Regulatory information

Bitizenship Capital, SCR, S.A. (the "Company") is a venture capital company (sociedade de capital de risco) authorised by the Comissão do Mercado de Valores Mobiliários (CMVM) to manage venture capital and alternative investment undertakings under the Asset Management Regime approved by Decree-Law no. 27/2023 of 28 April. It is a small-sized management company within the meaning of article 7 of that regime, and it is subject to the supervision of the CMVM.

The authorisation was granted by decision of the Board of the CMVM of 16 July 2026. The Company is identified at the CMVM under entity code 210051. Its registration, the members of its board and the funds it manages can be checked in the public register of management companies on www.cmvm.pt.

The Company's statutory auditor is PKF & Associados, SROC, Lda. Company details (registered office, registration number and share capital) are in the legal notice.

The Company manages two closed-ended funds, both incorporated by private subscription under Portuguese law:

• Bitizen One, Fundo de Investimento Alternativo Fechado(formerly Unbound), CMVM registration no. 2089, managed by the Company from 1 November 2026 by resolution of the unit holders' general assembly of 23 October 2026;
• Aspect I, Fundo de Capital de Risco, CMVM registration no. 1660, managed by the Company since 1 September 2026.

For each fund the Company publishes on this website the net asset value per unit at each valuation date, a summary of the investment policy and the risks, and the documents in force. Annual and half-yearly reports are made available to unit holders in the investor area. Units are placed exclusively by private subscription, by the Company, on the basis of each fund's management regulation and key information document, after the assessment of the appropriateness of the investment for the investor and the identification and anti-money laundering checks required by law.

These statements are made under Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (SFDR) and Regulation (EU) 2020/852 (Taxonomy Regulation).

Integration of sustainability risks (article 3). A sustainability risk is an environmental, social or governance event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of an investment. The Company identifies sustainability risks as part of the due diligence on each investment and records its assessment in the investment memorandum submitted to the board. For the funds currently under management, whose investment policies target companies in the Bitcoin ecosystem and companies in the Portuguese real estate sector, the Company does not at present consider sustainability risks likely to have a material negative impact on returns. This assessment is reviewed at least once a year and whenever the investment policy of a fund changes.

Adverse impacts on sustainability factors (article 4). The Company does not consider the principal adverse impacts of its investment decisions on sustainability factors. The reasons are its size, the small number of investments it makes and the limited availability of reliable sustainability data from the unlisted companies in which the funds invest. The Company will reconsider this position as the assets under management and the data available grow, and will update this statement if it changes.

Remuneration (article 5).The Company's remuneration policy is consistent with the integration of sustainability risks: it does not reward excessive risk-taking of any kind, and variable remuneration, where it exists, is not linked to the taking of sustainability risks.

Funds under management. Neither fund promotes environmental or social characteristics or has sustainable investment as its objective (article 6 SFDR). The investments underlying these financial products do not take into account the EU criteria for environmentally sustainable economic activities.

The Company's remuneration policy is approved by its board and reviewed every year. Remuneration is mostly fixed. Any variable component is set by reference to the long-term results of the funds under management, to compliance with the law and with the Company's internal rules, and to the interests of the unit holders; it is not paid in a way that encourages risk-taking inconsistent with the risk profile of the funds. Given its size, the Company has no remuneration committee. The staff whose activity has a material impact on the risk profile of the funds are identified in the policy.

A copy of the policy in force is sent free of charge to investors who request it at hi@bitizenshipcapital.com.

The Company keeps a written policy to identify, prevent and manage conflicts of interest between the Company, the funds it manages, their unit holders and other clients, as required by the Asset Management Regime. The policy lists the entities it covers and the typical situations it addresses, including the relationships between the Company, the other companies of the Bitizenship group and the other activities of its founders, and the case of portfolio companies connected to the group.

Investment, valuation, risk management and compliance are allocated to different people. Where a conflict cannot be avoided, the unit holders concerned are informed and treated fairly. A summary of the policy is available on request at hi@bitizenshipcapital.com.

The Company also keeps policies on the valuation of assets, on the exercise of voting rights in portfolio companies, on the handling of personal data and on the prevention of money laundering and terrorist financing. Investors may ask for information on any of them at hi@bitizenshipcapital.com.

Investors and prospective investors may complain to the Company free of charge, by email to hi@bitizenshipcapital.com or by post to Rua Dom Pedro V, 410, 2.º, 4050-015 Porto, Portugal. The Company acknowledges each complaint, records it, examines it independently of the people involved and answers in writing. The procedure is described in the complaints policy, available on request.

Complaints may also be submitted to the CMVM, through its website www.cmvm.pt, and through the electronic complaints book at www.livroreclamacoes.pt.

Pages describing a fund are marketing communications. They summarise the fund's documentation, which prevails over them, and are kept consistent with it. They are not an offer or a solicitation and are not addressed to persons in any jurisdiction where their publication would be contrary to local law. The terms on which this website is made available are in the legal notice.