WHITE SWAN WHITE PAPER

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.

Rights and Obligations of Purchasers:

Purchasers of $SWAN tokens do not acquire any legal or economic rights beyond the ability to transfer, hold, or exchange the tokens on the decentralized market and on any possibly supported trading platforms in the future. There are no voting, redemption, or profit-sharing mechanisms directly linked to holding $SWAN.

Exercise Procedure and Conditions:

Since the token does not entail specific rights, there are no associated procedures for exercising rights. Token holders may engage in peer-to-peer transfers or trade via crypto-asset service providers that may support $SWAN.

Modification of Rights and Obligations:

There are no mechanisms to unilaterally modify any aspect of the token's functionality or characteristics post-issuance. Any updates to the project or token metadata (e.g. display name, symbol) will be publicly disclosed but will not alter the non-rights-bearing nature of the token. No upgrades or forks are currently planned.

No subscription fees were charged to participants. The offer was non-custodial and open to the public, requiring only a compatible Solana wallet. Each purchaser's final allocation was calculated automatically based on their contribution relative to others, and tokens were claimable from 16 January 2025.

Participation was capped to 250 SOL per participant, and slight technical requirements (wallet and access to SOL) applied. All transactions were settled in SOL, and funds were safeguarded by an authorized custodian with refund functionality available until the close of the subscription period.

Admission of $SWAN tokens to trading on regulated crypto-asset service providers is pursued to enhance secondary market liquidity, improve accessibility for retail and institutional participants, and support broader market transparency. As the initial public offer has concluded and the token supply is fixed, admission to trading now enables fair and open price discovery under the regulated framework established by MiCA.

Purpose/Strategy/Vision

The company aims to pioneer innovation in blockchain technology by providing cutting-edge applications and services related to crypto-assets, smart contracts, and distributed ledger technologies. This includes, inter alia, integrating blockchain solutions into everyday activities, enabling transparency, efficiency, and security in financial and non-financial ecosystems.

Products/Services

The company's primary focus lies in the development and issuance of MiCA-compliant crypto-assets, including the $SWAN token, which is designed for compliant, transparent, and secure holding and transaction. Additionally, the company envisions developing blockchain-based software solutions and smart contract frameworks that cater to both business-to-business and business-to-consumer markets. Ancillary services may include blockchain consulting and solutions that enhance compliance and operational efficiency for entities using blockchain technologies.

Markets Served

The company's target markets include the European Economic Area (EEA), with a special focus on Finland as the hub of operations. Activities cater to retail and institutional investors interested in crypto-assets, as well as businesses seeking innovative blockchain solutions that align with the EU's regulatory practices and industry-standard technological implementations.

The project does not offer a financial product or promise returns; instead, it seeks to cultivate a cultural asset that derives value from community engagement, symbolic resonance, and digital market participation. There are no governance mechanisms, revenue-sharing rights, or underlying services tied to the token. The token supply is fixed, and all tokens were distributed through a single, concluded public offer via smart contract.

The project's long-term ambition is to foster an open, collaborative brand that can be organically developed and adopted across digital platforms, supported by clear compliance with EU crypto regulation under MiCA.

Past Milestones

• Q4 2024: Project conceptualization and development of the $SWAN token on the Solana blockchain.

• Q4 2024: Completion of legal and regulatory preparations, including the drafting of the white paper in compliance with MiCA requirements.

• January 10-13, 2025: Successful public offering of $SWAN tokens, raising 1694.35 SOL through a fair launch model.

• January 16, 2025: Token distribution, enabling participants to claim their $SWAN tokens.

Milestones after the public offer

• H1 2025: Initiation of steps to list $SWAN on regulated crypto-asset service providers (CASPs) within the EU.

• H1 2025: Implementation of staking mechanisms for $SWAN holders and further development of the Swan ecosystem.

• 2026 and beyond: Continued growth of the Swan ecosystem.

So 1,000,000,000 $SWAN — the entire flock of these White Swans — will seek listing.

In addition, holding a small amount of the Solana blockchain's native token (SOL) is required to complete transactions, such as sending, holding, or receiving $SWAN. Each transaction comes with a small fee, which is referred to as a "transaction fee".

If $SWAN is successfully admitted to trading and becomes available on crypto-asset exchanges or trading platforms, each platform may have its own technical or operational requirements. Users should consult the relevant platform's website for further information before making a purchase.

• Patrick Aarikka, who contributed to the legal and regulatory design of the $SWAN project and supported the drafting of MiCA-aligned documentation, currently serves as the Chief Compliance Officer of Kvarn Capital Oy, an applicant crypto-asset service provider (CASP), that may become authorized in the European Union. Kvarn Capital Oy may at a future stage facilitate trading of $SWAN tokens through its regulated platform. While Patrick Aarikka has abstained from any decision-making processes within Kvarn Capital Oy related to listing or commercial engagement with $SWAN, this dual involvement constitutes a potential conflict of interest.

• Another potential conflict of interest arises from the fact that certain core contributors to the $SWAN project hold $SWAN tokens that were allocated to them as part of the initial token distribution, subject to a defined vesting schedule. These individuals may be in a position to influence strategic decisions or public communications that could affect the market perception or secondary trading of $SWAN.

Conflict Risk and Mitigation:

Because team members benefit directly from the appreciation of $SWAN, there is an inherent incentive to influence market sentiment or trading conditions. While this does not violate any regulatory obligations, it introduces a perceived conflict of interest, particularly around marketing communications or ecosystem milestones coinciding with token unlocks.

To mitigate conflict of interest:

• Vesting wallets are publicly disclosed and monitored, ensuring transparency of any movements;

• No automatic selling mechanisms (e.g. token streaming sales) are in place; and

• Team members are committed to avoiding coordinated selling during periods of market sensitivity or ecosystem announcements.

$SWAN is fully transferable, divisible to 9 decimal places, and compatible with all Solana-compatible wallets and trading platforms. Its value is determined purely by market demand and cultural adoption. It does not grant holders access to services, income streams, or ownership rights in any entity or protocol.

The smart contract does not include any locking mechanisms, transfer approvals, or whitelisting conditions. However, purchasers and holders are responsible for ensuring compliance with any legal or regulatory restrictions applicable in their own jurisdictions or CASPs may end up freezing purchased $SWAN tokens.

Key technical features:

• Blockchain: Solana - a high-throughput, proof-of-stake blockchain optimized for speed and low transaction costs.

• Smart contract immutability: The $SWAN token contract is non-upgradable and does not include administrative control functions.

• Interoperability: $SWAN is compatible with Solana-based infrastructure, including wallets (e.g. Phantom, Solflare), DEXs (e.g. Jupiter, Raydium), and custodial platforms.

Solana's consensus model is optimized for high throughput and low latency. While Proof of History (PoH) is used to establish a verifiable time sequence for transactions, the actual consensus on block validity and finality is achieved through Proof-of-Stake with Tower BFT.

The $SWAN token itself does not include any native incentive or reward mechanism.

Applicable Fees:

• Transaction fees on the Solana network are minimal (typically a fraction of a cent) and are paid in SOL, not in $SWAN.

• No protocol-level fees are imposed by the $SWAN token contract.

• Trading or custodial platforms may impose additional service fees, which are external to the $SWAN protocol.

• Market volatility: The value of $SWAN may fluctuate significantly, including rapid declines. There is no guarantee of liquidity or stable pricing on secondary markets.

• Lack of intrinsic utility or rights: $SWAN does not grant access to services, governance, profits, or redemption. Its valuation is symbolic and not anchored in financial fundamentals.

• Regulatory risk: Future regulatory developments at EU or Member State level could affect the trading, availability, or classification of meme-style tokens.

• Technology risk: As $SWAN is built on the Solana blockchain, any failure, congestion, or compromise of the underlying network could impact the functionality or availability of the token.

• Cybersecurity risk: Loss of private keys, phishing attacks, or compromised wallets can result in irreversible loss of tokens.

• Concentration risk: While the token was fairly launched, any disproportionate accumulation by large holders may introduce volatility or price manipulation risks.

• Speculative nature: $SWAN is a meme-based token with no underlying utility, asset backing, or claim to services or revenues. Its value is driven purely by market sentiment, which may be irrational or short-lived.

• Extreme price volatility: The price of $SWAN may experience significant fluctuations, including rapid and sustained declines, with no inherent mechanism to stabilize or support its market value.

• Lack of redemption or utility: $SWAN does not provide rights to redeem for goods, services, or fiat currency, nor does it entitle holders to participate in governance or receive returns.

• No intrinsic value: As a symbolic and cultural token, $SWAN has no intrinsic or book value. Its worth is entirely subjective and may trend to zero without notice.

• Liquidity risk: There is no guarantee of continuous market liquidity. Trading may be limited or unavailable on certain platforms, especially during periods of market stress.

• Technology and smart contract risk: $SWAN is dependent on the Solana blockchain and its associated infrastructure. Vulnerabilities in the underlying code, wallet software, or smart contract could result in loss or malfunction.

• Holder responsibilities: Token custody is the responsibility of the holder. Loss of access credentials or interaction with malicious applications can result in irreversible loss of tokens.

• Execution risk: Planned developments — such as ecosystem tools, cultural initiatives, or community-driven applications — may be delayed, underdelivered, or not executed at all due to technical, strategic, or resource constraints.

• Regulatory uncertainty: Although the token is designed to comply with MiCA, future EU-level or Member State -specific regulatory actions could impact the feasibility or permissibility of certain integrations (e.g. meme-based DeFi products or entertainment features).

• Operational risk: The project is lean by design and does not rely on centralized infrastructure or staffing. This limits exposure to overhead but increases reliance on community coordination, which may impact delivery timelines and consistency.

• Market perception risk: The success of community or symbolic projects like $SWAN is heavily influenced by online culture and social attention. Shifts in sentiment or market trends could diminish engagement and reduce the project's perceived relevance.

• Resource allocation risk: Project funding was limited to the initial public offer. While treasury reserves are managed conservatively, unexpected legal, technical, or operational expenses may affect the pace or scope of implementation.

• Network reliability risk: The Solana blockchain has historically experienced congestion and temporary outages. Such disruptions can delay or prevent the execution of token transfers and trading activities.

• Consensus mechanism risk: Solana uses a Proof-of-Stake (PoS) consensus model with Tower BFT, which, while efficient, could be vulnerable to validator collusion or coordination failures under extreme conditions.

• Smart contract risk: Although the $SWAN smart contract is simple and non-upgradable, any undetected bugs, integration flaws, or unexpected interactions with other on-chain systems could expose holders to functional or financial risks.

• Centralization risk: Solana is often criticized for a relatively concentrated validator set, which may present theoretical vulnerabilities in governance or attack resistance compared to more decentralized blockchains.

• Custodian and wallet risk: Holders interact with $SWAN through third-party wallets and interfaces, which may contain vulnerabilities or be targeted by phishing and malware campaigns. Loss of private keys results in irreversible token loss.

• Upstream dependency risk: Any changes, forks, or disruptions in the Solana protocol itself (e.g. validator policies or network economics) could indirectly affect the $SWAN token's usability or availability.

These risks are inherent to the use of public blockchain infrastructure and should be carefully considered by all participants.

• Minimal smart contract complexity: The $SWAN token smart contract is intentionally simple, non-upgradable, and free of external dependencies. This reduces the surface area for bugs, exploits, or unintended interactions.

• Use of a mature token standard: $SWAN uses the well-established SPL standard on the Solana blockchain, benefiting from widespread community scrutiny and tooling support.

• Transparency and on-chain monitoring: All token-related transactions, allocations, and treasury holdings are verifiable on-chain, allowing the community and third parties to independently audit activity in real time.

• No centralized control functions: The token contract includes no admin keys, minting rights, or pausable mechanisms, reducing the risk of centralized interference or abuse.

• Redundancy and compatibility: $SWAN is compatible with a wide range of Solana-based wallets and platforms, reducing dependence on any single interface or provider.

S.2 Relevant legal entity identifier
743700R4JFMYVJT5UH80

S.3 Name of the crypto-asset
White Swan

S.4 Consensus Mechanism
$SWAN is implemented as a non-native token within the Solana blockchain, which utilizes a hybrid consensus mechanism combining Proof-of-History (PoH) and Proof-of-Stake (PoS). These mechanisms are designed to optimize throughput and transaction efficiency while relying on validator networks rather than energy-intensive mining processes typically associated with Proof-of-Work (PoW) blockchains.

S.5 Incentive Mechanisms and Applicable Fees

How validators earn money:
• Staking rewards: Validators stake SOL tokens to participate. The more SOL they stake, the more likely they are to be chosen to validate transactions and earn rewards.
• Transaction fees: Validators earn a portion of the fees users pay when making transactions.


How regular users can participate:
• Delegated staking: If you don't want to run a validator yourself, you can delegate your SOL tokens to a validator and share in their rewards.

Security measures:
• Penalties (slashing): Validators lose some of their staked tokens if they act maliciously or go offline frequently.
• Opportunity cost: When you stake tokens, you can't sell or use them elsewhere, which encourages honest behavior.

Fees on Solana:
1. Transaction fees: Very low and predictable compared to other popular blockchains. Paid in SOL to compensate validators.
2. Storage fees: Small fees for storing data on the blockchain to prevent waste and keep the network efficient.
3. Smart contract fees: Costs for running smart contracts based on how much computing power they use.

S.6 Beginning of the period to which the disclosed information relates
2025-01-01

S.7 End of the period to which the disclosed information relates
2025-12-31

Mandatory key indicator on energy consumption

S.8 Energy consumption
15 kWh

Sources and methodologies

S.9 Energy consumption sources and methodologies

How is $SWAN's energy use estimated:
Since $SWAN runs on the Solana blockchain, first it must be figured out how much energy Solana uses, then that information is used to calculate $SWAN's share of the total energy consumption.

The estimation method:
1. Focus on network nodes: We look at the computers (called "nodes") that keep the Solana network running, as these are what actually consume the energy.
2. Research network requirements: We study what kind of computer hardware is needed to run Solana's software effectively.
3. Use public data: We gather information from publicly available websites and sources to understand the network's energy usage patterns.
4. Calculate $SWAN's share: Once we know Solana's total energy use, we determine what portion can be attributed to $SWAN transactions and activities.

Why this approach works:
This method gives us a realistic estimate of energy consumption because it's based on the actual hardware requirements and real-world data from the network.