Particula Code of Professional Conduct

Preamble

Particula is committed to contributing to a fair, efficient, and transparent digital asset market by delivering independent, data-driven, and methodologically sound Digital Asset Risk Ratings ("Risk Ratings"). These assessments are designed to reduce information asymmetry and support investor decision-making, particularly in the context of evolving tokenized asset structures. Ratings produced by Particula reflect the application of the Particula Digital Asset Risk Framework (PDARF). PDARF generates point-in-time risk indicators based exclusively on verifiable on- and off-chain data. These indicators reflect observed risk exposures at the time of review. The framework is not forward-looking and does not incorporate scenario analysis, market forecasts, or analyst discretion in the scoring process; all outputs are derived from the consistent application of the framework itself. Adjustments, where necessary, are made exclusively at the framework level and follow the defined governance process. Scores do not represent credit ratings under applicable regulatory definitions and are not intended to assess default probability or expected loss.

This Code of Conduct defines the principles governing the integrity, quality, and independence of the risk rating process. It outlines measures to safeguard confidential information, ensure analytical rigor, manage conflicts of interest, and promote transparency and accountability throughout all aspects of the assessment process. Particula ensures that the information used in its Risk Ratings is of sufficient quality and derived from reliable sources, including third-party data providers. Risk Ratings are produced without any form of analyst discretion and are based exclusively on the structured application of PDARF. Any adjustments to methodology occur only at the framework level, under the oversight of the relevant governance bodies.

All employees and consultants engaged by Particula are required to uphold the highest standards of professional conduct and to comply with this Code of Conduct and related policies. Annual training and attestation are mandatory. Oversight of compliance lies with the Head of Risk and Compliance. The Code, along with the General Terms and Conditions and the Platform Terms of Service, is publicly available on Particula’s website1. In the event of any inconsistency between this Code and the General Terms and Conditions, the latter shall prevail. All applicable disclaimers are incorporated by reference.

¹ Although, in the interest of transparency, we have posted this Code and other related policies on Particula’s public website, Particula does not assume, as a result of such public disclosure, any responsibility or liability to any third party arising out of or relating to this Code or those policies. The Particula Code is not part of any contract with any third party, and no third party shall have any right to enforce any of its provisions. Particula also retains complete discretion to revise this Code at any time to reflect changes in Particula ratings policies and procedures or to address changes in market, legal, or regulatory circumstances.

Defined Terms

For the purposes of this Code, the following terms apply. Additional definitions from the General Terms and Conditions and the Platform Terms of Service are incorporated by reference.

Analyst - Any employee or consultant of Particula whose responsibilities include (a) supporting the generation and ongoing monitoring of Risk Ratings produced through the structured application of the Particula Digital Asset Risk Framework (PDARF); (b) contributing to the development and refinement of methodologies, models, or assessment tools used in the risk rating process; or (c) supervision of individuals performing such functions.

Employee - Any full-time or part-time staff member, contractor, or consultant engaged by Particula or any of its affiliated entities. All individuals performing rating-related activities are subject to this Code of Conduct.

Methodology - The formally documented Particula Digital Asset Risk Framework (PDARF), which defines the scoring logic, attribute design, and data aggregation principles used to generate Ratings. Methodology changes are implemented only at the framework level and are subject to governance review.

Rating Personnel - All individuals involved in the design, validation, quality control, oversight, or implementation of the methodology and scoring infrastructure used to generate Risk Ratings. This includes Analysts, as well as team members responsible for model calibration, data integration, and automated tooling. Risk Ratings are derived exclusively from the structured application of the framework and not assigned through individual discretion.

1. Quality and Integrity of the Rating Process

A. Quality of the Rating Process

1. Particula’s Risk Ratings are derived from the quantitative, rule-based application of the framework set forth in the PDARF and are intended to reduce information asymmetry by offering structured, point-in-time assessments of digital assets. A Risk Rating is not a credit rating assessing creditworthiness and does not incorporate analyst judgement or forward looking assumptions. Ratings are based on the framework and analytical processes as per the PDARF, subject to periodic validation and review.

2. All Risk Ratings are generated using the deterministic rating framework subject to periodic backtesting and internal validation. The rating framework is subject to ongoing review to ensure it captures all material risk attributes and enables a comprehensive, multidimensional assessment of digital asset risks. Analysts shall apply the approved and published version of the rating framework rigorously and consistently in connection with Particula’s Risk Ratings and the PDARF, in accordance with the General Terms and Conditions and all applicable internal procedures.

3. Only verifiable, relevant, and high-quality data inputs - sourced from on-chain records and reliable off-chain disclosure (including third-party sources) - may be used in Risk Ratings. All underlying data, assessments, and model interactions used to produce a Risk Rating shall be retained and documented in accordance with applicable data governance policies. Particula commits to ensuring that appropriate analytical and operational resources are allocated to support accurate and timely Risk Ratings and associated monitoring functions.

4. Particula reserves the right to change, suspend, or withdraw a Risk Rating at any time if it determines that there has been a material change in the underlying information used in the rating framework, or if sufficient and reliable data is no longer available to support the assessment as further set forth in the General Terms and Conditions.

B. Monitoring and Updating

5. All Risk Ratings, including public, private and confidential ratings, are monitored on an ongoing basis using automated oversight mechanisms. Formal reassessments beyond the ongoing monitoring with respect to applicability of the framework to the particular digital asset, and appropriateness of the risk rating levels, are conducted at least annually, or sooner if triggered by significant developments.

6. Where material changes are observed in risk-relevant data inputs to a Risk Rating, the Risk Rating will be updated in accordance with the framework set forth in the PDARF and as more fully set forth in the General Terms and Conditions.

7. Changes to the framework set forth in the PDARF are implemented through a structured governance process as set forth in the PDARF. Revisions to PDARF will be communicated to all relevant stakeholders promptly. All impacted Risk Ratings are re-evaluated using the updated framework, and any required changes to the risk ratings are reflected promptly.

C. Integrity of the Rating Process

8. Particula, along with all its Analysts and Employees, adheres to all applicable laws, regulatory requirements, and governance standards.

9. Particula, along with all its Analysts and Employees, shall conduct all interactions with clients, issuers, investors, and other market participants in a fair, transparent, honest and professional manner. Risk Ratings are not pre-negotiated or previewed; no assurance or indication of score outcomes is provided prior to the finalization of the assessment. Particula will not provide rating advisory services, act as brokers or dealers, or have financial interests in rated digital assets or issuers of such rated assets.

10. Particula is committed to producing Risk Ratings that are independent, objective, and derived exclusively from its published rating framework. While feedback from issuers or other stakeholders may be reviewed, any revisions to the rating framework or resulting Risk Ratings will be made solely based on Particula’s independent and data-driven assessment, in accordance with the procedures outlined in the General Terms and Conditions.

2. Independence and Management of Conflicts of Interest

A. General

11. Risk Ratings are produced independently of any commercial or strategic relationships. No business consideration, including issuer engagement or revenue, shall influence scoring outcomes.

12. Rating Personnel (i.e. Analysts or Employees taking part within the rating process) are operationally segregated from all revenue-generating and business development activities to avoid conflicts of interest. All Employees must maintain professional objectivity and act without bias or undue influence in the execution of their duties to maintain independence and objectivity.

13. Analysts and Rating Personnel are prohibited from soliciting or accepting cash, gifts, or items of value that could compromise, or appear to compromise, analytical independence.

14. Rating Personnel shall receive annual training on this Code of Conduct to ensure alignment with its principles and consistent application across the organization. This training reinforces the standards of analytical independence, objectivity, and professional integrity expected of all Employees.

B. Procedures and Policies

15. Particula maintains formal policies to identify, manage and mitigate actual or potential conflicts of interest, including compliance reviews.

16. Rating Personnel compensation is not tied to the issuance or outcome of individual Risk Rating and excludes metrics based on issuer engagement or revenue performance.

17. Employees engaged in employment negotiations with an entity involved in a Risk Rating must disclose the interaction and be recused from the relevant assessment.

C. Analyst and Employee Independence

18. Rating Personnel and Employees shall not participate in assessments involving entities in which they hold financial interests or with whom they have material personal relationships.

19. Rating Personnel must disclose any circumstance that may give rise to a conflict of interest to their manager or to the Head of Risk and Compliance.

20. Rating Personnel and their immediate family members - defined as the employee's spouse or domestic partner (or any other person with whom an employee cohabits and shares financial responsibilities) - are prohibited from holding or trading digital assets associated with any issuer rated by Particula.

21. Annual attestations by Rating Personnel are required to confirm compliance with this Code of Conduct, including a declaration that neither they nor their immediate family members have had financial interest in any digital assets or tokens issued by entities rated by Particula.

22. If a Rating Personnel or Employee is determined to be in a conflict of interest- whether through financial holdings, immediate family relationships, or trading activity by themselves or their immediate family members - they shall be immediately recused from all current and future assessments involving the affected entity. The matter will be escalated to the Head of Risk and Compliance for formal review. Appropriate remedial actions, including reassignment, additional disclosures, or internal disciplinary measures may be taken to safeguard the integrity of the Risk Rating process and ensure ongoing compliance with this Code.

3. Responsibilities to the Investors and Issuers

A. Transparency and Timeliness of Ratings Disclosure

23. Risk Ratings and related actions will be communicated to relevant stakeholders in a timely and transparent manner, in accordance with this Code of Conduct and the General Terms and Conditions. The type of Risk Rating, which may be classified as public, private or confidential, will determine the appropriate mode and scope of disclosure. Public Risk Ratings will be published through Particula’s official channels; private Risk Ratings will be disclosed only to designated recipients; and confidential Risk Ratings will remain internal unless explicitly authorized for release. Particula reserves the right to revise or withdraw a Risk Rating if material changes occur in the underlying data or if updates to the rating framework materially affect the outcome, as further set forth in the General Terms and Conditions.

24. Particula encourages issuers of digital assets to publicly disclose relevant and verifiable information to support transparent assessments. However, confidential information provided directly by issuers may also be considered in the Risk Rating process, provided it meets Particula’s data assurance standards and is handled in accordance with applicable confidentiality protocols.

25. Confidential or private Risk Ratings that have entered the public domain will be treated as public and updated accordingly, provided that sufficient and verifiable data remains available to support the assessment.

B. Treatment of Confidential Information

26. All issuer-supplied confidential information is subject to strict confidentiality protections and is used solely for assessment purposes in accordance with PDARF and the General Terms and Conditions.

27.  Employees will not disclose non-public or confidential information except where legally required or formally authorized for regulatory disclosure upon the request of regulatory bodies.

28. Employees may not use confidential information for personal or third-party benefit, including trading in associated digital assets.

29. Employees will protect confidential information with respect to a Risk Rating, including the timing or content of pending Risk Ratings (except to the issuer and its designated agents) and as set forth in the General Terms and Conditions.

30. Particula employs technical and procedural safeguards to prevent fraud, use, or misuse or inadvertent disclosure and adheres to information security protocols.

4. Governance, Risk Management, and Training

31. Management and the Head of Risk and Compliance is responsible for implementing and enforcing this Code, and any associated policies and procedures.

32. All Employees undergo mandatory onboarding and ongoing training to ensure a clear understanding of this Code of Conduct, and related compliance obligations. Continuous training includes annual attestations on conflicts of interest and professional conduct, as well as yearly compliance training. Additional ad-hoc training is provided whenever material updates are made to the Code or related compliance obligations to ensure continued organizational alignment and awareness.

33. Particula will establish and maintain measures that Employee shall follow to address complaints regarding its Risk Ratings or Methodologies, as well as good faith reports that an Employee has violated applicable law or regulations or engaged in unethical Conduct. Particula will not retaliate against Employees who take action pursuant to this latter provision.

34. Particula maintains experienced leadership and qualified personnel, supported by established risk management procedures designed to identify and mitigate potential risks arising from its Risk Ratings and operations, including regulatory, reputational, operational, and strategic risks.

5. Enforcement and Communication

35. This Code will be made publicly available via Particula’s website and shared with all Employees and applicable third parties.

36. Management and the Head of Risk and Compliance maintains the primary responsibility, with the support of the company management, for monitoring adherence to this Code and addressing all confirmed breaches in accordance with internal disciplinary policy.

37. The Code is subject to review at least annually and may be updated to reflect changes in regulation, methodology, or internal procedures.

38. All Employees must review and attest to their compliance with this Code of Conduct on an annual basis.