OKX Middle East BETH Whitepaper

VIRTUAL ASSET WHITEPAPER

BETH

OKX Staked ETH

Issuer:

OKX Middle East Fintech FZE

VARA Licence Reference VL/23/12/003

Prepared under Part III and Schedule 1 of the VA Issuance Rulebook

Version 1.0

Date: 6 August 2026

REGULATORY DISCLAIMER

VARA has not taken any steps to verify the information set out in this whitepaper, including its accuracy and completeness, and has no responsibility for any loss arising from reliance on it. The liability for the content of this whitepaper lies solely with the Issuer, OKX Middle East Fintech FZE.

VARA has not made any representation and does not provide any warranties regarding any Issuer or Virtual Asset including, but not limited to, their fitness for purpose, suitability or regulatory status in any jurisdiction other than the Emirate of Dubai, UAE.

BETH is a Category 2 Virtual Asset. No Virtual Asset issued under Category 2 shall be deemed to have been approved by VARA, and the issuance of this whitepaper shall not be construed as an endorsement by VARA of the Issuer or of BETH.

A. Information about the Issuer

A.i Name, legal structure, registered address and head office

A.ii Date of incorporation or registration

The Issuer was incorporated on 15 September 2022.

A.iii Parent company

The Issuer's parent company is OKX Global Holding Company Limited, incorporated in the British Virgin Islands.

A.iv Identities, business addresses and functions of owners, management and members

The Issuer is part of the OKX group. Its owners, senior management and members, together with their business addresses (each at the Issuer's registered office in Dubai, UAE, unless otherwise notified) and their functions, are as follows:

A.v Convictions and investigations

To the best of the Issuer's knowledge, and following due diligence enquiries, no individual involved in the issuance, including the Issuer's owners, management and members, has been convicted of any offence of dishonesty, fraud, financial crime, or any offence under laws relating to companies, banking, insolvency, money laundering or insider dealing. To the extent permissible under applicable laws, no such individual is subject to ongoing inquiries or investigations in respect of such offences.

A.vi Business activities, regulatory authorisations and Licences of the Issuer and its group

The Issuer is a Virtual Asset Service Provider licensed by VARA under Licence reference VL/23/12/003, issued on 17 September 2024 (CMA Registration Number CMA-VASP-1001010-0008). The Issuer is authorised to provide the following Virtual Asset Services in and from the Emirate of Dubai (excluding the DIFC):

• VA Exchange Services, including VA Derivatives Trading;

• VA Broker-Dealer Services;

• VA Management and Investment Services; and

• VA Lending and Borrowing Services.

On 8 June 2026, VARA granted the Issuer a Limited Licence Approval supplementing Licence VL/23/12/003, permitting the Issuer to issue and distribute BETH as a liquid staking token. BETH is a Category 2 VA Issuance.

The Issuer forms part of the OKX group, a global group of companies engaged in the provision of Virtual Asset and related technology services across a number of jurisdictions, certain members of which hold authorisations from the relevant regulators in those jurisdictions.

A.vii Financial condition over the past three years

The Issuer maintains a sound financial condition and holds capital and liquid assets in accordance with the prudential requirements applicable to it under the VARA Company Rulebook. The Issuer prepares financial statements and submits periodic financial and regulatory reporting to VARA. The Issuer's financial condition has remained stable, and the Issuer has at all times maintained compliance with the applicable capital and prudential requirements.

A.viii Assessment of development, performance and position

The Issuer commenced its licensed Virtual Asset activities in Dubai following the grant of its VASP Licence and has since developed its regulated business in a controlled and measured manner consistent with the conditions of its Licence. The development, performance and position of the Issuer's business have been stable over the relevant period, and there have been no material adverse changes to its financial position. This assessment is consistent with the size and complexity of the Issuer's business.

A.ix Governance arrangements

The Issuer maintains a governance framework consistent with the VARA Compulsory Rulebooks. The framework comprises a board of directors with oversight of the Issuer's strategy, risk and compliance, supported by management and control functions including the General Manager, the Compliance Officer and Money Laundering Reporting Officer, the Finance Officer, the Information Technology Officer, the Data Protection Officer and the Risk Officer. The Issuer ––– operates a three lines of defence model and maintains documented policies covering, among other matters, conduct of business, risk management, anti-money laundering and counter-terrorist financing, technology and information security, outsourcing, conflicts of interest, complaints handling, business continuity and wind down. These arrangements are designed to ensure effective oversight, accountability and risk management across the Issuer's regulated activities.

A.x Other Virtual Assets issued or other Virtual Asset Activities undertaken

In addition to BETH, the Issuer issues OKSOL, which is also a liquid staking token and a Category 2 VA Issuance and is the subject of a separate whitepaper. The Issuer also undertakes the Virtual Asset Activities described in paragraph A.vi above.

A.xi  Connection between the Issuer and the controller of the DLT

BETH is not issued on a public distributed ledger; it is an on-platform record maintained by the Issuer. The underlying ETH committed by clients is staked by the Issuer on the Ethereum network, a public, permissionless network that is not run, managed or controlled by the Issuer or by any Entity closely connected to the Issuer. There is no connection between the Issuer and any Entity or organisation that has control of the Ethereum ledger. The Issuer operates its own validators through which the underlying ETH is staked; participating as a validator does not give the Issuer any control over the Ethereum ledger itself.

A.xii Entities involved in the issuance and operation

The following Entities are involved in the issuance and operation of the Virtual Asset:

B. Information about the Virtual Asset

B.i  Name, abbreviation or ticker

B.ii  Characteristics, features and uses

BETH is a liquid staking token issued by the Issuer that represents ETH staked through the Issuer's staking service. BETH is recorded as a balance within the Issuer's platform; it is not an on-chain token. When a client commits ETH for staking through the Issuer's platform, the Issuer credits BETH to the client's account on the platform. The number of BETH in issue is equal at all times to the number of ETH committed by clients for the staking service. The characteristics, features and uses of BETH are:

• it represents staked ETH on a one-to-one (1:1) basis;

• it entitles the holder to receive Ethereum consensus-layer rewards (attestations, block proposals and sync committee duties), execution-layer rewards (priority fees), and any maximal extractable value rewards captured by the validators, net of the Issuer's service fee;

• it is redeemable for the underlying ETH on a 1:1 basis through the Issuer's redemption process, as described in Section C;

• it may be held, transferred to other clients of the Issuer, and traded on the Issuer's platform; and

• it may be used as collateral for lending and margin products offered by the Issuer on the same platform.

BETH exists only as a record within the Issuer's platform and is available only on that platform. It is not represented on any public distributed ledger, cannot be withdrawn to an external or self-custodied wallet, and cannot be transferred off the Issuer's platform.

B.iii  Plans, milestones and resources

BETH is an established liquid staking token offered by the OKX group, and is offered by the Issuer in Dubai under the Limited Licence Approval referred to in paragraph A.vi. The Issuer has allocated the operational, technology, compliance and risk resources necessary to operate the staking service, the issuance and redemption of BETH, and the related reporting to VARA.

B.iv  Target market and restrictions

BETH is made available, on the Issuer's platform, to Retail Investors, Qualified Investors and Institutional Investors as defined in the VARA Compulsory Rulebooks, who have completed the Issuer's onboarding requirements and accepted the Issuer's staking terms and Terms of Service. BETH is not available to sanctioned persons, to persons in jurisdictions where the Issuer does not offer the service, or to any person not eligible to hold or transact in Virtual Assets under applicable law.

B.v  Trading platform, access and costs

Admission to trading of BETH is sought only on the OKX platform operated by the Issuer. Clients access the platform through the Issuer's web interface and mobile application after completing onboarding. The costs involved are the trading and related fees set out in the Issuer's published fee schedule. BETH is not admitted to trading on any other platform.

B.vi  Technical requirements to own or hold the Virtual Asset

BETH is held as a balance in the client's account within the Issuer's platform. Holding BETH requires an onboarded account with the Issuer. Because BETH is an on-platform record rather than an on-chain token, it is not compatible with any external or self-custodied VA Wallet and cannot be held outside the Issuer's platform.

B.vii  Issuance structure

B.viii  Planned use of proceeds or consideration

BETH is not issued for monetary proceeds. The consideration received by the Issuer is the ETH committed by clients for staking, which is staked through the validators described in Section A.xii in order to generate staking rewards. Client-committed ETH is used only for the staking service and is not otherwise deployed by the Issuer.

C. Information about the rights and obligations attached to the Virtual Asset

C.i  Characteristics and functionality, and any changes

BETH entitles the holder to the economic benefits of the staked ETH that it represents, namely the right to receive staking rewards net of fees and the right to redeem for the underlying ETH on a 1:1 basis. The Issuer has no current plans to change the functionality of BETH. Any material change to the functionality of BETH would be notified to clients and reflected in an updated whitepaper.

C.ii  Rights and obligations of the owner, and how they are exercised

BETH represents a contractual claim against the Issuer. The holder has the right to:

• receive Ethereum staking rewards and other rewards attributable to the staked ETH, net of the Issuer's service fee; and

• redeem BETH for the underlying ETH on a 1:1 basis.

These rights are exercised through the Issuer's platform in accordance with the Issuer's staking terms and Terms of Service. BETH does not confer any ownership, governance or voting rights in the Issuer or any group entity, nor any governance or voting rights over the Ethereum protocol.

C.iii  Whether rights differ by DLT or platform

BETH is recorded and used only on the Issuer’s platform and is not represented on any distributed ledger. Accordingly, the rights attached to BETH do not differ by distributed ledger or platform.

C.iv  Conditions under which rights and obligations may be modified

The rights and obligations attached to BETH are governed by the Issuer's staking terms and Terms of Service, which may be amended in accordance with their terms. Material amendments will be notified to holders in accordance with the Conduct of Business requirements of the VARA Compulsory Rulebooks, and holders may redeem their BETH before a material adverse change takes effect.

C.v  Subsequent issuances with a dilutive effect, and units retained by the Issuer

Each unit of BETH is backed by one unit of client-committed ETH. Subsequent issuances of BETH are made only against further ETH committed by clients and do not have a dilutive effect on existing holders. To the extent the Issuer or a member of its group holds BETH, it is created under the same one-to-one (1:1) staking mechanism that applies to all clients; the Issuer does not retain any BETH by way of pre-mine, reserved supply or special allocation.

C.vi  How and where the Virtual Asset can be purchased or sold after issuance

After issuance, BETH can be purchased or sold, or redeemed for ETH, only on the Issuer's platform. It cannot be purchased, sold or transferred on any other platform or off the Issuer's platform.

C.vii  Restrictions on transferability

BETH may be transferred only between onboarded clients of the Issuer, as a record within the Issuer’s platform, subject to the Issuer’s operational rules, including recipient KYC status, transfer limits and sanctions screening, and applicable law. Because BETH is an on-platform record rather than an on-chain token, it cannot be transferred to an external wallet or off the Issuer’s platform. A permitted transfer takes effect as an update to balances within the Issuer’s platform; no on-chain transaction is involved.

C.viii  Protection schemes

There is no protection scheme protecting the value of BETH or any investment in BETH. No government or industry compensation or deposit insurance scheme applies to BETH or to the underlying staked ETH.

C.ix  Nature and enforceability of rights, including redemption and claims against the Issuer

Each unit of BETH represents an enforceable contractual right against the Issuer to redeem for one unit of the underlying ETH through the Issuer's redemption process, and to receive staking rewards net of fees. The right of redemption subsists for so long as BETH is held and the staking terms remain in effect, subject to the unbonding mechanics described in paragraph C.xiv and to any suspension of redemption permitted under the staking terms (for example, in circumstances of force majeure, technical incident, or as required by applicable law or regulatory direction).

Staking of the underlying ETH is subject to slashing risk under the Ethereum protocol, whereby a portion of staked ETH may be penalized in the event of validator downtime or misbehaviour. Any loss of underlying ETH resulting from slashing is not replaced by the Issuer and will reduce the amount of ETH available for redemption by BETH holders accordingly.

C.x Nature and enforceability of rights, including redemption and claims against the Issuer in the event of insolvency

In the event that the Issuer becomes insolvent or subject to any analogous proceeding, holders of BETH will have a claim against the Issuer in respect of their contractual right to redeem BETH for the underlying ETH. BETH does not constitute a deposit, and holders have no priority, security interest, or proprietary claim over the ETH held by the Issuer or its appointed staking infrastructure providers. Recovery in an insolvency, liquidation, or similar recovery or resolution process will depend on the assets available for distribution and the ranking of BETH holders' claims under the applicable insolvency law of the jurisdiction governing the Issuer, and may be partial or nil. No scheme of arrangement, recovery plan, or resolution mechanism specific to BETH holders currently exists.

C.xi Allocation of rights among owners

All BETH holders are subject to the same terms and conditions and are allocated identical rights, including the right to redeem BETH for the underlying ETH on a 1:1 basis and to receive staking rewards net of fees, as described in paragraph C.ix. No class or category of BETH holder is afforded preferential, subordinated, or otherwise differentiated rights. This uniform treatment reflects the Issuer's approach of applying a single, non discriminatory set of terms to all BETH holders regardless of holding size, date of acquisition, or channel of acquisition.

C.xii  Liquidity arrangements

Liquidity in BETH is provided through redemption for the underlying ETH on a 1:1 basis, and through trading on the Issuer's platform. The Entity responsible for these arrangements is the Issuer, OKX Middle East Fintech FZE.

C.xiii  Complaints contact and complaints-handling and dispute resolution procedures

Customers are not subject to any fees or charges for the submission or handling of complaints. Complaints in connection with BETH may be submitted to the Issuer through any of the following channels: the online “Contact Us” form at the foot of the OKX website; by email to support.uae@okx.com (generally responded to within one business day); by submitting a ticket through the contact page or the in-app support tool after logging in; or through LiveChat with a live agent via the website help centre. Where a complaint exceeds the scope of the Issuer's Customer Service Representatives or involves a third party, it is escalated to the relevant vendor management team and, if necessary, to the Issuer's Compliance team for resolution. The Issuer's Formal Complaint Handling Process is published at https://www.okx.com/help/complaints-handling-process.

C.xiv  Rights of redemption and how the Virtual Asset is redeemed

C.xv  Material legal or regulatory considerations

Holders should be aware of the following material legal and regulatory considerations applicable to owning, storing, transferring or using BETH:

• BETH is offered under a Category 2 VA Issuance and a Limited Licence Approval; the regulatory treatment of the Virtual Asset may change and the permissions granted to the Issuer may be modified or terminated by VARA;

• BETH may be held and transferred only on the Issuer's platform; and

• holders are responsible for compliance with the laws applicable to them, including any tax obligations, in their jurisdiction of residence.

C.xvi  Applicable law and competent court

The law applicable to BETH is the law of the Emirate of Dubai and the applicable federal laws of the United Arab Emirates, and the competent court is the Dubai Courts.

D. Information about underlying technology

D.i  Technology, DLT, protocols and technical standards

BETH is not issued on a distributed ledger and is not an on-chain token; it is recorded and maintained as a balance within the Issuer’s platform systems. The underlying asset that BETH represents is ETH, which the Issuer stakes on the Ethereum network. Ethereum is a public, permissionless Layer 1 distributed ledger that has operated a proof-of-stake consensus mechanism since the Merge in September 2022. The holding, recording and transfer of BETH are effected within the Issuer’s platform; the staking of the underlying ETH uses standard Ethereum network interfaces and protocols.

D.ii  Consensus mechanism

The underlying ETH is staked on Ethereum, which operates a proof-of-stake consensus mechanism (Gasper), combining the LMD-GHOST fork choice rule with Casper FFG finality. Each validator requires 32 ETH of effective stake and earns rewards for attestations, block proposals and sync committee participation. BETH itself is an on-platform record and is not issued on any distributed ledger; accordingly no variance in the rights of owners arises from differences between consensus mechanisms on different DLTs.

D.iii  Incentive mechanisms and applicable fees

The staking of the underlying ETH on the Ethereum network is secured by the proof-of-stake (Gasper) consensus mechanism, under which validators are rewarded for participating in consensus and may incur penalties for misbehaviour or downtime. BETH holders receive the Ethereum consensus-layer rewards (attestations, block proposals and sync committee duties), execution-layer rewards (priority fees), and any maximal extractable value rewards captured by the validators, net of the Issuer’s service fee, which is set out in the Issuer’s published fee schedule. Network transaction fees on the Ethereum network apply to the staking of the underlying ETH in the ordinary way; transfers of BETH between clients occur within the Issuer’s platform and do not incur Ethereum network fees.

D.iv  DLT operated by or on behalf of the Issuer, and audits

BETH is not issued, transferred or stored using a distributed ledger; it is an on-platform record maintained by the Issuer. The Ethereum ledger, on which the underlying ETH is staked, is not operated by the Issuer or by any third party on the Issuer’s behalf; it is a public, permissionless network.The Issuer operates its own validator infrastructure that participates in the Ethereum network on the same basis as other validators. The Issuer's validator infrastructure has not been the subject of an independent audit. The Issuer monitors validator performance on an ongoing basis through its own internal validator performance dashboard.

D.v  Environmental and climate-related impact

Since the Merge in September 2022, Ethereum has operated on proof-of-stake consensus. Third-party studies estimate that the transition reduced the network's energy consumption by more than 99.9% compared with the previous proof-of-work model.

E. Information about the Licensed Distributor

All placement and distribution of BETH is carried out by the Issuer in its capacity as Licensed Distributor. The particulars of the Licensed Distributor are:

F. Information about any initial offer to the public of the Virtual Asset

BETH is not the subject of an initial offer to the public. BETH is issued continuously, on demand, in exchange for ETH committed by clients for staking, and is not offered through a public offering, token sale or comparable distribution event.