(a) Problem the project solves

1inch exists to advance a simple proposition, that financial services should be open, self-custodial, and accessible to anyone, anywhere. Decentralized infrastructure is the path to making that a reality. The challenge is that decentralized finance, as it exists today, has not yet fully delivered on that proposition. Liquidity is fragmented across networks and venues, price discovery is uneven, users are routinely exposed to value extraction they can neither see nor control, and cross-chain activity remains complex enough to push most users back to centralized custodians. Without a layer that resolves this fragmentation and protects the participant, DeFi remains an interesting technical experiment rather than a credible alternative to traditional finance. A second dimension of the problem is risk management. Decentralized finance has not yet built out the institutional-grade risk frameworks that traditional financial infrastructure takes for granted, and that gap is a meaningful reason broader institutional participation in DeFi has lagged. 1inch treats security and risk management, for users, integrators, and institutional participants alike, as a first-class engineering and operational priority, dedicating substantial resources to threat modelling, defensive product design, and the development of risk frameworks that let capital engage with on-chain markets responsibly. 1inch's current frameworkis set out in the 1inch Risk Management Whitepaper. 1inch builds the layer needed to close these gaps. It is the connective infrastructure that lets users transact across the decentralized economy with confidence, accessing liquidity wherever it sits, settling at competitive rates, retaining custody of their assets, and doing so under conditions designed to limit extractive inter med iation. The purpose is to make self-custodial finance not just possible, but the preferable choice.

(b) Operational priorities

Ongoing development and direction of the 1inch Network's open-source protocols sit under the 1inch DAO, which acts through the 1IP process (forum discussion at gov.1inch.network, Snapshot voting, on-chain execution via SafeSnap) against a DAO-controlled Treasury funded by redirected protocol revenue. Near-term priorities include:

• Build-out of the Aqua liquidity layer as a focal point for new protocol-level capabilities. The Aqua Revenue Stream Incubator already deploys Treasury funding to teamsbuilding yield strategies on Aqua, with profit share returned to the Treasury; additional Aqua-related initiatives are expected through the same process.
• Strengthening DAO treasury operations, including the establishment of dedicated working groups or specialised contributors to actively manage Treasury assets.
• Broadening community engagement through expanded utility of the 1INCH token across the network's protocols and governance layers.
• Exploring additional DeFi primitives and liquidity deployment surfaces beyond the network's existing aggregation, intent-based execution, and Aqua layers, to widen the set of on-chain activities available to users.
• Reinforcing security and protocol-level compliance: ongoing third-party audits, additional defensive layers across products and protocols, and alignment of protocol practices with emerging DeFi risk-management and compliance standards informed by recent regulatory developments. Taken together, these priorities are designed to keep the Network self-sustaining over time: protocol- and program-level proceeds routed back to the DAO Treasury, the continued role of the 1INCH token within the network's protocols and governance, and the gradual broadening of on-chain activity available through the Network are intended to fund development and operations on an ongoing basis. The 1inch Foundation acts as an off-chain steward supporting DAO operations and community-approved initiatives, and administers funds dedicated to broader network-development activities, including grants and strategic programs designed to support the long-term growth of the 1inch Network as a whole. Contributing development companies (see Section 5) build and maintain 1inch's user-facing products (Swap, Wallet, Portfolio, Card) and continue to expand work into the liquidity layer; operating proceeds from these activities are reinvested into further product development and brand-building. A parallel development companies’ priority is widening adoption among institutional participants, including support for tokenised real-world assets and institutional-grade product surfaces, to grow the Network's reach and brand recognition with that audience, which in turn reinforces the Network's broader visibility and adoption.

(c) High-level project overview

The 1inch Network is a suite of open-source on-chain protocols which, together with the 1INCH token contract, are governed by the 1inch DAO. At a high level the 1inch Network protocols operate across two execution modes that share a common router:

• 1. Classic aggregation (Aggregation Protocol / Limit Order Protocol). A user submits a swap or limit order; the protocol's pathfinder algorithm splits the order across AMMs, private market makers, and other liquidity sources across 13+ EVM-compatible networks (and, via Fusion+, between Solana and EVM chains) to produce the best executable rate.
• 1. Intent-based execution (Fusion / Fusion+). The user signs an off-chain order describing the trade and the constraints (minimum return, deadline). A network of whitelisted resolvers — professional market makers who must hold or be delegated 1INCH-derived Unicorn Power — compete in a Dutch-auction style mechanism to fill the order, paying gas on the user's behalf and bundling the fill with other transactions to neutralise MEV exposure. User-facing entry points include the 1inch web app, the self-custodial 1inch Wallet, 1inch Portfolio (analytics), 1inch Card (CryptoLife-powered spend/borrow). Builder-facing entry points include the 1inch Business developer and B2B portal and the underlying open-source contracts. Governance, staking, and delegation interfaces are hosted on the community domain 1inch.network, and forum discussion lives at gov.1inch.network.

(d) Primary token functions

The 1INCH token is the governance token of the 1inch DAO, with a secondary, governance-defined utility role inside the Fusion / Fusion+ protocols. Specifically:

• Governance. 1INCH holders deposit tokens into the time-locked governance staking contract (st1INCH) to receive Unicorn Power (UP), a non-transferable representation of voting influence that decays over time. UP is used to submit and vote on 1inch Improvement Proposals (1IPs) through Snapshot, with on-chain execution via SafeSnap against the DAO Treasury. UP also confers voting weight in Instant Governance over protocol settings.
• Delegation. UP can be delegated independently to (i) governance delegates on Snapshot and (ii) Fusion / Fusion+ resolvers. The same UP can be delegated to both layers without conflict, and the original holder retains the ability to override a delegated vote.
• Resolver utility (Fusion / Fusion+). Resolvers may choose to maintain order-filling rights by attracting delegated UP (the function is currently paused). This creates a merit-based market for execution access and ties professional market-maker participation to the same governance layer used by token holders.

(e) Control surface reliance

The 1inch Network operates under a community-led control model. In particular:

• All 1inch protocols are open-source and publicly verifiable. The 1INCH token contract is deployed on Ethereum (and bridged to BNB Chain); its mint function was permanently burned on-chain in April 2022, fixing maximum supply at 1.5B tokens.
• The protocols, the 1INCH token contract administration, and the parameters that govern Fusion / Fusion+ (including the resolver whitelist and the Fusion settlement contract) sit under the 1inch DAO, which acts through Snapshot voting executed against the DAO Treasury via SafeSnap. Tokenomics changes, treasury allocations, fee parameters, and resolver economics are determined by 1INCH holders through this process.
• Staking, delegation, and governance participation are coordinated through the community-operated 1inch.network domain and the gov.1inch.network forum.
• The 1inch Foundation serves as an off-chain steward supporting DAO operations, and the contributing development entities build and maintain user-facing products and contribute to ongoing protocol development. Neither retains unilateral control over protocol parameters, treasury allocations, or token. The anticipated evolution of this model centers on deepening community engagement: community-led incentive programs, and the formation of additional committees and operational working groups within the DAO that drive initiatives forward, coordinate execution between proposals, and provide early stage expert input through the governance process.

Labs/DevCo

Foundation Note on Foundation Directors. The names of the 1inch Foundation's Directors have been with held from this filing due to security concerns. Given that the Foundation does not exercise any direct or indirect control over the 1INCH token, its supply, contract parameters, or the DAO Treasury (each of which sits under the authority of the 1inch DAO as described in Sections 3 and 4 of this filing), the Project considers that anonymising the Directors' identities does not materially affect the transparency objective of this disclosure. The Directors' professional qualifications and relevant background are disclosed below.

DAO/Onchain Governance The 1inch DAO does not have formal "leadership" in the traditional corporate sense — control sits with 1INCH holders voting through the 1IP process. However, several individuals and groups play a key role in steering and operationalising governance, and we disclose them below for transparency:

• Governance Lead, Pranav Sanjay Pandit. Acts as steward between the operating entities (Foundation, DevCo), the DAO, and the Recognized Delegates; coordinates governance forum activity and supports the governance process.
• Legal Working Group (LWG). DAO standing working group responsible for legal, compliance, and governance risk review of proposals and DAO activity. Current functioning members include Kylyna-Anastasiia Zabrodska, Orest Gavryliak, Jordan
• Reindl, and Kene Ezeji-Okoye. The LWG is supported by external counsel MME Legal, aleading Swiss law firm engaged by the DAO.
• Recognized Delegate Program (RDP). The 1inch DAO operates a Recognized Delegates Program (currently up for renewal under the Recognized Delegate Program Renewal proposal) under which professional governance teams are funded to actively participate in 1inch DAO governance. Active recognized delegates include Anode (formerly StableLab), Arana Digital, Curia (curia-delegates.eth), DAOplomats, and Franklin DAO, evaluated through a points-based system covering governance call participation, working-group involvement, product/proposal delivery, Unicorn Power, and Snapshot voting participation.

(a) IP ownership & control

• The 1inch Network protocols and the 1INCH token contract are decentralized, owned, and governed by the 1inch DAO. All protocol codebases are publicly available and open-source at github.com/1inch.
• The intellectual property of the 1inch Network, including its protocols, codebase, and brand, is community IP vested in the 1inch DAO and the Community. Because the DAO is an on-chain collective without legal personality, it cannot itself register or enforce intellectual-property rights off-chain. To enable that purely off-chain enforcement function, registered brand and protocol IP rights are held by the development company Degensoft Ltd. (DIFC), acting as licensor solely for the purposes of protection and enforcement on behalf of the DAO and the Community. This is a common structure in DeFi: the registered holder provides the off-chain enforcement capacity that community-owned protocols require, while substantive ownership and governance authority over the underlying IP remain with the DAO.
• The 1inch.network domain is held by the 1inch Foundation for community purposes and protection, in line with the Foundation's mission "to foster the 1inch Network's growth and support initiatives that benefit the Community".

(b) Contract/ admin powers

The DAO operates through a combination of on-chain and operational authorities established under the Guidelines. The principal elements are:

• 1inch DAO Treasury Safe ateth: 0x7951c7ef839e26F63DA87a42C9a87986507f1c07 — a Gnosis Safe multisig with 12 signers initially appointed by the 1inch Foundation from core contributors and well-known industry projects. Treasury allocations require a DAO vote executed on-chain via SafeSnap; the multisig signers retain the ability to veto malicious transactions with a 7/12 approval quorum.
• 1inch DAO Operations Multi-sig ateth: 0x45e84e10e8E85c583C002A40007D10629EF80fAF — a long-standing 3-of-4 multisig used to administer DAO-approved working-group programs (e.g. Recognized Delegates Program funding).
• Governance executor. Snapshot voting is executed on-chain through SafeSnap (Zodiac module https://etherscan.io/address/0xa62d2a75eb39c12e908e9f6bf50f189641692f2e + reality.eth oracle https://etherscan.io/address/0x5b7dD1E86623548AF054A4985F7fc8Ccbb554E2c), with a 72-hour bonded escalation period plus an additional 72-hour Timelock before incorporation. During the Timelock period, the Treasury multisig signers may veto malicious transactions with the same 7/12 quorum.
• 1IP voting thresholds. Standard proposals: 5-day temperature check + 7-day Snapshot vote. To create a Snapshot vote a member must hold a minimum of 100,000 Unicorn Power; to pass, a proposal requires a 10,000,000 UP quorum and a majority of votes must be Yes. Guidelines amendments (§5.8) require at least 10M UP participation.
• Fast-Track Proposals. Limited streamlined process (24-hour forum + 48-hour Snapshot) restricted to: (i) deploying 1INCH on new networks (subject to technical viability), (ii) changes to the Governance Process, and (iii) changes surrounding 1inch Fusion Mode.
• Fast-Track proposals have no spending power or authority. Only whitelisted addresses may initiate Fast-Track proposals.

(c) Locked-token rights (conditional)

A locking/ staking mechanism exists. Holders of 1INCH must stake 1INCH in the 1inch governance contract (an on-chain action issuing non-transferable st1INCH) to receive Unicorn Power (UP) — the voting weight used in DAO governance. Staking is time-locked, with a minimum lock of 1 month and a maximum lock of 2 years (longer locks yield more UP, which then decays over time). Holders of staked 1INCH gain:

• The right to submit and vote on 1IPs through the Snapshot governance process (subject to thresholds for Snapshot submission).
• The right to delegate UP independently to (i) governance delegates on Snapshot and (ii) Fusion / Fusion+ resolvers — the same UP can be delegated to both layers without conflict, and the original holder retains the ability to override a delegated vote.
• The right to participate in Instant Governance over specific protocol settings. Through these mechanisms, holders collectively control all matters within the DAO's scope ofresponsibility (as defined in 1inch DAO Guidelines), including the governance of all 1inchNetwork protocols; the smart contract, features and other characteristics of the 1INCH token; the rules and processes of governance itself (staking, delegation, the 1IP framework); the 1inch DAO Treasury and its allocation; the 1inch.network community domain (administered by the Foundation on behalf of the Community); and the ability to initiate new programmes, working groups, and ecosystem initiatives. Holders cannot decide matters outside the DAO's scope of responsibility and the operations of independent legal entities, such as operations of 1inch Foundation, development companies, and direct control of user-facing product layers (1inch Business, 1inch dApp, 1inch Wallet, etc.).

(d) Value accrual & holder rights

Tokenholders currently have no direct economic rights over protocol revenue or treasury assets. Protocol revenue is routed to the 1inch DAO Treasury and is controlled collectively by 1INCH holders through the proposal process; there is no dividend, fee-share, revenue-share, buyback, or other passive economic distribution from the protocols, the Treasury, or the 1inch token to individual tokenholders.

(e) Dissolution authority

The 1inch DAO has no formal mechanism for unilateral dissolution by any single party. The DAO is constituted by the 1INCH tokenholder community and the on-chain governance contracts. Accordingly, any wind-up, reorganisation, or material change to the DAO's structure would require a 1IP through the full 1IP lifecycle (Phase 1 discussion → Phase 2 formalisation → Phase 3 temperature check → Phase 4 Snapshot vote, satisfying the 10M UP quorum and majority Yes threshold). There is no individual director, founder, or external party with unilateral authority to wind up or dissolve the DAO.

(a) Entity

The 1inch Foundation is a Cayman Islands foundation company (an entity formed under the Cayman Islands Foundation Companies Act, 2017) operating as an independent non-profit organisation, as described in the 1inch DAO Guidelines. Its mission is to foster the 1inch Network's growth and to support initiatives that benefit the Community.

(b) IP ownership & control

The Foundation's only material IP-adjacent holding is the 1inch.network community domain, which it administers on behalf of the Community in line with its statutory mission. The Foundation has no subsidiary entities.

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

None. The Foundation is an independent steward with its own independent treasury. It does not exercise governance powers over the 1inch DAO, has no unilateral authority over the 1inch DAO Treasury, has no claim on or control over protocol-controlled resources, and has no authority over the administration of the 1INCH token or any reward parameters. For the avoidance of doubt: while the Foundation was the original issuer of the 1INCH token at the Network's December 2020 launch, the token's mint function was permanently burned on-chain in April 2022 and the token contract has since sat within the 1inch DAO's scope of responsibility under Guidelines §4.3.2. The Foundation does not retain any administrative, mint, upgrade, or issuance authority over the 1INCH token contract. The Foundation acts on the DAO's behalf only (i) when expressly requested or instructed by the DAO through the 1IP process, or (ii) where DAO-approved proposals necessarily require off-chain execution.

(d) Powers over DevCo

None. The 1inch Foundation does not exercise direct or indirect influence over the decision-making of the contributing development company (Degensoft Ltd.) or any other development entity. The Foundation and the DevCo are independent legal entities with no shared shareholding, no shared control, and no contractual hierarchy between them.

(e) Contract / admin powers

None. The Foundation has no pause, upgrade, or governance-executor authority over any of the 1inch Network protocols or the 1INCH token contract.

(f) Current economic arrangements and distribution policies

None. No current governance-approved, contractual, or programmatic mechanism exists by which protocol-controlled resources, DAO Treasury assets, fees, revenue, rewards, or ongoing token distributions are directed to the 1inch Foundation, its directors, contributors, or other participants. The Foundation operates from its own independent treasury and does not receive any ongoing or programmatic flow of value from the protocols or the DAO Treasury.

Scope of this section. The Blockworks definition of "Primary DevCo" anchors to the entity directly involved in the issuance of the native token at launch. For the 1inch Network this is a two-part disclosure:

• At the Network's December 2020 token launch, the primary DevCo was 1inch Limited (1L). For clarity, 1inch Limited was not itself involved in the launch or issuance of the 1INCH token — as described in Section 4, the original token issuer was the 1inch Foundation, and the token's mint function was subsequently permanently burned on-chain in April 2022. 1inch Limited's role at the time was that of a major Network contributor building and developing 1inch products and infrastructure.
• Following a corporate restructuring completed in 2025, the DevCo function (building and maintaining 1inch's user-facing products) has been carried out by Degensoft Ltd. (BVI), which absorbed the operational obligations previously sitting at 1inch Limited. 1inch Limited no longer operates as a development company today. For transparency and completeness, the responses below cover both entities. Where a response applies equally to both, that is stated; where the answer differs, the difference is noted.

(a) Entity

• Degensoft Ltd. — a British Virgin Islands (BVI) company limited by shares. Acts as the current primary DevCo, responsible for building, maintaining, and operating the 1inch Network's user-facing products.
• 1inch Limited (former DevCo at TGE) — also a British Virgin Islands (BVI) company limited by shares. Was the primary DevCo at the Network's December 2020 launch. As a result of the 2025 restructuring, its operational obligations were transferred to Degensoft Ltd.; 1inch Limited no longer holds active DevCo responsibilities.

(b) IP ownership & control

• Degensoft Ltd. (BVI) owns certain product-level assets associated with the user-facing 1inch products it operates (e.g. operational tooling and product-specific code that is not part of the community-owned protocol layer). These product-level assets are not part of the DAO-vested IP and are not under the control of the DAO. As described in Section 3(a), the Network's protocols, codebase, and brand IP are community IP vested in the 1inch DAO and the Community. Degensoft Ltd. (BVI) holds a license for the brand assets it uses to operate the 1inch products, and does not itself hold or control DAO IP.
• Degensoft Ltd. (BVI) has no subsidiary entities for the purposes of this section.
• 1inch Limited holds no operational assets today; 1inch Limited is not the licensor nor a licensee of any DAO IP and does not control any 1inch products.

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

None, neither Degensoft Ltd. nor 1inch Limited. Neither entity exercises governance powers over the 1inch DAO, has any unilateral authority over the 1inch DAO Treasury, has any claim on or control over protocol-controlled resources, or has any authority over the administration of the 1INCH token, supply, or reward parameters.

(d) Powers over Foundation

None, neither Degensoft Ltd. nor 1inch Limited. Neither DevCo exercises direct or indirect influence over the decision-making of the 1inch Foundation. The DevCo entities and the Foundation are independent legal entities with no shared shareholding, no shared control, and no contractual hierarchy between them.

(e) Contract / admin powers

None, neither Degensoft Ltd. nor 1inch Limited holds pause, upgrade, or governance-executor authority over the 1inch Network protocols or the 1INCH token contract as a company. Where individual contributors are signers on protocol- or DAO-administrative multi-sigs, those multi-sig roles are held by such contributors in their independent personal capacity, not as representatives of, or under the direction of, Degensoft Ltd. or 1inch Limited. Such individual roles are not formally recognised as corporate powers of either DevCo and the entities do not direct or coordinate the exercise of those keys.

(f) Current economic arrangements and distribution policies

No protocol-level fees currently are enforced on the 1inch Network, and consequently there is no current governance-approved, contractual, or programmatic mechanism by which protocol-controlled resources, DAO Treasury assets, protocol revenue, rewards, or ongoing token distributions are directed to Degensoft Ltd., 1inch Limited, their shareholders, contributors, or other participants. For transparency, because two categories of fees may be visible to users on the 1inch interface and would otherwise invite questions, the nature of those fees is as follows:

• Infrastructure fees. These originate at the API and interface integration level (i.e. at the layer that Degensoft Ltd. operates), not at the protocol level. They are received by Degensoft Ltd. as compensation for the operational services it provides in building, maintaining, and operating the user-facing products and API stack. They are not protocol revenue and are not paid out of the DAO Treasury.
• Swap surplus. Where execution conditions in a given trade leave a residual amount beyond the user's minimum return, that surplus is captured at the interface layer and likewise accrues to Degensoft Ltd. as compensation for the services it provides at that layer. The mechanism is determined by market conditions of each individual trade and is not a protocol-level distribution. Neither of the above is a protocol fee, neither is a distribution from the DAO or its Treasury, and neither is paid to 1inch Limited.

(a) Launch supply totals

• Total tokens issued at genesis: 1,500,000,000 1INCH (full max supply minted at genesis on 25 December 2020).
• Tokens locked at launch (held in vesting contracts): ~94% of total supply (~1.41B 1INCH) was held in time-locked vesting contracts at genesis.
• Tokens unlocked at launch (initial circulating supply): ~6% of total supply (~90M 1INCH) was initially circulating, comprising the initial airdrop to early protocol users and the initial liquidity mining program (the first two weeks of which contributed an additional ~0.5%).

(b) Recipient categories & use of funds

(c) Initial price per token

There was no fixed public offering price at launch. The 1INCH token was distributed via (i) an airdrop to early protocol users and (ii) initial liquidity-mining incentives, with secondary-market trading then beginning on third-party exchanges. The initial market-set price was therefore determined by exchange supply and demand from the first day of trading rather than by a fixed offering price set by the project.

(d) Ticker / market symbol

1INCH

(e) Total supply & supply regime

• Maximum total supply: 1,500,000,000 1INCH.
• Supply regime: Fixed (hard-capped). The 1INCH token contract's mint function was permanently burned on-chain in April 2022, structurally fixing the maximum supply at 1.5B 1INCH.

(f) Initial vesting / release schedules

All six recipient buckets were subject to vesting at genesis. The high-level timing logic was as follows:

The 1inch Network has already executed airdrop distributions. The disclosures below cover the principal airdrop events. A consolidated public registry of 1INCH claim transactions across all distributions describedbelow is available at: 1INCH-token-public-distribution-registry.csv. The registry sets out, perclaim: chain, distributor contract address, timestamp, 1INCH amount, recipient wallet address, and transaction hash.

(i) TGE Airdrop

25 December 2020 User segments covered: Early users of the 1inch aggregator who had interacted with the 1inch dApp prior to the airdrop snapshot. Allocation method: Eligibility required a wallet to have interacted with the 1inch dApp before 00:00 UTC on 24 December 2020, and to have met at least one of the following thresholds:

• at least one trade before 15 September 2020; or
• at least four trades on the 1inch dApp at any time before the snapshot; or
• at least US$20 in cumulative trade volume on the 1inch dApp before the snapshot. In addition, participants in the 1inch Mooniswap liquidity-mining program received an allocation based on their participation in that program. Recipient scale: Approximately 90,000,000 1INCH allocated; approximately 55,200 eligible addresses at launch. (ii) Secondary Airdrop / Retrodrop — early 2021 A subsequent retrodrop distribution allocated approximately 15,055,000 1INCH across several user segments:
• Mooniswap users (retrodrop): ~4,800,000 1INCH to ~9,094 addresses that had interacted with Mooniswap prior to the December 2020 snapshot.
• Second liquidity-mining participants: ~3,570,000 1INCH to ~1,308 addresses that participated in the second liquidity-mining program.
• Uniswap-only users: ~6,000,000 1INCH to addresses that had never previously swapped on 1inch or Mooniswap but met activity thresholds on Uniswap (at least 20 unique trading days and at least 3 trades during the qualifying period in 2021).
• Limit Order Protocol users: ~310,000 1INCH to active users of the 1inch Limit Order Protocol.
• Smart-wallet users: ~375,000 1INCH to users of Argent, Authereum, Gnosis Safe, and Pillar wallets. (iii) Ongoing event-based airdrops The 1inch Network has also conducted a series of small, event-based drops — distributions of 1INCH tokens at industry conferences and community events using NFC and QR-code claim mechanics. Each event-based drop allocates a fixed per-claim amount of 1INCH. These drops are small in aggregate and are administered through individual Merkle-distributor contracts deployed for each event (e.g. Denver, Lisbon, Davos, ETHCC, Token2049, ETH Global, and other industry events). They are not material to the network's overall supply but are disclosed here for completeness.

Score: Partially Complete

The Project maintains a limited number of arrangements with reputable professional market makers, the sole purpose of which is to support healthy exchange liquidity for the 1INCH token on third-party trading venues. The specific commercial terms of each arrangement (counterparty identity, allocation size, structure, and duration) are subject to mutual confidentiality and are not disclosed in this filing.

The 1INCH token is listed on third-party centralized and decentralized exchanges through ordinary, arms-length listing processes. As of the date of this filing, there are no native-token agreements or deals with centralized or decentralized exchanges under which native 1INCH tokens are committed, locked, or otherwise allocated for the purpose of listing, liquidity provision, or incentive programs; no listing fees have been paid in native 1INCH tokens by the 1inch DAO, the 1inch Foundation, or any contributing development company acting on behalf of the community.

All prior token-related fundraising by the Project was conducted as private, off-market (OTC) sales. The Project conducted three private fundraising rounds:

Note. The event-level token figures below reflect each round's actual final closing position. These figures may differ to certain extent from the initial allocation buckets disclosed in Section 6, as round sizes evolved during each closing period as investor demand grew, and some intra-bucket reclassifications between rounds were made through the closing process.

No exploits affecting the native 1INCH token, the 1INCH token contract, token supply, tokenholder balances, minting controls, burn mechanics, or custody of token supply have occurred as of the date of this filing. For the avoidance of doubt, this section is scoped — consistent with the Blockworks rubric — to incidents that directly affected the native 1INCH token itself, and not to general protocol, application, or smart-contract incidents that did not affect the token. Technology, Token Economics)

A. Regulatory, Legal & Tax Risks

Impact of regulatory change on TGE and listings. The 1INCH token has been live and freely circulating since its December 2020 launch, and its initial distribution is complete (see Sections 6 and 7). The regulatory environment for crypto tokens, including governance and utility tokens, continues to evolve in major jurisdictions through ongoing legislative processes and interpretive guidance, and the Project monitors developments on an ongoing basis. As at the date of this filing, recent developments are supportive of the 1INCH token's governance and utility characteristics, and the Project remains confident in the token's current standing. Accordingly, the Project does not foresee a regulatory event that would impair the token's ability to circulate or remain listed on the venues where it is currently traded. A theoretical worst-case scenario — a future change in law in a major jurisdiction that re-categorised 1INCH-class governance tokens as a regulated financial instrument — could in principle introduce restrictions on how the token may be held or transferred. The Project considers this scenario remote on the basis of the token's utility-centric design and the current regulatory direction, but flags it for completeness. Regional differences in legal treatment will, in any case, persist and require ongoing monitoring; that monitoring is performed by the 1inch DAO Legal Working Group (LWG, see Section 2) with the support of external counsel (MME) on behalf of the DAO and the Community. Entity-level regulatory impact. Regulatory or legal change is always capable of affecting the operating entities described, for example through new licensing requirements, enforcement priorities, or jurisdictional restrictions. The Project's response to this risk is a substantial, ongoing investment in regulatory and compliance risk management: 1inch publishes its currentrisk-management framework in the 1inch Risk Management Whitepaper, dedicates internal andexternal legal resources (including the LWG and MME engagement) to monitoring jurisdictional developments, and adjusts entity-level processes as the law evolves. The entities operate as legally required in their respective jurisdictions and remain alert to material changes. Tokenholder tax. Tax treatment of 1INCH and any associated activity is jurisdiction- and circumstance-specific. Each holder is solely responsible for understanding and complying with their own tax obligations and should seek qualified independent tax advice. Neither the DAO, the Foundation, nor any contributing development company provides tax advice. Jurisdictional & user access restrictions. Access restrictions implemented by the Project apply at the user-facing product level only: the 1inch dApp, the 1inch Wallet, 1inch Card, and B2B surfaces operated by the contributing development company observe applicable sanctions regimes and restrict access for sanctioned countries and certain other jurisdictions as required. These restrictions cannot be imposed at the protocol level because the 1inch Network protocols are open-source, on-chain, and permissionless, and the 1INCH token trades on secondary markets that the Project does not operate or control. Note on this Section. The discussion in this Section 12.A is provided for general information only and does not constitute legal, regulatory, or tax advice. No reliance should be placed on any statement in this Section; no legal, advisory, or fiduciary relationship is created between 1inch and any reader by reason of this disclosure.

B. Protocol, Technology & Security Risks

Bugs and design flaws. 1inch reduces the risks of any latent bugs, design flaws, or implementation errors through independent security audits, publicly available audit reports, bugbounty programme via HackenProof, liquidity-provider level controls, and emergency pausemechanisms in relevant contracts. The Project also operates a formal incident-response framework supporting rapid identification, triage, and remediation of security events, with findings systematically fed back into product hardening and security-control improvements. Security measures. Multi-layered: (i) multiple independent third-party audits per protocol and/orproductl, with reports and source code public on github.com/1inch; (ii) an ongoing public bugbounty programme via HackenProof; (iii) the Network's broader security and risk-managementframework set out in the 1inch Risk Management Whitepaper. As with any complex softwaresystem, these measures reduce but do not eliminate residual risk of latent bugs or novel attack vectors.

C. Token Economics, Unlocks & Incentive Risks

Critical economic assumptions. None of a financial-economics nature. The 1INCH token is a governance token, it is not designed as a yield-bearing, fee-share, staking-reward, MEV-capture, or other instrument dependent on persistent financial-economic assumptions. The full token-supply schedule has vested, so there are no remaining vesting-cliff or scheduled-supply risks. Governance control over monetary policy and rewards. All matters relating to the 1INCH token and to network-level economics within the DAO's scope sit under DAO authority and are decided through the governance process. Material changes are shaped and reviewed by the DAO's professional governance ecosystem (Recognized Delegates, LWG, engaged community participants), and the Project considers it unlikely that proposals materially adverse to tokenholders, regulatory clarity, or network safety would pass that process. Governance outcomes can nonetheless not be guaranteed — that is a structural feature of decentralised governance.