Horizen(ZEN) Whitepaper

CRYPTO-ASSET WHITE PAPER - [ZEN]

Version Number: 1.0

Document Type: White Paper

Document Author Offeror: OKX Europe Limited

Document Status: DRAFT

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 ZEN 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. ZEN is a utility and governance token within the Horizen ecosystem, issued as an ERC-20 standard token on the Base network. The token functions as a medium of exchange and grants holders the right to participate in the Horizen DAO governance process (ZenIPs). The total supply of ZEN is capped at 21,000,000 tokens globally. As an ERC-20 token on Base, it utilises the security and settlement finality of the Ethereum blockchain while operating on Layer 2 infrastructure. There are no guaranteed rights to profits or dividends attached to the token.

F. The ZEN token provides access to the Horizen ecosystem's services. Specifically, it allows users to participate in governance voting and interacts with decentralised applications within the ecosystem. The quantity of services accessible is proportional to the amount of ZEN held. Access to these services is available as long as the Horizen network and the Base Layer 2 infrastructure remain operational. The ZEN 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 ZEN 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 ZEN 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: ZEN 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 ZEN 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 ZEN 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 ZEN 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 ZEN 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 ZEN 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 ZEN 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 ZEN tokens price and future use cases.

• Holding Concentration Risk: A small number of holders controlling a large portion of the circulating supply may create risks of security concerns, price manipulation, sudden sell-offs, or influence of key governance decisions.

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 blockchain, 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 standard), 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.

• Sequencing Risk: The token may rely on a centralised sequencer(s) to process transactions to the native L1 network. If the sequencer(s) experience downtime, censorship, or misuse, transaction ordering and availability may be adversely affected.

6. Mitigation Measures

• Blockchain Performance Risk: The Ethereum blockchain has adopted a Proof-of-Stake consensus mechanism to improve network scalability and reduce latency. Ongoing upgrades to the network are designed to enhance throughput, and gas fees help prioritise transactions under load.

• Consensus Failure Risk: Ethereum Proof-of-Stake consensus mechanism includes validator incentives, slashing penalties for malicious actors, and finality checkpoints to ensure integrity. The validator set is large and globally distributed which reinforces decentralization of the network.

• Smart Contract Vulnerabilities: Smart contracts on Ethereum are immutable by design, unless explicitly designed to be upgradeable. The ecosystem encourages open source code, independent audits, and community input. Standardised libraries such as OpenZeppelin reduce coding errors by reusing tested components.

• Upgradeability Risk: Ethereum does not enforce upgrade functionalities within smart contracts, but supports their technical implementation. Risks related to upgradeable contracts can be mitigated through standard practices such as time delay triggers or multi-sig wallets.

• Third-party Infrastructure Dependency: The Ethereum blockchain & ecosystem supports decentralized indexing and querying via different protocols to reduce reliance on centralized third party data services.

• Interoperability Risk: Mitigations for cross-chain bridging include usage of audited bridges and token locking mechanisms.

• Protocol-level Risk: Ethereum maintains a public roadmap and follows a structured governance process. Core updates to the network undergo extensive testing and community reviews.

• Emerging Technology Risk: Ethereum developers monitor potential emerging technology threats, and are actively researching and developing quantum-resistant solutions. The network's modular design may allow for future cryptographic upgrades if required.

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: Zen Blockchain Foundation

• B.3 Legal Entity Identifier (LEI): 2549006XWZLJZJN7GE21

• B.4 Legal Form, if applicable: Foundation

• B.5 Registered Office, if applicable: c/o Incorporating Services, Ltd., 3500 S. Dupont Hwy, Dover, Delaware (US-DE), 19901, UNITED STATES

• B.6 Head Office, if applicable: 2000 Duke Street, Suite 300, Alexandria, Virginia (US-VA), 22314, UNITED STATES

• B.7 Date of Registration [YYYY-MM-DD]: 2017-06-20

• B.8 Legal Entity Number: 6451546

• B.9 Members of the Management Body:

  • Line ID 1: Identity - No information could be identified. Business Address - No information could be identified. Function - No information could be identified.

• B.10 Business Activity: The Zen Blockchain Foundation is a non-profit organisation dedicated to the development, promotion, and maintenance of the Horizen blockchain ecosystem. Its activities include overseeing protocol upgrades, managing the treasury, and fostering the growth of the developer and user community.

• B.11 Parent Company: No information could be identified in regards to this field at the time of drafting this whitepaper.

• B.12 Parent Company Business Activity: No information could be identified in regards to this field at the time of drafting this whitepaper.

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: Identity - Erald Henri J. Ghoos. Business Address - See C.4. Function - Director.

  • Line ID 2: Identity - Fang Hong. Business Address - See C.4. Function - Director.

  • Line ID 3: Identity - Joseph Portelli. Business Address - See C.4. Function - Director.

  • Line ID 4: Identity - Wei Man Cheung. Business Address - See C.4. Function - 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 ZEN 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: Horizen

• D.2 Crypto-Assets Name: See F.14

• D.3 Abbreviation: See F.14

• D.4 Crypto-Asset Project Description: Horizen is a distributed blockchain ecosystem facilitating decentralised applications and sidechains. While the broader ecosystem includes a Layer 0 mainchain and various sidechains, the specific crypto-asset described in this whitepaper is the ZEN token issued on the Base network. Base is an Ethereum Layer 2 solution built on the Optimism Stack. The ZEN token on Base allows users to interact with the ecosystem's utility and governance functions within the Ethereum-compatible DeFi landscape. The project historically focused on privacy but has deprecated shielded pools (ZenIP 42204) to align with global regulatory standards.

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

  • Name: Rob Viglione. Role: Co-founder & CEO at Horizen Labs. Business Address: San Juan, Puerto Rico.

  • Name: Rosario Pabst. Role: COO at Horizen Labs. Business Address: United States.

  • Name: Zain Cheng. Role: CTO at Horizen Labs. Business Address: New York, United States.

  • Name: Horizen Labs. Role: Core Contributor. Business Address: United States.

  • Name: Zen Blockchain Foundation. Role: Core Contributor/Issuer. Business Address: 2000 Duke Street, Suite 300, Alexandria, Virginia (US-VA), 22314, UNITED STATES.

• D.6 Utility Token Classification: TRUE

• D.7 Key Features of Goods/Services for Utility Token Projects, if applicable: The ZEN token serves as a utility unit within the Horizen ecosystem. It grants access to the following services:

  1. Governance: Used to participate in the Horizen DAO and vote on ZenIPs (Horizen Improvement Proposals).

  2. DeFi Integration: As an ERC-20 token on Base, it can be utilised within decentralised finance applications and liquidity pools on the Base network.

  3. Ecosystem Interaction: Used as a medium of value transfer within the Horizen community.

• D.8 Plans for the Token:

  • Past Milestones:

    • 2017: Launch of the Horizen ecosystem.

    • 2021: Launch of Zendoo cross-chain protocol.

    • 2023: Launch of Horizen EON.

    • 2024: Implementation of ZenIP 42204 (removal of shielded pools).

    • 2025: Migration of ZEN availability on Ethereum Layer 2 networks (Base) from its legacy Horizen mainnet.

  • Future Milestones:

    • Q4 2025 (Horizen L3 Appchain): Launch of the dedicated Horizen Layer 3 appchain on Base. This programmable privacy layer will enable customizable privacy configurations for decentralised applications while leveraging Ethereum's security.

    • Q1 2026 (Confidential Compute Environment): Release of the Confidential Compute Environment using Trusted Execution Environments (TEEs). This will allow developers to deploy privacy-preserving applications that execute secure, private computations on-chain.

• D.9 Resource Allocation, if applicable: The Horizen project (formerly ZenCash) launched via a fair launch hard fork of the Zclassic blockchain at block 110,000. There was no Initial Coin Offering (ICO), no pre-mine, and no initial allocation reserved for the team, advisors, or private investors.

  • Public Allocation (Zclassic Holders): 100% (Distributed 1:1 to ZCL holders at the snapshot).

  • Team/Foundation/Insiders: 0%.

  • Private Sale/Investors: 0%.

  • Ongoing Resource Allocation (Unmined Supply -- ZenIP 42407): Following the approval of ZenIP 42407 (January 2025) and the migration to the Horizen 2.0 architecture on Base, the distribution of the remaining unmined supply (approximately 5 million ZEN) was restructured to prioritise ecosystem growth and network security:

    • Node Incentives (Collateral Rewards): 40% (Allocated to Super Nodes and EON Forgers).

    • Horizen Foundation: 32.5% (Allocated for protocol development, operations, and compliance).

    • DAO Treasury: 27.5% (Allocated for community grants, marketing, and decentralised governance initiatives).

• D.10 Planned Use of Collected Funds or Crypto-Assets, if applicable: Funds collected via the Treasury allocation are governed by the Horizen DAO. These funds are utilised for:

  • Funding protocol development.

  • Marketing and community growth.

  • Operational expenses of the Foundation.

  • No external fiat funds are raised via the issuance of this token.

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 total maximum supply is capped at 21,000,000 ZEN.

• 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 ZEN 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 ZEN token functions as:

  1. Governance Instrument: Grants voting power in the Horizen DAO.

  2. Medium of Exchange: Used for peer-to-peer value transfer on the Base network.

  3. DeFi Collateral: Can be used within decentralised finance applications on Base. All functionalities from the above specified list apply as of the writing of this whitepaper.

• F.3 Planned Application of Functionalities: All functionalities are currently live and operational.

• F.4 Type of White Paper: OTHR

• F.5 Type of Submission: NEWT

• F.6 Crypto-Asset Characteristics: ZEN is the native utility token of Horizen. The specific asset admitted to trading is the ERC-20 standard token deployed on the Base network. Base is an Ethereum Layer 2 scaling solution.

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

• F.8 Website of the Issuer: https://www.horizen.io/

• F.9 Starting Date of Offer to the Public or Admission to Trading [YYYY-MM-DD]: 2025-11-20

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

• 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: KL03F6N2L

• F.15 Functionally Fungible Group Digital Token Identifier, where available: T9QL1ZT5D

• 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 to the ownership of the ZEN token. The token enables users to participate in on-chain governance through the Horizen DAO and interact with applications on the Base network. Ownership of the token does not grant any claim to profits, dividends, or assets of the issuer.

• G.2 Exercise of Rights and Obligations: As there are no obligations attached to the token, there are no specific procedures required to fulfill them. To exercise the rights associated with the ZEN token, such as governance voting, token holders must hold their ZEN tokens in a compatible non-custodial Ethereum-based wallet connected to the Base network. Voting is typically conducted via a snapshot interface or on-chain governance portal, where the weight of the vote is proportional to the number of tokens held.

• G.3 Conditions for Modifications of Rights and Obligations: There are currently no obligations to modify. The rights attached to the ZEN token, however, are defined by the Horizen protocol and governance parameters and can be modified through the project's decentralised governance mechanism. A ZenIP must be proposed and approved by a majority vote of the community to alter these rights. Consequently, the condition for modifying rights is strictly dependent on the consensus of the DAO and the resulting execution of code or policy updates.

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

• G.5 Issuer Retained Crypto-Assets, if applicable: The Zen Blockchain Foundation receives a portion of the block rewards (allocated to the Treasury) on an ongoing basis. There is no pre-mined static reserve held by the issuer; funds accumulate dynamically.

• G.6 Utility Token Classification: TRUE

• G.7 Key Features of Goods/Services of Utility Tokens: The ZEN token grants access to the Horizen ecosystem. It allows users to:

  • Vote on governance proposals.

  • Transfer value globally via the Base network.

  • Access DeFi services on the Base Layer 2.

• G.8 Utility Tokens Redemption, if applicable: The ZEN token is not redeemable against the issuer for fiat currency or specific physical goods. It is "redeemed" functionally by using it for governance or value transfer.

• 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 ZEN token is implemented using the ERC-20 token standard on the Base network. Base is an Ethereum Layer 2 (L2) blockchain that is fully equivalent to the Ethereum Virtual Machine (EVM). The ERC-20 standard on Base functions identically to Ethereum, defining a common interface for token issuance, transfers, and third-party integrations. This ensures compatibility with all EVM-compliant wallets, decentralised applications, and exchanges. The standard supports core functions such as transfer, approve, mint, and burn, enabling programmable token logic within Base's scalable architecture.

• H.3 Technology Used, if relevant: The ZEN token is deployed on the Base network, which is built on the open-source OP Stack (Optimism Stack). Base operates as an Optimistic Rollup, meaning it executes transactions off-chain to reduce costs and increase throughput while inheriting the security of Ethereum Layer 1. The ZEN token contract is written in Solidity and interacts with the Base network using standard RPC methods. Because Base is EVM-equivalent, the token benefits from the same composability as Ethereum assets, allowing seamless integration with DeFi protocols, NFT platforms, and DAO tooling deployed on the Layer 2 network.

• H.4 Consensus Mechanism, if applicable: Base utilises an Optimistic Rollup consensus model. Transactions are sequenced on the Base Layer 2 network by a centralized sequencer (currently operated by Coinbase) and then batched and posted to the Ethereum Layer 1 mainnet. Finality is derived from the underlying Ethereum Proof-of-Stake (PoS) consensus mechanism once the transaction data is settled on L1. The "optimistic" model assumes transactions are valid by default but allows for a "challenge period" (typically 7 days) where invalid state transitions can be disputed via fraud proofs (though currently in a stage of progressive decentralization). This mechanism ensures that while execution is rapid on L2, the ultimate integrity and immutability of the ZEN token ledger are secured by Ethereum validators.

• H.5 Incentive Mechanisms and Applicable Fees: Transaction fees (gas) for transferring or interacting with the ZEN token on Base are paid in Ether (ETH). The fee structure on Base consists of an L2 execution fee (paid to the sequencer) and an L1 security fee (the cost to publish the transaction batch to Ethereum). Due to the rollup architecture, these fees are significantly lower than on Ethereum Layer 1. Sequencers are incentivised by these fees to order and process transactions efficiently. There is no separate consensus mining reward for ZEN holders in this context, as the token is now an ERC-20 asset secured by the Base/Ethereum infrastructure rather than a native Proof-of-Work coin.

• H.6 Use of Distributed Ledger Technology: FALSE

• H.7 DLT Functionality Description: N/A

• H.8 Audit of the Technology Used: FALSE

• H.9 Audit Outcome, if applicable: N/A

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: Horizen

• I.4 Consensus Mechanism: Base is a Layer-2 (L2) solution on Ethereum that was introduced by Coinbase and developed using Optimism's OP Stack. L2 transactions do not have their own consensus mechanism and are only validated by the execution clients. The so-called sequencer regularly bundles stacks of L2 transactions and publishes them on the L1 network, i.e. Ethereum. Ethereum's consensus mechanism (Proof-of-stake) thus indirectly secures all L2 transactions as soon as they are written to L1.

• I.5 Incentive Mechanisms and Applicable Fees: Base is a Layer-2 (L2) solution on Ethereum that uses optimistic rollups provided by the OP Stack on which it was developed. Transaction on base are bundled by a, so called, sequencer and the result is regularly submitted as an Layer-1 (L1) transactions. This way many L2 transactions get combined into a single L1 transaction. This lowers the average transaction cost per transaction, because many L2 transactions together fund the transaction cost for the single L1 transaction. This creates incentives to use base rather than the L1, i.e. Ethereum, itself. To get crypto-assets in and out of base, a special smart contract on Ethereum is used. Since there is no consensus mechanism on L2 an additional mechanism ensures that only existing funds can be withdrawn from L2. When a user wants to withdraw funds, that user needs to submit a withdrawal request on L1. If this request remains unchallenged for a period of time the funds can be withdrawn. During this time period any other user can submit a fault proof, which will start a dispute resolution process. This process is designed with economic incentives for correct behaviour.

• I.6 Beginning of the period to which the disclosure relates: 2024-11-24

• I.7 End of the period to which the disclosure relates: 2025-11-24

• I.8 Energy consumption: 2.81837 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 Base 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.