TOKEN MODELS (A / B / C) AND REGULATORY FRAMEWORK (ARGENTINA)

1. Purpose and Scope

This section describes, at a conceptual level, three token configurations contemplated for structures linked to mining projects and summarizes their main regulatory implications in Argentina. The final regulatory classification depends on the specific token design, the associated economic rights, and the manner in which the token is offered and circulated.

2. Legal and Offering Disclaimers

This material is published exclusively for informational and educational purposes. It does not constitute (i) a public or private offering, (ii) an invitation to make an offer, (iii) an investment recommendation, (iv) legal, financial, tax, or accounting advice, nor (v) a commitment to issue, place, or list any instruments.

No offering of negotiable securities, virtual assets, or financial instruments is made through this medium, and no person is requested to make investment decisions based on this content.

The definitive regulatory classification of any structure depends on the facts and on the specific design (including, among others, the economic right represented, the homogeneity/fungibility of the instrument, the existence or absence of a secondary market, the distribution method, the target audience, transfer restrictions, and the applicable contractual documentation). Regulatory interpretation may vary depending on the case and the competent authority.

MineriumX may require due diligence processes, onboarding, contractual documentation, and/or compliance validations before enabling access to expanded information or to a Data Room, where applicable.

3. Token Typologies (A / B / C)

3.1. Token A — “Commodity-linked”

Conceptual definition:
A token linked to a commodity (e.g., a mineral), conceived as a digital representation of a physical asset or of a right directly associated with that asset.

Regulatory reading (high level):

• When the token is structured as a representation of a right to the physical asset (e.g., ownership rights or redemption/delivery of the commodity), it may approximate the concept of a commodity token.
  
  
  

• Regulatory risk increases when the token ceases to represent a right to the physical asset and instead represents payment rights, synthetic exposure to price variation, or incorporates promises/expectations of returns (e.g., royalties, participation in sales, or other benefits).
  
  
  

• Variables such as homogeneity/fungibility, expectation of profit derived from the efforts of others, and generalized circulation (including the existence or enablement of a secondary market) are relevant to assessing whether the token could be treated as a negotiable security or investment contract under the applicable legal framework.
  
  

Practical implication:
For Token A, the design of the tokenized right and the circulation conditions are decisive for regulatory classification.

3.2. Token B — “Cashflow / Royalties-linked”

Conceptual definition:
A token representing rights to receive payments or to participate in economic flows linked to a project (e.g., royalties, net revenues, future receivables, or other credit rights).

Regulatory reading (high level):

• By its nature, this configuration tends to align with the logic of an investment contract or an instrument representing economic rights within the capital markets framework.
  
  
  

• In local practice, structures of this nature may present similarities to securitization schemes, depending on how cash flows, guarantees, and investor rights are structured.
  
  
  

Practical implication:
For Token B, the definition of the offering regime (public or private), distribution restrictions, and transferability conditions are usually central to structuring the instrument in compliance with applicable regulations.

3.3. Token C — “Equity / Debt-linked”

Conceptual definition:
A token representing equity (shares/ownership interests) or corporate debt (e.g., negotiable obligations or other debt instruments).

Regulatory reading (high level):

• This type of asset typically falls within the universe of negotiable securities.
  
  
  

• A generalized and impersonal offering may constitute a public offering, subject to applicable authorizations and regulatory requirements before the competent authority.
  
  
  

Practical implication:
For Token C, classification as a negotiable security and the applicable offering regime are structural elements.

4. Regulatory Classification Conclusions

• Tokens B and C present a high probability of falling under the negotiable securities regime, given the nature of the underlying economic rights (cash flows/credit rights in B; equity/debt in C).
  
  
  

• For Token A, classification may vary: the closer it is to a direct right to the physical commodity or redemption, the lower the risk; the more it incorporates payment rights, yield, or synthetic price exposure (and/or generalized circulation), the higher the regulatory risk.
  
  
  

• Even where a token qualifies as a negotiable security, its commercialization may be structured without a public offering, through a private offering regime, provided that the applicable conditions are met (scope, target investors, dissemination restrictions, and other relevant criteria).
  
  
  

5. Comparative Table

6. Publication Scope and Updates

This content is published as a general framework. The specific documentation of any structure (including terms, risks, transferability limitations, placement modality, investor rights, guarantees, events, and enforcement mechanisms) will be set out, where applicable, in contractual documentation and/or in a Data Room under controlled access.