S-Token Disclaimer

Effective 3 June 2026

This S-Token Disclaimer (this “Disclaimer”) governs the nature and treatment of S-Tokens made available for use within the Spondula ecosystem. In this Disclaimer, “Spondula”, “we”, “us” and “our” mean the operator of the Spondula wallet, identity, and Know Your Customer (“KYC”) infrastructure; “you” and “User” mean any person who accesses or uses that infrastructure; “Operators” mean the independent ecosystem participants described in clause 6; and “S-Token(s)” has the meaning given in clause 1.

1. Nature of S-Tokens

1.1  S-Token(s) are digital tracking instruments used within the Spondula ecosystem. Each S-Token is designed to track the value of a specified reference asset, which may be a currency, digital asset, commodity, or other recognised reference market. For example, USD-S is designed to track the value of the US Dollar, GBP-S the value of the British Pound, EUR-S the value of the Euro, BTC-S the value of Bitcoin, and GOLD-S the value of gold.

1.2  For the avoidance of doubt, S-Tokens are not money, bank deposits, electronic money, legal tender, savings accounts, or securities, and nothing in this Disclaimer shall be construed as representing otherwise.

2. No Ownership of the Reference Asset

2.1  Holding an S-Token does not constitute, and shall not be construed as, ownership of, or any proprietary interest in, the reference asset that the S-Token is designed to track. By way of illustration:

2.2  (a) holding USD-S does not mean you own US Dollars; (b) holding BTC-S does not mean you own Bitcoin; and (c) holding GOLD-S does not mean you own physical gold.

2.3  S-Tokens are designed to track value only, and do not represent ownership of, title to, or any claim against the underlying reference asset.

3. Role of Spondula

3.1  Spondula is a provider of wallet, identity, and KYC infrastructure. Spondula does not issue, buy, sell, exchange, redeem, broker, market make, or act as a counterparty for S-Tokens.

3.2  Nothing in this Disclaimer shall be construed as Spondula offering, soliciting, or facilitating any of the activities disclaimed in clause 3.1, whether directly or indirectly.

4. Determination of Value

4.1  The value of an S-Token is designed to reflect the external market value of the reference asset that it is designed to track.

4.2  For the avoidance of doubt, Spondula does not arbitrarily set, fix, guarantee, or change the value of any S-Token.

5. Liquidity

5.1  Liquidity within the ecosystem is provided by independent ecosystem participants, which may include Operators, liquidity providers, proprietary traders, and other network participants.

5.2  Spondula does not guarantee liquidity, execution, settlement, or the availability of any buyer or seller in respect of any S-Token.

6. Liquidity Profile of S-Tokens

6.1  Major Reference S-Tokens may benefit from broader liquidity support from independent ecosystem participants.

6.2  Specialist S-Tokens may depend more heavily on participant demand, market activity, and peer-to-peer liquidity.

6.3  The ability to sell, swap, or transfer an S-Token at any given time is subject to, and contingent upon: (a) available counterparties and ecosystem participants; (b) prevailing market demand; and (c) any applicable restrictions. Spondula does not guarantee that any such transaction will be available or completed.

7. No Investment Offering or Advice

7.1  Spondula does not market or offer S-Tokens as investments, and does not provide investment, financial, legal, tax, or other advice.

7.2  You are solely responsible for understanding the risks associated with S-Tokens before participating in the ecosystem, and nothing in this Disclaimer shall be construed as a recommendation or inducement to acquire, hold, or dispose of any S-Token.

8. Contact

8.1  Questions concerning this Disclaimer or S-Tokens may be directed to hello@spondula.com.