TR

LISTING and DELISTING PROCEDURE

1. Purpose and Scope

This procedure has been prepared in order to regulate the principles regarding the identification, listing, supervision and, if necessary, delisting of crypto assets to be traded on the platform of Whitebit Kripto Varlık Alım Satım Platformu A.Ş. ("Company"). All steps regarding the evaluation of the legal, technical and financial suitability of crypto assets, receiving listing applications, managing the evaluation processes, making approval and rejection decisions, as well as the supervision and, if necessary, removal of listed assets are regulated within the scope of this procedure.

2. Definitions

  • Crypto Asset: Intangible assets that are created electronically using distributed ledger technology or a similar technology, express value or rights, and can be traded through crypto asset service providers.
  • Listing: The opening of a cryptoasset for trading on a company's platform.
  • Applicant: A natural or legal person requesting the listing of their crypto asset.
  • Listing Committee: It is a unit established within the Company and authorized to evaluate technical, legal and compliance issues.

3. General Principles

The Company adopts the principles of protecting investors, ensuring market integrity, preventing fraud and establishing information transparency in listing processes. In this context, each crypto asset to be listed is comprehensively evaluated in accordance with both internal policy criteria and relevant legislation. In the application and evaluation processes, objectivity, non-discriminatory approach, technical audit, legal analysis and MASAK and CMB compliance are observed.

4. Application Process

4.1 Application Documents

The listing request is made on the standard application form specified by the company. Following the receipt of the applications, the Listing Committee conducts a multi-faceted evaluation of each application. The applicant must submit the following documents in full and complete form.

  • Technical whitepaper of the project
  • Documents explaining the project's purpose, use case, token economy
  • UBO (declaration of final entitlement)
  • Identity and authorization documents of legal representatives
  • Third party safety audit documents, if any
  • Smart contract audit reports
  • Customer information forms in compliance with MASAK and CMB obligations
  • Statements of legal compliance (according to national regulations)

Smart contracts of the projects applying for listing are expected to be open source and audited by an independent third party. Audit reports should be attached to the application file.

4.2 Review Process

The application is evaluated by the company's Listing Committee on three main axes.

  • Technical Compliance: Code quality, vulnerabilities, blockchain structure, testnet/mainnet stability
  • Legal Compliance: Whether it conflicts with local and international regulations
  • Financial Risk: Fraud, manipulation risk, market volume and investor protection

The Committee decides by focusing on technical competence, smart contract security, market data, regulatory compliance, liquidity potential, fraud risk and whether there are any misleading elements to the investor. The review period is maximum 30 business days and the applicant will receive written feedback. Artificial intelligence or algorithmic analysis tools used to support the evaluation process are subject to independent technical audit at least once a year. These tools have only a recommendation function in the decision-making process; the final decision is made by the Listing Committee.

4.3. Committee Composition and Impartiality

The members of the Listing Committee shall act with impartiality during the evaluation of applications. Each member shall submit a written declaration that he/she has no direct or indirect interest in the project being evaluated. Otherwise, the relevant member is prohibited from participating in the evaluation process. The Listing Committee is composed of at least three members and the members are appointed from among competent persons in the fields of information systems, legal and financial expertise. Committee decisions are taken by majority vote; in case of a tie, the chairman's vote is decisive.

5. Listing Approval and Announcement

5.1.

If the application is approved, the decision of the Listing Committee is submitted for the approval of the board of directors. Public disclosure is made before the approved crypto asset is opened for trading on the platform. This information is provided through the company's official website and announcement channels. Investors are provided with clear and understandable information about the asset to be traded.

5.2.

Decisions regarding crypto assets deemed appropriate by the Listing Committee will be immediately notified to the Board via the Capital Markets Licensing Registry and Training Organization ("SPL") Notification Platform following the approval of the board of directors.

5.3.

Approved crypto assets are opened for trading on the platform by completing technical and operational preparations within 10 business days at the latest. In case this period is exceeded, the reason is shared with investors.

6. Post-Listing Obligations

Following the listing, the company regularly monitors technical developments, community announcements, potential changes such as hard forks, swaps, delists, etc. The project team is in constant communication with the company and is obliged to share developments with the company. When risky behavior or misleading statements are detected, suspicious transaction notifications are made within the framework of MASAK obligations.

7. Suspension and Delisting Criteria

7.1. Grounds for Suspension or Delisting

The Company may decide to suspend or completely remove the listing of a listed cryptoasset if it considers that it poses a threat to market order or investor safety. Grounds for this decision may include suspicion of fraud, evidence of illegal activity, market manipulation, technical vulnerabilities or warnings from regulatory authorities. Suspension or delisting decisions are also publicly announced in writing in a clear and timely manner. When it is considered that suspension or delisting may have effective consequences in terms of investor rights, the necessary information is made to the Capital Markets Board. The Company may temporarily suspend or completely delist a crypto asset in the following cases.

  • Suspicion of fraud or crime
  • Administrative requests by MASAK or CMB
  • Insufficient liquidity, suspicion of manipulation
  • Technical failures, problems in fork operations
  • Failure of the project team to provide information or misleading behavior by users

7.2. Delisting Transition Period

In case of delisting decisions, a transition period of at least 30 days is granted for users to withdraw the relevant crypto assets from the platform. Delist transactions are completed at the end of this period and investor victimization is prevented.

7.3. Post-Delisting Impact Assessment

After listing and/or delisting, an impact assessment report is prepared based on transaction volume, user behavior and complaint analysis. This report is submitted to internal audit by the Compliance Department. The summary results of the impact assessment reports are prepared in a manner that can be shared with the public via investor information platforms. In cases involving critical findings, the relevant findings are reported separately to the CMB.

8. Recording, Storage and Audit

Applications, evaluation records, decision texts, technical and legal review reports regarding the listing processes are securely stored in digital environment. These records are kept for at least ten years in order to be presented during CMB and FCIB audits. In terms of information security, it is essential that the records are time-stamped and stored in an unalterable format. All digital records will be kept in unalterable log format with time stamp and will be kept for at least ten years. These logs will be made available for presentation during internal audit, independent audit and CMB audits.

9. System Security and Compliance

The platform where listing transactions are carried out is continuously monitored in terms of information systems security. All infrastructure and application components are structured to have technical competencies in accordance with the Communiqué on Principles and Procedures for Information Systems Management (VII-128.10) and the Communiqué on Independent Audit of Information Systems (III-62.2.b). All software components related to listing processes are regularly tested, penetration tested and updated when necessary. Higher security thresholds are applied for assets with high transaction volume. All system accesses are recorded and unauthorized access attempts are reported instantly.

10. Compliance and Internal Audit Activities

The Listing Procedure is considered a fundamental part of the company's compliance policies. The unit directly responsible for the implementation of the Procedure is the Compliance and Internal Control Department. The Internal Audit Department periodically checks whether the relevant processes are carried out in compliance with all applicable legal regulations, particularly the CMB and MASAK regulations. In this context, internal audit activities are carried out at least once a year. Audit results are reported to the Compliance Committee and the Board of Directors.

Necessary corrective and preventive actions are planned in line with the identified nonconformities or areas open to improvement. Audit reports are also taken as basis for determining the need for revision. Documents related to all listing activities are kept ready to be submitted upon request for use in external audits conducted by the CMB.

11. Investor Protection Measures in the Listing Process

11.1.

The Company adopts informing and protecting investors as a fundamental principle. Accordingly, for each listed crypto asset, a publicly accessible asset information form is published on the platform. This form includes technical specifications of the asset, project purpose, blockchain infrastructure used, total supply and distribution information, previous price history and volatility trend of the asset.

11.2.

In addition, investors are informed about the price volatility and systemic risks inherent in the crypto asset market through risk warning texts. When deemed necessary, supporting content is prepared through investor training, online seminars and documents. These practices are in direct compliance with the CMB's investor protection strategies.

11.3.

The asset information sheet is updated and shared with investors on a quarterly basis or when necessary according to technical updates, security reports and changes in the token economy by the relevant project. In case of critical updates, investors are also informed via mobile application notification and e-mail.

12. Review and Continuous Improvement

The Listing Procedure is reviewed at least once a year in line with the changing needs of the company, legal regulations and sector dynamics. These reviews are conducted in accordance with the findings of the Internal Audit Unit, assessments of the Compliance Department, market practices and instructions from regulators.

The changes required as a result of the review are drafted by the Compliance and Internal Control Department and submitted to the board of directors. Following the approval of the board of directors, the new procedure version enters into force. Outdated procedures are entered into the internal document archive as "dated and invalid".

13. Enforcement

This procedure was approved by the Company's Board of Directors on 25/03/2025 and entered into force. It has been notified to all departments electronically and published on the company's internal communication platforms. It is mandatory for the departments directly affected by the implementation to fully read and implement the content of the procedure. As of the effective date, all procedures previously issued within the company in this regard shall be deemed invalid.

14. Responsibility and Implementation

The unit primarily responsible for the preparation, updating and implementation of this procedure is the Compliance Department. Before the said procedure is approved by the Board of Directors, the opinions of the Risk and Internal Control Department are taken. All relevant units are obliged to comply with the provisions of the procedure and to notify the Compliance Department when necessary. Employees involved in the listing process also comply with internal control and information security policies.