White Paper Report


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

	Digital Token Identifier:	LDQ7G0HM4
	Operator of the trading platform:	54930069NLWEIGLHXU42 - OKX Europe Limited
	Type of submission:	New

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	2026-04-28
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 operator of the trading platform 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 GRASS token is a utility token issued on the Solana blockchain using the Solana Program Library (SPL) token standard. It has a maximum and total supply of 1,000,000,000 tokens. The GRASS token functions as a medium of exchange and participation within the Grass Network ecosystem, facilitating access to decentralized bandwidth-sharing services and future protocol governance. Holders can delegate their tokens to routers and validators within the network to participate in securing operations and earning protocol-reward distributions.
09 Further information about utility tokens	textBlock	The GRASS token grants users access to the decentralized bandwidth-sharing infrastructure provided by the Grass Network. Participants may utilize GRASS to pay for web-scraping transactions and dataset purchases (once live), or they may stake and delegate GRASS to network routers to earn protocol rewards. The utility acquired depends on the active capabilities of the network and is subject to the network's terms of service. There is no fixed quantity of services guaranteed per token, as resource costs are determined dynamically by network demand. The GRASS token is freely and instantly transferable, utilising the underlying blockchain network's standard processes.
10 Key information about the offer to the public or admission to trading	textBlock	This whitepaper is published solely in connection with the admission to trading of the GRASS token on OKX Europe Limited's trading platform. There has been no offer of the crypto-asset to the public, and the crypto-asset has not been made available in exchange for fiat currency or other crypto-assets prior to its listing. The crypto-asset will be admitted to trading via OKX Europe Limited, an authorised crypto-asset service provider ("CASP") operating within the European Union. The trading admission does not involve any subscription, sale, or fundraising process. The purpose of this document is to provide key information regarding the characteristics of the crypto-asset, its governance, rights, and associated risks, to enable informed decision-making by users and market participants in the context of its admission to trading. Access to the crypto-asset on the trading platform may be subject to user verification, platform conditions, or applicable legal restrictions depending on the jurisdiction.
Part A - Information about offeror or person seeking admission to trading
A.1 Name	N/A		.
A.2 Legal form	N/A		.
A.3 Registered address
Registered addess	N/A		.
Country	N/A		.
Sub-division	N/A		.
A.4 Head office
Head office	N/A		.
Country	N/A		.
Sub-division	N/A		.
A.5 Registration date	N/A		.
A.6 Legal entity identifier	N/A		.
A.7 Another identifier required pursuant to applicable national law	N/A		.
A.8 Contact telephone number	N/A		.
A.9 E-mail address	N/A		.
A.10 Response time (days)	N/A		.
A.11 Parent company	N/A		.
A.12 Members of the management body
Member #1	N/A		.
Identity	N/A		.
Business address	N/A		.
Function	N/A		.
A.13 Business activity	N/A		.
A.14 Parent company business activity	N/A		.
A.15 Newly established	N/A		.
A.16 Financial condition for the past three years	N/A		.
A.17 Financial condition since registration	N/A		.
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	true
B.2 Name	text	Grass OpCo Ltd.
B.3 Legal form	text	Company limited
B.4 Registered address
Registered addess	text	Floor 4, Banco Popular Building, Road Town, Tortola VG1110, British Virgin Islands
Country	enumeration	Virgin Islands (British)
Sub-division	text	N/A
B.5 Head office
Head office	text	Floor 4, Banco Popular Building, Road Town, Tortola VG1110, British Virgin Islands
Country	enumeration	Virgin Islands (British)
Sub-division	text	N/A
B.6 Registration date	date	2024-03-07
B.7 Legal entity identifier	LEI
B.8 Another identifier required pursuant to applicable national law	text	2143555
B.9 Parent company	text	Grass Foundation
B.10 Members of the management body
Member #1	id	1
Identity	text	No information could be identified in regards to this field at the time of drafting this whitepaper.
Business address	text	No information could be identified in regards to this field at the time of drafting this whitepaper.
Function	text	No information could be identified in regards to this field at the time of drafting this whitepaper.
B.11 Business activity	textBlock	Grass OpCo Ltd. acts as the operational subsidiary overseeing the administration of the Grass websites and network services. This includes managing the legal and operational framework for the network's bandwidth-sharing software, as well as administering the airdrop and staking programs for network participants in accordance with its published terms.
B.12 Parent company business activity	textBlock	The Grass Foundation is a Cayman Islands foundation company responsible for treasury management, ecosystem growth incentives, and the planned governance framework for the Grass Network.
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	text	OKX Europe Limited
C.2 Legal form	text	Limited Liability Company
C.3 Registered address
Registered address	text	Piazzetta Business Plaza, Office Number 4, Floor 2, Triq Ghar il-Lembi, Sliema SLM1562, Malta
Country	enumeration	Malta
Sub-division	text	N/A
C.4 Head office
Head office	text	See C.4
Country	enumeration	Malta
Sub-division	text	N/A
C.5 Registration date	date	2018-09-07
C.6 Legal entity identifier	LEI	54930069NLWEIGLHXU42
C.7 Another identifier required pursuant to applicable national law	text	C 88193
C.8 Parent company	text	OKC International Holding Company Limited
C.9 Reason for crypto-asset white paper preparation	textBlock	This crypto-asset whitepaper has been prepared in accordance with Regulation (EU) 2023/1114 (MiCA) for the purpose of: - The admission to trading of GRASS on regulated platforms, starting with the OKX Exchange. OKX Europe Limited as a result of being a licenced CASP endeavours to fulfill the obligations established under MiCA and the respective MFSA guidelines to: - Notify this whitepaper to the MFSA; - Publish the whitepaper publicly; - And ensure its registration in the MiCA register maintained by the European Securities and Markets Authority (ESMA). This whitepaper has been prepared to provide transparent, accurate, and fair information to prospective token holders and regulatory authorities in line with the principles of MiCA.
C.10 Members of the management body
Member #1	id	1
Identity	text	Erald Henri J. Ghoos
Business address	text	See C.4
Function	text	Director
Member #2	id	2
Identity	text	Fang Hong
Business address	text	See C.4
Function	text	Director
Member #3	id	3
Identity	text	Joseph Portelli
Business address	text	See C.4
Function	text	Director
Member #4	id	4
Identity	text	Wei Man Cheung
Business address	text	See C.4
Function	text	Director
C.11 Operator business activity	textBlock	OKX Europe Limited is licensed as a Crypto-Asset Service Provider by the Malta Financial Services Authority, bearing licence number OEUR-24352, to provide crypto services under the Markets in Crypto-Assets Act, Chapter 647, Laws of Malta and is the operator of a Trading Platform for Crypto Assets, in accordance with Article 3(1)(18) of Regulation (EU) 2023/1114 (MiCA).
C.12 Parent company business activity	textBlock	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	text	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	text	N/A
Member #2	id	2
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		.
Member #3	id	3
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		.
Member #4	id	4
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	Grass
D.2 Crypto-asset name	text	See F.13
D.3 Abbreviation	text	See F.13
D.4 Crypto-asset project description	textBlock	Grass is a DePIN (Decentralised Physical Infrastructure Network) project operating in the AI data infrastructure sector. The project provides software applications; including a browser extension and desktop client, through which users contribute unused residential internet capacity to a pooled network resource. This resource is made available to vetted institutional clients, principally AI research organisations and data purchasers, to facilitate access to publicly available web data. User participation generates rewards eligibility tracked via the project's internal Grass Points system. GRASS tokens have been distributed to eligible participants through the project's airdrop programme and may be used within the project's staking programme, under the published staking terms administered by Grass OpCo Ltd. and the Grass Foundation.
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	Andrej Radonjic
Business address of person	text	United States of America
Domicile of company	enumeration
Person #2	id	2
Type of person	enumeration	Development team
Name of person	text	Chris Nguyen
Business address of person	text	Canada
Domicile of company	enumeration
Person #3	id	3
Type of person	enumeration	Other person involved in implementation
Name of person	text	Grass OpCo Ltd
Business address of person	text
Domicile of company	enumeration	Virgin Islands (British)
Person #4	id	4
Type of person	enumeration	Other person involved in implementation
Name of person	text	Grass Foundation
Business address of person	text
Domicile of company	enumeration	Cayman Islands
D.6 Utility token classification	boolean	true
D.7 Key features of goods or services for utility token projects	text	The Grass network operates a software-based platform through which users share surplus residential internet bandwidth with institutional clients seeking public web data and AI training datasets. Participation requires installation of the Grass application. Reward eligibility is accrued via the Grass Points programme, with GRASS token distributions determined at the discretion of the Grass Foundation. The staking component of the programme allows GRASS holders to delegate tokens to routers listed as Available Routers under the Foundation's published staking terms, in return for staking reward distributions in GRASS. On-chain governance is referenced in the project's tokenomics documentation as an aspirational future feature; it has not been formally implemented or specified as at the date of this whitepaper.
D.8 Plans for the token
Description of past milestones	textBlock	The project was founded in 2022 by Andrej Radonjic (CEO), Chris Nguyen (CTO), and Jordan Iman Abdollahi-Soufian (COO) under the name Wynd Labs. A pre-seed funding round of approximately $1.0 million was led by No Limit Holdings. A seed round of $3.5 million was announced in Q4 2023. The public beta of the Grass desktop client launched in Q1 2024, with initial institutional data-purchasing partnerships established during that period. In September 2024, the project closed a Series A funding round; the amount raised was not publicly disclosed. On 28 October 2024, the project executed "Airdrop One," distributing 100,000,000 GRASS tokens to over 2,000,000 eligible Grass users, with the token contract deployed on Solana. A token staking programme enabling GRASS holders to delegate to approved network routers became operational in Q2 2025.
Description of future milestones	textBlock	As at the date of this whitepaper, the project has not published a formal public roadmap. The Grass Foundation's tokenomics documentation references aspirational future features including further GRASS token distributions and on-chain governance enabling token holder participation in protocol decisions. The specific parameters, timelines, and eligibility criteria for these features have not been publicly established.
D.9 Resource allocation	text	The GRASS token has a fixed maximum supply of 1,000,000,000 tokens, allocated specifically as follows: 30% allocated to the Community (including 10% distributed in Airdrop One, 17% for future incentives, and 3% for router rewards). 25.2% allocated to Early Investors, generally subject to a one-year cliff followed by multi-year vesting. 22.8% allocated to Foundation & Ecosystem Growth reserves. 22% allocated to Core Contributors, also subject to a one-year cliff followed by multi-year vesting.
D.10 Planned use of collected funds or other tokens	text	The Grass Foundation retains a significant treasury of GRASS tokens (22.8% allocated for Foundation & Ecosystem Growth). These collected crypto-assets are earmarked to finance ongoing protocol research and development, conduct security audits, maintain and scale network infrastructure, and issue community grants. Off-chain collected fiat funds raised during seed and Series A funding rounds are utilized for corporate operations, core team expansion, legal compliance, and initial network bootstrapping.
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	Facilitating secondary trading for users on the OKX Trading platform in compliance with the MiCA regulatory framework.
E.3 Fundraising target
Target expressed in currency	monetary	0	EUR
Target expressed in units	decimal	0
Target expressed in digital token identifier	text	N/A
E.4 Minimum subscription goals
Goals expressed in currency	monetary	0	EUR
Goals expressed in units	decimal	0
Goals expressed in digital token identifier	text	N/A
E.5 Maximum subscription goals
Goasl expressed in currency	monetary	0	EUR
Goals expressed in units	decimal	0
Goals expressed in digital token identifier	text	N/A
E.6 Oversubscription acceptance	boolean	false
E.7 Oversubscription allocation	text
Issue price details
E.8 Issue price	decimal
E.9 Official currency determining issue price	enumeration
E.9 Any other tokens determining issue price	text
E.10 Subscription fee
Fee expressed in currency	monetary	0	EUR
Fee expressed in units	decimal	0
Fee expressed in digital token identifier	text	N/A
E.11 Offer price determination method	text	N/A
E.12 Total number of offered or traded other tokens	integer	1000000000
E.13 Targeted holders	enumeration	All types of investors
E.14 Holder restrictions	text	N/A
E.15 Reimbursement notice	boolean true	N/A
E.16 Refund mechanism	textBlock	N/A
E.17 Refund timeline	text	N/A
E.18 Offer phases	textBlock	N/A
E.19 Early purchase discount	textBlock	N/A
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	N/A
E.24 Payment methods for other token purchase	textBlock	In line with OKX current payment method offering.
E.25 Value transfer methods for reimbursement	textBlock	N/A
E.26 Right of withdrawal	textBlock	N/A
E.27 Transfer of purchased other tokens	textBlock	In line with OKX current Terms of Service.
E.28 Transfer time schedule	text	N/A
E.29 Purchaser's technical requirements	textBlock	In line with OKX current Terms of Service.
Other token services provider characteristics
E.30 Other token service provider (CASP) name	text	OKX Europe Limited
E.31 CASP identifier	LEI	54930069NLWEIGLHXU42
E.32 Placement form	enumeration	Not applicable
Trading platforms characteristics
E.33 Trading platforms name	text	OKX
E.34 Trading platforms market identifier code (MIC)	text	N/A
E.35 Trading platforms access	text	Users may access GRASS through the OKX Trading Platform via the Application Program Interface ("API"), the Application Software ("OKX App"), as well as the official OKX website as follows; www.okx.com.
E.36 Involved costs	textBlock	In line with the OKX current Terms of Service.
E.37 Offer expenses	textBlock	N/A
E.38 Conflicts of interest	textBlock	A crypto-asset is listed following a decision rendered independently by the Listing Committee in line with the internal policies of OKX Europe Limited. Any potential disclosures that may arise of conflicts of interest are published on the OKX website.
E.39 Applicable law	textBlock	Malta
E.40 Competent court	textBlock	Malta
Part F - Information about other tokens
F.1 Crypto-asset type	text	Other Crypto-Asset.
F.2 Other token functionality	textBlock	The GRASS token functions as a medium of exchange and coordination within the Grass Network. It is designed to be delegated or staked to network Routers and Validators to earn protocol-reward emissions. Additionally, according to the project's roadmap, GRASS will be accepted as payment for web-scraping transactions and dataset purchases. The token is also planned to be utilized in an on-chain governance system, where holders will be able to submit and vote on proposals guiding protocol upgrades and treasury grants.
F.3 Planned application of functionalities	textBlock	Token transfers and staking programs (delegation to approved routers) apply as of the writing of this whitepaper. Future functionalities, such as on-chain governance voting and direct payment for dataset purchases, are planned but not yet fully activated.
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	New
F.6 Other token characteristics	textBlock	The GRASS token is a fungible utility token issued natively on the Solana blockchain under the SPL standard. It has a fixed maximum and total supply of 1,000,000,000 tokens. The token is freely transferable across the Solana network and does not inherently confer ownership or profit rights in the issuing corporate entity. The circulating supply is subject to change depending on vesting schedules, unlocks, and ecosystem incentive distributions.
F.7 Commercial name or trading name	text	See F.13
F.8 Website of the issuer	text	https://www.grass.io/
F.9 Starting date of offer to the public or admission to trading	date	2026-05-27
F.10 Publication date	date	2026-05-27
F.11 Any other services provided by the issuer	textBlock	N/A
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	LDQ7G0HM4
F.14 Functionally fungible group digital token identifier, where available	text	MNCR2MKHP
F.15 Voluntary data flag	boolean	false
F.16 Personal data flag	boolean	true
F.17 LEI eligibility	boolean	false
F.18 Home member state	enumeration	Malta
F.19 Host member states #1	enumerationSet	Austria
F.19 Host member states #2	enumerationSet	Belgium
F.19 Host member states #3	enumerationSet	Bulgaria
F.19 Host member states #4	enumerationSet	Croatia
F.19 Host member states #5	enumerationSet	Cyprus
F.19 Host member states #6	enumerationSet	Czechia
F.19 Host member states #7	enumerationSet	Denmark
F.19 Host member states #8	enumerationSet	Estonia
F.19 Host member states #9	enumerationSet	Finland
F.19 Host member states #10	enumerationSet	France
F.19 Host member states #11	enumerationSet	Germany
F.19 Host member states #12	enumerationSet	Greece
F.19 Host member states #13	enumerationSet	Hungary
F.19 Host member states #14	enumerationSet	Iceland
F.19 Host member states #15	enumerationSet	Ireland
F.19 Host member states #16	enumerationSet	Italy
F.19 Host member states #17	enumerationSet	Latvia
F.19 Host member states #18	enumerationSet	Liechtenstein
F.19 Host member states #19	enumerationSet	Lithuania
F.19 Host member states #20	enumerationSet	Luxembourg
F.19 Host member states #21	enumerationSet	Malta
F.19 Host member states #22	enumerationSet	Netherlands
F.19 Host member states #23	enumerationSet	Norway
F.19 Host member states #24	enumerationSet	Poland
F.19 Host member states #25	enumerationSet	Portugal
F.19 Host member states #26	enumerationSet	Romania
F.19 Host member states #27	enumerationSet	Slovakia
F.19 Host member states #28	enumerationSet	Slovenia
F.19 Host member states #29	enumerationSet	Spain
F.19 Host member states #30	enumerationSet	Sweden
Part G - Information on rights and obligations attached to other tokens
G.1 Purchaser rights and obligations	textBlock	There are no obligations attached for or of the purchaser. GRASS token holders do have certain rights; they may delegate or stake their tokens to network Routers and Validators to receive protocol reward emissions. Holders may also have the future right to participate in on-chain governance, allowing them to submit proposals and vote on protocol parameters, as well as the right to use the token to access network services (such as dataset purchases). Ownership of the token does not grant any claim to profits, dividends, or assets of the issuer.
G.2 Exercise of rights and obligations	textBlock	Since the GRASS token does not grant obligations, there is no conceivable way to exercise such obligations. Purchasers can exercise the rights afforded to them via a compatible Solana wallet. To earn staking rewards, holders send an on-chain transaction delegating their GRASS to an approved Router or Validator. If on-chain governance is activated, holders may exercise their voting rights by locking or delegating GRASS in the relevant governance contract. All actions are confirmed by the Solana network and are subject to standard network fees.
G.3 Conditions for modifications of rights and obligations	textBlock	As the token does not grant obligations, there are no conditions under which the obligations may be modified. Any rights associated with purchasing GRASS tokens may be modified through future protocol upgrades, changes to the staking terms administered by Grass OpCo Ltd., or via community voting if the planned on-chain governance system goes live.
G.4 Future public offers	textBlock	N/A
G.5 Issuer retained other token	integer	228000000
G.6 Utility token classification	boolean	true
G.7 Key features of goods or services utility tokens	text	The GRASS token grants users access to the decentralized Grass Network ecosystem. Key features include the ability to delegate tokens to network routers to secure data pipelines and earn protocol reward emissions, and the planned ability to use the token as a payment mechanism for purchasing institutional web-scraping datasets and large-compute requests.
G.8 Utility tokens redemption	text	GRASS tokens are functionally redeemed by staking or delegating them within the network's ecosystem to activate reward accruals.
G.9 Non-trading request	boolean	true
G.10 Other tokens purchase or sale modalities	text	N/A
G.11 Other tokens transfer restrictions	text	In line with OKX current Terms of Service.
G.12 Supply adjustment protocols	boolean	false
G.13 Supply adjustment mechanisms	text	N/A
Other token schemes details
G.14 Token value protection schemes	boolean	false
G.15 Token value protection schemes description	textBlock	N/A
G.16 Compensation schemes	boolean	false
G.17 Compensation schemes description	textBlock	N/A
G.18 Applicable law	textBlock	Malta
G.19 Competent court	textBlock	Malta
Part H – Information on underlying technology
H.1 Distributed ledger technology (DTL)	text	See F.13
H.2 Protocols and technical standards	text	The GRASS token is implemented using the Solana Program Library (SPL) token standard on the Solana blockchain. SPL is the authorised standard for fungible and non-fungible tokens on Solana, similar in function to Ethereum's ERC-20 standard. SPL tokens are managed via smart contracts (programs) and utilize Solana's high-throughput, low-latency infrastructure for token transfers and programmatic interactions. Solana's runtime environment uses Rust-based smart contracts and supports token metadata, mint authorities, and secure wallet integration through the Solana Token Program.
H.3 Technology used	textBlock	The GRASS token is deployed on the Solana blockchain using the SPL token standard. Solana is a high-performance Layer 1 protocol built in Rust and uses a hybrid Proof-of-History (PoH) and Proof-of-Stake (PoS) consensus mechanism. GRASS's smart contract interactions are handled via the Solana Token Program. Network activity is coordinated through Solana smart contracts, and user wallets interact with the token via Solana-compatible clients.
H.4 Consensus mechanism	text	The Solana blockchain uses a hybrid consensus mechanism combining PoH with PoS. PoH provides a verifiable, cryptographic time source that sequences transactions before they are validated by a decentralized network of validators using PoS. Validators are selected based on staked SOL tokens and take turns producing blocks, which are finalized rapidly with high throughput and low latency. This mechanism allows Solana to achieve sub-second block times and high scalability while maintaining decentralization and network security.
H.5 Incentive mechanisms and applicable fees	text	On the Solana blockchain, validators are incentivized through a PoS system where they earn rewards in the native token SOL for validating transactions and producing blocks. These rewards are distributed proportionally based on the amount of SOL staked. Transaction fees are also paid in SOL, and a portion of these fees is burned, with the rest distributed to validators.
H.6 Use of distributed ledger technology	boolean	false
H.7 DLT functionality description	textBlock	N/A
Other token audit details
H.8 Audit	boolean	false
H.9 Audit outcome	textBlock	N/A
Part I - Information on risks
I.1 Offer-related risks	textBlock	This whitepaper is submitted by OKX Europe Limited solely for the purpose of the assets admission to trading. No public offer of GRASS tokens is being made by the issuer or OKX Europe Limited. Risks associated with the admission to trading include; Service-related interruption; Holders may be unable to access the utility due to technical, operation, or regulatory disruptions. Jurisdictional limitations; GRASS services or token utility may not be available in all jurisdictions, potentially restricting access. Platform reliance; Access depends on third-party infrastructure (wallets,platforms) and service interruptions or failures may affect token utility. Limited liability; OKX Europe Limited assumes no responsibility for the issuers project continuation, and token ownership does not confer contractual rights or guarantees. Unexpected Risks: Beyond the risks outlined in this whitepaper, there may be additional risks that are currently unforeseen. It is imperative to note that certain risks may emerge from unforeseen events, changes, or interactions among factors that are difficult to predict. These unexpected risks may significantly and negatively impact the crypto-asset, the project, or the parties involved.
I.2 Issuer-related risks	textBlock	Operational Risks; There is a risk that the issuer may face financial or operational difficulties, including insolvency, which could impact the continued development or availability of the services associated with the GRASS token. Counterparty Risks; Counterparty risks may arise where the issuer relies on third-party service providers or technology partners. Reputational Risks; Adverse media and/or damage or loss of key personnel could negatively affect the ecosystem that the GRASS token lives on. Competition Risk; The issuer may face increased competition or changes in market conditions that affect its ability to carry out its objectives. Regulatory Risks; The issuer may be subject to investigations, enforcement actions, or change in regulation that affect the tokens legal status in certain jurisdictions. Disclosure Risks; The issuer may not be required to provide financial statements, limiting GRASS token holders visibility into the financial health status of the issuer/project. Issuer Risks; The information provided is based solely on publicly available sources and does not constitute any form of guarantee or warranty as to its accuracy or completeness.
I.3 Other tokens-related risks	textBlock	Market Volatility; The GRASS token may be subject to significant volatility and could lose value rapidly, either due to market conditions or otherwise (issuer-related/technology/project implementation risks) Utility Risk; The GRASS tokens utility depends on access to certain services, and any modification or discontinuation of those services could reduce the associated utility of the token. Smart Contract Risk; The GRASS token may operate through smart contracts that may contain vulnerabilities, even if audited, and upgrades to the protocol or governance changes may affect functionality. Liquidity Risk; Periods of low/limited liquidity may occur, particularly if the demand for the token or its use case decreases, which could have adverse effects on the GRASS tokens price and future use cases.
I.4 Project implementation-related risks	textBlock	Scalability Issues; There is a risk that the project may not be implemented or scaled as intended. Technical limitations or infrastructure bottlenecks could hinder the expected scalability of the project, especially if user demand exceeds network or protocol capacity. Governance Risk; The project may be subject to governance processes that involve on-chain voting or community proposals. Misaligned incentives, low participation, or malicious actors may affect the outcome of governance decisions and disrupt the project's roadmap. Centralisation Risk; Similar to governance risks outlined above, centralisation within the governance process, or validator centralisation could lead to a lack of decentralization within the network, which carries future risks in terms of trust within the project, and also in regards to future roadmaps where plans may not reflect the interests of the broader user base.
I.5 Technology-related risks	textBlock	Blockchain Performance Risk; The Solana blockchain, on which the token is issued, may experience downtime or congestion, which could delay or prevent token transfer or utility usage. Consensus Failure Risk; A failure in the blockchains consensus mechanism could result in halted transactions, unexpected behavior, or loss in network integrity. Smart Contract Vulnerabilities; Although the token uses audited or standard smart contract makeups (SPL Token Program), undetected bugs, exploits, or implementation errors could compromise functionality or security. Upgradeability Risk; if the token or related contracts are upgradeable and have designated "owner" addresses, this introduces a central point of failure, and could be misused by malicious actors. Third-party Infrastructure Dependency; Interaction with the token or project may rely on external infrastructure (APIs, wallet services, off-chain governance voting). Outages or attacks may interrupt access to token-related services. Interoperability Risk; If the token interacts with other chains, bridges, or oracles, failures or exploits in those systems could affect the tokens operations. Protocol-level Risk; Upgrades or forks of the protocol itself may affect the token, which could lead to compatibility issues and/or unexpected token behaviour. Emerging Technology Risk; Advances in computing or undiscovered vulnerabilities in cryptographic algorithms may pose long-term security risks to the blockchain or associated smart contracts
I.6 Mitigation measures	textBlock	Blockchain Performance Risk; The Solana blockchains design prioritises throughput and speed by combining Proof-of-History with Proof-of-Stake. The validator set is geographically diverse, and further performance improvements are ongoing. Consensus Failure Risk; Solanas consensus mechanism is supported by stake-weighted voting and finality checkpoints. Validators face slashing if they act in a malicious manner. Updates on Solana uptime can be found here; https://status.solana.com/ Smart Contract Vulnerabilities; Smart contracts on Solana are immutable by design, unless explicitly designed to be upgradeable. The ecosystem encourages open source code, independent audits, and community input. Upgradeability Risk; Solana does not enforce upgrade functionalities within smart contracts, but supports their technical implementation. Risks related to upgradeable contracts can be mitigated through standard practices such as multi-sig wallets. Third-party Infrastructure Dependency; Solana supports multiple independent RPC providers within its ecosystem, enabling infrastructure diversification. Interoperability Risk; Mitigations for cross-chain bridging include usage of audited bridges and token locking mechanisms. Protocol-level Risk; Solana maintains a public roadmap and follows a structured governance process. Core updates to the network undergo extensive testing and community reviews. Emerging Technology Risk; Solana developers monitor potential emerging technology threats, and are actively researching and developing quantum-resistant solutions. Solana has implemented a quantum-resistant feature through the optional Solana Winternitz Vault as of January 2025.
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	OKX Europe Limited
S.2 Relevant legal entity identifier	text	54930069NLWEIGLHXU42
S.3 Name of the crypto-asset	text	Grass
S.4 Consensus mechanism	text	Solana uses a unique combination of Proof of History (PoH) and Proof of Stake (PoS) to achieve high throughput, low latency, and robust security. Core Concepts: 1. Proof of History (PoH): - Time-Stamped Transactions: PoH is a cryptographic technique that timestamps transactions, creating a historical record that proves that an event has occurred at a specific moment in time. - Verifiable Delay Function: PoH uses a Verifiable Delay Function (VDF) to generate a unique hash that includes the transaction and the time it was processed. This sequence of hashes provides a verifiable order of events, enabling the network to efficiently agree on the sequence of transactions. 2. Proof of Stake (PoS): - Validator Selection: Validators are chosen to produce new blocks based on the number of SOL tokens they have staked. The more tokens staked, the higher the chance of being selected to validate transactions and produce new blocks. - Delegation: Token holders can delegate their SOL tokens to validators, earning rewards proportional to their stake while enhancing the network's security. Consensus Process: 1. Transaction Validation: Transactions are broadcast to the network and collected by validators. Each transaction is validated to ensure it meets the network's criteria, such as having correct signatures and sufficient funds. 2. PoH Sequence Generation: A validator generates a sequence of hashes using PoH, each containing a timestamp and the previous hash. This process creates a historical record of transactions, establishing a cryptographic clock for the network. 3. Block Production: The network uses PoS to select a leader validator based on their stake. The leader is responsible for bundling the validated transactions into a block. The leader validator uses the PoH sequence to order transactions within the block, ensuring that all transactions are processed in the correct order. 29 of 32 4. Consensus and Finalization: Other validators verify the block produced by the leader validator. They check the correctness of the PoH sequence and validate the transactions within the block. Once the block is verified, it is added to the blockchain. Validators sign off on the block, and it is considered finalized. Security and Economic Incentives: 1. Incentives for Validators: - Block Rewards: Validators earn rewards for producing and validating blocks. These rewards are distributed in SOL tokens and are proportional to the validator's stake and performance. - Transaction Fees: Validators also earn transaction fees from the transactions included in the blocks they produce. These fees provide an additional incentive for validators to process transactions efficiently. 2. Security: - Staking: Validators must stake SOL tokens to participate in the consensus process. This staking acts as collateral, incentivizing validators to act honestly. If a validator behaves maliciously or fails to perform, they risk losing their staked tokens. - Delegated Staking: Token holders can delegate their SOL tokens to validators, enhancing network security and decentralization. Delegators share in the rewards and are incentivized to choose reliable validators. 3. Economic Penalties: Slashing: Validators can be penalized for malicious behavior, such as double-signing or producing invalid blocks. This penalty, known as slashing, results in the loss of a portion of the staked tokens, discouraging dishonest actions.
S.5 Incentive mechanisms and applicable fees	text	Solana uses a combination of Proof of History (PoH) and Proof of Stake (PoS) to secure its network and validate transactions. Incentive Mechanisms: 1. Validators: - Staking Rewards: Validators are chosen based on the number of SOL tokens they have staked. They earn rewards for producing and validating blocks, which are distributed in SOL. The more tokens staked, the higher the chances of being selected to validate transactions and produce new blocks. - Transaction Fees: Validators earn a portion of the transaction fees paid by users for the transactions they include in the blocks. This provides an additional financial incentive for validators to process transactions efficiently and maintain the network's integrity. 2. Delegators: 30 of 32 - Delegated Staking: Token holders who do not wish to run a validator node can delegate their SOL tokens to a validator. In return, delegators share in the rewards earned by the validators. This encourages widespread participation in securing the network and ensures decentralization. 3. Economic Security: - Slashing: Validators can be penalized for malicious behavior, such as producing invalid blocks or being frequently offline. This penalty, known as slashing, involves the loss of a portion of their staked tokens. Slashing deters dishonest actions and ensures that validators act in the best interest of the network. - Opportunity Cost: By staking SOL tokens, validators and delegators lock up their tokens, which could otherwise be used or sold. This opportunity cost incentivizes participants to act honestly to earn rewards and avoid penalties. Fees Applicable on the Solana Blockchain Transaction Fees: 1. Low and Predictable Fees: Solana is designed to handle a high throughput of transactions, which helps keep fees low and predictable. The average transaction fee on Solana is significantly lower compared to other blockchains like Ethereum. 2. Fee Structure: Fees are paid in SOL and are used to compensate validators for the resources they expend to process transactions. This includes computational power and network bandwidth. 3. Rent Fees: State Storage: Solana charges rent fees for storing data on the blockchain. These fees are designed to discourage inefficient use of state storage and encourage developers to clean up unused state. Rent fees help maintain the efficiency and performance of the network. 4. Smart Contract Fees: Execution Costs: Similar to transaction fees, fees for deploying and interacting with smart contracts on Solana are based on the computational resources required. This ensures that users are charged proportionally for the resources they consume.
S.6 Beginning of period to which disclosed information relates	date	2025-04-28
S.7 End of period to which disclosed information relates	date	2026-04-28
Mandatory key indicator
S.8 Energy consumption	energy (kWh)	323.16242
Sources and methodologies
S.9 Energy consumption sources and methodologies	textBlock	The energy consumption of this asset is aggregated across multiple components: To determine the energy consumption of a token, the energy consumption of the network(s) solana is calculated first. For the energy consumption of the token, a fraction of the energy consumption of the network is attributed to the token, which is determined based on the activity of the crypto-asset within the network. When calculating the energy consumption, the Functionally Fungible Group Digital Token Identifier (FFG DTI) is used - if available - to determine all implementations of the asset in scope. The mappings are updated regularly, based on data of the Digital Token Identifier Foundation. The information regarding the hardware used and the number of participants in the network is based on assumptions that are verified with best effort using empirical data. In general, participants are assumed to be largely economically rational. As a precautionary principle, we make assumptions on the conservative side when in doubt, i.e. making higher estimates for the adverse impacts.
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