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Turtle

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Turtle Disclosures

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Issuer-filed·B2 v2.2·Filed 23 Oct 2026Partial - 2 gaps

Contents

  1. Project & Team
  2. 01Description of Project
  3. 02Known Project Team
  4. 03DAO Structure
  5. 04Primary Foundation
  6. 05Primary DevCo
  7. 06Affiliated Protocol Contributor
  8. Token Supply & Allocation
  9. 07Initial Allocation
  10. 08Vesting Insider Tokens
  11. 09Disclosure of Token Advisory Billings
  12. 10KOL Marketing Activities
  13. 11Labelled Unissued & Operational Token Wallets
  14. Transactions & Market Structures
  15. 12Market Maker Agreements & Deals
  16. 13Exchange Agreements & Deals
  17. 14Liquidity Deals and Market Activity
  18. Resource Disclosures
  19. 15Prior Token Sales & Fundraising
  20. 16Operational Funding, Economic Flows, and Resource Provisioning
  21. 17Previous Exploits Affecting The Native Token
  22. 18[Optional] Offchain Foundation Or DevCo Income Statement
  23. Token Addresses and Deployments
  24. 19[Optional] Token Addresses and Deployments

Project & Team

01Description of Project

Question

Provide a narrative description of the purpose of the project.

Response

Turtle is capital coordination infrastructure for internet capital markets. The protocol connects asset issuers to a verified network of onchain liquidity providers and handles the full path between them: deal sourcing, due diligence, incentive distribution, billing, and liquidity provider relationship management, with capital flows attributable and verifiable onchain.

02Known Project Team

Question

For each existing entity: Labs/DevCo (e.g., Founder, CEO, CTO, COO), Foundation (e.g., President, Executive Director, CFO, COO), and DAO / onchain governance leadership (if applicable) list the:

  • (a) full names,
  • (b) official titles,
  • (c) and prior experience of key team members.

For any non-existent entity, explicitly mention it does not exist. External links may be included but they will not factor into the score.

Response

Labs / DevCo

Full Name

Official Title

Prior Experience

does not exist

Foundation

Contents

  1. Project & Team
  2. 01Description of Project
  3. 02Known Project Team
  4. 03DAO Structure
  5. 04Primary Foundation
  6. 05Primary DevCo
  7. 06Affiliated Protocol Contributor
  8. Token Supply & Allocation
  9. 07Initial Allocation
  10. 08Vesting Insider Tokens
  11. 09Disclosure of Token Advisory Billings
  12. 10KOL Marketing Activities
  13. 11Labelled Unissued & Operational Token Wallets
  14. Transactions & Market Structures
  15. 12Market Maker Agreements & Deals
  16. 13Exchange Agreements & Deals
  17. 14Liquidity Deals and Market Activity
  18. Resource Disclosures
  19. 15Prior Token Sales & Fundraising
  20. 16Operational Funding, Economic Flows, and Resource Provisioning
  21. 17Previous Exploits Affecting The Native Token
  22. 18[Optional] Offchain Foundation Or DevCo Income Statement
  23. Token Addresses and Deployments
  24. 19[Optional] Token Addresses and Deployments

Full Name

Official Title

Prior Experience

Esfandiar (Essi) Lagevardi

President of the Board (Chairperson, individual signing authority); CEO & Co-Founder

CFO at Omniscia (smart contract audit firm, 2021-2024); Director of DeFi at W3BCLOUD; Aston Business School

Nicholas Jeffrey Thoma

Member of the Board (joint signature, any two to sign); CTO & Co-Founder

ParaFi Capital, Brain Corp, NASA

Connor Milner

CBDO

RE7 Capital

Waseem Shabout

COO (Operations and Diligence)

Arkham, Celsius

Tim Haldorsson

CMO; CEO of Lunar Strategy (business unit of the Association)

Founder of Lunar Strategy

DAO / Onchain Governance

Full Name

Official Title

Prior Experience

does not exist

No separate DAO governance leadership exists. On-chain governance is exercised directly by sTURTLE holders through the OpenZeppelin Governor contract; all officers are Turtle.Club Association staff and are listed under Foundation above.

Not applicable

03DAO Structure

Question

Provide a structured description of the DAO's governance, powers, and economic rights. If a DAO does not exist, state so for each sub question. Even if there is no DAO, there must be an answer to (d). Address the lettered items below.

  • (a) IP ownership & control — State what IP the DAO owns or controls (e.g., codebases/repos, trademarks/brands). Note any license if relevant.
  • (b) Contract/admin powers — List on-chain or administrative authorities and limits: pause/upgrade roles (e.g., multisig pause), governance-executor authorities, and the method of authority for each (e.g., veto, majority, super-majority).
  • (c) Locked-token rights (conditional) — If locking/staking for additional rights exists, explain the additional rights and what tokenholders can and cannot decide. If no locking mechanism exists, leave absent.
  • (d) Current tokenholder governance rights and economic arrangements — If any, describe the current governance rights of tokenholders and any presently operative rights or arrangements relating to treasury actions, fee-routing, rewards, buybacks, or other protocol-controlled resources. If none, state that explicitly.
  • (e) Control surface reliance — If any, briefly describe the anticipated or possible evolution of the protocol's governance/control model.
  • (f) Dissolution authority — State who can dissolve/wind up the DAO and by what mechanism (e.g., on-chain vote threshold, board resolution of a legal wrapper).

Response

(a) IP ownership & control

No for-profit development company exists, and no entity with equity shareholders claims rights to the protocol. Intellectual property is held and administered by the Turtle Club Association (a Swiss Verein based in Zug, with no equity shareholders), solely to execute decisions approved by the DAO. This covers the protocol codebase, developed by contributors engaged under the Association's Master Token Incentive Plan (TMTIP), and the Turtle brand and domains. The protocol repositories are proprietary; public transparency data (per-address airdrop allocations) is published under the turtle-dao GitHub organization (github.com/turtle-dao/turtle-transparency) without a separate open-source license. The Association also holds the Lunar Strategy brand and business: Lunar Strategy, a marketing and go-to-market business acquired in June 2026 (publicly announced 2026-07-22), operates as a business unit of Turtle inside the Turtle Club Association, not as a separate legal entity, so its brand, client contracts and economic value sit within the Association for the benefit of the DAO.

(b) Contract/admin powers

DAO Treasury Multisig, 0x2e0355922EF3a5b77d29287C808aEafB4e7f25B2 (Ethereum and BSC, same address and signer set). Gnosis Safe v1.4.1 with a 3-of-5 signing threshold; five signers comprising core team members and independent parties; no modules or guard contracts are enabled. Holds the unallocated Ecosystem and Community allocation. Method of authority: 3-of-5 signature execution of governance-approved actions. Limits: no on-chain timelock, veto or guard; its authority is bounded off-chain by the Association's Articles of Association (the Board manages the Association's assets and implements DAO resolutions, Articles 12 and 23) and by the standing rule that every treasury outflow requires governance approval.d contracts are enabled. Holds the unallocated Ecosystem and Community allocation. Method of authority: 3-of-5 signature execution of governance-approved actions. Limits: no on-chain timelock, veto or guard; its authority is bounded off-chain by the Association's Articles of Association (the Board manages the Association's assets and implements DAO resolutions, Articles 12 and 23) and by the standing rule that every treasury outflow requires governance approval.

Off-chain governance approval standard: pending activation of the deployed Governor contract, DAO-approved actions are authorized by resolution of the board of the Turtle Club Association, acting on token holder signal, and executed by the 3-of-5 Treasury Multisig.

Governor contract (OpenZeppelin Governor), 0x27cbB991EfF5E5c7b6734675E837EDDF924Ffece (Ethereum). Deployed, not yet active. Parameters: proposal threshold 1.5M sTURTLE, quorum 4%, voting delay 4 days, voting period 2 weeks. Method of authority once active: token-weighted majority of sTURTLE votes cast, subject to quorum. Executor powers once active: a passed proposal authorizes the Association's Board to execute the approved action, with on-chain treasury movements executed through the 3-of-5 Treasury Multisig; no timelock is configured. Limits: the Governor holds no authority over the TURTLE token contract (immutable, no mint or pause), cannot change the fixed supply, and cannot deviate from the TMTIP standard vesting schedule without the separate supermajority (66%) token holder vote.

TURTLE token contract, 0x66fd8de541c0594b4dccdfc13bf3a390e50d3afd (Ethereum and BSC). Immutable ERC-20: no mint function, no pause role, no admin key. No authority exists over this contract.

Rewards distribution contract, 0x56aa6D651bfefA9207B35E508716466359BAe8eF (BSC). Owned by the 3-of-5 DAO Treasury Multisig; method of authority: 3-of-5 signature execution of governance-approved actions.

Staking contract (sTURTLE), 0x2d362158034EEB28e1a7062F24FfC436b1D01858 (Ethereum). Upgradeable proxy governed by an on-chain access manager (OpenZeppelin AccessManager, itself an upgradeable proxy) at 0xD5e4ac485F09eE907F5dD8b9a9935a09875f7bFb. Admin authority over the manager is held by a single address, 0xaed8FCC3B124E754D4a8Def82f2CA579b4370058 (Turtle Access Admin), an operator-controlled wallet held in Utila MPC custody by the Turtle Club Association; it is not a DAO multisig and not the deployer, and no other address holds the admin role. Method of authority: transactions submitted directly from that wallet, signed through Utila MPC custody under a policy requiring approval by at least one additional Utila administrator (all four authorised approvers are Association personnel); this control is enforced at the custody layer, not as an on-chain signing threshold, and transactions execute immediately with no on-chain timelock. Limits: the admin role controls the staking contract's privileged functions (setting the redeem delay, pausing and unpausing, rescuing unclaimed redeem requests, and authorising contract upgrades), with protections enforced in the contract itself: a pause suspends deposits and mints only, leaving redemption requests and claims available so holders can always exit, and unclaimed redeem requests can be rescued only after 365 days past their unlock timestamp.

Sablier vesting streams: the Association may cancel a stream solely under the TMTIP leaver provisions. Method of authority: a resolution of the Association's Board, passed by simple majority of Board members present with the President holding the casting vote (Articles 11 and 12 of the Articles of Association), determining good-leaver or bad-leaver status; the cancellation transaction is then submitted by the Association's authorised signatories. No other person can cancel a stream, no other ground for cancellation exists, and any deviation from the standard vesting schedule requires a supermajority (66%) token holder vote.

Bridge pools: controlled by Chainlink CCIP; Turtle holds no unilateral bridge authority.

(c) Locked-token rights (conditional)

A locking mechanism exists. TURTLE holders stake TURTLE to receive sTURTLE, which carries governance voting power; unstaked TURTLE carries no voting rights. sTURTLE holders can decide: treasury allocations and outflows, protocol parameters and upgrades, strategic initiatives, distributions from the Ecosystem Growth allocation, and, by supermajority, deviations from the standard vesting schedule and any new token launch. sTURTLE holders cannot: compel dividend-style distributions to holders (no such mechanism exists), direct the Turtle Club Association beyond the execution of DAO-approved decisions, or alter the fixed token supply without a quorum-based governance vote. Tokens locked in vesting contracts (team, investors, advisors) cannot be staked, carry no voting power, and earn no staking rewards until vested and claimed.

(d) Current tokenholder governance rights and economic arrangements

Governance is currently conducted off-chain by sTURTLE holders, with approved outcomes executed by the Turtle Club Association and the DAO Treasury Multisig. Presently operative arrangements:

Treasury actions: all treasury outflows require governance approval and are executed by the DAO Multisig. Distributions from the Ecosystem Growth allocation are disclosed publicly at least 7 days in advance, including recipient category, amount, vesting terms, and rationale.

Fee routing: all protocol inflows (boost payments, vault performance and AUM fees, campaign revenues, curation and transaction fee shares) flow directly to the DAO-controlled treasury. No fee share is routed to any equity holder or off-chain entity beyond Association operating expenses approved by the DAO.

Rewards: staking rewards accrue to non-insider sTURTLE stakers; unvested insider allocations are excluded.

Buybacks: no standing buyback or token-repurchase program operates. No dividends or direct distributions to token holders currently operate; value accrues to the DAO treasury, which token holders govern. Lunar Strategy, the marketing and go-to-market business acquired in June 2026, operates as a business unit inside the Turtle Club Association rather than as a separate legal entity; its revenue and costs form part of the Association's accounts, and its economic value accrues to the DAO as the Association's beneficiary.

(e) Control surface reliance

The protocol anticipates transitioning voting on-chain. An OpenZeppelin Governor contract is already deployed (proposal threshold 1.5M sTURTLE, quorum 4%, voting delay 4 days, voting period 2 weeks) and will assume active use when the protocol activates on-chain governance. The intended end state is a hybrid model: binding on-chain votes by sTURTLE holders, with the Turtle Club Association executing off-chain actions (legal agreements, treasury transfers) strictly as directed by vote outcomes. No changes to the fixed supply, the absence of a DevCo, or the routing of protocol inflows to the DAO treasury are anticipated as part of this transition. No firm activation date is committed; activation will be announced through official channels.

(f) Dissolution authority

The DAO's off-chain wrapper is the Turtle Club Association, a Swiss Verein domiciled in Zug (founded 12 July 2024, entered in the Commercial Register of the Canton of Zug, UID CHE-258.098.477). Under its Articles of Association, dissolution is decided by the General Meeting of members with a majority of three quarters (75%) of the members present (Articles 9 and 24); the same 75% threshold applies to amendments of the Articles. If dissolution is resolved, the Board carries out the liquidation unless the General Meeting appoints special liquidators (Article 24). Net assets remaining after payment of all debts and other obligations may be distributed to the members of the Association (Article 25); membership is a single class admitted at the Board's discretion, with one vote per member and a membership fee of CHF 0. The Association may also be dissolved by operation of law under Articles 76 et seq. of the Swiss Civil Code (insolvency, or a court finding its purpose unlawful). Under Article 23 of the Articles, DAO resolutions are proposals to the Association which the General Meeting or the Board implements unless implementation lacks funding, contradicts the Association's purpose, breaches Swiss or foreign law, or creates other risk for the Association. A wind-up of the DAO treasury itself is a treasury action: it requires sTURTLE holder approval under the standard governance process (proposal threshold 1.5M sTURTLE, quorum 4%, token-weighted majority of votes cast) and execution by the 3-of-5 DAO Treasury Multisig, with any related legal steps resolved by the Association's Board.

04Primary Foundation

Question

For the Primary Foundation do the following independently. If a Foundation does not exist, state so for each sub question. Items (a)–(f) apply only if that entity exists; state explicitly that the entity doesn't exist.

Definition: The primary Foundation can be explained as the entity which was directly/indirectly involved in the issuance of the native token at launch. If the original Foundation has been dissolved and in its place a "new Foundation" was created, then detail the "new Foundation".

  • (a) Entity — Type and jurisdiction.
  • (b) IP ownership & control — What IP the entity owns/controls (repos/code, trademarks/brand; license optional)
  • (c) Powers over DAO, treasury, protocol-controlled resources, and token administration — If any, describe the current powers over DAO governance, treasury actions, protocol-controlled resources (e.g. revenue), token administration, or reward parameters, and the method/threshold for each.
  • (d) Powers over DevCo — Explain whether the foundation can exert direct or indirect influence over decision-making of the DevCo.
  • (e) Contract/admin powers — Pause/upgrade/governance-executor authorities, and the method/threshold for each (e.g., veto/majority/super-majority).
  • (f) Current economic arrangements and distribution policies — Describe any current governance-approved, contractual, or programmatic mechanisms, if any, by which protocol-controlled resources, treasury assets, fees, revenue, rewards, or token distributions may be directed to this entity, its equityholders, contributors, or other participants. If no such mechanism currently exists, state that explicitly.

Response

(a) Entity

Entity: Turtle Club Association, a Swiss Verein (association under Articles 60 et seq. of the Swiss Civil Code) with its seat at Gotthardstrasse 26, 6300 Zug, Switzerland, UID CHE-258.098.477. Founded on 12 July 2024 and entered in the Commercial Register of the Canton of Zug (application filed 15 July 2024). Non-profit under Article 3 of its Articles of Association; no equity and no shareholders. Its bodies are the General Meeting of members (one vote per member) and a Board of at least two members elected for one-year terms. Board as registered: Esfandiar Lagevardi (President, sole signing authority), Felix Frisk (member, joint signature at two), Caspar Sauter (member, sole signing authority). No auditor is appointed because the thresholds of Article 69b of the Swiss Civil Code are not met. It was the entity directly involved in the issuance of TURTLE at TGE (October 22, 2025).

(b) IP ownership & control

IP: the Association holds and administers the protocol codebase IP, the Turtle brand and domains, and the Lunar Strategy brand and business unit, solely to execute DAO-approved decisions. Article 3 of its Articles of Association expressly permits the Association to hold participations in other companies, to acquire, exploit, administer and dispose of tokens and intellectual property rights, and to establish subsidiaries and branch offices in Switzerland and abroad; the protocol IP and the Lunar Strategy business unit are held under that authority. Lunar Strategy is not a separate legal entity. The protocol repositories are proprietary. Public transparency data (per-address airdrop allocations) is published under the turtle-dao GitHub organization (github.com/turtle-dao/turtle-transparency) without a separate open-source license.

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

The Foundation (Turtle Club Association) holds the following powers, each with its method of exercise; it holds no others.

Treasury: no unilateral power. Treasury outflows require DAO governance approval and execute through the DAO Treasury Multisig with a 3-of-5 signature threshold; the signer set includes core team members and independent parties.

Protocol revenue: no power to redirect. All protocol inflows (boost payments, vault fees, campaign revenues, curation and transaction fee shares) route to the DAO treasury by default; the Association cannot capture or redirect revenue to itself beyond DAO-approved operating funding (see (f)).

Reward parameters: none. Incentive campaign parameters (rates, durations, eligibility) are configured by the partner protocols running each campaign, within the protocol's rules; the Association does not set or alter reward parameters on live campaigns.

Token administration: the token contract is immutable (no mint, no pause), so no administration power exists over supply. The Association administers the TMTIP vesting plan; method: Association board action strictly bounded by the plan's terms, limited to (i) issuing grants on the standard 12-month-cliff/36-month-linear schedule and (ii) cancelling Sablier streams solely upon a board determination of leaver status under the plan's leaver provisions. Any deviation from the standard schedule requires a supermajority (66%) token holder vote, which the Association cannot waive.

Market maker lending: the Association acts as lender of record for the three market maker token loans. Method: the Association executes each loan agreement as a DAO-approved action; the loaned tokens (aggregate 22,500,000 TURTLE, 2.25% of supply) are drawn from the Liquidity, MM & Exchange reserve and released via the 3-of-5 Treasury Multisig.

(d) Powers over DevCo

Powers over DevCo: no DevCo exists.

(e) Contract/admin powers

Pause authority: none. The TURTLE token contract has no pause function on any chain, and the Association holds no pause keys over any token-related contract.

Upgrade authority: none held directly on-chain. The one upgradeable token-related contract (the sTURTLE staking proxy) is governed by an on-chain access manager at 0xD5e4ac485F09eE907F5dD8b9a9935a09875f7bFb, whose admin is a single operator-controlled wallet (Turtle Access Admin, 0xaed8FCC3B124E754D4a8Def82f2CA579b4370058) held in Utila MPC custody. The Association holds an indirect role in that process: the Utila custody account through which the admin wallet operates is held by the Turtle Club Association, all four authorised approvers are Association personnel, and the Association designates those approvers. The Association therefore participates indirectly in staking contract upgrade and admin actions through its control of the custody account, while holding no direct on-chain admin key. Approval threshold within the Utila custody account: 3 of the 4 authorised approvers.

Governance-executor authority: yes. The Association executes DAO-approved decisions off-chain (legal agreements, treasury transfers). Method: an Association board resolution implementing the approved outcome, with any on-chain movement executed through the 3-of-5 DAO Treasury Multisig. The Association cannot originate treasury actions without governance approval.

Vesting stream administration: the Association may cancel a Sablier vesting stream solely under the TMTIP leaver provisions. Method: board determination of good-leaver or bad-leaver status per the plan; no other modification authority exists, and schedule deviations require a supermajority (66%) token holder vote.

Association signing authority per the Commercial Register of the Canton of Zug: the President (Esfandiar Lagevardi) signs alone, one Board member (Caspar Sauter) signs alone, and one Board member (Felix Frisk) signs jointly with a second signatory. Board resolutions pass by simple majority of members present with the President holding the casting vote, and may be taken by circular resolution unless a member requests a meeting (Articles 11 and 12 of the Articles of Association). No on-chain timelock applies to any authority listed above.

(f) Current economic arrangements and distribution policies

Authorizing mechanism: the Association's funding is authorized through DAO governance-approved treasury resolutions, under the standing arrangement disclosed in Section 3(d) that every treasury outflow requires governance approval; approved amounts are released by the 3-of-5 Treasury Multisig. Distributions from the Ecosystem Growth allocation additionally follow a programmatic disclosure rule: public notice at least 7 days before distribution, stating recipient category, amount, vesting terms, and rationale.

Recipients: resources flow to (i) the Association itself, strictly for operating expenses (legal, compliance, treasury management, infrastructure); (ii) core contributors and independent contractors, as TURTLE grants under the TMTIP, streamed via Sablier on the standard vesting schedule; (iii) external advisors and service providers, from the 16M TURTLE Advisor Allocation; and (iv) ecosystem participants, via governance-approved Ecosystem Growth distributions and campaign incentives. No resources flow to equity holders (none exist), and no direct distributions flow to token holders.

05Primary DevCo

Question

For the Primary DevCo do the following independently. If an entity does not exist, state that explicitly across each sub-question. Items (a)–(f) apply only if that entity exists; state explicitly that the entity doesn't exist.

Definition: The primary DevCo can be explained as the entity which was directly/indirectly involved in the issuance of the native token at launch. If the original DevCo has been dissolved and in its place a "new DevCo" was created, then detail the "new DevCo".

  • (a) Entity — Type and jurisdiction.
  • (b) IP ownership & control — What IP the entity owns/controls (repos/code, trademarks/brand; license optional)
  • (c) Powers over DAO, treasury, protocol-controlled resources, and token administration — If any, describe the current powers over DAO governance, treasury actions, protocol-controlled resources (e.g. revenue), token administration, or reward parameters, and the method/threshold for each.
  • (d) Powers over Foundation — Explain whether the DevCo can exert direct or indirect influence over decision-making of the Foundation.
  • (e) Contract/admin powers — Pause/upgrade/governance-executor authorities and the method/threshold for each (e.g., veto/majority/super-majority; "3/5 multisig").
  • (f) Current economic arrangements and distribution policies — Describe any current governance-approved, contractual, or programmatic mechanisms, if any, by which protocol-controlled resources, treasury assets, fees, revenue, rewards, or token distributions may be directed to this entity, its equityholders, contributors, or other participants. If no such mechanism currently exists, state that explicitly. Do not discuss hypothetical future dividends, repurchases, or distributions unless formally adopted.

Response

(a) Entity

No DevCo exists. No for-profit development company was directly or indirectly involved in the issuance of TURTLE at launch, none has been dissolved or replaced, and none exists today.

(b) IP ownership & control

Not applicable; no DevCo exists. No development company owns or controls any protocol IP, codebase, or brand.

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

Not applicable; no DevCo exists and no such entity holds any power over the DAO, treasury, protocol-controlled resources, or token administration.

(d) Powers over Foundation

Not applicable; no DevCo exists and no entity holds powers over the Turtle Club Association other than its own governing bodies.

(e) Contract/admin powers

Not applicable; no DevCo exists and no development company holds pause, upgrade, or executor authority over any contract.

(f) Current economic arrangements and distribution policies

Not applicable; no DevCo exists. No protocol cash flows are or can be directed to development-company equity holders, as no such entity or equity exists.

06Affiliated Protocol Contributor

Question

Definition (for this section): An Affiliated Protocol Contributor (APC) is a non-issuer company - not the protocol's primary Foundation or DevCo - that materially contributes to the protocol's code, operations, governance, or funding. For example, Blockworks Advisory would be considered an APC of Ethena because it materially contributes to its operations through Ethena's risk council.

Provide a structured description per APC. If no APCs exist, state that explicitly across each sub-question. Items below apply per APC.

  • (a) Identity & role — Legal name, entity type, jurisdiction, and role (e.g., core development, security, infrastructure, market making, operations).
  • (b) Parameter control & scope — For each existing APC, if any, what major protocol parameters the APC controls; include the method of authority (e.g., veto, majority, super-majority). If none, say so.
  • (c) Contract/admin powers — For each existing APC, if any, provide the pause/upgrade powers (e.g., multisig pause), governance-executor authorities and limitations; include the method of authority for each (e.g. veto, majority, super-majority). If none, say so.
  • (d) Compensation and material economic arrangements — For each existing APC, if protocol-generated resources or economic value is dynamically routed to the APC, describe the arrangement. If applicable, include the resource sources, routing mechanism, payment frequency, and duration. If no protocol resources or resources-linked economics are routed to the APC, state that explicitly.

Response

(a) Identity & role

One Affiliated Protocol Contributor exists: Lunar Strategy. Lunar Strategy is a brand and business unit of Turtle and not a separate legal entity, so its identity fields are those of the entity that operates it. Legal name: Turtle Club Association. Entity type: Swiss Verein (association under Articles 60 et seq. of the Swiss Civil Code). Jurisdiction: Zug, Switzerland, UID CHE-258.098.477. Role: marketing, communications, go-to-market and events for the protocol and its partner protocols, run as a separately managed P&L inside the Association since the Lunar Strategy business was acquired in June 2026 (publicly announced 22 July 2026). The market makers disclosed in the Market Maker Agreements section are counterparties under token loan agreements, not protocol contributors, and are not Affiliated Protocol Contributors. No other APC exists.

(b) Parameter control & scope

Lunar Strategy holds no control over protocol parameters, contracts, or governance; its scope is limited to marketing, communications and go-to-market services. No other APC exists.

(c) Contract/admin powers

None. Lunar Strategy holds no keys, no multisig seats in its business-unit capacity, and no pause, upgrade, or governance-executor authority over any protocol contract. No other APC exists.

(d) Compensation and material economic arrangements

Lunar Strategy is a business unit inside the Turtle Club Association, so no protocol resources are routed to any third party. Source: its operating costs (staff, tooling, events) are paid from the Association's operating budget, which is funded from the DAO treasury under governance-approved treasury resolutions. Routing mechanism: approved amounts are released by the 3-of-5 DAO Treasury Multisig to the Association's operating accounts. Frequency: ongoing, settled through the Association's regular operating cycle. Duration: for as long as the business unit operates, with no fixed end date. Revenue: client fees earned by Lunar Strategy are received by the Association and accrue to the DAO as the Association's beneficiary. No token allocation, revenue share, fee routing or other protocol-linked economics are routed to Lunar Strategy beyond that operating budget; individual contributors may receive TURTLE grants under the TMTIP, disclosed in the Vesting Insider Tokens section. No other APC exists.

Token Supply & Allocation

07Initial Allocation

Response

Ticker

Date

Allocation Category Name

Recipient Type

Allocation %

Allocation Tokens

TGE Unlock %

TGE Unlock Tokens

Cliff Months

Cliff Unlock %

Linear Vesting Months

Cadence Months

Circulating Treatment

Notes on what each category is used for

If applicable: Contract / Wallet address

TURTLE

2025-10-22

Ecosystem & Community

Ecosystem

0.293

293000000

0

0

0

0

0

0

Conditional

Unallocated ecosystem and community reserve held in the DAO Treasury Multisig; distributions require token holder governance approval with 7-day public notice. Source: docs.turtle.xyz/transparency (B-2 filing, April 2026)

0x2e0355922EF3a5b77d29287C808aEafB4e7f25B2

TURTLE

2025-10-22

Private Rounds (Investors)

Private / VC

0.275

275000000

08Vesting Insider Tokens

Question

If there are no post-TGE token compensation plans, state explicitly they do not exist across each sub-question. If there are, explain each of (a)–(b) below.

  • (a) Post-TGE employee lock as % of total supply — State the current total amount of tokens locked attributable to post-TGE employees, expressed as a percentage of total supply.
  • (b) Typical post-TGE vesting schedule — Describe the standard vesting terms used for post-TGE grants, including: cliff length (or "no cliff"), vesting frequency (e.g., monthly/quarterly), and total duration.

Response

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

Post-TGE token compensation exists and is governed by the same plan as founding-team grants: the Turtle Master Token Incentive Plan (TMTIP), drawing from the Team, Advisors & Contributors allocation (23.10% of total supply). Tokens currently locked and attributable specifically to employees and contractors hired after TGE (October 22, 2025) total approximately 55,000,000 TURTLE, approximately 5.5% of total supply. All such tokens remain locked under the standard schedule and cannot be staked or voted until vested and claimed.

(b) Typical post-TGE vesting schedule

Post-TGE hires receive grants on the identical Standard Schedule applied to founding contributors, with no separate or discounted plan: total duration 48 months, a mandatory 12-month cliff, then linear vesting over 36 months, streamed continuously via Sablier contracts for on-chain verifiability. The Vesting Commencement Date for post-TGE hires is set to the TGE date (October 22, 2025) rather than the hire date, aligning all unlock timelines to a single schedule; the practical effect is that a later hire's effective cliff from their start date is shorter than 12 months, while their total lock still ends no earlier than any founding contributor's. Signing bonuses in unlocked tokens, cliffs under 12 months, and schedules under 4 years are prohibited; any deviation requires a supermajority (66%) vote of token holders. Bad-leaver termination forfeits 100% of unvested and vested-but-unclaimed tokens to the treasury; good leavers retain vested tokens only.

09Disclosure of Token Advisory Billings

Question

Disclose current token-based compensation for external advisors and service providers (e.g., legal, marketing, technical, growth) funded from the on-chain treasury. Do not disclose individual payments to advisors receiving fiat-only compensation. If there are no advisors contracted in tokens then state across each sub-question that no token-based advisory compensation exists.

  • (a) Existence — Whether any such token-based payments or advisory commitments exist (or explicitly state that no token-based compensation for advisory commitments exist).
  • (b) Total token allocation — For all existing token-based advisors, disclose the total token allocation across all advisory services.
  • (c) Payer entity — For each existing token-based advisor, share the payer entity (e.g., Foundation, Labs/DevCo, DAO/treasury).
  • (d) Description of advisory/services — For each existing token-based advisor, provide a brief description of the advisory/services (e.g., "legal and regulatory advisory," "growth and BD support," "security advisory").

Response

(a) Existence

Token-based advisory compensation exists. External advisors providing strategic, technical, and legal services are compensated exclusively in TURTLE token allocations; no fiat payments and no revenue-sharing arrangements exist for advisors. Advisors receiving fiat-only compensation: none.

(b) Total token allocation

A total of 13,000,000 TURTLE (1.3% of total supply) is currently outstanding for advisory services, from the dedicated Advisor Allocation pool within the Team, Advisors & Contributors allocation. The pool originally comprised 16,000,000 TURTLE across strategic, technical, and legal advisors; 2,000,000 TURTLE was subsequently repurchased from one advisor by the treasury, and approximately 1,000,000 TURTLE was cancelled following the termination of an advisory relationship, leaving 13,000,000 TURTLE outstanding. This is the aggregate across all existing token-based advisory services. All advisor allocations are subject to the standard vesting schedule and cannot be staked or voted until vested and claimed.

(c) Payer entity

The Turtle Club Association (Swiss Verein, Zug), via the dedicated Advisor Allocation pool defined in the tokenomics. Grants are streamed through Sablier vesting contracts, released per the standard schedule; the Association administers the streams and may cancel them solely under the TMTIP leaver provisions.

(d) Description of advisory/services

Three service categories, each with its allocation:

10KOL Marketing Activities

Question

Disclose ongoing KOL/influencer relationships that partially or fully received tokens for payment. You do not need to disclose KOL/influencers that do not receive tokens for payment. If no KOL engagements exist, state for each sub-question that no KOL engagements exist.

  • (a) Existence & scope — State plainly whether KOLs receive tokens for payment.
  • (b) Usernames & roles — List usernames/handles (with platforms) for KOLs that received token-based compensation and describe the nature of their activities. Legal names are not required.
  • (c) Token allocation & vesting/locks — Provide the aggregate token amount across all such arrangements and summarize vesting, lock, or release terms.

Response

(a) Existence & scope

No KOLs or influencers receive TURTLE tokens as payment, in whole or in part, and no token-paid KOL engagements have existed since TGE. Turtle's creator-facing program is deliberately structured as the alternative to token-paid KOL marketing: distributors are compensated through deposit-based revenue share on verified deposits they route to opportunities, settled outside the native token, with no TURTLE grants attached to promotion. No token-paid engagements were inherited through the Lunar Strategy acquisition.

(b) Usernames & roles

Not applicable; no KOL or influencer receives tokens for payment, so there are no usernames or roles to disclose.

(c) Token allocation & vesting/locks

Not applicable; zero tokens are allocated to KOL or influencer engagements, and no vesting or lock arrangements of this kind exist.

11Labelled Unissued & Operational Token Wallets

Question

For each wallet that holds Unissued Tokens or is essential to operations (e.g., foundation, operations, treasury, investor reserve), disclose:

  • (a) A category label explaining the wallet's primary function.
  • (b) chain the wallet is on.
  • (c) The unique address of the wallet.
  • (d) The mechanism of control (e.g., DAO, multisig).
  • (e) One verification link to a blockchain explorer.

Definition: Unissued Supply = tokens authorized by the contract but not yet issued to any party; where they sit (treasury or mint authority) does not change that they are unissued. For instance: if a token has a total supply cap of 1B, and 400M tokens have been issued to investors, the team, and users (whether vested or unlocked), then those 400M count as issued supply. The remaining 600M are authorized but unissued supply, even if they are already minted into a DAO treasury wallet.

Response

Title

Primary Function

Chain

Address

Control Mechanism

Explorer Link

DAO Treasury Multisig

Holds the unallocated Ecosystem & Community allocation; executes governance-approved treasury outflows

Ethereum & BSC (same address)

Transactions & Market Structures

12Market Maker Agreements & Deals

Question

Projects must disclose all material terms of market-making arrangements that affect token liquidity. If the project has no agreements or deals with market makers, state that explicitly.

For each market maker, include in a table:

  • (a) Market maker's name — the market maker's name;
  • (b) Token allocation or loaned amount — the token allocation or loaned amount as a percentage of total supply;
  • (c) Duration/term of agreement — the duration/term of the agreement; and, where applicable,
  • (d) Name of agreement structure — label the financial vehicle being used in the agreement (i.e. loan, option/call, retainer model).

If no native tokens were loaned or allocated to market makers, state that explicitly; cash/fiat retainers or fees are not required for (b).

Response

Market Maker Name

Token Allocation Committed

Term Duration

Structure Name

Laser Digital (Nomura)

7,500,000 TURTLE (0.75% of total supply), fully delivered in three tranches of 2,500,000; final tranche delivered May 5, 2026

18 months

Token loan

GSR Markets

7,500,000 TURTLE (0.75% of total supply), fully unlocked at TGE. Part of the 22,500,000 TURTLE aggregate committed across the three token-loan counterparties.

18 months

Token loan

FalconX

7,500,000 TURTLE (0.75% of total supply), fully unlocked at TGE. Part of the 22,500,000 TURTLE aggregate committed across the three token-loan counterparties.

12 months

Token loan

13Exchange Agreements & Deals

Question

Projects must disclose all material terms of centralized or decentralized exchange listings that affect token liquidity.

For each listing, include in a table:

  • (a) Exchange name / DEX pool — the exchange name (and, for DEX, the specific pool/pair);
  • (b) Token allocation for listing — the token allocation supplied or committed for listing as a percentage of total supply;
  • (c) Term Duration — the duration/term of any listing lockups, liquidity, or incentive programs; and, where applicable,
  • (d) Native-token listing fees — whether any listing fees were paid in native tokens, with amounts (tokens or % of supply), recipients, and any vesting or lock terms tied to the partnership.

If the project has no agreements or deals with CEX or DEX, state that explicitly; doing so earns full credit; cash/fiat fee amounts are not required for this item.

Response

Exchange Name

Token Allocation Committed

Term Duration

Native Token Listing Fees

Binance (via Binance Alpha)

None; no TURTLE tokens were allocated to Binance in connection with this listing

Listed October 22, 2025 via Binance Alpha, a discovery platform for early-stage tokens; no formal listing agreement, lockup, or incentive program

None; no listing fee was paid in native tokens or otherwise

14Liquidity Deals and Market Activity

Question

If a category does not exist or is not applicable, make that clear in plain language.

  • (a) Token repurchases or secondary-market accumulations (if any) — Source of funds, treatment (burn, treasury retention, POL, redistribution, or other), policy controller (who can change the secondary-market accumulation strategy), and whether those tokens may be re-used, re-issued, or permanently removed from circulation.
  • (b) Protocol-owned liquidity (POL) (if any) — Where deployed, total token or dollar size across deployments, policy controller (who can change the POL strategy), and unwind/exit policy.
  • (c) Liquidity deals / purchased TVL (if any) — The total size across all deals, and where the capital participates - no counterparty names needed.
  • (d) Token-secured loans/lines (incl. against unissued tokens) (if any) — Principal, gross position size, collateral, counterparties, and unwind/exit policy.

Response

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

No token repurchase program and no secondary-market accumulation strategy exists. The single exception is a one-off, treasury-funded repurchase of 2,000,000 TURTLE from one advisor, disclosed in the Token Advisory Billings section. Source of funds: the DAO treasury. Treatment: treasury retention; the tokens are held by the treasury and have not been burned. Policy controller: any repurchase or secondary-market accumulation is a treasury action that requires DAO governance approval and is executed by the Board of the Turtle Club Association, which manages the Association's assets and implements DAO resolutions under Articles 12 and 23 of its Articles of Association, through the 3-of-5 DAO Treasury Multisig; no standing mandate or discretionary buyback authority exists, and the Association cannot originate such a transaction without governance approval. Re-use: the repurchased tokens are not permanently removed from circulation; they may be re-issued or redistributed only through a governance-approved distribution, subject to the 7-day advance public disclosure rule that applies to treasury distributions. No open-market buybacks have been conducted.

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

Protocol-owned liquidity exists. Turtle's protocol-owned liquidity is deployed in a single venue: the TURTLE/USDC 0.30% fee-tier pool on Uniswap v4 (Ethereum), which is the protocol's primary onchain market for TURTLE.

Size: approximately USD 1.4 million of total value locked as of 23 September 2026. The full liquidity of that pool is protocol-owned. Four further TURTLE pools exist on Ethereum with combined total value locked below USD 9,000 (TURTLE/ETH, TURTLE/USDT, and two additional TURTLE/USDC and TURTLE/ETH fee tiers); these are immaterial.

Resource Disclosures

15Prior Token Sales & Fundraising

Question

Disclose all prior token sales by the Project — including fundraising rounds, any material OTC sales to investors, and any discounted market-maker sales.

For each sale, provide:

  • (a) Series Name;
  • (b) Early-Stage Investment Instrument used (i.e. SAFT, STAMP, SAFE, SAFE+Token Warrant, etc.);
  • (c) Date of sale (at least month & year);
  • (d) Number of tokens sold (or % of total supply);
  • (e) Vesting schedule.

If no prior sales occurred, state that explicitly (e.g., "No prior fundraising, OTC, or discounted MM sales have occurred.").

Response

Series Name

Investment Instrument

Date Of Sale

Number of tokens sold

Vesting Schedule

Pre-Seed

SAFT

FEBRUARY 2024

55800000

6 months cliff, 36 months linear; cliff runs from TGE, 2025-10-22

Seed

SAFT

AUGUST 2024

107500000

6 months cliff, 36 months linear; cliff runs from TGE, 2025-10-22

Strategic

SAFT

OCTOBER 2025

91700000

6 months cliff, 36 months linear; cliff runs from TGE, 2025-10-22

Anchor LP Distribution

Token distribution agreement (anchor LP program)

APRIL 2024

20000000

6 months cliff, 36 months linear; cliff runs from TGE, 2025-10-22

16Operational Funding, Economic Flows, and Resource Provisioning

Question

Provide a narrative description of the Project's material funding sources, economic flows, and operational provisioning, broken out by entity: Foundation, Lab/DevCo, and DAO. If an entity does not exist, state that explicitly.

  • (a) Entity existence — Explicitly state whether each of Foundation, Lab/DevCo, and DAO exists.
  • (b) Material sources of funding or economic inflows — For each existing entity, describe its primary sources of operational funding or economic inflows, if any (e.g., service fees, grants, donations, treasury reserves, token reserves, staking rewards, validator/sequencer income, partnership payments, retained revenue, or other protocol-related receipts).
  • (c) Operational use of resources — For each existing entity, briefly describe how those resources are generally used (e.g., development, operations, security, ecosystem support, grants, liquidity support).
  • (d) Onchain Resource Usage — For each existing entity, provide links to public dashboards and token holder relations reports that help explain on-chain financial activity, treasury activity, fee flows, rewards, or other protocol-controlled resources. Make certain to explain what each link is for.

Response

(a) Entity existence

Foundation: exists. The Turtle Club Association, a Swiss Verein domiciled in Zug, with no equity shareholders. Lab/DevCo: does not exist; no for-profit development company exists or was involved in token issuance. DAO: exists, comprising TURTLE token holders, with voting power exercised through staked sTURTLE.

(b) Material sources of funding or economic inflows

DAO: all protocol-generated inflows route to the DAO treasury: boost payments negotiated from partner protocols for routed liquidity; performance and AUM fees on vault products; ecosystem campaign revenue from partner chains and foundations for structuring and bootstrapping liquidity; curation and transaction fee shares from the liquidity layer; and yield earned on treasury assets. The treasury also holds proceeds from the prior fundraising rounds disclosed in Prior Token Sales & Fundraising.

Foundation: the Association has no independent revenue source; it is funded from the DAO treasury and protocol inflows strictly to cover operating expenses, under governance-approved treasury resolutions executed by the 3-of-5 Treasury Multisig.

Lab/DevCo: not applicable; no such entity exists to receive funding.

(c) Operational use of resources

Foundation: resources cover legal and compliance, treasury management, infrastructure, and contributor engagement. Contributor token compensation flows under the TMTIP (12-month cliff, 36-month linear, Sablier-streamed); advisor compensation flows from the 16M TURTLE Advisor Allocation. The Association also funds the operating costs of its Lunar Strategy business unit (marketing and go-to-market, not a separate legal entity) under the same budget process, and receives that unit's client revenue.

17Previous Exploits Affecting The Native Token

Question

If any, list prior exploits or incidents that directly affected the token, token supply, tokenholder balances, token contract, minting controls, burn mechanics, or custody of token supply. This question is not asking about general protocol, application, or smart contract exploits unless the incident directly affected the native token itself.

If no prior incidents, state this explicitly (e.g., "No exploits affecting tokenholders or protocol funds as of YYYY-MM-DD").

  • (a) Date & component affected — Date (YYYY-MM or YYYY-MM-DD), chain(s)/component affected.
  • (b) Exploit vector summary — Plain-language summary of the exploit vector (what the hack was).
  • (c) Quantified impact — Quantified impact (assets/tokens affected or a clear "no loss of funds" statement).
  • (d) Remediation/response taken — Remediation/response taken (patches, upgrades, governance actions, compensation).
  • (e) Current status — Current status (resolved, in litigation, under investigation, refunded, etc.).
  • (f) References — Link(s) to post-mortem/advisory/PR.

Response

(a) Date & component affected

No exploits or incidents affecting the TURTLE token have occurred as of 2026-08-25. This covers the token contract on all chains (Ethereum, BSC, Linea), token supply, tokenholder balances, minting controls (none exist; the contract is immutable with no mint function), burn mechanics, and custody of token supply, none of which have been affected by any incident since TGE (October 22, 2025).

(b) Exploit vector summary

No exploits or incidents affecting the native token have occurred as of 2026-08-25. There is therefore no exploit vector to summarize: the token contract (Ethereum, BSC, Linea) is immutable with no mint or pause functions, and no incident has affected token supply, tokenholder balances, or custody of token supply since TGE (October 22, 2025).

(c) Quantified impact

Not applicable; zero tokens and zero tokenholders have been affected by any exploit or incident.

(d) Remediation/response taken

Not applicable; no token-affecting incident has required remediation. Preventive posture for completeness: the token contract is immutable with no mint or pause functions, treasury custody sits behind a 3-of-5 multisig, and vesting custody runs through audited Sablier streaming contracts.

(e) Current status

No open, ongoing, or historical token-affecting incidents exist as of 2026-08-25.

18[Optional] Offchain Foundation Or DevCo Income Statement

Question

Provide a single income statement, expense summary, or comparable operating statement for the primary Foundation or Developer Company. A consolidated or entity-level presentation is acceptable. Balance Sheet and Statement of Cash Flows may be included but are not required. This item is intended to provide transparency into offchain operating resources and expenditures only.

Response

Token Addresses and Deployments

19[Optional] Token Addresses and Deployments

Question

Identify to the best of your ability the token's current deployments across chains, including project-issued deployments, project-endorsed representations, and, if possible, documented third-party wrapped or bridged representations.

For each entry, provide:

  • Token Contract Address or Chain-Specific Asset Identifier
  • Chain
  • Deployment Type: Protocol-level asset / Direct token issuance / Wrapped or bridged representation
  • Project Relationship: Native-token / Project-endorsed / Endorsed third-party / Third-party, endorsement not established / Explicitly unsupported
  • Supporting Source: Link to supporting source

Multiple entries on the same chain are permitted.

Definition: A protocol-level asset is an asset whose balances and transfers are handled directly by the blockchain's core rules, rather than by a token smart contract. For protocol-level assets without a token contract address, enter "No contract address" and identify the asset and chain.

Response

This Token Transparency Filing is provided for general informational purposes only. Blockworks reviews completeness only and does not verify or warrant the accuracy of individual answers. Turtle is solely responsible for the content, accuracy, and legality of its disclosures.

0

0

6

0

36

1

No

Pre-Seed, Seed, Strategic and Anchor LP rounds; 6-month cliff then 36-month linear vesting streamed via Sablier. Source: docs.turtle.xyz/transparency (B-2 filing, April 2026)

TURTLE

2025-10-22

Team, Advisors & Contributors

Insiders

0.231

231000000

0

0

12

0

36

1

No

Grants under the Turtle Master Token Incentive Plan (TMTIP); 12-month cliff then 36-month linear vesting via Sablier; tokens cannot be staked or voted until vested and claimed. Source: docs.turtle.xyz/transparency (B-2 filing, April 2026)

TURTLE

2025-10-22

Airdrop

Community

0.121

121000000

0.0747

74700000

0

0

0

0

Conditional

Genesis airdrop claimable at TGE (74.7M, consistent with the disclosed 154.7M circulating at TGE); remainder distributed in subsequent airdrops per published airdrop rules, no cliff. Source: docs.turtle.xyz/transparency (B-2 filing, April 2026)

TURTLE

2025-10-22

Liquidity, MM & Exchange Reserves

Liquidity

0.08

80000000

1.0

80000000

0

0

0

0

Yes

Reserve funding market maker token loans and exchange liquidity; 100% unlocked at TGE and treated as circulating from TGE. Source: docs.turtle.xyz/transparency (B-2 filing, April 2026)

Strategic and institutional partnerships (6,000,000 TURTLE): market maker introductions, exchange relationships, and institutional outreach.

Technical and infrastructure advisory (5,000,000 TURTLE): multi-chain architecture design, security reviews, and infrastructure scaling.

Legal and regulatory advisory (5,000,000 TURTLE): DAO legal structuring, compliance frameworks, and regulatory advisory.

Advisor vesting is formally aligned with the team schedule: 12-month cliff from TGE, 36-month linear vesting thereafter, streamed via Sablier. Advisory grants are compensation for verified ongoing services under the TMTIP's eligibility rules; one-time or lump-sum unlocked advisory payments are prohibited.

0x2e0355922EF3a5b77d29287C808aEafB4e7f25B2

Gnosis Safe multisig, 3-of-5 threshold (core team members and independent parties)

https://etherscan.io/address/0x2e0355922EF3a5b77d29287C808aEafB4e7f25B2

Governor Contract

Deployed for on-chain governance; not yet active

Ethereum

0x27cbB991EfF5E5c7b6734675E837EDDF924Ffece

OpenZeppelin Governor; sTURTLE token-weighted voting once activated

https://etherscan.io/address/0x27cbB991EfF5E5c7b6734675E837EDDF924Ffece

Rewards & Distribution Contract

Automated distribution of rewards and emissions; served as the genesis airdrop claim contract at TGE

BSC

0x56aa6D651bfefA9207B35E508716466359BAe8eF

Owned by the DAO Treasury Multisig (3-of-5)

https://bscscan.com/address/0x56aa6D651bfefA9207B35E508716466359BAe8eF

Staking Contract (sTURTLE)

TURTLE staking; sTURTLE carries governance voting power

Ethereum

0x2d362158034EEB28e1a7062F24FfC436b1D01858

Upgradeable proxy governed by an on-chain access manager

https://etherscan.io/address/0x2d362158034EEB28e1a7062F24FfC436b1D01858

TURTLE Token Contract

Immutable ERC-20, fixed supply of 1,000,000,000; no mint function, no pause role, no admin key

Ethereum & BSC (same address)

0x66fd8de541c0594b4dccdfc13bf3a390e50d3afd

Immutable contract; no administrative authority exists

https://etherscan.io/address/0x66fd8de541c0594b4dccdfc13bf3a390e50d3afd

CCIP Bridge Pool (Ethereum)

Lock-and-mint pool enabling cross-chain TURTLE transfers

Ethereum

0xd3bd7db2b40dbee54ca70a34921fde8a8d2f8bbb

Chainlink CCIP protocol; Turtle holds no unilateral bridge authority

https://etherscan.io/address/0xd3bd7db2b40dbee54ca70a34921fde8a8d2f8bbb

CCIP Bridge Pool (BSC)

Lock-and-mint pool enabling cross-chain TURTLE transfers

BSC

0x4559605e3003fda8c059e14af4f16ba9a004335a

Chainlink CCIP protocol; Turtle holds no unilateral bridge authority

https://bscscan.com/address/0x4559605e3003fda8c059e14af4f16ba9a004335a

CCIP Bridge Pool (Linea)

Lock-and-mint pool enabling cross-chain TURTLE transfers

Linea

0x7263bc9f9d2f94e9a3bcb3efb40c79c43ac0c647

Chainlink CCIP protocol; Turtle holds no unilateral bridge authority

https://lineascan.build/address/0x7263bc9f9d2f94e9a3bcb3efb40c79c43ac0c647

Investor & Contributor Vesting Wallet

Funds and creates every Sablier vesting stream for the Private Rounds and the Team, Advisors & Contributors allocations; holds tokens awaiting streaming and receives residual tokens when a stream is cancelled under the TMTIP leaver provisions. The 2,000,000 TURTLE repurchased from one advisor returned to this wallet on 4 September 2026 when that advisor's stream was cancelled, and is retained here.

Ethereum

0x74adb5972F13Af86ae5e911437b5f077CCc38E5C

Utila MPC custody wallet held by the Turtle Club Association (approval threshold 3 of the 4 authorised approvers, as disclosed in Section 4(e)); sole sender of all TURTLE Sablier streams and the only address able to cancel them

https://etherscan.io/address/0x74adb5972F13Af86ae5e911437b5f077CCc38E5C

Sablier Lockup (vesting escrow)

Escrows the vesting TURTLE for the Private Rounds (275M) and Team, Advisors & Contributors (231M) allocations, including the 13,000,000 TURTLE of advisor grants outstanding; releases tokens to recipients per each stream's schedule

Ethereum

0x93b37Bd5B6b278373217333Ac30D7E74c85fBDCB

Sablier Lockup protocol contract, non-upgradeable, no Turtle admin key; streams cancellable only by the Investor & Contributor Vesting Wallet above, solely under the TMTIP leaver provisions; recipients withdraw vested tokens directly

https://etherscan.io/address/0x93b37Bd5B6b278373217333Ac30D7E74c85fBDCB

Gate

None; no token allocation supplied or committed for listing

No listing lockup, liquidity program, or incentive program applies; the listing was facilitated through the market maker relationships disclosed in Section 12, with no separate listing agreement

None

MEXC

None; no token allocation supplied or committed for listing

No listing lockup, liquidity program, or incentive program applies; the listing was facilitated through the market maker relationships disclosed in Section 12, with no separate listing agreement

None

Policy controller: protocol-owned liquidity is a treasury asset of Turtle.Club Association. Any change to the POL strategy, including adding to, rebalancing or withdrawing the position, requires DAO governance approval and is executed by the Board of Turtle.Club Association under Articles 12 and 23 of its Articles of Association, through the 3-of-5 DAO Treasury Multisig. No standing mandate or discretionary authority to alter the position exists.

Unwind and exit policy: there is no time-based or automatic unwind schedule. The position is held to support continuous onchain liquidity for TURTLE. Any withdrawal or unwind would be a treasury action requiring the same governance approval and execution path described above.

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

No liquidity deals or purchased TVL exist. Turtle has not entered into any arrangement to purchase, rent, or otherwise acquire TVL, and no capital participates in the protocol under any such deal.

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

No token-secured loans or credit lines exist, including against unissued tokens. Neither the Association, the DevCo, nor any affiliated entity has borrowed against TURTLE, and no unissued supply is pledged as collateral.

DAO: treasury resources fund ecosystem growth distributions (subject to 7-day advance public disclosure of recipient category, amount, vesting, and rationale), campaign incentives, and the Association's operating budget. No resources flow to equity holders, and no distributions flow to token holders.

Lab/DevCo: not applicable; no such entity exists.

(d) Onchain Resource Usage

DAO: (1) DAO Treasury Multisig on Etherscan, https://etherscan.io/address/0x2e0355922EF3a5b77d29287C808aEafB4e7f25B2, and on BscScan, https://bscscan.com/address/0x2e0355922EF3a5b77d29287C808aEafB4e7f25B2: every treasury holding, inflow and outflow, including protocol fee receipts and governance-approved distributions. (2) Treasury dashboard, https://app.turtle.xyz/treasury: real-time view of current holdings, historical inflows and expense outflows across the labeled treasury wallets. (3) Governor contract, https://etherscan.io/address/0x27cbB991EfF5E5c7b6734675E837EDDF924Ffece: on-chain governance parameters (deployed, not yet active). (4) Staking contract, https://etherscan.io/address/0x2d362158034EEB28e1a7062F24FfC436b1D01858: sTURTLE staking balances that carry voting power. (5) Rewards distribution contract, https://bscscan.com/address/0x56aa6D651bfefA9207B35E508716466359BAe8eF: reward and airdrop claim events. (6) Airdrop claims dashboard, https://dune.com/3lixbt/turtle-airdrop-1-claims, and the per-address allocation list, https://github.com/turtle-dao/turtle-transparency: genesis airdrop distribution and claims.

Foundation (Turtle Club Association): (1) Transparency documentation and quarterly reports, https://docs.turtle.xyz/transparency: treasury position, inflows, operating expenses (including the Association's operating budget), token supply and vesting changes, and protocol metrics, published within 30 days of quarter-end; also hosts the Turtle Master Token Incentive Plan governing contributor and advisor vesting. (2) Contract and wallet registry, https://docs.turtle.xyz/token/contracts: canonical list of token, staking, bridge and treasury addresses. (3) Vesting for team, advisors and investors is executed through Sablier streaming contracts on Ethereum; individual stream addresses are published on the contract registry page above as streams are deployed, and each stream is viewable at https://app.sablier.com.

Lab/DevCo: not applicable; no such entity exists, so no dashboards or reports apply.

(f) References

Not applicable; no incident reports exist. Token contract and treasury addresses are independently verifiable at the explorer links provided in the Labelled Wallets section.

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