Listing and Delisting Procedure

Last Update: 27 June 2025

1. PURPOSE AND SCOPE

This Listing and Delisting Policy ("Policy") establishes the principles regarding the listing and delisting pursuant to the Capital Markets Law No. 6362 ("Law") and the Capital Markets Board ("CMB" or "Board") Communiqué on the Establishment and Operating Principles of Crypto Asset Service Providers numbered III-35/B.1 ("Communiqué on Operating Principles") and Communiqué on Operating Procedures and Principles and Capital Adequacy of Crypto Asset Service Providers numbered III-35/B.2 ("Working Principles Communiqué The OKX TR Kripto Varlık Alım Satım Platformu Anonim Şirketi (“Company” or “OKX TR”)  performs the listing and delisting procedures within the scope of the principles set forth in this Policy.

The Policy is published on the Company’s website pursuant to Article 22/2 of the Communiqué on Operating Principles. The Policy aims to promote the growth of blockchain technology, protect customer rights and interests and ensure transparency regarding the criteria for determining which crypto assets can be listed and delisted.

The Policy will enter into force as of 30 June 2025, and the obligations in this Policy shall apply as of the enforcement date.

2.GENERAL PRINCIPLES FOR LISTING

a.Listing Committee

i.Creation

Listing committee ("Listing Committee" or "Committee") consisting of at least 3 (three) persons ("Listing Committee" or "Committee") shall be established in order to make decisions regarding the listing and delisting of crypto assets and to check the compliance of the crypto assets to be listed in terms of the principles in this Policy.

The majority of the members of the Listing Committee must have at least 7 (seven) years of experience in finance, law, information technologies, information security and distributed ledger technologies and at least one member must be a member of the Company's board of directors. The roles and responsibilities of the units in implementing this Policy are outlined below:

ii.Mission

The Listing Committee prepares an assessment report on whether crypto assets are listable or not. According to the outcome of the evaluation report, crypto assets are listed or delisted.

The Company has sole discretion in this regard.

The Listing Committee, through its sub-committees, may create the reports whose names and contents are given below, and may make use of them in its evaluation report.

(a)Pre-Listing Report: This report provides details on the crypto asset’s classification, trading metrics, supply mechanics, processing speed and transaction costs, network reliability and consensus mechanism, transaction traceability, and regulatory status in Türkiye and abroad.

(b)Crypto Asset Due Diligence Research Report: This report contains at least a comprehensive description of the market, technical, regulatory and compliance-related aspects of the crypto asset. The Due Diligence Report consists of responses to a list of predetermined questions agreed upon by the Listing Committee or OKX TR.

(c)Compliance Analysis Report: Compliance Crypto Asset Listing Team analyst prepares the Compliance Analysis report. The Compliance Crypto Asset Listing analyst uses the information in the Research Report and conducts a compliance analysis assessing the risks of the project team and token ecosystem.

iii.Voting

Each member of the Listing Committee has one (1) vote and the vote of the absolute majority of the total number of members of the Listing Committee is required to determine whether the crypto asset is listed. If this majority is not achieved at the first meeting, a decision will be made by a simple majority of those present at the meeting.

b.Crypto Assets Available for Listing

i.General Principles

It is checked that the crypto assets to be listed on the Company contain the minimum elements required to be written in the smart contract in accordance with the legal nature of the crypto assets to be listed within the scope of Article 16/1 of the Communiqué on Operating Procedures and the accuracy of the contract and various similar transactions are carried out.

OKX TR ensures that crypto assets, which are capital market instruments for which it acts as an intermediary in issuance, are structured in a way that facilitates compliance with the principles and responsibilities outlined in the relevant regulations of the CMB. In this regard, for the listing of capital market instrument crypto assets, a commitment from the project team or issuer ("Project Owner") confirming that the conditions have been met may be requested.

OKX TR, in the case of the sale or distribution of assets falling under the regulatory jurisdiction of various institutions and organizations, ensures that the conditions set forth in the relevant regulations of these bodies are met and verifies that the smart contract is designed to comply with applicable regulations.

After the relevant regulatory provisions enter into force, the crypto assets to be listed on the Company must have an infrastructure suitable for custody and the custody service must be available.

ii.Non-Listable Crypto Assets

Crypto assets may not be subject to listing if they contravene any restrictions or prohibitions imposed by competent authorities on the issuance or trading of the underlying asset, or if they are intended to circumvent legal regulations or are of a nature to serve this purpose in substance.

Crypto assets issued in a way that provides unilateral and extraordinary powers to the project owner cannot be listed.

Crypto assets that are in violation of the legislation on laundering of assets arising from crime and financing of terrorism, and crypto assets belonging to project owners who are on national or international banned lists within the framework of Law No. 7262 cannot be listed on the Company.

Crypto assets classified as capital market instruments that do not satisfy the conditions stipulated in the applicable legislation shall not be eligible for listing. In this context, particularly pursuant to Article 13 of the Law, prior to any regulation issued by the CMB concerning the issuance of crypto assets as capital market instruments, capital market instruments defined under Article 3 of the Law (including securities, derivative instruments, and investment contracts, as well as other capital market instruments identified by the CMB), indices whose value is determined in relation to capital market instruments, baskets comprising various asset classes (including crypto assets), precious metals, and crypto assets issued based on underlying assets regulated by the Communiqué on Warrants and Investment Firm Certificates No. VII-128.3 shall not be issued or listed on Companys.

Crypto assets with significant compliance, legal, regulatory or reputational risks that are known to be used to increase secrecy such as privacy-based crypto assets , conceal the flow of funds, hide wallet address of recipient/sender during the transfer or facilitate illicit activities cannot be listed.

Crypto assets that cannot be custodied in cold wallets shall not be eligible for listing.

Except for the issuance of crypto assets in the nature of capital market instruments within the scope of Article 16/3 of the Communiqué on the Board's Working Procedures and the sale and distribution of assets that fall within the scope of regulation of different institutions and organizations as tokens within the scope of Article 16/4 and other crypto assets determined by the Board:

1. From crypto assets issued by the Company or real persons, their spouses and children under their custody, as well as partnerships in which they are partners with unlimited liability or in which they serve as chairman, member, general manager or deputy general manager of the board of directors,

2. crypto assets issued by the Company or by a legal entity, excluding public legal entities, or by partnerships in which the aforementioned persons participate directly or indirectly in 10% or more of their capital or voting rights,

(c) From crypto assets issued by persons and institutions that are determined by the Board to act together due to employment relationship, contractual relationship or other reasons,

Crypto assets that the Company first sells or distributes cannot be listed.

iii.Exemption

The provisions of this Policy shall not apply to non-replica and unique assets used to record the representation and ownership of digital assets and assets used only to create or provide various elements in virtual games.

3.CONSIDERATIONS IN THE EVENT OF LISTING AND DELISTING

a.In General

The Company will apply the following written procedures, approved by the Company's board of directors, in determining the crypto assets to be traded on the Company.

The Listing Committee may utilize, but is not limited to, the following persons or documents prepared pursuant to this Policy:

1. Crypto Asset Due Diligence Research Report

2. Pre-Listing Report

(c) Global Compliance Analysis

      b.Existence and Nature of the Right Granted to the User by the Crypto Asset

Crypto assets that grant the user one or more of the right to use, right to receive, right in rem or governance rights -such as ability to vote on key matters such as protocol upgrades, changes to rules, or other significant decisions- may be listed if they comply with the legislation and Board decisions.

The subject matter, cause or purpose of such rights or the underlying assets may not, in whole or in part, directly or indirectly, contravene the mandatory provisions of Turkish law. Crypto assets within the scope of this paragraph cannot be listed on the Company.

c.Crypto Asset Trading Volume and Circulating Supply

The Listing Committee analyzes the trading volume of the crypto asset in accordance with global standards and ensures that only crypto assets that are reliable and stable are available on the Company.

The Listing Committee may take into account the number of crypto assets in the market, their market capitalization and whether a significant portion of the crypto asset is controlled by a single person or group.

d.Crypto Asset Offering

If the Listing Committee considers that the supply of the crypto asset is limited, it shall take into account the trading volume, market capitalization and liquidity conditions.

In this context, measures can be taken such as, but not limited to, ensuring liquidity providers contribute to the creation of healthy markets with organic price discovery through the usage of agreements and controls to monitor market manipulation. In addition, for the sustainability of the project and the healthy development of the ecosystem, transparency regarding the circulating supply of the asset and the implementation of mechanisms to prevent supply manipulation may be required.

e.Transaction Speed and Related Asset Specific Cost

i.Process Speed

The listing committee takes into account the trading speed of the crypto asset. This review considers the presence or risk of network density-related fluctuations and whether they are persistent.

ii.Related Asset Specific Cost

The Listing Committee evaluates the transaction costs of the crypto asset. The Company does not prioritize the listing of assets with high network fees or additional fees that may result in unsustainable costs for clients, as this may negatively impact the client experience.

In this context, the project proponent may be asked to take measures to optimize network fees, create mechanisms to reduce costs, or provide solutions to increase transaction efficiency.

f.Reliability of the Crypto Asset and the Systems, including the Distributed Ledger Network, Associated with the Crypto Asset

The Listing Committee thoroughly assesses the security of the crypto asset project. If the project has network vulnerabilities, smart contract vulnerabilities, the risk of manipulation of decentralized finance protocols, fraudulent transaction generation or systemic vulnerabilities or other security threats, or if vulnerabilities in the main network or smart contracts are considered to pose a threat to the Company or its clients, the Committee may require necessary measures to be taken.

g.Tracking Crypto Asset Transactions

In accordance with the Company's principles of maximum transaction transparency and record- keeping, the Listing Committee prioritizes the listing of crypto assets whose transfers are traceable through the blockchain. This ensures that every transaction is recorded in a secure and auditable manner.

The Listing Committee decides whether the relevant crypto asset is eligible for listing, taking into account criteria such as the analyzability of the crypto asset's trading history, regular traceability of trading data, accessibility of project information and roadmap.

h.Price Movements of the Crypto Asset in Previous Periods

The Listing Committee may review the price movements of the crypto asset in the past periods in order to prevent market manipulation and to ensure that the Company's transactions take place in a more orderly and transparent environment. The review is based on maintaining market integrity and ensuring a fair trading environment.

The Committee considers the quantity and quality of suspicious price movements, frequency, trading volume and liquidity, erroneous transactions or blockchain failures, or price movements on previous exchanges.

i.Algorithmic Determination of the Value of a Crypto Asset

The Listing Committee determines and assesses whether the value of crypto assets is algorithmically determined.

j.Background of the Project Owner where the Project Owner is Known

The Listing Committee conducts a thorough background check on the company or project owner that made the initial sale or distribution of the crypto assets to be listed on the Company.

During this review, factors such as whether the project owner has been subject to any investigation for fraud or capital market crimes, whether the project owner has been subject to any allegations of these crimes in administrative authorities or in the press, the success of previous commercial projects and the existence of legal disputes related to these projects are taken into consideration. In addition, ethical values such as whether the project owner operates in an area that requires a license or permit, whether a bankruptcy application has been filed, financial problems such as insolvency or insolvency, and adherence to transparency principles are also evaluated. Intellectual property violations, security vulnerabilities and reputational damaging comments arising from the project owner's past projects are also taken into account and the suitability of the project is decided.

The Listing Committee also considers the terrorist financing, money laundering, sanctions risk perspective of the issuer of the crypto asset, the controlling owner and the management team of the crypto asset, including whether the crypto asset has an internal anonymization function, unless the project owner or the owner of the crypto asset and its trading history can be identified.

In the application of this provision, not only the project owner but also the team members involved in the project will be evaluated in the same way.

k.Representation of Other Assets or Legal Right Ownership of a Crypto Asset

The Listing Committee examines whether the crypto asset is linked to a physical asset or a legal right. During this review, it looks at whether the owner of the crypto asset can legally and factually exercise the right in question.

l.Status of the Crypto Asset According to the Regulations in Turkey and Abroad and Obtaining Approval

The Listing Committee examines whether the project is legally feasible. For crypto assets issued by Project Owners residing abroad and subject to the regulations of the country of issuance, it will also be taken into account whether the necessary approval has been obtained from the foreign regulatory authority for the project's implementation or whether the relevant regulations have been violated.

In addition, the following issues related to the project are also taken into consideration:

• Any existing negative media and public information about the project team and management team,

• Assessment of sanction controls over the project and management team,

• History of any previous investigations, lawsuits or sanctions by regulatory and supervisory authorities against the project team or the project,

• Assessment of geographic risk if the project team is registered in or operates in a jurisdiction considered high risk.

m.Ownership or Control over the Crypto Asset

The Listing Committee identifies those who have control over the crypto asset and assesses their impact on the network's security, decision-making processes and the overall structure of the network, in particular through the principle of decentralization.

n.Potential Security Risks Related to Crypto Asset Forking

A fork occurs when a community makes changes to the fundamental rules of the blockchain. This change leads to a split in the chain; although the newly formed chain initially carries the transaction history of the original chain, it continues on its own path thereafter. The Listing Committee analyzes the distribution of ownership and control in detail in order to identify violations of centralization that may negatively affect the security and governance processes of the crypto assets network. In this process, projects with decentralization risks may threaten the security and proper functioning of the network.

By distributing control of the network to more users, establishing staking systems, extending voting rights to a wider group of users, or creating a more secure consensus mechanism is essential.

o.Obligations Regarding Listing Agreement and Customer Agreement

The Listing Committee decides whether the Project Owner is eligible to enter into a listing agreement and whether the fundamental nature of the crypto asset is in line with OKX TR client agreements and terms of service.

p.Pre-Listing Blackout Period Implementation

The blackout period is the closing period of the trading window during which OKX TR executives and/or employees with access to information within OKX TR are prevented from trading, including any trading, on the crypto asset to be listed in order to maintain market integrity.

The trading window will open a reasonable time after the information of the crypto asset to be listed is made public. During the blackout period, OKX TR executives and/or employees may not engage in any transaction related to the trading of the crypto asset to be listed. In addition, the information that OKX TR has imposed a blackout period on the crypto asset to be listed cannot be disclosed to third parties by OKX TR directors and/or employees until the blackout period ends.

r. Issuance and Bidding Risks

The Listing Committee shall review the terms of the issue or other offer prepared by the issuer of the crypto asset in accordance with the principles in this Policy.

The terms of the issue and the terms of the offer must be acceptable from a commercial point of view or in accordance with the commercial policies adopted by OKX TR or the group of companies to which OKX TR belongs or in accordance with common decency.

s. Obligations of the Project Team

It is essential that the project team, especially critical personnel, have the commercial and moral reputation to ensure the continuity and stability of the project.

Hence the Listing Committee,

(a)Whether there is any negative news or information about the project team or owner, persons and groups having control over the project, and the management team that has been reported in the press or is publicly known,

(b)Whether politically important individuals or groups have influence over the project team or owner and those who have control over the project, and the sanctioning mechanism,

(c)Whether there have been any previous lawsuits or sanctions against the project team by regulatory and supervisory authorities, particularly the Board,

(d) The project team is registered or active in a jurisdiction considered high risk,

(e) The complexity of the cryptoasset, its operational characteristics and, if the cryptoasset and cryptoasset ecosystem has already been established by the project team, the ecosystem's practices regarding whether it uses open source code, documented peer reviews, whether other authorized exchanges and/or custodians support or delist the cryptoasset,

and makes an assessment by taking into account.

4.NO GUARANTEE OF LISTING

The listing of crypto assets on OKX TR does not imply any guarantee by OKX TR regarding these assets. OKX TR conducts its evaluations within the framework of listing standards, based on the statements it is aware of and has learned, and to the extent of such information. Customers are advised to conduct their own assessments regarding listed crypto assets, and to review the statements of the Project Owner as well as the whitepaper. Changes in the values of listed assets are not the responsibility of OKX TR and arise under free market conditions, beyond the capacity of OKX TR to intervene.

5.DELISTING AND OTHER MEASURES

a.Delisting and Suspension

If the crypto assets listed by the Company do not meet the principles specified in this Policy or if a different risk is detected, these crypto assets may be removed from the list based on the evaluation report prepared by the Listing Committee. In this context, the Listing Committee may reasonably determine that a crypto asset

• That it poses a significant compliance risk,

• That the crypto asset no longer adds commercial value to the Company,

• It is not appropriate to be listed under the provisions of this Policy or the relevant legislation, as detailed below, or

• Any other factor has arisen that poses an unacceptable risk to the Company or its customers

prepares the evaluation report to initiate the delisting process. According to the outcome of the evaluation report, it is decided whether to delist or not.

In lieu of delisting, the Listing Committee may decide on other sanctions deemed appropriate as long as they are in compliance with the legislation.

The vote of the absolute majority of the total number of members of the Listing Committee is sufficient for the suspension or delisting of the crypto asset from the list or for taking other measures and sanctions deemed appropriate by the Listing Committee.

Clients are notified at least seven (7) days in advance of the planned delisting via registered communication tools. In the event that the removed crypto asset is delisted by a global crypto asset Company, delisting may take place without waiting for seven (7) days, provided that at least one (1) day prior notice is given. One-day period may not be expected for delisting transactions due to extraordinary circumstances arising in global markets.

In the event that the Company or public authorities or judicial jurisdictions request that a crypto- asset has characteristics contrary to the principles in Articles 2.2.1 and 2.2.2 of this Policy, or if there is reasonable doubt about the reliability of the relevant crypto-asset or the systems of the associated distributed ledger network, crypto-assets may be removed from the list without waiting for a seven (7) day period; all purchase, sale and transfer transactions are stopped.

b.Transformation

OKX TR does not allow clients to trade in non-listable crypto assets, except as provided for in the legislation or as announced in the delisting decision.

The delisting decision will be notified to the clients and the project owner in accordance with this Policy and other policies and terms of the Company.

Upon the delisting decision, OKX TR may offer customers one of the following options

1. Conversion of a crypto asset into another crypto asset supported by the Company at current market prices, less the transaction cost;

2. Allowing customers to withdraw the crypto asset to a non-custodial wallet, provided that the unsupported crypto asset has such a feature;

3. Other transactions in accordance with the legislation and as decided by the Listing Committee.

c.Other Measures

Without prejudice to the relevant provisions of this Policy, the Listing Committee has the right to take any measures in accordance with the legislation, including the right to not disclose certain trading pairs on website or application or suspend trading.

Suspension can take place in the following ways, among others:

• Suspension of some or all trading pairs associated with the cryptoasset,

• Suspension of crypto asset deposits,

• Suspension of withdrawals of crypto assets

Before withdrawals are suspended, clients are given an additional period of time to withdraw crypto assets whose listing has been terminated.

d.Briefing the Listing Committee

i.Asking Questions and Requesting Documents

The Listing Committee may ask any questions, request information and documents from the Project Owner and any team involved in the OKX TR crypto asset listing process in order to conduct the reviews set out in this Policy.

OKX TR may request information and documents regarding the crypto asset and may take non- compliance with these requests into consideration when deciding whether to list the crypto asset.

The Listing Committee may conduct reviews at regular intervals or on an ad hoc basis to conduct the reviews set out in this Policy. During reviews, the project owner and the project team should make every effort to work in harmony with the Listing Committee.

e.Storage Of Records

OKX TR will retain all documents, communications and information relating to crypto assets under consideration for listing, suspension or delisting for ten (10) years after the listing, suspension or delisting decision is made by the Listing Committee, including, but not limited to

1. Names of the Listing Committee members involved in the decision-making process,

2. Listing Committee meeting minutes regarding the approval, disapproval, suspension or delisting of the listing of a cryptoasset,

(c) all documents reviewed by the Listing Committee in connection with the approval, 

(d) disapproval, suspension or delisting of the listing of a cryptoasset; and

Reviews and approvals by listing teams, if any, of all relevant crypto assets.

6.FINAL PROVISIONS

a.Collectivity of Grounds for Delisting

Since the reasons for delisting are integrated, the Listing Committee may prepare different evaluation reports and make different decisions for two similar crypto assets that come before it. The discretion in this regard belongs to the Listing Committee.

b.Discretion of the Listing Committee

In any case that prevents the crypto asset from being listed, the Listing Committee may require measures to be taken or undertakings to be given to eliminate the situation that prevents listing. The Listing Committee has the discretion in this regard.

c.Validity and Implementation

This Policy shall become effective as of 18 June 2025, upon approval by the Company's Board of Directors. It will also be published on the website.

7.REGULAR REVIEW AND APPROVAL

This Policy will be reviewed annually, or more frequently if necessary, by the Document Owner or the Document Author to ensure it remains up-to-date with regulatory changes and business practices. If deemed necessary (e.g., for the purpose of aligning with current industry practices or complying with new legislative requirements), it will be updated accordingly.

The Document Approver's approval is required at least once every year or when major and significant revisions are made, whichever precedes. Minor and limited revisions may be approved by the Document Owner, unless the Document Owner is also the Author.

The Listing Committee reserves the right to amend this Policy at any time, and any changes will be duly notified to customers.

8.RECORD KEEPING

A copy of this Policy will be retained for a minimum of ten (10) years or longer, in accordance with applicable legislation.