..

White paper for crypto-assets other than asset-referenced tokens or e-money tokens


Digital Token Identifier:   XBL17BS2C

Offeror or person seeking admission to trading:   529900OX94239BUDFN51 - SC STEELCOIN GmbH

Type of submission:   Modify


Table of content

General information

SUMMARY

Part A - Information about offeror or person seeking admission to trading

Part B - Information about issuer, if different from offeror or person seeking admission to trading

Part C - Information about the operator of the trading platform in cases where it draws up the crypto-asset white paper and information about other persons drawing the crypto-asset white paper pursuant to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114

Part D - Information about other token project

Part E - Information about offer to public of other tokens or their admission to trading

Part F - Information about other tokens

Part G - Information on rights and obligations attached to other tokens

Part H – Information on underlying technology

Part I - Information on risks

Part J - Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts




[Table 2] Template for white papers for crypto-assets other than asset-referenced tokens or e-money tokens


Template for white papers for crypto-assets other than asset-referenced tokens or e-money tokens [abstract]

General information



00 Table of content
boolean true true

01 Date of notification
date 2026-10-05

02 Statement in accordance with Article 6(3) of Regulation (EU) 2023/1114
boolean true This crypto-asset white paper has not been approved by any competent authority in any Member State of the European Union. The offeror of the crypto-asset is solely responsible for the content of this crypto-asset white paper.

03 Compliance statement in accordance with Article 6(6) of Regulation (EU) 2023/1114
boolean true This crypto-asset white paper complies with Title II of Regulation (EU) 2023/1114 of the European Parliament and of the Council and, 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.

04 Statement in accordance with Article 6(5), points (a), (b), (c), of Regulation (EU) 2023/1114
boolean true The crypto-asset referred to in this crypto-asset white paper may lose its value in part or in full, may not always be transferable and may not be liquid

05 Statement in accordance with Article 6(5), point (d), of Regulation (EU) 2023/1114
boolean true The utility token referred to in this white paper may not be exchangeable against the good or service promised in this white paper, especially in the case of a failure or discontinuation of the crypto-asset project.

06 Statement in accordance with Article 6(5), points (e) and (f), of Regulation (EU) 2023/1114
boolean true The crypto-asset referred to in this white paper is not covered by the investor compensation schemes under Directive 97/9/EC of the European Parliament and of the Council or the deposit guarantee schemes under Directive 2014/49/EU of the European Parliament and of the Council.

SUMMARY



07 Warning in accordance with Article 6(7), second subparagraph, of Regulation (EU) 2023/1114
boolean true 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.

08 Characteristics of the crypto-asset
textBlock The Issuer issues Steelcoin X as utility tokens within the meaning of Art 3 para 1 no 9 MiCAR and therefore as crypto-assets other than asset-referenced tokens or e-money tokens under Art 4 MiCAR. Steelcoin X are based on the ERC-20 protocol and transferable on the Ethereum blockchain and Arbitrum One network (together, the "Blockchain"), but only to Investors located in Austria or another EEA country, unless the applicable laws and regulations permit otherwise; compliance is the transferor's responsibility. Future issues may use different technology. The minimum subscription from the Issuer is one Steelcoin X. Fractions may be transferred, subject to the above restrictions, down to 0.000000000000000001 Steelcoin X. Steelcoin X are available to Investors located in Austria or another EEA country and grant only the right to acquire and collect Hot Rolled Coil Steel ("HRC") supplied by the Issuer. One Steelcoin X is required per metric ton of HRC, but only a whole HRC may be obtained. As each HRC weighs between 20 and 30 tons, 20 to 30 Steelcoin X are required per HRC. Cash redemption is excluded. To redeem Steelcoin X for one or more HRCs, holders must email redemption@steelcoin.com, register their intention and specify the full number of HRCs requested. The Issuer will review the request and identify HRCs meeting the requested specifications that may be collected at a location in the EEA determined by the Issuer. Subject to compliance with the specifications in D.7 of this White Paper, the Issuer may determine the specific HRC(s) offered. The selected HRC(s) may therefore differ from the redeemer's preferences, and the redeemer has no right to a particular HRC, to choose among available HRCs or to select the collection location. The Issuer will nevertheless use reasonable efforts to accommodate stated preferences within the defined specifications. For the HRC(s) selected by the redeemer from those offered, the Issuer will state the exact weight and corresponding amount of Steelcoin X to be transferred to a designated redemption address on the Blockchain. Once the Issuer has received the full amount of Steelcoin X, the HRC(s) will be available for collection at the specified EEA location at an agreed time within 12 months after receipt of the redemption request. Collection may be delayed, including beyond 12 months, in circumstances including force majeure, production disruptions, armed conflict or other unforeseen or unusual developments. The Issuer will promptly notify the redeemer of any delay and provide updated information on expected availability. Because redemption against collection of HRC depends on market availability and the Issuer's economic situation, it may be substantially delayed or ultimately impossible. Steelcoin X cannot be redeemed for monetary value and may be used solely to acquire HRC. The Issuer may set the offer price up to the Maximum Issue Price, which may be amended, and the offer price may therefore fluctuate. The Issuer holds a trading business licence but operates no storage facilities. At its discretion, it may store a limited number of HRCs at specific facilities, but is not obliged to do so and generally will not hold enough HRCs to cover all potential redemptions. Acquirers must therefore not rely on Steelcoin X being backed by stored HRC. To purchase Steelcoin X, an interested Investor must email subscription@steelcoin.com with the requested number of Steelcoin X and proposed issue price per Steelcoin X in EUR (the "Offer"). The proposed price must fall between the minimum and maximum subscription amounts per Steelcoin X specified in 10 below; the actual issue price will be agreed within that range. The Issuer may accept or reject an Offer in whole or accept it in part for a reduced number of Steelcoin X, but only at the price offered by, or agreed with, the Investor (the "Offered Subscription Price"). An Offer is deemed rejected unless the Issuer notifies the Investor of full or partial acceptance within two business days after submission. Upon full or partial acceptance, the Investor subscribes for the accepted number of Steelcoin X. Issuance is conditional on full prior payment of the accepted number multiplied by the agreed issue price. Subscriptions may be paid only in EUR. Available payment methods are communicated after an Offer is made. Once the Investor has paid the full subscription amount using an available payment method, the Investor must provide the public address of the Blockchain account to which the Steelcoin X are to be transferred. The Issuer will transfer the Steelcoin X to that address by the end of the following business day after receiving it and will bear the gas fee in the Blockchain's native currency, Ether (ETH). Issuance of Steelcoin X does not itself trigger VAT. VAT becomes due upon the actual handover of the HRC and, in the event of redemption, must be paid before handover based on the applicable assessment basis and tax rate, which also depends on the collection location. Reverse-charge procedures apply where eligible. The Issuer bears all gas fees in the subscription process, so purchasers incur no Blockchain transaction costs when subscribing directly from the Issuer. During redemption, the redeemer bears all gas fees for the Steelcoin X transfer. The Issuer has no influence over costs arising from purchases from third parties. Steelcoin X confer no shareholder rights, including participation or voting rights at shareholders' meetings, co-determination rights, rights to the Issuer's profits or rights to liquidation proceeds. The Issuer may use the offering proceeds at its discretion and is not required to invest them in steel products, use them for steel trading or apply them in any other specific manner.

09 Further information about utility tokens
textBlock The Issuer will issue Steelcoin X. Holders of Steelcoin X have the right to collect HRC at locations in the EEA against return of the required number of Steelcoin X and payment of applicable VAT (if any). The Issuer shall determine the location(s) at which the HRC(s) may be collected. Redeemers are not entitled to choose or request a specific delivery or collection site. Acquiring one HRC requires 20 to 30 Steelcoin X depending on the weight of the HRC. However, only whole HRC can be obtained (thus, no parts of HRC).
While the Issuer expects that usually a certain number of HRC will be available for collection at locations in the EEA, this may not be the case at all locations and as outlined in 08 the collection of HRC may be delayed or not be possible at all.
A collection of HRC is possible within thirty years upon issuing the last Steelcoin X. The Issuer will publish the date of such last issuance on its website (www.steelcoin.com).
Steelcoin X cannot be redeemed for monetary value.
Steelcoin X are based on the ERC-20 protocol and can be transferred on the Blockchain (public blockchain) to the extent permitted by applicable laws and regulations. Thus, only the private key holders can authorize transfers to other addresses. Once transferred, associated rights and obligations are also transferred. Nevertheless, further issues of Steelcoin X may be based on a different technology (e.g., token standard, blockchain, etc).
While Steelcoin X are basically transferable (subject to the limitations in 08 above), there is no guarantee that the Investor will be able to sell Steelcoin X to third parties. The Issuer has no obligation to and will not redeem Steelcoin X against cash.

10 Key information about the offer to the public or admission to trading
textBlock
Total amount of the offer: EUR 60,000,000 to EUR 180,000,000 depending on the actual issue price;

Total number of Steelcoin X to be offered to the public: Up to 100,000 Steelcoin X are to be offered to the public. However, the Issuer reserves the right to increase the total number of Steelcoin X at any time;

Subscription period: Not applicable (the Steelcoin X will be issued continuously until further notice);

Minimum and maximum subscription amount: The minimum subscription amount is EUR 500 per Steelcoin X. The maximum subscription amount is EUR 1,800 per Steelcoin X. The exact subscription amount will be agreed between the Issuer and the interested purchaser within this range;

Issue price of Steelcoin X: The Steelcoin X are not issued at a fixed issue price. Instead, each interested purchaser may make a subscription offer to the Issuer specifying the number of Steelcoin X as well as the proposed issue price therefor. The issue price ranges between EUR 500 and EUR 1,800 per Steelcoin X and will be agreed between the Issuer and the interested purchaser within this range. The Issuer is free to accept or reject any such offer in whole, or to accept any such offer in part with a reduced number of Steelcoin X but only at the issue price per Steelcoin X offered by the purchaser. If all Steelcoin X that are subject to this offering would be issued at the Maximum Issue Price, the maximum volume of the present issue would amount to EUR 180,000,000. The Issuer reserves the right to increase or decrease the maximum number of Steelcoin X to be issued in the future;

Subscription fees (if any): The Issuer does not charge a subscription fee;

Target prospective holders: Steelcoin X are available to Investors, who are located in Austria or other countries of the EEA. The Issuer aims for a public offering in further European countries also outside the EEA and worldwide, provided that the regulatory requirements and the local laws and regulations allow this;

Description of offer phases (including discounted purchase price for early purchasers of Steelcoin X, if any): There will not be a pre-sale conducted. The subsequent sale of Steelcoin X will be conducted on a continuous basis (until further notice) via the Issuer or third parties based on agreements with the issuer;

Crypto-asset service provider in charge of the placing of Steelcoin X : Not applicable. The Issuer may appoint such service providers in the future;

Form of placement (with or without a firm commitment basis): Without a firm commitment basis;

Admission to trading (including name of the trading platform): Steelcoin X is admitted to trading on the trading platform of ZBX. ZBX is authorised as a crypto-asset service provider and in particular holds a license for the operation of a trading platform for crypto-assets in accordance with MiCAR; its market identifier code is ZBXE.
Steelcoin X might also become accepted by third parties such as (other) exchanges or decentralized finance (DeFi) protocols which are out of the control of the Issuer.
Even in case of a listing on those and further trading venues, which may be available in the future, the holder of Steelcoin X may not be able to sell Steelcoin X at all or for a specific price.

Part A - Information about offeror or person seeking admission to trading



A.1 Name
text SC STEELCOIN GmbH

A.2 Legal form
text Gesellschaft mit beschränkter Haftung (limited liability company) under Austrian law.

A.3 Registered address



Registered addess
text Praterstraße 15/3/Top 17

Country
enumeration
Austria

Sub-division
text  1020 Vienna

A.4 Head office



Head office
text Praterstraße 15/3/Top 17

Country
enumeration
Austria

Sub-division
text  1020 Vienna

A.5 Registration date
date 2022-04-22

A.6 Legal entity identifier
LEI 529900OX94239BUDFN51

A.7 Another identifier required pursuant to applicable national law
text


A.8 Contact telephone number
text +43505030

A.9 E-mail address
text office@steelcoin.com

A.10 Response time (days)
integer 7

A.11 Parent company
text FRANKSTAHL Rohr- und Stahlhandelsgesellschaft m.b.H. (100 %)

A.12 Members of the management body



Member #1
id 1

Identity
text Mag. Marcel Javor

Business address
text Praterstraße 15/3/Top 17, 1020 Vienna

Function
text Managing Director

Member #2
id 2

Identity
text Dr. Ronald Nagy

Business address
text Praterstraße 15/3/Top 17, 1020 Vienna

Function
text Managing Director

A.13 Business activity
textBlock Trade in metal goods and building materials.

A.14 Parent company business activity
textBlock FRANKSTAHL Rohr- und Stahlhandelsgesellschaft m.b.H.'s ("FRANKSTAHL") business activities include the fol-lowing: wholesale of ores, iron, steel and semi-finished products as well as metalworking. The parent company's principal markets are EU countries.

A.15 Newly established
boolean false

A.16 Financial condition for the past three years
textBlock OVERVIEW 2023 TO 2025

2023
Revenue (in EUR): 14,907,865.49
Net Profit (in EUR): 22,484.85
Total Assets (in EUR): 10,432,595.58
Equity (in EUR): 9,099,151.14

2024
Revenue (in EUR): 15,282,228.02
Net Profit (in EUR): -583,296.72
Total Assets (in EUR): 11,724,244.99
Equity (in EUR): 8,515,854.42

2025
Revenue (in EUR): 13,502,906.57
Net Profit (in EUR): -206,416.67
Total Assets (in EUR): 9,489,320.52
Equity (in EUR): 8,309,437.75

BALANCE SHEETS 2023 TO 2025

Balance Sheet

FY 31.12.2025 / FY 31.12.2024 / FY 31.12.2023

Assets

A. Current Assets

I. Goods
2025: 6,532,281.45
2024: 10,471,000.84
2023: 10,090,414.56

II. Receivables and Other Assets

1. Receivables from affiliated companies
2025: 732,476.62
2024: 173,825.44
2023: 8,798.09

of which other
2025: 61,066.96
2024: 173,825.44
2023: 7,500.00

2. Other receivables and assets
2025: 450,855.03
2024: 540,678.71
2023: 215,414.72

III. Bank balances
2025: 1,577,668.97
2024: 176,117.15
2023: 117,968.21

B. Prepaid Expenses
2025: 196,038.45
2024: 362,422.85
2023: -

Total Assets
2025: 9,489,320.52
2024: 11,724,244.99
2023: 10,432,595.58

Equity and Liabilities

A. Equity

I. Called-up share capital
2025: 100,000.00
2024: 100,000.00
2023: 100,000.00

of which paid-in capital
2025: 100,000.00
2024: 100,000.00
2023: 100,000.00

II. Capital reserves
2025: 9,000,000.00
2024: 9,000,000.00
2023: 9,000,000.00

III. Net loss
2025: -790,562.25
2024: -584,145.58
2023: -848.86

of which loss carried forward
2025: -584,145.58
2024: -848.86
2023: -23,333.71

Total Equity
2025: 8,309,437.75
2024: 8,515,854.42
2023: 9,099,151.14

B. Provisions

1. Other provisions
2025: 459,653.26
2024: 621,064.72
2023: 151,253.53

C. Liabilities

1. Trade payables
2025: 251,710.31
2024: 1,283,281.50
2023: 127,580.68

2. Liabilities to affiliated companies
2025: 415,859.39
2024: 1,290,927.07
2023: 1,040,099.27

3. Other liabilities
2025: 52,659.81
2024: 13,117.28
2023: 14,510.96

Total Liabilities
2025: 720,229.51
2024: 2,587,325.85
2023: 1,182,190.91

Total Liabilities and Equity
2025: 9,489,320.52
2024: 11,724,244.99
2023: 10,432,595.58

PROFIT AND LOSS STATEMENTS 2023 TO 2025

Profit and Loss Statement

FY 31.12.2025 / FY 31.12.2024 / FY 31.12.2023

1. Revenue
2025: 13,502,906.57
2024: 15,282,228.02
2023: 14,907,865.49

2. Other operating income
2025: 2,500.00
2024: 100,091.75
2023: 43,479.16

3. Cost of materials and purchased services
2025: 12,619,845.29
2024: 14,701,709.49
2023: 14,138,184.91

4. Personnel expenses
2025: 190,621.83
2024: 98,864.58
2023: -

5. Other operating expenses
2025: 860,424.76
2024: 1,375,050.77
2023: 746,083.94

6. Operating result
2025: -165,485.31
2024: -793,386.07
2023: 67,075.80

7. Other interest and similar income
2025: 3,270.13
2024: 44,587.07
2023: 12,731.79

8. Interest and similar expenses
2025: 105,268.45
2024: 7,449.16
2023: 57,322.74

9. Financial result
2025: -101,998.32
2024: 37,137.91
2023: -44,590.95

10. Result before taxes
2025: -267,483.63
2024: -756,248.16
2023: 22,484.85

11. Income taxes
2025: -61,066.96
2024: -172,951.44
2023: -

Corporate tax
2025: -
2024: 974.00
2023: -

of which offset within tax group
2025: -61,066.96
2024: -173,925.44
2023: -

12. Result after taxes
2025: -206,416.67
2024: -583,296.72
2023: 22,484.85

13. Net income/loss for the year
2025: -206,416.67
2024: -583,296.72
2023: 22,484.85

14. Loss carried forward
2025: -584,145.58
2024: -848.86
2023: -23,333.71

15. Balance sheet result
2025: -790,562.25
2024: -584,145.58
2023: -848.86

The Issuer was established on 31 March 2022 and registered with the Austrian Company Register (Firmenbuch) on 22 April 2022. The assets of the Issuer are mainly financed from contributions from the parent company FRANKSTAHL. As of 31 December 2025, total assets amounted to EUR 9,489,320.52, compared to EUR 11,724,244.99 at the end of 2024 and EUR 10,432,595.58 at the end of 2023.

In 2023, liabilities amounted to EUR 1,182,190.91, and by 2024 they more than doubled to EUR 2,587,325.85 (around half of it are liabilities towards affiliates). In 2025, liabilities decreased to EUR 720,229.51.

As far as revenues are concerned, 2023 was the first full revenue-generating year, with EUR 14,907,865.49 in sales and a modest net profit of EUR 22,484.85. In 2024, while revenue slightly increased to EUR 15,282,228.02, the Issuer incurred a net loss of EUR 583,296.72. This planned annual loss was recorded due to strategic investments in trading infrastructure, platform development, marketing, and regulatory compliance. In 2025, revenue amounted to EUR 13,502,906.57 and the Issuer incurred a net loss of EUR 206,416.67.

A.17 Financial condition since registration
textBlock Not applicable – see A.16.

Part B - Information about issuer, if different from offeror or person seeking admission to trading



B.1 Issuer different from offerror or person seeking admission to trading
boolean false

B.2 Name
N/A
.

B.3 Legal form
N/A .

B.4 Registered address

Registered addess
N/A .

Country
N/A .

Sub-division
N/A .

B.5 Head office

Head office
N/A .

Country
N/A .

Sub-division
N/A .

B.6 Registration date
N/A .

B.7 Legal entity identifier
N/A .

B.8 Another identifier required pursuant to applicable national law
N/A .

B.9 Parent company
N/A .

B.10 Members of the management body

Member #1
N/A .

Identity
N/A .

Business address
N/A .

Function
N/A .

B.11 Business activity
N/A .

B.12 Parent company business activity
N/A .

Part C - Information about the operator of the trading platform in cases where it draws up the crypto-asset white paper and information about other persons drawing the crypto-asset white paper pursuant to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114

C.1 Name
N/A .

C.2 Legal form
N/A .

C.3 Registered address

Registered address
N/A .

Country
N/A .

Sub-division
N/A .

C.4 Head office

Head office
N/A .

Country
N/A .

Sub-division
N/A .

C.5 Registration date
N/A .

C.6 Legal entity identifier
N/A .

C.7 Another identifier required pursuant to applicable national law
N/A .

C.8 Parent company
N/A .

C.9 Reason for crypto-asset white paper preparation
N/A .

C.10 Members of the management body

Member #1
N/A .

Identity
N/A .

Business address
N/A .

Function
N/A .

C.11 Operator business activity
N/A .

C.12 Parent company business activity
N/A .

C.13 Other persons drawing up the crypto-asset white paper according to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114
N/A .

C.14 Reason for drawing the white paper by persons referred to in Article 6(1), second subparagraph, of Regulation (EU) 2023/1114
N/A .

Part D - Information about other token project



D.1 Crypto-asset project name
text Steelcoin X

D.2 Crypto-asset name
text Steelcoin X

D.3 Abbreviation
text SCX

D.4 Crypto-asset project description
textBlock The Issuer in the context of this project will issue Steelcoin X. Steelcoin X are crypto-assets (other than asset-referenced tokens or e-money tokens) pursuant to Art 4 MiCAR. They also qualify as utility token pursuant to Art 3 para 1 no 9 MiCAR. Steelcoin X are based on the ERC-20 protocol and can be transferred on the Blockchain (public blockchain). However, the Issuer may decide to base further issues of Steelcoin X on a different technology (e.g., token standard, blockchain, etc).
Steelcoin X are offered to persons, who are located in Austria or other countries of the EEA.
Holders of Steelcoin X gain the right to return Steelcoin X against physical collection of HRC at a later stage (whereby ownership in the HRC is transferred to the owner of the Steelcoin X upon such collection). To acquire one HRC requires 20 to 30 Steelcoin X depending on the weight of the HRC. However, only whole HRC can be obtained (thus, no HRC-fragments). Steelcoin X cannot be redeemed for monetary value. For further details regarding the redemption of Steelcoin X see G.8.
For the buyers Steelcoin X have the advantage that they can buy a right to obtain steel in the form of HRC without the requirement of keeping steel in storage. Steelcoin X make it also possible to transfer such rights easily on the Blockchain (subject to the limitations outlined in 08 above) without having to manipulate physical steel. However, the holder of the Steelcoin X does not own HRC (or a share in HRC) prior to the redemption of a sufficient number of Steelcoin X
The Issuer has a business license for the trading business and is part of the FRANKSTAHL Group that is primarily active in steel trading. The issuing of Steelcoin X is a further means for the Issuer to sell steel products. The Issuer intends – without assuming any obligation thereto – to use the proceeds from Steelcoin X for its strategic procurement of steel (including, without limitation, physical inventory or through relevant financial instruments for hedging purposes; for details see D.10).

D.5 Details of all natural or legal persons involved in implementation of crypto-asset project



Person #1
id 1

Type of person
enumeration
Other person involved in implementation

Name of person
text SC Steelcoin GmbH

Business address of person
text  Praterstraße 15/3 Top 17
1020 Vienna

Domicile of company
enumeration
Austria

Person #2
id 2

Type of person
enumeration
Other person involved in implementation

Name of person
text Fireblocks Ltd

Business address of person
text Floor 25, Yizhak Sade 8
Tel Aviv 6777508

Domicile of company
enumeration
Israel

Person #3
id 3

Type of person
enumeration
Other person involved in implementation

Name of person
text  Frankstahl Rohr- und Stahlhandelsgesellschaft mbH

Business address of person
text Frankstahlstraße 2
2353 Guntramsdorf

Domicile of company
enumeration
Austria

D.6 Utility token classification
boolean true

D.7 Key features of goods or services for utility token projects
text Steelcoin X are exclusively granting the owner the right to acquire HRC supplied by the Issuer. Only whole HRC can be obtained (thus, no HRC-fragments). In order to exchange one whole HRC, 20 to 30 Steelcoin X depending on the weight of the HRC are required.

The HRC can be specified as follows:

Unit: 1 HRC;
Standard: EN 10025-2;
Settlement method: Physical settlement;
Places of collection: HRC ex-works location in EEA (to be defined by Issuer);
Steel grade: S235 or equivalent (based on Issuer's discretion);
Thickness: 4 millimeters, 5 millimeters, or 6 millimeters (as chosen by redeemer subject to availability);
Width: 1,200 millimeters to 1,600 millimeters (based on Issuer's discretion);
Tolerances: According to EN 10051;
Weight: 20 to 30 metric tons;
Minimum redemption: 1 HRC (1 Steelcoin X is required per 1 metric ton of HRC [mill edge], thus usually 20 to 30 Steelcoin X will be required for one HRC depending on its weight).

The Issuer reserves the right to determine which specific HRC will be offered to the redeemer, provided that it complies with the specifications set out in the table above. The redeemer shall have no entitlement to receive a particular HRC or to select from available HRC(s). Thus, the HRC(s) selected by the Issuer may deviate from the preferences of the redeemer. Nevertheless, the Issuer will make reasonable efforts to accommodate the re-deemer's stated preferences to the extent possible within the defined specifications.

The issuance of the Steelcoin X as such does not trigger VAT. However, VAT is due at the time of the actual handing over of the HRC and needs to be paid in case of redemption prior to the HRC(s) being handed over to the respective Investor based on the applicable assessment basis and tax rate for the calculation of VAT (the latter also depending on the location in which the HRC is collected). Reverse charge procedures will be applying where eligible.

D.8 Plans for the token



Description of past milestones
textBlock The Steelcoin X project was initiated in 2024 with the goal of developing a MiCAR-compliant utility token. The key milestones of this project are:
Q1 2022: Incorporation of the Issuer
Q3 2024: Conceptualization of Steelcoin X and initial legal structuring (defining project visions, use case and tar-get audience as well as tokenomics)
Q1 2025: Drafting initial white paper in accordance with MiCAR requirements
Q2 2025: Filing of the white paper
Q2 2025: Soundings regarding a planned admission to trading
Q3 2025: Initial issuance of Steelcoin X tokens
Q3 2025: Planned admission to trading on ZBX's trading platform
Q4 2025: Expansion of the offer to a broader industrial and institutional investor base

Description of future milestones
textBlock Q4 2026: Availability to clients of Bitpanda GmbH

D.9 Resource allocation
text The Steelcoin X project is resourced with the necessary financial, human, and technical capital to launch the Steelcoin X project. The current team manages all operational, technical and regulatory aspects.
The Steelcoin X token is deployed and secured using Fireblocks' enterprise-grade digital asset infrastructure, to accomplish safe transaction integrity. Fireblocks has a long track record, a large and experienced team, and expertise in tokenization.
Furthermore, FRANKSTAHL provides assistance with regard to personnel, IT, cyber security and blockchain technology and sharing its experience from similar projects.
Additionally, partnerships with selected crypto platforms may be set up with the allocated resources.
The Issuer estimates the total costs for the issue of STEELCOINS under this White Paper to amount to up to around EUR 300,000. This amount is fully financed.

D.10 Planned use of collected funds or other tokens
text The Issuer will use the revenues generated from the sale of Steelcoin X for its ongoing business operations in steel trading.
In particular, the Issuer intends to hedge (without obligation thereto) itself with the issuing of Steelcoin X, as this allows the Issuer to invest into steel and to increase the volume of its own steel trading.
The Issuer might also use the collected funds to store – without obligation thereto and at its own discretion – a limited number of HRC at specific storage facilities but is not obliged to and usually will not store as many HRC as could be potentially redeemed against Steelcoin X and also may sell such HRC at any time. The holders of the Steelcoin X thus are not (co-)owners of the stored HRC and their claims against the Issuer are also not otherwise secured by such stored HRC. Thus, the redemption of Steelcoin X (in a sufficient amount) against collection of HRC also depends on the availability of HRC on the market and thus, in particular subject to market conditions but also the economic situation of the Issuer, may be delayed substantially or not be possible at all.

Part E - Information about offer to public of other tokens or their admission to trading



E.1 Public offering or admission to trading
enumeration
Admission to trading

E.2 Reasons for public offer or admission to trading
textBlock The primary reason for the public offer and admission to trading is to ensure broad appeal to the market. As the Issuer has a business license for the trading business and is part of the FRANKSTAHL Group that is primarily active in steel trading, the issuing of Steelcoin X is a further means for the Issuer to sell steel products. The Issuer introduces the opportunity for Investors to acquire and transfer (to other Investors) rights to obtain ownership of HRC in a digital format, something not possible with traditional instruments such as Exchange Traded Funds, Exchange Traded Products, or other financial products (as outlined in this White Paper, ownership of HRC is only obtained once HRC are collected – see 08 above and G.8 below). Leveraging blockchain technology and smart contract functionality, the Issuer allows Steelcoin X holders to hold and transfer the right to acquire steel, with the possibility of physical redemption, benefiting from comparably low transaction costs and the convenience of a digital wallet.

E.3 Fundraising target



Target expressed in currency
monetary
EUR

Target expressed in units
decimal


Target expressed in digital token identifier
text


E.4 Minimum subscription goals



Goals expressed in currency
monetary
EUR

Goals expressed in units
decimal


Goals expressed in digital token identifier
text


E.5 Maximum subscription goals



Goasl expressed in currency
monetary 180000000 EUR

Goals expressed in units
decimal 100000

Goals expressed in digital token identifier
text


E.6 Oversubscription acceptance
boolean false

E.7 Oversubscription allocation
text Not applicable

Issue price details



E.8 Issue price
decimal


E.9 Official currency determining issue price
enumeration
Euro

E.9 Any other tokens determining issue price
text Not applicable

E.10 Subscription fee



Fee expressed in currency
monetary
EUR

Fee expressed in units
decimal


Fee expressed in digital token identifier
text


E.11 Offer price determination method
text The Steelcoin X are not issued at a fixed issue price. Instead, each interested purchaser may make a subscription offer to the Issuer specifying the (full) number of Steelcoin X such purchaser would like to acquire as well as the issue price offered therefor in EUR by sending an e-mail to subscription@steelcoin.com. The issue price ranges between EUR 500 and EUR 1,800 (the latter being the "Maximum Issue Price") per Steelcoin X and will be agreed between the Issuer and the interested purchaser within this range, and the minimum investment amount offered by the Investor per Steelcoin X thus must be at least EUR 500. The Issuer is free to accept or reject any such offer in whole, or to accept any such offer in part with a reduced number of Steelcoin X but only at the issue price per Steelcoin X offered by or agreed with the purchaser.

E.12 Total number of offered or traded other tokens
integer 100000

E.13 Targeted holders
enumeration
All types of investors

E.14 Holder restrictions
text The offer of Steelcoin X pursuant to this White Paper is not available for Investors outside the EU/EEA. The Issuer might in the future offer Steelcoin X to such Investors subject to and in compliance with applicable laws and regulations.

E.15 Reimbursement notice
boolean true


E.16 Refund mechanism
textBlock Not applicable

E.17 Refund timeline
text Not applicable

E.18 Offer phases
textBlock Steelcoin X will be offered on a continuous basis in one ongoing offer phase. However, the Issuer reserves the right to increase or decrease the maximum number of Steelcoin X to be issued in the future.

E.19 Early purchase discount
textBlock There will not be a pre-sale of Steelcoin X and thus, no discount to the issue price.

E.20 Time-limited offer
boolean false

E.21 Subscription period beginning
date


E.22 Subscription period end
date


E.23 Safeguarding arrangements for offered funds or other tokens
textBlock Not applicable (as there is no time limited offer and no right of withdrawal see E.26)

E.24 Payment methods for other token purchase
textBlock Subscriptions for Steelcoin X can only be made in EUR. The Issuer offers the following payment methods for the purchase of Steelcoin X:
•     SEPA bank transfer; and
•     Stablecoins in the form of e-money token in accordance with Art 3 para 1 no 7 MiCAR.
Payment methods are subject to change. Not all payment methods may be available in every country where Steelcoin X are offered for purchase. Interested Investors are not entitled to any specific payment method. De-tails on the currently available payment methods are communicated to the interested Investors following the in-terested Investors making an offer to subscribe Steelcoin X as outlined in E.8 above. All payments made to the Issuer shall originate from accounts within the EU and/or the EEA. The interested Investor must pay the Subscrip-tion Amount immediately.
In addition, when Steelcoin X is purchased via ZBX's trading platform, ZBX offers a variety of payment methods including bank transfers, credit/debit cards, Apple Pay, and Google Pay. Payment methods are subject to ZBX's terms and conditions as amended from time to time. The same applies where Steelcoin X is purchased on third-party trading platforms or via third-party brokerage platforms, the applicable modalities are governed by the terms and conditions of the respective operator or service provider and are outside the control of the Issuer.
Please note that when purchasing Steelcoin X via ZBX's or another trading platform, available payment methods are subject to the respective operator's own discretion and are thus, out of the Issuer's control.

E.25 Value transfer methods for reimbursement
textBlock Not applicable (as outlined above there is no reimbursement mechanism)

E.26 Right of withdrawal
textBlock Not applicable (as the Steelcoin X have not been issued to retail holders as defined in Art 3 para 1 no 37 MiCAR prior to the admission of Steelcoin X to trading on the MiCAR trading platform ZBX).

E.27 Transfer of purchased other tokens
textBlock The minimum denomination (= smallest transferable unit) of a Steelcoin X is 0.000000000000000001 Steelcoin X. However, the smallest unit of Steelcoin X that can be subscribed from the Issuer and will be transferred from the Issuer to the Investor is 1 (one) Steelcoin X.
Steelcoin X as well as fractions thereof are, subject to applicable laws and regulations, generally transferable subject to the limitations outlined in 08 above. However, any transfer of a Steelcoin X (or a fraction thereof) re-quires a transfer on the Blockchain. Any transfer, including in particular, also the exercise of the redemption for HRC will generate gas fees payable by the redeemer in Ether (ETH, the Blockchain's native currency). Thus, if the user wants to perform a transfer, it must have the corresponding amount of ETH to pay the gas fees incurred for the transfer. The Issuer has no influence on the amount of payable gas fees.
The gas fees for the initial transfer of Steelcoin X to the Investor will be borne by the Issuer.
Investors can also purchase Steelcoin X through ZBX's or potentially other third party trading platforms by plac-ing an order. Upon successful purchase, Steelcoin X are transferred to the Investor's designated wallet address within the third party trading platform. To execute an order, Investors must hold an active account with the third party trading platform and a sufficient account balance to execute the trade. The applicable modalities are gov-erned by the terms and conditions of the respective operator and are outside the control of the Issuer.
Please note that when purchasing Steelcoin X via a third party trading platform, the transfer modalities are sub-ject to the third party trading platform's own terms and conditions and are thus out of the Issuer's control.

E.28 Transfer time schedule
text After complete payment of the subscription amount (the amount of Steelcoin X accepted by the Issuer multiplied with the issue price per Steelcoin X agreed between the Issuer and the Investor) in EUR was effected by the Investor using an available payment method, the interested Investor is asked to provide his public address of the account on the Blockchain to which the Steelcoin X shall be transferred. Subsequently the Issuer transfers the Steelcoin X to the Investor's provided public address of the account on the Blockchain until the end of the following business day after the Issuer having received such public address. The gas fee for the transfer of the Steelcoin X payable in the Blockchain's native currency Ether (ETH) is borne by the Issuer.
The issuing of the Steelcoin X to the subscriber is subject to prior payment in full of the subscription amount. If payment of the full subscription amount is not effected within the time agreed between the Issuer and the subscriber, the applicable subscription offer is cancelled. Should a payment of the subscription amount be revoked or cancelled for whatsoever reason, the subscriber has to return the Steelcoin X to the Issuer. Should such revocation or cancellation be attributable to the Investor, the Issuer reserves the right to demand full payment instead.
When purchasing Steelcoin X via ZBX's trading platform the following applies: All crypto-asset trades on the ZBX platform are settled within the timeframe as determined by the ZBX terms and conditions as amended from time to time and subject to the necessary compliance checks and satisfying other conditions as stipulated therein. The same applies where Steelcoin X is purchased on other third-party trading platforms or via third-party brokerage platforms, whereby the applicable modalities are governed by the terms and conditions of the respective operator or service provider and are outside the control of the Issuer.
Please note that when purchasing Steelcoin X via ZBX's or another trading platform, the transfer time is subject to the respective operator's terms and conditions and is thus out of the Issuer's control.

E.29 Purchaser's technical requirements
textBlock  The access to the Steelcoin X is only possible via an ERC-20 compatible (hardware or software) wallet with a combination of a public key (address) and private key (or seed phrase) of the purchaser. The private key (or seed phrase) is essential to access the wallet and is used to authorize transactions on the Blockchain. Thus, in case of loss or theft of the private key (or seed phrase), the access to the Steelcoin X may be irretrievably lost.
For the avoidance of doubt, the Issuer does not provide such wallets for crypto-assets.

Other token services provider characteristics



E.30 Other token service provider (CASP) name
text Not applicable

E.31 CASP identifier
LEI


E.32 Placement form
enumeration
Not applicable

Trading platforms characteristics



E.33 Trading platforms name
text Steelcoin X is admitted to trading on ZBX (Zillion Bits Ltd). ZBX is a crypto-asset service provider pursuant to MiCAR and in particular holds a license for the operation of a trading platform; its market identifier code is ZBXE.
The Issuer intends to make Steelcoin X available on further trading platforms. Where such availability is procured by the Issuer, this will be disclosed. Please note that independently of that, Steelcoin X may also become accepted by third parties such as other exchanges or decentralized finance (DeFi) protocols without any involvement of the Issuer and outside its control.
Even in case of a listing on ZBX and further trading venues, which may be available in the future, the holder of Steelcoin X may not be able to sell Steelcoin X at all or for a specific price.

E.34 Trading platforms market identifier code (MIC)
text ZBXE (Zillion Bits Ltd).

E.35 Trading platforms access
text In order to access the trading platform and engage in any trades with ZBX, the potential investor must create an account with ZBX. The account may be accessible through ZBX's website (www.zbx.com) or mobile application using a username, password and other methods of authentication established by ZBX. The access to ZBX's trad-ing platform is subject to ZBX's terms and conditions as amended from time to time. Access to further trading or brokerage platforms may likewise require the opening of an account with the respective operator and is subject to its terms and conditions and onboarding requirements.
Please note that the access modalities to ZBX's or other trading platforms and services referred to above are subject to the respective operator's own terms and conditions and are thus out of the Issuer's control.

E.36 Involved costs
textBlock The current list of applicable fees and charges for the access of Investors to ZBX's trading platform can be ac-cessed at ZBX's website (www.zbx.com/fee-rate). These fees may be amended, updated, supplemented and/or replaced by ZBX from time to time. The fees and charges applicable to further trading or brokerage platforms may also be amended from time to time.
Please note that the involved costs for Investors in order to gain access to the trading platforms and services re-ferred to above are subject to the respective operator's own terms and conditions and are thus out of the Issuer's control.

E.37 Offer expenses
textBlock Not applicable

E.38 Conflicts of interest
textBlock Marcel Javor, one of the Issuer's managing directors (Geschäftsführer), is also managing director of the Issuer's sole shareholder FRANKSTAHL and (indirect) sole ultimate beneficial owner of the Issuer and FRANKSTAHL. Thus, conflicts of interest may arise between the Issuer, its shareholder FRANKSTAHL and its sole ultimate beneficial owner.
The other managing director of the Issuer, Ronald Nagy, is currently a procura holder (Prokurist) and head of fi-nance at FRANKSTAHL as well as managing director of various other companies of the FRANKSTAHL group of companies.
Conflicts of interest may arise between the Issuer, its shareholder FRANKSTAHL, its sole ultimate beneficial own-er, other companies of FRANKSTAHL group, its respective management, any employees, service providers or other persons or companies associated with the Issuer.

E.39 Applicable law
textBlock The offer of Steelcoin X to the public shall be governed by and interpreted in accordance with Austrian law, excluding its choice of law clauses and the UN Sales Convention.

E.40 Competent court
textBlock For all disputes arising out of or in connection with the Steelcoin X or in connection with this White Paper be-tween the Issuer and an Investor, who is not a consumer (according to the Austrian Consumer Protection Act – Konsumentenschutzgesetz), the court competent for commercial matters in Vienna, Inner City shall have exclu-sive jurisdiction.

Part F - Information about other tokens



F.1 Crypto-asset type
text Steelcoin X are crypto-assets (other than asset-referenced tokens or e-money tokens) pursuant to Art 4 MiCAR. They also qualify as utility token pursuant to Art 3 para 1 no 9 MiCAR.

F.2 Other token functionality
textBlock Steelcoin X grant the owner exclusively the right to acquire and collect HRC supplied by the Issuer. One HRC requires 20 to 30 Steelcoin X depending on the weight of the HRC. However, only whole HRC can be obtained (thus, no HRC-fragments).
Steelcoin X are based on the ERC-20 protocol and can be transferred on the Blockchain (public blockchain) subject to the limitations outlined in 08 above and to the extent permitted by applicable laws. Thus, only the private key holders can authorize transfers to other addresses. Once transferred, associated rights and obligations are also transferred.

F.3 Planned application of functionalities
textBlock Immediately following the offering of Steelcoin X.

A description of the characteristics of the other token, including the data necessary for classification of the crypto-asset white paper in the register referred to in Article 109 of Regulation (EU) 2023/1114, as specified in accordance with paragraph 8 of that Article



F.4 Type of crypto-asset white paper
enumeration
Other crypto-asset token white paper

F.5 Type of submission
enumeration
Modify

F.6 Other token characteristics
textBlock The Issuer (a member of the FRANKSTAHL Group, which is active in the steel trade) offers Steelcoin X which are designed as utility token pursuant to Art 3 para 1 no 9 MiCAR and thus crypto-assets other than asset-referenced tokens or e-money tokens in accordance with Art 4 MiCAR. Steelcoin X are based on the ERC-20 protocol and can be transferred on the Blockchain (outside the EU and the EEA, however, only if this is permitted by the respective local laws and regulations). The smallest unit of Steelcoin X that can be subscribed from the Issuer is 1 (one) Steelcoin X. Nevertheless, fractions of Steelcoin X can be transferred, with the smallest fraction being 0.000000000000000001 Steelcoin X.
Steelcoin X grant the owner only the right to acquire and collect HRC supplied by the Issuer. One Steelcoin X is required per one metric ton of HRC. However, only a whole HRC can be obtained. Depending on the weight of the HRC, an HRC weighs between 20 to 30 tons. Thus, 20 to 30 Steelcoin X are required to obtain one HRC.
Cash redemption is not possible.
The Issuer is basically free to set the offer price for Steelcoin X. Thus, the offer price of Steelcoin X may fluctuate.
Steelcoin X do not grant the purchaser any shareholder rights, in particular neither participation rights nor voting rights in the shareholders' meetings of the Issuer nor co-determination rights and no rights to profits of the Issuer or to liquidation proceeds. The Issuer is free to use the proceeds from offering Steelcoin X at its own discretion and in particular is not obliged to invest them in steel products or use them for steel trading or in any other specific way.

F.7 Commercial name or trading name
text SC STEELCOIN GmbH

F.8 Website of the issuer
text https://steelcoin.com/

F.9 Starting date of offer to the public or admission to trading
date 2025-06-28

F.10 Publication date
date 2026-10-21

F.11 Any other services provided by the issuer
textBlock Steel trading and the issuance as well as fulfilment of the Issuer's obligations connected to (i) the financial instruments called Steelcoin (ISIN: ATSTEELCOIN5) and Steelcoin ETP (ISIN: DE000A3G9Q60) that were publicly offered under two individual prospectuses under the EU Prospectus Regulation (Regulation (EU) 2017/1129 ) and whose offering does not form part of this white paper (the public offer of the Steelcoin ETP was ended by way of ordinary termination and the issuance of the Steelcoin was discontinued, so that neither is offered to the public any more), or (ii) the Steelcoin X is the primary business purpose of the Issuer.
The Issuer 's strategic objective is to establish a new facet of classic steel trading and for this purpose the Issuer started with the issuance of the Steelcoin in September of 2022, the Steelcoin ETPs in November of 2023 and the Steelcoin X in June 2025.
As a steel trader, the Issuer's operational activities may include the trade in steel products with third parties (other wholesalers, traders, steel mills, large steel consumers). The Issuer has a corresponding trade licence (Trade Information System Austria [Gewerbeinformationssystem Austria – GISA] number 34882627). Through this steel trading, the Issuer will, on the one hand, aim to fulfil the physical settlement obligations of providing steel to Investors and, on the other hand, the Issuer intends to build up and expand its own stock and generate own profit. The Issuer could (without obligation) also hedge against price increases and risks in the future and enter into corresponding transactions. The Issuer can build or acquire its own warehouses in the future and may also acquire and dispose of companies or interests in companies. As an operative entity, the Issuer is not committed to a specific strategy. The Issuer is in particular under no obligation to keep an own stock of steel (or other) products or to apply a specific investment or hedging strategy but is free to use the proceeds of the issue at its own discretion for its own account. Furthermore, the Issuer can also strive – without being obliged to do so – for a physical stockpiling of goods by building up a basic stockpile (which can also be stored with third parties) and subsequently expand it. The stock range (if any) is not limited to HRC but can be wider, as the Issuer operates the steel trading business with the aim to generate own profits.
Steel trading in general is undergoing a transformation into a new digital age. Digital purchasing/sales platforms are constantly being developed. With the issuing of Steelcoin X, additional steel trade turnover should be generated, and a new customer segment is targeted.
The strategic goals also include an expansion of the public offer of Steelcoin X to countries other than those in the EEA subject to the requirements of applicable laws, whereby it is yet not determined, whether such goals can be achieved.

F.12 Language or languages of white paper
text English

F.13 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
text XBL17BS2C

F.14 Functionally fungible group digital token identifier, where available
text X56VB72WS

F.15 Voluntary data flag
boolean false

F.16 Personal data flag
boolean true

F.17 LEI eligibility
boolean true

F.18 Home member state
enumeration
Austria

F.19 Host member states #1
enumerationSet
Belgium

F.19 Host member states #2
enumerationSet
Bulgaria

F.19 Host member states #3
enumerationSet
Croatia

F.19 Host member states #4
enumerationSet
Cyprus

F.19 Host member states #5
enumerationSet
Czechia

F.19 Host member states #6
enumerationSet
Denmark

F.19 Host member states #7
enumerationSet
Estonia

F.19 Host member states #8
enumerationSet
Finland

F.19 Host member states #9
enumerationSet
France

F.19 Host member states #10
enumerationSet
Germany

F.19 Host member states #11
enumerationSet
Greece

F.19 Host member states #12
enumerationSet
Hungary

F.19 Host member states #13
enumerationSet
Iceland

F.19 Host member states #14
enumerationSet
Ireland

F.19 Host member states #15
enumerationSet
Italy

F.19 Host member states #16
enumerationSet
Latvia

F.19 Host member states #17
enumerationSet
Liechtenstein

F.19 Host member states #18
enumerationSet
Lithuania

F.19 Host member states #19
enumerationSet
Luxembourg

F.19 Host member states #20
enumerationSet
Malta

F.19 Host member states #21
enumerationSet
Netherlands

F.19 Host member states #22
enumerationSet
Norway

F.19 Host member states #23
enumerationSet
Poland

F.19 Host member states #24
enumerationSet
Portugal

F.19 Host member states #25
enumerationSet
Romania

F.19 Host member states #26
enumerationSet
Slovakia

F.19 Host member states #27
enumerationSet
Slovenia

F.19 Host member states #28
enumerationSet
Spain

F.19 Host member states #29
enumerationSet
Sweden

Part G - Information on rights and obligations attached to other tokens



G.1 Purchaser rights and obligations
textBlock Steelcoin X grant the purchaser (Investor) only the right to acquire and collect HRC supplied by the Issuer. One Steelcoin X is required per one metric ton of HRC. However, only a whole HRC can be obtained. Depending on the weight of the HRC, an HRC weighs between 20 and 30 tons. Thus, 20 to 30 Steelcoin X are required to obtain one HRC. Cash redemption is not possible. The redemption process must generally be completed by the Issuer within a maximum of 12 months after notification by the Investor and acceptance from the Issuer, subject to HRC availability and market conditions, which may lead to delays or, in exceptional cases, make redemption temporarily or permanently impossible. For details regarding the redemption process see G.8.
The purchaser is obliged to pay the offer price for the acquired Steelcoin X. The Issuer is basically free to set the offer price for Steelcoin X. Thus, the offer price of Steelcoin X may fluctuate. The Issuer is not obliged to accept offers by potential Investors to acquire Steelcoin X. Regarding the issue price see also E.8 above.
When acquiring Steelcoin X the Investor will have to accept the terms and conditions of the Steelcoin X as set out in Annex I of this White Paper.
The issuance of the Steelcoin X as such does not trigger VAT. However, when the Investor redeems Steelcoin X to obtain HRC, VAT is due at the time of the actual handing over of the HRC and needs to be paid in case of redemption prior to the HRC(s) being handed over to the respective Investor based on the applicable assessment basis and tax rate for the calculation of VAT (the latter also depending on the location in which the HRC is collected). Reverse charge procedures will be applied where eligible. Such VAT will have to be settled by the Investor prior to HRC handed over to the Investor. The Investor also will have to bear the costs of transport of the HRC from the place of collection to the place of destination.
The Issuer covers all gas fees during the subscription process, meaning purchasers do not incur Blockchain transaction costs when subscribing Steelcoin X directly from the Issuer. However, during redemption, the redeeming party is responsible for all gas fees related to the Steelcoin X transfer. If a user purchases Steelcoin X from another party, the Issuer has no influence on any costs associated with that transaction.
Holding Steelcoin X does not provide the Investor with rights other than those rights explicitly provided within this White Paper, the Steelcoin X terms and conditions, as well as under MiCAR and applicable laws. In particular, Steelcoin X does not grant the purchaser any shareholder rights, in particular neither participation rights nor voting rights in the shareholders' meetings of the Issuer nor co-determination rights and no rights to profits of the Issuer or to liquidation proceeds. The Issuer is free to use the proceeds from offering Steelcoin X at its own discretion and in particular is not obliged to invest them in steel products or use them for steel trading or in any other a specific way.
Steelcoin X also do not provide the Investor with (co-)ownership rights regarding HRC. The Investor only becomes owner of HRC once the redemption process is completed. The obligations of the Issuer towards the Investors are unsecured and rank pari passu with all other unsecured claims of creditors of the Issuer.

G.2 Exercise of rights and obligations
textBlock To exercise the rights associated with Steelcoin X, Investors must possess and maintain their Steelcoin X tokens in accordance with Steelcoin X's terms and conditions.
As only whole HRC can be obtained (thus, no HRC-fragments), holders of Steelcoin X require 20 to 30 Steelcoin X depending on the weight of the steel HRC, in order to return Steelcoin X for at least one HRC (for details see G.1 above and G.8 below).

G.3 Conditions for modifications of rights and obligations
textBlock The Issuer reserves the right to modify the conditions under which the rights and obligations of Steelcoin X may be modified in its sole discretion to the extent permitted by applicable law and from time to time for the future issue of Steelcoin X. Such modifications will be published as required by applicable law.

G.4 Future public offers
textBlock At this moment the Issuer does not plan further offers to the public of crypto-assets. However, the Issuer reserves the right so make such offers in the future.
The Issuer previously offered financial instruments (Steelcoin and Steelcoin ETP) to the public; those offers have ended (see F.11 above).

G.5 Issuer retained other token
integer 0

G.6 Utility token classification
boolean true

G.7 Key features of goods or services utility tokens
text Steelcoin X allows the holder to exchange the tokens for physical HRC. For one HRC, 20 to 30 token (depending on the weight of the HRC) are required. Regarding the specification of HRC see D.7 above.

G.8 Utility tokens redemption
text Steelcoin X cannot be redeemed for monetary value. They can be used solely for exchange against HRC.
If Steelcoin X holders wish to redeem their tokens for one or more HRC, the holders must contact the Issuer via email (redemption@steelcoin.com) to register their intention to redeem and specify the (full) number of HRC they wish to receive. Upon receiving the request, the Issuer will review the request and inform the holder which HRC matching the requested specifications can be collected at a given location in the EEA within a specific timeframe. The Issuer reserves the right to determine which specific HRC(s) will be offered to the redeemer, provided that such HRC complies with the specifications set out in this White Paper (see D.7 above). Thus, the HRC(s) selected by the Issuer may deviate from the preferences of the redeemer. The redeemer shall have no entitlement to receive a particular HRC or to select from available HRCs or select a specific location to collect the HRC(s). Nevertheless, the Issuer will make reasonable efforts to accommodate the redeemer's stated preferences to the extent possible within the defined specifications.
Additionally, the Issuer will provide the Investor with the exact weight of the HRC(s) to be collected and thus the corresponding number of Steelcoin X, which must be transferred to a designated redemption address on the Blockchain which will be provided by the Issuer. Once the full number of tokens has been received by the Issuer on such redemption address, the HRC(s) will be ready for collection within 12 months after the redemption request is received by the Issuer at the given location in the EEA as determined by the Issuer at the time agreed between the Issuer and the Investor. There is no obligation of the Issuer to deliver or arrange for delivery of the HRC to a place designated by the Investor. In certain circumstances including, but not limited to, events of force majeure, like disruptions at production facilities, armed conflict, or other unforeseen developments, times may be extended (even beyond 12 months) or not be possible at all. In such cases, the Issuer will promptly notify the redeemer of the delay and provide updated information regarding the expected availability of the requested HRC(s).
Investors should note that the Issuer has a business license for the trading business but does not operate own storage facilities. The Issuer might store at its own discretion HRC at specific storage facilities but is not obliged to store as many HRC as could be potentially redeemed against Steelcoin X. As the redemption of Steelcoin X (in a sufficient amount) against collection of HRC also depends on the availability of HRC on the market but also the economic situation of the Issuer, such redemption may ultimately be delayed substantially (even beyond 12 months) or not be possible at all.

G.9 Non-trading request
boolean true

G.10 Other tokens purchase or sale modalities
text An admission to trading is sought. For further details see E.33f.

G.11 Other tokens transfer restrictions
text Steelcoin X are based on the ERC-20 protocol and can be transferred on the "Ethereum" blockchain and on the "Arbitrum One" blockchain, but may only be transferred to persons who are located in Austria or other countries of the EEA, unless a transfer is permitted by the respective applicable laws and regulations (whereby it is the responsibility of the transferor to comply with such laws and regulations).

G.12 Supply adjustment protocols
boolean false

G.13 Supply adjustment mechanisms
text Not applicable.

Other token schemes details



G.14 Token value protection schemes
boolean false

G.15 Token value protection schemes description
textBlock Not applicable.

G.16 Compensation schemes
boolean false

G.17 Compensation schemes description
textBlock Not applicable.

G.18 Applicable law
textBlock Steelcoin X shall be governed by and interpreted in accordance with Austrian law, excluding its choice of law clauses and the UN Sales Convention.

G.19 Competent court
textBlock For all disputes arising out of or in connection with the Steelcoin X or in connection with this White Paper be-tween the Issuer and an Investor, who is not a consumer (according to the Austrian Consumer Protection Act – Konsumentenschutzgesetz), the court competent for commercial matters in Vienna, Inner City shall have exclu-sive jurisdiction.

Part H – Information on underlying technology



H.1 Distributed ledger technology (DTL)
text Steelcoin X is issued as a fungible token on the Blockchain, utilizing ERC-20 standard smart contracts. Ethereum is a widely adopted and secure distributed ledger technology (DLT). All transactions involving Steelcoin X are recorded on the Ethereum public ledger and on Arbitrum One, an Ethereum roll-up. The smart contract governing Steelcoin X includes functions for minting, transferring, and redeeming tokens.

H.2 Protocols and technical standards
text  Steelcoin X are based on the ERC-20 protocol. The bridged representation on Arbitrum One follows the same token standard.

H.3 Technology used
textBlock Please see H.1.

H.4 Consensus mechanism
text Not applicable (ERC-20 based).

H.5 Incentive mechanisms and applicable fees
text There are no incentive mechanisms to secure transactions. There are also no applicable fees charged by the Is-suer for the issuing (other than the issue price) or transfer of Steelcoin X. However, the Issuer reserves the right to introduce such fees in the future for new transactions. In such case, any applicable fees will be disclosed to purchasers and may be adjusted over time.
Regarding gas fees and costs in case of transfer or redemption of Steelcoin X see G.1 and G.8 above.

H.6 Use of distributed ledger technology
boolean false

H.7 DLT functionality description
textBlock Not applicable, as Steelcoin X are issued, transferred, and stored on a decentralized blockchain not operated by the Issuer or a third-party acting on the Issuer's behalf.

Other token audit details



H.8 Audit
boolean false

H.9 Audit outcome
textBlock Not applicable

Part I - Information on risks



I.1 Offer-related risks
textBlock GENERAL
Subject only to the limitations and requirements of MiCAR and applicable mandatory statutes, each purchaser and holder of Steelcoin X as covered by this White Paper acts in their own sole responsibility and on their own sole risk. All liability in regard to the risks mentioned herein is excluded, as far as legally permissible.
Purchasers should evaluate these risks carefully and consider seeking professional advice before participating in the token issuance.
There are the following offer-related risks:

•     Regulatory Risks: The regulatory environment for crypto-assets is changing rapidly and can differ greatly between jurisdictions. Although Steelcoin X are issued and categorized under the MiCAR framework within the EU, there is a possibility that it may be interpreted differently in other regions. Such variations in classification could result in Steelcoin X facing additional or conflicting regulatory obligations, or even being restricted or deemed non-compliant in certain areas outside (or potentially even within) the EU. These inconsistencies could affect the issuance, trading, or utilization of Steelcoin X, potentially restricting its accessibility or functionality in some markets.
•     Limited acquisition channel from the Issuer: Steelcoin X can be subscribed directly from the Issuer only via the Issuer's e-mail address (subscription@steelcoin.com). This restriction on acquisition channels may expose buyers to risks if they do not utilize the official and secure methods.
•     Market Risks: The value of Steelcoin X on markets (if any) as well as the price of HRC that can be obtained in exchange for (a sufficient number of) Steelcoin X will be determined solely by market forces, which means that they may experience significant fluctuations due to market dynamics, speculation, and external influences. Consequently, purchasers of Steelcoin X may risk losing part or all of their investment.
•     Liquidity Risks: Steelcoin X cannot be redeemed against cash but only exchanged against HRC, which requires between 20 to 30 Steelcoin X. Further, Steelcoin X is available for trading (for details see E.33). However, there is no guarantee of adequate market demand or liquidity.
•     No Assurance of Continued Trading Admission: Steelcoin X is admitted to trading and made available as set out in E.33. However, there is no guarantee that such admission and availability will be maintained, or that any further trading admission the Issuer may pursue will be achieved. A withdrawal of an admission, or delays or failures in achieving further admissions, could limit the marketability of the tokens and impact their perceived value (if any).
•     Operational Risks: The issuance depends on the effectiveness and security of the project's platform and related technologies. Technical glitches, cybersecurity threats, or operational failures could disrupt the issuance process or adversely affect the value of the Steelcoin X.

Risks that are specific to the Steelcoin X being admitted to trading

•     Liquidity Risks: Even if Steelcoin X continues to be listed or traded on a trading platform they may not have sufficient market liquidity, making it difficult for holders to sell their Steelcoin X without significantly impacting the market price. Despite the availability of a trading platform, subject to market conditions Investors may not be able to sell Steelcoin X at all or at least not for the desired price and thus may also incur a loss in case of such sale.
•     It is out of the Issuer's control, if Steelcoin X is listed on any (other) trading platforms which are not procured by the Issuer.
•     Loss due to attacks on third party applications: The Steelcoin X is accepted by ZBX and might become accepted by other third party services such as exchanges or decentralized finance (DeFi) protocol, which are out of the control of the Issuer. The use of such services by the Issuer or the Investor could result in partial or total loss of the Investor's Steelcoin X. The same risk arises in respect of further third-party trading platforms.
•     Changes to ZBX's trading platform, which are out of the Issuer's control: ZBX has the full responsibility for its trading platform. Thus, anything related to ZBX's trading platform (including but not limited to transfer and trading modalities; fees and charges for the access to the trading platform as well as for the trading, etc) is out of the Issuer's control. This might result in the following risks: (i) operational risk of ZBX's trading platform: If ZBX experiences technical failures, cyberattacks, or service disruptions, Investors may not be able to trade or access their Steelcoin X; (ii) fee structure changes: ZBX may unilaterally change trading or withdrawal fees, which could impact Investor returns or liquidity; (iii) regulatory risk: If ZBX is affected by regulatory actions (e.g., suspension, investigation, or forced shutdown), Investors may lose access to the trading platform; (iv) counterparty risk: ZBX holds custody of Investor's funds or assets during trading, which introduces the risk of loss of the Investors investment due to mismanagement or insolvency. The same risks (operational risk, unilateral fee changes, regulatory measures and counterparty risk in respect of assets held in custody) apply in respect of further third-party trading or brokerage platforms.
•     Risk of fraud: The Investor may lose the investment in Steelcoin X due to fraud. In particular, the Malta Financial Services Authority has issued on 14 March 2025 a warning about a fraudulent website (zbx-exchanges.com), which is impersonating the legitimate ZBX exchange platform. This clone site is not licensed or regulated, meaning that investors using it are not protected under any financial laws or EU consumer safeguards. Anyone who deposits funds on this fake platform risks losing their entire investment. The clone website may also collect sensitive personal data, such as identification documents and banking information, which could lead to identity theft or misuse.
•     Termination of the listing on ZBX's trading platform: The Issuer may terminate the listing of Steelcoin X on ZBX's trading platform at its own discretion at any time. This might result in the risk that the Steelcoin X cannot be traded on any trading platform, if no other admission to trading to another trading platform takes place. Furthermore, it may be difficult for Investors to sell or exchange their Steelcoin X. The availability of Steelcoin X on further third-party trading or brokerage platforms may likewise end, in particular upon expiry or termination of the respective agreement with the Issuer or by decision of the respective operator or service provider.

I.2 Issuer-related risks
textBlock The Issuer is heavily dependent on FRANKSTAHL: The Issuer was incorporated and commenced operations only in 2022. At the date of this White Paper, it remains heavily dependent on its sole shareholder, FRANKSTAHL:
a) The Issuer lacks the personnel and infrastructure required for ordinary business functions, including purchasing, accounting/bookkeeping, IT and customer support, and relies on FRANKSTAHL for these resources. It could not establish them independently in the short to medium term. b) If FRANKSTAHL ceases to support the Issuer for any reason, including cessation of business or breach of contract, and cannot be replaced on comparable terms, the Issuer may be unable to continue its business or meet its obligations under Steelcoin X. Holders could therefore lose some or all of their investment (risk of partial or total loss). The Issuer also depends on FRANKSTAHL's infrastructure and personnel (see the following risk factor [The Issuer has only few own personnel and might not be able to build up additional own staff, in particular key personnel, and the know-how required for its operations]).
The Issuer has only few own personnel and may be unable to recruit additional staff, particularly key personnel, or develop the know-how required for its operations: The Issuer currently employs only limited personnel and therefore depends on (i) personnel or know-how provided by FRANKSTAHL or (ii) external services or expertise, particularly in steel trading, hedging, IT, cyber security and blockchain technology. It may lack or lose access to essential experts, for example if FRANKSTAHL refuses to provide or loses them, or if suitable third-party expertise or services are unavailable. The Issuer intends to develop its own personnel and know-how in key areas, but may not succeed in attracting and retaining suitably qualified individuals. A shortage of key personnel could impede its operations, materially adversely affect its net assets, financial position and/or results of operations, and impair its ability to fulfil its obligations under Steelcoin X in HRC. Investors could therefore lose some or all of their investment (risk of partial or total loss).
The Issuer may be unable to acquire the HRC required to fulfil its obligations under Steelcoin X or for physical hedging (availability risk), or may be able to do so only on commercially unreasonable terms (price volatility risk): The Issuer is not required to hedge its obligations under Steelcoin X, including the provision of HRC, in any manner. Its long-term ability to perform under the Terms and Conditions nevertheless depends on its ability to acquire HRC and/or hedge its risks and operate its business on commercially reasonable terms. Physical purchases of steel products are one possible hedge against rising prices. Supply shortages may prevent the Issuer from purchasing steel products for hedging or satisfying Investors' claims, or may increase purchase prices to its disadvantage. In particular, the following circumstances may restrict supply or increase prices and thereby adversely affect Investors: i) Concentration among producers of raw steel or steel products, enabling them to control output or sales terms; ii) Non-performance or unenforceability of contracts with direct or intermediary suppliers of steel products, including due to the insolvency of steel mills or suppliers; iii) Shortages of raw materials or other production inputs, including coke, scrap, energy, personnel, iron ore and alloying elements, limiting steel-mill output; iv) Changes in emissions limits or other environmental requirements that restrict steel production; v) Limited logistics capacity or rising logistics costs causing supply disruptions; vi) Rising costs associated with the transition to CO2-neutral steel production; vii) Reduced steel production due to (a) declining private, industrial or public-sector demand; (b) increased use of substitute metals or other existing or future materials; or (c) increased use of alternative construction materials such as wood, concrete or plastic; viii) Difficulties sourcing steel or steel products within the EU due to production being relocated outside the EU.
Any one or more of these factors may adversely affect the Issuer's net assets, financial position and/or results of operations and impair its ability to fulfil its obligations under Steelcoin X in HRC. Investors could therefore lose some or all of their investment (risk of partial or total loss).
The Issuer commenced operations only in 2022: The Issuer was incorporated in April 2022 and commenced operations thereafter, so only limited historical financial information is available. It may be unable to execute its business plan, operate profitably or compete successfully. This may adversely affect its net assets, financial position and results of operations, impair its ability to fulfil its obligations under Steelcoin X in HRC and, in the worst case, lead to insolvency (see [The Issuer could become insolvent]). Investors could therefore lose some or all of their investment (risk of partial or total loss).
Conflicts of interest may arise from personal and/or capital links between the Issuer, its shareholder and its managing directors: See E.38 of this White Paper. Such conflicts may result in transactions detrimental to the Issuer, adversely affect its net assets, financial position and results of operations, and impair its ability to fulfil its obligations under Steelcoin X in HRC.
The Issuer could become insolvent: The occurrence of one or more risks, including risks not currently identified and therefore not described herein, may materially adversely affect the Issuer's net assets, financial position or results of operations and lead to insolvency. In particular, insolvency may occur if revenues are lower or expenses higher than planned and available liquidity is insufficient to meet liabilities relating to issued Steelcoin X and the Issuer's operational, financing or other expenses. Under the Austrian Insolvency Act, insolvency proceedings require illiquidity (Zahlungsunfähigkeit) or over-indebtedness (Überschuldung), while restructuring proceedings may be requested in case of impending illiquidity. Insolvency proceedings generally comprise (i) bankruptcy proceedings (Konkursverfahren), involving liquidation and pro rata distribution of proceeds to creditors, or (ii) reorganisation proceedings (Sanierungsverfahren), aimed at preserving the Issuer as a going concern under a reorganisation plan (Sanierungsplan). In insolvency, Steelcoin X holders have only unsecured, non-priority creditor claims and no rights to segregation or separation. They may therefore lose some or all claims against the Issuer, and their investment may become partially or entirely worthless (risk of partial or total loss).

I.3 Other tokens-related risks
textBlock Investing in or using crypto-assets carries several risks, which can be categorized into various types. Here are some of the key risks associated with crypto-assets:
•     The market price of Steelcoin X (if any) might be volatile: This may result in a loss for the Investors. Tokens created using the ERC-20 standard can experience extreme price volatility, presenting risks for Investors who may face significant financial losses.
•     No cash settlement: Steelcoin X cannot be redeemed for cash.
•     The (fractions of) Steelcoin X held by Investors may not be sufficient to exchange them for HRC, as 20 to 30 Steelcoin X are required for one whole HRC. Any number of Steelcoin X below this number will not enable Investors to exchange them into HRC. As no cash redemption is possible, the Investor thus may not be able to monetize the Steelcoin X held by such Investor.
•     VAT does not accrue for the purchase of Steelcoin X, but once the exchange of Steelcoin X into HRC takes place: The issuance of Steelcoin X as such currently is not subject to VAT. However, in case the Steelcoin X are exchanged for HRC, generally VAT will accrue. Consequently, for Investors that cannot deduct VAT, the actual costs to acquire HRC is increased by the amount of VAT that needs to be paid prior to collecting the HRC based on the assessment basis and VAT rate under applicable laws.
•     The Issuer is free to determine the location from which the steel goods (HRC) may be collected in the EEA. Collecting the HRC and transporting them to the final destination thus may cause substantial costs for the Investor.
•     The Steelcoin X do not grant any shareholder rights. Holders of Steelcoin X cannot influence the management of the Issuer on a personal or substantive basis.
•     An Investor could lose access to its Steelcoin X due to a loss of access to the wallet / the private key (or seed phrase) of the Investor.
•     The loss of the private key (or seed phrase) of the Issuer would lead to the incapacitation of the Issuer and/or loss of control over functions of the smart contract underlying the Steelcoin X.
•     Steelcoin X might be lost to hackers and may not be recoverable for the Investor who consequently could not exchange them for HRC.
•     Governments/authorities could take actions that are to the detriment of the Issuer, the Steelcoin X and/or the Investors.
All these risks could lead to a partial or full loss of the Investors investment in Steelcoin X.
Also see the technology-related risks listed below.
It's crucial for individuals and institutions involved in crypto-assets to thoroughly understand these risks and conduct proper due diligence before investing or engaging in transactions with crypto-assets.

I.4 Project implementation-related risks
textBlock Implementing a project that involves utility tokens can pose several risks. Here are some of the key project implementation-related risks associated with utility tokens:
•     Regulatory Compliance Risks: Uncertainty around regulatory frameworks can lead to legal challenges. Non-compliance with securities and other laws could result in penalties or project shutdown.
•     Market Volatility: Utility tokens can be subject to significant price fluctuations, impacting project funding and sustainability. Market sentiment can change rapidly, affecting token value and user adoption.
•     Token Utility and Adoption Risks: The utility of the token may not be clearly defined, leading to confusion and lack of interest. Low adoption rates can result in insufficient funding and project viability issues.
•     User Trust and Reputation Risks: Negative publicity or security breaches can damage the project's reputation. Lack of transparency can lead to distrust among users and investors.
•     Economic Model Risks: Flaws in the tokenomics (supply, demand, distribution) can lead to unsustainable economic models.
•     Operational Risks: Inefficient operations or logistical issues can impede project timelines and deliverables. Dependencies on third-party services (e.g., exchanges, wallets) can introduce vulnerabilities.
•     Legal and Jurisdictional Risks: Different jurisdictions may have varying laws regarding utility tokens, complicating international operations. Legal challenges from users or Investors can arise if token utility is perceived differently.
•     Exit Scams and Fraud Risks: The potential for malicious actors to engage in fraud or exit scams can deter legitimate investors. Poor due diligence can lead to partnerships with unreliable or unethical entities.
•     Integration and Interoperability Risks: Challenges in integrating the utility token with existing platforms and services can limit functionality. Lack of compatibility with other blockchain networks can restrict user base growth.
All these risks could lead to a partial or full loss of the Investors investment in Steelcoin X.

I.5 Technology-related risks
textBlock Steelcoin X are based on the ERC-20 protocol and can be transferred on the Blockchain (public blockchain). However, there are the following risks associated with the ERC-20 protocol:
•     Smart Contract Vulnerabilities: Bugs or vulnerabilities in the smart contracts can lead to exploits, allowing attackers to steal tokens or manipulate the contract's behaviour.
•     Steelcoin X might be lost due to vulnerabilities of the underlying software application, the underlying smart contract, and the Blockchain infrastructure (the Ethereum Network) and Steelcoin X might be lost due to attacks to the Ethereum Network.
•     Steelcoin X may be lost in connection with a "fork" of the Ethereum network: In the event of a fork in the Ethereum network − whether due to disagreement or even consensus − a split can occur, creating multiple blockchains with identical histories up to the fork (which the Issuer cannot control). This duplicates the Steelcoin X on all resulting blockchains. However, the Issuer cannot and must not accept all Steelcoin X existing after the fork (i.e., the originally issued Steelcoin X and all Steelcoin X duplicated by the fork). Therefore, the Issuer has to choose sooner or later one of the blockchains resulting from the fork. Transactions made on non-selected chains may become invalid, potentially causing investors to lose all or part of their investment. To reduce risk, the Issuer can temporarily pause the smart contract on all chains until a decision is made. During this pause, investors may be unable to execute transactions in Steelcoin X (i.e., transfers to third parties or to the Issuer when initiating the redemption process at the time the Investor considers this to be favourable for him.
•     Token Scams and Frauds: The ease of creating ERC-20 tokens can lead to a proliferation of scams and fraudulent projects, where tokens are issued with no intention of delivering a genuine product or service.
•     Lack of Regulation: Many ERC-20 tokens operate in a regulatory grey area, which can lead to legal risks for both developers and investors, particularly as regulations evolve.
•     Interoperability Issues: While ERC-20 is a standard, not all wallets and exchanges support every ERC-20 token, leading to potential accessibility and liquidity issues.
•     Network Congestion: High transaction volumes on the Ethereum network can lead to increased gas fees and slower transaction times, affecting the usability of ERC-20 tokens.
•     Dependency on Ethereum: The success and functionality of ERC-20 tokens on the Blockchain are to a certain degree tied to the Ethereum network's performance, including potential issues like network upgrades, forks, or scalability challenges.
•     Privacy Concerns: Transactions on the Blockchain are publicly accessible, which can lead to privacy concerns for users and potentially expose sensitive transaction information.
•     Custodial Risks: If users store their tokens on exchanges or custodial wallets, they face risks associated with those platforms, including hacks, insolvency, or operational failures.
•     Risk associated with Layer-2 networks: Steelcoin X is already represented on the Arbitrum One Layer-2 network. Technical or operational issues may occur which are outside the Issuer's control. These may include, but are not limited to: delayed transaction finality, network congestion, compatibility issues with wallets or exchanges, or risks related to the bridging mechanism between Layer-2 and Layer-1. While Layer-2 solutions typically rely on the security of the underlying Layer-1 blockchain, disruptions or vulnerabilities on the Layer-2 level may affect the accessibility or transferability of Steelcoin X. Investors should note in particular that a pause of the Steelcoin X smart contract on Ethereum does not take effect for Steelcoin X held on Arbitrum One; such Steelcoin X may continue to be transferred while transfers on Ethereum are suspended.
All these risks could lead to a partial or full loss of the Investors investment in Steelcoin X.
Investors and developers should conduct thorough due diligence and risk assessments when engaging with ERC-20 tokens and projects.

I.6 Mitigation measures
textBlock Mitigating the risks associated with the technology requires careful planning, robust project management and a thorough legal analysis. Here are several mitigating measures that can be taken to address the risks associated with the technology (ERC-20 protocol) of Steelcoin X:
•     Robust Smart Contract Development: Implement rigorous testing and audits of smart contracts to identify vulnerabilities. As well as using established frameworks and best practices in smart contract development to enhance security.
•     Careful selection of blockchain: Steelcoin X is based on wide-known and well established networks (the Ethereum blockchain based on the ERC-20 protocol and the Arbitrum One roll-up, which settles on Ethereum) to minimize reputational risks and risks of attacks and fraud.
•     Careful selection of partnerships and collaborations: The Issuer collaborates with well-established firms or platforms to enhance credibility and stability as well as in order to engage with industry experts.
However, these measures may not be efficient enough to actually mitigate any of the risks outlined above and the Investors thus cannot rely on such mitigation measures to prevent a full or partial loss.

Part J - Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts



J.1 Adverse impacts on climate and other environment-related adverse impacts
textBlock


Mandatory information on principal adverse impacts on the climate and other environment-related adverse impacts of the consensus mechanism



General information about adverse impacts



S.1 Name
text SC STEELCOIN GmbH

S.2 Relevant legal entity identifier
text 529900OX94239BUDFN51

S.3 Name of the crypto-asset
text Steelcoin X

S.4 Consensus mechanism
text Not applicable (ERC-20 based)

S.5 Incentive mechanisms and applicable fees
text See H.5 above.

S.6 Beginning of period to which disclosed information relates
date 2026-10-21

S.7 End of period to which disclosed information relates
date 2027-10-21

Mandatory key indicator



S.8 Energy consumption
energy (kWh)  1.644

Sources and methodologies



S.9 Energy consumption sources and methodologies
textBlock Trading in Steelcoin X commenced in 2025. The on-chain transaction history since then covers a short period with low and irregular volumes and does not allow a reliable projection for the reference period. The Issuer therefore does not rely on live data.
Instead, for the whole reference period the Issuer uses estimates based on the following assumptions and calculations:
•     The total number of Steelcoin X to be offered is 100,000. We assume that within one calendar year, 300,000 transactions will be attributable to the Steelcoin X.
•     The ERC-20's network's annual energy consumption is approximately 0.0026 terawatt-hours (TWh), which equates to 2.6 million kilowatt-hours (kWh) per year (source: https://ethereum.org/en/energy-consumption/). Steelcoin X bridged to the Arbitrum One network settles on Ethereum, so the energy required for that settlement is already reflected in the Ethereum figure above. The additional energy attributable to the Arbitrum sequencer is de minimis and has therefore not been added separately.
•     The ERC-20 network handles approximately 1.3 million transactions per day, which equates to 474.5 million transactions per year (source: https://etherscan.io/chart/tx).
Based on this, the energy consumption attributable to the Steelcoin X was calculated as follows:
Energy consumption of Steelcoin X in kWh
=
(300,000/474,500,000) * 2,600,000

Supplementary information on principal adverse impacts on climate and other environment-related adverse impacts of consensus mechanism



Supplementary key indicators



S.10 Renewable energy consumption
percent


S.11 Energy intensity
energy (kWh)


S.12 Scope 1 DLT GHG emissions - controlled
GHG emissions (tCO2e)


S.13 Scope 2 DLT GHG emissions - purchased
GHG emissions (tCO2e)


S.14 GHG intensity
GHG emissions (tCO2e)


Sources and methodologies



S.15 Key energy sources and methodologies
textBlock


S.16 Key GHG sources and methodologies
textBlock


Optional information on principal adverse impacts on the climate and on other environment-related adverse impacts of the consensus mechanism



Optional indicators



S. 17 Energy mix
percent


S.18 Energy use reduction



Energy use reduction target (absolute value)
energy (kWh)


Energy use reduction target (percentage)
percent


S.19 Carbon intensity (kgCO2e/kWh)
decimal


S.20 Scope 3 DLT GHG emissions - value chain
GHG emissions (tCO2e)


S.21 GHG emissions reduction targets or commitments
textBlock


S.22 Generation of waste electrical and electronic equipment (WEEE)
mass (tonnes)


S.23 Non-recycled WEEE ratio
percent


S.24 Generation of hazardous waste
mass (tonnes)


S.25 Generation of waste (all types)
mass (tonnes)


S.26 Non-recycled waste ratio (all types)
percent


S.27 Waste intensity (all types)
mass (tonnes)


S.28 Waste reduction targets or commitments (all types)
textBlock


S.29 Impact of use of equipment on natural resources
textBlock


S.30 Natural resources use reduction targets or commitments
textBlock


S.31 Water use
volume (m3)


S.32 Non recycled water ratio
percent


Sources and methodologies



S.33 Other energy sources and methodologies
textBlock


S.34 Other GHG sources and methodologies
textBlock


S.35 Waste sources and methodologies
textBlock


S.36 Natural resources sources and methodologies
textBlock

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