LISTING AND DELISTING PROCEDURE – Arbitex

1. PURPOSE AND SCOPE

The purpose of this procedure is to determine the procedures and principles regarding the identification, listing, and delisting of crypto assets to be traded before Arbitex Kripto Varlık Alım Satım Platformu A.Ş. ("Platform") and to ensure their applicability.

This procedure has been prepared pursuant to Articles 35/B and 35/C of the Capital Markets Law No. 6362 and Articles 16, 20, 21, 22, and 23 of the "Communiqué Regarding Operating and Principles and Capital Adequacy of Crypto Asset Service Providers" No. III-35/B.2, and it covers the procedures and principles regarding the determination of crypto assets to be traded before the "Platform" and the termination of their trading, as well as all operations regarding audit and reporting activities for this process.

The Platform carries out the transactions regarding listing and delisting within the scope of the principles specified in this Procedure.

2. DEFINITIONS

Crypto Asset: Refers to intangible assets that can be created and stored electronically using distributed ledger technology or a similar technology, distributed over digital networks, and capable of expressing value or rights,
Smart Contract: Refers to programmable asset protocols executed over distributed ledger technology,
Listing: Refers to the inclusion of a crypto asset found suitable according to certain criteria into the corporate portfolio,
Delisting: Refers to the removal of a previously listed crypto asset from the portfolio due to security, performance, legal, or strategic reasons,
Listing Committee: Refers to the committee that decides on the listing and removal of crypto assets,
Project Owner: Refers to the real or legal person who issues the crypto asset or performs its initial sale.

3. LISTING PRINCIPLES

3.1. Listing Committee

A Listing Committee is established within the Platform by the board of directors. It is mandatory that the listing committee to be established by the Platform's board of directors consists of at least three members, the majority of the number of members consists of persons who have at least seven years of experience in the fields of finance, law, information technologies, information security, and distributed ledger network technologies, and at least one member is a member of the Platform's board of directors.

The Listing Committee is obliged to control the compliance of the crypto assets to be listed with the required principles for listing, by showing the necessary prudence and diligence in making decisions regarding the listing and delisting of crypto assets and in evaluating the crypto assets to be listed.

The listing committee prepares an evaluation report regarding whether crypto assets can be listed within the framework of this Procedure or whether a listed crypto asset needs to be delisted, and crypto assets are listed or delisted according to the results of the evaluation reports. The said reports are stored within the framework of document record regulations regarding crypto asset service providers.

Committee members do not have to be platform personnel (except for the member who is a member of the board of directors). However, committee members who are outside the platform personnel are subject to the principles and rules regarding personnel specified in the “Communiqué on the Establishment and Operating Principles of Crypto Asset Service Providers” No. III-35/B.1.

Appointments made to committee memberships or resignations from membership, along with their justifications, are notified to the Capital Markets Board and to Central Securities Depository and Licensing Registry (Sermaye Piyasası Lisanslama Sicil ve Eğitim Kuruluşu A.Ş.) within two business days.

3.2. Crypto Assets That Can Be Listed

In the event that custody services cannot be offered by custody institutions regarding a crypto asset listed on the Platform, the Platform may store the said asset for a maximum period of six months, provided that capital adequacy provisions are reserved. Except for this matter, it is essential to list crypto assets that can be stored in custody institutions authorized by the Board on the Platform. The crypto assets to be listed must comply with the principles set forth below:

a) Being of a nature compliant with the principles determined in the first, third, and fourth paragraphs of Article 16 of the "Communiqué on the Operating Principles and Capital Adequacy of Crypto Asset Service Providers" No. III-35/B.2; the Platform controls the minimum elements to be written into smart contracts according to the type and legal nature of each crypto asset whose initial sale or distribution it will intermediate, and examines the accuracy of the contracts. In the event that the Capital Markets Board makes a determination under the Price Monitoring System regarding the issuance of capital market instruments as crypto assets and their tracking by dematerialization before the electronic environment offered by the crypto asset service providers where they are created and stored, the Platform is responsible for controlling that the crypto assets in the nature of capital market instruments whose issuance they will intermediate are created in a way that allows the fulfillment of the principles and responsibilities determined in the relevant regulations of the Board. In case the sale or distribution of assets falling under the regulatory field of different institutions and organizations by virtue of their subject matter and nature is made as tokens, the Platform is obliged to confirm that the conditions in the legislation of the relevant institution or organization are fulfilled and to control that the smart contract is created in a way that can adapt to the regulations.

b) No limitation or prohibition has been imposed by the relevant authorities regarding the issuance and being subject to buy-sell transactions of the underlying asset of the crypto asset, and it is not of a nature that can be used to circumvent legal regulations or significantly for this purpose.

c) It has not been created in a way that provides unilateral extraordinary rights to the project owner.

ç) The project owner is not on national or international sanction lists within the scope of prevention of laundering proceeds of crime and financing of terrorism and the provisions of Law No. 7262.

d) It is not of a nature that allows transfer transactions by concealing wallet addresses.

e) It is capable of being stored in cold wallets.

Except for the other crypto assets specified in the third and fourth paragraphs of Article 16 of the "Communiqué on the Operating Principles and Capital Adequacy of Crypto Asset Service Providers" No. III-35/B.2 and determined by the Board, the Platform cannot list crypto assets whose initial sale or distribution is made by themselves or by;

a) A real person and their spouse and children under their guardianship, partnerships in which they participate with unlimited liability or of which they are the chairman of the board of directors, member, general manager, assistant general manager,

b) A legal person, excluding public legal entities, or those listed above, partnerships in which they directly or indirectly participate in 10% or more of their capital or voting rights,

c) Those determined by the Board to be acting together due to employment relationships, contractual relationships, or other reasons.

3.3. Listing and Delisting

This Procedure relates to the determination of crypto assets to be traded before the Platform and the determination of the principles for the termination of their trading. This procedure has been prepared by taking into account at least the principles specified below, in addition to the criteria contained in the article above, and enters into force with the decision of the board of directors.

a) Whether the crypto asset grants a right to its user and the nature of this right.

Right Provided to the User: The right represented by the crypto asset (payment instrument, utility token, security, etc.) and the documentation of this legal nature.
Asset/Right it Represents: If it represents the ownership of another asset, the availability and legal validity of the rights.

b) The transaction volume and circulating supply of the crypto asset.

Circulating Supply: Total supply, circulating supply, and liquidity depth.
Transaction Volume: Volume data for the last 6 months and volume manipulation risk analysis.

c) Whether the supply of the crypto asset is limited.

Whether there is a maximum supply limit and inflation mechanisms.

ç) Transaction speed and costs specific to the relevant asset.

Average transaction time, fee structure, and scalability solutions.

d) The reliability of the crypto asset and its systems, including the distributed ledger network associated with the crypto asset.

The blockchain's hash rate, node distribution, attack history.

e) Traceability of crypto asset transactions.

Transparency of transactions and AML compliance.

f) Historical price movements of the crypto asset.

Historical 1-year volatility graph and abnormal price movements.

g) Whether the crypto asset is prone to price manipulation or fraud for any reason and whether there is any solution or mitigating measure that can be implemented by the Platform.

Price Manipulation Risks: The ownership rate of whales (detection of those controlling 10%+).
History of Fraud: Past sanctions, investigation records of the project owner.

ğ) Whether the value of the crypto asset is determined algorithmically.

Transparency of the support mechanism if it is a stablecoin or algorithmic token.

h) In cases where the project owner can be known, the history of the company performing the initial sale or distribution of the crypto asset or the project owner, including but not limited to whether they have been subject to any investigation or allegation regarding fraud or capital market crimes defined in the Law.

Compliance with Turkey and global regulations (MiCAR, FATF rules, etc.).

ı) If the crypto asset represents the ownership of any other asset or legal right, the availability of these rights.

Existence of a license/permission obtained from another regulator.

i) The status of the crypto asset according to the regulations in Turkey and abroad, especially whether approval has been obtained from any regulatory authority for the issuance of the crypto asset or whether regulations have been violated.

Status of being included in FATF, OFAC, EU, MASAK sanction lists.

j) The degree of weight of a person or group in the ownership or control of the crypto asset.

Previous projects of the founder/team and relationship with regulators.

k) Potential security risks regarding the forking operations of crypto assets.

Hard/soft fork history and potential vulnerabilities.

The Platform is obliged to monitor the financial strength, cybersecurity vulnerabilities, compliance with domestic and foreign legislation of the crypto assets it lists and the company or project owner performing the initial sale or distribution of these crypto assets, or technological or infrastructural problems of a nature that may cause customer victimization, and to make the necessary updates regarding this in this Procedure.

Regarding the notification of listed and delisted crypto assets to the MKK (Central Registry Agency), the principles determined by the MKK are complied with.

3.4. Delisting Process in Extraordinary Situations

The principles regarding the measures to be taken in the event that the need arises to delist a crypto asset due to an extraordinary situation by the Platform are as follows:

Definition of Extraordinary Situation:

An extraordinary situation is the occurrence of one or more of the following situations regarding a listed crypto asset:

Bankruptcy of the developer/service provider of the crypto asset, suspension of its activities, or revocation of its operating license,
Determination by the authorized authorities that the crypto asset is used in illegal activities or the initiation of a judicial/administrative investigation about it,
The network becoming inoperable, occurrence of a security vulnerability, or the occurrence of a systematic technical failure in a way that will cause loss to the investor,
Sudden and unexplained drops in the value of the asset or suspicion of price manipulation,
Prohibitive or restrictive provisions brought by domestic or foreign regulatory institutions.

Measure Process:

In the event that an extraordinary situation arises, a suspension decision is immediately given for the crypto asset. The Risk Assessment Committee evaluates the extraordinary situation within 24 hours and prepares a report.
In line with the report, measures towards delisting the crypto asset, closing trading pairs, informing users, secure withdrawal of investor assets, and mitigating loss are implemented.

Informing Users:

Information regarding the situation is given to users via e-mail, SMS, and in-platform notification.
A minimum period of 30 days is granted for crypto asset withdrawal transactions (excluding situations containing security risks).

MKK Notification:

For each crypto asset delisted or listed, a notification is made within 3 business days at the latest with the form and method determined by the Central Registry Agency (MKK).
The notification includes the name of the asset, type, listing/exit date, reason(s), and measures taken.
Continuous information flow and updates are provided with the MKK throughout the process.

Monitoring and Afterwards:

Following the delisting of the asset, relevant investment transactions and user complaints are monitored for 90 days.
If necessary, the asset can be taken into the agenda of the Listing Committee to be re-evaluated.

4. DELISTING

The delisting process to be implemented by the Platform must comply with the principles set forth below:

In the event that the Platform detects that the crypto assets it has listed no longer meet the criteria determined in this procedure, it may delist the relevant crypto assets within the framework of the evaluation report it will prepare. In this case, the Platform is obliged to notify its customers of the crypto assets it plans to delist at least seven days in advance through registered communication tools. However, these principles are not sought in the following situations:

In the event that the crypto asset is delisted by a crypto asset platform on a global scale, it is possible for the platforms to delist the relevant crypto asset without waiting for seven days, provided that they inform the investors at least one day in advance.
The one-day period may not be waited for in delisting processes carried out due to extraordinary situations arising in global markets.

Crypto assets can be delisted without waiting for the seven-day period, and all buying, selling, and transfer transactions directed towards the relevant crypto assets are stopped in the following cases:

a) The subsequent detection by the Platform that it is not compliant with the principles determined in the first paragraph of Article 21 of the "Communiqué on the Operating Principles and Capital Adequacy of Crypto Asset Service Providers" No. III-35/B.2, or the receipt of a request from public authorities or judicial authorities to the Platform in this regard.

b) Occurrence of reasonable suspicion regarding the reliability of the systems of the relevant crypto asset or the associated distributed ledger network.

In the event that the Platform detects that the crypto assets it has listed no longer meet the criteria determined in this Procedure and decides to delist the relevant crypto assets within the framework of the evaluation report they will prepare, trading may be enabled by the Platform for the crypto assets decided to be delisted to be traded in peer-to-peer digital marketplaces. In any case, it is enabled to return the relevant crypto assets in kind or in cash within the framework of customer requests.

5. ENFORCEMENT

This Procedure enters into force on 30.06.2025. It is reviewed at least once a year. This Procedure and the current list directed towards crypto assets deemed suitable for listing within the framework of this Procedure are published on the Platform's website. Lists published within the last six months are made available for access in a way that historical retro-active screening can be performed.

6. EXECUTION

The Listing Committee executes the provisions of this Procedure.