..

White paper for crypto-assets other than asset-referenced tokens or e-money tokens


Digital Token Identifier:   KXJKPKMPK

Offeror or person seeking admission to trading:   8156009799D757EA3557 - Digital Energy S.r.l.

Type of submission:   New


Table of content

General information

SUMMARY

Part A - Information about offeror or person seeking admission to trading

Part B - Information about issuer, if different from offeror or person seeking admission to trading

Part C - Information about the operator of the trading platform in cases where it draws up the crypto-asset white paper and information about other persons drawing the crypto-asset white paper pursuant to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114

Part D - Information about other token project

Part E - Information about offer to public of other tokens or their admission to trading

Part F - Information about other tokens

Part G - Information on rights and obligations attached to other tokens

Part H – Information on underlying technology

Part I - Information on risks

Part J - Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts





[Table 2] Template for white papers for crypto-assets other than asset-referenced tokens or e-money tokens


Template for white papers for crypto-assets other than asset-referenced tokens or e-money tokens [abstract]

General information



00 Table of content
boolean true true

01 Date of notification
date 2026-02-27

02 Statement in accordance with Article 6(3) of Regulation (EU) 2023/1114
boolean true This crypto-asset white paper has not been approved by any competent authority in any Member State of the European Union. The offeror of the crypto-asset is solely responsible for the content of this crypto-asset white paper.

03 Compliance statement in accordance with Article 6(6) of Regulation (EU) 2023/1114
boolean true This crypto-asset white paper complies with Title II of Regulation (EU) 2023/1114 of the European Parliament and of the Council and, to the best of the knowledge of the management body, the information presented in the crypto-asset white paper is fair, clear and not misleading and the crypto-asset white paper makes no omission likely to affect its import.

04 Statement in accordance with Article 6(5), points (a), (b), (c), of Regulation (EU) 2023/1114
boolean true The crypto-asset referred to in this crypto-asset white paper may lose its value in part or in full, may not always be transferable and may not be liquid

05 Statement in accordance with Article 6(5), point (d), of Regulation (EU) 2023/1114
boolean true Not applicable

06 Statement in accordance with Article 6(5), points (e) and (f), of Regulation (EU) 2023/1114
boolean true The crypto-asset referred to in this white paper is not covered by the investor compensation schemes under Directive 97/9/EC of the European Parliament and of the Council or the deposit guarantee schemes under Directive 2014/49/EU of the European Parliament and of the Council.

SUMMARY



07 Warning in accordance with Article 6(7), second subparagraph, of Regulation (EU) 2023/1114
boolean true Warning

This summary should be read as an introduction to the crypto-asset white paper.

The prospective holder should base any decision to purchase this crypto –asset on the content of the crypto-asset white paper as a whole and not on the summary alone.

The offer to the public of this crypto-asset does not constitute an offer or solicitation to purchase financial instruments and any such offer or solicitation can be made only by means of a prospectus or other offer documents pursuant to the applicable national law.

This crypto-asset white paper does not constitute a prospectus as referred to in Regulation (EU) 2017/1129 of the European Parliament and of the Council or any other offer document pursuant to Union or national law.


08 Characteristics of the crypto-asset
textBlock The Green Energy Sharing Token (GEST) is a fungible token connected to the Digital Energy blockchain platform. Each GEST token represents a right to access a proportional share of renewable-energy generation capacity within the Digital Energy platform.
To activate this right, token holders must lock their tokens in a dedicated non-custodial smart contract, which grants access rights of the corresponding renewable-energy production capacity, whether derived from photovoltaic, wind, hydroelectric, or other renewable sources, as selected by the users from among the power plants made available on the platform. Tokens may also be issued and held fractionally, allowing flexible participation in the platform.
By staking their crypto-assets, users activate the allocation of such share. Based on the actual energy output generated by the relevant portion of the energy plant, staking users are entitled to receive the related energy proceeds in one of the following forms:
-     a payment credited to their designated bank account; or
-     (subject to availability) a discount applied to their electricity bill through partner energy providers integrated into the platform.
The platform ensures transparent monitoring of the energy plants, providing periodic data on production performance and energy yield recorded on blockchain, thus enabling traceability of renewable-energy generation and usage. Neither the crypto-assets nor the staking activity grant users any ownership, proprietary, or real rights over the energy plants selected by the users, which remain at all times the exclusive property of the relevant owners.
The platform applies a time-based service adjustment to GEST tokens when they are unlocked after being locked in a non-custodial smart contract to access renewable energy services. Upon unlocking, users receive slightly fewer tokens than originally locked – typically reflecting an annualized adjustment factor initially in the range of approximately 0.5% to 1.0%. Such adjustment factor may be revised over time, including potential increases, based on the long-term operational characteristics and performance assessments. The deducted portion is permanently removed from circulation through a burn mechanism..
GEST tokens are used exclusively within the Digital Energy platform to access the energy generation capacity. The GEST token does not constitute a financial instrument, share, or debt claim. The issuance of new GEST tokens will be subject to both procedural governance controls and technical constraints embedded within the relevant smart contracts. Such issuance will be linked to objective parameters derived from the renewable-energy plants integrated into the platform, with the aim of maintaining, over time, a general alignment between the number of circulating tokens and the effective production capacity available within the ecosystem. Temporary deviations may occur during phases of plant acquisition, integration, or expansion.


09 Further information about utility tokens
textBlock Not applicable

10 Key information about the offer to the public or admission to trading
textBlock Amount of the Offer
The GEST Token will be offered to the public during an initial subscription program structured in multiple phases.
The issue price of one GEST Token will range from EUR 900 (nine hundred) to EUR 1,100 (one thousand one hundred).
Tokens are divisible and fractions of GEST Tokens may be purchased. The minimum subscription amount is EUR 100 (one hundred).
The maximum target subscription amount for this initial offering program is EUR 10,000,000 (ten million).
Subscription Goals
No minimum subscription goal is set.
The maximum subscription cap for this initial offering program is EUR 10,000,000 (ten million), which represents the total amount to be raised during this issuance program.
Subscription Fees
No additional subscription fees are charged to purchasers beyond the applicable issue price.
Prospective Holders
The offer is open to retail and qualified investors, both natural and legal persons, who register on the Digital Energy platform and accept the platform's terms of use.
Phases of the Offer
The initial offering program is divided into four successive phases.
Each phase shall terminate upon the earlier occurrence of either:
(i) the expiration of the applicable time period, or
(ii) the sale of the maximum allocation assigned to that phase.
First Phase
Duration: up to two (2) months
Price: EUR 900 per GEST Token
Allocation: up to 5% of the total offering, corresponding to a maximum of EUR 500,000
Second Phase
Duration: up to two (2) months
Price: EUR 950 per GEST Token
Allocation: up to 10% of the total offering, corresponding to a maximum of EUR 1,000,000
Third Phase
Duration: up to three (3) months
Price: EUR 1000 per GEST Token
Allocation: up to 20% of the total offering, corresponding to a maximum of EUR 2,000,000
Final Phase
Duration: up to six (6) months
Price: EUR 1100 per GEST Token
Allocation: remaining portion of the total offering, up to the overall maximum cap of EUR 10,000,000
Additional issuance tranches may be offered in the future in connection with the integration of new renewable-energy projects into the Digital Energy ecosystem.


Part A - Information about offeror or person seeking admission to trading



A.1 Name
text Digital Energy S.r.l.

A.2 Legal form
text Società a responsabilità limitata (S.r.l.)

A.3 Registered address



Registered addess
text IT, IT-34, IT-RO, Papozze
Via Palmiro Togliatti 10, 45010


Country
enumeration
Italy


Sub-division
text Veneto

A.4 Head office



Head office
text IT, IT-34, IT-RO, Papozze
Via Palmiro Togliatti 10, 45010


Country
enumeration
Italy


Sub-division
text Veneto

A.5 Registration date
date 2022-11-08

A.6 Legal entity identifier
LEI 8156009799D757EA3557

A.7 Another identifier required pursuant to applicable national law
text Numero REA: RO – 447446
Codice fiscale e Partita Iva: 01635170291


A.8 Contact telephone number
text +393514233652

A.9 E-mail address
text  info@dgtenergy.it

A.10 Response time (days)
integer 5

A.11 Parent company
text Not applicable

A.12 Members of the management body



Member #1
id 1

Identity
text Johnny Lodo

Business address
text Via Togliatti 10
45010 Papozze (RO)
Italy


Function
text President of the Board of Directors

Member #2
id 2

Identity
text Carlo Alfano

Business address
text Via Federico Turano 61/A/2
00155 Roma (RM)
Italy


Function
text Member of the Board of Directors

A.13 Business activity
textBlock The company's purpose is to operate in the renewable energy and related sectors. Its activities include:
-Feasibility studies, design, construction, management, purchase, sale, and commercialization of renewable energy plants, as well as production and direct sale of renewable energy.
-Energy sector consulting, including support for investments and plant operations, either directly or via subcontracting.
-Assistance, consultancy, and maintenance services for energy plants owned by the company or third parties.
-Construction, installation, expansion, transformation, and maintenance of technological and energy plants.
-Wholesale and retail trade of electrical materials and products related to renewable energy plants.
-Advertising and promotion of renewable energy plants and components.
-Purchase, sale, lease, restructuring, and management of real estate and land, including agricultural property, but excluding brokerage.
-Participation in property auctions and real estate consulting.
-Consulting for innovative projects and creation of new subsidiaries or ventures, also abroad.
-Business consulting in marketing, advertising, IT, software, and database management.
-Professional training, requalification, and educational activities.
-Creation and commercialization of multimedia content, digital platforms, machine learning solutions, and investment monitoring platforms.
-Sale or subscription-based supply of digital platforms.
-Organization of events, meetings, exhibitions, and conferences to promote products and services.
-Participation in national and international projects, tenders, or joint ventures.
-Creation and registration of trademarks, and acquisition of stakes or shares in other companies with similar or related purposes.
-The company may also carry out any commercial, industrial, financial, real estate, or movable asset operations deemed useful for achieving its objectives, provided they are not reserved by law for regulated entities.


A.14 Parent company business activity
textBlock Not applicable

A.15 Newly established
boolean false

A.16 Financial condition for the past three years
textBlock Digital Energy S.R.L. has maintained financial stability across the three-year period ending December 31, 2025. The Company has not identified any risk factors that would impair its ability to continue as a going concern.
-Financial Year 2023
In fiscal year 2023, Digital Energy generated revenues of EUR 24,984 against operating costs of EUR 5,893, yielding an operating result of EUR 19,091. After net financial charges of EUR 124 and income taxes of EUR 5,283, the Company achieved a net profit of EUR 13,684. Total assets stood at EUR 31,887, with equity of EUR 23,685 (including EUR 10,000 share capital) and total debt of EUR 8,165.
-Financial Year 2024
In fiscal year 2024, revenues declined to EUR 2,018 with operating costs of EUR 3,011, resulting in an operating loss of EUR 993. However, financial income of EUR 3,000 offset this loss, producing a pre-tax result of EUR 1,997 and a net profit of EUR 1,446 after taxes of EUR 551. Equity strengthened to EUR 25,131 (with EUR 684 allocated to the legal reserve), while total debt decreased to EUR 5,341, reflecting improved financial leverage.
-Financial Year 2025
Based on operational trends and continuity of the business model, Digital Energy's financial performance during fiscal year 2025 developed broadly in line with 2024, maintaining a stable cost structure.


A.17 Financial condition since registration
textBlock Not applicable

Part B - Information about issuer, if different from offeror or person seeking admission to trading



B.1 Issuer different from offerror or person seeking admission to trading
boolean false

B.2 Name
N/A
.

B.3 Legal form
N/A .

B.4 Registered address

Registered addess
N/A .

Country
N/A .

Sub-division
N/A .

B.5 Head office

Head office
N/A .

Country
N/A .

Sub-division
N/A .

B.6 Registration date
N/A .

B.7 Legal entity identifier
N/A .

B.8 Another identifier required pursuant to applicable national law
N/A .

B.9 Parent company
N/A .

B.10 Members of the management body

Member #1
N/A .

Identity
N/A .

Business address
N/A .

Function
N/A .

B.11 Business activity
N/A .

B.12 Parent company business activity
N/A .

Part C - Information about the operator of the trading platform in cases where it draws up the crypto-asset white paper and information about other persons drawing the crypto-asset white paper pursuant to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114

C.1 Name
N/A .

C.2 Legal form
N/A .

C.3 Registered address

Registered address
N/A .

Country
N/A .

Sub-division
N/A .

C.4 Head office

Head office
N/A .

Country
N/A .

Sub-division
N/A .

C.5 Registration date
N/A .

C.6 Legal entity identifier
N/A .

C.7 Another identifier required pursuant to applicable national law
N/A .

C.8 Parent company
N/A .

C.9 Reason for crypto-asset white paper preparation
N/A .

C.10 Members of the management body

Member #1
N/A .

Identity
N/A .

Business address
N/A .

Function
N/A .

C.11 Operator business activity
N/A .

C.12 Parent company business activity
N/A .

C.13 Other persons drawing up the crypto-asset white paper according to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114
N/A .

C.14 Reason for drawing the white paper by persons referred to in Article 6(1), second subparagraph, of Regulation (EU) 2023/1114
N/A .

Part D - Information about other token project



D.1 Crypto-asset project name
text Digital Energy

D.2 Crypto-asset name
text Green Energy Sharing Token

D.3 Abbreviation
text GEST

D.4 Crypto-asset project description
textBlock Digital Energy is a blockchain-based platform designed to democratize access to renewable energy generation by linking digital assets to real-world renewable capacity.
The project leverages tokenization, smart contracts, and blockchain transparency to create a decentralized ecosystem where users can participate directly in the renewable energy value chain.
Through the issuance of Green Energy Sharing Token s (GEST), each representing access to a proportional share of renewable-energy production capacity, users can obtain access rights to the energy production capacity of real assets such as photovoltaic, wind, or hydroelectric plants. By locking their tokens in non-custodial smart contracts, users activate their corresponding share of productive capacity.
The energy generated by these tokenized portions is monitored and recorded through the platform's digital infrastructure, providing periodic data on production and yield. Based on the actual energy produced, users receive either a payment credited to their bank account or, where available, a discount on their electricity bill from partner energy providers affiliated with the issuer.
Digital Energy thus connects renewable energy generation with digital finance, creating a transparent, traceable, and sustainable mechanism for sharing the economic benefits of clean energy. Its blockchain architecture ensures data integrity, transparency, and compliance, while fostering broader participation in the transition to renewable energy.


D.5 Details of all natural or legal persons involved in implementation of crypto-asset project



Person #1
id 1

Type of person
enumeration
Other person involved in implementation


Name of person
text Johnny Lodo

Business address of person
text Via Togliatti 10
45010 Papozze (RO)
Italy


Domicile of company
enumeration
Italy


Person #2
id 2

Type of person
enumeration
Other person involved in implementation


Name of person
text Carlo Alfano

Business address of person
text Via Federico Turano 61/A/2
00155 Roma (RM)
Italy


Domicile of company
enumeration
Italy


D.6 Utility token classification
boolean false

D.7 Key features of goods or services for utility token projects
text Not applicable

D.8 Plans for the token



Description of past milestones
textBlock The Digital Energy project has almost completed the core technical development phase, including the creation of its smart contract architecture, and tokenomics model supporting the GEST tokens.
All essential components of the platform – wallet integration, token issuance protocol, energy data tracking, and marketplace functionalities – are in the process of being developed and will be soon operational in a controlled environment.
From the outset of the project, a photovoltaic power plant with an installed capacity of approximately 1 MW will be integrated into the Digital Energy platform, with a portion or, where applicable, the full generation capacity made available for token-based operations.
This initial facility will provide the first source of renewable-energy generation supporting user participation and will enable the operational validation of real-world energy data integration, serving as the foundation for the platform's early deployment and scalability.


Description of future milestones
textBlock The next planned milestones include:
-[Q2 2026] – Official Token Launch: public release of the GEST crypto-asset, enabling users to access tokenized photovoltaic capacity through the Digital Energy platform;
-[Q3 2026] – Acquisition and Integration of a Second Power Plant: expansion of the available photovoltaic capacity within the ecosystem to support wider user participation and scalability of the token model.
Further developments will focus on the progressive acquisition and integration of additional renewable-energy plants, the enhancement of monitoring and reporting tools, and the scaling of the Digital Energy platform's operational infrastructure.


D.9 Resource allocation
text Financial resources already allocated to the Digital Energy project have been primarily used for the technical implementation of the platform and the development of its blockchain infrastructure, including smart contract deployment, system integration, and initial operational testing.
Additional funds have been employed to cover legal, regulatory, and compliance-related expenses, including consultancy and documentation activities required for the preparation of this white paper and related filings.
A portion of the resources will be dedicated to marketing and communication activities, aimed at promoting awareness of the project, engaging potential partners, and supporting the community-building phase preceding the public token launch.


D.10 Planned use of collected funds or other tokens
text Funds or crypto-assets collected in connection with the Digital Energy project are planned to be allocated primarily to the acquisition, development, or integration of renewable-energy plants, including new installations as well as plants already constructed or under construction, in order to expand the energy generation capacity of the ecosystem. Additional resources may be used to support technological upgrades, energy monitoring systems, partnership development, platform scaling activities, marketing and education, ensuring the long-term sustainability and transparency of the Digital Energy infrastructure.

Part E - Information about offer to public of other tokens or their admission to trading



E.1 Public offering or admission to trading
enumeration
Offer to public


E.2 Reasons for public offer or admission to trading
textBlock The public offer of the Green Energy Sharing Token (GEST) is intended to enable broad participation in the Digital Energy ecosystem and to support the expansion of renewable-energy generation capacity through blockchain-based tokenization.
By allowing users to acquire and lock GEST tokens, the project establishes a transparent and traceable connection between digital assets and real renewable-energy production capacity, fostering community involvement in the transition to clean energy.
The funds collected through the offer will be used primarily for the acquisition and development of renewable-energy plants, including both new installations and existing facilities.
Additional proceeds may be allocated to technological improvements, regulatory compliance, and the development of partnerships with energy companies and service providers, ensuring the long-term sustainability and scalability of the Digital Energy platform.


E.3 Fundraising target



Target expressed in currency
monetary 10000000 EUR

Target expressed in units
decimal 9478

Target expressed in digital token identifier
text


E.4 Minimum subscription goals



Goals expressed in currency
monetary 0 EUR

Goals expressed in units
decimal 0

Goals expressed in digital token identifier
text


E.5 Maximum subscription goals



Goasl expressed in currency
monetary 10000000 EUR

Goals expressed in units
decimal 9478

Goals expressed in digital token identifier
text Not applicable

E.6 Oversubscription acceptance
boolean true

E.7 Oversubscription allocation
text In the event of oversubscription during the public offer of the Green Energy Sharing Token (GEST), allocations will be managed in accordance with the same principles and priorities applied to the general distribution of tokens.


Issue price details



E.8 Issue price
decimal 900

E.9 Official currency determining issue price
enumeration
Euro


E.9 Any other tokens determining issue price
text Not applicable

E.10 Subscription fee



Fee expressed in currency
monetary 0 EUR

Fee expressed in units
decimal 0

Fee expressed in digital token identifier
text Not applicable

E.11 Offer price determination method
text Not applicable

E.12 Total number of offered or traded other tokens
integer 9478

E.13 Targeted holders
enumeration
All types of investors


E.14 Holder restrictions
text The GEST Tokens will not be available for purchase or allocation to individuals or entities located, resident, or established in restricted jurisdictions for anti–money laundering (AML) and countering the financing of terrorism (CFT) compliance reasons.

E.15 Reimbursement notice
boolean true Purchasers participating in the offer to the public of crypto-asset will be able to be reimbursed if the minimum target subscription goal is not reached at the end of the offer to the public, if they exercise the right to withdrawal provided for in Article 13 of Regulation (EU) 2023/1114 of the European Parliament and of the Council or if the offer is cancelled

E.16 Refund mechanism
textBlock EU residents exercising their Article 13 withdrawal rights must notify the offeror of their decision to withdraw.
All payments received shall be reimbursed without undue delay, in accordance with MiCAR, using the same payment method as the original purchase, subject to the return of the corresponding Green Energy Sharing Token s (GEST).
Any blockchain network fees (gas fees) related to the return of the tokens shall be borne by the purchaser.
Sale Cancellation:
In the event of sale cancellation by the offeror, purchasers shall be automatically reimbursed using the same payment methods, subject to the return of the GEST tokens, within 14 calendar days of the cancellation announcement.


E.17 Refund timeline
text Withdrawal requests under Article 13 MiCAR must be exercised within 14 calendar days of the GEST Token purchase agreement, until the tokens are admitted to trading, or until the end of the GEST token sale subscription period, whichever occurs soonest. Once a withdrawal request is made, reimbursement must be processed within 14 calendar days from the date the offeror is informed of the withdrawal decision, as required by MiCAR. In case of sale cancellation, refunds will be processed within 14 days of the cancellation announcement.

E.18 Offer phases
textBlock Amount of the Offer
The GEST Token will be offered to the public during an initial subscription program structured in multiple phases.
The issue price of one GEST Token will range from EUR 900 (nine hundred) to EUR 1,100 (one thousand one hundred).
Tokens are divisible and fractions of GEST Tokens may be purchased. The minimum subscription amount is EUR 100 (one hundred).
The maximum target subscription amount for this initial offering program is EUR 10,000,000 (ten million).
Subscription Goals
No minimum subscription goal is set.
The maximum subscription cap for this initial offering program is EUR 10,000,000 (ten million), which represents the total amount to be raised during this issuance program.
Subscription Fees
No additional subscription fees are charged to purchasers beyond the applicable issue price.
Prospective Holders
The offer is open to retail and qualified investors, both natural and legal persons, who register on the Digital Energy platform and accept the platform's terms of use.
Phases of the Offer
The initial offering program is divided into four successive phases.
Each phase shall terminate upon the earlier occurrence of either:
(i) the expiration of the applicable time period, or
(ii) the sale of the maximum allocation assigned to that phase.
First Phase
Duration: up to two (2) months
Price: EUR 900 per GEST Token
Allocation: up to 5% of the total offering, corresponding to a maximum of EUR 500,000
Second Phase
Duration: up to two (2) months
Price: EUR 950 per GEST Token
Allocation: up to 10% of the total offering, corresponding to a maximum of EUR 1,000,000
Third Phase
Duration: up to three (3) months
Price: EUR 1,000 per GEST Token
Allocation: up to 20% of the total offering, corresponding to a maximum of EUR 2,000,000
Final Phase
Duration: up to six (6) months
Price: EUR 1,100 per GEST Token
Allocation: remaining portion of the total offering, up to the overall maximum cap of EUR 10,000,000
Additional issuance tranches may be offered in the future in connection with the integration of new renewable-energy projects into the Digital Energy ecosystem.


E.19 Early purchase discount
textBlock Not applicable

E.20 Time-limited offer
boolean true

E.21 Subscription period beginning
date 2026-05-12

E.22 Subscription period end
date 2027-06-12

E.23 Safeguarding arrangements for offered funds or other tokens
textBlock During the public offer period, all funds and crypto-assets collected in connection with the Green Energy Sharing Token(GEST) sale will be safeguarded directly by Digital Energy through dedicated accounts held with an Italian credit institution duly authorized under applicable banking and financial regulations. This institution will ensure the custody, segregation, and protection of collected assets in accordance with Article 10 of Regulation (EU) 2023/1114, guaranteeing that participants' funds remain secure at all times.

E.24 Payment methods for other token purchase
textBlock EUR

E.25 Value transfer methods for reimbursement
textBlock EU residents exercising withdrawal rights under Article 13 will receive reimbursement using the same payment method employed for their original GEST Token purchase. Reimbursements for payments made in euro or other fiat currencies will be processed directly by Digital Energy through its designated banking accounts. Reimbursements for purchases made in cryptocurrencies or digital tokens will be executed through the partner exchange platform originally used for the transaction, following the same method and blockchain address provided by the buyer.
Sale Cancellation: In the event of an issuer-initiated sale cancellation, all purchasers will be automatically reimbursed using the same payment method employed for their original GEST token purchase.


E.26 Right of withdrawal
textBlock In accordance with Article 13 of Regulation (EU) 2023/1114 (MiCAR), purchasers who acquire GEST through a public offer shall have the right to withdraw from the purchase without giving any reason and without incurring any penalty within a period of fourteen (14) calendar days from the date of their purchase agreement.
The right of withdrawal applies exclusively to natural persons who are retail investors and who acquire GEST tokens directly from Digital Energy S.r.l. and only in connection with the primary issuance phase.
To exercise the right of withdrawal, the purchaser must notify Digital Energy S.r.l. within the prescribed fourteen-day period by submitting a clear and unambiguous statement of their decision to withdraw. Notification may be provided electronically per email indicated above A.9 or through the same platform or communication channel used for the purchase, in accordance with the withdrawal procedures published on the platform's website.
Upon exercising the right of withdrawal, the purchaser must return the GEST tokens to Digital Energy S.r.l. following the instructions provided by the issuer.
Reimbursement will be issued only after the returned tokens are received and verified, and it will be processed using the same payment method employed for the original purchase.


E.27 Transfer of purchased other tokens
textBlock The transfer of GEST tokens will be executed on the Polygon blockchain to each user's internal smart-account wallet automatically created within the Digital Energy platform. Users may optionally link or withdraw their tokens to an external self-custodial wallet compatible with Polygon and ERC-20 standards.

E.28 Transfer time schedule
text 2026-05-12

E.29 Purchaser's technical requirements
textBlock Purchasers of GEST Tokens are not required to hold an external wallet, as each user is automatically provided with an internal smart-account wallet within the Digital Energy platform, implemented through account abstraction technology.
This wallet enables users to receive, hold, and use GEST Tokens seamlessly on the Polygon blockchain. At any time, users may choose to transfer their tokens to an external self-custodial wallet compatible with Polygon and ERC-20 standards (e.g., MetaMask or equivalent). Such transfer, however, remains optional and is not required for participating in the platform's ecosystem or for exercising the rights associated with the GEST tokens.


Other token services provider characteristics



E.30 Other token service provider (CASP) name
text Not applicable

E.31 CASP identifier
LEI 0000000000000000000X

E.32 Placement form
enumeration
Not applicable


Trading platforms characteristics



E.33 Trading platforms name
text Not applicable

E.34 Trading platforms market identifier code (MIC)
text Not applicable

E.35 Trading platforms access
text Not applicable

E.36 Involved costs
textBlock To carry out transactions on the Polygon blockchain, including receiving, transferring, or interacting with GEST tokens, users are not required to hold POL tokens. Network transaction fees ("gas fees") are automatically processed through the Digital Energy platform using the user's active payment method (e.g., credit card or other approved payment option). These fees are generally minimal and remain the responsibility of the user through the selected payment method.

E.37 Offer expenses
textBlock The offer expenses are estimated to be around EUR 50000, covering the development of the offering platform, legal expenses, compliance-related costs and marketing expenses.

E.38 Conflicts of interest
textBlock The offeror is not aware of any conflicts of interest

E.39 Applicable law
textBlock Republic of Italy

E.40 Competent court
textBlock Court of Rome, Republic of Italy

Part F - Information about other tokens



F.1 Crypto-asset type
text The Green Energy Sharing Token($GEST) is a fungible crypto asset classified as a crypto-asset other than asset-referenced tokens (ARTs) and electronic money tokens (EMTs). It is a digital representation of value that can be stored and transferred using distributed ledger technology (DLT) or similar technology, without embodying or conferring any rights to its holder other than the access rights to the goods and services described in this White Paper.
The crypto-asset does not aim to maintain a stable value by referencing any official currency, basket of assets, or underlying rights. The value of the GEST token is determined entirely by market forces, specifically the dynamics of supply and demand, and is not supported by any stabilization mechanism. It is neither pegged to fiat currency nor backed by external assets, which differentiates it from EMTs and ARTs.
Moreover, the Green Energy Sharing Token (GEST) does not qualify as a financial instrument, deposit, insurance policy, pension product, or any other regulated financial product under EU law. It does not confer any financial entitlements or contractual claims on its holders, thereby placing it outside the regulatory scope governing traditional financial instruments.


F.2 Other token functionality
textBlock The Green Energy Sharing Token (GEST) is a fungible token connected to the Digital Energy blockchain platform. Each GEST token represents a right to access a proportional share of renewable-energy generation capacity within the Digital Energy platform.
To activate this right, token holders must lock their tokens in a dedicated non-custodial smart contract, which grants access rights of the corresponding renewable-energy production capacity, whether derived from photovoltaic, wind, hydroelectric, or other renewable sources, as selected by the users from among the power plants made available on the platform. Tokens may also be issued and held fractionally, allowing flexible participation in the platform.
By staking their crypto-assets, users activate the allocation of such share. Based on the actual energy output generated by the relevant portion of the energy plant, staking users are entitled to receive the related energy proceeds in one of the following forms:
-     a payment credited to their designated bank account; or
-     (subject to availability) a discount applied to their electricity bill through partner energy providers integrated into the platform.
The platform ensures transparent monitoring of the energy plants, providing periodic data on production performance and energy yield recorded on blockchain, thus enabling traceability of renewable-energy generation and usage. Neither the crypto-assets nor the staking activity grant users any ownership, proprietary, or real rights over the energy plants selected by the users, which remain at all times the exclusive property of the relevant owners.
The platform applies a time-based service adjustment to GEST tokens when they are unlocked after being locked in a non-custodial smart contract to access renewable energy services. Upon unlocking, users receive slightly fewer tokens than originally locked – typically reflecting an annualized adjustment factor initially in the range of approximately 0.5% to 1.0%. Such adjustment factor may be revised over time, including potential increases, based on the long-term operational characteristics and performance assessments. The deducted portion is permanently removed from circulation through a burn mechanism..
GEST tokens are used exclusively within the Digital Energy platform to access the energy generation capacity. The GEST token does not constitute a financial instrument, share, or debt claim. The issuance of new GEST tokens will be subject to both procedural governance controls and technical constraints embedded within the relevant smart contracts. Such issuance will be linked to objective parameters derived from the renewable-energy plants integrated into the platform, with the aim of maintaining, over time, a general alignment between the number of circulating tokens and the effective production capacity available within the ecosystem. Temporary deviations may occur during phases of plant acquisition, integration, or expansion.


F.3 Planned application of functionalities
textBlock The functionalities associated to the GEST tokens will become fully applicable in Q2 2026.

A description of the characteristics of the other token, including the data necessary for classification of the crypto-asset white paper in the register referred to in Article 109 of Regulation (EU) 2023/1114, as specified in accordance with paragraph 8 of that Article



F.4 Type of crypto-asset white paper
enumeration
Other crypto-asset token white paper


F.5 Type of submission
enumeration
New


F.6 Other token characteristics
textBlock The GEST Token is a fungible crypto- asset, structured according to the ERC-20 token standard on the Polygon network.
Each GEST token represents a digital right to access a proportional share of renewable-energy generation capacity within the Digital Energy platform. To activate this right, token holders must lock their tokens in a non-custodial smart contract, which grants them an access right of the corresponding renewable-energy production capacity, whether derived from photovoltaic, wind, hydroelectric, or other renewable sources.
To activate access the power plant energy generation capacity, the holder must lock the token in a non-custodial smart contract, which grants access rights of the corresponding renewable-energy portion.
Token Characteristics:
-Standard: fungible ERC-20 token (Polygon network);
-Divisibility: Fractional amounts supported.
The GEST token serves exclusively as an access token within the Digital Energy Platform, enabling participation in the platform's renewable-energy framework, and does not represent ownership, equity, or debt in any entity or physical plant.


F.7 Commercial name or trading name
text GEST

F.8 Website of the issuer
text www.dgtenergy.it

F.9 Starting date of offer to the public or admission to trading
date 2026-05-12

F.10 Publication date
date 2026-04-02

F.11 Any other services provided by the issuer
textBlock Not applicable

F.12 Language or languages of white paper
text English

F.13 Digital token identifier code used to uniquely identify the crypto-asset or each of the several crypto assets to which the white paper relates, where available
text KXJKPKMPK

F.14 Functionally fungible group digital token identifier, where available
text Not applicable

F.15 Voluntary data flag
boolean false

F.16 Personal data flag
boolean true

F.17 LEI eligibility
boolean true

F.18 Home member state
enumeration
Italy


F.19 Host member states #1
enumerationSet
Austria


F.19 Host member states #2
enumerationSet
Belgium


F.19 Host member states #3
enumerationSet
Bulgaria


F.19 Host member states #4
enumerationSet
Croatia


F.19 Host member states #5
enumerationSet
Cyprus


F.19 Host member states #6
enumerationSet
Czechia


F.19 Host member states #7
enumerationSet
Denmark


F.19 Host member states #8
enumerationSet
Estonia


F.19 Host member states #9
enumerationSet
Finland


F.19 Host member states #10
enumerationSet
France


F.19 Host member states #11
enumerationSet
Germany


F.19 Host member states #12
enumerationSet
Greece


F.19 Host member states #13
enumerationSet
Hungary


F.19 Host member states #14
enumerationSet
Iceland


F.19 Host member states #15
enumerationSet
Ireland


F.19 Host member states #16
enumerationSet
Latvia


F.19 Host member states #17
enumerationSet
Liechtenstein


F.19 Host member states #18
enumerationSet
Lithuania


F.19 Host member states #19
enumerationSet
Luxembourg


F.19 Host member states #20
enumerationSet
Malta


F.19 Host member states #21
enumerationSet
Netherlands


F.19 Host member states #22
enumerationSet
Norway


F.19 Host member states #23
enumerationSet
Poland


F.19 Host member states #24
enumerationSet
Portugal


F.19 Host member states #25
enumerationSet
Romania


F.19 Host member states #26
enumerationSet
Slovakia


F.19 Host member states #27
enumerationSet
Slovenia


F.19 Host member states #28
enumerationSet
Spain


F.19 Host member states #29
enumerationSet
Sweden


Part G - Information on rights and obligations attached to other tokens



G.1 Purchaser rights and obligations
textBlock Each GEST represents a digital right to access a proportional share of renewable-energy generation capacity within the Digital Energy platform. To activate this right, token holders must lock their tokens in a non-custodial smart contract, which grants them the access right of the corresponding renewable-energy production capacity, whether derived from photovoltaic, wind, hydroelectric, or other renewable sources.
By locking their tokens in a non-custodial smart contract, purchasers become entitled to receive the economic benefits derived from the actual energy produced by the associated renewable-energy portion, in the form of either:
-a payment credited to their designated bank account; or
-(subject to availability) a discount on their electricity bill through partner energy providers.
Purchasers are required to comply with all KYC/AML requirements, as well as with the terms of use of the Digital Energy platform. The GEST token does not grant any ownership rights, voting rights, or claims over physical assets or the issuer's revenue.


G.2 Exercise of rights and obligations
textBlock To exercise their rights, token holders must lock their GEST in a dedicated non-custodial smart contract accessible through the Digital Energy platform.
Locking activates the access right of the corresponding renewable-energy portion and enables the system to record and monitor the associated energy generation data on the blockchain.
Only locked tokens generate the corresponding economic and energy-related benefits, while unlocked or unallocated tokens do not accrue any returns linked to energy production.
The platform applies a time-based service adjustment to GEST tokens when they are unlocked after being locked in a non-custodial smart contract to access renewable energy services. Upon unlocking, users receive slightly fewer tokens than originally locked – typically reflecting an annualized adjustment factor initially in the range of approximately 0.5% to 1.0%. Such adjustment factor may be revised over time, including potential increases, based on the long-term operational characteristics and performance assessments. The deducted portion is permanently removed from circulation through a burn mechanism.


G.3 Conditions for modifications of rights and obligations
textBlock The issuer or offeror may modify certain operational parameters of the Digital Energy platform – such as smart contract conditions, allocation mechanisms, or payout methods – where necessary to maintain regulatory compliance, ensure system integrity, or improve functionality.
The holder has always the capacity to unlock the GEST Tokens.
Any material modification affecting purchasers' rights or obligations will be communicated publicly through the issuer's official channels prior to implementation and will comply with applicable regulatory requirements.


G.4 Future public offers
textBlock At present, no additional public offers of the Green Energy Sharing Token (GEST) are planned.
However, the issuer may conduct future offers in connection with the acquisition, development, or integration of additional renewable-energy plants, in order to expand the energy generation capacity available within the Digital Energy ecosystem.GEST


G.5 Issuer retained other token
integer 0

G.6 Utility token classification
boolean false

G.7 Key features of goods or services utility tokens
text Not applicable

G.8 Utility tokens redemption
text Not applicable

G.9 Non-trading request
boolean false

G.10 Other tokens purchase or sale modalities
text Following the public offer, Green Energy Sharing Token s (GEST) may be purchased or sold only through partnered or regulated exchange platforms expressly authorized by Digital Energy.
No peer-to-peer trading or internal marketplace is provided within the Digital Energy platform, and no external listing on unauthorized third-party exchanges is foreseen or permitted.
All authorized transactions will occur on-chain through smart contracts, ensuring transparency, traceability, and compliance with applicable KYC/AML procedures and regulatory requirements.


G.11 Other tokens transfer restrictions
text Not applicable

G.12 Supply adjustment protocols
boolean false

G.13 Supply adjustment mechanisms
text Not applicable

Other token schemes details



G.14 Token value protection schemes
boolean false

G.15 Token value protection schemes description
textBlock Not applicable

G.16 Compensation schemes
boolean false

G.17 Compensation schemes description
textBlock Not applicable

G.18 Applicable law
textBlock Republic of Italy

G.19 Competent court
textBlock Court of Rome, Republic of Italy

Part H – Information on underlying technology



H.1 Distributed ledger technology (DTL)
text The GEST Token operates on the Polygon Proof-of-Stake (PoS) blockchain, an Ethereum-compatible distributed ledger technology (DLT) that offers scalability, low transaction costs, and full interoperability with the Ethereum ecosystem.
The Polygon PoS network uses a consensus mechanism based on Proof-of-Stake, ensuring high throughput, reduced energy consumption, and decentralized security through a network of validators.
All token transactions, smart contract interactions, and energy data records are immutably stored on-chain, guaranteeing transparency, traceability, and verifiability of operations within the Digital Energy platform


H.2 Protocols and technical standards
text The Digital Energy platform is built using industry-standard blockchain protocols and open technical specifications designed to ensure security, interoperability, and scalability.
All smart contracts related to the Green Energy Sharing Token(GEST) follow the ERC-20 token standard, deployed on the Polygon (PoS) network, which provides high throughput, low transaction costs, and compatibility with the Ethereum Virtual Machine (EVM).
Core platform modules rely on:
• Non-custodial smart contracts for token locking and access rights management;
• Account abstraction technology for internal user wallets and transaction automation;
• On-chain event logging for transparency and traceability of energy-related data;
• APIs to connect verified renewable-energy production data from monitored plants to the blockchain layer.
For detailed technical documentation, protocol references, refer to the official Digital Energy Documentation Portal available at:
https://docs.digitalenergy.io


H.3 Technology used
textBlock The Digital Energy ecosystem integrates blockchain, IoT, and cloud technologies to tokenize and manage renewable-energy production assets in a secure and transparent environment.
Key technological components include:
• Blockchain layer: Polygon (Ethereum-compatible), hosting ERC-20 GEST smart contracts;
• Smart contract infrastructure: Solidity-based non-custodial contracts enabling locking, data logging, and token functionality activation;
• Data layer: Cloud-based e Blockchain Based monitoring system aggregating real-time and historical production data from renewable plants via IoT gateways;
• Integration APIs: REST and Web3 APIs enabling interoperability with partner energy providers and external platforms;
• Security layer: Multi-signature authorization, on-chain auditability, and adherence to best practices in Web3 security;
This architecture ensures traceability, scalability, and operational reliability, while supporting future integration of additional renewable technologies and tokenized assets within the Digital Energy platform.


H.4 Consensus mechanism
text The Polygon Proof-of-Stake (PoS) network employs a PoS consensus mechanism designed to achieve scalability and efficiency while maintaining a high level of decentralization and security.
Validators on the Polygon network stake POL tokens to participate in the block validation process and are selected to propose and verify blocks based on their stake and reputation.
This model significantly reduces the energy consumption associated with transaction validation compared to Proof-of-Work systems, while ensuring fast finality and low latency for on-chain operations.
The consensus process ensures that all transactions involving GEST Tokens are secure, traceable, and immutable within the Polygon blockchain environment.


H.5 Incentive mechanisms and applicable fees
text The Polygon PoS network relies on a system of validators to maintain network security and integrity.
Validators receive block rewards and transaction fees, denominated in POL, the native token of the Polygon ecosystem, as compensation for their participation in consensus and transaction validation.
Interactions involving the Green Energy Sharing Token(GEST) and the related smart contracts require the payment of blockchain network transaction fees ("gas"), which are ultimately settled in POL on the Polygon network.
The Digital Energy platform may facilitate such interactions through transaction abstraction mechanisms, including the sponsorship of gas fees on behalf of users.
In these cases, users may be charged a platform service fee, denominated in fiat currency and payable through supported payment methods, to cover operational costs and platform services.
Blockchain network fees are influenced by network conditions at the time of execution and are generally low, reflecting the efficiency and scalability of the Polygon PoS network.


H.6 Use of distributed ledger technology
boolean false

H.7 DLT functionality description
textBlock Not applicable

Other token audit details



H.8 Audit
boolean true

H.9 Audit outcome
textBlock The audit was successfully completed, with no critical vulnerabilities identified. The system is considered secure based on the scope and methodology of the review.

Part I - Information on risks



I.1 Offer-related risks
textBlock Regulatory Risk. Although this White Paper has been prepared with diligence and in accordance with applicable Regulations, future changes in EU or national regulations may affect the legal classification, tradability, or compliance status of GEST.
Market Risk. GEST can be subject to significant price fluctuations based on supply-demand dynamics, market sentiment, and external macroeconomic factors. These may result in financial losses for token holders.
Liquidity Risk. While a future admission to trading increases accessibility, liquidity is not guaranteed. Low trading volumes may result in high slippage or the inability to exit positions efficiently.
Issuer Non-involvement in Trading. When GEST will be tradable on exchanges, the issuer does not act as a contractual party to these transactions. All legal relationships regarding these trading platforms are subject to their respective terms and conditions, with no responsibility assumed by the issuer for their operations and services.


I.2 Issuer-related risks
textBlock Financial Sustainability Risk. Although the issuer operates under a sustainable economic framework, it may nevertheless face financial distress due to unforeseen circumstances, such as failure to achieve adoption targets, loss of key personnel, or adverse regulatory developments.
Operational Dependency Risk. The issuer relies on various infrastructure providers – including cloud services, validators, and custodial partners – to support its operations. Any interruption, failure, or termination of these relationships could adversely affect the functioning of the protocol or associated services.
Reputational Risk. Negative publicity stemming from operational incidents, security breaches, or perceived associations with illicit activities could harm the issuer's public image, potentially reducing confidence in and demand for GEST Tokens.
Internal Operations Risk. Weaknesses in the issuer's internal processes, human resources, or technology systems could impair the effective management of token operations. Failures in operational integrity may result in service disruptions, financial losses, or reputational harm.
Legal and Regulatory Risk. Evolving legal frameworks, regulatory changes, or adverse legal proceedings may create uncertainty around the legality, usability, or valuation of GEST tokens, potentially restricting their circulation or acceptance.
Competitive Market Risk. The Digital Energy platform operates in a highly dynamic and competitive market. Emerging innovative or better-capitalized competitors may offer alternative solutions that diminish user adoption or the market position of the Digital Energy ecosystem.
Asset Lifecycle and Token Sustainability Risk. The renewable assets backing the Green Energy Sharing Token(GEST) may reach the end of their technical or contractual life, for example due to aging, expiration of surface rights, or replacement by newer technologies.
Increased Costs. Delays or increased costs in replacing decommissioned assets could temporarily reduce energy production and affect token yield. The issuer mitigates this risk by maintaining adequate reserves and ensuring gradual rotation and diversification of energy sources.


I.3 Other tokens-related risks
textBlock Nature of the GEST Token. The GEST Token does not grant holders any rights to dividends, profits, or corporate-style governance. Its valuation is market-driven and depends on the platform's use case, user adoption, and market perception.
Volatility Risk. As with most crypto-assets, GEST is subject to substantial short- and long-term price fluctuations. Market sentiment, liquidity shifts, and macroeconomic trends can all cause significant volatility, potentially resulting in GEST financial losses for holders.
Liquidity Risk. Market depth and trading activity for GEST may vary over time. Limited order book participation could lead to price slippage or difficulty executing trades efficiently, particularly during periods of market stress.
Technological Obsolescence Risk. The blockchain and crypto-asset sectors evolve rapidly. Innovations or competing protocols could surpass or replace the Digital Energy platform functionality, reducing GEST's adoption or relevance.
Speculative Nature Risk. The value of GEST is highly speculative and depends on market demand, protocol adoption, validator participation, and community engagement. There are no guarantees of future value, performance, or rewards associated with the token.
Blockchain Dependency Risk. GEST operates on public blockchains such as Polygon. Changes to their infrastructure, governance, consensus mechanisms, or transaction fees could affect GEST's usability, transferability, and cost efficiency.
Security Risks.
a) Smart Contract Vulnerabilities: Despite comprehensive audits, unforeseen bugs or vulnerabilities could compromise smart contract functionality, impacting token security, staking, or governance.
b) Private Key Management: Token holders are solely responsible for safeguarding their wallets and private keys. Loss or compromise of credentials will irreversibly result in the loss of tokens.
Fraud and Scam Risks. Holders face exposure to scams, phishing, impersonation, counterfeit tokens, and fake airdrops. Interacting with unverified platforms or unofficial channels significantly increases the risk of fraud or asset loss.
Cybercrime and Theft Risks. Blockchain assets may be targeted by cyberattacks, including hacking, malware, or phishing. Breaches affecting wallets, exchanges, or smart contracts could lead to theft, loss of assets, or service disruption.
Data Integrity Risk. Software bugs, human error, or malicious tampering could corrupt blockchain data, impacting transaction records, network reliability, and user confidence.
Wallet and Storage Risk. Access to GEST requires compatible wallets. Incompatibility, network errors, or the shutdown of wallet providers may restrict users' ability to access, store, or transfer tokens.
Regulatory and Compliance Risks.
a) Evolving Legal Frameworks: Regulatory regimes governing digital assets are changing rapidly, potentially impacting GEST's classification, availability, or functionality.
b) Jurisdictional Restrictions: Certain jurisdictions may limit or prohibit GEST trading or use, restricting accessibility for some users.
c) Enforcement Actions: Regulators could take action if GEST were reclassified as an unregistered security or other regulated financial instrument.
d) AML & CTF Risks: Transactions involving crypto-assets may be scrutinized for compliance with antimoney laundering and counterterrorism financing laws, potentially affecting users' ability to trade or transfer GEST.


I.4 Project implementation-related risks
textBlock Implementation and Execution Risks. Delays or failures in achieving key project milestones, deploying updates, or implementing technological upgrades may negatively affect the perception, functionality, and market value of the GEST Token. Furthermore, intense market competition from other protocols offering similar or superior solutions could limit user adoption and hinder Digital Energy's overall success.
Resource Constraint Risk. The successful development of the Digital Energy platform depends on the availability of adequate financial and human resources. Budget limitations, difficulties in attracting or retaining qualified technical personnel, or reliance on external or volunteer contributors could impede progress and delay protocol improvements.
Competitive Risk. The Digital Energy platform operates in a rapidly evolving market. The emergence of more advanced, better-capitalized, or innovative competitors could reduce network adoption and negatively impact GEST's market position and value.
Energy Asset Availability Risk. The successful implementation of the Digital Energy project depends on the issuer's ability to identify, acquire, or contract renewable energy assets suitable for tokenization.
Limited Availability of Viable Plants. Competition for high-performing assets, or regulatory or permitting constraints may delay or reduce the pipeline of energy capacity. This could affect the pace of token issuance, impact the expected returns to token holders, or require adjustments to the platform's operational model.


I.5 Technology-related risks
textBlock Blockchain Infrastructure Risk. The GEST token operates on public blockchain networks. Any downtime, congestion, network reorganization, or protocol-level vulnerability affecting these blockchains could impair transaction processing, accessibility, or reliability of the token and related protocol functions.
Smart Contract Vulnerability Risk. Although the Digital Energy smart contracts have undergone extensive security audits, there remains a possibility of undetected bugs or exploitation through novel attack vectors. Such vulnerabilities could compromise token integrity, staking mechanisms, or governance processes.
Fault-Tolerance and Incentive Mechanism Risk. GEST's operational model relies partly on user participation and incentive structures. Misconfigurations, design flaws, or unexpected failures in these mechanisms could lead to inconsistent performance or temporary instability in protocol operations.
Private Key Management Risk. Token holders are solely responsible for the secure management of their private keys and recovery credentials. Loss, theft, or compromise of wallet access will irreversibly result in the loss of GEST tokens, as blockchain transactions cannot be reversed.
External Infrastructure Dependency Risk. The functioning of the platform depends on third-party infrastructure providers, including RPC services, decentralized storage solutions, and agent orchestration frameworks. Downtime, cyberattacks, or incompatibility issues within these components could impact data availability, performance, or verification processes across the network.
Technological and Coordination Failure Risk. Participants should be aware that technological malfunctions, software errors, or coordination breakdowns among validators, developers, or governance participants could impair the availability, security, or functionality of both the GEST Token and the Digital Energy platform.
Digital Energy platform and Upgrade Risk. Ongoing platform maintenance, software updates, or protocol upgrades introduce a residual risk of unexpected bugs or compatibility issues.


I.6 Mitigation measures
textBlock Technical Security.
a)     Independent Smart Contract Audits: All smart contracts are subjected to multiple third-party security audits prior to deployment and after major upgrades.
b)     Bug Bounty Programs: Continuous bounty initiatives incentivize community reporting of vulnerabilities.
Operational Resilience.
a)     Infrastructure Diversification: Multiple RPC providers, storage networks, and validator partners are employed to reduce reliance on any single provider.
b)     Incident Response Procedures: A structured monitoring and response framework enables rapid detection, containment, and resolution of potential security or operational incidents.
c)     Periodic Stress Testing: Protocol systems undergo regular performance and load testing to evaluate resilience under adverse conditions.
Regulatory and Compliance Measures.
a)     Regulatory Monitoring: The issuer and foundation actively monitor evolving EU and international regulations, including MiCAR developments, to ensure continuous compliance.
b)     Legal Reviews: Ongoing external legal assessments help ensure that token operations remain consistent with applicable laws and regulatory classifications.
Project Implementation
a)     Develop a diversified pipeline across geographies and technologies (solar, wind, hydro, storage).
b)     Where appropriate, use contractual rights to implement power plants instead of full asset acquisition.
Market and Financial Controls.
a)     Treasury Management Policies: Treasury operations follow internal governance controls to ensure transparent use of funds and responsible liquidity management.
Community and Transparency.
a)     Clear Documentation: documentation and informative materials are publicly accessible, enabling independent review.
b)     Continuous Communication: Regular updates through governance forums, community calls, and transparency reports ensure ongoing stakeholder engagement.


Part J - Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts



J.1 Adverse impacts on climate and other environment-related adverse impacts
textBlock ADVERSE IMPACTS ON CLIMATE AND OTHER ENVIRONMENT-RELATED ADVERSE IMPACTS

Mandatory information on principal adverse impacts on the climate and other environment-related adverse impacts of the consensus mechanism



General information about adverse impacts



S.1 Name
text Digital Energy S.r.l.

S.2 Relevant legal entity identifier
text 8156009799D757EA3557

S.3 Name of the crypto-asset
text Green Energy Sharing Token

S.4 Consensus mechanism
text Polygon is a Layer-2 scaling solution for Ethereum that operates under a Proof-of-Stake (PoS) consensus mechanism. Validators must stake Polygon's native token (POL, formerly MATIC) to participate in block validation, replacing the need for energy-intensive mining and allowing the network to achieve high efficiency. Blocks on Polygon are produced roughly every few seconds by a validator selected based on stake, and finality is attained once a checkpoint containing those block hashes is validated on Ethereum, anchoring Polygon's state to the highly secure main chain.

S.5 Incentive mechanisms and applicable fees
text Polygon's PoS consensus is secured through a balanced system of rewards and penalties that promote honest participation. Validators who stake POL tokens are rewarded for processing transactions, proposing new blocks, and securing the network. Following the transition from MATIC to POL in 2024, the network introduced an annual token emission of about 2%, roughly half of which (≈1% of supply) is allocated to validator staking rewards to compensate validators for their work in securing the chain. In practice, validators (and their delegators) earn newly issued POL as block rewards as well as a share of the transaction fees collected on the Polygon network. Token holders who do not run a node can delegate their POL to professional validators and receive a portion of the rewards, broadening participation in network security.

S.6 Beginning of period to which disclosed information relates
date 2024-12-08

S.7 End of period to which disclosed information relates
date 2025-12-08

Mandatory key indicator



S.8 Energy consumption
energy (kWh)  96,637

Sources and methodologies



S.9 Energy consumption sources and methodologies
textBlock The energy consumption estimate for Polygon POL is determined using a "bottom-up" approach that identifies network nodes as the primary sources of electricity usage. Energy use is calculated based on the number of validator nodes and their hardware requirements, using empirical data gathered from public information and network scans. For a layered network like Polygon, which relies on Ethereum for periodic checkpointing, the model also allocates a portion of Ethereum's energy consumption to Polygon's footprint. This Ethereum share is proportional to Polygon's activity on Ethereum (for example, the gas used by Polygon's checkpoint transactions on the Ethereum mainnet). The hardware power draw for typical node equipment is measured in certified labs, and the assumptions about node count and performance are made conservatively to avoid underestimation. In general, when precise data is unavailable, higher estimates are used as a precautionary principle.

Supplementary information on principal adverse impacts on climate and other environment-related adverse impacts of consensus mechanism



Supplementary key indicators



S.10 Renewable energy consumption
percent 37,91%

S.11 Energy intensity
energy (kWh) 0,00001

S.12 Scope 1 DLT GHG emissions - controlled
GHG emissions (tCO2e) 0

S.13 Scope 2 DLT GHG emissions - purchased
GHG emissions (tCO2e) 32

S.14 GHG intensity
GHG emissions (tCO2e) 0,00001

Sources and methodologies



S.15 Key energy sources and methodologies
textBlock The sustainability metrics above are sourced from Polygon Labs' official sustainability disclosures and dashboard (developed in collaboration with the Crypto Carbon Ratings Institute).

S.16 Key GHG sources and methodologies
textBlock The greenhouse gas emission calculations use the CCRI's methodology, which aligns with the GHG Protocol and other industry standards.

Optional information on principal adverse impacts on the climate and on other environment-related adverse impacts of the consensus mechanism



Optional indicators



S. 17 Energy mix
percent 0%

S.18 Energy use reduction



Energy use reduction target (absolute value)
energy (kWh) 0

Energy use reduction target (percentage)
percent 0%

S.19 Carbon intensity (kgCO2e/kWh)
decimal 0

S.20 Scope 3 DLT GHG emissions - value chain
GHG emissions (tCO2e) 0

S.21 GHG emissions reduction targets or commitments
textBlock 0

S.22 Generation of waste electrical and electronic equipment (WEEE)
mass (tonnes) 0

S.23 Non-recycled WEEE ratio
percent 0%

S.24 Generation of hazardous waste
mass (tonnes) 0

S.25 Generation of waste (all types)
mass (tonnes) 0

S.26 Non-recycled waste ratio (all types)
percent 0%

S.27 Waste intensity (all types)
mass (tonnes) 0

S.28 Waste reduction targets or commitments (all types)
textBlock


S.29 Impact of use of equipment on natural resources
textBlock


S.30 Natural resources use reduction targets or commitments
textBlock


S.31 Water use
volume (m3) 0

S.32 Non recycled water ratio
percent 0%

Sources and methodologies



S.33 Other energy sources and methodologies
textBlock


S.34 Other GHG sources and methodologies
textBlock


S.35 Waste sources and methodologies
textBlock


S.36 Natural resources sources and methodologies
textBlock

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