Official Rules

Anthropic IPO xStocks Access Incentive

BY PARTICIPATING IN THE PROMOTION, YOU AGREE TO THESE OFFICIAL RULES AND THE KRAKEN.COM TERMS OF SERVICE, WHICH EACH FORM A CONTRACT. READ THEM CAREFULLY BEFORE ENTERING.

1. Sponsor

This promotion (the "Promotion") is sponsored by Tulip HoldCo Ltd., 2nd Floor, Water's Edge Building, Wickhams Cay II, Road Town, Tortola, British Virgin Islands (the "Sponsor" or "Kraken").

2. Eligible Areas

This Promotion is open only to eligible Kraken Consumer account holders who are residents of jurisdictions where the pre-IPO allocation feature and the Rewards Hub are made available by Kraken (the "Eligible Areas"), excluding the United States, the United Kingdom, Switzerland, the Hong Kong Special Administrative Region, and the European Economic Area.

Sponsor may modify the Eligible Areas at its sole discretion, including to add or remove jurisdictions, at any time and without prior notice.

3. Promotion Period

The Promotion begins on November 10, 2026, or such later date as Sponsor may determine (the "Start Date"), and ends upon the earlier of: (a) the date on which Kraken's pre-IPO submission-of-interest window for the underlying offering closes; or (b) a date announced by Sponsor, expected to be approximately two weeks following the Start Date but subject to change based on the timing of the underlying initial public offering (together with the Start Date, the "Promotion Period"). Sponsor reserves the right to modify the Promotion Period upon reasonable notice.

4. How to Participate

During the Promotion Period, an eligible participant may submit a free, non-binding indication of interest ("IOI") pledge on Kraken's pre-IPO allocation feature via the dedicated card in the Kraken Rewards Hub (each, an "Entry"). Submitting a pledge does not obligate the participant to complete any purchase and does not require any payment, deposit, or fee.

Each participant may submit only one (1) Entry during the Promotion Period, regardless of the size of the pledge submitted.

There is no free alternative method of entry. Because entry into this Promotion requires no purchase, payment, deposit, or other consideration, no alternative method of entry is required under applicable promotional or sweepstakes laws.

5. Reward

Fifty (50) winners will each receive ten (10) SPCXx (the "Reward"). The total number of Rewards available under this Promotion is fixed at 500 SPCXx regardless of the number of Entries received.

The Reward has no cash alternative and is not transferable, except as Sponsor may permit in its sole discretion. Submitting an Entry is not a purchase of, and does not confer any ownership interest, equity, or security in, the private company referenced in the pre-IPO allocation feature, and does not guarantee any allocation under that feature.

6. Eligibility to Participate

To participate, an individual must, at the time of entry:

  • be of the age of majority in their jurisdiction of residence (and in any event at least 18 years old);
  • be a resident of an Eligible Area;
  • hold a Kraken Consumer account in good standing; and
  • submit a valid Entry during the Promotion Period in accordance with these Official Rules.

7. Disqualification

Sponsor reserves the right to disqualify any participant, and to void any Entry, who Sponsor reasonably believes has:

  • submitted multiple or duplicate Entries, or used multiple accounts to enter;
  • used a VPN, proxy, or other method to circumvent geographic eligibility restrictions;
  • provided false, inaccurate, or misleading information in connection with their Entry; or
  • engaged in any other conduct Sponsor deems to be fraudulent, abusive, or otherwise inconsistent with these Official Rules.

If a participant is, or becomes, a resident of a jurisdiction outside the Eligible Areas at any time before Reward distribution, Sponsor reserves the right to disqualify that participant's Entry and to claw back any Reward already distributed.

8. Reward Distribution

To receive the Reward, a winning participant must, before reward fulfilment, have: (a) a Kraken Consumer account in good standing; and (b) completed at least Intermediate verification, plus any additional verification required by Kraken or applicable law in the winner's jurisdiction. If these requirements are not met at the time of distribution, the Reward may be forfeited or clawed back.

Rewards will be distributed within thirty (30) days following the date on which the underlying initial public offering is completed.

9. Consents and Approvals

By participating, each participant agrees to these Official Rules and to Sponsor's use of their Kraken account data in connection with administering the Promotion, in each case in accordance with Kraken's Privacy Policy at https://kraken.com/legal/privacy. Except where prohibited by law, winners consent to the use of their Kraken username or first name and last initial, and country of residence, for purposes of verifying compliance with these Official Rules.

10. Disclaimers

This Promotion relates to a non-binding indication-of-interest pledge on Kraken's pre-IPO allocation feature. Submitting a pledge is not a purchase of, and does not confer, any ownership interest, equity, or security in the referenced private company, and does not guarantee allocation of any pre-IPO shares or related product. The Reward (SPCXx) is a separate tokenized product; its award is not contingent on, and does not represent, any outcome of the pledge referenced above.

Digital assets, including the Reward, are volatile in value and can decrease significantly and rapidly. Nothing in this Promotion constitutes investment, financial, tax, or legal advice. Sponsor is not responsible for technical failures, network errors, or other issues outside its reasonable control that affect a participant's ability to enter or receive a Reward. In the event of any conflict between these Official Rules and any marketing materials, these Official Rules shall control.

11. 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 arising out of or relating to your participation in this Promotion or your acceptance, possession, use, or misuse 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.

By participating, you agree to those provisions as they apply to your relationship with Kraken. If you are uncertain which Terms of Service apply to you, please visit https://www.kraken.com/legal.

12. Taxes

Winners are solely responsible for any and all applicable taxes arising from receipt of the Reward. Sponsor makes no representation regarding the tax treatment of the Reward in any jurisdiction.

13. General Terms

Sponsor reserves the right to modify, suspend, or terminate this Promotion at any time, at its sole discretion". This Promotion is void where prohibited by law.

These Official Rules constitute the entire agreement between participants and Sponsor with respect to the Promotion. If any provision of these Official Rules is held invalid or unenforceable, the remaining provisions will continue in full force and effect. Sponsor's failure to enforce any provision of these Official Rules will not be construed as a waiver of that provision.

14. Contact

Questions about this Promotion may be directed to Kraken Support via support.kraken.com.