STOKR Custody and Transfer of Crypto-Assets

How are my crypto-assets protected if STOKR becomes insolvent?

Your crypto-assets remain protected and legally yours at all times, even if STOKR S.A. were to become insolvent. We achieve this through clear rules, internal procedures, and safeguards designed to protect clients.

How your assets are kept separate

• Separate wallets: Your crypto-assets are held in wallets that are dedicated to clients only. They are never mixed with STOKR's own funds or operational accounts.
• Clear ownership: STOKR acts only as a custodian. This means we safeguard your assets on your behalf, but we never become their owner.

Legal protection under EU law

• Protection in insolvency: EU rules (MiCAR) require crypto-asset service providers like STOKR to ensure that client assets are protected if the firm fails. Your crypto-assets are legally separated from STOKR's own assets and cannot be claimed by STOKR's creditors.
• Return of assets: If STOKR were ever to stop operating, clear procedures are in place to ensure your crypto-assets are returned to you without unnecessary delay.

How we ensure this in practice

• Written policies and procedures: STOKR has documented internal rules that describe how client assets are held, recorded, and protected.
• Ongoing controls: We regularly check that client assets match our records and that they remain fully segregated.
• No misuse of assets: STOKR never trades, lends, pledges, or otherwise uses your crypto-assets for its own benefit.

How does STOKR keep my crypto-assets secure and handle transfers?

We protect your crypto-assets using clear security measures, well-defined processes, and transparent communication, so you always understand how your assets are handled.

How we keep your crypto-assets secure

• Strong access controls: Your crypto-assets are protected using systems that require multiple authorised people to approve any action. No single person can move assets alone.
• Encryption and secure storage: Access keys and recovery information are protected using strong security measures and stored securely in protected locations.
• Regular monitoring: Automated systems continuously monitor balances and transactions to detect unusual activity.
• Internal checks: STOKR has internal policies that clearly define who can access systems, how actions are approved, and how errors or incidents are handled.

These arrangements are designed to ensure your assets are protected against loss, misuse, or unauthorised access, as required by EU rules.

How transfers of your crypto-assets work

• Client authorisation: Your crypto-assets are only transferred based on your instructions or in line with clearly defined contractual arrangements.
• Verification before transfer: We verify wallet ownership and transfer details before sending any crypto-assets, to reduce the risk of mistakes or fraud.
• Limited holding periods: STOKR only holds your crypto-assets for as long as necessary (for example, during investment or distribution periods).
• Clear records: All transfers are properly recorded so we can always identify which assets belong to which client.

What transfer services does STOKR provide?

STOKR provides crypto-asset transfer services exclusively in connection with tokenised investment offerings. We handle transfers related to:

• Investing: Receiving crypto-assets when you subscribe to an offering
• Settlement: Transferring your investment to the issuer upon successful offering close
• Cancellation: Returning your crypto-assets if you cancel within the permitted period
• Payouts: Distributing redemption proceeds or dividends from issuers to investors

Can I withdraw my crypto-assets at any time?

No. STOKR does not operate like an exchange. We do not process ad-hoc withdrawal requests. Your crypto-assets can only be transferred in connection with specific events:

• When an offering successfully closes (settlement to issuer)
• When you exercise a valid cancellation right
• When an issuer makes a redemption or distribution payment

Why can't I just withdraw whenever I want?

STOKR specialises in tokenised investment offerings, not trading or exchange services. When you invest, your crypto-assets are committed to the offering and held in custody until the offering outcome is determined. This structure protects both investors and issuers by ensuring committed funds remain available for settlement.

Can I withdraw my consent to a transfer?

For offering settlements, by subscribing to an offering you authorise us to transfer your invested crypto-assets to the issuer upon successful offering close. You cannot withdraw this authorisation once the offering has closed. However, if you are within the applicable cancellation period (as set out in the Offering Documents), you may cancel your investment and your crypto-assets will be returned to you.

Under what conditions might a transfer be refused?

We may refuse or delay a transfer if:

• you have not complied with our Terms;
• the transfer would be unlawful;
• required compliance information is incomplete;
• the destination address or recipient is flagged by sanctions screening;
• anti-money laundering concerns require investigation;
• your account is subject to restrictions;
• a regulatory authority directs suspension.

For specific offerings, additional conditions may apply as set out in the Offering Documents (for example, if an investor is not whitelisted for a particular offering, they may not be eligible for payouts or redemptions from that offering).

Is there a cut-off time for transfer-related requests?

For operational purposes, requests received after 17:00 CET on a business day, or on weekends and public holidays, are treated as received on the next business day. This applies to subscription confirmations, cancellation requests, and distribution instructions.

Which crypto-assets and networks are supported?

STOKR supports transfers on the Ethereum and Bitcoin blockchains. The specific crypto-assets accepted for each offering are specified in the offering documentation.

How long until my deposit is confirmed?

Confirmation times depend on the blockchain network:

You understand that crypto-assets transactions cannot be reversed. Once a transfer achieves the required number of blockchain confirmations (12 blocks for Ethereum, approximately 3 minutes; 3 blocks for Bitcoin, approximately 30 minutes), it is considered final and irreversible. If you provide an incorrect wallet address, your crypto-assets cannot be recovered and we will not be liable for such loss.

How long do transfers take?

• Investment deposits: Credited once confirmed on the blockchain (approximately 3 minutes for Ethereum, 30 minutes for Bitcoin)
• Offering settlement: Within 2 business days of offering close
• Cancellation returns: Within 2 business days of valid cancellation request
• Redemptions/distributions: Within 2 business days of receipt from the issuer.

Processing may take longer if additional compliance checks are required, if we need to verify your wallet address, or during periods of high blockchain network congestion. We will notify you of any significant delays.

What fees apply to transfers?

• Investment deposits: No STOKR fee (network fees paid by you when sending)
• Cancellation returns: No STOKR fee; network fees may apply
• Distributions: No STOKR fee; network fees may apply

Network fees (on Ethereum called "gas fees") are blockchain transaction costs and vary depending on network conditions. Any applicable fees are disclosed before or at the time of transfer.

Where can I see the fees for my offering?

Fee details are provided in the Offering Documents for each investment opportunity.

Transparency and client information

• Clear information: We explain our custody, security, and transfer arrangements in clear, non-technical language so you understand how your assets are protected.
• Regular reporting: You receive periodic statements showing your crypto-asset positions and relevant transactions.
• Access to policies: Key information about our safeguarding, custody, and transfer arrangements is made available to clients so you know what protections are in place. A summary of the custody policy is available at your request in electronic format.

What we never do with your crypto-assets

• Use them for STOKR's own benefit
• Lend, borrow, or pledge them
• Transfer them without proper authorisation or a clear legal basis

In summary:

STOKR has clear policies, procedures, and security arrangements to protect your crypto-assets, ensure they remain yours, and inform you transparently about how they are safeguarded and transferred. We act only as a custodian, in line with EU regulatory requirements, with your protection as our priority.

What happens if my crypto-assets are lost while in STOKR's custody?

STOKR is liable for any loss of your crypto-assets or means of access to them if the loss results from an incident attributable to us.

If we are responsible, we will compensate you up to the market value of the lost crypto-assets at the time the loss occurred.

When is STOKR not liable?

We are not liable for losses caused by events outside our control, such as:

• Problems with the underlying blockchain or distributed ledger technology (e.g., protocol failures or hard forks);
• Your own actions that breach our agreement or instructions;
• Failure to keep your authentication credentials secure;
• Force majeure events (natural disasters, acts of war, government actions);
• Actions of third parties not engaged by STOKR.

What happens if there is an incident?

If an incident occurs that may affect your crypto-assets, we will:

• Notify you promptly;
• Investigate the cause and determine whether STOKR is responsible;
• Provide you with a written determination explaining our findings;
• Compensate you within a reasonable timeframe if liability is established.

You have the right to access information about the investigation and to challenge our determination through our complaints procedure.

How will STOKR notify me of fraud or security threats?

If we detect suspected fraud or security threats affecting your account, we will notify you promptly via secure notification through the STOKR platform and email to your registered email address. Official emails from STOKR will only come from addresses ending in @stokr.io. If you receive any suspicious communications claiming to be from STOKR, do not click any links and report it to [email protected] immediately.

How does STOKR ensure it can meet its liability obligations?

STOKR maintains own funds in accordance with MiCAR prudential requirements, at a level sufficient to cover potential liabilities to clients. The adequacy of these funds is monitored on an ongoing basis.

Who regulates STOKR?

STOKR S.A. is authorised and supervised by the Commission de Surveillance du Secteur Financier (CSSF) in Luxembourg.

What regulations apply to transfers?

STOKR's transfer services comply with:

• MiCAR (EU Markets in Crypto-Assets Regulation)
• Travel Rule (EU Transfer of Funds Regulation for crypto-assets)
• AML/CFT requirements (Anti-Money Laundering)

Why does STOKR need information about me for transfers?

EU regulations require crypto-asset service providers to collect and verify information about the sender and recipient of transfers. This helps prevent money laundering and financial crime. We may request additional information before processing certain transfers.