1. Introduction

This Listing Procedure has been prepared by CLTS Kripto Varlık Alım Satım Platformu Anonim Şirketi ("Aquanow") in accordance with the legislation to which it is subject. Our Platform is committed to establishing and implementing effective systems to ensure full compliance with all applicable regulations.

The purpose of this Procedure is to set out the principles governing the determination of the Crypto Assets to be traded on the Platform and the termination of their trading.

This Procedure has been prepared within the framework of the relevant legislation and Communiqué No. III-35/B.2 on the Working Procedures and Principles and Capital Adequacy of Crypto Asset Service Providers.

2. Definitions

Platform/Company: CLTS Kripto Varlık Alım Satım Platformu Anonim Şirketi ("Aquanow").

Crypto Asset: Intangible assets that may be created electronically using distributed ledger technology or similar technology, distributed over digital networks, and represent value or rights.

Crypto Asset Service Provider: Crypto Asset platforms, custody service providers, and other relevant service providers.

Board: The Capital Markets Board of Türkiye (CMB).

Listing Committee: The committee established by the Platform's Board of Directors that decides on the listing and delisting of Crypto Assets.

Legislation: Capital Markets Law No. 6362, Communiqués No. III-35/B.1 and III-35/B.2, and all relevant secondary legislation.

MKK: The Central Securities Depository of Türkiye (MKK).

Project Owner: The natural or legal person(s) that develop Crypto Asset projects.

Token: Crypto Assets that do not have their own network, are created through smart contracts on existing distributed ledger technology, and represent value, services, or rights within a particular ecosystem.

3. Listing Principles

3.1. Crypto Assets Eligible for Listing

Crypto Assets under consideration for trading on the Platform must satisfy the following fundamental conditions:

• They must be capable of being securely held with a custodian authorised by the Board.
• They must be created in accordance with the relevant legislation and operate transparently.
• Where smart contracts are used, the contract code must be designed in compliance with regulatory requirements and industry best practices.
• The underlying asset, if any, must be of a type that is not prohibited by law from being made the subject of transactions.
• Crypto Assets must not enable Users to conceal their wallet addresses when transacting.
• The assets must be capable of secure storage through cold-storage methods such as hardware wallets.
• The relevant Project Owner or development team must have a reliable track record and must not appear on official national or international sanctions lists.
• The structure of the Crypto Asset must provide its holders with fair use and access and must not grant the Project Owner extraordinary or arbitrary powers of intervention.

3.2. Crypto Assets Ineligible for Listing

Crypto Assets with the following characteristics will not be listed on the Platform:

• Crypto Assets whose custody conditions do not comply with Board regulations or that cannot be held securely.
• Assets whose creation process or technical infrastructure is incompatible with the legislation.
• Assets whose smart contracts are susceptible to manipulation or are designed in a manner that may infringe User rights.
• Tokens linked to underlying assets that, by their nature, are contrary to Turkish legislation or relevant international regulations.
• Crypto Assets that provide wallet privacy and thereby restrict transaction transparency and traceability.
• Assets whose Project Owner or management team has serious security vulnerabilities, suspected fraud, blacklist records, or similar adverse history.
• Assets whose project structure includes arrangements granting extraordinary powers that enable the Project Owner to intervene unilaterally in the asset.
• Crypto Assets that carry technical and operational risks such as fork risks, unstable trading volume, or low network security.

4. Listing Criteria

The following criteria are considered for Crypto Assets under consideration for listing on the Platform:

• Rights and Obligations: Where a Crypto Asset grants its holder a particular right or represents an obligation, that matter is expected to be defined clearly and transparently.
• Trading Volume and Market Depth: Assets with sufficient trading volume and no liquidity risk are given priority in the assessment.
• Circulating Supply: The total supply and the proportion of circulating supply of the Crypto Asset are reviewed in terms of market stability.
• Limited Supply: Whether the supply is subject to a specified limit and whether that limit has been transparently disclosed to the public are taken into account.
• Transaction Speed and Costs: The speed of transactions on the Crypto Asset network and the costs passed on to Users are analysed.
• Security and Infrastructure Quality: The reliability of the distributed ledger network or other technological infrastructure underlying the relevant Crypto Asset is assessed.
• Traceability and Transparency: Transaction traceability is an important criterion for ensuring transparency against activities such as money laundering.
• Market Behaviour: The price history, volatility, and susceptibility to speculation of the Crypto Asset are analysed.
• Manipulation Risk: Low market depth or the excessive influence of particular persons or entities over the price may prevent listing.
• Algorithmic Structures: Where value is determined entirely through algorithmic mechanisms, those systems are assessed for sustainability and reliability.
• Project Owner's History: The Project Owner's past financial and operational performance and any previous disciplinary or investigation records are reviewed.
• Exercise of Rights: The rights represented by the Crypto Asset are expected to be capable of being exercised and enforced in practice.
• Compliance and Regulation: Transactions connected with the relevant Crypto Asset are analysed for compliance with local and international regulations.
• Ownership Structure: Whether any persons or entities hold concentrated ownership or control over the asset is assessed.
• Fork and Update Risks: Risks that may arise from potential protocol changes (hard forks or soft forks) or network splits are taken into account.

During the assessment process, each criterion is weighted according to its materiality. The final listing decision is made by considering all criteria together.

5. Delisting Principles

Crypto Assets previously listed on the Platform may be delisted if any of the following circumstances arise:

• Breach of Critical Criteria: If the asset subsequently ceases to satisfy any of the mandatory conditions required for listing, the relevant Crypto Asset will be delisted immediately.
• Trading Status on Global Platforms: The loss of the ability to trade the Crypto Asset on major international exchanges, a decline in its volume, or its delisting is grounds for reassessment by the Platform.
• Judicial and Administrative Proceedings: If a judicial investigation is initiated against persons or entities directly connected with the Crypto Asset, or sanctions are imposed by official authorities, the listing decision is reviewed.
• Suspicious Activities: Delisting may be applied where reasonable suspicion arises of fraud, money laundering, or unlawful activities associated with the Crypto Asset.
• Security and Technology Vulnerabilities: Listing may be terminated where security vulnerabilities, hacking attempts, or systemic weaknesses in the Crypto Asset network increase the risk of loss to investors.
• Forks and Network Changes: The Platform may delist the asset if a hard fork, soft fork, or similar technical split occurs in the Crypto Asset network and creates additional risks for investors.
• Market Stability and Manipulation Risk: The listing decision may be revoked if the Crypto Asset experiences excessive price fluctuations, loses liquidity, or becomes susceptible to market manipulation.
• Regulatory Non-Compliance: Delisting may be decided where transactions connected with the relevant Crypto Asset contravene national or international legislation.

The utmost care is taken during the delisting process to protect customer rights and prevent investor detriment.
The Platform informs its customers as necessary about delisted assets and separately announces the methods for returning or liquidating those assets.

6. Extraordinary Circumstances and Measures

If extraordinary circumstances arise in relation to Crypto Assets traded on the Platform, the following measures are applied:

• Immediate Risk Assessment: The Listing Committee convenes urgently if a serious security vulnerability affecting the Crypto Asset, the insolvency of the Project Owner, an attempted fraud, a sudden regulatory change, or a similar extraordinary development occurs.
• Temporary Suspension: Trading in the relevant Crypto Asset may be temporarily suspended during the assessment to protect investors. The suspension decision takes effect immediately, depending on the urgency of the circumstances.
• Listing Review and Final Decision: Following the technical, legal, and operational review conducted by the Committee, a decision is made as to whether the relevant Crypto Asset may continue to be traded on the Platform. The asset is fully delisted where necessary.
• Customer Notification: Information on the extraordinary circumstances and the measures taken is announced to customers through the Platform's official communication channels.
• Return of Assets: If a decision is made to delist a Crypto Asset, customers are provided with the return of an equivalent amount of the relevant assets they hold. If return is not possible, a cash payment of equivalent value is made.
• Trading Restrictions: Depending on the sensitivity of the circumstances, partial or complete restrictions may be imposed on transactions in the relevant Crypto Asset.

In all decisions and measures taken in extraordinary circumstances, the Platform takes the protection of investor rights and the minimisation of systemic market risk as its basis.

7. Listing Committee

Decisions on the listing and delisting of Crypto Assets on the Platform are made by an independently operating Listing Committee.

The principles governing the structure and operation of the Committee are as follows:

• Committee Structure: The Listing Committee consists of at least three persons. Committee members are selected from persons with at least seven years of professional experience in fields such as finance, law, information technology, information security, or distributed ledger technologies.
• Board Representation: At least one member of the Platform's Board of Directors serves on the Committee. This establishes a direct link between senior management and the decision-making process.
• Independent Decision-Making: Committee members make listing and delisting decisions independently and solely in accordance with the Platform's principles of security, transparency, and customer interests.
• Assessment Process: The Committee reviews listing applications and currently listed assets against the established criteria and prepares a separate assessment report for each asset.
• Majority Principle: Listing and delisting decisions are made with the approval of a majority of Committee members.
• Annual Assessment: The Committee's activities are reviewed at least annually, and its membership is changed where necessary.

The purpose of the Committee is to ensure that Crypto Assets to be traded on the Platform are selected so as to protect investor safety and market integrity to the greatest extent possible.

8. Notification

Developments relating to Crypto Assets listed or delisted by the Platform are notified in a timely manner to the Central Securities Depository of Türkiye (MKK) and other competent institutions within the scope of the relevant legislation.

Customers are informed in accordance with the following principles:

• If a Crypto Asset is planned to be delisted, this is announced at least seven days in advance through the Platform's official communication channels.
• However, where urgent intervention is required due to extraordinary circumstances, the notification period may be reduced to one day and customers are informed as quickly as possible.
• Notifications clearly specify the Crypto Asset to be delisted, the reasons for delisting, and the alternative transaction options to be provided to customers.

When fulfilling its notification obligations, the Platform takes the utmost care to ensure that investors are informed accurately, completely, and in a timely manner.

9. Amendments and Entry into Force

This Procedure is reviewed periodically and updated as necessary.
The review is conducted at least annually or immediately upon the occurrence of any of the following circumstances:

• Changes in the legislation,
• New requirements arising in Platform practices,
• Deficiencies identified within the risk-management framework.

Amendments to the Procedure enter into force following the approval of the Platform's Board of Directors. The updated provisions are announced to customers through the Platform's official communication channels and published in an accessible manner.

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