Declaration of Compliance with Latvian and EU Law Digi Creative SIA — LOTOSS Bond Offering Ref: 10.1 | Version 2 | 26 March 2026 Company Digi Creative SIA Registration No. LV41203061418 Address Krasta iela 8C, Iecava, Bauskas nov., LV-3913, Latvia Authorised signatory Gints Ādams, Board Member / Authorised Representative Declaration date 26 March 2026 Digi Creative SIA (the "Issuer") hereby declares that the issuance of LOTOSS Bonds (up to 403 unsecured, subordinated, profit-sharing tokenized bonds at EUR 200 each; total offering EUR 80,600), their tokenization via the Maritime DAO LLC technical platform (app.maritimedao.com) on Ethereum mainnet, and secondary market trading fully comply with the following Latvian and EU legislation as of 26 March 2026. 1. Prospectus exemption Applicable regulation Regulation (EU) 2017/1129 (Prospectus Regulation), Article 1(3). Exemption basis Total offering: EUR 80,600. This falls below: (a) EUR 1,000,000 — the Art. 1(3) threshold (no summary document required); and(b) threshold (no approved prospectus required). Both exemptions are satisfied independently. Note 1(3) threshold to The current offering relies on the existing Latvia national threshold Latvia has not introduced a national threshold lower than EUR 1,000,000 under Art. 1(3) as of 26 March 2026. The Latvian Financial Instruments Market Law (Section 16) is consistent with this EU-level exemption. Latvian law Financial Instruments Market Law (Finanšu instrumentu tirgus likums), Section 16. Conclusion No approved prospectus is required or has been prepared. The Information Memorandum (04.2/04.2.1) is issued voluntarily. 2. Instrument classification — MiFID II transferable security Classification LOTOSS Bonds constitute transferable securities within the meaning of MiFID II Article 4(1)(44) — they are debt instruments that are negotiable on the capital market. MiFID II services The Issuer conducts self-placement of its own securities only. It does NOT provide: reception and transmission of orders (Annex I, A(1)); execution of orders on behalf of clients (A(2)); investment advice (A(5)); portfolio management (A(4)); or operation of a regulated market, MTF, or OTF. Latvian law Financial Instruments Market Law, Sections 3 and 69 — permits private/OTC transactions for small-scale issuances. 3. MiCA — tokenization and DLT Classification LOTOSS Bonds are tokenized traditional financial instruments (debt securities governed by Latvian law). They are NOT classified as e-money tokens, asset-referenced tokens, or utility tokens under Regulation (EU) 2023/1114 (MiCA).
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MiCA exclusion As the bonds qualify as financial instruments under MiFID II, they fall outside the scope of MiCA pursuant to Article 2(4) of Regulation (EU) 2023/1114. Token nature The Ethereum token is the technical representation of the bond on a distributed ledger. Legal ownership and bond rights are determined exclusively by Latvian contract law and the bond register maintained by Maritime DAO LLC on behalf of the Issuer. DLT Pilot Regime The offering does not operate under Regulation (EU) 2022/858 (DLT Pilot Regime), which applies to DLT market infrastructure operators — not to issuers of tokenized bonds. 4. Secondary market trading Platform status The Maritime DAO platform (app.maritimedao.com) is NOT a regulated trading venue — it is not an MTF, OTF, or DLT Pilot Regime operator. It provides technical registry and transfer facilitation services only. MiFID II compliance The transfer model does not constitute the operation of a multilateral trading facility because: (a) the Issuer does not organise multilateral nondiscretionary trading; (b) transfers require KYC verification of the buyer; (c) all transfers are individually processed, not matched algorithmically. This is consistent with Financial Instruments Market Law, Section 69. Disclosure The non-regulated status of the platform is disclosed to investors in: Information Memorandum (04.2, Section 8); Risk Disclosure (09.5); Terms and Conditions (04.1, Section 5); and PRIIPs KID (04.3, Section 2). 5. PRIIPs Regulation compliance Applicable regulation Regulation (EU) 1286/2014 (PRIIPs) — applicable to packaged retail investment products sold to retail investors. KID prepared A PRIIPs-compliant Key Information Document (KID) has been prepared in English (document 04.3) and Latvian (document 04.3.1) containing: Summary Risk Indicator (SRI 6/7); four performance scenarios; cost table; recommended holding period (24 months); and complaints information. Pre-purchase delivery The KID is provided to all investors before subscription via the Maritime DAO platform. Investors must confirm receipt before purchase can be completed. Outstanding item The Maritime DAO platform fee for the cost table is pending confirmation from Maritime DAO LLC and must be inserted before go-live. 6. MiFID II retail investor protection (Art. 24–25) Appropriateness assessment A mandatory appropriateness questionnaire (document 05.6) is completed by all investors before subscription, assessing knowledge and experience with fixed-income instruments, DLT/blockchain risks, and capital loss capacity. Risk disclosures Investors receive: Risk Disclosure (09.5); LOTOSS Risk Disclosure section in KID (04.3); Risk Acknowledgement Form requiring explicit acknowledgement of all material risks (04.4/04.4.1). Complaints handling Complaints Handling Policy (02.6) complies with MiFID II Article 16 — 35 business days response timeline, FKTK escalation path, ODR reference.
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7. AML/CTF and GDPR compliance AML/CTF Full KYC/AML verification performed by Maritime DAO LLC on all investors before subscription and on an ongoing basis. Compliant with: Directive (EU) 2018/843 (AMLD5); Directive (EU) 2018/1673 (6AMLD) as transposed by Latvian AML Law; FATF Recommendations including VA guidance. GDPR Personal data processing complies with Regulation (EU) 2016/679. EU Representative (GDPR Art. 27): Digi Creative SIA. Privacy Policy (02.2) and GDPR Framework (07.1) published. 8. Conclusion Digi Creative SIA confirms that the LOTOSS Bond offering is structured in full compliance with applicable Latvian and EU law as of 26 March 2026. All investor-facing documents contain complete and accurate risk disclosures. The offering is private, small-scale (EUR 80,600), does not involve the organisation of a regulated market, and does not require a MiFID II investment firm licence under the current structure. This Declaration is made in good faith and is true as of 26 March 2026. Authorised signatory Gints Ādams — Board Member / Authorised Representative Signature ___________________________ Date 26 March 2026 Document details Reference: 10.1 Declaration of Compliance with Latvian and EU Law v2 — 26 March 2026 | Last updated: 26 March 2026
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