GAL MiCA White Paper

Index

General information Page 3
Part A - Information about offeror or person seeking admission to trading Page 4
Part B - Information about issuer, if different from offeror or person seeking admission to trading Page 5
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 Page 6
Part D - Information about other token project Page 7
Part E - Information about offer to public of other tokens or their admission to trading Page 8
Part F - Information about other tokens Page 9
Part G - Information on rights and obligations attached to other tokens Page 10
Part H – Information on underlying technology Page 11
Part I - Information on risks Page 12
Part J - Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts Page 13
GAL MiCA White Paper

General information

N Field Content
00 Table of contents I. Compliance with duties of information
II. Summary
Part A: Information about the offeror or the person seeking admission to trading
Part B: Information about the issuer, if different from the 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 the crypto-asset project
Part E: Information about the offer to the public of crypto-assets or their admission to trading
Part F: Information about the crypto-assets
Part G: Information on the rights and obligations attached to the crypto-assets
Part H: Information on the underlying technology
Part I: Information on the risks
Part J: Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts
01 Date of notification 2025-12-23
02 Statement in accordance with Article 6(3) of Regulation (EU) 2023/1114 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 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 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 FALSE
06 Statement in accordance with Article 6(5), points (e) and (f), of Regulation (EU) 2023/1114 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.
07 Warning in accordance with Article 6(7), second subparagraph, of Regulation (EU) 2023/1114 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 documents pursuant to the applicable national law.
08 Characteristics of the crypto-asset $GAL is the official Fan Token of Galatasaray Spor Kulübü (Galatasaray S.K.). It is a permissionless blockchain-based token based on the standard CAP20, issued in February 2020 by Socios Services Limited in partnership with the club. Following the initial offer to the public, Socios Services Limited transferred the reserve of unsold $GAL tokens, which were not in circulating supply, to its Swiss affiliate, Socios Technologies AG (STAG), as of January 2021. From this date onwards, STAG assumed full responsibility for managing and conducting the post-FTO sales and distributions of the $GAL Fan Token.

$GAL is a crypto-asset used primarily to provide fans with access to exclusive experiences and rewards directly linked to fan engagement activities. Token holders can benefit from a range of Web3 utilities, including access to decentralized applications (dApps), the ability to collect NFTs and digital collectibles, integration with connected merchandise, and enhancements to the club’s loyalty program. In addition, the token offers more traditional benefits such as hospitality and ticketing privileges, real-life experiences (e.g. Meet and Greets, Matchday access, Play on the Pitch), exclusive signed merchandise, stadium tours, and more.

For the avoidance of doubt, the token is not used for payments or value transfer—holders retain full ownership when using its features. Similarly, holders of Fan Tokens do not acquire the right
to receive any financial return, dividend, or any right to participate in any voting related to the management, corporate, or strategic matters of Galatasaray S.K., the Offeror or any affiliated entity.

In light of the above, the $GAL token is a crypto-asset other than asset-referenced token and e-money token. It does not qualify as a utility token under Article 3 of Regulation (EU) 2023/1114, as it is intended to provide access to goods and services that are not exclusively supplied by the Issuer or any entity associated with the Issuer.
09 Further information about utility tokens This field does not apply, as 05 is False.
10 Key information about the offer to the public or admission to trading The $GAL public offer was structured as a “fair-launch Fan Token Offering” with no pre-sale and equal access for all participants. The offer targeted retail investors, with the following key details:

  • Total number of offered tokens: 2,000,000 $GAL, each token is priced at the equivalent of 10 Turkish Lira (TRY) in $CHZ. This means the total amount of $CHZ collected will be equal to TRY 20000000.
  • Total number of $GAL tokens offered to the public: 2000000 $GAL
  • Subscription period: 20200204 at 08:00 CET to 20200531 at 22:58 CET
  • Minimum and maximum subscription amount: Not applicable.
  • Issue price: Amount of TRY10 worth of $CHZ per $GAL Token Subscription fees (if any): Not applicable.
  • Target holders of tokens: Retail Investors (Football Fans). Description of offer phases: Not applicable as public offering has already been completed.
  • CASP responsible for placing the token (if any): Socios Europe Services Limited.
  • Form of placement: Without a firm commitment basis.
  • Admission to trading: The Offeror was not seeking admission to trading of the $GAL Token at the time of the Fan Token Offering (hereinafter FTO).
GAL MiCA White Paper

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

N Field Content
A.1 Name Socios Services Limited which subsequently, as of January 2021, transferred the reserve of unsold $GAL tokens that were not in circulating supply, to its Swiss affiliate Socios Technologies AG Therefore, from the date of such transfer, STAG assumed full responsibility for managing and conducting the post-FTO sales of the $GAL Fan Token.
A.2 Legal form Limited Liability Company
A.3 Registered address Level 6, Wembley Business Centre, Rue D'Argens, 1360
A.3 Country
MT-34
A.3 Sub-division
MT.
A.4 Head Office Level 6, Wembley Business Centre, Rue D'Argens, 1360
A.4 Country
MT-34
A.4 Sub-division
MT.
A.5 Registration date 2019-05-16
A.6 Legal entity identifier N/A
A.7 Another identifier required pursuant to applicable national law C 91496
A.8 Contact telephone number +356 20607777
A.9 E-mail address [email protected]
A.10 Response time (Days) 007
A.11 Parent company The Chiliz Group Limited, C 77290, Malta.
A.12 Members of the management body
Identity Business Address Functions
Alexandre Dreyfus Level 6, Wembley Business Centre, Rue D'Argens, 1360, MT-34, MT. Director
A.13 Business activity Purpose/Strategy/Vision
The vision of the Socios Services Limited (Offeror)'s Group is to support the continued growth of Fan Tokens into a world-recognised digital asset class by delivering a range of Fan Token services and features tailored to the global Web3 sports community.

Products/Services
The Socios.com platform (“Platform”), operated by Socios Europe Services Limited, a limited liability company incorporated and registered in Malta bearing company registration number C-108717 and holding a MiCA-authorization ID number SESL2-25081 (“Operator”), is a utility-centric platform offering a range of utilities and features in relation to Fan Tokens. By creating an account on the Platform and participating in the features it offers, users can earn off-chain reward points that can be redeemed for diverse rewards and in-real-life experiences, such as match tickets and exclusive partner team experiences. In addition, the Platform integrates the Socios.com Wallet, a non-custodial wallet infrastructure that allows users to remain in control of the crypto-assets they hold on the Chiliz Chain.

Markets Served
Our primary audience comprises individuals aged 18 and above, with intersecting interests in cryptocurrency, Web3 technologies, and sports. The Group’s target markets include the European Economic Area (EEA). Italy and Spain are currently our principal markets in Europe due to the partnership inroads we've made in the respective sports leagues and the growing interest in crypto assets. Beyond the EU, our global Platform aims to cater to fans worldwide, adhering to local regulatory standards. Brazil is particularly significant in our strategic plan. The country's deep football culture and the proactive stance of local authorities and regulators toward blockchain technologies make it an ideal target market.
A.14 Parent company business activity The Chiliz Group Limited is the sole shareholder of Socios Services Limited and the majority shareholder of Socios Services Limited and Socios Technologies AG, with its main role being that of a holding company. It does not undertake any specific commercial or business activities, saving being the original issuer of the $CHZ token.
A.15 Newly established FALSE
A.16 Financial condition for the past three years Financial Performance and Strategic Progress

As Socios Services Limited (SSL) was the Issuer and Offeror for the $GAL Fan Token but has been largely inoperative for the past four years, the financial review focuses on Socios Technologies AG (STAG), which assumed full responsibility for managing and conducting the post-initial public offer sales of the $GAL Fan Token as of January 2021. For investor protection purposes, this review emphasizes STAG's financial performance and stability, reflecting the active and ongoing operations that directly affect the future prospects of the $GAL token.
Over the past three years, Socios Technologies AG, has demonstrated a clear trajectory toward financial stability, driven by disciplined cost management, strategic growth initiatives, and operational improvements. Following a highly profitable year in 2021, the company faced a net loss in 2022 due to challenging market conditions, rising operating expenses, and significant investments in scaling its business. However, in 2023, decisive measures to enhance efficiency, optimize expenditures, and strengthen revenue streams led to a substantial reduction in losses.
By 2024, these efforts had significantly improved financial performance, with key metrics reflecting a strong upward trend:
  • Revenue Growth: Revenue increased by more than 70% from 2023 to 2024, signaling renewed momentum in the company’s core business—Fan Token sales—supported by a recovering crypto market.
  • Profitability: Despite incurring losses in 2023, the company’s profitability improved by over 60% in 2024 due to rising revenue and enhanced financial efficiency.
    1. As of 2024, the company has been actively working toward break-even, leveraging sustained revenue growth, improved margins, and a more resilient business model. Financial and operational performance indicators point to steady progress, underpinned by stable cash flows and a well-structured capital strategy. The company has demonstrated strong financial improvements in 2024, marked by higher revenue, reduced losses, improved cash flow, and stronger margins.
    1. Financial Position as of December 31, 2024
    1. The following is a summary of Socios Technologies AG's financial position based on the audited financial statements for the year ended 2024.
    1. Assets
    1. As of December 31, 2024, Socios Technologies AG's assets are categorized as follows:
  • Total Current Assets: CHF 92,790,921.
  • Total NonCurrent Assets: CHF 294,874.
  • TOTAL ASSETS: CHF 93,085,795.
    1. Debts and Other Liabilities
    1. As of December 31, 2024, Socios Technologies AG's liabilities are detailed as follows:
  • Total Shortterm Liabilities: CHF 75,790,910
  • Total Longterm Liabilities: CHF 1,723,172
  • Total Liabilities: CHF 77,514,081
    1. Shareholders' Equity
  • Total Shareholders' Equity: CHF 15,571,714 Future Outlook
    1. Looking ahead, the company remains committed to further strengthening its revenue and profitability, capitalizing on the improving crypto market and increasing demand for Fan Tokens. A continued focus on cost management and revenue expansion will enhance financial stability. Additionally, the company is undertaking a strategic review to eliminate unnecessary expenses, thereby improving long-term profitability. With a solid foundation in place, it is well-positioned for continued financial growth and sustainable profitability.
    1. Key Performance Indicators (KPIs)
    1. Socios Technologies AG’s key KPIs reflect its core business priorities:
  • Fan Token Sales: The company’s primary business, Fan Token sales, has shown strong performance over the past year. Despite volatility in the crypto market, it has successfully maintained substantial sales volumes. With a market rebound, management expects further improvement in this KPI.
  • Expansion of Fan Token Offerings: The company actively seeks new partnerships to expand its portfolio of Fan Tokens and plans to launch new tokens in 2025.
  • Enhanced Fan Token Utility: Management is focused on increasing the utility of Fan Tokens, both through the company’s own Platform and thirdparty collaborations. Providing greater utility encourages longterm holding and enhances token value.
    1. Capital Resources
    1. The company’s capital resources are primarily derived from Fan Token sales, ensuring a sustainable funding model aligned with business growth.
    1. Non-Financial Factors
    1. Beyond financial metrics, the company’s success is underpinned by its reliance on highly skilled personnel and efficient resource allocation, reinforcing the strength of its operational model.
A.17 Financial condition since registration This field does not apply as both SSL and STAG have been established for the past three years.
GAL MiCA White Paper

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

N Field Content
B.1 Issuer different from offerror or person seeking admission to trading FALSE
B.2 Name N/A
B.3 Legal form N/A
B.4 Registered address N/A
B.5 Head office 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 N/A
B.11 Business activity N/A
B.12 Parent company business activity N/A
GAL MiCA White Paper

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

N Field Content
C.1 Name N/A
C.2 Legal form N/A
C.3 Registered address N/A
C.4 Head office 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 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
GAL MiCA White Paper

Part D - Information about other token project

N Field Content
D.1 Crypto-asset project name $GAL Fan Token
D.2 Crypto-asset name $GAL Fan Token
D.3 Abbreviation $GAL
D.4 Crypto-asset project description $GAL is the official Fan Token of Galatasaray Spor Kulübü Club (Galatasaray S.K.), one of Turkey's most prestigious football clubs, and part of the pioneering Fan Token ecosystem powered by Socios.com. This utility-focused crypto-asset is designed to bring fans closer to the club by offering new ways to engage with the club, and reward Fan Token holders for their engagement, all through a secure and transparent
blockchain-based platform.

The $GAL grants holders a variety of exclusive digital and
real-world utilities with the potential of expanding to web3 and DeFi product functionality within the Chiliz Chain ecosystem, transforming passive supporters into active participants in the club's fan communities and digital ecosystems. They can vote on official Galatasaray S.K. club non-managerial decisions through polls on the Socios.com wallet and Platform or through other integrated channels (with voting power proportional to their holdings). Holding $GAL also unlocks access to exclusive rewards such as VIP matchday experiences, signed merchandise, and unique opportunities like play at Rams Park or Meet and Greet with Players of the first team, as well as access to digital experiences and rewards. Through the Socios.com app, fans earn loyalty points redeemable for rewards when engaging with the features of the Fan Token, such as through Fan Token stake and earn. Such reward points can be redeemed for
limited-edition items and enhanced utilities available through the dedicated fan shop. $GAL fan token holders can connect their non-custodial wallet to various dApps available through the integrated dApp browser to enable interaction of the $GAL tokens with decentralized sports and DeFi platforms within the Chiliz ecosystem.

The project's mission is to strengthen the bond between Galatasaray S.K. and its global fanbase by leveraging Web3 technology to provide meaningful engagement, recognition, and rewards within a secure and transparent framework. As the world of sports and entertainment transitions to Web3, the $GAL is more than just a crypto-asset—it serves as a gateway to a new era of fandom, enabling supporters to engage with the club in immersive and innovative ways within this new digital realm. Fully aligned with the evolving regulatory landscape, the project emphasizes transparency, user protection, and responsible digital engagement.
D.5 Details of all natural or legal persons involved in implementation of crypto-asset project
Name of person Type of person Business address Domicile
Socios Technologies AG
Other person involved
Gubelstrasse 11, 6300 CH-ZG
Switzerland
Socios Services Baltics UAB
Development Team
Vilnius, Lithuania
Lithuania
Socios Europe Services Limited
Crypto-asset service provider
Msida, Malta
Malta
Galatasaray S.K.
Other person involved
Istanbul, Türkiye
Turkey
D.6 Utility Token Classification FALSE
D.7 Key Features of Goods/Services for Utility Token Projects N/A
D.8 Plans for the token Past Milestones

  • February 2020: Galatasaray Fan Token Offering (FTO) goes live on Socios.com.
  • March 2020: Vote for the team's official home match entrance anthem to be played at Türk Telekom Stadium.
  • November 2020: Vote for the best design of dressing room.
  • May 2021: Vote for a special message for the 'Aslan Yuvası' at Türk Telekom Stadium.
  • August 2021: Vote for Olimpiu Morutan jersey number for the 2021/2022 season
  • September 2021: Token Holders get a unique opportunity for a Meet and Greet session with club legends.
  • November 2021: Vote for a mural design for the Florya Metin Oktay Facilities.
  • January 2022: Vote for the design of the new Scoreboard design.
  • May 2022: Vote for the 'Best of the Season' rewards.
  • August 2022: Vote for choose Dries Mertens' new jerseys number
  • September 2022: Token Holders get an exclusive tour of the stadium and museum on the anniversary of Galatasaray's historic UEFA Super Cup win.
  • November 2022: Vote for the message to be displayed on the Champions League captain's armband.
  • January 2023: Launch of the Digital Collectible campaign for the special derby “İSTANBUL IS RED”
  • August 2023: Vote on the design of a limited edition digital collectible.
  • November 2023: Vote on the design of the corner flags for home matches.
D.8 Plans for the token Future Milestones

Future initiatives include strengthening connections with fans around the world, introducing a new way to reward fan engagement, and offering fans innovative Web3 functionalities provided by third parties within the Chiliz Chain ecosystem.
D.9 Resource allocation The resources allocated to the $GAL project primarily consisted of non-financial contributions, including the extensive man-hours and expertise provided by the development team of the Issuer/Offeror.
Additionally, marketing efforts of Socios Services Limited and Galatasaray Spor Kulübü in relation to the offering were deployed to drive awareness, foster community engagement, and ensure the successful adoption of the token.
D.10 Planned use of Collected funds or crypto-Assets A portion of the proceeds was primarily allocated to cover partnership fees, facilitating Galatasaray Spor Kulübü (“Partner”) engagement and securing the Fan Token offering. Additionally, the funds were allocated to support Socios Services Limited group operational expenses and to ensure ongoing provisioning of utility on the Socios.com platform for the $GAL Fan Token.
GAL MiCA White Paper

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

N Field Content
E.1 Public offering or admission to trading
OTPC
E.2 Reasons for public offer or admission to trading The $GAL public offer was driven by the following objectives:

Community Growth and Fan Engagement:

  • The Fan Token Offering was conducted to increase fan engagement and provide monetization opportunities for the first men’s football team of Galatasaray Spor Kulübü(Galatasaray S.K.).
  • The Fan Token Offering sale aimed to grow the Galatasaray S.K. community by fostering engagement with its global fan base, allowing fans to connect with the club through multiple utilities that may be offered by holding these Fan Tokens. This initiative not only strengthens the connection between the Galatasaray
    1. S.K. brand and its global fanbase but also fosters
    1. long-term engagement, rewarding fans for their ongoing commitment to the club.
  • All in all, owning $GAL allows investors to be part of a global community of likeminded fans, enhancing their sense of belonging and identity within that community.
    1. Funding for enhancing utility and long-term development:
  • A portion of the offer to the public proceeds were used to enhance the utility of the $GAL Fan Token on the Socios.com platform, including securing ticketing, merchandise, and exclusive experiential rewards for token holders.
E.3 Fundraising target 20000000
E.4 Minimum subscription goals N/A
E.5 Maximum subscription goals N/A
E.6 Oversubscription acceptance FALSE
E.7 Oversubscription allocation N/A
E.8 Issue price 10
E.9 Official currency or any other crypto-assets determining the issue price
TRY
E.10 Subscription fee 0
E.11 Offer price determination method The offer price of $GAL was determined by the Issuer/Offeror in accordance with the agreed terms with Galatasaray Spor Kulübü. The price of $GAL was set at an amount of $CHZ equivalent to 10 TRY at the time of purchase.
E.12 Total number of offered/traded crypto-assets 2000000
E.13 Targeted holders
RETL
E.14 Holder restrictions Participation requirements

The Offering was only available to users who had created an account on the Socios.com platform at the time of the FTO. All participants were obliged to comply with Socios.com's
Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) requirements, including completing all necessary customer due diligence procedures.

Additionally, for eligibility purposes, the user must have been at least eighteen years old or of sufficient age to legally obtain and hold Fan Tokens in the user’s jurisdiction, and must not have been a citizen or resident of: (i) an Excluded Jurisdiction; or (ii) any other jurisdiction or territory as outlined in the applicable Terms and Conditions (TCs) for the respective FTO.
The user should not have participated in the Fan Token Offering if there were any legal restrictions in the user’s country of residence or domicile. It was the sole responsibility of the user to ensure that their participation in the Fan Token Offering was not prohibited, restricted, curtailed, hindered, impaired, or otherwise adversely affected by any applicable law, regulation, or rule in the user’s country of residence or domicile.
E.15 Reimbursement notice 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 Not applicable as public offering has already been completed.
E.17 Refund timeline Not applicable as public offering has already been completed.
E.18 Offer phases Not applicable as public offering has already been completed.
E.19 Early purchase discount There is no early purchase discount offered.
E.20 Time-limited offer TRUE
E.21 Subscription period beginning 2020-02-04
E.22 Subscription period end 2020-05-31
E.23 Safeguarding arrangements for offered funds/crypto-Assets There are no safeguarding arrangements implemented for the offered tokens.
E.24 Payment methods for crypto-asset purchase The only accepted payment method for purchasing $GAL Fan Tokens during the public offering was the transfer of $CHZ to the Offeror (Socios Services Limited). This transaction was required to complete the purchase of $GAL tokens.
No other payment methods, including fiat currencies or any other cryptocurrencies, were accepted during the public offer.
E.25 Value transfer methods for reimbursement This field does not apply as the public offering has already been completed and, consequently, no value transfer methods for reimbursement are applicable.
E.26 Right of withdrawal This field does not apply as public offering has already been completed and right to withdrawal is only relevant in the context of public offering (Article 13 of Regulation (EU) 2023/1114).
E.27 Transfer of purchased crypto-assets Purchased $GAL tokens were transferred to holders as follows:

FTO mechanics:

  • Participants of the FTO mechanism were able to buy an amount of $GAL until FTO supply was sold out. The mechanism allowed users to purchase $GAL tokens for an amount of $CHZ. If the FTO supply was not yet sold out, then, the purchase was confirmed and the $GAL tokens were deposited to the participant’s Socios.com wallet within 12 minutes of purchase.
  • Participants in the public offer submitted a request to purchase a fixed number of $GAL tokens that were denominated in $CHZ (at a fixed price of 10TRY worth of
    1. $CHZ per $GAL token that was based on the CHZ/TRY conversion rate at the time of purchase). Therefore, the user received in the Socios.com wallet the requested and paid-for amount of $GAL as soon as payment was received.
    1. Blockchain-Based Delivery and Socios.com Platform Exclusivity:
  • The $GAL Fan Tokens were distributed to eligible participants via the FTO mechanism conducted exclusively on the Socios.com platform.
  • $GAL Tokens were delivered directly to the Chiliz Legacy Chain wallet address associated with the Socios.com Wallet that the participant used to participate in the public offer.
    1. Direct delivery granted a seamless, transparent, and secure transfer of the $GAL tokens to holders.
    1. Exclusivity of Socios.com Wallet:
    1. As participants were required to participate in the public offer via Socios.com, only Socios.com Wallet addresses on the Chiliz Legacy Chain were able to receive $GAL tokens.
E.28 Transfer time schedule During the Fan Token Offering, users received their purchased $GAL immediately, typically within 1-2 minutes of completing the purchase. The distribution mechanism was designed to be instant, with $GAL tokens being sent directly to the user upon confirmation of the purchase.
E.29 Purchaser's technical requirements To participate in the public offer and receive $GAL Fan Tokens, purchasers had to meet the following technical requirements:

Socios.com Account and Custodial Wallet:

  • Purchasers must have a registered account on Socios.com platform, where a Socios.com custodial wallet will be automatically assigned to them, in order to participate in the public offer and receive the $GAL tokens.participate in the public offer and to receive the $GAL tokens. The FTO was conducted exclusively on the Socios.com platform for registered Socios.com account holders.
  • For the sake of clarity, please note that Offeror’s Group has moved away from providing custodial wallet services and has since transitioned to a noncustodial wallet model, whereby the Socios.com Platform interface now allows users to create and access a fully noncustodial wallet as of Q4 2024, following which Socios.com users maintain full custody of any and all crypto assets they store within the wallet which they can access through the Platform including Fan Tokens. However, given that there remains a number of users1 that have not set up their noncustodial wallet, Socios Europe Services Limited shall continue to provide custodial services for their remaining assets until such users either transition to the noncustodial wallet model or they no longer hold any token balance in their old wallets.
E.30 Crypto-asset service provider (CASP) name Socios Europe Services Limited. For the avoidance of doubt, no placing services will be conducted within the territory of France.
E.31 CASP identifier 984500EBA2E9980CDD80
E.32 Placement form
WOUT
E.33 Trading platforms name This field does not apply as no admission to trading is being sought at the time the White Paper is drawn up and notified to the competent authority. Admission to trading was also not sought at the time the offer to the public took place.
Notwithstanding this, STAG does not exclude the possibility of seeking admission to trading on MiCA-compliant trading platforms established in the EU at a future date.
E.34 Trading platforms market identifier code (MIC) N/A
E.35 Trading platforms access N/A
E.36 Involved costs This field does not apply as there no an admission to trading
E.37 Offer expenses The resources allocated to the $GAL offer to the public were primarily non-financial, encompassing significant man-hours and expertise from the Offeror's development team. These efforts focused on technical development, ensuring compliance with applicable laws at the time of launch, and comprehensive project planning to facilitate a successful public offering and token launch.
E.38 Conflicts of interest N/A
E.39 Applicable law Malta
E.40 Competent court Subject to mandatory applicable law, any dispute arising out of or in connection with $GAL offer to the public and all claims related to the $GAL token were exclusively, including matters of validity, invalidity, breach, or termination, subject to the jurisdiction of the courts of Malta.
GAL MiCA White Paper

Part F - Information about other tokens

N Field Content
F.1 Crypto-asset type The $GAL Fan Token is a crypto-asset other than asset-referenced tokens and e-money tokens based on the standard CAP20. This token is permissionless and was issued by Socios Services Limited in collaboration with $GAL, and can be used, among other digital platforms, on Socios.com. Its key utility and functionality is to serve as a digital fan engagement tool, granting holders access to token-gated experiences such as voting in club-related polls, earning loyalty rewards, and unlocking exclusive content and benefits—while fostering a closer, non-financial connection between Galatasaray Spor Kulübü Club and its global fanbase.

For the avoidance of doubt, when a user makes use of a $GAL Fan Token Functionality on the Platform, the $GAL used to access the token functionality will not be burned, consumed, transferred, or otherwise surrendered but will remain with the user. Accordingly, the $GAL Fan Token does not function as a means of payment or value transfer, but rather serves as an eligibility criterion to unlock token functionalities made available for the Fan Token holder, subject to the conditions set forth on the Platform with respect to the particular token functionality.

Crucially, the $GAL Token has no legal or otherwise rights or obligations attached to it either by those purchasing the token or the Team the token is issued on behalf of, nor does it entitle holders thereof to participate in any decisions which are ordinarily reserved to corporate bodies or vested in directors and shareholders of either Galatasaray S.K. or Socios Services Limited, or their respective affiliates, nor shall it entitle holders to receive any sort of profits generated by Galatasaray S.K. or Socios Services Limited, or their respective affiliates.

Token Classification:
The $GAL Token is designed as a fungible token that enhances fan engagement and interaction within the Galatasaray S.K. community. Its primary purpose is to serve as a community-driven token, offering exclusive access, experiences, and participation opportunities within the Galatasaray S.K. ecosystem.

Therefore, $GAL token falls within the definition of crypto-asset set forth in article 3 of Regulation (EU) 2023/1114) as it is a digital representation of a value or of a right that is able to be transferred and stored electronically using distributed ledger technology or similar technology (Chiliz Chain).

$GAL does not purport to maintain a stable value and, thus, it should be classified as a crypto-asset other than asset-referenced token or e-money token.
The $GAL does not qualify as a utility token under Article 3 of the Regulation (EU) 2023/1114, as the associated utilities are not provided exclusively by the Issuer or an entity related to that Issuer.

Blockchain:

The $GAL operates on the Chiliz Chain, a fully sovereign EVM-compatible layer 1 blockchain.
Allocation and Distribution:

A total of 2,000,000 $GAL tokens were made available during a fair-launch public offer, with the focus of the initial launch being on equitable access for participants.
F.2 Crypto-asset functionality Purpose

The $GAL Fan Token is a utility-based crypto-asset originally issued by Socios Services Limited on the Chiliz Legacy Chain and subsequently migrated to the Chiliz Chain, an EVM-compatible Layer 1 blockchain designed specifically for the sports and entertainment industry. It is designed to increase community engagement between Galatasaray Spor Kulübü Club (Galatasaray S.K.) and its global fanbase. The token serves as a digital membership credential that enables users to access token-gated features and exclusive non-financial experiences. Its issuance is linked to the engagement strategy of Galatasaray
S.K. and forms part of a broader initiative to integrate Web3 technology into the fan experience.

Utility

The functionalities of the $GAL Fan Token on the Platform depend on the contractual arrangement with the Club’s rights’ holder. These functionalities may include, but are not limited to, participation in polls, access to exclusive content/experiences, and rewards mechanisms through the Platform.
Importantly, token holders do not acquire any financial rights, ownership, or entitlements to revenues or intellectual property from Galatasaray S.K., Socios Services Limited, or Socios Europe Services Limited, or their respective affiliates.. Fan Tokens are not intended to be used as a means of payment or value transfer but are intended for fan engagement purposes.

Ongoing and Recurring Rewards for GAL Fan Token Holders In addition to special activations, $GAL Fan Token holders regularly enjoy:
  • Hospitality tickets
F.3 Planned application of functionalities Token holders may have access to a range of $GAL token-gated features, which can be accessed through Galatasaray S.K.'s native platforms or any other platform as may be decided in the future including the Socios.com fan engagement and rewards platform.

The functionalities available shall include, but not be limited to, benefits to be availed of on the Galatasaray S.K.’s own platforms. Over time, additional functionalities aimed at enhancing fan engagement with Galatasaray Spor Kulübü may be introduced, further enhancing the token holder experience, on the Socios.com platform or on any other third party platform developed within the Chiliz Chain ecosystem that decides to integrate the $GAL fan tokens.
Such features are subject to change and may be added, modified, or removed at the discretion of the Issuer or the Operator or based on Galatasaray Spor Kulübü Club instructions.
F.4 Type of crypto-asset white paper
OTHR
F.5 The type of submission
MODI
F.6 Crypto-asset characteristics General Characteristics:
Name: $GAL.
Type: Crypto-asset other than asset-referenced token or e-money token.
Blockchain: Chiliz Chain.
Overall Total Token Supply: 9,975,000 $GAL.
Public Offering Token Supply: 2,000,000 $GAL.
Token Standard: ERC-20 equivalent (CAP-20).

Classification under MiCA (Regulation (EU) 2023/1114):
The $GAL is classified as a crypto-asset other than asset-referenced token or e-money token.
Functionality:
To provide fans with access to exclusive experiences, rewards, and Web3 utilities, enhancing fan engagement with Galatasaray Spor Kulübü.
F.7 Commercial name or trading name Socios Service Limited
F.8 Website of the issuer https://www.socios.com/
F.9 Starting date of offer to the public or admission to trading 2025-02-04
F.10 Publication date 2026-01-26
F.11 Any other services provided by the issuer Socios Services Limited does not currently provide any other services.
F.12 Language or languages of the crypto-asset white paper 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 Not Available
F.14 Functionally fungible group digital token identifier, where available Not Available
F.15 Voluntary data flag FALSE
F.16 Personal data flag FALSE
F.17 LEI eligibility TRUE
F.18 Home Member State
Malta
F.19 Host Member States
Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden
GAL MiCA White Paper

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

N Field Content
G.1 Purchaser rights and obligations Rights of the Purchaser

Holding or trading the $GAL Fan Token does not grant ownership, governance, profit-sharing, or any analogous economic or corporate rights in Galatasaray Spor Kulübü, Socios Technologies AG, or any affiliated entity.

Within this framework, purchasers of the $GAL Fan Token are nevertheless granted limited rights associated solely with the acquisition and use of the token, as described below:

  • Token Allocation: Purchasers were entitled to receive $GAL tokens in proportion to their $CHZ contribution during the public offer.
  • Participation in a FairLaunch Public Offer: Purchasers were guaranteed equal access to the public offer, ensuring fairness and preventing overconcentration.
  • Token functionalities: Purchasers have the right to access specific fan engagement functionalities associated with their $GAL token, as provided on the Platform, along with additional functionalities that may be provided by third parties within the Chiliz Chain ecosystem.
  • Ownership Rights: Upon receipt, purchasers obtained ownership of the $GAL Fan Tokens solely as digital assets, which may be held, transferred, or traded once listed and admitted to trading on a trading platform, and used to access the utilities associated with them on the Platform. Such ownership does not confer any ownership interest, governance rights, profitsharing rights, or any other economic or corporate rights in Galatasaray Spor Kulübü, Socios Technologies AG, or any related entity. For the avoidance of doubt, purchasers may continue to hold or trade their $GAL Fan Tokens even if the associated functionalities are modified, expired, or removed as a result of the expiration or termination of the underlying partnership agreement.
    1. Obligations of the Purchaser
  • Payment commitment: CHZ contribution: Purchasers were required to contribute the amount of $CHZ specified in the FTO terms, which was equivalent to 2 TRY per $GAL, during the subscription period.
  • Technical Requirements: Socios Account Creation: To participate in the $GAL FTO in 2020, users were required to have created a Socios account before the offering was made available. For the sake of transparency, prior to the recent transition to the noncustodial wallet model in November 2024, users registering on the platform were automatically assigned a dedicated Socios.com custodial wallet for the storage of Fan Tokens.
  • Compliance with applicable laws and regulations:
    1. 1. Jurisdiction Restrictions: Users were prohibited from participating in the FTO if they were citizens or residents of any Excluded Jurisdictions, or any other jurisdictions outlined in the specific Terms and Conditions (TCs) for the FTO.
    1. 2. Legal restrictions: It was the user's responsibility to ensure that their participation in the FTO was not in violation of any laws, regulations, or rules in their country of residence or domicile. If there were any local legal restrictions, users were expected not to participate in the offering.
    1. 2.1 Age Requirement: Users were required to be at least 18 years old, or of the minimum legal age to obtain and hold Fan Tokens, according to the laws of their jurisdictions.
    1. 2.2 KYC/AML requirements adherence: Users must adhere to any and all AML/CFT requirements including customer due diligence requirements of the socios.com platform.
  • Acknowledgment and Acceptance of FTO Terms: Users must have read, understood, and accepted the specific Terms and Conditions (TCs) of the FTO before proceeding with their purchase.
G.2 Exercise of rights and obligations Aside from the rights and obligations described in G1, the following conditions shall apply:

  • The user understands that the Fan Tokens do not represent or constitute any ownership rights or stake, shares or security or equivalent rights in the Issuer, the Offeror, the Operator or the Partner i.e. Galatasaray Spor Kulübü and do not convey any rights to receive or participate in future profits, revenue streams, or proceeds that are related to the activities the Issuer, the Offeror, the Operator or the Partner;
  • The user understands that the Fan Tokens do not create or confer any enforceable contractual or other obligations against the Issuer, the Offeror, or the collaborating Partner and that the Fan Tokens do not grant to the user any license or right of any nature with respect to any intellectual property rights, rights of publicity, or equivalent rights in or related to the collaborating partner or any of its affiliates.
  • The user acknowledgeThe user acknowledges that the inclusion of functionalities in the Fan Token is not guaranteed, and as a result, the Fan Token may not provide the user with any Token Functionalities.In such cases, the Issuer, Offeror, Operator, Partner, or any third party will not be liable for any losses, expenses, or damages, and the user may lose access to any Token functionalities related to the Fan Token.
G.3 Conditions for modifications of rights and obligations The terms related to the crypto-assets and to the FTO, applicable to Fan Tokens holders, were made available and remain accessible on Socios.com website.
The Offeror reserves the right to change or amend such terms from time to time. In this case, the Offeror will inform the user about such changes. The Offeror will further change the “Last Updated” date at the top of the terms. To the extent permissible by law, any amended terms shall become effective immediately upon the date indicated in the terms. The user’s continued use of the Platform after the publishing of the amended terms constitutes user acceptance of such amended terms. It is the users responsibility to regularly check to read through such notices and updates.
G.4 Future public offers There are no future public offerings planned at the moment of writing the white paper.
G.5 Issuer retained crypto-assets N/A as the offering was structured such that, upon completion, Socios Services Limited (SSL), in its capacity as the Issuer, would retain and manage the non-circulating supply of $GAL—those Fan Tokens not made available in the public offering. In January 2021, this unsold and non-circulative $GAL reserve was transferred to Socios Technologies AG (STAG), which subsequently assumed responsibility for their allocation and ongoing management.
G.6 Utility Token Classification FALSE
G.7 Key features of goods/services of utility tokens N/A
G.8 Utility tokens redemption Not applicable. In any case, please note that when a user makes use of a particular Fan Token functionality, the Fan Token used to access the token functionality will not be burned, consumed, transferred, or otherwise surrendered but will remain with the user.
G.9 Non-trading request FALSE
G.10 Crypto-assets purchase or sale modalities The $GAL token was not sought or admitted to trading at the time of the FTO. Notwithstanding this, $GAL was subsequently admitted to trading on various third party platforms where separate terms and conditions may apply, including but not limited to: BtcTurk | Kripto, Paribu, OKX, Gate, Bybit, Bitget, and Mercado Bitcoin.
As the $GAL token is a CAP-20 token running on the Chiliz Chain, it is currently possible that $GAL may also be traded on decentralized exchanges, such as Kayen.org, the largest decentralized exchange native to the Chiliz Chain. For the sake of clarity, such decentralized Exchanges are not operated in any manner whatsoever by the Offeror or any of their Affiliates.
G.11 Crypto-assets transfer restrictions $GAL tokens were initially minted as ERC-20 tokens on the Chiliz private side chain, which was permissioned and not freely transferable. $GAL tokens were capable of being transferred as from 10th December 2020 when they became freely tradable on exchanges where the token was listed and admitted to trading. Before such admission to trading, the $GAL tokens could not be withdrawn from the Socios.com platform but were freely used for the utility rights attached to them on the Socios.com platform.
G.12 Supply adjustment protocols FALSE
G.13 Supply adjustment mechanisms This field does not apply, as G.12 is false.
G.14 Token value protection schemes FALSE
G.15 Token value protection schemes description This field does not apply, as G.14 is false.
G.16 Compensation schemes FALSE
G.17 Compensation schemes description This field does not apply, as G.16 is false.
G.18 Applicable law Malta
G.19 Competent court Subject to mandatory applicable law, any dispute arising out of or in connection with $GAL offer to the public and all claims related to the $GAL token were exclusive, including matters of validity, invalidity, breach, or termination, subject to the jurisdiction of the courts of Malta.
GAL MiCA White Paper

Part H – Information on underlying technology

N Field Content
H.1 Distributed ledger technology (DTL) The Chiliz Legacy Chain, also known as Chiliz Chain 1.0, was the original blockchain infrastructure used by Chiliz to facilitate the issuance, transfer, and storage of Fan Tokens, including $GAL. This chain operated as a closed ecosystem and a permissioned side chain, based on a Proof of Authority (PoA) consensus mechanism. It allowed for a controlled environment for the management of Fan Tokens. The migration to the Chiliz Chain (Chiliz Chain 2.0) occurred in 2023, bringing with it several enhancements in terms of consensus mechanisms, scalability, and decentralization.

The migration was executed in phases between June and September 2023, with all Fan Tokens, including $GAL tokens, being successfully transferred from the Legacy Chain to the Chiliz Chain by Q1 2024.

The migration was split into three steps:
  • Deployment of the Fan Token smart contracts on the new Chiliz Chain.
  • The migration of Fan tokens to the Chiliz Chain occurred both within the Socios.com app and on the exchanges that listed the tokens.
  • Opening up Withdrawals and Deposits of the Fan Tokens on the new network.
    1. Following this migration, the Legacy Chain was officially deprecated. As of Q1 2024, all new activities, including new Fan Token launches, have been conducted exclusively on the Chiliz Chain.
    1. Distributed ledger technology
    1. The Chiliz Legacy Chain was the original blockchain infrastructure used for the issuance and storage of $GAL, a token initially issued under the ERC-20 standard. However, following the migration to Chiliz Chain 2.0, the $GAL token is now managed on the Chiliz Chain, which operates under the CAP-20 token standard.
    1. The Chiliz Chain presents the following characteristics:
  • It is an EVM (Ethereum Virtual Machine) compatible blockchain. EVMcompatible blockchains implement the same instruction set and data structures as the Ethereum blockchain.
  • The Chiliz Chain follows a Proof of Staked Authority (PoSA) consensus mechanism, meaning that only a limited number of main validators can validate transactions and add blocks to the chain. New validators must stake Chiliz Token ($CHZ), the native token of the Chiliz Chain, and be approved by validators through onchain governance. Validator seats are currently limited to 13 (subject to onchain governance).
  • The Chiliz Chain can handle up to 400 Transactions per second (TPS).
  • Transaction costs on the Chiliz Chain are relatively low, with a minimum gas price of 2501GWEI (units used for the calculation of gas fees on EVMcompatible blockchains).
  • The Chain System contracts, including those responsible for core functionalities such as staking, governance, and upgrade mechanisms, are fully audited.
  • Tokens issued on the Chiliz Chain follow CAP20 Token Standard (ERC20 compatible).
H.2 Protocols and technical standards Protocols and technical standards

$GAL is deployed on Chiliz Chain, an EVM-compatible layer-1 blockchain described in the official documentation as a fork of BNB Smart Chain, itself a derivative of go-Ethereum. This heritage means Chiliz Chain inherits Ethereum-style account management, transaction encoding and developer tooling, while operating as a distinct network.

Token standard

The network’s fungible-asset standard is CAP-20, defined in the Chiliz documentation as Chiliz Chain’s ERC-20-style token standard. CAP-20 is code-equivalent to ERC-20 but enforces zero decimals, so all balances and transfers represent whole-number units. $GAL is treated as a standard CAP-20 Fan Token implementing the familiar ERC-20-style interface.

Interfaces and client standards

Wallets and applications connect to Chiliz Chain via standard JSON-RPC and WebSocket endpoints. At protocol level, this means Chiliz Chain follows standard Web3 RPC patterns. Any client that supports custom EVM networks can treat Chiliz Chain as another Ethereum-style chain, provided it uses the documented network parameters.
H.3 Technology used Implementation and architecture

The $GAL token contract runs on the Chiliz Chain client implementation published as open-source software in the chiliz-chain/v2 repository, written in Go. A separate genesis-configuration repository defines the chain parameters and network configuration. Together, these components define the execution and consensus stack within which the $GAL CAP-20 contract is deployed and executed.

Smart-contract platform and execution environment

Smart contracts on Chiliz Chain are written in Solidity 0.8.24 and compiled for the Shanghai-equivalent EVM introduced with the Dragon8 upgrade. Dragon8 implemented modern Ethereum proposals such as EIP-1559 and EIP-2718, aligning Chiliz Chain’s fee mechanics and transaction format with Ethereum.
All transactions on Chiliz Chain are metered using the EVM gas schedule and settled in CHZ, the network’s native token. The deterministic EVM runtime ensures that, given the same inputs and state, contract execution produces identical results across all validator nodes.

Transfer and interoperability technology

Before transferring $GAL, users must hold native CHZ to pay transaction fees. Once funded, the same wallet address receives or purchases $GAL. Transfers are then executed as standard CAP-20 transactions on Chiliz Chain, with gas paid in CHZ and finality achieved upon block confirmation.

Two smart-contract-based bridges maintain liquidity between Ethereum and Chiliz Chain:
  • Dcentralab’s Chainport, which converts ERC20 CHZ on Ethereum to wrapped CHZ (wCHZ) on Chiliz Chain;
  • the Chiliz Bridge, which performs a direct ERC20 to native CHZ conversion using paired contracts on Ethereum and Chiliz Chain.
    1. Protocol-wise, these bridges define the standard mechanism for moving CHZ between networks. They are primarily used to supply wallets with native CHZ on Chiliz Chain for gas, staking and governance.
H.4 Consensus Mechanism $GAL does not implement its own consensus mechanism. All $GAL transactions are executed within Chiliz Chain’s base layer execution environment and achieve finality once they are included in Chiliz Chain blocks that reach the relevant commitment level. Settlement, ordering and data availability are determined entirely by Chiliz Chain’s validator set. $GAL inherits those security and availability guarantees.

Chiliz Chain uses Proof of Staked Authority , a hybrid consensus mechanism that combines Proof-of-Authority-style validator rotation with Proof-of-Stake-based weighting and eligibility. A limited set of “Main Validators”, each required to bond CHZ and be approved through on-chain governance, is responsible for proposing and validating blocks, while additional validator candidates can remain in an active queue with bonded stake, ready to replace or supplement the main set as staking weights or governance decisions change. Main Validators take turns producing blocks in a deterministic rotation, rather than open competition, which keeps block times predictable. The Parlia consensus engine coordinates block production and interacts with system contracts that manage staking, validator-set updates, distribution of block rewards and penalties for misbehaving or offline validators. This PoSA design, adapted from BNB Smart Chain, is tuned for short block times, low transaction fees and fast practical finality suitable for consumer-facing applications such as Fan Tokens, while relying on a comparatively small validator set and therefore offering a lower degree of permissionless decentralisation than large, fully open validator networks.
H.5 Incentive Mechanisms and Applicable Fees $GAL benefits from Chiliz Chain’s low transaction fees, making it ideal for high-frequency trading and broad accessibility.

At the network level, the Chiliz Chain employs a gas-based fee model denominated in $CHZ. Every transaction specifies a gas limit and gas price; the product defines the maximum fee the sender is willing to pay. Validators collect these fees as compensation for processing transactions and securing the network. A base-fee adjustment mechanism modulates prices according to block utilisation, keeping costs low and predictable.

At protocol level, all on-chain transactions on Chiliz Chain, including $GAL CAP-20 transfers, pay gas fees in CHZ, the native token. Transactions are priced using standard EVM gas semantics, and since the Dragon8 hard fork the network supports EIP-1559-style type-2 transactions with a dynamically adjusted base fee and optional priority fee.
H.6 Use of distributed ledger technology FALSE
H.7 DLT functionality description N/A
H.8 Audit TRUE
H.9 Audit outcome Halborn’s Chiliz Chain Core Contracts
Object: Core Chiliz Chain smart contracts used at mainnet launch, including the staking contract, governance contract and bridge contract.
Findings: Minor risks were identified in these contracts, with no indication of unresolved high-severity issues at launch.
Remediation: The necessary fixes were implemented before the 2023 mainnet launch, and the contracts remain subject to further audits when they are upgraded.

CertiK’s Governance and Core Contracts
Object: Smart contracts underpinning Chiliz governance and core V2 contracts, including the V2 Genesis Contracts and related upgradeable components, as well as the on-chain vote token implementation reviewed under the Chiliz project on CertiK Skynet.
Findings: No critical issues, several major centralisation-type findings, plus medium, minor and informational issues, all marked as acknowledged.
Remediation: The identified issues have been addressed.

Halborn’s Chiliz Bridge Smart-Contract Audit
Object: Smart-contract infrastructure for the Chiliz Bridge that connects CHZ between Ethereum and the Chiliz Chain.
Findings: No critical, unaddressed issues.
Remediation: Subsequent updates to bridge logic are tracked via blockchain code-change logs and outage reports.
GAL MiCA White Paper

Part I - Information on risks

N Field Content
I.1 Offer-related risks Not applicable, as neither a public offering of the $GAL Fan Token is being conducted nor an admission to trading is being sought at the time this White Paper is drawn up and notified to the competent authority.
I.2 Issuer-related risks Regulatory Compliance Risks: Issuers of crypto assets must adhere to a wide array of regulatory requirements across different jurisdictions. Non-compliance can result in fines, sanctions, or the prohibition of the crypto asset offering, impacting its viability and market acceptance.

Operational Risks: These include risks related to the Issuer's internal processes, personnel, and technologies, which can affect their ability to manage crypto-asset operations effectively. Failures in operational integrity might lead to disruptions, financial losses, or Issuer’s reputational damage.

Legal Risks: Legal uncertainties, potential lawsuits, or adverse legal rulings can pose significant risks to issuers. Legal challenges may affect the legality, usability, or value of a crypto-asset.

Reputational Risks: Negative publicity, whether due to operational failures, security breaches, or association with illicit activities, can damage an Issuer's reputation and, by extension, the value and acceptance of the crypto-asset.

Dependency on Key Individuals: The success of some crypto projects can be highly dependent on the expertise and leadership of Issuer’s key individuals. Loss or changes in the project’s leadership can lead to disruptions, loss of trust, or project failure.

Counterparty Risks: Risks associated with the Issuer's partners, suppliers, or collaborators, including the potential for non-fulfillment of obligations that can affect the Issuer’s operations.
I.3 Crypto-assets-related risks Regulatory Risks:
  • Regulatory uncertainty: The regulatory environment surrounding cryptoassets is constantly evolving, which can directly impact their usage, valuation, and legal status. Changes in regulatory frameworks may introduce new requirements related to consumer protection, taxation, and antimoney laundering compliance, creating uncertainty and potential challenges for token holders and businesses operating in the crypto space.
    1. Market and Liquidity Risks:
  • Volatility risk: $GAL’s value is likely to be highly volatile and subject to market speculation. The Fan Tokens’ price may fluctuate significantly, resulting in potential losses.
  • Liquidity risk: The availability of liquidity depends on the level of trading activity on decentralized exchanges (DEXs) and, where applicable, on centralized exchanges (CEXs). Insufficient trading volume could hinder the ability to buy or sell the Fan Tokens.
    1. Adoption Challenges
    1. If users do not engage with the $GAL as expected, demand for the token may remain low.
    1. Macroeconomic risk
  • Global Economic Factors: A crypto market crash or financial crisis could reduce interest and investment in the token.
    1. Reputational Concerns
  • Cryptoassets are often subject to reputational risks stemming from associations with illegal activities, highprofile security breaches, and technological failures. Such incidents can undermine trust in the broader crypto ecosystem or specific project, negatively affecting investor confidence and market value, thereby hindering widespread adoption and acceptance.
I.4 Project implementation-related risks Competition risk
It should be noted that the project may face strong competition from other similar projects or the token may have low liquidity in the secondary market, which may hinder its success.

Token Functionalities
The User understands that the Partnership Agreements with Galatasaray S.K. will eventually expire or may be terminated and the User acknowledges that $GAL Fan Tokens may partially or fully lose their Token Functionalities as a result of such expiration or termination.
I.5 Technology-related risks Operational and Technical Risks
Blockchain Dependency Risk: The $GAL token is built on the Chiliz Chain, making it inherently reliant on the stability, security, and long-term operation of the underlying blockchain. Any disruptions, protocol upgrades, or governance decisions on the Chiliz Chain could potentially impact the token’s functionality, transaction speed, and overall ecosystem integration. Changes to gas fees, validator incentives, or consensus mechanisms may also influence transaction costs and user adoption.

Smart Contract Risks
Despite thorough testing and audits, smart contracts are susceptible to vulnerabilities such as logic errors, reentrancy attacks, or integer overflows. If an exploit is discovered in the $GAL token’s contract, it could lead to financial losses, token theft, or unintended behaviors.

Private key management
The security of crypto-assets heavily depends on the effective management of private keys, which serve as the only means to access and control digital funds. Losing a private key or engaging in poor security practices, such as sharing or storing keys insecurely, can result in the irreversible loss of assets. Additionally, theft or unauthorized access to private keys can lead to the complete loss of funds, emphasizing the importance of secure key storage solutions like hardware wallets and multi-signature schemes.

Network Security Risks
While Chiliz Chain benefits from robust blockchain security, it remains susceptible to network-level attacks such as Sybil attacks, 51% attacks, or DDoS attempts on validators.

Transaction Finality
Transactions on the Chiliz Chain achieve finality probabilistically, meaning their security increases as more blocks are confirmed. However, theoretical risks of transaction reversals exist, particularly in cases of blockchain reorganizations or consensus attacks. Furthermore, transactions sent to incorrect or unintended addresses are typically irreversible, making it crucial for users to double-check addresses and transaction details before execution.

Scalability issues
As blockchain networks experience increased adoption and usage, scalability challenges can arise. A higher number of transactions on the Chiliz Chain might lead to network congestion, resulting in increased transaction fees, slower confirmation times, and reduced usability.

Consensus Failures
Issues with a blockchain’s consensus mechanism can lead to serious disruptions such as network forks, operational halts, and a loss of trust among participants. Forks can result in duplicate transactions or diverging ledger states, causing confusion and potential financial losses.

Ecosystem Dependency Risks
The $GAL token is currently compatible with many platforms across the Chiliz Chain or even the wider EVM Ecosystem. It is always best practice to only interact with reputable platforms.

Evolving Technology Risks
Blockchain technology is rapidly evolving, and new standards, protocols, or competitor chains could render existing token implementations obsolete.
I.6 Mitigation measures Smart Contract Risks
Comprehensive Testing: The smart contracts were extensively tested in multiple scenarios to ensure reliability and correctness during token distribution and refunds. However, the User understands and acknowledges that complex software such as the smart contract system, and all other software applications that are used for the Fan Token Offering are never entirely free from defects, errors, bugs, and security vulnerabilities, and that the Issuer therefore does not warrant thatthe Fan Token will be free from defects, errors, and bugs. If any issues or problems arise in connection with the participation in the Fan Token Offering, it may take days, weeks or months to resolve, and some issues may not be resolved at all.

Network Security Risks
Validator Network Diversity: Chiliz Chain’s validator network continues to grow and diversify, enhancing resilience against potential centralization or targeted attacks. However, the User understands and acknowledges that any transaction of Fan Token may be delayed or not be executed due to the transaction volume on the blockchain, mining attacks and/or similar events.
Tokens on blockchain platforms face multiple risks including software errors, network connectivity disruptions, hardware failures, security threats from hacking or unauthorized access, and changes in consensus rules. Additionally, forks, validator penalties, and fluctuations in token stability and value can affect tokens adversely. These issues can lead to token loss or negatively impact their value.

Evolving Technology Risks
Adoption of Updates: The $GAL project team actively monitors advancements in blockchain technology and commits to adopting improvements in the Chiliz Chain ecosystem to maintain competitiveness.
GAL MiCA White Paper

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

N Field Content
S.1 Name Socios Technologies AG
S.2 Relevant legal entity identifier 984500B6F8407AE38911
S.3 Name of the crypto-asset $GAL
S.4 Consensus Mechanism $GAL does not implement its own consensus mechanism. All $GAL transactions are executed within Chiliz Chain’s base layer execution environment and achieve finality once they are included in Chiliz Chain blocks that reach the relevant commitment level. Settlement, ordering and data availability are determined entirely by Chiliz Chain’s validator set. $GAL inherits those security and availability guarantees.
Chiliz Chain uses Proof of Staked Authority, a hybrid consensus mechanism that combines Proof-of-Authority-style validator rotation with Proof-of-Stake-based weighting and eligibility. A limited set of “Main Validators”, each required to bond CHZ and be approved through on-chain governance, is responsible for proposing and validating blocks, while additional validator candidates can remain in an active queue with bonded stake, ready to replace or supplement the main set as staking weights or governance decisions change. Main Validators take turns producing blocks in a deterministic rotation, rather than open competition, which keeps block times predictable. The Parlia consensus engine coordinates block production and interacts with system contracts that manage staking, validator-set updates, distribution of block rewards and penalties for misbehaving or offline validators. This PoSA design, adapted from BNB Smart Chain, is tuned for short block times, low transaction fees and fast practical finality suitable for consumer-facing applications such as Fan Tokens, while relying on a comparatively small validator set and therefore offering a lower degree of permissionless decentralisation than large, fully open validator networks.
S.5 Incentive Mechanisms and Applicable Fees $GAL is issued on the Chiliz Chain: On the Chiliz Chain, both validators and delegators are incentivized through a structured staking model. Validators are responsible for creating and validating blocks, and in return, they earn rewards derived from transaction fees and a portion of the network's inflationary token supply. Delegators, who may not run validator nodes themselves, can participate by delegating their CHZ tokens to chosen validators. This delegation allows them to earn a share of the validators rewards proportional to the amount of CHZ tokens delegated, thereby promoting broader community involvement and greater security. Transaction fees are low and encourage widespread participation and high volume of transactions. Additionally, the network has implemented a transaction fee burning mechanism inspired by EIP-1559 governance proposal, where a significant portion of the gas fees is burned at the protocol level, introducing a deflationary mechanism to CHZ token supply.
S.6 Beginning of period to which disclosed information relates 2024-08-22
S.7 End of period to which disclosed information relates 2025-08-22
S.8 Energy consumption 114.14821
S.9 Energy consumption sources and methodologies The energy consumption of this asset is aggregated across multiple components: To determine the energy consumption of a token, the energy consumption of the network(s) chiliz is calculated first. For the energy consumption of the token, a fraction of the energy consumption of the network is attributed to the token, which is determined based on the activity of the crypto-asset within the network. When calculating the energy consumption, the Functionally Fungible Group Digital Token Identifier (FFG DTI) is used - if available - to determine all implementations of the asset in scope. The mappings are updated regularly, based on data of the Digital Token Identifier Foundation. The information regarding the hardware used and the number of participants in the network is based on assumptions that are verified with best effort using empirical data. In general, participants are assumed to be largely economically rational. As a precautionary principle, we make assumptions on the conservative side when in doubt, i.e. making higher estimates for the adverse impacts.
S.10 Renewable energy consumption N/A as the energy consumption value (S.8) does not exceed 500,000 kilowatt-hours as set forth in article 4.2 of Commission Delegated Regulation (EU) 2025/422 of 17 December 2024 supplementing Regulation (EU) 2023/1114 of the European Parliament and of the Council with regard to regulatory technical standards specifying the content, methodologies and presentation of information in respect of sustainability indicators in relation to adverse impacts on the climate and other environment-related adverse impacts.
S.11 Energy intensity N/A (see S.10)
S.12 Scope 1 DLT GHG emissions - controlled N/A (see S.10)
S.13 Scope 2 DLT GHG emissions - purchased N/A (see S.10)
S.14 GHG intensity N/A (see S.10)
S.15 Key energy sources and methodologies N/A (see S.10)
S.16 Key GHG sources and methodologies N/A (see S.10)
S.17 Energy mix
Renewable: 17.204390967%; Other (unspecified fossil/energy sources): 82.795609033%
S.18 Energy use reduction N/A
S.19 Carbon intensity N/A
S.20 Scope 3 DLT GHG emissions – Value chain N/A
S.21 GHG emissions reduction targets or commitments N/A
S.22 Generation of waste electrical and electronic equipment (WEEE) N/A
S.23 Non-recycled WEEE ratio N/A
S.24 Generation of hazardous waste N/A
S.25 Generation of waste (all types) N/A
S.26 Non-recycled waste ratio (all types) N/A
S.27 Waste intensity (all types) N/A
S.28 Waste reduction targets or commitments (all types) N/A
S.29 Impact of the use of equipment on natural resources N/A
S.30 Natural resources use reduction targets or commitments N/A
S.31 Water use N/A
S.32 Non recycled water ratio N/A
S.33 Other energy sources and methodologies N/A
S.34 Other GHG sources and methodologies N/A
S.35 Waste sources and methodologies N/A
S.36 Natural resources sources and methodologies N/A
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