Publication Date: 14.11.2025

1. PURPOSE AND SCOPE

This Listing and Delisting Procedure (the “Procedure”) has been established in respect of the listing and delisting of crypto‑assets on the platform of Gate Kripto Varlık Alım Satım Platformu Anonim Şirketi (the “Platform”), pursuant to the Capital Markets Law No.6362 (the “Law”), and primarily the Communiqué on the Principles Regarding the Establishment and Operations of Crypto‑Asset Service Providers No.III‑35/B.1 (the “Operating Principles Communiqué”) and the Communiqué on the Working Procedures and Principles and Capital Adequacy of Crypto‑Asset Service Providers No.III‑35/B.2 (the “Working Procedures Communiqué”), and other applicable capital markets legislation.

The Platform carries out the listing and delisting processes within the framework of the principles of transparency and fairness as set out in this Procedure.

This Procedure is published on the Platform’s website in accordance with Article22/2 of the Operating Principles Communiqué.

2. GENERAL PRINCIPLES REGARDING LISTING

2.1 Listing Committee

2.1.1 Establishment

A listing committee (the “Listing Committee” or “Committee”) composed of at least three (3) persons is established to make decisions regarding the listing and delisting of crypto‑assets, and to assess whether the crypto‑assets to be listed meet the criteria as set out in this Procedure. The majority of the members of the Listing Committee must have at least seven (7) years’ experience in the fields of finance, law, information technology, information security or distributed ledger technologies, and at least one (1) member must be a member of the Platform’s Board of Directors.

2.1.2 Duties

The Listing Committee prepares an evaluation report on whether a crypto‑asset is listable. Based on the evaluation report, crypto‑assets are either listed or delisted. The Listing Committee may make decisions by the simple majority of the members present at the meeting. Discretion in this regard belongs solely to the Platform. The evaluation reports are retained for ten (10) years.

2.2 Crypto‑Assets That May Be Listed

2.2.1 General Principles

Crypto‑assets to be listed on the Platform are checked for whether they contain the minimum elements to be recorded in a smart contract in accordance with the legal nature of the crypto‑assets under the Working Procedures Communiqué. On the Platform:

• • In case of a crypto‑asset issuance that qualifies as a capital markets instrument, compliance with the principles stipulated in the Capital Markets Board’s (the “Board”) relevant regulations is required;
  • In case of assets falling under the regulatory domain of different institutions and organizations being offered or distributed as tokens, compliance with the procedures and principles envisaged by the relevant legislation is mandatory.
  • After the relevant legislation comes into force, crypto‑assets to be listed on the Platform must have an infrastructure appropriate for custody and be capable of being offered with custody services for the crypto‑asset. It must be possible to hold the listed crypto‑assets in cold wallets.

2.2.2 Crypto‑Assets That Cannot Be Listed

Crypto‑assets are not eligible for listing if they are contrary to restrictions or prohibitions imposed by competent authorities on the issuance or trading of the underlying asset, or if they are structured in such a way or principally serve to circumvent legal regulations. Crypto‑assets created in a way that grants the project owner unilateral and extraordinary powers cannot be listed. Crypto‑assets related to property values derived from crime or facilitating financing of terrorism under the relevant legislation, or crypto‑assets of project owners listed on national or international sanctions lists under Law No.7262 cannot be listed on the Platform. Crypto‑assets that allow sender or recipient wallet addresses to be hidden, thus enabling anonymous transfers, cannot be listed. Crypto‑assets that qualify as capital markets instruments may be listed only to the extent that they comply with the Board’s regulations and are permitted by the Board. Except for the cases determined by the Board under Article16/3 of the Working Procedures Communiqué regarding issuance of crypto‑assets qualifying as capital markets instruments, and Article16/4 relating to assets subject to regulation by different institutions, the following crypto‑assets cannot be listed:

• • Crypto‑assets issued by the Platform or by real persons together with their spouses and dependent children, or by partnerships where they serve as unlimited liability partners or serve as the chairman, member of the board of directors, general manager or deputy general manager;
  • Crypto‑assets issued by the Platform, or by a legal entity (other than a public legal entity) in which a person specified above directly or indirectly holds 10% or more of capital or voting rights;
  • Crypto‑assets issued by persons or institutions determined to act in concert with the Platform under employment, contractual or other reasons as determined by the Board;
  • Crypto‑assets whose initial sale or distribution was carried out by the Platform.

2.2.3 Exemption

The provisions of this Procedure do not apply to assets that are non‑fungible and unique in nature, used to represent or record ownership of digital assets, or assets used solely in virtual games to create or obtain various elements.

3. MATTERS TO BE CONSIDERED IN CASE OF LISTING AND DELISTING

3.1 General

The Platform will apply the procedures set out in this Procedure in determining the crypto‑assets to be traded on its platform. In this framework, before the Listing Committee makes a decision regarding listing or delisting of crypto‑assets, it obtains the written opinion of the Compliance Unit. The opinion of the Compliance Unit is advisory and not binding on the Listing Committee.

3.2 Existence and Nature of the Right Granted by the Crypto‑Asset to Customers

Crypto‑assets granting the customer one or more of usage rights, receivables rights, in rem rights or governance rights may be listed, provided they comply with legislation and Board decisions. Such rights themselves or the underlying assets, their subject matter, cause or purpose may not, in whole or in part, directly or indirectly, be contrary to the legislation in force in Turkey. The Listing Committee examines whether the crypto‑asset is linked to a physical asset or a legal right.

3.3 Trading Volume and Circulating Supply of the Crypto‑Asset

The Listing Committee analyses the trading volume of the crypto‑asset in accordance with global standards. In this context, long term lack of liquidity and absence of any trading order for a long period may also be considered. The Listing Committee may also evaluate the number of crypto‑assets in the market, market value and trading volume, the relationship with trading volume of other crypto‑assets, and whether a significant portion of the crypto‑asset is controlled by a single person or group. This assessment is not made for newly issued or initial offering crypto‑assets.

3.4 Supply of the Crypto‑Asset

The Listing Committee may examine the supply of the crypto‑asset in view of trading volume, market value and liquidity conditions.

3.5 Transaction Speed and Asset‑Specific Cost

3.5.1 Transaction Speed

The Listing Committee reviews the transaction speed of the crypto‑asset. Crypto‑assets and blockchains that provide fast confirmation times and low latency may be given priority.

3.5.2 Asset‑Specific Cost

The Listing Committee assesses that listing assets with high network fees or unsustainable costs may negatively affect the customer experience.

3.6 Reliability of the Crypto‑Asset and the Ledger Network and Related Systems

The Listing Committee evaluates the security of the crypto‑asset’s project.

3.7 Traceability of Crypto‑Asset Transactions

The Listing Committee may prioritise listing crypto‑assets whose transfers are traceable on the blockchain in conformity with the Platform’s principles of maximal transaction transparency and record‑keeping. The Committee considers criteria such as the analyzability of the crypto‑asset’s transaction history, regular traceability of transaction data, accessibility of project information and roadmap, and decides whether the crypto‑asset is eligible for listing.

3.8 Past Price Movements of the Crypto‑Asset

The Listing Committee may examine past price movements of the crypto‑asset in order to prevent market manipulation and to ensure that the Platform’s transactions are conducted in a more orderly and transparent environment. Maintenance of market integrity and a fair trading environment is essential.

3.9 Susceptibility of the Crypto‑Asset to Price Manipulation or Fraud and Platform’s Measures

The Committee assesses whether the crypto‑asset carries risk of price manipulation or fraud, taking into account the Platform’s mechanisms for detecting market manipulation, price limits, transaction suspension, suspicious account detection, bot usage, liquidity restrictions and anti‑money laundering procedures.

3.10 Algorithmic Determination of the Crypto‑Asset’s Value

The Listing Committee examines whether the value of the crypto‑asset is determined algorithmically. Within this scope, the Committee may additionally evaluate whether an asset whose value is algorithmically determined poses risks for customers due to susceptibility to price manipulation.

3.11 Status of the Crypto‑Asset under Turkish and Foreign Regulations and Receipt of Approvals

The Listing Committee examines whether the project is legally feasible. In the case of crypto‑assets issued abroad or subject to foreign country legislation, it evaluates whether necessary approvals from foreign regulatory authorities have been obtained and whether there has been any violation of legislation. Changes in regulations are also taken into account.

3.12 Ownership or Control over the Crypto‑Asset

The Listing Committee determines the holders of control over the crypto‑asset and evaluates their influence on network security, decision‑making processes and structure, particularly with respect to the principle of decentralisation.

3.13 Potential Security Risks Related to Forking of the Crypto‑Asset

A fork is the result of changes in the fundamental rules of a blockchain by a community, causing the chain to split into two separate paths. Although initially the new chain shares the transaction history of the original chain, over time it follows its own path and becomes independent. The Listing Committee may analyse ownership and control distribution in order to identify all kinds of forking risks that could adversely affect the security and governance processes of the crypto‑asset network, including violations of decentralisation.

4. DELISTING AND OTHER MEASURES

4.1 Delisting

If it is determined that crypto‑assets listed by the Platform fail to meet the criteria set out in this Procedure, they may be delisted based on the evaluation report prepared by the Listing Committee. Crypto‑assets subject to planned delisting are notified to customers via registered communication channels at least seven (7) days in advance following the entry into force of the relevant legislation. If the crypto‑asset is delisted by a global crypto‑asset platform, the Platform may proceed to delist with at least one (1) day’s notice, without waiting the seven‑day period. In extraordinary situations arising in global markets, the one‑day period may not be required. If it is later determined by the Platform that the crypto‑asset is contrary to this Procedure, or if a request is received from public authorities or judicial courts, or if reasonable suspicion arises regarding the security of the crypto‑asset or its associated distributed ledger network systems, the crypto‑asset may be delisted without waiting the seven‑day period; all purchase, sale and transfer operations are suspended. In particular, but not limited to, the following cases may trigger delisting:

• Use of the crypto‑asset in price manipulation;
• Identification of the crypto‑asset as risky in periodic controls
• Emergence of suspicion of security vulnerabilities related to the crypto‑asset;
• The crypto‑asset is no longer supported by the Project Team;
• News emerges that the Project Team has engaged in fraud, money laundering or other crimes, or conducted actions contrary to legislation, or an administrative or judicial investigation or prosecution against the Project Team is initiated;
• Transaction speeds continuously decline due to increased network congestion;
• The crypto‑asset can no longer be listed due to new regulatory changes;
• A member of the Project Team or the Project Team itself leaves the project;
• Global crypto‑asset service providers decide to delist the crypto‑asset;
• The Project Team directly or indirectly conducts transactions with the Company;
• Other situations deemed appropriate at the Company’s discretion.
• If delisting occurs:
• A notice is published on the website and application；
• Users are notified by e‑mail;
• Trading and fund transfers are suspended.
• Instead of delisting, the Listing Committee may decide on other sanctions deemed appropriate provided they comply with the legislation.

4.2 Conversion

After the withdrawal of a crypto‑asset is suspended or even without suspension, actions determined by the Listing Committee in compliance with the legislation may be taken directly.

4.3 Other Measures

Without prejudice to separate provisions of this Procedure, the Listing Committee is entitled to undertake all legally permissible measures including, but not limited to, hiding certain trading pairs or suspending trading.

4.4 Record Retention

Following a decision by the Listing Committee to list, suspend or delist a crypto‑asset, the Platform retains all documents, communications and information regarding the crypto‑assets under consideration for listing, suspension or delisting for ten (10) years.

5. NON‑ASSURANCE OF LISTING

Listing of crypto‑assets on the Platform does not mean that the assets are guaranteed by the Company. The Company makes assessments solely on the basis of the standards it has established in the listing processes and the information available. Customers are advised to conduct more detailed investigation of listed crypto‑assets, carefully read the Project Team’s disclosures and the relevant white‑paper. Additionally, price changes of listed assets are outside the Company’s control and are entirely shaped by free market conditions.

6. FINAL PROVISIONS

6.1 Review

This Procedure is reviewed at least once a year. It is also reviewed taking into account regulatory changes made by the Board and experience gained in practice, and updates to the Procedure are made where necessary.

6.2 Discretion of the Listing Committee

The Listing Committee may prepare different evaluation reports and make different decisions for two similar crypto‑assets. In every case where a crypto‑asset prevents listing, the Listing Committee may require that the condition preventing the listing be eliminated or that undertakings be given. The absolute discretion regarding this matter belongs to the Listing Committee.