Information about the Offer to the Public of the Crypto-Asset or Its Admission to Trading

• E.1 Public Offering or Admission to Trading: ATTR

• E.2 Reasons for Public Offer or Admission to Trade: Facilitating secondary trading for users on the OKX Trading platform in compliance with the MiCA regulatory framework.

• E.3 Fundraising Target, if applicable: N/A

• E.4 Minimum Subscription Goals, if applicable: N/A

• E.5 Maximum Subscription Goals, if applicable: N/A

• E.6 Oversubscription Acceptance: N/A

• E.7 Oversubscription Allocation, if applicable: N/A

• E.8 Issue Price: N/A

• E.9 Official Currency or Any Other Crypto-Assets determining the Issue Price: N/A

• E.10 Subscription Fee: N/A

• E.11 Offer Price Determination Method: N/A

• E.12 Total Number of Offered/Traded Crypto-Assets, if applicable: The ACH token has a fixed maximum supply of 10,000,000,000 tokens.

• E.13 Targeted Holders: N/A

• E.14 Holder Restrictions: N/A

• E.15 Reimbursement Notice: N/A

• E.16 Refund Mechanism: N/A

• E.17 Refund Timeline: N/A

• E.18 Offer Phases: N/A

• E.19 Early Purchase Discount: N/A

• E.20 Time-Limited Offer: N/A

• E.21 Subscription Period, beginning [YYYY-MM-DD]: N/A

• E.22 Subscription Period, end [YYYY-MM-DD]: N/A

• E.23 Safeguarding Arrangement for Offered Funds/Crypto-Assets: N/A

• E.24 Payment Methods for Crypto-Asset Purchase: In line with OKX current payment method offering.

• E.25 Value Transfer Methods for Reimbursement: N/A

• E.26 Right of Withdrawal, if applicable: N/A

• E.27 Transfer of Purchased Crypto-Assets: In line with OKX current Terms of Service.

• E.28 Transfer Time Schedule [YYYY-MM-DD]: N/A

• E.29 Purchaser's Technical Requirements: In line with OKX current Terms of Service.

• E.30 Crypto-Asset Service Provider (CASP) name, if applicable: OKX Europe Limited

• E.31 CASP identifier, if applicable: 54930069NLWEIGLHXU42

• E.32 Placement Form: NTAV

• E.33 Trading Platforms Name, if applicable: OKX

• E.34 Trading Platforms Market Identifier Code (MIC): n/a

• E.35 Trading Platforms Access, if applicable: Users may access ACH through the OKX Trading Platform via the Application Program Interface ("API"), the Application Software ("OKX App"), as well as the official OKX website as follows; www.okx.com.

• E.36 Involved Costs, if applicable: In line with the OKX current Terms of Service.

• E.37 Offer Expenses: n/a

• E.38 Conflicts of Interest: A crypto-asset is listed following a decision rendered independently by the Listing Committee in line with the internal policies of OKX Europe Limited. Any potential disclosures that may arise of conflicts of interest are published on the OKX website.

• E.39 Applicable Law: Malta

• E.40 Competent Court: Malta

F. Information about the Crypto-Assets

• F.1 Crypto-Asset Type: Other Crypto-Asset

• F.2 Crypto-Asset Functionality: The ACH token's primary functionality is to serve as a utility token within the Alchemy Pay ecosystem. It is used by enterprise partners, such as e-commerce platforms and payment companies, who are required to pledge a certain amount of ACH to access and integrate Alchemy Pay's payment services. The token is also planned to function as the native gas token for the upcoming Alchemy Chain and to grant voting rights in a future decentralized governance system.

• F.3 Planned Application of Functionalities: The utility functionality for pledging ACH to access services is currently available. The application of functionalities related to its use as a gas token on Alchemy Chain and for participation in on-chain governance is planned for the future, with the Alchemy Chain mainnet scheduled for Q2 2026.

• F.4 Type of White Paper: OTHR

• F.5 Type of Submission: NEWT

• F.6 Crypto-Asset Characteristics: ACH is a fungible utility token issued as an ERC-20 token on the Ethereum blockchain and a BEP-20 token on the Binance Smart Chain. It has a fixed maximum supply of 10,000,000,000 tokens. The token is transferable on its respective networks and does not confer any ownership rights or claims on the profits or assets of the issuer.

• F.7 Commercial Name or Trading Name, if applicable: See F.14

• F.8 Website of the Issuer: https://alchemypay.org/

• F.9 Starting Date of Offer to the Public or Admission to Trading [YYYY-MM-DD]: 2025-02-11

• F.10 Publication Date [YYYY-MM-DD]: [To be filled]

• F.11 Any Other Services Provided by the Issuer: N/A

• F.12 Identifier of Operator of the Trading Platform: N/A

• F.13 Language/s of the White Paper: English

• F.14 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: VFLDZKHPK, 546Q433WH

• F.15 Functionally Fungible Group Digital Token Identifier, where available: MBKSZCVQM

• F.16 Voluntary Data Flag: FALSE

• F.17 Personal Data Flag: TRUE

• F.18 LEI Eligibility: N/A

• F.19 Home Member State: Malta

• F.20 Host Member States: Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Italy, Ireland, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden

G. Information about the Rights and Obligations Attached to the Crypto-Asset

• G.1 Purchaser Rights and Obligations: There are no obligations attached for/of the purchaser. Purchasers of the ACH token obtain the right to use the token within the Alchemy Pay ecosystem. These rights include the ability to pledge ACH tokens to gain access to the platform's payment services, a requirement for business partners. In the future, holders may have the right to participate in the protocol's governance by voting on key decisions and to use the token to pay for transaction fees on the planned Alchemy Chain. Token ownership does not grant any claim to profits, dividends, or assets of the issuer.

• G.2 Exercise of Rights and Obligations: As the token does not grant obligations, there is no conceivable way to exercise such obligations. Rights are exercised programmatically through interaction with the Alchemy Pay platform and its associated smart contracts. The right to access services is exercised by pledging tokens through the platform's interface. Future governance rights are expected to be exercised via a decentralized voting mechanism, and the right to pay for gas fees will be exercised by submitting transactions on the future Alchemy Chain.

• G.3 Conditions for Modifications of Rights and Obligations: As the token does not grant obligations, there are no conditions under which the obligations may be modified. The rights associated with the ACH token may be modified through future protocol upgrades. Currently, such changes are determined by the project's management committee. Once the planned decentralized governance system is implemented, token holders may be able to propose and vote on modifications to the token's rights and functionalities.

• G.4 Future Public Offers, if applicable: N/A

• G.5 Issuer Retained Crypto-Assets, if applicable: At the time of the token's launch, 38% of the total supply was allocated to stakeholders, which included 18% for the team. These tokens were subject to vesting schedules which have since concluded. The project also controls a rewards pool address that holds tokens designated for ecosystem incentives.

• G.6 Utility Token Classification: TRUE

• G.7 Key Features of Goods/Services of Utility Tokens: The ACH token provides access to the Alchemy Pay network's crypto-fiat payment processing services. The primary utility is for business partners, who must pledge a specified quantity of ACH tokens to integrate the payment gateway. The amount pledged is typically tied to the partner's expected transaction volume. This grants them the ability to accept crypto payments from customers and receive settlement in fiat currency.

• G.8 Utility Tokens Redemption, if applicable: The ACH token is not redeemable for a specific good, service, or fiat currency from the issuer. Its utility is realised through its use within the Alchemy Pay ecosystem, primarily by pledging it to gain access to the payment network's services. The pledged tokens can be reclaimed if the business partner decides to discontinue the service.

• G.9 Non-Trading Request: TRUE

• G.10 Crypto-Assets Purchase or Sale Modalities: N/A

• G.11 Crypto-Assets Transfer Restrictions: In line with OKX current Terms of Service.

• G.12 Supply Adjustment Protocols: N/A

• G.13 Supply Adjustments Mechanisms: N/A

• G.14 Token Value Protection Schemes: FALSE

• G.15 Token Value Protection Schemes Description: N/A

• G.16 Compensation Schemes: FALSE

• G.17 Compensation Schemes Description, if applicable: N/A

• G.18 Applicable Law: Malta

• G.19 Competent Court: Malta

H. Information about the Underlying Technology

• H.1 Distributed Ledger Technology, if applicable: See F.14

• H.2 Protocols and Technical Standards: The ACH token is implemented using the ERC-20 token standard on the Ethereum blockchain and the BEP-20 standard on the Binance Smart Chain. Both are widely adopted standards for fungible tokens on their respective networks, defining a common interface for token issuance, transfers, and third-party integrations with wallets, decentralised exchanges, and other DeFi applications.

• H.3 Technology Used, if relevant: The ACH token is deployed on the Ethereum and Binance Smart Chain blockchains, both of which are general-purpose Layer 1 blockchains that support smart contract execution via the Ethereum Virtual Machine (EVM). The token contracts are written in Solidity and interact with the networks using RPC-compatible clients. The EVM compatibility across both chains enables composability with a broad ecosystem of DeFi, NFT, and DAO infrastructure.

• H.4 Consensus Mechanism, if applicable: Ethereum uses a Proof-of-Stake (PoS) consensus mechanism. Validators are selected to propose and attest to new blocks based on the amount of ETH they have staked. Blocks are finalized through a checkpoint-based finality system, with strong economic incentives to penalize dishonest behavior. This mechanism supports decentralization, finality, and high security. This consensus model ensures the integrity of the blockchain, including the execution and recording of all associated transactions for the ACH token. The Binance Smart Chain uses a Proof-of-Staked-Authority (PoSA) consensus mechanism, a hybrid model that combines features of Delegated Proof-of-Stake (DPoS) and Proof-of-Authority (PoA). A limited set of validators are elected based on their stake and are responsible for producing blocks, which allows for high throughput and low transaction fees.

• H.5 Incentive Mechanisms and Applicable Fees: Ethereum validators earn rewards in the native token (ETH) for producing and attesting to blocks. Gas fees are paid in ETH and are required to execute transactions or smart contract calls, including ACH token transfers. Under EIP-1559, a portion of the base fee is burned while the remainder is distributed to validators. Fees vary depending on network congestion and computational complexity of the transaction. On the Binance Smart Chain, validators earn rewards from transaction fees paid in BNB. Fees are required for all transactions, including ACH token transfers, and are determined by network congestion and the computational complexity of the transaction.

• H.6 Use of Distributed Ledger Technology: FALSE

• H.7 DLT Functionality Description: N/A

• H.8 Audit of the Technology Used: TRUE

• H.9 Audit Outcome, if applicable: The ACH token smart contract underwent a public, automated audit by Cyberscope. The audit did not identify any critical vulnerabilities. Further details regarding the audit scope and findings can be found at: https://www.cyberscope.io/audits/coin-alchemy-pay

I. Information on the Principal Adverse Impacts on the Climate and Other Environmental-Related Adverse Impacts of the Consensus Mechanism Used to Issue the Crypto-Asset.

• I.1 Name: OKX Europe Limited

• I.2 Relevant legal entity identifier: 54930069NLWEIGLHXU42

• I.3 Name of the crypto-asset: Alchemy

• I.4 Consensus Mechanism: Alchemy is present on the following networks: Binance Smart Chain, Ethereum. Binance Smart Chain (BSC) uses a hybrid consensus mechanism called Proof of Staked Authority (PoSA), which combines elements of Delegated Proof of Stake (DPoS) and Proof of Authority (PoA). This method ensures fast block times and low fees while maintaining a level of decentralization and security. Core Components 1. Validators (so-called "Cabinet Members"): Validators on BSC are responsible for producing new blocks, validating transactions, and maintaining the network's security. To become a validator, an entity must stake a significant amount of BNB (Binance Coin). Validators are selected through staking and voting by token holders. There are 21 active validators at any given time, rotating to ensure decentralization and security. 2. Delegators: Token holders who do not wish to run validator nodes can delegate their BNB tokens to validators. This delegation helps validators increase their stake and improves their chances of being selected to produce blocks. Delegators earn a share of the rewards that validators receive, incentivizing broad participation in network security. 3. Candidates: Candidates are nodes that have staked the required amount of BNB and are in the pool waiting to become validators. They are essentially potential validators who are not currently active but can be elected to the validator set through community voting. Candidates play a crucial role in ensuring there is always a sufficient pool of nodes ready to take on validation tasks, thus maintaining network resilience and decentralization. Consensus Process 4. Validator Selection: Validators are chosen based on the amount of BNB staked and votes received from delegators. The more BNB staked and votes received, the higher the chance of being selected to validate transactions and produce new blocks. The selection process involves both the current validators and the pool of candidates, ensuring a dynamic and secure rotation of nodes. 5. Block Production: The selected validators take turns producing blocks in a PoA-like manner, ensuring that blocks are generated quickly and efficiently. Validators validate transactions, add them to new blocks, and broadcast these blocks to the network. 6. Transaction Finality: BSC achieves fast block times of around 3 seconds and quick transaction finality. This is achieved through the efficient PoSA mechanism that allows validators to rapidly reach consensus. Security and Economic Incentives 7. Staking: Validators are required to stake a substantial amount of BNB, which acts as collateral to ensure their honest behavior. This staked amount can be slashed if validators act maliciously. Staking incentivizes validators to act in the network's best interest to avoid losing their staked BNB. 8. Delegation and Rewards: Delegators earn rewards proportional to their stake in validators. This incentivizes them to choose reliable validators and participate in the network's security. Validators and delegators share transaction fees as rewards, which provides continuous economic incentives to maintain network security and performance. 9. Transaction Fees: BSC employs low transaction fees, paid in BNB, making it cost-effective for users. These fees are collected by validators as part of their rewards, further incentivizing them to validate transactions accurately and efficiently. The crypto-asset's Proof-of-Stake (PoS) consensus mechanism, introduced with The Merge in 2022, replaces mining with validator staking. Validators must stake at least 32 ETH every block a validator is randomly chosen to propose the next block. Once proposed the other validators verify the blocks integrity. The network operates on a slot and epoch system, where a new block is proposed every 12 seconds, and finalization occurs after two epochs (~12.8 minutes) using Casper-FFG. The Beacon Chain coordinates validators, while the fork-choice rule (LMD-GHOST) ensures the chain follows the heaviest accumulated validator votes. Validators earn rewards for proposing and verifying blocks, but face slashing for malicious behavior or inactivity. PoS aims to improve energy efficiency, security, and scalability, with future upgrades like Proto-Danksharding enhancing transaction efficiency.

• I.5 Incentive Mechanisms and Applicable Fees: Alchemy is present on the following networks: Binance Smart Chain, Ethereum. Binance Smart Chain (BSC) uses the Proof of Staked Authority (PoSA) consensus mechanism to ensure network security and incentivize participation from validators and delegators. Incentive Mechanisms 1. Validators: Staking Rewards: Validators must stake a significant amount of BNB to participate in the consensus process. They earn rewards in the form of transaction fees and block rewards. Selection Process: Validators are selected based on the amount of BNB staked and the votes received from delegators. The more BNB staked and votes received, the higher the chances of being selected to validate transactions and produce new blocks. 2. Delegators: Delegated Staking: Token holders can delegate their BNB to validators. This delegation increases the validator's total stake and improves their chances of being selected to produce blocks. Shared Rewards: Delegators earn a portion of the rewards that validators receive. This incentivizes token holders to participate in the network's security and decentralization by choosing reliable validators. 3. Candidates: Pool of Potential Validators: Candidates are nodes that have staked the required amount of BNB and are waiting to become active validators. They ensure that there is always a sufficient pool of nodes ready to take on validation tasks, maintaining network resilience. 4. Economic Security: Slashing: Validators can be penalized for malicious behavior or failure to perform their duties. Penalties include slashing a portion of their staked tokens, ensuring that validators act in the best interest of the network. Opportunity Cost: Staking requires validators and delegators to lock up their BNB tokens, providing an economic incentive to act honestly to avoid losing their staked assets. Fees on the Binance Smart Chain 5. Transaction Fees: Low Fees: BSC is known for its low transaction fees compared to other blockchain networks. These fees are paid in BNB and are essential for maintaining network operations and compensating validators. Dynamic Fee Structure: Transaction fees can vary based on network congestion and the complexity of the transactions. However, BSC ensures that fees remain significantly lower than those on the Ethereum mainnet. 6. Block Rewards: Incentivizing Validators: Validators earn block rewards in addition to transaction fees. These rewards are distributed to validators for their role in maintaining the network and processing transactions. 7. Cross-Chain Fees: Interoperability Costs: BSC supports cross-chain compatibility, allowing assets to be transferred between Binance Chain and Binance Smart Chain. These cross-chain operations incur minimal fees, facilitating seamless asset transfers and improving user experience. 8. Smart Contract Fees: Deployment and Execution Costs: Deploying and interacting with smart contracts on BSC involves paying fees based on the computational resources required. These fees are also paid in BNB and are designed to be cost-effective, encouraging developers to build on the BSC platform. The crypto-asset's PoS system secures transactions through validator incentives and economic penalties. Validators stake at least 32 ETH and earn rewards for proposing blocks, attesting to valid ones, and participating in sync committees. Rewards are paid in newly issued ETH and transaction fees. Under EIP-1559, transaction fees consist of a base fee, which is burned to reduce supply, and an optional priority fee (tip) paid to validators. Validators face slashing if they act maliciously and incur penalties for inactivity. This system aims to increase security by aligning incentives while making the crypto-asset's fee structure more predictable and deflationary during high network activity.

• I.6 Beginning of the period to which the disclosure relates: 2024-10-16

• I.7 End of the period to which the disclosure relates: 2025-10-16

• I.8 Energy consumption: 326.85047 (kWh/a)

• I.9 Energy consumption sources and methodologies: The energy consumption of this asset is aggregated across multiple components: To determine the energy consumption of a token, the energy consumption of the network(s) binance_smart_chain, ethereum is calculated first. For the energy consumption of the token, a fraction of the energy consumption of the network is attributed to the token, which is determined based on the activity of the crypto-asset within the network. When calculating the energy consumption, the Functionally Fungible Group Digital Token Identifier (FFG DTI) is used - if available - to determine all implementations of the asset in scope. The mappings are updated regularly, based on data of the Digital Token Identifier Foundation. The information regarding the hardware used and the number of participants in the network is based on assumptions that are verified with best effort using empirical data. In general, participants are assumed to be largely economically rational. As a precautionary principle, we make assumptions on the conservative side when in doubt, i.e. making higher estimates for the adverse impacts.

VII. GLOSSARY

• Consensus Mechanism: Shall mean the rules and procedures by which an agreement is reached, among the DLT network nodes, that a transaction is validated.

• Crypto-Asset: Shall mean 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.

• Distributed Ledger Technology or DLT: shall mean the technology that enables the operation and use of distributed ledgers.

• Home Member State: Shall mean either (a) where the offeror or person seeking admission to trading of crypto-assets other than asset-referenced tokens or e-money tokens has its registered office in the Union, the Member State where that offeror or person has its registered office; or (b) where the offeror or person seeking admission to trading of crypto-assets other than asset-referenced tokens or e-money tokens has no registered office in the Union but does have one or more branches in the Union, the Member State chosen by that offeror or person from among the Member States where it has branches; or (c) where the offeror or person seeking admission to trading of crypto-assets other than asset-referenced tokens or e-money tokens is established in a third country and has no branch in the Union, either the Member State where the crypto-assets are intended to be offered to the public for the first time or, at the choice of the offeror or person seeking admission to trading, the Member State where the first application for admission to trading of those crypto-assets is made; or (d) in the case of an Issuer of asset-referenced tokens, the Member State where the Issuer of asset-referenced tokens has its registered office; or (e) in the case of an Issuer of e-money tokens, the Member State where the Issuer of e-money tokens is authorised as a credit institution under Directive 2013/36/EU or as an electronic money institution under Directive 2009/110/EC; or (f) in the case of crypto-asset service providers, the Member State where the crypto-asset service provider has its registered office.

• Host Member State: Shall mean the Member State where an Offeror or Person Seeking Admission to Trading has made an offer to the Public of Crypto-Assets or is seeking admission to trading, or where a Crypto-Asset Service Provider provides crypto-asset services, where different from the Home Member State.

• Issuer: Shall mean a natural or legal person, or other undertaking, who issues crypto-assets.

• Management Body: Shall mean the body or bodies of an Issuer, Offeror, Person Seeking Admission to Trading, or of a Crypto-Asset Service Provider, which are appointed in accordance with National Law, which are empowered to set the entity's strategy, objectives and overall direction, and which oversee and monitor management decision-making in the entity and include the persons who effectively direct the business of the entity.

• Offer to the Public: Shall mean a communication to persons in any form, and by any means, presenting sufficient information on the terms of the offer and the crypto-assets to be offered so as to enable prospective holders to decide whether to purchase those crypto-assets.

• Offeror: Shall mean a natural or legal person, or other undertaking, or the Issuer, who offers crypto-assets to the public.

• Operator: Shall mean the entity that runs a trading platform for crypto-assets.

• Qualified Investors: Shall mean persons or entities that are listed in Section I, points (1) to (4), of Annex II to Directive 2014/65/EU.

• Retail Investor/Holder: Shall means any natural person who is acting for purposes which are outside that person's trade, business, craft or profession.

• Utility Token: Shall mean a type of crypto-asset that is only intended to provide access to a good or a service supplied by its Issuer.