Legal Documentation
Sustainable Digital Assets Inc.
Inside Information Policy
Effective Date: 1 January 2024
Last Updated: 15 September 2024
Review Frequency: Quarterly or upon material regulatory changes
Purpose and Scope
This Inside Information Policy ensures that Sustainable Digital Assets Inc. ("SDA", "Company") complies with the disclosure requirements under EU Regulation 2023/1114 (MiCA) and provides transparent, timely, and fair information to all market participants.
Definition of Inside Information
For the purposes of SDA Token disclosures, "inside information" means information that:
- Is precise and relates directly to SDA Token or underlying projects
- Has not been made public through our official disclosure channels
- Would be likely to significantly affect the token price or investor decisions
- Relates to circumstances that exist or may reasonably be expected to occur
Disclosure Channels and Distribution
Primary Disclosure Channels
| Channel | Type | Target Audience | Update Frequency |
|---|---|---|---|
| Company Website | https://sdafintech.com/inside-information | General Public | Real-time |
| RSS Feed | Machine-readable updates | Automated systems | Real-time |
| Email Alerts | Subscriber notifications | Registered investors | Immediate |
| Media Distribution | Press releases | Financial media | Same-day |
| Social Media | @SDAFintech verified accounts | General public | Within 1 hour |
✅ Simultaneous Disclosure Commitment
All material information is disclosed simultaneously across all channels to ensure fair access. No selective disclosure to specific investors, analysts, or media representatives occurs prior to public announcement.
EU-Wide Media Distribution
To ensure compliance with MiCA requirements for EU-wide disclosure, we distribute material information through:
- European newswire services: Reuters, Bloomberg European, PR Newswire Europe
- Financial media: Financial Times, Börsen-Zeitung, Il Sole 24 Ore, Les Échos
- Crypto-specific outlets: CoinDesk, CoinTelegraph, The Block (European editions)
- Regulatory channels: National competent authority notifications where required
Information Subject to Disclosure
Mandatory Disclosure Categories
🏗️ Project Development Updates
- Major milestone achievements or delays
- Material changes to project timelines
- Significant partnership announcements
- Regulatory approval status changes
- Technology deployment updates
💰 Financial and Commercial Developments
- Phase transition triggers (market cap thresholds)
- Material fundraising or capital events
- Significant revenue or asset acquisition announcements
- Changes to dividend or profit-sharing policies
- Material cost overruns or budget revisions
⚖️ Legal and Regulatory Matters
- Regulatory license applications and outcomes
- Legal proceedings that could materially affect operations
- Changes in regulatory status or classification
- Compliance issues or regulatory enforcement actions
- Material changes to legal structure
🔧 Technical and Operational Issues
- Smart contract upgrades or security issues
- Significant operational disruptions
- Cybersecurity incidents affecting investor assets
- Changes to custody or safeguarding arrangements
- Platform or technology failures
👥 Governance and Management
- Changes to executive team or board composition
- Material governance policy updates
- Token holder voting outcomes
- Changes to token economics or supply
- Strategic direction shifts
Disclosure Timeline Requirements
Critical security incidents, trading halts, emergency measures
Material financial events, regulatory actions, major partnership announcements
Project updates, governance decisions, operational changes
Quarterly reports, annual reviews, planned updates
Contact Information
Disclosure Officer: Chief Compliance Officer
Email: legal@sdafintech.com
Phone: +358 30 623 0300
Media Inquiries: media@sdafintech.com
Investor Relations: investors@sdafintech.com
Note: This policy is subject to updates based on regulatory requirements and operational needs. Always refer to the latest version available on our website.