CoW Protocol is an intent-based trading protocol deployed on Ethereum and other supported EVM-compatible chains. Users authorise orders specifying the assets, amounts, price constraints, validity period and other applicable conditions under which they are willing to trade.

Eligible orders are processed through an off-chain competition in which independent solvers compute candidate solutions. Candidate solutions may match compatible user orders directly or source liquidity from on-chain or other available liquidity sources. Eligible solutions are assessed under the applicable competition rules, and the transaction corresponding to the selected solution may then be submitted for on-chain settlement.

If the transaction is included and successfully processed by the relevant blockchain, the GPv2Settlement smart contract validates and processes the authorised fills, transfers and interactions. A settlement cannot validly require a user to accept an economic outcome outside the conditions authorised in that user's order.

CoW Protocol is designed to mitigate certain forms of MEV, including front-running and sandwiching, through mechanisms including batch auctions and solver competition. It does not guarantee execution, price improvement or complete protection from MEV.

Users retain control of their wallets and assets until settlement. No CoW entity takes custody or discretionary control of user assets as part of the ordinary trading process. During a successful settlement, the relevant smart contracts transfer the amounts authorised by users in accordance with the applicable approvals and order constraints.

Labs / DevCo

Foundation

DAO / Onchain Governance

(a) IP ownership & control

Pursuant to CIP-64 and the legal structure established under it, CoW Foundation is the designated owner and manager of intellectual property rights originating from or created for CoW DAO, subject to applicable third-party rights and open-source licences.

This includes CoW-related brands and trade marks and intellectual property created for CoW DAO by entities within the legal structure. Intellectual property created by CoW Core Limited in connection with its CoW-related activities is transferred to CoW Foundation pursuant to the applicable IP assignment arrangements.

A substantial part of the CoW Protocol codebase is publicly available under open-source licences, including Apache, GPL and other licences depending on the relevant repository. Open-source licensing grants rights to users under those licences; it does not by itself mean that the underlying copyright is unowned.

Ownership of intellectual property should be distinguished from technical control over deployed smart contracts. CoW Foundation's ownership of relevant source-code IP does not, by itself, give CoW Foundation the ability to pause, upgrade or otherwise control a deployed smart contract.

(b) Contract/admin powers

CoW governance is conducted through COW token-holder proposals and voting through the cow.eth Snapshot space. Approved decisions are implemented through the relevant Safe, legal entity or technical mechanism where implementation is required.

The principal currently disclosed control surfaces include:

CoW DAO Main Safe. Ethereum address 0xcA771eda0c70aA7d053aB1B25004559B918FE662. The Safe has a 3/5 signing threshold and is used to implement matters falling within its mandate following applicable governance approval [COW token-holder majority via Snapshot; minimum quorum: 35,000,000 COW; execution through CoW DAO Main Safe: 3/5].

GPv2Settlement. The deployed production GPv2Settlement implementation is non-upgradeable and non-pausable. Settlement submission is, however, restricted to callers satisfying the applicable solver-authentication mechanism.

GPv2AllowListAuthentication. Solver authentication is provided through the GPv2AllowListAuthentication component. The authenticator maintains the solver allow-list. Unlike GPv2Settlement, GPv2AllowListAuthentication is deployed through an upgradeable proxy. The manager can add or remove solvers, and the manager can be replaced by the proxy owner or by the manager itself.

• Add/remove solvers**:** Solver Controller / Solver Voucher Safe
• Change Manager: Proxy Owner (CoW DAO Main Safe)

Solver Controller / Solver Voucher Safe. Ethereum address 0x423cEc87f19F0778f549846e0801ee267a917935, threshold 4/15. It administers solver admission and removal under the applicable DAO-approved participation and bonding rules**** [DAO governance mandate: COW token-holder majority via Snapshot; minimum quorum: 35,000,000 COW; operational execution through Solver Controller / Solver Voucher Safe: 4/15]. Operational responsibility is delegated to CoW Core Limited within that mandate.

Solver Payouts Safe. Ethereum address 0xA03be496e67Ec29bC62F01a428683D7F9c204930, threshold 4/11. It is used for solver reward distributions under the governance-approved solver-reward framework, including CIP-20 and applicable successor CIPs, including CIP-85 [COW token-holder majority via Snapshot; minimum quorum: 35,000,000 COW; operational execution through Solver Payouts Safe: 4/11]. Operational responsibility for reward calculation and distribution is delegated to CoW Business Limited within that mandate.

COW token supply. The COW token permits inflation of up to 3% of total supply, subject to the contract mechanics and a minimum interval of 365 days. Any decision to activate inflation is subject to CoW governance and the applicable implementation process.

Neither CoW Foundation nor CoW Core Limited holds unilateral pause or upgrade authority over GPv2Settlement or the COW token contract.

(c) Locked-token rights (conditional)

NA

(d) Current tokenholder governance rights and economic arrangements

COW is a governance token. CoW governance is conducted through the cow.eth Snapshot space, with voting power determined by the applicable governance rules, including COW holdings and eligible vested-but-unclaimed vCOW at the relevant snapshot block.

Subject to the applicable governance process, COW token-holder majority via Snapshot; minimum quorum: 35,000,000 COW, COW token holders may approve or reject CIPs addressing matters including protocol parameters, fee policies, solver participation and bonding rules, solver incentives, treasury actions, grants, partner programmes and other matters within CoW governance.

Governance may also approve mandates concerning the entities established under CIP-64, including appointments or changes to those entities. Where a governance decision requires a formal corporate action, the decision must be implemented through the appropriate corporate mechanism in accordance with the relevant entity's constitutional documents and applicable law. A Snapshot vote does not itself constitute the corporate act of appointing a director, removing a supervisor or dissolving a company.

Current economic arrangements include protocol-level fees determined under applicable governance decisions; solver rewards under CIP-20; grants and security expenditure; partner-related fees and reward programmes; treasury-management activity; and governance-approved COW buybacks.

CoW DAO has authorised COW token buybacks under CIP-36 and CIP-48. CoW Business Limited operationally executes the authorised transactions within its mandate.

Repurchased COW remains available for DAO-directed uses, including future solver-reward initiatives, subject to applicable governance decisions.

There are currently no dividends, equity repurchases or distributions of profit to natural persons or external equityholders arising from CoW DAO governance.

(e) Control surface reliance

The current legal structure allocates defined functions to CoW Foundation, CoW Core Limited, CoW Business Limited and CoW Hosting Limited pursuant to CIP-64 and subsequent governance-approved mandates.

Those allocations are not intended to make any one entity the general operator or controller of CoW Protocol. Where governance determines that a mandate should be changed, transferred or terminated, the relevant governance and corporate steps may be taken to implement that change.

Changes affecting a legal entity remain subject to the entity's constitutional documents, applicable law and any duties owed by its directors or other officeholders.

(f) Dissolution authority

CoW governance may approve a proposal directing that all or part of the legal structure established under CIP-64 be reorganised or wound down [COW token-holder majority via Snapshot; minimum quorum: 35,000,000 COW].

Such a governance vote would constitute the governance authorisation for the proposed action. It would not itself dissolve a Cayman Islands or British Virgin Islands entity. It allows the Director to wind down the Foundation. Any dissolution, director change, supervisor change or other corporate action must also be implemented through the formal procedure required by the relevant entity's constitutional documents and applicable law.

(a) Entity

CoW Foundation is the Primary Foundation. It is a Cayman Islands foundation company.

(b) IP ownership & control

Pursuant to CIP-64, CoW Foundation is the designated owner and manager of intellectual property rights originating from or created for CoW DAO, subject to applicable third-party rights and open-source licences.

This includes the relevant CoW brands and trade marks and IP assigned to CoW Foundation by entities in the legal structure. CoW-related IP created by CoW Core Limited is transferred to CoW Foundation pursuant to the applicable IP assignment arrangements.

Relevant software repositories are made available under their respective open-source licences. The existence of an open-source licence does not itself transfer ownership of the underlying copyright.

IP ownership is separate from administrative control of deployed contracts. CoW Foundation does not acquire a pause, upgrade or transaction-control power over a deployed contract merely because it owns or manages intellectual property associated with the relevant code.

(c) Powers over DAO, treasury, protocol-controlled resources, and token administration

CoW Foundation was established under CIP-64 to perform legal, treasury, administrative and coordination functions for CoW DAO within defined mandates.

It does not originate CoW governance decisions and does not have unilateral authority to amend DAO governance, the COW token supply or GPv2Settlement.

CoW Foundation manages certain DAO financial assets within its treasury-management mandate. Treasury-management functions, including administration of allocated funds, are conducted through the Treasury Committee established under CIP-62, including support from kpk. The CIP-62 treasury mandate was established through a COW token-holder vote on Snapshot, subject to a minimum quorum of 35 million COW tokens voting, and CIP-62 fund allocation has been substantially executed to date.

COW token holders continue to determine material treasury, fee, solver-reward and related governance parameters through the applicable governance process, exercised via a Snapshot vote among COW token holders and subject to that same minimum quorum of 35 million COW tokens voting.

CoW Foundation has no unilateral authority to alter the COW token contract or GPv2Settlement and does not hold a direct administrative key allowing it to pause or upgrade those contracts.

(d) Powers over DevCo

CoW Core Limited is a British Virgin Islands company limited by guarantee. CoW Foundation is its sole member and guarantor and acts as its corporate director.

CoW Foundation therefore has the corporate powers arising from that formal relationship, subject to applicable BVI law and the relevant constitutional documents.

Operationally, CoW Core performs development and technical functions pursuant to DAO governance-approved mandates. CoW Foundation coordinates implementation of mandates across the legal structure and provides funding under applicable approved budgets, but does not thereby acquire every technical or protocol function performed by CoW Core.

(e) Contract/admin powers

CoW Foundation is a Cayman Islands Company Foundation mandated by CoW DAO to act as the DAO's legal interface. It does not have unilateral authority over DAO governance, has no authority over the COW token supply or the settlement contract, and does not hold direct admin keys over the production settlement contract or the COW token contract.

The production settlement contract and the COW token contract remain under DAO multisig authority.

CoW Foundation owns the Operational CoW DAO Safe (CIP-43) - an OPEX dedicated safe - and mandates the Core Team and Foundation Operator to operationalize that safe for the bug bounty program, ETH flow funding, and smart contracts. The Operational CoW DAO Safe has a 2/3 signer setup, with signers representing the Director, the Foundation Operator and the Core Team. Authority for those actions comes from a COW token-holder majority via Snapshot, execution is carried out by the relevant multisig, and proposals require a minimum quorum of 35 million COW tokens voting.

CoW Foundation does not hold any authority or admin power over the DAO's smart contracts, neither does it have any upgrade / freeze / pause power over them. The CoW Foundation is bound to token governance, executing decisions in the real world that are appointed or defined by governance.

The Operational CoW DAO Safe is a mere gas and bounty OPEX safe and is not to be confused with the CoW DAO main safe.

(f) Current economic arrangements and distribution policies

CoW Foundation receives and manages assets for the purposes authorised under its mandate, including treasury assets and amounts transferred to it by related entities under the applicable arrangements. Treasury assets may also generate yield under the Treasury Committee mandate established under CIP-62.

Under CIP-64, the running-cost budget for the four-entity legal structure was estimated at approximately USD 130,000 for the first ten months of operation and approximately USD 180,000 per year thereafter for the entire structure, subject to the applicable budget terms, including the Director's permitted discretion and reallocation between the entities. These amounts relate to the running costs of the legal structure and are not the Service Agreement budget for substantive services.

Separately, CIP-79 approved a USD 12.6 million Service Agreement No. 5 budget for calendar year 2026. CoW Foundation allocates that approved service budget quarterly among CoW Foundation, CoW Core Limited, CoW Hosting Limited and CoW Business Limited in line with their respective workstreams and mandates. Each legal entity then subcontracts the Core Team Service Provider for its respective workstream and compensates the Service Provider monthly in arrears. The CIP-79 service budget is separate from the CIP-64 running-cost budget for the legal structure.

Other governance-approved uses of DAO resources include grants, security audits and bug bounties, solver rewards, partner programmes, treasury-management activity and contributor incentive programmes.

Under CIP-83, CoW DAO approved a 50 million COW replenishment of the CoW Team Grant Allocation through a four-year stream. CIP-83 also established a performance-based incentive tier of up to 100 million COW, subject to the applicable milestone conditions.

CoW DAO has also authorised COW token buybacks under CIP-36 and CIP-48, operationally executed by CoW Business Limited within its mandate.

There are no current distributions of profits, dividends or equity to natural persons or external equityholders through CoW Foundation.

(a) Entity

The Primary DevCo is CoW Core Limited, a British Virgin Islands company limited by guarantee.

CoW Core performs development and technical functions relating to CoW Protocol and associated infrastructure within its governance-approved mandates.

CoW Core has no unilateral or shared governance-executor authority

(b) IP ownership & control

Pursuant to CIP-64, CoW Core Limited does not retain ownership of CoW-related intellectual property created for CoW DAO. CoW Core does not own or control CoW-related IP

Intellectual property developed by CoW Core in connection with its CoW-related activities is transferred to CoW Foundation pursuant to the applicable IP assignment arrangements, subject to third-party rights and open-source licences.

CoW Core may develop, maintain or contribute to software distributed under open-source licences. The applicable licence governs use of that software; CoW Core's technical contribution does not mean that it owns the wider CoW Protocol intellectual-property portfolio.

(c) Powers over DAO, treasury, protocol-controlled resources, and token administration

CoW Core performs development and technical-operational functions within DAO governance-approved mandates. These include work relating to backend infrastructure, the orderbook, Autopilot, the Reference Driver, solver research and development, analytics and solver-participation infrastructure.

CoW Core has delegated operational responsibility for solver admission and removal through the Solver Controller / Solver Voucher arrangement, subject to DAO-approved solver eligibility and bonding rules. Solver approval or removal from listing is executed through the Solver Controller Safe, which carries the same 4/15 signer threshold set out in Q3b.

CoW Core Limited does not hold any governance-executor authority. It cannot alter, control or manage the COW token supply. It has no token administration power. CoW Core cannot pause or upgrade GPv2Settlement, or vary DAO-defined solver eligibility rules outside its mandate.

CoW Core does not have authority over treasury actions or protocol-controlled resources outside the specific operational functions delegated to it under applicable mandates. CoW Core Limited has no signing authority through the CoW DAO Main Safe's 3/5 threshold.

Solver reward calculation and distribution are operationally managed by CoW Business Limited under the governance-approved solver-reward framework, including CIP-20 and applicable successor CIPs, including CIP-85. CoW Core may provide technical systems, data or analytics used in connection with those processes but does not hold the payout mandate

(d) Powers over Foundation

CoW Core Limited exists as a British Virgin Islands Company Limited by Guarantee. CoW Core does not exert decision-making influence over CoW Foundation: CoW Foundation is CoW Core’s sole guarantor and corporate director, CoW Core operates strictly under mandates issued by CoW DAO via the governance mechanism, and CoW Core has no power over the Foundation.

(e) Contract/admin powers

• CoW Core does not hold authority to pause GPv2Settlement
• CoW Core does not hold authority to upgrade GPv2Settlement
• CoW Core does not hold governance-executor authority

(f) Current economic arrangements and distribution policies

CoW Core's corporate running costs form part of the structure-wide running-cost budget established under CIP-64.

Separately, under CIP-79, CoW Foundation allocates part of the USD 12.6 million 2026 Service Agreement No. 5 budget to CoW Core for the workstreams falling within CoW Core's mandate and compensates the Service Provider monthly in arrears. The 2026 allocation to CoW Core workstreams is USD 5.8 million, covering backend and smart contracts, solvers, and DevOps/infrastructure. The USD 5.8 million is a service-provider/workstream budget and should not be characterised as CoW Core's corporate running-cost budget.

CoW Core does not receive protocol-generated resources dynamically as dividends or distributions, and there are no current dividends or distributions to natural persons or external equityholders.

(a) Identity & role

APC #1: CoW Business Limited
Legal name: CoW Business Limited. Entity type: BVI limited liability company organised as a company limited by shares, sole shareholder CoW Foundation, with CoW Foundation as corporate director. Jurisdiction: British Virgin Islands.
Role: commercial relationships including CEX listings, market makers, partner integrations and fee agreements under CIP-61, as amended by CIP-75; operational management of protocol payment safes; solver reward calculation and distribution underthe governance-approved solver-reward framework, including CIP-20 and applicable successor CIPs, including CIP-85; COW token buybacks under CIP-36 and CIP-48; MEV Blocker related payments.

APC #2: CoW Hosting Limited
Legal name: CoW Hosting Limited. Entity type: BVI company limited by guarantee, sole member CoW Foundation, with CoW Foundation as corporate director. Jurisdiction: British Virgin Islands.
Role: UI hosting and maintenance including CoW Swap and CoW Widget, domain ownership, user support and token list management.

APC #3: kpk (formerly karpatkey)
Legal name: Karpatkey Foundation, trading as "kpk" (formerly "karpatkey"). Entity type: Cayman Islands company operating as an onchain asset management firm, spun out of the Gnosis ecosystem and governed by the kpk DAO. Jurisdiction: Cayman Islands.
Role: provides treasury management services to the CoW Treasury Safe (0x616dE58c011F8736fa20c7Ae5352F7f6FB9F0669) to generate yield on idle treasury funds, in coordination with the Treasury Committee under CIP-62 and under CoW Foundation's treasury management mandate. Maintains the public CoW DAO treasury dashboard at app.syncrone.fi/public/cow and publishes monthly treasury reports on forum.cow.fi.

APC #4: Leeward Management Limited
Legal name: Leeward Management Limited. Entity type: Cayman Islands corporate services firm providing independent directorship and fiduciary services. Jurisdiction: Cayman Islands.
Role: provides the natural-person Director for CoW Foundation, serves as Secretary of the Foundation handling secretarial work and AML for funds received, and was mandated by the Mooderator CIP (CIP-64) to incorporate the four legal entities on behalf of CoW DAO.

APC #5: Leeward Supervisors Limited
Legal name: Leeward Supervisors Limited. Entity type: Cayman Islands professional services firm acting as independent supervisor. Jurisdiction: Cayman Islands.
Role: acts as Supervisor of CoW Foundation, providing independent oversight of Director activities and compliance with the Articles of Association, with authority to remove the Director for gross negligence, to initiate investigations independently, and an obligation to respond to concerns raised by interested parties.

APC #6: Wintermute
Legal name: Wintermute. Contracting entities in the Wintermute group are Wintermute Trading Ltd, incorporated in England and Wales, and Wintermute Asia Pte Ltd, incorporated in Singapore. Entity type: private limited company. Jurisdiction: England and Wales / Singapore.
Role: market maker for COW, engaged under the market maker mandate held by CoW Business Limited, with a 0.75% of supply commitment under a one-year loan and option structure.

APC #7: Keyrock
Legal name: Keyrock SA. Entity type: Belgian société anonyme. Jurisdiction: Belgium.
Role: market maker for COW, engaged under the market maker mandate held by CoW Business Limited, with a 0.25% of supply commitment under a one-year loan and option structure.

(b) Parameter control & scope

For the disclosed non-issuer service-provider APCs, no major protocol-parameter control is held, and no veto, majority, or super-majority method of protocol-parameter authority applies.

• kpk**(**Karpatkey) provides treasury management services to the CoW Treasury safe to generate yield on idle treasury funds, in coordination with the Treasury Committee and under the Foundation’s treasury management mandate. Karpatkey does not control protocol parameters; its scope is limited to treasury yield strategies within the Treasury Committee’s CIP-mandated authority. It is a co-signer on the CoW Treasury safe, but it is only one part of the treasury committee and does not unilaterally control strategy or allocations.
• Leeward Management Limited provides the natural-person Director for CoW Foundation, serves as Secretary, handles secretarial work and AML for funds received, and was mandated to incorporate the four legal entities on behalf of CoW DAO. It has no protocol-parameter control and no on-chain admin authority. Its authority is limited to corporate secretarial, AML, and director duties, with director-level authority over CoW Foundation subject to Supervisor oversight and removability by CoW DAO governance.
• Leeward Supervisors Limited acts as Supervisor of CoW Foundation and provides independent oversight of director activities and compliance with the Articles of Association, including authority to remove the director for gross negligence and initiate investigations independently. It has no protocol-parameter control and no on-chain authority; its authority is off-chain supervisory authority over the Foundation’s director.

(c) Contract/admin powers

CoW Business Limited. Holds no pause or upgrade authority over the GPv2Settlement contract or the COW token contract, and no unilateral authority over DAO governance or token administration. CoW Business applies parameters set by CIP and controls no protocol parameters itself; it cannot vary on-chain fee parameters. Ultimate authority over funds in all safes below rests with CoW DAO. Delegated authority (CIP-64: majority):

• Solver Payouts safe, 0xA03be496e67Ec29bC62F01a428683D7F9c204930, Ethereum. Threshold 4/11. This is the safe referred to as the Payout Safe and is also the recipient of fees collected from the settlement contract. Permitted actions: calculation and execution of solver reward payouts under the governance-approved solver-reward framework, including CIP-20 and applicable successor CIPs, including CIP-85. Limitations: the reward formula is fixed by the applicable governance-approved reward framework, leaving no discretion over amounts beyond applying the formula; cannot redirect funds outside the approved payout scope. Method of authority: the applicable solver-reward CIPs (majority).
• COW token buybacks. Executed through market transactions on the open market via TWAP orders. Permitted actions: weekly revenue-funded repurchase of COW. Limitations: mandate covers the entirety of solver rewards emitted in the week, capped at 120% of solver rewards; cannot mint; repurchased tokens are held at the DAO's disposal and any reuse for future solver reward initiatives requires governance approval. Method of authority: CIP-36 (majority) and CIP-48 (majority).
• Partner fee agreements and partner-related payments. Permitted actions: negotiation and signing of fee agreements with partners on behalf of CoW DAO, and payment of amounts due. Limitations: bound by the fee framework, ranges and caps set in CIP-61 as amended by CIP-75; cannot exceed the approved maximum partner share or vary the on-chain fee parameters, which are set by CIP. Method of authority: CIP-61 and CIP-75 (majority).
• Market maker relationships. Permitted actions: negotiation and administration of market-making agreements, including the loan and option structures with Wintermute and Keyrock. Limitations: supply commitments are limited to those approved by CIP, currently 0.75% and 0.25% of supply for one-year terms; CoW Business cannot commit additional supply without a further CIP. Method of authority: CIP mandate CIP-64: majority.
• MEV Blocker related payments. Permitted actions: settlement of amounts arising from the MEV Blocker arrangement. Limitations: within the mandate and budget approved by CIP. Method of authority: CIP-64 (majority).

CoW Hosting Limited. None. Holds no pause, upgrade, parameter-setting or governance-executor authority over the GPv2Settlement contract, the COW token contract or any other CoW Protocol contract, and is not a signer on any safe holding protocol funds or COW. Its control surface is off-chain only: ownership and DNS administration of the protocol's domains, hosting and deployment of the CoW Swap and CoW Widget frontends, and curation of the token list. Those functions can restrict or alter access to the hosted interfaces but cannot alter on-chain protocol behaviour, order settlement or user funds. Method of authority: mandate from CoW Foundation as sole member and corporate director, amendable or revocable by CIP; Director appointment and removal by COW token holder majority via Snapshot.

kpk. Holds no pause, upgrade, parameter-setting or governance-executor authority over any CoW Protocol contract.

• CoW Treasury Safe, 0x616dE58c011F8736fa20c7Ae5352F7f6FB9F0669, Ethereum. Threshold 3/5. kpk is one co-signer alongside CoW DAO signers. Permitted actions: execution of treasury yield strategies and POL management within the Treasury Committee's mandate. Limitations: signing authority only; cannot act without two further signers; scope is constrained by a role-based permissions policy restricting permitted destinations and interactions; no authority over the COW token contract or the settlement contract; is one part of the Treasury Committee and does not unilaterally control strategy or allocations. The investment policy statement is public and regularly updated. Method of authority: CIP-62.

Leeward Management Limited. None. Holds no pause, upgrade, parameter-setting or governance-executor authority over any CoW Protocol contract, and is not a signer on any safe holding protocol funds or COW. Its authority is off-chain and corporate: Director and Secretary duties for CoW Foundation under the Foundation's incorporation documents, exercisable subject to oversight by the Supervisor. Method of authority: appointment by COW token holder majority via Snapshot; removal by the same majority, and removal for gross negligence by the Supervisor.

Leeward Supervisors Limited. None. Holds no pause, upgrade, parameter-setting or governance-executor authority over any CoW Protocol contract, and is not a signer on any safe. Its authority is off-chain supervisory authority over the Foundation's Director, comprising oversight of Director activities and compliance with the Articles of Association, removal of the Director for gross negligence, and initiation of independent investigations. Method of authority: appointment and removal by CoW DAO governance via Snapshot.

Wintermute and Keyrock. None. Neither holds pause, upgrade, parameter-setting or governance-executor authority over any CoW Protocol contract, and neither is a signer on any safe holding protocol funds. Each relationship is contractual only, governed by a market-making agreement administered by CoW Business Limited. Method of authority: contract, within the supply commitment approved by CIP.

(d) Compensation and material economic arrangements

CoW Business Limited. CoW Business's corporate running costs form part of the structure-wide running-cost budget under CIP-64.

Separately, under CIP-79, USD 3.0 million of the 2026 Service Agreement No. 5 budget is allocated to CoW Business workstreams. Revenue collected by CoW Business, including partner fees and protocol service fees is included in treasury management. No dividends or distributions to natural persons are in operation.

No compensation-linked dynamic routing of protocol resources to CoW Business exists: it handles protocol revenue operationally but retains none of it as compensation.

CoW Hosting Limited. CoW Hosting's corporate running costs form part of the structure-wide running-cost budget under CIP-64.

Separately, under CIP-79, USD 1.5 million of the 2026 Service Agreement No. 5 budget is allocated to CoW Hosting workstreams.

No dividends or distributions to natural persons are in operation. No protocol-generated resources or resource-linked economics are dynamically routed to CoW Hosting Limited.

kpk. Compensation is a hybrid fee comprising a fixed services component and a performance component calculated as a percentage of returns above a hurdle rate set separately per asset type. The fee sits within, and below, the ceiling previously approved by CIP for treasury management services; the specific commercial terms are contained in the services agreement and are not published.
Source of payment: CoW DAO treasury assets held in the CoW Treasury Safe under the Core Treasury Mandate. Routing mechanism: payment by discrete transaction from the CoW Treasury Safe (0x616dE58c011F8736fa20c7Ae5352F7f6FB9F0669), each requiring the 3/5 signing threshold. There is no automated, contract-level or standing payment authority. Payment frequency: periodic, settled by transaction from that safe and reflected in the monthly treasury reports published on forum.cow.fi. Duration: for the term of the treasury management mandate under CIP-62, continuing until amended or revoked by CIP.
No protocol-generated resources or resource-linked economics are dynamically routed to kpk. Protocol fee revenue does not flow to kpk, and its compensation is not a share of protocol fees, solver rewards or partner fees. The performance component is calculated on treasury investment returns, not on protocol revenue. This remains the only disclosed APC arrangement with a performance-linked economic component.

Leeward Management Limited. Fee-for-service, paid in fiat from the operational budget allocated by CoW DAO under CIP-58 and the auto-renewing annual operational budget. A one-time setup cost of approximately $50,000, plus or minus 10%, was borne by the service provider under CIP-58. No token-based compensation. No protocol-generated resources or resource-linked economics are dynamically routed to Leeward Management Limited.

Leeward Supervisors Limited. Fee-for-service, paid in fiat from the operational budget. No token-based compensation. No protocol-generated resources or resource-linked economics are dynamically routed to Leeward Supervisors Limited.

Wintermute. Committed 0.75% of total supply under a one-year loan and option structure administered by CoW Business Limited. The commitment is a loan of COW with an associated option, not a grant or fee. No cash fee funded from protocol resources is disclosed, and no protocol-generated resources or resource-linked economics are dynamically routed to Wintermute.

Keyrock. Committed 0.25% of total supply under a one-year loan and option structure administered by CoW Business Limited, on the same basis. No protocol-generated resources or resource-linked economics are dynamically routed to Keyrock.

Separately, CoW DAO operates a paid affiliate program under CIP-84 under which referrers and providers of volume receive a share of fees generated by the DAO. This filing does not identify company participants in that affiliate program as APCs.

(a) Post-TGE employee lock as % of total supply

Post-TGE token compensation plans exist.

As of 18 August 2026, tokens locked attributable to post-TGE contributors equal 5.0% of total supply (50,000,000 COW of 1,000,000,000). This is the CoW Team Grant Allocation replenishment approved under CIP-83. The four-year stream began in February 2026, so no individual grant funded from it has completed vesting and less than 0.1% of total supply has vested to date.

Of that 5.0%: the portion already streamed into the Team Grant Allocation is held either as unvested individual grants or pending attribution by the CoW Team Grant Allocation Committee, and the remainder is still in the DAO treasury and not yet streamed. Tokens remain under DAO control until streamed, and unvested amounts can be cancelled by governance at any time.

Excluded from the 5.0%: the Performance-Based Incentive Tier. Milestone 1 was met on February 2026 revenue and 25,000,000 COW (2.5% of supply) was transferred in May 2026. Those tokens are not subject to vesting and are therefore not counted as locked. The remaining three milestone tranches (up to 7.5% of supply) are unearned, remain in the treasury, and expire if not reached within four years of CIP-83's execution.

Also excluded: the original team allocation approved at TGE (15% of supply). Its four-year grants completed vesting by February 2026, and the unallocated residual of roughly 2.5% of supply is pool capacity rather than locked grants

(b) Typical post-TGE vesting schedule

Standard post-TGE grant schedule for individual grants attributed from the CoW Team Grant Allocation:

• Total duration: four years
• Cliff: no cliff
• Vesting frequency: continuous streaming
• Start: the grant start date set by the CoW Team Grant Allocation Committee at attribution
• Mechanism: on-chain vesting positions created through the allocation module attached to the relevant CoW DAO Safe

This is a separate schedule from how CoW DAO funds the allocation. Under CIP-83, the 50M COW replenishment is delivered from the DAO treasury into the CoW Team Grant Allocation as a four-year linear stream with no cliff. The "no cliff" applies to that treasury-to-allocation stream, not to individual grants.

Performance-Based Incentive Tier tranches follow neither schedule. They are funded by one-off transfers into the same Safe when a revenue milestone is met and are not subject to vesting.

(a) Existence

Token allocation commitments are disclosed for market maker relationships managed by CoW Business Limited: Wintermute has a 0.75% of supply commitment under a 1-year loan-and-option structure, and Keyrock has a 0.25% of supply commitment under a 1-year loan-and-option structure. No ongoing token-based advisory billings or commitments exist beyond the initial 0.6% CoW Advisory allocation distributed at TGE on a four-year linear vest to strategic advisors.

(b) Total token allocation

No current token-based advisory compensation exists. Beyond the initial 0.6% CoW Advisory allocation distributed at TGE on a four-year linear vest to strategic advisors, there are no ongoing token-based advisory billings or commitments. Leeward Management Limited and Lemma Solutions are compensated in fiat from the operational budget, not in COW tokens, and CoW DAO does not engage KOLs or influencers under token-based compensation arrangements.

(c) Payer entity

No current token-based advisory compensation exists. Beyond the initial 0.6% CoW Advisory allocation distributed at TGE on a four-year linear vest to strategic advisors, there are no ongoing token-based advisory billings or commitments. External service providers Leeward Management Limited and Lemma Solutions are compensated in fiat from the operational budget, not in COW tokens, and CoW DAO does not engage KOLs or influencers under arrangements involving token-based compensation. Accordingly, there is no payer entity for any existing token-based advisor.

(d) Description of advisory/services

No current token-based advisory compensation exists. Beyond the initial 0.6% CoW Advisory allocation distributed at TGE on a 4-year linear vest to strategic advisors, there are no ongoing token-based advisory billings or commitments; Leeward Management Limited and Lemma Solutions are compensated in fiat from the operational budget, not in COW tokens.

(a) Existence & scope

KOLs and influencers do not receive COW tokens for payment. CoW DAO does not engage KOLs or influencers under arrangements involving token-based compensation, and any creator partnerships do not include COW token payments.

(b) Usernames & roles

No KOL/influencer engagements receiving token-based compensation exist; accordingly, there are no usernames, handles, platforms, or related KOL activities to disclose.

(c) Token allocation & vesting/locks

No KOL/influencer engagements involving token-based compensation exist. Accordingly, there is no aggregate token allocation across such arrangements and no vesting, lock, or release terms to disclose.

(a) Token repurchases or secondary-market accumulations (if any)

CoW DAO operates a COW token buyback program authorized under CIP-36 and CIP-48. Buybacks are executed by CoW Business Limited through market transactions and are based on weekly revenue-funded open-market TWAPs. The Core Team has a DAO mandate to buy back the entirety of solver rewards emitted in the week and may buy up to 120% of solver rewards. Tokens bought back are held at the DAO’s disposal for funding future solver rewards initiatives, creating a self-funded flywheel under governance approval. COW token holders control changes to the strategy through the CIP process, including authority over treasury actions, fee routing, solver reward parameters, protocol parameters, treasury actions, fee policies, solver bonding rules, partner agreements, and grants. No burn or permanent-removal treatment is disclosed; the disclosed treatment is treasury/DAO retention for potential reuse in future solver rewards initiatives.

(b) Protocol-owned liquidity (POL) (if any)

CoW DAO holds protocol-owned liquidity (POL) in COW pairs. All POL pools are owned by the CoW Treasury address 0x616dE58c011F8736fa20c7Ae5352F7f6FB9F0669.

Deployment chains and venues. POL is deployed across Ethereum Mainnet, Gnosis Chain, Base, Arbitrum and BSC, following a February 2026 consolidation in which liquidity was migrated out of legacy positions, ranges were tightened and allocations were rebalanced across those five chains. Current deployment venues are Uniswap and PancakeSwap. CoW DAO

Aggregate size. As of the 1 August 2026 00:00 UTC period-end snapshot, POL positions total $560,631, comprising $450,585 on Uniswap and $110,046 on PancakeSwap. That is 2.9% of the $19.12M actively managed treasury. A residual Balancer safe and the CoW TWAP Safe are tracked on the treasury dashboard but sit outside the Core Treasury Mandate and are excluded from that figure. Figures are published monthly in the CoW DAO treasury reports on forum.cow.fi and on the treasury dashboard at app.syncrone.fi/public/cow. CoW DAOCoW DAO

Unwind and exit policy. There is no fixed unwind schedule or pre-committed exit date. Adjusting, rebalancing, migrating or exiting any POL position is a Treasury Committee decision under the mandate approved in CIP-62, executed by transaction from the CoW Treasury Safe, which has a 3/5 signing threshold. kpk provides treasury management services under the Foundation's treasury management mandate and in coordination with the Treasury Committee, is a co-signer on that Safe, and does not unilaterally control strategy or allocations. Amending or revoking the mandate itself requires a CIP. Position-level composition can be reviewed at https://dune.com/kpk/cow-token-analysis.

(c) Liquidity deals / purchased TVL (if any)

No TVL-oriented liquidity deal or purchased TVL arrangement exists.

(d) Token-secured loans/lines (incl. against unissued tokens) (if any)

No token-secured loans or lines exist at the DAO level, including against unissued COW. Principal, gross position size, collateral, counterparties, and unwind/exit policy are not applicable.

(a) Entity existence

Foundation exists: CoW Foundation exists as a Cayman Islands Company Foundation. Lab/DevCo exists: CoW Core Limited exists and conducts development. DAO exists: CoW DAO exists as an unincorporated, governance arrangement governed by COW token holders via Snapshot at cow.eth.

(b) Material sources of funding or economic inflows

CoW DAO exists as an unincorporated governance arrangement governed by COW token holders via Snapshot at cow.eth. CoW governance directs specified DAO-controlled resources and approves mandates concerning treasury assets, protocol-related fees and other resources within its governance scope. Those assets and flows are held, received or administered through the relevant Safes, contracts or legal entities. This should not be read as stating that CoW DAO legally owns every asset or economic flow generated anywhere in the broader CoW ecosystem. DAO-level economic sources include the 44.4% initial CoW DAO Treasury allocation for long-term governance, ecosystem growth, grants, partnerships, solver rewards, and retained protocol resources; historical token-sale funding consisting of a February 2022 private sale covering 10% of total supply (100,000,000 COW) and a February 2022 CoWmunity Investment that sold 10% of total supply, for total prior token sales of 20% of total supply; protocol fees collected at the settlement contract level, including price-improvement fees, volume-based fees, reduced fees on correlated pairs, and service fees from solvers and partners; and yield generated by Karpatkey on idle treasury funds in the CoW Treasury safe

CoW Foundation exists as a Cayman Islands Company Foundation. Its economic inflows include profit generated from its related entities, including revenue from CoW Business Limited partner fee agreements and commercial integrations that flows back to CoW Foundation as profit, and treasury yield on assets under management. Under CIP-64, the four-entity legal structure has a separate running-cost budget estimated at USD 130,000 for the first ten months and USD 180,000 per year thereafter for the entire structure, subject to the applicable Director discretion and reallocation mechanisms. Separately, under CIP-79, CoW Foundation administers the USD 12.6 million 2026 Service Agreement No. 5 budget, allocates it quarterly among the four legal entities in line with their workstreams and mandates.

CoW Core Limited, functioning as the Lab/DevCo entity, exists as a BVI Company Limited by Guarantee. CoW Core's corporate running costs form part of the structure-wide CIP-64 budget. Separately, under CIP-79, USD 5.8 million of the 2026 Service Agreement No. 5 budget is allocated to workstreams contracted through CoW Core. CoW Core may also receive service fees for analytics or solver-related services where applicable.

CoW Hosting Limited exists as a BVI Company Limited by Guarantee. Its corporate running costs form part of the structure-wide CIP-64 budget. Separately, under CIP-79, USD 1.5 million of the 2026 Service Agreement No. 5 budget is allocated to workstreams contracted through CoW Hosting.

CoW Business Limited exists as a BVI Limited Liability Company / company limited by shares. Its corporate running costs form part of the structure-wide CIP-64 budget. Separately, under CIP-79, USD 3.0 million of the 2026 Service Agreement No. 5 budget is allocated to workstreams contracted through CoW Business. CoW Business also generates revenue from partner fee agreements under CIP-61, as amended by CIP-75, and commercial integrations; that revenue flows back to CoW Foundation as profit.

(c) Operational use of resources

CoW DAO exists as an unincorporated, governance arrangement governed by COW token holders via Snapshot at cow.eth; DAO funds support solver rewards, the CoW Grants program, security audits, partner reward programs, and retained treasury for long-term operations, with solver rewards being the largest recurring outflow.

Foundation funds support ecosystem promotion, treasury management, grants administration, legal protection of the protocol and contributors through the Defense Reserve, tooling and coordination across entities, and community management.

CoW Core funds support solver operations management, backend infrastructure including the orderbook, autopilot, and Reference Driver, solver R&D, and analytics.

CoW Hosting funds support UI hosting and maintenance, including CoW Swap and CoW Widget, domain ownership, user support, and token list management.

CoW Business funds support solver reward calculation and distribution operations, COW buyback execution, partner relationship management, CEX listings, market maker relationships, and fee-agreement negotiation.

(d) Onchain Resource Usage

CoW DAO exists as an unincorporated, governance arrangement governed by COW token holders via Snapshot at cow.eth. The main DAO-facing resources for on-chain resource usage are: https://dune.com/cowprotocol, which shows protocol volume, settlement counts, fees collected, and solver performance; https://forum.cow.fi, which contains all CIPs, financial reports, and treasury reports; https://snapshot.org/#/cow.eth, which shows historical votes and proposals; and https://docs.cow.fi/governance/multisigs, which lists the operational multisigs. These resources explain protocol fees collected at the settlement contract level and DAO-funded uses including solver rewards, the CoW Grants program, security audits, partner reward programs, and retained treasury for long-term operations.

CoW Foundation exists as a Cayman Islands Company Foundation. Foundation-related treasury activity can be reviewed through https://forum.cow.fi for financial and treasury reports, https://app.syncrone.fi/public/cow for Karpatkey’s CoW DAO treasury dashboard, and https://dune.com/kpk/cow-token-analysis for CoW Treasury Committee POL positions. Karpatkey generates yield on idle treasury funds in the CoW Treasury safe, and POL pools are owned by the CoW Treasury address 0x616dE58c011F8736fa20c7Ae5352F7f6FB9F0669. Foundation funds support ecosystem promotion, treasury management, grants administration, legal protection of the protocol and contributors through the CIP-50 Defense Reserve, tooling and coordination across entities, and community management.

The Lab/DevCo and operational entities disclosed are CoW Core Limited, CoW Hosting Limited, and CoW Business Limited. The entities' corporate running costs form part of the structure-wide CIP-64 running-cost budget. Separately, under CIP-79, CoW Foundation allocates the 2026 Service Agreement No. 5 budget among the legal entities. Their operational activity is explained through the shared public resources above, especially https://forum.cow.fi for CIPs, financial reports, and treasury reports, https://docs.cow.fi/governance/multisigs for operational multisigs, and https://dune.com/cowprotocol for protocol volume, fees, and solver performance. For 2026, the CIP-79 workstream allocations are USD 5.8 million to CoW Core, USD 1.5 million to CoW Hosting, USD 3.0 million to CoW Business and USD 2.3 million to Foundation workstreams. These workstream allocations and are separate from the legal structure's CIP-64 corporate running-cost budget.

(a) Date & component affected

No prior incidents directly affecting the COW token, token supply, tokenholder balances, the COW token contract, minting controls, burn mechanics, or custody of token supply have occurred as of 2026-09-04.

(b) Exploit vector summary

Not applicable. No prior incidents affecting the native COW token have occurred as of 2026-09-04, so there is no exploit vector to summarise. No incident has involved unauthorised minting, unauthorised burning, alteration of tokenholder balances, compromise of the COW token contract, or compromise of custody of token supply

(c) Quantified impact

Not applicable. No prior incidents affecting the native COW token have occurred as of 2026-09-04. There has been no loss of COW tokens, no loss of tokenholder balances, and no unauthorised change to total supply. Quantified impact is zero tokens and zero dollars in respect of the native token.

(d) Remediation/response taken

Not applicable. No prior incidents affecting the native COW token have occurred as of 2026-09-04, so no remediation or response in respect of the native token has been required or undertaken.

(e) Current status

Not applicable. No prior incidents affecting the native COW token have occurred as of 2026-09-04, so there is no incident status to report. No incident affecting the COW token, its supply, its contract, or tokenholder balances is open, under investigation, or unresolved.

(f) References

Not applicable. No prior incidents affecting the native COW token have occurred as of 2026-09-04, so no post-mortems, advisories, or pull requests relating to a native-token incident exist.