Conclusion
According to our analysis of the EU-level regulation and general legal framework of regulating
crypto assets having securities-like characteristics, we estimate that the Token is not likely to fall
within the general regulatory framework of financial instruments, specifically transferrable
securities, units in collective investment undertakings and derivative instruments, on the EU level
and within the majority of EU member states adopted EU general regulatory framework of named
financial instruments. The Token do not constitute an asset-referenced token or an electronic money
token according to the EU general regulatory framework.

Analysis
General Analysis
On 13 November 2017, the European Securities and Markets Authority (ESMA) issued the
Statement1 where ESMA noted that some tokens, but not all tokens automatically, may be
considered financial instruments and all activities connected with these tokens may constitute
regulated activity. ESMA did not provide any definite guidance on how to define whether a token
is a security under EU law or not. EU legal regulation does not have any analogue of the US Howey
test. In basics, EU securities legislation is quite complex due to two levels of regulation: the union
level and the national level. That means that applicable regulation approaches may vary from state
to state.

In order to bring certainty to crypto assets, the European Commission adopted Regulation on
Markets in Crypto-assets (MiCA Regulation)2. MiCA Regulation sets missing regulations for utility
tokens and asset-referenced coins as well as sets requirements for such tokens’ distribution.

Security-like tokens still remain within the securities framework and are not additionally regulated
by MiCA Regulation.

Crypto assets should be analysed through the perspective of the general EU legislation covering
financial instruments and financial markets that is represented by the EU Directive on markets in
financial instruments (MiFID II)3.

Analysis of the applicability of the transferable securities category

It is important to outline that MiFID II does not provide a definition of “securities” generally. By
analysing MiFID II, we can come to the conclusion that the class of transferable securities is the
closest class of financial instruments in the EU to classify security tokens, the same opinion is shared
by ESMA in its Advice on Initial Coin Offerings and Crypto-Assets4.

According to our knowledge of national legislation of EU members, most of the EU-member
countries implemented the definition of transferable security in a scope similar to the MiFID II
Directive scope. This European harmonisation regulation takes supremacy in the hierarchy of
sources and requires national authorities to avoid regulatory additions and to exercise their powers
in harmony with European provisions.

According to MiFID II, transferable securities are those classes of securities which are negotiable
on the capital market, with the exception of instruments of payment, such as:

shares in companies and other securities equivalent to shares in companies, partnerships or
other entities, and depositary receipts in respect of shares;

bonds or other forms of securitised debt, including depositary receipts in respect of such
securities;

any other securities giving the right to acquire or sell any such transferable securities or
giving rise to a cash settlement determined by reference to transferable securities,
currencies, interest rates or yields, commodities or other indices or measures.

In order to fall under this definition, the crypto asset should be “negotiable on the capital market”.
There is no approach set by any administrative guidance on the general EU level in order to
determine what is considered as negotiable on the capital market with specific relation to crypto and
crypto exchange activities. According to the already mentioned Advice on Initial Coin Offerings
and Crypto-Assets issued by ESMA, most EU-member states interpret negotiability as the potential
transferability or tradability of crypto assets, however, it is not set in legislation, rather it is the
opinion of regulators.

MiCA Regulation does not add additional rules on whether a token is negotiable on the capital
market. MiCA Regulation sets rules for whitepapers of crypto assets and requires issuers to disclose
that crypto assets may not always be transferable.

When analysing the Token and its model, we come to the conclusion that the Token will become
transferable from the day of its unlock to the purchasers (depending on the sale events).

When we analyse the Token’s tradability, we check the availability and the Company’s plans to
make the Token available on the secondary market as well as the easiness of transfer of Tokens
between parties. At the moment of making this Analysis, the Token is not listed neither at centralised
or decentralised crypto exchanges. Listing the Token at a centralised exchange and/or at a
decentralised exchange protocol allows any third party to purchase and sell Tokens. We consider
that the Token only becomes tradable upon listing on a crypto exchange. At the moment of making
this Analysis, the Token is not tradable.

However, a crypto asset should not only be negotiable on the capital market itself, but rather it
should have characteristics of a transferable security.

By analysing the definition of transferable securities, we come to the conclusion that the following
types of tokens may be considered transferable security: i) equity-like token, ii) debt-like token.
MiFID II and ESMA did not set any additional requirements or broad interpretation of the
transferable security definition similar to the Howey test (applied in the United States jurisdiction)
and its broad interpretation by the US SEC and its FinHub5.

The Token does not represent rights to any types of shares or stock in any company, partnership or
entity and does not have any classic characteristics of equity, the Token does not grant to its
purchasers and holders any typical rights of shares or stocks, including the right to receive dividends
from the Company or to receive a part of the Company’s profits or revenues, right to participate in
the Company’s share capital, right to participate in the distribution of the Company’s surplus assets
upon winding up of the Company, right to request allocation of any Company’s property or assets
in a return for Tokens. The holders of Tokens do not have the right to inspect Company’s corporate
books and records, to participate in Company’s shareholders meetings and to inspect the Company’s
minutes of shareholders meetings.

The ecosystem implements a tiered access model where project participants can commit or stake
Tokens to assist in trust confirmation and unlock progressive functional utility. Based on the tier
threshold, Token holders unlock premium AI models, advanced platform features, higher service
capacity limits and the ability to facilitate larger loan offerings for other ecosystem participants.
This staking mechanism also functions as a requisite security deposit to safeguard the SAALT’s
proprietary technology and mandate responsible governance. High-tier Token stakers are granted
early access to undisclosed beta features and new ecosystem initiatives, their staked Tokens act as
collateral against malicious or irresponsible activity. Should a user abuse these advanced privileges,
such as by executing the unauthorised public disclosure of confidential platform mechanics or
engaging in highly detrimental governance practices, the project implements a punitive confiscation
mechanism. Conceptually similar to the “slashing” mechanic utilised in Proof-of-Stake consensus
models, but executed natively at the application and governance layer, this allows the ecosystem to
revoke or burn the abusive user’s staked Tokens. This punitive structure inherently deters bad actors
and strictly enforces compliance with the project’s operational standards.

Furthermore, the economic rationale underpinning this staking mechanism is driven by functional
network necessity and operational efficiency rather than speculative financial yield. Because the AI
infrastructure relies on heavy, resource-intensive computational requests, staking serves as a vital
bandwidth allocation. By requiring a verifiable commitment of Tokens for trust confirmation, the
network effectively filters out malicious actors and prevents network congestion caused by
fraudulent requests. As was indicated by the Company, Token holders who stake higher amounts
will receive guaranteed bandwidth, lower latency and higher service capacity during periods of peak
network congestion.

For decentralised governance to function safely, voting rights must be placed in the hands of active,
long-term users rather than short-term market speculators. Staking acts as a verifiable metric of a
holder’s commitment to the SAALT ecosystem. By restricting governance capabilities (such as
voting on new AI models, platform upgrades or parameter changes) to those who have staked their
Tokens, the Company ensures that the technological roadmap is directed exclusively by the
enterprises and partners whose daily business operations depend on the ecosystem’s success.

It is imperative to establish from a regulatory perspective that the staking mechanism embedded
within the SAALT ecosystem is fundamentally devoid of any speculative nature. Unlike traditional
financial investment contracts wherein purchasers passively commit capital with an expectation of
monetary return driven by secondary market dynamics or the entrepreneurial efforts of a central
issuer, staking the Token is an active, operational prerequisite. As established in the project’s d
Documentation, the primary function of committing Tokens to the network is to facilitate trust
confirmation and to unlock progressive functional utility within the ecosystem. Network
participants stake tokens strictly to access higher service capacity limits, secure computational
bandwidth for proprietary artificial intelligence lender tools and obtain premium application
programming interface rate limits. The mechanism is conceptualised entirely around software
architecture and resource management rather than capital appreciation.

Consequently, the economic rationale underpinning this staking architecture is rooted in commercial
utility rather than financial speculation. The ecosystem ensures that incentives are inextricably
linked to the user’s active consumption of the SAALT project and their strict adherence to
operational standards. Because the Company is under no obligation to distribute ecosystem fees
solely based on the status of passive token ownership, there is no legal correlation between the act
of staking and the generation of speculative financial yield.

Participants who stake Tokens must assume a continuous, active role in maintaining data integrity
and engaging in responsible ecosystem governance. The staked Tokens act as a requisite security
deposit or digital surety bond. Should a user engage in malicious activity, submit fraudulent open
banking data or abuse early-access features, their staked tokens are subject to a punitive confiscation
mechanism executed at the application layer. This exposure to operational penalty requires
participants to act with persistent diligence, thereby thoroughly negating the passive expectation of
profit derived primarily from the efforts of others, which is a core tenet of identifying speculative
securities.

Ultimately, the staking architecture serves as a necessary technological safeguard against ecosystem
spam and resource depletion, ensuring that the heavy computational demands of real-time
underwriting and predictive analytics are sustainably coordinated. Therefore, the act of staking
Tokens is exclusively a functional software management tool. It provides tangible, commercial
sense for active platform users seeking guaranteed technological performance and remains entirely
distinct from speculative financial enterprises designed to generate rapid monetary returns for
passive holders.

The Token holders do not have intrinsic rights to claim financial returns and the Company is under
no obligation to distribute any part of its pre-allocated Tokens or project fees solely based on the
status of Token ownership. Receiving any potential staking yields or rewards depends entirely on
product adoption, network conditions and the active commitment of tokens to the network, which
may be changed, reduced or cancelled at the Company’s sole discretion.

According to the Token model adopted by the Company, the Token will not grant its holders rights
to vote on the corporate governance, corporate business strategy, corporate revenues and financials
or any other matters related to the entity. As was explained to the Legal Advisor by the Company
the Token model would provide Token holders rights to suggest and vote on matters connected with
the development and the evolution of the ecosystem and only upon reaching decentralisation of such
ecosystem.

In our opinion, the introduced rewards program does not bring either shares (stocks) or debenture
characteristics to the Token, and it does not bring the right to Token holders to receive any part of
the Company’s revenues. A reward for the provision of liquidity to the ecosystem is not a payment
of interest to Token holders and it is not a repayment of Tokens purchase.

No Token holders would be partners for any kind of joint venture and none of the Token holders
would be authorised to act on behalf of or make any decisions binding the Company or a community
of Token holders.

In our opinion, the Token is not likely to fall within the category of transferable security on the EU
wide level due to the absence of classic equity-like or debt-like features, however, it may fall into
national regulation of EU members if country-specific regulation would be adopted.

Analysis of the applicability of the category of units in collective investment undertakings

The second thing to be analysed for the EU region is the other relevant types of financial instruments
set by MiFID II: units in collective investment undertakings and derivative instruments.

In order to define a collective investment undertaking, MiFID II refers to the EU Directive on the
coordination of laws, regulations and administrative provisions relating to undertakings for
collective investment in transferable securities (UCITS)6, that in its turn sets the definition of an
undertaking for collective investment in transferable securities (UCITS) that means an undertaking with the sole object of collective investment in transferable securities or in other liquid financial
assets, financial derivative instruments, units in UCITS or money-market instruments and which
operate on the principle of risk-spreading; and with units which are, at the request of holders,
repurchased or redeemed, directly or indirectly, out of those undertakings’ assets.

The Company specifically confirmed to the Legal Advisor that the Company does not intend to
invest the proceeds from its Token sale in any transferable securities or other financial instruments
mentioned in the UCITS Directive, such as financial derivative instruments, units in UCITS or
money-market instruments. The Company specifically confirmed that it does not intend to take any
actions to influence the market price of Tokens.

There are no promises in the Documentation and the public communication of the Company to pool,
invest pooled assets in any property and further distribute any profits (or part of profits) from such
investing to Token holders. Moreover, as was previously discussed in this Analysis the ecosystem
incentivises only holders’ contribution to the ecosystem, validating of transactions and maintaining
consensus over the ecosystem or participating in governance, meaning that no token holders per se
are entitled to incentives, rather they would need to perform actions in order to become eligible to
such incentives.

Additionally, Token holders do not acquire any economic or legal claims over property or assets,
and the Token does not entitle holders to dividends, revenue, or profits. While tokens can be traded
on secondary markets, their primary purpose is to serve the function of a core asset of the protocol
and the ecosystem and be used for paying fees to the protocol and rewarding for the provision of
services to the protocol and the ecosystem. Token holders are not entitled to participate in the
distribution of the Company’s surplus assets in the event of its winding up. They also have no right
to request the allocation of any of the Company’s property or assets in exchange for their tokens

The proceeds from the sale of Tokens constitute the Company’s revenue. These funds will be
utilised by the Company for operational purposes, including but not limited to paying salaries to
team members and further developing the underlying software until its deployment and subsequent
decentralisation. It is important to note that the Company has not made any promises or
commitments to repurchase the Tokens from holders.

We consider that it is unlikely that the Company may be considered a UCITS under the UCITS
Directive, and Tokens are unlikely to represent units in a UCITS.

Analysis of the applicability of the category of derivative instruments

MiFID II sets the following types of derivative instruments: financial contracts for difference,
options, futures, swaps, forward rate agreements, any other derivative contracts relating to
securities, commodities, currencies, interest rates or yields, emission allowances or other
derivatives instruments, financial indices or financial measures, any other derivative contracts
relating to climatic variables, freight rates or inflation rates or other official economic statistics,
and any other derivative contracts relating to assets, rights, obligations, indices and measures.

A future means a contract to buy or sell a commodity or financial instrument on a designated future
date at a price agreed upon at the initiation of the contract by the buyer and seller. Every futures
contract has standard terms that dictate the minimum quantity and quality that can be bought or sold,
the smallest amount by which the price may change, delivery procedures, maturity date and other
characteristics related to the contract.

An option means a contract that gives the owner the right, but not the obligation, to buy (call) or sell
(put) a specific financial instrument or commodity at a predetermined price, strike or exercise price,
at or up to a certain future date or exercise date.

A swap means a contract in which two parties agree to exchange cash flows in one financial those
of another financial instrument at a certain future date.

A forward or a forward agreement means a private agreement between two parties to buy or sell a
commodity or financial instrument at a designated future date at a price agreed upon at the initiation
of the contract by the buyer and seller.

A financial contract for difference is a derivative product that gives the holder an economic right,
which can be long or short, to the difference between the price of an underlying asset at the start of
the contract and the price when the contract is closed.

Neither Token holders nor the Company or any third parties are subject to obligations similar to
specified above for the typical derivative contracts, and Token holders are not entitled to demand
from the Company any commodity or financial instrument to be sold to them, neither Token holders
are entitled to demand an exchange of cash flows in any financial instruments or a cash settlement
from any third party.

The value of the Token is not based on or relate to securities, commodities, currencies, interest rates
or yields, emission allowances or other derivatives instruments, financial indices or financial
measures, or any other assets, rights, obligations, indices and measures and is only determined based
on the current market demand for it, and the Token is not used to transfer credit risk.

We consider that it is unlikely that the Token would be considered as a derivative financial
instrument according to the provisions of MiFID II.

According to our analysis of EU-level regulation and the general legal framework of regulating
crypto assets having securities-like characteristics, we estimate that the Token is not likely to fall
within the general regulatory framework of financial instruments, specifically, transferrable
securities, units in collective investment undertakings and derivative instruments, on the EU level
and within the majority of EU member states adopted EU general regulatory framework of named
financial instruments.

Analysis of the applicability of the category of asset-referenced tokens or e-money tokens

MiCA introduces regulatory frameworks for stablecoins, specifically addressing two categories:
asset-referenced tokens and electronic money tokens.

An asset-referenced token means a type of crypto-asset that is not an electronic money token and
that purports to maintain a stable value by referencing another value or right or a combination
thereof, including one or more official currencies. And in its turn, an electronic money token (or e
money token) means a type of crypto-asset that purports to maintain a stable value by referencing
the value of one official currency.

Unlike asset-referenced tokens or e-money tokens, the Token does not maintain a stable value by
referencing fiat currencies, cryptocurrencies, a basket of assets, or other external benchmarks. Its
value is entirely independent of such references.

The price of the Token is intended to be determined solely by the dynamics of the secondary market.
There is no mechanism, algorithm or external stabilisation measure in place to artificially manage
or peg its price. The Token derives its value primarily from its utility within the project and
ecosystem. This includes roles such as paying for access to the software and AI transactions,
enabling governance participation and provision additional functionality for token holders. The lack
of any explicit or implicit commitment to maintain value stability further distinguishes the Token
from MiCA-regulated stablecoins.

The Token is not an asset-referenced token or an electronic money token under MiCA and is
therefore not subject to the specific regulatory requirements applied to stablecoins.