Last Updated: July 17, 2026

Crosmsint Europe, S.L. (Crossmint Europe)

1.     INTRODUCTION 

Crossmint Europe, S.L. (hereinafter, “Crossmint” or the “Entity”) is a provider of cryptoasset services, registered with the corresponding official registry of the National Securities Market Commission (“CNMV”).

This Commercial Communications Policy (the “Policy”) has been developed by Crossmint with the aim of establishing an internal framework to ensure that the Entity’s commercial or advertising communications are prepared, reviewed, approved, and disseminated in accordance with applicable regulations, in particular, the provisions of Regulation (EU) 2023/1114 of the European Parliament and of the Council of May 31, 2023, on crypto-asset markets (“MiCA Regulation”), as well as its implementing regulations.

Furthermore, in drafting this Policy, consideration has been given to all other regulations that may be applicable to advertising, commercial communications, and communications with customers or potential customers, such as:

●      Law 34/1988 of November 11, the General Advertising Law, 

●      Law 3/1991, of January 10, on Unfair Competition, and 

●      Royal Legislative Decree 1/2007, of November 16, approving the consolidated text of the General Law for the Protection of Consumers and Users and other complementary laws, insofar as they establish the general framework applicable to advertising, commercial practices, and misleading acts and omissions.

Commercial communications sent by email or other equivalent electronic means must also comply with Law 34/2002, of July 11, on Information Society Services and Electronic Commerce.

2.     PURPOSE

The purpose of this Policy is to establish a regulatory framework to ensure that Crossmint’s commercial communications are impartial, clear, identifiable as such, and not misleading, and to prevent them from misleading customers or potential customers regarding the nature, characteristics, risks, costs, fees, or real or perceived benefits of cryptoassets or the cryptoasset-related services provided by the Entity.

The Policy aims to ensure that commercial communications are consistent with the pre-contractual, contractual, regulatory, and public information made available to clients, and that Crossmint can demonstrate, when necessary, the controls applied to such communications

This Policy applies to commercial communications regarding cryptoasset services provided by Crossmint in accordance with its business program, namely: custody and management of cryptoassets on behalf of clients; exchange of cryptoassets for funds; exchange of cryptoassets for other cryptoassets; and transfer of cryptoassets on behalf of clients. This Policy does not govern the operational content of such services nor does it supersede Crossmint’s specific policies that may apply in each case.

3.    DEFINITION OF COMMERCIAL COMMUNICATION

For the purposes of this Policy, “commercial communication” means any communication made by Crossmint, or by a third party on behalf of Crossmint, in the course of its professional activities, intended to directly or indirectly promote the purchase, use, or awareness of its cryptoasset services, products, brand, or business.

This concept includes both advertising communications in the strict sense and marketing materials, commercial campaigns, promotional content on social media, promotional electronic communications, sponsored content, sales materials, commercial communications on the website or app, and public appearances for promotional purposes.

The following shall not be considered commercial communications, unless they include promotional content: individualized responses to customer requests for information; legal or contractual notifications; communications regarding orders, transfers, or operational incidents; security communications; regulatory compliance communications; and communications issued in the context of complaint and claim management.

4.     SCOPE OF APPLICATION: SUBJECT 

This Policy applies to all directors, executives, and employees of Crossmint. Likewise, where applicable, this Policy may apply to agents, third parties, and any affiliated persons who perform any function on behalf of or in the name of Crossmint with respect to the Company’s commercial communications (hereinafter, the “Covered Persons”).

5.     ROLES AND RESPONSIBILITIES

5.1. Board of Directors

The Board of Directors shall be responsible for the following functions: 

●      Approving this Policy and any relevant amendments thereto.

●      Reviewing and approving the general guidelines for commercial communications. 

●      Ensuring that appropriate functions, responsibilities, and controls are in place for the preparation, review, approval, publication, and monitoring of commercial communications.

●      Receiving, when appropriate, information regarding relevant incidents, non-compliance, or significant risks identified in the area of commercial communications.

5.2. Compliance

The Regulatory Compliance department will be responsible for overseeing compliance with this Policy and applicable regulations in this area. Furthermore, with regard to commercial communications, it will carry out the following tasks: 

●      Verify that commercial communications comply with the principles defined in this Policy. 

●      Review the inclusion, adequacy, and visibility of any applicable legal notices, risk warnings, disclaimers, or mandatory disclosures.

●      Oversee the retention of records documenting the review and approval process for commercial communications.

●      Participate in the subsequent follow-up phase, reviewing incidents, complaints, requests from authorities, or potential deviations detected after the dissemination of a communication.

●      Advise the Marketing Department and business units on the requirements applicable to commercial communications.

5.3. Marketing Department 

The Marketing Department must perform the following functions: 

●      Identify the need, purpose, and target audience for each commercial communication.

●      Develop the content, design, and format of commercial communications, taking into account the intended distribution channel.

●      Incorporate the changes requested during the review phase.

●      Coordinate the publication or distribution of commercial communications once the corresponding internal approvals have been obtained.

●      Retain, or facilitate the retention of, the final versions distributed, publication dates, channels used, and other relevant evidence.

●      Monitor published communications and report any incidents, complaints, or requests for withdrawal or modification to Regulatory Compliance.

6.     PRINCIPLES 

Crossmint’s commercial activities shall be governed by the following principles: 

●      Impartiality: Communications will present information objectively, without unduly emphasizing the benefits over the applicable risks, costs, or limitations. 

●      Clarity: Commercial communications must be written in clear, simple language that is understandable to the target audience, avoiding formats or expressions that hinder understanding of the essential characteristics of the promoted product. 

●      Non-misleading Communications: Communications must not contain information that is false, inaccurate, incomplete, or likely to mislead customers or potential customers. 

●      Identification: All commercial communications must be identified as such, regardless of the channel or medium used. 

7.     ADVERTISING AND COMMERCIAL ACTIVITIES

7.1. Procedures and Internal Controls

When developing commercial communications and campaigns, the Marketing Department will first prepare an initial briefing that details the following: 

a)     Campaign duration: start and end dates.

b)     Objectives of the commercial initiative.

c)     Target audience.

d)     Description of the product or service to be promoted.

The briefing prepared by the Marketing Department will be submitted to the Company’s Board of Directors for review and initial evaluation. In particular, the Board will analyze the appropriateness of the proposed commercial communication, piece, or campaign, its alignment with the Company’s strategy, and its overall compliance with the principles established in this Policy. If approval is granted, the Marketing Department will proceed to develop the content, design, and format of the commercial communication.

Once the communication has been prepared, it will be forwarded to the Regulatory Compliance Department for review of its compliance with applicable regulations, as well as its consistency with the principles established in this Policy. Furthermore, the department will verify, where applicable, the inclusion of legal disclaimers, mandatory disclosures, risk information, or any other required references based on the content, channel, or target audience.

Once approved by Regulatory Compliance, the communication may be processed for publication, using the following channels: i) website; ii) brochures and communications addressed to customers; iii) media outlets; iv) social media.

7.2.         Specializations by Channel

Website, Apps, and Other Proprietary Digital Content

Commercial content published on Crossmint’s website, app, platform, or any other proprietary digital channel must comply with the principles set forth in this Policy. In particular, content describing products, services, or their functionality must accurately reflect their characteristics and risks, or include a link to the webpage where such information is provided.

The pricing, cost, and fee policy must be prominently displayed on the Crossmint website

Commercial communications (email and other electronic means)

Commercial communications sent by email or other equivalent electronic means must comply with applicable regulations regarding electronic commercial communications. In particular, they must be identifiable as such, identify Crossmint as the entity on whose behalf they are sent, and be sent only when requested or authorized by the recipient, unless a legal exception applies.

Crossmint must provide the recipient with a simple and free means to object to or unsubscribe from these communications, and will respect any unsubscriptions, objections, and preferences communicated by recipients.

Electronic commercial communications must be sent through systems, tools, or accounts authorized by Crossmint. Personal accounts or unauthorized means shall not be used to disseminate commercial communications on behalf of the Entity

Social Media

Commercial communications on social media must adhere to the same principles of clarity, identification, and non-misleading nature as any other commercial communication from Crossmint. Crossmint’s official social media accounts may only be created, managed, suspended, or deleted by internally authorized individuals or teams.

Employees must not make anonymous statements or recommendations, or post links to Crossmint’s websites, products, or services in chat rooms, online forums, or third-party websites, unless they are authorized to do so.

Crossmint may monitor, moderate, or remove third-party communications, comments, or posts on its channels when they could be interpreted as an endorsement, recommendation, or approval by Crossmint, or when they are deemed inappropriate, offensive, or contrary to this Policy

Other Media

Only individuals authorized by Crossmint may speak publicly on behalf of the Company in interviews, conferences, seminars, webinars, podcasts, publications, presentations, or other similar formats.

Scripts, slides, brochures, or other materials prepared for public appearances, seminars, or promotional activities must be reviewed in accordance with this Policy prior to use.

When an authorized person expresses personal opinions in a context where there may be confusion with Crossmint’s official position, they must make it clear that such opinions do not necessarily reflect Crossmint’s position, views, or policies.

7.3. Use of Third Parties

In the course of its business activities, Crossmint may contract with third parties specializing in the field to carry out, support, advise on, or disseminate commercial or advertising campaigns. 

In any case, responsibility for reviewing commercial content rests with Crossmint. 

Likewise, if third parties are contracted to disseminate commercial communications, this activity will not be carried out under an agency model; such third parties may not solicit clients or provide services on behalf of Crossmint and receive compensation for doing so. The services provided by third parties will be limited exclusively to the dissemination and advertising promotion of the services provided by Crossmint. 

7.4.         Prohibited or Unpermitted Communications

No commercial communication containing false, inaccurate, ambiguous, unbalanced, or misleading information that could mislead customers, potential customers, or the public will be approved or disseminated. 

Nor will communications be approved that present Crossmint’s cryptoassets or services as safe, guaranteed, risk-free, or suitable for any type of customer when this is not accurate; that conceal or omit information necessary for the recipient to make an informed decision; that highlight benefits or advantages without reflecting the relevant risks or conditions; that suggest unjustified guarantees of profitability or future results; or that encourage excessively risky trading. 

Commercial communications containing recommendations or advice regarding a security, a cryptoasset, or a trading strategy—including sales materials, studies, or materials prepared or provided by a party that is not independent of Crossmint—may not be disseminated.

Likewise, testimonials, reviews, third-party content, or commercial collaborations must not be used in a way that could mislead regarding the independence of the message, the existence of a commercial relationship, the actual experience of other clients, or the possibility of achieving similar results.

8.     RECORD-KEEPING

Crossmint maintains an internal record of the advertising activities carried out by the Entity. The record will include documentation corresponding to each advertising campaign conducted, organized by calendar year and identified by sequential order number and trade name. Specifically, the record will contain the following information: 

1. General campaign details; 

2. Specific information about the advertising materials; and

3. Monitoring information regarding the advertising campaign in question. 

The record will be kept up to date at all times and retained for 5 years from the start of the advertising campaign. 

9.     APPROVAL AND REVISION OF THE POLICY

This Policy will be approved by Crossmint’s Board of Directors, as will any subsequent amendments. 

The Policy will be reviewed at least once a year and will be updated and/or amended, at a minimum, in the following cases: 

-        When legal or regulatory changes occur that affect the provisions of this document. 

-       At the proposal of the Compliance Department or Marketing Department when it deems that there are aspects that could be improved to achieve the proposed objectives or to adapt appropriately to the characteristics of the services offered by Crossmint at any given time. 

-       At the request of regulatory authorities. 

-       At the request of regulatory authorities.