The $5,000,000 USDG Kraken Futures Challenge

PARTICIPATION IN THIS PROMOTION REQUIRES ENROLLMENT AND TRADING ON KRAKEN FUTURES. PARTICIPANTS ARE RANKED BY WEIGHTED TRADING VOLUME, NOT BY PROFIT. THE SIZE OF THE REWARD POOL DEPENDS ON THE TOTAL TRADING VOLUME OF ALL PARTICIPANTS AND IS NOT GUARANTEED. ONLY THE PARTICIPANTS DESCRIBED IN SECTION 5 WILL RECEIVE A REWARD.

Futures and derivatives trading involves a high degree of risk and is not suitable for all investors. Leverage can work against you. You may lose more than your initial deposit. Ensure you fully understand the risks before trading. Futures products are not available in all jurisdictions.

These terms and conditions (the “Terms”) govern The $5,000,000 USDG Kraken Futures Challenge (the “Promotion”). By enrolling in the Promotion, you agree to be bound by these Terms and by the Kraken Terms of Service applicable to you (the “Kraken Terms”). If there is any conflict between these Terms and the Kraken Terms in relation to the Promotion, these Terms will prevail. You should not trade more than you otherwise would, or take on risk you do not understand, in order to participate in the Promotion. Nothing in the Promotion constitutes investment, financial, or trading advice.

1. Sponsor

The Promotion is sponsored by Tulip HoldCo Ltd. (company number 2121376), 2nd Floor, Water’s Edge Building, Wickhams Cay II, Road Town, Tortola, British Virgin Islands (“Kraken” or the “Sponsor”). Futures services are provided by Kraken Derivatives, the trading name of Payward Digital Solutions Ltd., a Bermuda company licensed to conduct digital asset business by the Bermuda Monetary Authority. Eligible clients that have agreed to the relevant terms and conditions will access futures contracts listed on multiple venues via Payward Digital Solutions Ltd. Rewards under this Promotion will be paid by Tulip HoldCo Ltd. or an affiliate of Tulip HoldCo Ltd. acting on its behalf.

2. Eligible Areas

The Promotion is open to eligible customers residing in jurisdictions where Kraken Futures trading is available to them, excluding the United States, the United Kingdom, the European Economic Area, Switzerland, Canada, Australia, Brazil, and Argentina.  Void where prohibited.

3. Promotion Period

The Promotion begins at 13:30:00 UTC on October 12, 2026 and ends at 23:59:59 UTC on December 10, 2026 (the “Promotion Period”). Kraken’s systems are the official timekeeping device for the Promotion.

4. How to Participate

To participate, you must:

(a) log in to your Kraken account, or create one, and have access to Kraken Futures;

(b) enroll in the Promotion by selecting “Join the Challenge” on the Promotion page at https://pro.kraken.com/app/promos/trading-competitions/futures-5m-usdg-challenge-10-26

during the Promotion Period; and

(c) trade Eligible Instruments (defined below and listed in Annex A) on Kraken Futures during the Promotion Period.

Only trades executed after your enrollment is confirmed and within the Promotion Period count toward your Trading Volume. Trades executed before enrollment, including the opening of any position opened before enrollment, do not count.

Definitions. For the purposes of these Terms:

• “Eligible Instruments” means the Kraken Futures contracts listed in Annex A, as available to you during the Promotion Period.
• “Trading Volume” means the USD notional value of each filled order on an Eligible Instrument executed from your enrolled account after your enrollment is confirmed, including opening and closing trades (and closing trades on positions you opened before enrolling) and both maker and taker, as calculated by Kraken, excluding any Excluded Volume. Volume from your sub-accounts is aggregated at the master-account level.
• “Weighted Trading Volume” means your Trading Volume on each Eligible Instrument multiplied by the applicable weighting (3x for the Gold Instrument, 2x for RWA Instruments and 1x for Crypto Instruments, each as listed in Annex A), summed across all Eligible Instruments.
• “Community Volume” means the Weighted Trading Volume, during the Promotion Period, of all participants who meet the Qualifying Minimum (defined below), excluding Excluded Volume, as calculated by Kraken. Community Volume is a weighted measure. It is not the actual USD value traded by participants, and the Community Volume thresholds in Section 5 are expressed in weighted USD.
• “Excluded Volume” means any volume that Kraken determines arises from Prohibited Trading Activity (Section 9.1) or from an Excluded Account (Section 8), and any fills resulting from liquidation.

Qualifying Minimum. To be ranked and eligible for a Reward, you must achieve at least USD 50,000 in Trading Volume (not Weighted Trading Volume) during the Promotion Period.

5. Ranking and Reward Distribution

Ranking. Qualifying participants are ranked on a leaderboard by Weighted Trading Volume, from highest to lowest. Profit and loss is not considered. If two or more participants have the same Weighted Trading Volume, the participant who reached that total first will rank higher. The leaderboard displayed during the Promotion Period is indicative only; final rankings are subject to verification under Sections 7 and 9 and will be published within a reasonable time after the end of the Promotion Period.

Reward Pool. The Reward Pool is determined by the highest tier whose Community Volume threshold is met at the end of the Promotion Period:

Rewards by rank (USDG). Each qualifying participant will receive the Reward shown for their final rank under the Reward Pool tier achieved:

Tail Pool. The Tail Pool is shared equally among all qualifying participants ranked 51st or lower, based on final rankings.

If fewer qualifying participants exist than the number of Rewards available, unallocated Rewards will not be distributed. Rewards are not cumulative across tiers; each participant receives only the Reward for the final tier achieved.

6. Rewards

Rewards are paid in USDG and credited to the winner’s Kraken spot account. The maximum total value of all Rewards is 5,000,000 USDG. Rewards are non-transferable and cannot be exchanged for cash or any other asset by the winner. Kraken may substitute a Reward with one of equal or greater value if a Reward cannot be provided for any reason, including if USDG is not available to a winner in their jurisdiction.

7. Kraken Account and KYC Requirement

To receive a Reward of USD 10,000 or more, a participant must, before the end of the Promotion Period, have: (a) a Kraken account in good standing; and (b) completed at least Intermediate KYC verification, plus any additional verification required by Kraken or applicable law in the participant’s jurisdiction. A participant who does not satisfy these requirements before the end of the Promotion Period will forfeit their Reward. Final rankings and Reward amounts are not known until after the Promotion Period ends, so participants who may rank for a Reward of USD 10,000 or more should complete these requirements before it ends.

8. Eligibility

To be eligible, you must: (a) reside in an Eligible Area under Section 2; (b) be at least 18 years old or the age of majority in your jurisdiction, whichever is higher; (c) agree to these Terms and the Kraken Terms; and (d) not be prohibited from participating under applicable law. Each person may participate with one Kraken account only.

Excluded Accounts. The following are not eligible to participate, and any volume they generate does not count toward Community Volume (each, an “Excluded Account”):

• Market makers and liquidity providers: any account that trades under a market making, liquidity provision, or similar agreement or program with Kraken or any of its affiliates, and any account owned or controlled by, or affiliated with, such a person or entity.
• Managed accounts: any account traded, in whole or in part, by or on behalf of a person other than the account holder, including accounts managed by an investment manager, fund, or trading firm, accounts traded under a power of attorney or trading mandate, and accounts traded through a copy-trading, signal, or account-management service.
• Kraken personnel: employees, contractors, and directors of Kraken and its affiliates, and their immediate family and household members.

Kraken may determine, in its sole discretion, whether an account is an Excluded Account, including after the end of the Promotion Period.

9. Prohibited Trading Activity and Disqualification

9.1 Prohibited Trading Activity. The Promotion rewards genuine trading activity. The following are prohibited (each, “Prohibited Trading Activity”):

• Wash trading: buying and selling the same or a substantially similar Eligible Instrument, at or around the same time, where there is no genuine change in market risk or beneficial ownership.
• Self-matching: placing orders that match, or are intended to match, against your own orders, including orders from your sub-accounts or from any other account you own or control.
• Cross-account and collusive trading: trading with or against another participant or third party by agreement or coordination, including pre-arranged trades, or trading between accounts under common ownership or control.
• Offsetting or hedged positions: opening offsetting positions across accounts or across related instruments (for example, opposing positions in the Gold Instrument and PF_GLDXUSD, or in an xStocks perpetual and its equivalent equity perpetual) to generate Trading Volume or Weighted Trading Volume with little or no net market exposure.
• Churning for volume: repeatedly opening and closing positions, or placing and filling orders, mainly to increase Trading Volume rather than for a genuine trading purpose.
• Spoofing and layering: placing orders you do not intend to execute, or placing and canceling orders to create a misleading impression of market activity or prices.
• Market manipulation and abuse: any other conduct that is manipulative or abusive under the Kraken Terms or applicable law, or that exploits fee, rebate, funding, or weighting mechanics to gain an unfair advantage in the Promotion.

9.2 Other grounds for disqualification. Kraken may also disqualify any participant who has: (a) used multiple accounts, or false or misleading information; (b) used bots, scripts, or other automated means to manipulate the Promotion (ordinary API trading is permitted unless it is used for Prohibited Trading Activity); (c) used a VPN or other means to circumvent geographic restrictions; or (d) otherwise breached these Terms or the Kraken Terms, or acted fraudulently or in bad faith.

9.3 Consequences. Kraken may monitor and review all trading activity connected with the Promotion. If Kraken believes, in its sole discretion, that a participant has engaged in Prohibited Trading Activity or falls within Section 9.2, Kraken may, without prior notice: (a) exclude the relevant volume from the participant’s Trading Volume and from Community Volume; (b) adjust the participant’s ranking; (c) disqualify the participant from the Promotion; (d) withhold, cancel, or reclaim any Reward, including after it has been credited; and (e) take any other action permitted under the Kraken Terms. Kraken’s determinations under this Section 9 are final.

10. Winner Notification and Reward Fulfillment

Winners will be notified by email to their Kraken account email address and/or in the Kraken app within 14 days after final rankings are confirmed. Rewards will be credited within a reasonable time after all verification is complete. If a winner cannot be contacted or does not respond within a reasonable time after notification, or does not satisfy the requirements in Section 7, the Reward will be forfeited. Any Reward, including any share of the Tail Pool, that is forfeited under this Section 10 or Section 7 will not be reallocated to other participants.

11. Consents and Approvals; Data and Privacy

By participating, you consent to Kraken displaying a pseudonymous identifier, your rank, and your Weighted Trading Volume on the Promotion leaderboard, and to Kraken processing your personal data to administer the Promotion, including disclosure to third parties engaged to administer it. Kraken will not display your name or account details on the leaderboard without your consent. Personal data is processed in accordance with the Kraken Privacy Notice at https://www.kraken.com/legal/privacy.

12. Disclaimers

Kraken is not responsible for any failure to participate or to record trades due to technical failures, platform outages or maintenance, network or connectivity issues, market disruptions, trading halts, instrument delistings, or events beyond Kraken’s reasonable control (including force majeure). Kraken is not responsible for, and will not compensate, any trading losses, fees, funding payments, or liquidations incurred in connection with the Promotion.

Certain Eligible Instruments are perpetual futures contracts referencing the price of a commodity, currency, equity, index or other asset. They are derivative contracts and confer no ownership interest in, or entitlement to, the reference asset. Company names, tickers and marks are used only to identify the reference asset; no issuer or rights-holder has sponsored, endorsed or is affiliated with this Promotion. SOXL and SOXS reference leveraged ETFs and carry embedded leverage in addition to any futures leverage.

13. Limitation of Liability, Disputes, and Governing Law

By participating in this Promotion, you agree to and hereby release and hold harmless Tulip HoldCo Ltd. and its affiliates, officers, directors, employees, and agents (collectively, “Kraken”) from any damage, injury, death, loss, claim, action, demand, or other liability (“Claims”) arising from or related to your participation in this Promotion or your receipt or use of any Reward, regardless of whether such Claims, or knowledge of the facts constituting such Claims, exist at the time of entry or arise at any time thereafter.

TO THE EXTENT PERMITTED BY APPLICABLE LAW: (1) ANY AND ALL DISPUTES, CLAIMS AND CAUSES OF ACTION THAT CANNOT BE RESOLVED BETWEEN YOU AND KRAKEN ARISING OUT OF OR CONNECTED WITH THE PROMOTION WILL BE RESOLVED INDIVIDUALLY, WITHOUT RESORT TO ANY FORM OF CLASS ACTION; (2) ANY AND ALL CLAIMS, JUDGMENTS, AND AWARDS WILL BE LIMITED TO ACTUAL THIRD-PARTY, OUT-OF-POCKET COSTS INCURRED, IF ANY, NOT TO EXCEED TWENTY-FIVE US DOLLARS (USD $25.00). ATTORNEYS’ FEES ARE NOT RECOVERABLE; (3) YOU WAIVE ALL RIGHTS TO SEEK PUNITIVE, INCIDENTAL, CONSEQUENTIAL, OR SPECIAL DAMAGES, OR LOST PROFITS; AND (4) YOUR REMEDIES ARE LIMITED TO A CLAIM FOR MONEY DAMAGES ONLY AND YOU IRREVOCABLY WAIVE ANY RIGHT TO SEEK INJUNCTIVE OR EQUITABLE RELIEF.

Dispute resolution and governing law are governed by the Kraken Terms of Service applicable to you, available at https://www.kraken.com/legal/global-terms, including all dispute resolution and governing law provisions contained therein.

14. Taxes

Winners are solely responsible for any taxes, duties, or reporting obligations arising from receipt of a Reward. Kraken does not provide tax advice. Kraken may withhold or report amounts where required by law.

15. General Terms

Kraken may modify, suspend, or terminate the Promotion, or amend these Terms, at any time, including if the Promotion cannot run as planned or is affected by fraud or technical issues. Any material changes will be posted on the Promotion page. Kraken’s decisions on all matters relating to the Promotion, including the calculation of Trading Volume, Weighted Trading Volume, Community Volume, rankings, and Rewards, are final and binding. If any provision of these Terms is held invalid or unenforceable, the remaining provisions will continue in full force. If these Terms are translated into any other language, the English version will prevail in the event of any inconsistency.

Annex A — Eligible Instruments

Gold Instrument (3x): PF_XAUUSD (Gold 24/7 Pyth Index).

RWA Instruments (2x): Commodities: PF_BRENTOILUSD, PF_NATGASUSD, PF_WTIOILUSD, PF_XAGUSD, PF_XCUUSD. Forex: PF_CHFUSD, PF_EURUSD, PF_GBPUSD. Equities: PF_NBISUSD, PF_SAMSUNGUSD, PF_SKHYUSD, PF_SNDKUSD, PF_SOXLUSD, PF_SOXSUSD, PF_MUUSD, PF_INTCUSD. xStocks: PF_AAPLXUSD, PF_AMZNXUSD, PF_COINXUSD, PF_CRCLXUSD, PF_GLDXUSD, PF_GOOGLXUSD, PF_HOODXUSD, PF_METAXUSD, PF_MSTRXUSD, PF_NVDAXUSD, PF_QQQXUSD, PF_SPCXXUSD, PF_SPYXUSD, PF_TSLAXUSD. Indices: PF_US100USD.

Crypto Instruments (1x): all other perpetual and fixed-maturity futures contracts listed on Kraken Futures and available to the participant during the Promotion Period.

Kraken may add or remove Eligible Instruments during the Promotion Period, including where an instrument is listed, delisted, or expires. Any change will be posted on the Promotion page and applies only to trades executed after it is posted.