MiCA White Paper

2026-04-03

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.

This crypto-asset white paper complies with Title II of Regulation (EU) 2023/1114 of the European Parliament and of the Council and, to the best of the knowledge of the management body, the information presented in the crypto-asset white paper is fair, clear and not misleading and the crypto-asset white paper makes no omission likely to affect its import.

The crypto-asset referred to in this crypto-asset white paper may lose its value in part or in full, may not always be transferable and may not be liquid.

As defined in Article 3(9) of Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on Markets in Crypto-Assets – amending Regulations (EU) No 1093/2010 and (EU) No 1095/2010 and Directives 2013/36/EU and (EU) 2019/1937 – a utility token is “a type of crypto-asset that is only intended to provide access to a good or a service supplied by its issuer”. This crypto-asset does not qualify as a utility token, as its intended use goes beyond providing access to a good or service supplied solely by the issuer.

The crypto-asset referred to in this white paper is not covered by the investor compensation schemes under Directive 97/9/EC of the European Parliament and of the Council or the deposit guarantee schemes under Directive 2014/49/EU of the European Parliament and of the Council.

Warning:
This summary should be read as an introduction to the crypto-asset white paper. The prospective holder should base any decision to purchase this crypto–asset on the content of the crypto-asset white paper as a whole and not on the summary alone. The offer to the public of this crypto-asset does not constitute an offer or solicitation to purchase financial instruments and any such offer or solicitation can be made only by means of a prospectus or other 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.

The crypto-asset NatGold Token (NATG) referred to in this white paper is a crypto-asset other than EMTs and ARTs, and is issued on the Ethereum network. The maximum supply of the crypto-asset is not fixed. Total token supply is determined through standardized tokenization ratios that are applied uniformly to independently verified, in‑ground gold resources based on geological confidence levels.

NatGold Token is issued as a standard ERC‑20 token. It represents independently verified, in‑ground gold resources (“Certified NatGold Resources”) that remain permanently in the ground (no physical extraction). Token issuance is gated by third‑party technical reporting, AML due diligence and legal transfer of qualifying subsurface mineral rights to NatGold. Key infrastructure built around NATG includes: (i) a certification and qualification workflow anchored to NI 43‑101/JORC/S‑K 1300 reporting; (ii) a legal custody framework for subsurface mineral rights; and (iii) smart-contract based issuance on a public blockchain.

NatGold tokens do not provide equity ownership, governance or voting rights, revenue participation, dividends, yield, or physical redemption. There is no issuer commitment to price stability and purchasers are advised that value of NatGold Tokens may be volatile and subject to a number of external influencing factors. NatGold Tokens function as a blockchain-native representation of certified in-ground gold resources and may be held, transferred, and traded on supported secondary markets.

Not applicable.

NATGOLD INTEGRITY VAULT LLC is seeking admission to trading on Payward Global Solutions LTD (“Kraken”) platform in the European Union in accordance with Article 5 of Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on Markets in Crypto-Assets, and amending Regulations (EU) No 1093/2010 and (EU) No 1095/2010 and Directives 2013/36/EU and (EU) 2019/1937.

US-DE

US-DE

254900KUJXF09EV47T51

+41798880918

Issuance and management of blockchain-based crypto-assets representing a beneficial interest in independently verified in-ground gold resources.

The business activity per se of NatGold Integrity Vault LLC is the same as for its parent (NatGold Digital Ltd.). The specific purpose of the 100% owned subsidiary is to be the legal custodian of all the subsurface mineral rights that support Certified NatGold Resources – those inground gold deposits that have passed the third-party due diligence process and that are approved for tokenization.

Issuance and management of blockchain-based crypto-assets representing a beneficial interest in independently verified in-ground gold resources.

Not applicable.

2025:

The company focused on the development of its ecosystem, smart contract architecture, and trading platform engagement. The company remained in pre-revenue phase. Note: the company was funded by its parent and all related expenses and fees were routed via its parent, NatGold Digital Ltd.

Not applicable.

Not applicable since NATGOLD INTEGRITY VAULT LLC is not a trading platform.

Long Name: “NatGold Token”, Short Name: “NATG” according to the Digital Token Identifier Foundation (www.dtif.org, DTI see F.13, FFG DTI see F.14 as of 2026-03-04).

Long Name: “NatGold Token” according to the Digital Token Identifier Foundation (www.dtif.org, DTI see F.13, FFG DTI see F.14 as of 2026-03-04).

Short Name: “NATG” according to the Digital Token Identifier Foundation (www.dtif.org, DTI see F.13, FFG DTI see F.14 as of 2026-03-04).

NatGold Token (NATG) is a digital asset representing independently verified, in-ground gold resources that have been certified under globally recognized technical reporting standards (NI 43-101, JORC Code, or S-K 1300).

Unlike traditional gold products that reference physically extracted bullion held in vaults, NatGold Tokens represent an economic interest in gold resources that remain permanently in the ground and are never physically mined. The utility of the token is to provide blockchain-native, transferable exposure to gold without physical extraction, refining, transportation, storage, or vaulting.

NatGold Tokens are comparable to other gold ownership instruments – such as physical bullion held through custodians or tokenized gold assets – that rely on contractual or custodial representations rather than direct possession of metal. The key distinction is structural: NatGold’s model eliminates extraction-related costs, environmental impact, and ongoing carrying expenses, while maintaining a transparent linkage to independently verified gold resources.

NatGold Tokens do not provide equity ownership, governance or voting rights, revenue participation, dividends, yield, or physical redemption. NatGold Tokens function as a blockchain-native representation of certified in-ground gold resources and may be held, transferred, and traded on supported secondary markets. Compared to traditional physical gold supply chains (mining, processing, refining, transport, vaulting), NatGold’s model is intended to reduce extraction-related environmental/societal impact and ongoing physical logistics.

This section provides an overview of the historical developments related to the NATG crypto-asset and a description of planned or anticipated project milestones.

Past milestones:

– First Gold Resource Submitted for Tokenisation (November 2025) – The first gold resource intended to support the NatGold ecosystem was reportedly submitted for tokenisation. At the time of disclosure, the asset was undergoing due diligence procedures and technical evaluation as part of the preparation process for potential token issuance.

– Finalisation of the First Version of the Smart Contract (January 2026) – According to publicly communicated project updates, the initial version of the NATG smart contract was finalised. This version is intended to support the technical framework for token issuance and on-chain functionality.

Future milestones:

– Finalisation of Custodian Onboarding and Ecosystem Setup (April – estimated) – Project communications indicate that the onboarding of a custodian responsible for the underlying asset arrangements and the completion of initial ecosystem infrastructure are expected to be finalised.

– Token Launch and Expected Public Listing (May 2026 – estimated) – The project anticipates the launch of the NATG crypto-asset and a potential public listing on trading platforms, subject to technical readiness, market conditions, and other operational considerations.

Note: All future milestones are subject to significant uncertainty, including but not limited to technical feasibility, regulatory developments, market adoption, and community governance decisions.

NatGold has completed several private funding rounds with external investors, raising approximately USD 7.5 million in total.

The purpose of seeking admission to trading is to enable the crypto-asset to be listed on a regulated platform in accordance with the applicable provisions of Regulation (EU) 2023/1114 and Commission Implementing Regulation (EU) 2024/2984. The white paper has been drawn up to comply with the transparency requirements applicable to trading venues.

Holder restrictions are subject to the rules applicable to the crypto-asset service provider, as well as any additional restrictions that provider may impose.

The token is intended to be initially listed on the trading platform operated by Payward Global Solutions LTD (“Kraken”). Access to this platform depends on regional availability and user eligibility under Kraken’s terms and conditions. Investors should consult Kraken’s official documentation to determine whether they meet the requirements for account creation and token trading.

The costs involved in accessing the trading platform depend on the specific fee structure and terms of the respective crypto-asset service provider. These may include trading fees, deposit or withdrawal charges, and network-related gas fees. Investors are advised to consult the applicable fee schedule of the chosen platform before engaging in trading activities.

Not applicable, as this white paper is written to seek admission to trading, not for the initial offer to the public.

MiCA-compliant Crypto Asset Service Providers shall have strong measurements in place in order to manage conflicts of interests. Due to the broad audience this white-paper is addressing, potential investors should always check the conflicts of Interest policy of their respective counterparty.

Not applicable, as this white paper is written to seek admission to trading, not for the initial offer to the public.

Not applicable, as this white paper is written to seek admission to trading, not for the initial offer to the public.

The crypto-asset described in the white paper is classified as a crypto-asset under the Markets in Crypto-Assets Regulation (MiCA) but is neither classified as an electronic money token (EMT) nor an asset-referenced token (ART). It is a digital representation of value that can be stored and transferred using distributed ledger technology (DLT) or similar technology, without embodying or conferring any rights to its holder. The crypto-asset is not categorised as a financial instrument, deposit, insurance product, pension product, or any other regulated financial product under EU law. It does not grant financial rights, voting rights, or any contractual claims to its holders, and therefore remains outside the scope of regulatory frameworks applicable to traditional financial instruments.

NatGold Tokens are minted only following the successful completion of independent technical, legal, and AML due diligence and the irrevocable transfer of subsurface mineral rights to NatGold Digital. Token issuance is therefore tied to the quantity of gold resources that have been independently certified and approved for tokenization.

Total token supply is determined through standardized tokenization ratios that are applied uniformly based on geological confidence levels. These ratios establish the proportion of estimated resources eligible for tokenization. For example, Measured Resources are tokenized at 80%, meaning that for every 100 troy ounces of Measured Resources, NatGold will not tokenize 20% of the estimated resources. Indicated Resources are tokenized at 40%, and Inferred Resources at 20%; deposits consisting solely of Inferred Resources are not eligible for tokenization. These confidence levels – Measured, Indicated, and Inferred Resources – are industry-standard mining classifications defined under globally recognized technical reporting frameworks such as NI 43-101, JORC Code, and S-K 1300.

NATG is non-inflationary. Total supply is not fixed in advance but is constrained by independently certified resources. Supply may be reduced through token burning if certified resources are removed or in connection with legal, regulatory, or integrity actions, to maintain alignment between tokens outstanding and certified resources.

Token issuance is determined by recognized mining classification standards and standardized tokenization ratios. There is no redemption mechanism, no yield, and no issuer commitment to price stability.

Future milestones:

– Finalisation of Custodian Onboarding and Ecosystem Setup (April 2026 – estimated) – Project communications indicate that the onboarding of a custodian responsible for the underlying asset arrangements and the completion of initial ecosystem infrastructure are expected to be finalised.

– Token Launch and Expected Public Listing (May 2026 – estimated) – The project anticipates the launch of the NATG crypto-asset and a potential public listing on trading platforms, subject to technical readiness, market conditions, and other operational considerations.

Note: All future milestones are subject to significant uncertainty, including but not limited to technical feasibility, regulatory developments, market adoption, and community governance decisions.

The crypto-asset referred to herein is a crypto-asset other than EMTs and ARTs, and is available on the Ethereum network. The crypto-asset is fungible up to 18 digits after the decimal point. The crypto-asset constitutes a digital representation recorded on distributed-ledger technology and does not confer ownership, governance, profit participation, or any other legally enforceable rights. Any functionalities associated with the token are limited to potential technical features within the relevant platform environment.

Long Name: “NatGold Token” according to the Digital Token Identifier Foundation (www.dtif.org, DTI see F.13, FFG DTI see F.14 as of 2026-03-04).

https://natgold.com/

2026-05-07

2026-05-07

No such services are currently provided by the issuer.

EN

VNVWKPZTZ

RZF8Q6GLN

The crypto-asset does not grant any legally enforceable or contractual rights or obligations to its holders or purchasers. Any functionalities accessible through the underlying technology are of a purely technical or operational nature and do not constitute rights comparable to ownership, profit participation, governance, or similar entitlements known from traditional financial instruments. Accordingly, holders do not acquire any legally enforceable claim against the issuer of the crypto-asset or any third party.

As the crypto-asset does not confer any legally enforceable rights or obligations, there are no applicable procedures or conditions for their exercise. Any interaction or functionality that may be available within the project’s technical infrastructure – such as participation mechanisms or protocol-level features – serves operational purposes only and does not create, evidence, or constitute any contractual or statutory entitlement.

As the crypto-asset does not confer any legally enforceable rights or obligations, there are no conditions or mechanisms for modifying such rights or obligations. Adjustments to the technical protocol, smart contract logic, or related systems may occur in the ordinary course of development or maintenance. Such changes do not alter the legal position of holders, as no contractual rights exist and no rights arise under applicable law or regulation. Holders should not interpret technical updates or governance-related changes as amendments to legally binding entitlements.

Information on the future offers to the public of crypto-assets were not available at the time of writing this white paper (2026-03-06).

The crypto-assets themselves are not subject to any technical or contractual transfer restrictions and are generally freely transferable. However, crypto-asset service providers may impose restrictions on buyers or sellers in accordance with applicable laws, internal policies or contractual terms agreed with their clients.

Not applicable.

This white paper is submitted by NatGold Digital Ltd., incorporated in Nevada, United States. Accordingly, this white paper shall be governed by the laws of Nevada.

Any disputes arising in relation to this framework or its implementation may be brought before the competent courts in Carson City, Nevada.

The crypto-asset in scope is implemented on the Ethereum network after minting following the standards described below.

The crypto-asset that is the subject of this white paper is available on the Ethereum network after minting of the token.

The following applies to Ethereum:

The crypto-asset operates on a well-defined set of protocols and technical standards that are intended to ensure its security, decentralization, and functionality. Below are some of the key ones:

1. Network Protocols

The crypto-asset follows a decentralized, peer-to-peer (P2P) protocol where nodes communicate over the crypto-asset’s DevP2P protocol using RLPx for data encoding.

– Transactions and smart contract execution are secured through Proof-of-Stake (PoS) consensus.

– Validators propose and attest blocks in Ethereum’s Beacon Chain, finalized through Casper FFG.

– The Ethereum Virtual Machine (EVM) executes smart contracts using Turing-complete bytecode.

2. Transaction and Address Standards

crypto-asset Address Format: 20-byte addresses derived from Keccak-256 hashing of public keys.

Transaction Types:

– Legacy Transactions (pre-EIP-1559)

– Type 0 (Pre-EIP-1559 transactions)

– Type 1 (EIP-2930: Access list transactions)

– Type 2 (EIP-1559: Dynamic fee transactions with base fee burning)

The Pectra upgrade introduces EIP-7702, a transformative improvement to account abstraction. This allows externally owned accounts (EOAs) to temporarily act as smart contract wallets during a transaction. It provides significant flexibility, enabling functionality such as sponsored gas payments and batched operations without changing the underlying account model permanently.

3. Blockchain Data Structure & Block Standards

– the crypto-asset’s blockchain consists of accounts, smart contracts, and storage states, maintained through Merkle Patricia Trees for efficient verification.

Each block contains:

– Block Header: Parent hash, state root, transactions root, receipts root, timestamp, gas limit, gas used, proposer signature.

– Transactions: Smart contract executions and token transfers.

– Block Size: No fixed limit; constrained by the gas limit per block (variable over time). In line with Ethereum’s scalability roadmap, Pectra includes EIP-7691, which increases the maximum number of “blobs” (data chunks introduced with EIP-4844) per block. This change significantly boosts the data availability layer used by rollups, supporting cheaper and more efficient Layer 2 scalability.

4. Upgrade & Improvement Standards

Ethereum follows the Ethereum Improvement Proposal (EIP) process for upgrades.

The crypto-asset that is the subject of this white paper is available on the Ethereum network after minting of the token.

The following applies to Ethereum:

1. Decentralized Ledger: The Ethereum blockchain acts as a decentralized ledger for all token transactions, with the intention to preserving an unalterable record of token transfers and ownership to ensure both transparency and security.

2. Private Key Management: To safeguard their token holdings, users must securely store their wallet’s private keys and recovery phrases.

3. Cryptographic Integrity: Ethereum employs elliptic curve cryptography to validate and execute transactions securely, intended to ensure the integrity of all transfers. The Keccak-256 (SHA-3 variant) Hashing Algorithm is used for hashing and address generation. The crypto-asset uses ECDSA with secp256k1 curve for key generation and digital signatures. Next to that, BLS (Boneh-Lynn-Shacham) signatures are used for validator aggregation in PoS.

The crypto-asset that is the subject of this white paper is available on the Ethereum network after minting of the token.

The following applies to Ethereum:

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, and a validator is randomly selected to propose each new 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.

The crypto-asset that is the subject of this white paper is available on the Ethereum network after minting of the token.

The following applies to Ethereum:

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.

Not applicable, as the DLT is not operated by the issuer, the offeror, the person seeking admission to trading, or any third-party acting on their behalf.

NatGold smart contract infrastructure has undergone an independent security code review conducted by FYEO Inc., a Web3 security auditing firm. The review (source: https://github.com/fyeo-io/public-audit-reports/tree/main/Code%20Audit%20Reports/2026/NatGold, accessed 2026-03-04) covered the core smart-contract system responsible for the tokenization and lifecycle management of NatGold mining projects.

FYEO (February 2026) – Core Smart Contract Infrastructure

– Identified 5 informational findings classified as general security recommendations

– No vulnerabilities were identified in the critical, high, medium, or low severity categories

– All informational recommendations were reviewed and remediated by the development team

The audit focused on the NatGoldQueueOrchestrator.sol contract, which manages project intake, approval workflows, and lifecycle state transitions, and the NatGoldToken.sol contract responsible for token minting and distribution. The system architecture also incorporates role-based access controls and multi-signature administrative governance using a Gnosis Safe configuration.

Overall Assessment:

The independent review identified no security vulnerabilities across low to critical severity levels. All informational recommendations were addressed following the review. Based on the publicly disclosed audit outcome, the NatGold smart contract system demonstrated a baseline security posture at the time of assessment.

1. Regulatory and Compliance

Regulatory frameworks applicable to crypto-asset services in the European Union and in third countries are evolving. Supervisory authorities may introduce, interpret, or enforce rules that affect (i) the eligibility of this crypto-asset for admission to trading, (ii) the conditions under which a crypto-asset service provider may offer trading, custody, or transfer services for it, or (iii) the persons or jurisdictions to which such services may be provided. As a result, the crypto-asset service provider admitting this crypto-asset to trading may be required to suspend, restrict, or terminate trading or withdrawals for regulatory reasons, even if the crypto-asset itself continues to function on its underlying network.

2. Trading venue and connection risk

Trading in the crypto-asset depends on the uninterrupted operation of the trading venues on which it is listed and, where applicable, on its technical connections to external liquidity sources or venues. Interruptions such as system downtime, maintenance, faulty integrations, API changes, or failures at an external venue can temporarily prevent order placement, execution, deposits, or withdrawals, even when the underlying blockchain is functioning. In addition, trading platforms in emerging markets may operate under differing governance, compliance, and oversight standards, which can increase the risk of operational failures or disorderly market conditions.

3. Market formation and liquidity conditions

The price and tradability of the crypto-asset depend on actual trading activity on the venues to which the service provider is connected, whether centralised exchanges (CEXs) or decentralised exchanges (DEXs). Trading volumes may at times be low, order books thin, or liquidity concentrated on a single venue. In such conditions, buy or sell orders may not be executed in full or may be executed only at a less favourable price, resulting in slippage.

Volatility: The market price of the crypto-asset may fluctuate significantly over short periods, including for reasons that are not linked to changes in the underlying project or protocol. Periods of limited liquidity, shifts in overall market sentiment, or trading on only a small number of CEXs or DEXs can amplify these movements and lead to higher slippage when orders are executed. As a result, investors may be unable to sell the crypto-asset at or close to a previously observed price, even where no negative project-specific event has occurred.

4. Counterparty and service provider dependence

The admission of the crypto-asset to trading may rely on several external parties, such as connected centralised or decentralised trading venues, liquidity providers, brokers, custodians, or technical integrators. If any of these counterparties fail to perform, suspend their services, or apply internal restrictions, the trading, deposit, or withdrawal of the crypto-asset on the listing crypto-asset service provider can be interrupted or halted.

Quality of counterparties: Trading venues and service providers in certain jurisdictions may operate under regulatory or supervisory standards that are lower or differently enforced than those applicable in the European Union. In such environments, deficiencies in governance, risk management, or compliance may remain undetected, which increases the probability of abrupt service interruptions, investigations, or forced wind-downs.

Delisting and service suspension: The crypto-asset’s availability may depend on the internal listing decisions of these counterparties. A delisting or suspension on a key connected venue can materially reduce liquidity or make trading temporarily impossible on the admitting service provider, even if the underlying crypto-asset continues to function.

Insolvency of counterparties: If a counterparty involved in holding, routing, or settling the crypto-asset becomes insolvent, enters restructuring, or is otherwise subject to resolution measures, assets held or processed by that counterparty may be frozen, become temporarily unavailable, or be recoverable only in part or not at all, which can result in losses for clients whose positions were maintained through that counterparty. This risk applies in particular where client assets are held on an omnibus basis or where segregation is not fully recognised in the counterparty’s jurisdiction.

5. Operational and information risks

Due to the irrevocability of blockchain transactions, incorrect transaction approvals or the use of wrong networks or addresses will typically make the transferred funds irrecoverable. Because trading may also rely on technical connections to other venues or service providers, downtime or faulty code in these connections can temporarily block trading, deposits, or withdrawals even when the underlying blockchain is functioning. In addition, different groups of market participants may have unequal access to technical, governance, or project-related information, which can lead to information asymmetry and place less informed investors at a disadvantage when making trading decisions.

6. Market access and liquidity concentration risk

If the crypto-asset is only available on a limited number of trading platforms or through a single market-making entity, this may result in reduced liquidity, greater price volatility, or periods of inaccessibility for retail holders.

1. Insolvency of the issuer

As with any commercial entity, NatGold may face insolvency, liquidity, or broader financial distress risks. These may result from insufficient funding, reduced market interest, adverse business performance, unexpected liabilities, mismanagement, disputes, or external shocks such as pandemics, armed conflicts, macroeconomic disruption, or adverse regulatory developments. In such circumstances, NatGold may be unable to continue operations, maintain the project, protect or administer the NatGold Certified Resources and related rights, implement contingency measures, or meet its legal, operational, or disclosure obligations. This may negatively affect the viability, market confidence, tradability, or value of the NatGold Tokens.

2. Legal and regulatory risks

NatGold operates in a dynamic and evolving legal and regulatory environment. Failure to comply with applicable laws, regulations, permit requirements, disclosure obligations, sanctions regimes, tax rules, consumer protection rules, anti-money laundering obligations, or other regulatory requirements in relevant jurisdictions may result in investigations, enforcement actions, penalties, restrictions, litigation, or limitations on NatGold’s operations. In addition, changes in the regulatory treatment of blockchain technology, crypto-assets, tokenized structures, mineral rights, land use, or resource-related activities may require NatGold to modify its operations, legal structure, disclosures, or business model. Any such event may negatively impact the issuance, availability, market acceptance, legal status, or value of the NatGold Tokens.

3. Operational risks

NatGold may fail to implement or maintain adequate internal controls, risk management procedures, documentation standards, monitoring systems, recordkeeping, or governance processes. Operational weaknesses may lead to disruption of business activities, inaccurate disclosures, delays in updating the white paper, failures in managing asset-related information, deficiencies in oversight of service providers, financial losses, or reputational harm. Operational failures may also impair NatGold’s ability to respond effectively to adverse events affecting the NatGold Certified Resources or the NatGold Tokens.

4. Governance and decision-making risk

NatGold’s management body is responsible for key strategic, operational, legal, and disclosure decisions relating to the project and the NatGold Tokens. Ineffective governance, delays in decision-making, conflicts of interest, weak oversight, inadequate staffing, concentration of authority, or changes in ownership or control may compromise the stability of the project, the quality of issuer decision-making, and NatGold’s ability to comply with MiCA requirements and other applicable obligations. These factors may negatively affect market confidence and the perceived credibility of the NatGold Tokens.

5. Reputational risks

NatGold’s reputation may be harmed by internal failures, external allegations, litigation, regulatory scrutiny, disputes relating to the NatGold Certified Resources or associated rights, negative media coverage, or actual or perceived association with illicit activity or unethical practices involving NatGold, its parent entities, affiliates, or associated partners. Reputational damage affecting NatGold, its parent entities, or affiliates may reduce trust in NatGold as issuer and may negatively affect the market perception, acceptance, liquidity, or value of the NatGold Tokens.

6. Counterparty dependence

NatGold may depend on third-party service providers, advisers, contractors, consultants, custodians, infrastructure providers, technical developers, legal advisers, or other counterparties for functions relevant to the project and the NatGold Tokens. NatGold may also depend on third parties in relation to documentation, verification, certification, management, or protection of the NatGold Certified Resources and associated rights. If such third parties discontinue their services, fail to perform as expected, become insolvent, change ownership, are subject to legal or regulatory action, or otherwise underperform, NatGold’s ability to operate the project, maintain compliance, communicate with token holders, or preserve confidence in the project may be impaired. This could disrupt project continuity and adversely affect the value of the NatGold Tokens.

7. Rights administration and contingency mechanism risk

NatGold’s ability to support confidence in the NatGold Tokens depends in part on its ability to secure, maintain, document, defend, and administer the Qualified Mineral Rights and other rights or arrangements relevant to the NatGold Certified Resources, as well as to operate any contingency mechanisms it may establish. NatGold may face legal, administrative, operational, or financial difficulties in protecting such rights or in implementing contingency measures in the event of loss, expropriation, impairment, or competing claims. Although NatGold may establish a contingency fund comprised of a dedicated allocation of NatGold Tokens and/or other assets that may, where appropriate and at NatGold’s discretion, be used to burn NatGold Tokens in certain adverse scenarios, NatGold cannot guarantee that such mechanisms will be available, sufficient, timely, or effective, nor that any holder will be fully compensated or otherwise made whole.

Even where NatGold implements internal controls, governance measures, third-party oversight arrangements, and contingency mechanisms, these may not operate as intended or may prove insufficient in practice. As a result, the occurrence of one or more of the risks described above may adversely affect NatGold’s ability to operate the project, comply with applicable requirements, maintain market confidence, and support the value or utility of the NatGold Tokens.

1. Valuation risk

The crypto-asset does not represent a redemption claim, a right to receive physical gold, a right to mining proceeds, or any other enforceable claim against the underlying in-ground resources referenced by the issuer. While token issuance is stated to represent independently verified subsurface gold resources, such linkage does not constitute asset backing in the sense of providing holders with a right of recourse, guaranteed recoverable value, or price stability mechanism. Accordingly, the value of the crypto-asset may be highly speculative and may depend largely on market sentiment, supply and demand, and confidence in the issuer’s methodology and disclosures. As there is no redemption mechanism, no yield, and no commitment by the issuer to stabilise the price, holders may lose all of the value of their investment.

2. Market volatility risk

Crypto-asset prices can fluctuate sharply due to changes in market sentiment, macroeconomic conditions, regulatory developments, or technology trends. Such volatility may result in rapid and significant losses. Holders should be prepared for the possibility of losing the full amount invested.

3. Liquidity and price-determination risk

Low trading volumes, fragmented trading across venues, or the absence of active market makers can restrict the ability to buy or sell the crypto-asset. In such situations, it is not guaranteed that an observable market price will exist at all times. Spreads may widen materially, and orders may only be executable under unfavourable conditions, which can make liquidation costly or temporarily impossible. Investors may not be able to sell due to limited liquidity.

4. Crypto-asset security risk

Loss or theft of private keys, unauthorised access to wallets, or failures of custodial or exchange service providers can result in the irreversible loss of assets. Because blockchain transactions are final, recovery of funds after a compromise is generally impossible.

5. Fraud and scam risk

The pseudonymous and irreversible nature of blockchain transactions can attract fraudulent schemes. Typical forms include fake or unauthorised crypto-assets imitating established ones, phishing attempts, deceptive airdrops, or social-engineering attacks. Investors should exercise caution and verify the authenticity of counterparties and information sources.

6. Legal and regulatory reclassification risk

Legislative or regulatory changes in the European Union or in the Member State where the crypto-asset is admitted to trading may alter its legal classification, permitted uses, or tradability. In third countries, the crypto-asset may be treated as a financial instrument or security, which can restrict its offering, trading, or custody.

7. Absence of investor protection

The crypto-asset is not covered by investor-compensation or deposit-guarantee schemes. In the event of loss, fraud, or insolvency of a service provider, holders may have no access to recourse mechanisms typically available in regulated financial markets.

8. Counterparty risk

Reliance on third-party exchanges, custodians, or intermediaries exposes holders to operational failures, insolvency, or fraud of these parties. Investors should conduct due diligence on service providers, as their failure may lead to the partial or total loss of held assets.

9. Reputational risk

Negative publicity related to security incidents, misuse of blockchain technology, or associations with illicit activity can damage public confidence and reduce the crypto-asset’s market value.

10. Community and sentiment risk

Because the crypto-asset’s perceived relevance and expected future use depend largely on community engagement and the prevailing sentiment, a loss of public interest, negative coverage or reduced activity of key contributors can materially reduce market demand.

11. Macroeconomic and interest-rate risk

Fluctuations in interest rates, exchange rates, general market conditions, or overall market volatility can influence investor sentiment towards digital assets and affect the crypto-asset’s market value.

12. Taxation risk

Tax treatment varies across jurisdictions. Holders are individually responsible for complying with all applicable tax laws, including the reporting and payment of taxes arising from the acquisition, holding, or disposal of the crypto-asset.

13. Anti-money-laundering and counter-terrorist financing risk

Wallet addresses or transactions connected to the crypto-asset may be linked to sanctioned or illicit activity. Regulatory responses to such findings may include transfer restrictions, reporting obligations, or the freezing of assets on certain venues.

14. Market-abuse risk

Due to limited oversight and transparency, crypto-assets may be vulnerable to market-abuse practices such as spoofing, pump-and-dump schemes, or insider trading. Such activities can distort prices and expose holders to sudden losses.

15. Legal ownership and jurisdictional risk

Depending on the applicable law, holders of the crypto-asset may not have enforceable ownership rights or effective legal remedies in cases of disputes, fraud, or service failure. In certain jurisdictions, access to exchanges or interfaces may be restricted by regulatory measures, even if on-chain transfer remains technically possible.

16. Concentration risk

A large proportion of the total supply may be held by a small number of holders. This can enable market manipulation, governance dominance, or sudden large-scale liquidations that adversely affect market stability, price levels, and investor confidence.

A large proportion of the subsurface mineral rights linked to NatGold Certified Resources may be concentrated within a small number of in-ground gold resources. This may cause a risk in the case that this small number of in-ground gold resources are removed, invalidated or otherwise determined to no longer support outstanding tokens, including in connection with legal, regulatory, or integrity actions

1. Asset impairment risk

The NatGold Certified Resources may be adversely affected by unforeseen or catastrophic geological, geotechnical, hydrological, or environmental events, including erosion, prolonged flooding, contamination, unexpected ground instability, sinkholes, or seismic shifts. Such events may cause temporary or permanent damage to the underlying gold deposits or otherwise impair their accessibility, integrity, certification basis, or economic relevance. Any such impairment may negatively affect the project and the value of the NatGold Tokens.

2. Loss, theft, seizure, or expropriation risk

Some or all of the NatGold Certified Resources may be lost, damaged, stolen, seized, nationalized, expropriated, suspended, revoked, or otherwise become inaccessible. Such events may result from third-party conduct, administrative action, political developments, governmental intervention, or other circumstances beyond NatGold’s control. If some or all of the NatGold Certified Resources are affected in this way, the project’s credibility and the value of the NatGold Tokens may be negatively affected.

3. Rights challenge risk

There is a risk that claims, rights, interests, or legal challenges by third parties or public authorities may affect the availability or practical usability of some or all of the NatGold Certified Resources within the project structure. Even where NatGold believes the relevant rights are validly held or documented, competing claims, administrative disputes, or legal uncertainty may interfere with the implementation or continued functioning of the project and may negatively affect the value of the NatGold Tokens.

4. Implementation and delivery risk

The project may not be implemented exactly as described in the white paper, public roadmap, technical documentation, or other project materials. Delays, changes, limitations in scope, technical failures, or dependency on external providers or infrastructure may affect the rollout, maintenance, or functionality of elements relevant to the NatGold Tokens. Even if implementation occurs on schedule, certain features, processes, or integrations may not perform as intended or may be scaled back, suspended, or abandoned, which may reduce the practical utility or perceived credibility of the project.

5. Regulatory impact on project implementation

Changes in the regulatory environment applicable to blockchain technology, crypto-assets, tokenized structures, natural resource-linked arrangements, or related activities may affect the way in which the project can be implemented, maintained, or offered. Regulatory uncertainty or change may require adjustments to the project structure, disclosures, technical setup, or operational model, which may delay implementation or reduce the intended utility of the NatGold Tokens.

Even where mitigation measures, legal protections, operational safeguards, or contingency arrangements are implemented, they may not function as intended or may prove insufficient in the event of loss, impairment, implementation failure, or competing claims affecting the NatGold Certified Resources. As a result, such events may undermine market confidence and negatively affect the practical utility, perceived credibility, or value of the NatGold Tokens.

As this white paper relates to admission to trading of the crypto-asset, the following risks concern the underlying distributed ledger technology (DLT), its supporting infrastructure, and related technical dependencies. Failures or vulnerabilities in these systems may affect the availability, integrity, or transferability of the crypto-asset.

1. Blockchain dependency risk

The functionality of the crypto-asset depends on the continuous and stable operation of the blockchain(s) on which it is issued. Network congestion, outages, or protocol errors may temporarily or permanently disrupt on-chain transactions. Extended downtime or degradation in network performance can affect trading, settlement, or the usability of the crypto-asset.

2. Smart contract vulnerability risk

The smart contract that defines the crypto-asset’s parameters or governs its transfers may contain coding errors or security vulnerabilities. Exploitation of such weaknesses can result in unintended token minting, permanent loss of funds, or disruption of token functionality. Even after external audits, undetected vulnerabilities may persist due to the immutable nature of deployed code.

3. Wallet and key-management risk

The custody of crypto-assets relies on secure private key management. Loss, theft, or compromise of private keys results in irreversible loss of access. Custodians, trading venues, or wallet providers may be targeted by cyberattacks. Compatibility issues between wallet software and changes to the blockchain protocol (e.g. network upgrades) can further limit user access or the ability to transfer the crypto-asset.

Outdated or vulnerable wallet software:

Users relying on outdated, unaudited, or unsupported wallet software may face compatibility issues, security vulnerabilities, or failures when interacting with the blockchain. Failure to update wallet software in line with protocol developments can result in transaction errors, loss of access, or exposure to known exploits.

4. Network security risks

Attack risks: Blockchains may be subject to denial-of-service (DoS) attacks, 51% attacks, or other exploits targeting the consensus mechanism. These can delay transactions, compromise finality, or disrupt the accurate recording of transfers.

Centralisation concerns: Despite claims of decentralisation, a relatively small number of validators or a high concentration of stake may increase the risk of collusion, censorship, or coordinated network downtime, which can affect the resilience and operational reliability of the crypto-asset.

5. Bridge and interoperability risk

Where tokens can be bridged or wrapped across multiple blockchains, vulnerabilities in bridge protocols, validator sets, or locking mechanisms may result in loss, duplication, or misrepresentation of assets. Exploits or technical failures in these systems can instantly impact circulating supply, ownership claims, or token fungibility across chains.

6. Forking and protocol-upgrade risk

Network upgrades or disagreements among node operators or validators can result in blockchain “forks”, where the blockchain splits into two or more incompatible versions that continue separately from a shared past. This may lead to duplicate token representations or incompatibilities between exchanges and wallets. Until consensus stabilises, trading or transfers may be disrupted or misaligned. Such situations may be difficult for retail holders to navigate, particularly when trading platforms or wallets display inconsistent token information.

7. Economic-layer and abstraction risk

Mechanisms such as gas relayers, wrapped tokens, or synthetic representations may alter the transaction economics of the underlying token. Changes in transaction costs, token demand, or utility may reduce its usage and weaken both its economic function and perceived value within its ecosystem.

8. Spam and network-efficiency risk

High volumes of low-value (“dust”) or automated transactions may congest the network, slow validation times, inflate ledger size, and raise transaction costs. This can impair performance, reduce throughput, and expose address patterns to analysis, thereby reducing network efficiency and privacy.

9. Front-end and access-interface risk

If users rely on centralised web interfaces or hosted wallets to interact with the blockchain, service outages, malicious compromises, or domain expiries affecting these interfaces may block access to the crypto-asset, even while the blockchain itself remains fully functional. Dependence on single web portals introduces a critical point of failure outside the DLT layer.

10. Decentralisation claim risk

While the technical infrastructure may appear distributed, the actual governance or economic control of the project may lie with a small set of actors. This disconnect between marketing claims and structural reality can lead to regulatory scrutiny, reputational damage, or legal uncertainty – especially if the project is presented as ‘community-governed’ without substantiation.

None.

NATGOLD INTEGRITY VAULT LLC

254900KUJXF09EV47T51

NatGold Token

The crypto-asset that is the subject of this white paper is available on the Ethereum network.

The following applies to Ethereum:

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, and a validator is randomly selected to propose each new 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.

The crypto-asset that is the subject of this white paper is available on the Ethereum network.

The following applies to Ethereum:

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.

2026-03-01

2027-03-01

The energy consumption associated with this crypto-asset is aggregated of multiple contributing components, primarily the underlying blockchain network and the execution of token-specific operations. To determine the energy consumption of a token, the energy consumption of the underlying blockchain network: Ethereum is calculated first. A proportionate share of that energy use is then attributed to the token based on its expected activity level within the network (e.g. transaction volume, contract execution).

The Functionally Fungible Group Digital Token Identifier (FFG DTI) is used to determine all technically equivalent implementations of the crypto-asset in scope.

Estimates regarding hardware types, node distribution, and the number of network participants are based on informed assumptions, supported by best-effort verification against available empirical data. Unless robust evidence suggests otherwise, participants are assumed to act in an economically rational manner. In line with the precautionary principle, conservative estimates are applied where uncertainty exists – that is, estimates tend towards the higher end of potential environmental impact.

To determine the proportion of renewable energy usage, the locations of the nodes are to be determined using public information sites, open-source crawlers, and crawlers developed in-house. If no information is available on the geographic distribution of the nodes, reference networks are used that are comparable in terms of their incentivization structure and consensus mechanism. This geolocation data is merged with public information from Our World in Data (see citation). The intensity is calculated as the marginal energy cost with respect to an additional transaction. Share of electricity generated by renewables – Ember and Energy Institute” [dataset]. Ember, “Yearly Electricity Data Europe”; Ember, “Yearly Electricity Data”; Energy Institute, “Statistical Review of World Energy” [original data]. Retrieved from https://ourworldindata.org/grapher/share-electricity-renewables.

To determine the GHG Emissions, the locations of the nodes are to be determined using public information sites, open-source crawlers and crawlers developed in-house. If no information is available on the geographic distribution of the nodes, reference networks are used which are comparable in terms of their incentivization structure and consensus mechanism. This geo-information is merged with public information from Our World in Data, see citation. The intensity is calculated as the marginal emission wrt. one more transaction. Ember (2025); Energy Institute – Statistical Review of World Energy (2024) – with major processing by Our World in Data. “Carbon intensity of electricity generation – Ember and Energy Institute” [dataset]. Ember, “Yearly Electricity Data Europe”; Ember, “Yearly Electricity Data”; Energy Institute, “Statistical Review of World Energy” [original data]. Retrieved from https://ourworldindata.org/grapher/carbon-intensity-electricity Licenced under CC BY 4.0.