A narrative description of the purpose of the project and its operation in layman's terms is provided.
Turtle is the first Liquidity Distribution Protocol, effectively acting as a "matchmaker" and coordination layer for decentralized finance (DeFi). Purpose: Its goal is to solve "liquidity fragmentation" where billions in capital sit idle or inefficiently deployed across thousands of incompatible protocols. Turtle connects three key stakeholders: For Users (LPs): It acts as an aggregator (similar to Expedia for yields), simplifying access to high-quality, risk-adjusted returns through automated Vaults and Boosted opportunities without requiring users to navigate complex underlying protocols. For Protocols: It serves as an "Ecosystem-as-a-Service," helping new and existing projects attract the deep liquidity they need to function (cheaper and faster than traditional methods) by offering precise, performance-based incentives. For Distributors: It enables wallets and interfaces to monetize their user base by routing deposits through Turtle’s secure infrastructure. Technically, the protocol uses advanced indexing and APIs to track on-chain activity, ensuring rewards flow transparently to the most useful capital providers.
A narrative description of the Project's primary sources of revenue is provided, broken out by entity (e.g. Foundation, Labs, DAOs, or other).
Turtle DAO: The DAO exists and is the primary beneficiary of all protocol revenue. It captures value through multiple streams which flow directly to the DAO-controlled MultiSig Safe Wallet treasury: Boost Payments: The protocol negotiates additional shares of tokens or incentives from partner protocols for routing liquidity, generating over $6M in boost payments to date. Vault Fees: The DAO charges Performance and Assets Under Management (AUM) fees on its automated vault products. Ecosystem-as-a-Service: Campaigns run for partner chains and foundations generate payment streams for structuring and bootstrapping liquidity. Curation & Transaction Fees: Revenue is generated from utilizing deal flow for curation and transaction fee shares from the liquidity layer. Turtle. Club (Association): This entity exists as a Swiss Verein (Association) and operates as a non-profit with no equity shareholders. Its operations (legal, compliance, treasury management) are provisioned for by funding from the DAO treasury and protocol inflows, strictly to cover operational expenses necessary for protocol maintenance. Labs / DevCo: No such entity exists. There is no separate for-profit development company. The Core Team does not hold equity stakes in any entity and is compensated exclusively through TURTLE token allocations.
The Project must clearly disclose the rights, value accrual mechanisms, and distinctions between token holders and DevCo equity holders. Any value allocated specifically to equity holders (e.g., dividends, profit-sharing) must be communicated separately from value accruing to token holders.
If core team members are compensated by any Tokens allocated to the Foundation through advisory services or similar agreements, or by any other payment method (i.e. fiat), these payments must be disclosed. Note, foundation team members known and exclusively compensated by the Foundation are excluded.
16,000,000 TURTLE tokens (1.6% of the total supply) are allocated for advisory services.
Yes, token-based commitments exist. The protocol explicitly states that advisors are compensated only through token allocations, with no fiat payments or revenue sharing.
Turtle. Club Association (via the dedicated Advisor Allocation pool defined in the tokenomics).
The identities of key team members (e.g., founders, CEO, CTO, COO of Labs, President of Foundation, etc.) are publicly disclosed.
Labs / DevCo: No Labs or DevCo exists. The protocol explicitly states there is no for-profit development company with equity shareholders. Association: Turtle. Club Association (Swiss Verein).
The Project must provide publicly accessible documentation covering the Token's governance rights, rights to value accrual, any additional utility, and the mechanism by which token governance is implemented (e.g. an insider multi-sig).
TURTLE token holders must stake their assets to receive sTURTLE and delegate voting power to participate in governance. Token holders have the right to vote on protocol upgrades, treasury management, and strategic initiatives. Decisions regarding the "Ecosystem Growth" allocation and future token issuance also require governance approval.
Value accrues directly to the Turtle DAO Treasury, which is controlled by token holders. Protocol inflows include performance and AUM fees from Vaults, curation revenues, and Boost payments. The protocol explicitly states that no value accrues to equity holders (no dividends or profit sharing), as all revenue flows to the DAO.
The protocol utilizes OpenZeppelin's Governor Contract for on-chain voting.
Disclosed information explaining the launch and initial supply that includes: the total number of tokens issued, the category of the recipient (team, investor, foundation, community), the total supply of the token and if it is capped, and the initial vesting schedule.
Total Supply: 1,000,000,000 TURTLE. The supply is fixed and capped. Allocation Breakdown: Ecosystem / Community: 29.30% (293,000,000 tokens). Vesting: Governance-directed unlocks. Private Rounds (Investors): 27.50% (275,000,000 tokens). Vesting: 6-month cliff, followed by 36-month linear vesting. Includes Pre-Seed, Seed, Strategic, and Anchor LP rounds. Team, Advisors, Contributors: 23.10% (231,000,000 tokens). Vesting: 12-month cliff, followed by 36-month linear vesting. Airdrop: 12.10% (121,000,000 tokens). Vesting: Claim/linear per airdrop rules (No cliff). Liquidity, MM & Exchange Reserves: 8.00% (80,000,000 tokens). Vesting: 100% unlocked at Token Generation Event (TGE). Circulating Supply: 154,700,000 TURTLE (15.47%) as of October 22, 2025.
All Insider Token allocations (team, investor, foundation) must be transparent, per the disclosed Initial Allocation. If vesting occurs at a custodian, clearly disclose the employee categories and associated vesting schedules clearly in your documentation.
Status of Post-TGE Compensation: Currently, no distinct Post-TGE token compensation plans exist. All contributors, regardless of whether they joined before or after the Token Generation Event (TGE), are subject to the same standard vesting policy. Standard Policy for Future Hires: Any future employees or contributors hired Post-TGE will be subject to the following standard terms, aligned with the original team schedule: Cliff: Minimum 12-month cliff counting from the TGE date. Vesting: Linear vesting over 36 months following the cliff (totalling a 4-year duration). Alignment: No "fast-track" or discounted vesting schedules are offered to any new hires. TURTLE MASTER TOKEN INCENTIVE PLAN (TMTIP) Governing Body: Turtle Club Association, Zug, Switzerland Effective Date: October 22, 2025 (TGE Date) Last Updated: January 8, 2026
Addresses that hold any Unissued Tokens (e.g. foundation, future contributors, treasury) must be publicly labelled (address listed in docs) and be held in distinct wallets. This includes the foundation allocation. The party (e.g. team, foundation, DAO) that controls the funds must also be disclosed.
All Turtle protocol and treasury wallets are publicly labeled and verifiable on-chain. Each category uses a unique address with a disclosed controller. No Labs/DevCo entity exists.
The project must disclose all airdrop eligibility criteria clearly and provide a full CSV list of recipients, including addresses and amount received.
Status: Executed. 121,000,000 TURTLE (12.10% of total supply) distributed to approximately 144,000 on-chain participants at TGE on October 22, 2025. Eligibility Criteria: Segments: Users were scored based on the Turtle Liquidity Leaderboard, which tracked on-chain activity across partner protocols, partner NFT holdings, campaigns, and partner protocol interactions. Allocation Method:
Disclose information on insiders (Team, Investors, Foundation, Advisors) tokens that are locked and can earn rewards.
Do locked insiders earn rewards? No. Explanation: The protocol explicitly states that tokens locked in vesting contracts (covering Team, Investors, and Advisors) cannot be staked for sTURTLE or participate in governance until they are fully vested and claimed. Therefore, unvested insider allocations do not earn any staking rewards.
The project commits that any future token issuance (e.g., minting or emissions outside scheduled vesting) will be publicly disclosed and justified on an official platform (e.g., governance forum, blog, or docs).
Issuance Policy: The Total Supply is fixed at 1,000,000,000 TURTLE. Disclosure Commitment: Any distribution from the "Ecosystem Growth" allocation will be disclosed publicly at app.turtle.xyz at least 7 days before the distribution occurs. The disclosure will include the recipient category, amount, vesting terms, and business rationale. Future Minting: Any proposal to increase supply would require a quorum-based governance vote by the DAO.
The team discloses all tokens launched by its key team members in the past and explicitly lays out its philosophy around launching new tokens, related to the project or otherwise. (e.g. "We do not plan to launch additional tokens" or "Any additional tokens will be given 1:1 to existing token holders who can then vote on proposals submitted by the management team.")
None. No core team members have launched other tokens in the past.
The Core Team has a binding commitment NOT to launch any new tokens unless the following strict conditions are met: 60-Day Community Discussion period. Supermajority Governance Approval (66% threshold). Token Holder Protection: Must include a 1:1 airdrop to existing TURTLE holders or an automatic conversion mechanism.
The project commits to disclosing any material Related Party & Insider Transaction within 30 days and includes: The nature of the transaction, the Related Person, the basis on which the person is a Related Person, and the number of tokens involved in the transaction. This includes tokens issued by the foundation.
Turtle explicitly commits to the following policy: "Turtle commits to disclosing all material related party transactions publicly at docs.turtle.xyz/ within 30 days of execution." Each disclosure will include: Nature of transaction: Purpose and value. Related Person: Parties involved and their relationship to Turtle. Basis of Relationship: Detailed rationale. Number of Tokens: Token amounts involved.
Disclosed information of previous fundraising rounds, material OTC rounds to investors, or discounted market maker sales involving the Project and its Token that includes: the date of sale, number of tokens sold, and the vesting schedule of these tokens. The Project commits to disclosing any material OTC deal involving token sales and purchases by the foundation within 30 days.
The following prior token sales and distributions have occurred and have been successfully executed: Pre-Seed Round: Q1 2024. Sold ~5.58% of supply ($1.8M). Vesting: 6-month cliff, 36-month linear. Anchor LP Distribution: April 2024. Distributed ~2% of supply ($150M TVL). Vesting: 6-month cliff, 36-month linear. Seed Round: August 2024. Sold ~10.75% of supply ($4.3M). Vesting: 6-month cliff, 36-month linear. Strategic Round: October 2025. Sold ~9.17% of supply ($5.5M). Vesting: 6-month cliff, 36-month linear. Total: ~$11.6M raised for ~27.5% of the token supply.
Projects must disclose key details of market making and centralized exchange agreements affecting token liquidity, including: names of all market makers & centralized exchanges involved, the token allocation for each (as % of total supply), and the duration of each agreement.
Turtle currently has three active market makers, each engaged via a token loan with the Turtle. Club Association as lender. The aggregate active allocation across all three counterparties is 22,500,000 TURTLE (2.25% of total supply), drawn from the 8.00% Liquidity, MM & Exchange reserves. All allocations were 100% unlocked at TGE to facilitate immediate liquidity provision. Per-counterparty allocation figures are kept confidential in line with standard market maker practice; the aggregate figure above reflects the full active exposure. One earlier engagement (Selini Capital, structured as a 6-month retainer) was discontinued by mutual agreement and is disclosed below for completeness of the MM history. Market Maker Agreements (per partner):
The Project commits to providing updates to token holders on a quarterly basis via forum posts, live dashboards, or reports that cover core project KPIs, changes to Token supply or allocations, and disclosure of top line revenue and expenses. The Project may engage third-party contractors to prepare and deliver these updates.
Turtle explicitly commits to providing quarterly updates to token holders. Commitment: "Turtle commits to publishing comprehensive quarterly reports within 30 days of quarter-end at docs.turtle.xyz/transparency/ (we are building the first report now)." Content: These reports cover: Treasury Financial Position: Balances by asset type (ETH, stablecoins, etc.). Inflow Analysis: Protocol fees, partnership revenues, and yield. Operating Expenses: Team compensation, infrastructure, legal, and grants. Token Supply Changes: Vesting updates, distributions, and airdrops. Key Protocol Metrics: TVL, active wallet counts, and deal volume.
The foundation's assets or working capital are held onchain and publicly labelled, providing the ability to track asset holdings, revenue, and expenses. Or, the foundation publishes a quarterly, publicly available financial report of its assets, working capital, revenue and expenses.
Turtle applies a layered approach to financial transparency, combining real-time on-chain visibility with periodic off-chain reporting. On-Chain Dashboard (real-time): A public dashboard at app.turtle.xyz/treasury provides real-time visibility into current holdings, historical inflows, and expense outflows. All treasury wallets are publicly labeled on block explorers and independently trackable. Off-Chain Quarterly Reports: Turtle publishes quarterly transparency reports covering treasury position, revenue (protocol commissions and DeFi yield), operating expenses, net operating result, token supply and vesting changes, and key protocol metrics. Reports are published quarterly. Links:
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.
