BNKA

ANNEX A: OPERATIONAL TRANSITION AND CONTRACTUAL ADAPTATION PLAN — MiCA REGULATION – EUROPEAN ECONOMIC AREA

Supplement to the General Terms and Conditions of Use of the BNKA Platform.

This Annex establishes the formal procedure for the cessation, liquidation, and orderly safeguarding of the platform's digital asset services vertical within the European Economic Area (EEA), in strict compliance with Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCA).

1. Definitive Suspension of Digital Asset Operations

Effective July 1, 2026, the platform will permanently cease all active operations related to crypto-assets for EEA users, including, without limitation, the functions of purchasing, exchanging (inbound swap), receiving, and depositing new digital funds. Any incoming transfer executed after this date will be rejected by network nodes, and the platform disclaims all liability for asset losses in disabled channels.

2. Liquidation and Mandatory Withdrawal Window

A grace period is established, concluding on July 30, 2026. During this interval, users with crypto-asset balances greater than zero ($>0$) will have restricted access in "Withdrawal-Only" mode to exclusively carry out:

Ordinary Conversion: Final sale of their crypto-assets with direct crediting to their fiduciary balances in Euros (EUR), which remain fully operational.

External Withdrawal (On-Chain): Transfer of their assets to external addresses under their control, operating through the compatible blockchain networks indicated in the user interface (e.g., SOL and TRX).

3. Treatment of Non-Operable Technical Balances

For balances whose residual amounts fall below the platform's minimum transaction thresholds, or that do not cover the network/gas fees required for an on-chain transfer, a Voluntary Waiver and Technical Write-Off flow is enabled. This process will be executed exclusively from the mobile application through express confirmation of these terms and dual identity validation via a robust authentication factor (security code sent via SMS to the holder's mobile device). Once completed, the balance will be irreversibly adjusted to zero.

4. Regime for Blocked Residual Balances and Inactive Custody Administrative Fee

After the Liquidation Period ends on July 30, 2026, the platform will proceed with the definitive closure of the operational digital asset databases. Crypto-asset balances that have not been withdrawn by the user will be transferred outside the ordinary mobile interface environment to contingency technical custody accounts, and the user will lose the right of autonomous disposal.

In order to cover the extraordinary costs of technical security, segregated infrastructure, specific key control, and regulatory compliance for orphaned balances under the new European Union legal framework, starting on day sixty (60) after the Deadline, BNKA will apply an Inactive Balance Custody Administrative Fee of up to the equivalent of EUR 10.00 per month.

This fee will be automatically and directly deducted from the user's remaining balance until the account balance reaches zero ($0$). The legitimate holder may only request that this charge be stopped through the definitive liquidation and manual withdrawal of their remaining funds, formally managed through the oversight channel compliance@bnka.com, subject to strict and up-to-date identity verification (KYC) and source of funds verification (AML).

5. Continuity of the Fiduciary Business (EUR)

It is expressly stated that this contractual adaptation plan affects exclusively and solely the crypto-asset vertical. Fiduciary payment accounts, Euro (EUR) balances, virtual technical identifiers (vIBANs), and European Economic Area (SEPA) transfer rails are not affected in any way; they remain fully in force and continue to operate with total normalcy and under the corresponding regulatory protection and safeguard schemes.