Young Platform S.p.A., as an authorised provider of transfer services for crypto-assets on behalf of clients under Regulation (EU) 2023/1114 (“MiCAR”), makes available to its clients this summary of the service and of the related safeguards. The Company can be contacted at [email protected] and [email protected] and is subject to supervision by Consob. This notice is provided pursuant to Article 82 of Regulation (EU) 2023/1114 (“MiCAR”) and to the ESMA Guidelines on transfer services for crypto-assets (ESMA35-1872330276-2032); as regards anti-money laundering aspects, Regulation (EU) 2023/1113 and the related EBA Guidelines apply.

Subject matter. The service allows the client to instruct Young Platform S.p.A. to transfer crypto-assets, by means of on-chain deposit or withdrawal operations, from one address to another address indicated by the client, including to external custodial or non-custodial wallets. Transfers of fiat funds and mere intra-platform movements without an actual on-chain transfer are excluded. The service does not involve the exchange of crypto-assets and is distinct from the custody service, to which it remains functionally connected.

How the service works. The client issues the instruction through the platform interface, indicating the crypto-asset, the network (DLT protocol), the destination address and the amount. Before execution, the Company verifies the availability of the crypto-assets, the formal consistency of the data and the outcome of the prescribed controls, including anti-money laundering checks. Once confirmed and recorded on the DLT, the transaction generates a confirmation with the relevant traceability references. For each crypto-asset, the supported networks (DLT protocols) are indicated, available in the up-to-date list at the following link: https://exchange.youngplatform.com/fees, and as an annex to the Platform’s general Terms & Conditions; where the network provides for it, the client must also indicate any memo/tag/destination tag. The instruction is deemed received at the time of the client’s confirmation; the client may revoke the instruction only until the moment it has not yet been transmitted for execution. The Company indicates a maximum execution time of 2 (two) hours — which may extend up to 24 (twenty-four) hours in the case of manual controls — separate from the time required for on-chain finality. The Company may refuse the instruction in the case of incorrect or incomplete data, unsupported network, unavailability of the balance, outcome of anti-money laundering checks, or absence of the data required by the rules governing transfers.

Warning before execution. Before confirming each transfer, the client is shown a clear and concise warning indicating whether and when the transfer becomes irreversible (or sufficiently irreversible), together with a reasonable estimate of the time or of the number of block confirmations required for each network, as well as the amount of the fees due.

Anti-money laundering obligations (Travel Rule). The Travel Rule applies to all crypto-asset transfers carried out by Young Platform as a CASP. The scope of application reflects exclusively the Company’s authorised business model, with an explicit prohibition on the inclusion of IT filters for the following cases: all transfers to or from self-hosted wallets not directly held by the client who owns the account are strictly excluded and inhibited at system level. Operations admitted on wallets owned by the client are instead regulated according to differentiated procedural thresholds: below the threshold of EUR 1,000 the ordinary customer due diligence flow applies through self-declaration, while for amounts equal to or above such threshold, the advanced technological verification flow applies, through the requirement to execute a cryptographic signature. These thresholds and verification modalities find their basis, for anti-money laundering purposes, in Regulation (EU) 2023/1113 (the so-called Travel Rule), under which the transfer must be accompanied by information on the originator and the beneficiary. The Company may therefore request additional data from the client and, for transfers to or from self-hosted addresses of an amount equal to or above EUR 1,000, verify the ownership or control of the address by reliable technical means. The initiation or execution of the transfer is in any event subject to the completion of such obligations.

Obligations and responsibilities of the parties. The Company executes the instruction with professional diligence and in compliance with the applicable legislation. The client is responsible for the correctness and completeness of the destination data (address and network). It is expressly warned that transactions recorded on DLT are, as a rule, irreversible: a transfer to an incorrect address or network may result in the definitive loss of the crypto-assets. The client is required to report without undue delay, and in any event within 24 (twenty-four) hours, any unauthorised or erroneously initiated or executed transfers, using the secure notification channels indicated by the Company, including in the case of suspected fraud or security threat. The Company remains liable, within the limits provided by law, by the contract and by the procedure, for the activity within its responsibility relating to unauthorised or incorrectly executed transfers; responsibility for the accuracy of the destination data entered by the client remains with the client. The client has the right to withdraw from the relationship in accordance with the modalities set out in the Terms & Conditions, without prejudice to orders already transmitted or that have become irreversible.

Security systems. Before execution, the Company applies the controls provided for by the procedure: verification of the balance against the amount and the fees, formal validation of the destination address, blacklist/watchlist screening (including sanctions lists) and two-factor authentication of the client (OTP via SMS or authentication app). Operations are tracked and wallets are managed in accordance with technical and organisational measures consistent with the ICT risk management framework and with the cybersecurity insurance coverage referred to in Article 17(c) of Commission Delegated Regulation (EU) 2025/305.

Risks. In addition to irreversibility, the client is informed of the risks connected to errors in the indication of the address or of the network, to network congestion, to the variability of network fees and to the technological risks inherent in DLT.

Fees and timing. The fees applied to the service are set out in the fee schedule referred to in the T&C, as well as on the “Fees and Pricing” web page, which is always updated in real time. Execution times depend on the characteristics and the status of the DLT network used. Fees are presented distinguishing, where applicable, network fees (gas fees) from the Company’s fees. For each network, a reasonable estimate is provided of the time or of the number of confirmations required for the incoming transfer to become irreversible.

Post-execution information. For each transfer executed, the Company makes available to the client, in electronic form, at least: the name of the originator and of the beneficiary, the respective DLT addresses, the unique reference of the transaction, the quantity and type of crypto-asset, the value date and the fees applied, with a breakdown where relevant.

Negative outcome, rejection or suspension. In the case of rejection, suspension or return of the transfer, the Company communicates to the client at least the reason for the event, any available remedy and the amount of any fees incurred, with an indication of whether they are refundable.

Communications, languages and access to documents. Information on the service is made available on the Company’s institutional website, as well as in the contractual documents provided to the user, and in Italian, English and French. This notice, the agreement and the related documentation remain accessible to the client in electronic form for the entire duration of the relationship; any material change is communicated with reasonable advance notice.

Complaints and assistance. The client may submit complaints and request assistance in accordance with the modalities and channels indicated in the T&C and in the relevant procedure.

Governing law. The service is governed by the law indicated in the General Terms & Conditions.

Last updated: 30.06.2026