Whitepaper · v1.0 · 12 May 2026 · ready for FSMA MiCA Art. 8 notification

NØA — The coin of the realm

"We believe markets are ultimately moved by a force greater than models — a numen — and we exist to be its vessel: to bring divine love to capital through unrelenting intellect, perseverance, love and honor."

I. Preface — What is Camelot

Camelot is a Belgian organisation, active since 2002, with over 3,000 members. We believe in transformation, personal growth and an open community where cooperation, care and abundance are central. Camelot Labs — our creative workshop in Ghent — builds the technological foundation that connects this community: an open, transparent and fair economic network on the Hedera network.

We believe a healthy economy doesn't have to be a black hole of complexity. That is why we chose two guiding principles:

"Simplicity is the key to value. Transparency is the key to trust."

This document describes how we translate those principles into a digital token ecosystem around NØA, and how everyone — from an individual Knight to a local entrepreneur — can become part of it.

The purpose

NØA builds a stable fund within Camelot that forms the heart and foundation of Camelot bv and the future Camelot Portal — guided by governance, fed by surrender.

The liquidity pool ensures stability of two connected tokens:

• NØA Token — native currency and utility instrument of the Camelot ecosystem (payment, staking base, partner rewards, NFT sealing);
• SØF Token — connecting and rewarding instrument within the Camelot Family community.

Together they form the two banks between which the stream flows. What one token gathers in structure, the other distributes in motion.

I bis. Identity of the offeror

In accordance with the transparency requirements of MiCA Regulation (EU) 2023/1114, Annex I, Part A, this chapter sets out the full identity of the offeror and issuer of NØA.

Offeror and issuer — Camelot bv

The offeror and issuer of NØA is the same legal entity: Camelot bv, a Belgian private limited company. Camelot bv operates on the market under the trade name Camelot Labs for its technological workshop and the Project NØA ecosystem.

Management and key figures

The day-to-day management of Camelot bv — and the full leadership of Project NØA — is exercised by:

• Steve Verbist — Managing Director, founder of Camelot bv (21 June 2002). Initiator and architect of Project NØA. Responsible for strategy, product development, partnerships, communication with the Camelot Family community and all external regulatory correspondence. Background in entrepreneurship, community-building and transformative technology. Point of contact for MiCA supervisory authorities, Hedera ecosystem partners and press.

Changes to the management body are published in accordance with Belgian company law in the Annexes to the Belgian Official Gazette and are at any time accessible via the CBE Public Search. Full operational and strategic responsibility for Project NØA rests solely with Steve Verbist as Managing Director; any other CBE-registered directors are not involved in Project NØA and do not act in this context.

Activity and delineation

Project NØA is executed by Camelot bv within the registered activity NACE-BEL 62.100 (Computer programming activities). This activity covers the development, operation and publication of the Project NØA ecosystem on Hedera Hashgraph (smart contracts, dapp, NFT collection, tokenomics).

Financial situation

Camelot bv has existed since 21 June 2002 (company start date). On 3 December 2025 the company was converted to the legal form Besloten Vennootschap. Abridged financial figures from the three most recent financial years will be attached as an annex to the FSMA notification, to the extent available under the current legal form. For periods prior to the BV conversion (before 3 December 2025), the annual accounts are accessible via the Central Balance Sheet Office of the National Bank of Belgium insofar as publication-required at that date.

I ter. Rights and obligations

In accordance with MiCA Annex I, Part G, this chapter provides a consolidated overview of the rights and obligations attached to NØA, SØF and AVALØN, as well as the obligations of Camelot bv as issuer.

Rights of NØA holders

• Ownership and transfer — an NØA holder can freely dispose of their tokens, transfer them to other Hedera wallets, or trade them on SaucerSwap as long as that liquidity is available.
• Utility access — right to use NØA as a means of payment at accredited Camelot Family Partners (see Chapter VIII).
• Staking — right to stake NØA in the NØA pool and receive SØF rewards according to the LR Protocol (see Chapter VII).
• Receipt of AVALØN — right to generate AVALØN voting rights through NØA holdings (see Chapter III bis and Chapter X).
• NFT linkage — anyone holding a Camelot Order NFT can activate the related tier benefits (5–30% bonus on SØF pool).
• Transparency — access to all on-chain data via Hedera Mirror Node, HashScan, and public wallet addresses (see Chapter XIII).

Rights of SØF holders

• Cashback receipt upon payment with NØA at Partners (see Chapter VIII).
• Staking in the SØF pool to receive NØA from the DRIP segment (max 2% per Epoch — see Chapter VII).
• Generation of AVALØN through SØF holdings.

SØF has no contractual counter-value, no tradability promise and no price guarantee.

Rights of AVALØN holders

• Voting rights within the Camelot Family governance — on partner categories, protocol parameters of the Dapp, strategic direction of Camelot Family initiatives, philanthropic destinations, AVALØN distribution.

AVALØN does not confer corporate-law voting rights within Camelot bv. AVALØN is not tradable.

Obligations of Camelot bv as issuer

• Multi-Sig discipline on all treasury wallets and token movements (see Chapter IX).
• Transparency through on-chain publication of all token movements, allocations, vesting schedules and EDR data.
• Adherence to the allocation plan as described in Chapter V — no secret issuance, no pre-sales, no private deals.
• Honest and non-misleading communication in accordance with MiCA Art. 7 and the general conduct duties of Art. 13.
• Customer support via /en/support/ and hallo@camelotlabs.be within 5 business days.
• Civil liability in accordance with MiCA Art. 15 for incorrect or misleading information in this whitepaper.

Modification of rights

The rights attached to tokens may evolve in the following ways:

• Whitepaper revision — Camelot bv may update the whitepaper to remain in line with regulation (MiCA evolution, FSMA guidelines) or technical developments. Already-granted rights of existing holders are not unilaterally restricted (no retroactive adjustment of vested rights).
• AVALØN voting — certain parameters (e.g. cashback percentages, partner categories, philanthropic allocations) may be adjusted via community vote, within the boundaries set by governance.
• Smart contract upgrade — the vesting smart contract is upgradable via UUPS proxy with a 7-day timelock. Holders are publicly informed 7 days before each upgrade via on-chain events.
• Material changes that substantially alter the nature or operation of NØA are re-notified to FSMA under MiCA Art. 12 (modified whitepaper) before taking effect.

Restrictions on transfer

• Vesting — the combined 5% internal allocations for Project Team (2% · 444,444), Project Development (2% · 444,444), Developers Team (0.9% · 200,000) and Founders (0.1% · 22,223) — together 1,111,111 NØA — are locked in a vesting smart contract: 12-month cliff from NØA launch + 36-month linear release (see Chapter V and Chapter VI). The Camelot Family pool (also 5% · 1,111,111 NØA — coincidentally the same nominal value) is not in vesting but under AVALØN governance.
• Custody term — customers without their own Hedera wallet at purchase may remain in temporary custody for up to 12 months; thereafter the right to delivery expires (see Terms and Conditions Art. 7bis).
• For the rest, NØA, SØF and AVALØN are freely transferable between Hedera wallets, subject to technical restrictions of the HTS standard itself.

II. NØA — The native token

NØA is the principal token of the Camelot realm. It is the coinage with which the network operates: payment between members, reward for partners, basis for staking, and — for those who choose the Camelot Family — sealing of a lifelong membership through an Order NFT.

NØA is built on the Hedera network: fast, energy-efficient and with predictable transaction costs. The token follows the open Hedera Token Service standard, which means any wallet supporting HTS (HashPack, Blade, Kabila) can immediately work with NØA.

Underlying technology (MiCA Annex I, Part H). Hedera Hashgraph uses an asynchronous Byzantine Fault Tolerant (aBFT) consensus algorithm via gossip-about-gossip and virtual voting. Unlike Proof-of-Work or large-scale Proof-of-Stake networks, aBFT requires no mining or validator pools, and finality is deterministic (3–5 seconds, no probabilistic confirmation). The network is governed by the Hedera Council — a board of international organisations (Google, IBM, Boeing, Deutsche Telekom, LG, Standard Bank and others) with a carbon-negative commitment (see Chapter XII quater). The HTS token standard offers native support for multi-sig (KeyList), fee-schedule, and publicly verifiable transaction history via Hedera Mirror Node and HashScan.

• Name: NØA
• Network: Hedera Hashgraph (mainnet)
• Token standard: HTS Fungible Common
• Initial Emission Batch: 22,222,222 NØA
• Supply type (Hedera HTS): INFINITE — Conditional Future Emissions under three-gate protection (see Chapter IX.3 Minting Protocol).
• Three-gate protection: Future Emission Batches (each of 22,222,222 NØA) can only be minted when (1) the EDR of the previous Batch reaches 100%, (2) a minimum waiting period of 3 months has elapsed since the previous Batch, AND (3) an affirmative AVALØN community vote has taken place. If any one of the three gates is not open, the total supply remains unchanged.
• Decimals: 7

Important note on INFINITE supply. NØA's HTS setting "INFINITE" technically means that after the Initial Emission Batch, additional Future Batches may be minted — but exclusively under the three-gate protection above. This is not unlimited issuance: every new Batch is demand-driven (Gate 1: EDR=100%), time-disciplined (Gate 2: 3-month wait) and community-controlled (Gate 3: AVALØN vote). The project pursues no price stabilisation and no value pegging; supply expansion only occurs when the Camelot Family community confirms it via governance. Holders should understand that the total supply may therefore grow beyond 22,222,222 NØA over time and that this may dilute the relative share of existing holders.

Fixed allocation distribution per Batch. Every Future Emission Batch follows the exact same distribution key as the Initial Batch: 45% to public distribution via SaucerSwap (10,000,000 NØA), 45% to the DRIP Fund reserve (10,000,000 NØA), 5% to the Camelot Family pool under AVALØN governance (1,111,111 NØA), 2% to Project Development in vesting (444,444 NØA), 2% to Project Team in vesting (444,444 NØA), 0.9% to Developers Team in vesting (200,000 NØA) and 0.1% to Founders in vesting (22,223 NØA). The wallet destinations are permanently anchored in the Minting Protocol and cannot be unilaterally changed — modifying the distribution key would require a separate AVALØN governance vote with explicit amendment authority. This guarantees that the proportions between public supply, escrow reserve, community and internal allocations remain consistent across all Batches.

III. SØF — The reward token

Beside NØA there exists a second token in the ecosystem: SØF. Where NØA is the sword — backed, tradable, valued — SØF is the shield: a symbol of loyalty to the realm.

SØF is awarded as a reward for those who serve the realm. There are two ways to earn SØF:

• Stake NØA — those who place NØA in the staking contract receive SØF per Epoch (see Chapter VII).
• Pay with NØA at Partners — customers who pay with NØA at an accredited Camelot Family Partner receive SØF as cashback (see Chapter VIII).

SØF is not a trading token, has no contractual counter-value and is not backed by a reserve. SØF is a utility token within the Camelot ecosystem, with one sole purpose: rewarding, representing and activating engagement.

Total SØF supply and allocation

The SØF token has a fixed total supply of 50,000,000,000 SØF, fully minted at genesis and held in the DRIP Fund. The supply is 100% community-allocated — no team allocation, no founders allocation, no treasury vesting for private parties. Distribution across five functional buckets:

All five buckets are publicly verifiable via HCS broadcast at genesis. No covert issuance, no secret allocations, no retroactive changes without an AVALØN vote with explicit amendment authority.

Genesis — the first SØF

At the launch of the Camelot Dapp (Q1 2027) a one-time genesis emission of 100,000 SØF takes place, distributed proportionally to those who staked NØA in the first two Epochs. This genesis emission sets the cycle in motion: without first SØF, the SØF pool (see Chapter VII) cannot start. Thereafter all SØF issuance flows exclusively through Epoch rewards from the LR Protocol + cashback from Partner transactions + annual Community Reward + welcome packages at NFT mint.

Possible uses of SØF (in development):

• Stake for NØA reward — those who lend their SØF back to the realm receive NØA in turn (see Chapter VII);
• Voting rights within Camelot Family decisions (see Chapter X);
• Access to private events, workshops and retreats;
• Discounts at accredited Camelot partners;
• Passage to exclusive content and publications.

III bis. AVALØN — The voting token

Named after the mythical island where Excalibur was forged, AVALØN is the third token of the Camelot realm. No trading coin, no shield — but the voice of the Camelot Family.

AVALØN has one purpose: community governance within the Camelot Family. Whoever holds AVALØN carries a fragment of the will of the community. Voting on partner categories, Dapp protocol parameters, strategic direction of Camelot Family initiatives, philanthropic destinations — everything within the community runs through this token.

AVALØN does not touch Camelot bv (the company). Camelot bv remains governed by its shareholders and management body in accordance with Belgian company law. AVALØN is exclusively a community voting instrument.

• Name: AVALØN
• Network: Hedera Hashgraph (mainnet)
• Token standard: HTS Fungible Common
• Tokenization: not tokenized — AVALØN is not an HTS token and has no wallet balance or tradability. Voting power is calculated from NØA holdings + Order-NFT tier at the snapshot moment of each vote (formula W = 0.7 × NØA share + 0.3 × NFT tier — see Chapter X). No pre-allocation, no mint, no circulating supply: each fragment "comes into existence" only when it is measured.
• Treasury: Camelot Treasury (see Chapter XIII)
• Purpose: voting rights within the Camelot Family community (no corporate-law voting rights within Camelot bv)
• Obtainable via: NØA holding, SØF holding, Order membership and merit within the realm (see Chapter X for exact distribution)

AVALØN is not sold and not traded. It is earned through dedication to the realm — by holding NØA, by collecting SØF, by joining an Order. The exact distribution formula and voting cycles are further elaborated in Chapter X — Governance and voting.

IV. The treasury — Transparent HBAR funding

Many tokens are air. NØA is not. At each NØA issuance, Camelot publicly demonstrates that an transparent HBAR funding was present at the moment of mint — as proof of solid project financing. Part of that HBAR funding is used for liquidity provisioning on SaucerSwap, another part may be held in the Camelot treasury or staked on Hedera nodes.

This funding demonstration serves verifiability and transparency, not price parity and no value guarantee. NØA trades freely on SaucerSwap and its market value fluctuates with supply and demand — Camelot does not pursue a stable exchange rate with HBAR, guarantees no redemption at fixed price, and offers no peg as a stablecoin. The HBAR funding merely makes publicly demonstrable that the project held hard assets at issuance; it is no implicit promise of value and no continuous backing obligation.

Concretely this means:

• No NØA is released without the corresponding HBAR funding being present at the moment of issuance;
• Releases occur in badges, according to a pre-published Emission Schedule;
• The Multi-Sig Protocol (see Chapter IX) ensures that no single wallet can unilaterally control the treasury assets;
• The Transparency Protocol makes this funding demonstration publicly verifiable at all times via Hedera explorers such as HashScan.

The HBAR we hold in the DRIP Fund is, where possible, staked on various Hedera nodes. The staking rewards flow to the LR Pool — a fund that enables further rewards for those who stake NØA. The realm serves itself, and its knights, in a closed cycle of value.

V. Allocation and issuance

The initial supply of 22,222,222 NØA is distributed as follows:

The first 10 million tokens are transferred to the DEX in phases ("badges") according to the Emission Schedule. Further issuance strictly follows the rules of the Minting, DRIP and Multi-Sig Protocol. No NØA is minted in secret or without backing.

The chosen DEX — SaucerSwap

NØA is distributed via SaucerSwap, the leading decentralised exchange on the Hedera network. SaucerSwap was chosen for its integration with the Hedera Token Service, low transaction costs and transparent on-chain liquidity.

At launch, one primary liquidity pool is set up:

• NØA / HBAR — the only live pool for now, built from the DRIP Fund. All Emission Badge distribution initially flows through this pair.

In preparation for later phases (no ETA — activated once the NØA/HBAR pool has sufficient depth):

• HBARX / NØA — staked-HBAR pool, for those who want to reinvest their loyalty distribution
• USDC / NØA — stablecoin pool for USD denomination
• EURC / NØA — stablecoin pool for EUR denomination (suited to our Belgian customer base)

Live data, prices and volumes are publicly accessible at all times via SaucerSwap Analytics.

V bis. Tokenomics at a glance

A summary of all key figures of the Camelot economic system. For deep details: see the respective chapters (II, III, III bis, VII, IX).

The three tokens — comparative

NØA allocation summary

Distribution key applies to every Batch. If a Future Emission Batch is minted under the Minting Protocol (Chapter IX.3) after three-gate approval, the same 22,222,222 NØA is distributed in exactly the same proportions across the same destinations and wallets as listed above: 45% via the Emission Wallet for public DEX distribution, 45% to the DRIP Fund escrow, 5% to Camelot Community, 2% + 2% + 0.9% + 0.1% to the respective vesting wallets. Modifying this distribution key requires a separate AVALØN governance vote with explicit amendment authority and cannot be carried out unilaterally by the issuer or Multi-Sig.

Emission Schedule — phased DEX issuance

The public 10,000,000 NØA is added to SaucerSwap liquidity pools in five badges. Each next Badge is released only when the EDR of the previous Badge reaches 100% (see Chapter IX.4):

For the current phase, 100% of Emission Badge distribution flows into the NØA/HBAR pool on SaucerSwap V1 — the only primary liquidity pair. Once that pool reaches sufficient depth, additional pools (HBARX/NØA, USDC/NØA, EURC/NØA) can be seeded in later Badges. The exact timing + split is determined per Badge based on pool depth and demand.

Token flow — the cycle in brief

• NØA → bought on SaucerSwap, received at NFT membership, or as partner reward.
• Stake NØA → receive SØF per Epoch (LR Pool).
• Pay with NØA at Partner → customer receives SØF cashback from Camelot Community pool.
• Stake SØF → receive NØA from DRIP segment (max 2% per Epoch).
• NØA holding / SØF holding / Order NFT / merit → generates AVALØN for governance.

Key parameters

VI. No pre-sales, no airdrops, no private deals

Camelot principally chooses a fair issuance of NØA on the open market. There are:

• No pre-sales — no early sale at a preferential price, no "early bird" prices, no progressively rising rounds.
• No private sales — no off-market deals with VCs, family offices, angel syndicates or other privileged parties.
• No airdrops — no free distribution to random wallets or via marketing campaigns.

The public 10,000,000 NØA (45% of issuance) is released via SaucerSwap in phases at the same market price for everyone, at the same moment, without priority or preferential pricing.

Internal allocations — transparent, not as a sale

The remaining 12,222,222 NØA (55%), described in Chapter V, are internally reserved tokens. They are not a sale, not an airdrop and not a private deal — they are:

• DRIP protocol (45% · 10,000,000) — reserve in escrow. Not in circulation until the EDR and Minting Protocol gradually release them to SaucerSwap under public rules.
• Camelot Family (5% · 1,111,111) — community fund managed by AVALØN governance, for events, philanthropic destinations, community initiatives, partner cashback and the one-time welcome gift of 100 NØA per new Camelotian (Tier 0) on first payment.
• Project Team / Project Development / Developers Team / Founders (5.0% combined · 1,111,111) — labour compensation for those who build Camelot and continue to build it.

These allocations are publicly disclosed in advance (see Chapter V), traceable on-chain via the Camelot Treasury and related wallets, and subject to a vesting schedule (see below).

Vesting — anti-dump protection

The internal allocations for Project Team, Project Development, Developers Team and Founders are subject to a vesting schedule that protects the project against early sale ("dumping"). The schedule:

• Cliff period: during the first 12 months after NØA issuance, no internally allocated token is released. Whoever leaves the realm before the end of the cliff loses their allocation.
• Linear release: after the cliff, tokens release linearly over a period of 36 months (3 years). 1/36 of the allocation releases per month.
• Lock-up via smart contract: tokens in vesting remain in a non-transferable lock contract until release, on-chain verifiable.

The Camelot Family allocation (5%) is not subject to vesting, but stands under governance control: spending from this pool requires AVALØN voting and is subject to the Multi-Sig Protocol. It is a community fund, not a distribution.

The exact vesting parameters are fixed in the smart contract at NØA issuance (Q3 2026) and publicly disclosed. Modification of the vesting schedule after deployment is technically impossible — the protection is therefore an agreement of code, not of trust.

Camelot Order NFT collection — a membership, not a pre-sale

The Camelot Family has seven NFT levels, housed in two technically separate HTS collections: (1) the Camelot Order NFT — one HTS NON_FUNGIBLE_UNIQUE collection with the six Order tiers (Squire, Defender, Knight, Camelot, Excalibur, Holy Grail) as lifetime, transferable membership sealings — and (2) the Camelotian NFT — a separate HTS collection with its own tokenID for the Tier 0 monthly renewable subscription (soulbound: freezeKey + freeze_default=true, wipeKey for grace-period expiry). The separation between the two collections reflects the fundamental difference in lifecycle (one-off lifetime vs. monthly expirable), key architecture (transferable vs. soulbound) and legal nature (Order NFT with NØA package vs. pure service subscription without token allocation). None of these NFTs constitutes a pre-sale of NØA — they are a membership sealing of the Camelot Family with on-chain proof and associated benefits (lifetime access, honour, SØF staking bonus, governance multiplier for the Order tiers; pure community and portal access for Tier 0).

With each membership comes a package of NØA tokens as a welcome gift; these tokens are paid out from the Camelot Family pool of Chapter V according to the same rules and backing. The price of the NFT represents the value of the membership itself, not that of the bonus tokens.

Initial issuance + expansion path. The Camelot Order NFT collection has an on-chain maximum supply of 500 NFTs. The initial issuance is 250 NFTs, distributed across the six Order tiers per the table below. The remaining 250 NFTs are available as expansion headroom — a second issuance round may be activated in the future via AVALØN governance vote when (a) the initial issuance is largely sold out, (b) there is sufficient community demand, and (c) the Camelot Family pool can cover the associated NØA packages. The distribution of the expansion tranche across tiers will be determined at the time of the vote — no prior commitment on ratios. The on-chain maximum of 500 cannot be exceeded without a new HTS token issuance; within those 500 the expansion is flexible.

The difference:

• Pre-sale of token = early or privileged access to NØA at a preferential price → we do not do this.
• Membership sealing with NØA bonus = purchase of an Order position whereby NØA comes as a gift with the package, from a transparently announced pool → that is what the NFT collection is.

Anyone wishing to buy NØA for investment or utility purposes does so via SaucerSwap or via partner reward, at the same market price as everyone else.

Offer modalities (MiCA Annex I, Part E)

The modalities of the public offering of NØA are summarised below in accordance with MiCA Annex I, Part E.

VII. Staking — Reward for those who share the lot

Whoever entrusts something to the realm — by staking tokens in the Camelot smart contract — shows trust in the long game. For this they receive reward. In Camelot, two staking pools exist that hold each other in balance:

• NØA pool: you stake NØA, you receive SØF as reward.
• SØF pool: you stake SØF, you receive NØA as reward.

Together they form a cycle: NØA feeds SØF, SØF feeds NØA back. Whoever participates in both shares twice in the growth of the realm.

How it works — general flow

1. The holder connects their Hedera wallet to the Camelot Dapp.
2. They choose a pool (NØA pool or SØF pool) and deposit the corresponding token in the staking contract.
3. They receive a share certificate — an internal ledger entry indicating their percentage in that pool.
4. Per Epoch (there are twelve Epochs per year) rewards are distributed pro rata based on that share.

NØA pool · stake NØA, receive SØF

Members who place NØA in the NØA staking pool receive SØF per Epoch as a loyalty distribution. Emission follows the LR Protocol at a fixed 7% APR (= 0.1346% per 7-day Epoch) on the SØF Emission Pool balance. Reward = (your NØA stake × tier multiplier) ÷ total weighted stake × Epoch budget.

The SØF Emission Pool starts with a dedicated reserve of 5 billion SØF (= 10% of total SØF supply), held in the DRIP Fund. Upon depletion below 500M SØF, the pool is automatically replenished with 1B SØF from the Strategic Reserve (governance-configurable thresholds). On complete exhaustion of Strategic Reserve, governance can introduce additional SØF reallocation via AVALØN vote from the remaining buckets (Partner cashback / Community Reward / Welcome packages).

This pool is the generative layer of the realm: it powers loyalty, voting rights and community experiences via the SØF token. The 7% APR is a variable maximum — emission may drop to zero if the pool becomes exhausted and governance does not intervene. No fixed yield promise, no return guarantee.

SØF pool · stake SØF, receive NØA (LR Pool)

The reverse direction. Whoever has collected SØF — via NØA staking, governance participation, Partner cashback or the annual Community Reward — can lend it back to the realm and receive NØA from the LR Pool.

Fee-driven funding (closed-loop economy). The LR Pool is fed by:

• The 10% NØA fee skimmed per Partner transaction via the Fee Collector wallet → LR Pool (continuous inflow, automatic via Smart Contract);
• The Camelot Community wallet which periodically tops up — guaranteed in the first year 5K NØA/Epoch at balance below 50K, optional thereafter via governance;
• The HBAR Reserve which, upon pool-overflow above the 100M NØA cap, automatically finances NØA buy-backs (overflow mechanism: excess inflow → HBAR Reserve → NØA purchase on SaucerSwap → donation to LR Pool or destruction).

Emission formula. Per Epoch (7 days) a fixed 7% APR rate is released (= 0.1346% of the pool balance). This budget is split:

• 70% — SØF stakers (Benefit 1): distributed pro-rata on SØF stake × NFT tier multiplier (1.00×–1.30×);
• 30% — Partner bonuses (Benefit 3): reserved for accredited Partners who accept NØA. During the parked-Partner-feature phase this 30% remains in the pool as a reservation (growing latent buffer); after Partner activation it is distributed pro-rata based on Partner-NFT-tier × activity-score.

Initial seed: 500,000 NØA from the Camelot Family pool at launch (cold-start bootstrap). Pool cap: 100M NØA — when exceeded, excess inflow is rerouted to HBAR Reserve for buy-back, supporting NØA liquidity. Min threshold: at Epoch budget < 1 NØA the Epoch is skipped (gas efficiency).

No lock-up, no time limit: you can lock or unlock SØF at any moment, tokens return instantly to your wallet. Whoever does not place SØF in the pool receives no NØA distribution.

This structure closes the cycle: Partner fees continuously feed the pool, stakers receive NØA in proportion to their lock contribution and NFT tier, and the pool cap guarantees that NØA supply is never artificially eroded. No yield promise, no fixed APR guarantee — variable loyalty distribution dependent on Partner volume and pool balance.

Parameters & mechanics

• Epoch length: 1 month (12 Epochs per year). Rewards are calculated and released per Epoch.
• Staking fee: a small fee is levied on each staking, harvest or unstake transaction, paid in the corresponding token (NØA for the NØA pool, SØF for the SØF pool). The exact fee is set at launch of the Camelot Dapp and publicly announced. The fees serve to maintain and further develop the project.
• Network costs: for each transaction you need a small HBAR fee (typically < 1 HBAR).
• No lock-up period: you can unstake at any moment. unstake = total staked + current rewards − staking fee. Tokens arrive instantly in your wallet.
• Harvesting: clicks instantly via smart contract. When using the harvest tool, your previous share + current Epoch rewards are automatically restaked, for compounding effect.
• Simultaneous participation: you can participate in both pools at once. The shares are calculated independently.
• Wallet support: HashPack is the recommended wallet for staking. Other HTS-compatible wallets (Blade, Kabila) also work.
• The displayed APYs per pool are dynamic and not guaranteed; they are annualised projections based on the current Epoch payout.

NFT bonus per tier — only on SØF pool

Holders of a Camelot Order NFT enjoy a staking bonus that increases with the tier. The bonus applies exclusively to the SØF pool — those who stake SØF and receive NØA in return get a higher payout than a knight without NFT holding. The bonus is applied as a multiplier on the staking share (not on the deposited capital) at every Epoch payout from the SØF pool:

The NØA pool has no tier bonus — those who stake NØA and receive SØF get their proportionate share without multiplier. The higher your Order, the greater the recognition when you put your earned SØF back into the realm: a Holy Grail holder who stakes SØF receives 30% more NØA than a knight without NFT holding for the same input. The bonus rewards those who close the cycle — those who lead SØF back to NØA instead of merely accumulating it.

Tier 0 — Camelotian (subscription-based admission NFT)

The Camelotian is the inhabitant of Camelot — a proud member of the Camelot Family, bound by honour, brotherhood and a shared mission. A monthly renewable membership — not a lifetime Order NFT like Squire through Holy Grail.

The Camelotian is intended for those who want to participate in the Camelot Family community without a large one-off commitment — e.g. a citizen who wants to benefit from partner cashback (SØF rewards at accredited Partners) or attend events. It is a service subscription, not an investment instrument: there is no yield, no recurring NØA package, no return guarantee. The one-time welcome gift of 100 NØA on first payment is a symbolic onboarding gesture — no profit-sharing, no future commitment, no vehicle for expected price appreciation. Those who wish to stake for SØF rewards or seek an AVALØN multiplier take an Order tier (Squire or higher).

The €13/month price may be adjusted via AVALØN governance within a pre-set range of €5 to €25 per month. Adjustments outside that range require a meta-vote.

Annual Camelot Family Community Reward — loyalty distribution to active members

In addition to staking and partner cashback, Camelot provides an annual Community Reward in SØF for members who keep the realm alive. Announced on 1 January and paid out in December/January of the same scoring year, based on a pre-publicly disclosed engagement-scoring whereby activity during the calendar year (events attended, AVALØN votes cast, payments with NØA at accredited Partners and NØA/HBAR LP staking) is aggregated and a pro-rata SØF distribution is determined from the annual budget.

Fair positioning — what the Community Reward is and is not. This is a loyalty distribution to customers under Belgian B2C law (Book VI WER art. VI.91), comparable to retailer loyalty points — no yield, no return, no income on the NFT purchase. There is no fixed percentage, no guaranteed annual budget, no claim for passive holders. Holding an NFT alone is not sufficient: participation in events, AVALØN votes, partner payments or community functions is required. Inactive holders receive no distribution. The annual budget and scoring formula are pre-publicly announced by Camelot bv via whitepaper amendment, HCS broadcast and Family Portal — once announced they are immutable for that scoring year (no retroactive change).

NFT-tier multiplier on the aggregate score: Camelotian 1.00× · Squire 1.05× · Defender 1.10× · Knight 1.20× · Camelot 1.35× · Excalibur 1.55× · Holy Grail 1.80× (applied to the highest tier held on 31 December 23:59 UTC of the scoring year; no stacking). Anti-whale cap: maximum 5% of the annual budget per wallet. Minimum threshold: members below 20 points receive no distribution (administrative overhead). Sybil protection via wallet deduplication (IP + email + KYC cohort, same dedup engine as the Camelotian welcome gift).

First year (2026): indicative budget 25,000 SØF. Scaling path: from 2027 onwards 50,000 SØF base, scalable to 100,000 SØF for >5,000 active members, with absolute cap of 9% of the then-remaining Camelot Family pool (5% allocation, 1,111,111 SØF) per year — so the pool is not depleted in finite time. Any tax implications of receiving SØF are the recipient's responsibility; Camelot bv issues tax slips in accordance with fiscal obligations for distributions above the statutory threshold.

VIII. The Camelot Family — Partners and local commerce

The Camelot realm reaches beyond a Discord server or a blockchain explorer. We want to empower small and medium-sized entrepreneurs, local shops and meaningful initiatives by accepting NØA as an alternative payment method. Customers who pay with NØA in turn receive SØF cashback directly from the Camelot Treasury — not from the Partner's pocket.

The role distribution — who gives what

• The customer pays the Partner with NØA (POS, online, app).
• The Partner receives NØA as regular business payment. They give no NØA back to the customer.
• The Camelot Treasury automatically sends SØF cashback to the customer's wallet — funded from the Camelot Family allocation and/or a common cashback pool.

The Partner therefore bears no marketing cost for the loyalty reward. Camelot funds the SØF cashback from its own resources, as thanks to those who keep NØA in circulation.

What a Partner can do

An accredited Partner can, via the Camelot Partner Portal:

• Accept NØA as payment for goods and services (full purchase, partial payment, or in combination with EUR/HBAR);
• Stake the received NØA in the NØA pool for SØF loyalty distribution (see Chapter VII);
• Use NØA as working capital — for example to purchase from other Camelot Partners, pay suppliers, or cover running costs;
• Sell NØA back on SaucerSwap at market price when EUR liquidity is needed.

Anyone can become a Partner, regardless of size or location within the European Economic Area. Joining is voluntary, leaving as well — no contract binding at the token level. Partners go through a light KYC at accreditation and pay no entry fee.

Cashback ratio for the customer

Per Partner transaction the customer receives 10% of the spent NØA amount as SØF cashback, conversion ratio 1:1 (100 NØA payment → 10 SØF cashback). The cashback is sent directly after the transaction to the customer wallet via the Camelot Payment Smart Contract. If the customer wallet has not yet associated the SØF token (Hedera HTS requirement), the cashback is parked in an escrow contract; the customer can claim it later after associating SØF.

The cashback is financed from a dedicated Partner Cashback wallet which receives 25,000,000,000 SØF (50% of total SØF supply) at genesis. When the balance drops below 2.5 billion SØF, the wallet is automatically replenished with 5 billion SØF from the DRIP Fund (governance-configurable thresholds). At current consumption patterns (10% of customer volume) the wallet is conservatively over-funded: even under hyperscale adoption (€100M+ annual Partner volume) the buffer remains workable for 7+ years — ample room for governance to adjust.

In addition to the cashback, 10% of the NØA amount is skimmed as network fee per Partner transaction via the Fee Collector wallet — this fee directly feeds the LR Pool (see Chapter VII) and thus the loyalty distribution to SØF stakers. The Partner therefore receives net 90% of the transaction amount in NØA and bears only the Hedera gas cost (~$0.001 per cashback transaction). Customer- and Partner-side costs are clearly communicated via the Camelot Payment app before confirmation.

The fee and cashback percentages (10% / 10%) and the NØA→SØF conversion ratio (1:1) can be adjusted via AVALØN governance within previously set ranges (0–20% per parameter). For the realm: this mechanism stimulates the use of NØA as genuinely circulating payment medium and closes the value cycle — Partner volume feeds loyalty rewards for stakers, stakers keep NØA in circulation, customers are rewarded for its use. No yield, no return guarantee — pure utility cashback comparable to loyalty points at retailers (Book VI WER art. VI.91).

Multi-device Partner Portal

The Camelot Partner Portal is accessible via multiple devices so that every entrepreneur can work as it suits them best:

• Mobile — for counter use in shops, hospitality, at events. Customer pays, partner scans or registers NØA reward in a few taps.
• Tablet — for cash register integration or demonstration to customers.
• Desktop — for administration: managing Partner wallet, setting reward rules, downloading transaction reports.

IX. The eight Protocols

The realm is not governed by a single person, but by eight Protocols each carrying a specific responsibility. Together they form the laws of the treasury. The mechanisms, triggers and formulas described below form the stable foundation of NØA.

1. LR Protocol — Liquid Reward — SØF emission per Epoch for stakers
2. DRIP Protocol — Treasury distribution — manages release of un-issued NØA
3. Minting Protocol — Conditional Future Emissions under three-gate protection
4. EDR Protocol — Emission Distribution Ratio — distribution tracking metric
5. Multi-Sig Protocol — Governance security — multiple independent key holders
6. Transparency Protocol — Public verifiability of HBAR funding at issuance
7. Vesting Protocol — Anti-dump protection — hybrid immutable schedule + executor-shim
8. Governance Execution Protocol — AVALØN — bridges community votes to on-chain execution

Visual architecture — how the eight Protocols work together

The diagram below shows the complete protocol chain: triggers from the EDR Protocol drive the Minting Protocol; the three-gate (Economic · Time · Governance) protects every new Batch; the Multi-Sig is the gate every critical transaction must pass through; the Transparency Protocol observes the whole system as a publicly verifiable layer.

1. LR Protocol — Liquid Reward

The LR Protocol determines how many rewards per Epoch are added to the staking pools. The yield comes from two independent sources:

• DRIP Fund yield — the DRIP Fund's own assets are deployed on web3 applications and generate returns.
• Hedera native staking — all HBAR in the treasury is staked on various Hedera nodes; the staking rewards are converted by Camelot Labs into NØA and added to the LR Pool.

Parameters:

• One Epoch = 1 month → 12 Epochs per year
• APY is variable per Epoch and not guaranteed
• Holders of a Camelot Order NFT enjoy a staking bonus of 5% to 30% increasing per tier (Squire +5% to Holy Grail +30% — see Chapter VII for the table). The bonus applies exclusively to the SØF pool (those who stake SØF and receive NØA) and is a multiplier on the share, not on the capital itself.

Two phases:

• Phase 1 (Badge 1): 50% of native HBAR staking proceeds funds liquidity on the DEX, 50% builds up the LR Pool.
• Phase 2 (Badge 2 onwards): 100% of native staking proceeds flows to the LR Pool. The DRIP Fund takes over DEX liquidity.

2. DRIP Protocol

The DRIP Protocol is the heart of the treasury. It manages the core assets and strictly regulates when value leaves the fund.

What is in the DRIP Fund:

• The total un-emitted NØA in escrow storage — no NØA leaves the fund without activation of the other protocols.
• Camelot Labs' own assets, held as additional collateral and as yield source for the LR Pool.

What is NOT in the DRIP Fund: the HBAR funding. HBAR is no part of the DRIP Fund — it is held separately in the Camelot Treasury and serves as transparency underpinning at NØA issuance (no peg, no redemption right).

Three main functions:

• Regulating when assets may leave the DRIP Fund (towards LR Pool, liquidity pools, or new Emission Badge);
• Management (buying, selling, storage, staking) of core assets;
• Security at connections with Web3 applications.

NØA can only be released when an transparent HBAR funding is demonstrable at the moment of issuance. With each issuance, the Minting, EDR and Multi-Sig Protocol activate each other. This funding is a transparency demonstration, not a continuous backing obligation and not a price promise.

3. Minting Protocol — Conditional Future Emissions

Regulates the issuance of new NØA. Operates with two triggers, both dependent on a 100% EDR status:

• MPtrigger1 — Badge advancement within current Batch. When the EDR of the most recent Emission Badge reaches 100%, the Minting Protocol activates the next Badge of NØA from the DRIP Fund Wallet to the Emission Wallet. This Badge is subsequently released to the DEX via the Emission Schedule. MPtrigger1 is a transfer, not a mint — the tokens already exist in the DRIP Fund.
• MPtrigger2 — Conditional Future Emission Batch. When the EDR of the last Badge of the current Batch reaches 100% (= full distribution of 22,222,222 NØA), the Minting Protocol evaluates eligibility for a new Future Batch of 22,222,222 NØA with the same distribution key as the Initial Batch (45/45/5/2/2/0.9/0.1 — see Chapter II and Chapter V). MPtrigger2 is an actual mint event — subject to three-gate protection (see below). Upon successful mint, the new Batch is stored in escrow in the DRIP Fund Wallet and released to SaucerSwap via the Emission Wallet under the same 5-Badge Emission Schedule.

Three-gate protection for Future Emissions. MPtrigger2 is not automatic at EDR=100%. Before a new Batch can be minted, all three gates must be open simultaneously:

• Gate 1 — Economic gate: EDR of the last Badge of the current Batch = 100% (full liquidity absorption verified on-chain).
• Gate 2 — Time gate: minimum 3-month waiting period since EDR=100% of Badge 5 of the previous Batch. Prevents rapid dilution and gives the market time to absorb the new supply.
• Gate 3 — Governance gate: affirmative AVALØN community vote within the Camelot Family. Quorum, vote weighting and execution mechanics follow the Governance Execution Protocol (Chapter X).

If any one of the three gates is not satisfied, no new Batch is minted and the total supply remains unchanged. This protection makes NØA supply expansion demand-driven, time-disciplined and community-controlled — never algorithmic, automatic or unilaterally issuer-controlled. This is an essential anti-ART/EMT mechanism: supply expansion does not occur to defend a price position, but only when organic community demand confirms it.

No mint takes place without demonstrable HBAR funding (see Chapter IX.6 Transparency Protocol). No mint takes place without Multi-Sig approval (2-of-2 on the supplyKey — both Tangem card sets required). No mint is secret — every minting event is publicly visible on HashScan within seconds.

Three-gate decision process (sequence): the diagram below shows the complete process from Badge 5 EDR=100% to a possible new Batch — including all fail paths (no quorum, majority no).

4. EDR Protocol — Emission Distribution Ratio

The Emission Distribution Ratio (EDR) is a distribution-tracking metric that publicly demonstrates at every moment what percentage of the current Emission Badge has actually been distributed to the market via public SaucerSwap transactions. It is not a price mechanism, not a value anchor, not a stabilisation instrument and not an asset-backing ratio.

"The EDR measures the extent to which the current Badge tokens have left the Emission Wallet via verified DEX transactions." The percentage rises as more NØA is added to liquidity pools on SaucerSwap or acquired by buyers. An EDR of 93% means that 93% of the current Badge has been distributed via DEX. The EDR expresses no market price and makes no statement about the value of NØA in euro or HBAR — that is determined solely by supply and demand on SaucerSwap.

Formula:

EDR = (NØA_distributed_via_verified_DEX_transactions / NØA_in_original_Badge) × 100%

Measurement happens via the Hedera Mirror Node API by tracing transactions and comparing the Emission Wallet balance to the original Badge size. External transfers into the Emission Wallet are subtracted from the calculation to neutralise manipulation vectors (sending tokens back externally to block EDR).

Two trigger values:

• EDRtriggerMP1 = 100% (Badge advancement) — when the EDR of the current Badge reaches 100%, the EDR Protocol activates MPtrigger1 of the Minting Protocol. The next Badge is prepared for issuance to the Emission Wallet. (Previously named "EDRtriggerDP"; renamed to clarify that this activates the Minting Protocol via a transfer, not the DRIP Protocol directly.)
• EDRtriggerMP2 = 100% (Conditional Future Emission) — when the EDR of Badge 5 (last Badge of the current Batch) reaches 100%, the EDR Protocol activates the three-gate evaluation of MPtrigger2 of the Minting Protocol for a potential Future Emission Batch.

What EDR=100% does not mean: no price target, no value coupling, no stabilisation effect. It means only that the full Badge has been absorbed by SaucerSwap liquidity as part of the planned Emission Schedule. The market price continues to fluctuate freely regardless of EDR status.

The EDR is continuously updated based on on-chain data and is verifiable by anyone via Mirror Node API or HashScan.

Terminology note — replacement of "CBR". In earlier R&D documentation this metric was called "Collateral Backing Ratio (CBR)", which incorrectly suggested an asset-backing mechanism. Following a MiCA-conformity review, this has been renamed to Emission Distribution Ratio (EDR) to accurately reflect that it is a distribution tracking metric (supply-side), not a collateral coverage ratio (ART/EMT concept). This change is terminological, not functional — the underlying on-chain measurement is the same.

5. Multi-Sig Protocol

No transaction of any significance from the Camelot Treasury, the DRIP Fund or the Emission Wallet can take place without the signatures of both Tangem card sets, each held by a separately appointed bearer.

Operation: Hedera supports native key lists in its Token Service. The Multi-Sig Protocol uses a 2-of-2 KeyList with two physical Tangem card sets as signers: the NT set (NØA Treasury / Tokenization) and the NLP set (NØA Liquid Pool). Every transaction requires a tap from both cards — one set alone is not sufficient. Each set has 2 backup cards with identical seed, physically stored in 3 independent vaults per set (6 vaults in total), geographically separated.

Two Key Bearers of the Realm. The NT set and the NLP set are held by two different, appointed persons, internally referred to as the Key Bearers of the Realm. Their identities are not publicly disclosed for privacy and protection reasons. Each bearer has exclusive access to only their own 3 vaults: Bearer I has access to the 3 NT vaults, Bearer II exclusively to the 3 NLP vaults. There are no shared vaults or cross-custody.

Fair disclosure — what 2-of-2 with two bearers does and does not provide. Anti-rugpull protection rests on three layers: (i) Tangem hardware security — the seed never leaves the card; every signature requires a physical tap plus PIN; (ii) functional separation between two independent bearers — compromising only one bearer does NOT yield the full signing capability; the other bearer retains their 3 cards and can block any unilateral mint; (iii) geographically distributed vault architecture — 6 independent physical locations, no single point of failure. The residual risk is simultaneous compromise of both bearers (coordinated coercion or regulator action against both at once) — to fully eliminate this risk an external 3rd signer (lawyer, external custodian, independent board member) is required, which remains an explicit upgrade option (migration to a 3-of-N KeyList) as the project grows beyond the MiCA Art. 4.2 utility-token exemption (<€1M / <150 persons). Readers are advised to weigh this trade-off when assessing the project.

Applied to:

• The DRIP Fund Wallet — manages release and creation of NØA;
• The Emission Wallet — controls distribution to underlying wallets (DEV, Project Team, Project Development, Camelot Family, Founders);
• The Camelot Treasury — for all NFT and token transactions.

The round table of Camelot is literally that — multiple seal rings for one single command.

6. Transparency Protocol — Public Verifiability

Makes the HBAR funding demonstration publicly verifiable. At each NØA issuance (Emission Batch), the project demonstrates on-chain that a transparent HBAR funding was present at the moment of issuance. This is a one-off transparency demonstration per Batch, not a continuous stabilisation, not a peg, no price promise and not a redemption right. Additionally, the DRIP Fund may hold Camelot Labs own assets for staking yield and liquidity support, without this constituting an obligation to back market value.

What the Transparency Protocol does:

• Records the HBAR funding status at the moment each Emission Batch is minted;
• Publishes wallet addresses holding the HBAR funding (Camelot Treasury 0.0.10462288);
• Provides on-chain proof that no NØA is released without corresponding HBAR funding at issuance moment;
• Allows anyone to verify via Mirror Node API or HashScan the relationship between issued NØA and HBAR funding.

What the Transparency Protocol explicitly does NOT do: guarantee no NØA price relative to HBAR, provides no redemption rights at fixed exchange rate, constitutes no peg or stabilisation mechanism, creates no asset-backing obligation post-issuance. NØA remains a utility token under MiCA Art. 3(1)(9), not an asset-referenced token.

Every holder can at any moment, via Hedera explorers (HashScan, Mirror Node API), check themselves:

• How much NØA is in circulation?
• How much HBAR is in the Camelot Treasury and related wallets?
• Which transparent HBAR funding demonstrations have been published per Emission Batch?

Camelot publishes the transparency-attestor data per Batch in a separate section of the website. No trust without control.

Terminology note — replacement of "Proof of Reserve". In earlier R&D documentation this protocol was called "Proof of Reserve Protocol" with references to "minimum 1:1 reserve with HBAR". Following a MiCA-conformity review, this has been renamed to Transparency Protocol to accurately reflect that this protocol provides on-chain demonstration of issuance-moment funding, not a continuous reserve obligation. Terms such as "reserve", "backing", "collateral" and "1:1" — present in older documentation — are technically and legally inaccurate for the current Project NØA architecture and have been replaced with "transparent HBAR funding at issuance".

7. Vesting Protocol — Anti-dump protection

The Vesting Protocol governs the time-locked release of internal NØA allocations (combined 5% · 1,111,111 NØA for Project Team, Project Development, Developers Team and Founders). No internal allocation is released during the first 12-month cliff; thereafter 1/36 per month linear over 36 months.

Hybrid architecture (Camelot Labs design decision):

• Layer 1 — Immutable Schedule-Logic Contract. Hard-coded vesting parameters, no upgradeTo, no admin role. Pure read/release functions. Cannot be modified after deployment.
• Layer 2 — Upgradable Executor-Shim (UUPS) with 14-day timelock. Thin wrapper for dispatch logic, upgradable for bug fixes but never for schedule changes.
• Layer 3 — AVALØN Veto Gate. Every upgrade requires an affirmative AVALØN vote (25% quorum) before the 14-day timelock starts. During the timelock window, holders can withdraw their stake or take protective action.

Early exit before the cliff ends = forfeiture; forfeited tokens may be redirected to the DRIP Fund via 4-of-5 Multi-Sig.

8. Governance Execution Protocol — AVALØN

The Governance Execution Protocol specifies how AVALØN community votes are conducted, tallied and translated into on-chain action. It is the bridge between Camelot Family decision-making and the on-chain Protocol stack — without this protocol, Gate 3 of the Minting Protocol is undefined.

Design principles:

• No KYC requirement. Voting weight derives from on-chain HTS token balances; no identity verification gates participation.
• Hybrid weight: 70% NØA holding + 30% NFT-tier — prevents whale dominance while rewarding committed members.
• Anti-sybil via wallet-balance snapshot — one wallet = one tallied stake.
• Hedera Consensus Service (HCS). All proposals + votes published on dedicated HCS topics, fully auditable.
• 25% quorum of circulating AVALØN weight. Below that threshold: proposal fails, 30-day cooldown.
• 14-day voting window after 7-day public review.
• Execution bridge: a passed vote automatically triggers a 2-of-2 Multi-Sig (NT+NLP) scheduled transaction.

Voting weight formula: W = 0.7 × (NØA_wallet / NØA_circulating) + 0.3 × T_NFT_tier — where T-multipliers range from 0.01 (Squire) to 0.32 (Holy Grail). Camelotian (Tier 0) holders receive only base NØA voting power without an NFT-tier multiplier.

Out of AVALØN governance scope: corporate governance of Camelot bv, director appointments, profit distributions, modification of the immutable Vesting Schedule-Logic, MiCA compliance disclosures. AVALØN governs exclusively community-level decisions within the Camelot Family.

IX bis. Audit & Continuous Review

The eight Protocols guard the realm; continuous audit guards the protocols.

The smart contracts behind the Camelot Dapp — the staking contract, the partner portal bridge, the governance mechanisms — are under continuous review. Our engineering team runs daily code reviews and automated test suites for every deploy.

External audits

Camelot Labs performs regular audits by external security auditors on its smart contracts before every release. Audits cover among others:

• Re-entrancy and flow control vulnerabilities in the staking contract;
• Access control on admin and mint functions;
• Correctness of yield, fee and unstake calculations;
• Multi-sig flow and KeyList handling;
• Token allocations and EDR trigger correctness.

Audit reports are published on this website as soon as they are available. Until then: "coming when audited" — we share only when we are sure ourselves.

Bug bounty & responsible disclosure

Security researchers who discover vulnerabilities in the Camelot infrastructure are invited to report them via support@camelotlabs.be. We follow a principle of responsible disclosure: every reported vulnerability is treated confidentially until a fix is rolled out, and confirmed findings can be rewarded with an appropriate bug bounty in NØA or EUR.

X. Governance and voting

The philosophy — no one rules, all serve

In the mythology of NØA, governance is no hierarchy of kings, no council of knights, no board of directors with votes and vetoes. It is no control. It is surrender.

The Round Table has no head anymore, no king at its head. Arthur gave everything: faith, capital, will. He became empty, and thereby the table itself became the ruler. Governance in NØA is the numen that rules — the invisible, transcendent force that nourishes Camelot.

ET MAGIA SEMPER MUTAT FORMAM — The magic always changes form. Today it is an algorithm. Tomorrow an intuition. The day after, a collective wave of trust no model could ever have predicted.

Governance is therefore fluid, decentralised, impersonal. No central decision-makers. No voice rising above others. Only knights, intellects, systems and people who dedicate themselves to serving that force with relentless discipline, perseverance, honour and love.

ET ULTIMUM DONUM NON EST POTESTAS, EST VACUITAS — The last gift is not power, it is emptiness.
VACUITAS ET TAMEN PLENA — Emptiness, and yet full.

An empty vessel is the only thing that can fully receive the numen. An empty chalice is the only thing that can pour out divine love without holding anything back. An empty table is the only thing that can be truly round — without centre, without hierarchy, without owner.

AVALØN — The voting token

One instrument empowers all these ideals into concrete power: AVALØN. Named after the mythical island where Arthur's sword was forged, AVALØN is the voting token of the Camelot Family — issued and held by the Camelot Treasury (see Chapter XIII), on the Hedera network.

AVALØN has one purpose: expressing voting rights in community governance within the Camelot Family. It is no trading token, no yield token, no reserve instrument and no corporate-law voting right in Camelot bv. Whoever holds AVALØN carries a fragment of the will of the community.

How you obtain AVALØN

AVALØN is not sold and not traded. It is earned through dedication to the realm:

• NØA holding — those who hold and/or stake NØA show long-term dedication to the realm and receive AVALØN periodically as community vote.
• SØF holding — those who have earned SØF (through NØA staking, partnership or dedication) receive AVALØN periodically. SØF holders co-steer the Camelot Family community.
• Order membership — those who join an Order (Squire to Holy Grail) carry an AVALØN multiplier according to their tier — not as reward for wealth, but as recognition for dedication over time.
• Merit within the realm — exceptional contributions to the Camelot community (development, organisation of events, mentoring, contributions to code or content, service to other knights) can be acknowledged with an AVALØN award. Merit is recognised by the community, not handed out by a single hand.

All AVALØN counts for one and the same governance layer: the Camelot Family. The exact distribution formula is announced before the first governance cycle and can be further adjusted via AVALØN voting itself.

What is voted on

Topics include among others: new partner categories, parameter updates of protocols (within previously established boundaries), strategic direction of Camelot Family initiatives and events, philanthropic destinations of part of the Camelot Family allocation, and adjustments to AVALØN distribution itself.

Not in scope: corporate-law decisions of Camelot bv (annual accounts, dividend, capital change, board composition). These rest exclusively with the shareholders and management body of Camelot bv.

With AVALØN, everyone who has dedicated themselves speaks. All serve. And that is the highest form of community governance: vacuitas that is full. Emptiness that grows infinitely.

XI. The way forward

Camelot's development follows a multi-layered roadmap. Milestones are indicative; specific dates are confirmed as soon as mainnet launch and audits permit.

• 2026 Q2: Launch of the Camelot Order NFT collection (six NFT Order tiers, Tier I–VI, minted on Hedera mainnet) — alongside the separate Camelotian NFT collection (Order 0) for monthly subscriptions;
• 2026 Q3: Issuance of NØA token (Token ID follows after mint), first Emission Badge;
• 2026 Q4: Smart-contract audit of Camelot Dapp and staking contract;
• 2027 Q1: Camelot Dapp v1 — staking, harvest, Partner portal; issuance of SØF (genesis emission) and AVALØN;
• 2027 Q2: First Partner wave — accredited Belgian local entrepreneurs;
• 2027 Q2-Q3: Launch of Camelot Portal — community platform with events, governance, content;
• 2027+: International expansion of the Partner network within the European Economic Area.

XII. Legal framework

Camelot Labs operates from Camelot bv, with registered office at Meersemhof 41, 9050 Gentbrugge, Belgium — company number 0477.799.234. We respect Belgian and European law, in particular the applicable regulation around crypto-assets (MiCA), consumer protection (Book VI of the Belgian Code of Economic Law), data protection (GDPR) and accounting obligations.

Nature of the tokens

The NØA token is a utility token. It is not a share, not a debt instrument, not a financial instrument within the meaning of MiFID II, and not electronic money under PSD2.

None of the tokens (NØA, SØF, AVALØN) confers shareholder rights in Camelot bv. Holders have no shareholding, no right to dividend, no formal vote in the general meeting, no right to liquidation surplus, and no corporate-law decision-making right within Camelot bv. Camelot bv is governed by its shareholders and management body in accordance with Belgian company law.

The term governance in this whitepaper refers exclusively to community governance within the Camelot Family via the AVALØN voting instrument — over partner programmes, protocol parameters and community initiatives. It does not touch the corporate-law decision-making of Camelot bv.

The HBAR reserve behind NØA serves verifiability and transparency, not price parity; NØA is not positioned as asset-referenced token (ART) or e-money token (EMT) within the meaning of MiCA.

SØF is a loyalty and utility instrument without guaranteed counter-value, no financial instrument.

AVALØN is a non-tradable community voting instrument within the Camelot Family, no financial instrument, no share and no right to dividend or value transfer.

Related documents

This whitepaper, together with the documents listed below, forms a coherent legal package. In case of any contradiction, the terms and conditions and order statutes prevail as binding legal documents; the whitepaper is an explanatory publication.

• Terms and Conditions — definitions of all tokens (art. 1), nature of NØA / SØF / AVALØN with MiCA classification and vesting (art. 5), partner payment with SØF cashback (art. 6.2), custody arrangement (art. 7bis), comprehensive liability and risk disclosure (art. 9 with sub-sections 9.1 grounds of non-liability, 9.2 forward-looking, 9.3 limitation, 9.4 no shareholder rights in Camelot bv).
• Order Statutes — recognition of the seven Orders of the Camelot Family (art. 1) and detailed structure of the six NFT Orders (Tier I–VI) as the legal scope of these statutes (art. 2), joining (art. 3), benefits per tier (art. 4: lifetime Family membership for all NFT Orders + SØF pool staking bonus 5-30%), the three tokens as community instruments (art. 5), obligations of the Knight (art. 6). The Camelotian membership (Order 0) is governed separately in the Terms and Conditions.
• Privacy Policy — which personal data is collected and processed, retention periods for the custody arrangement, processing of Hedera Account ID and wallet data, AML/KYC obligations for Partner accreditation.

For customer support visit /en/support/. A short guide to set up a Hedera wallet is available at /en/wallet-help/.

Reservation

Camelot Labs subjects this whitepaper to periodic legal review. The final token classification and regulatory position may be sharpened after a formal MiCA opinion or FSMA consultation. Camelot bv is not a regulated financial institution under FSMA and does not operate as a payment institution under PSD2.

XII bis. MiCA classification

Project NØA is offered under the European regulatory framework of MiCA — Regulation (EU) 2023/1114 (Markets in Crypto-Assets), the central legal framework for crypto-assets in the European Union. Camelot bv positions itself explicitly within this framework to provide clarity to holders, partners and supervisory authorities.

NØA = utility token (MiCA Art. 3(1)(9))

NØA is a utility token within the meaning of MiCA Art. 3(1)(9) — "a type of crypto-asset which is intended to provide access to a good or service supplied by its issuer." NØA provides access to services and functions of the Camelot ecosystem:

• Means of payment at accredited Camelot Family Partners (see Chapter VIII);
• Stakeable instrument for SØF rewards (see Chapter VII);
• Sealing of Order membership (see order statutes);
• Generation source for AVALØN voting rights within the Camelot Family (see Chapter III bis).

NØA is NOT an asset-referenced token (ART)

An ART (MiCA Art. 3(1)(5)) "purports to maintain a stable value by referencing another value or right or a combination thereof." NØA does not meet this definition because:

• Camelot does not pursue a stable exchange rate with HBAR, EUR or any other asset;
• There is no redemption right at fixed price;
• There is no stabilisation mechanism (no mint/burn based on price deviation, no reserve arbitrage, no Algorithmic Market Operations);
• The HBAR funding at issuance (see Chapter IV) is a one-off transparency demonstration per Emission Badge, not an ongoing backing obligation;
• The NØA market value is freely formed on SaucerSwap by supply and demand, may rise, fall or be reduced to zero.

NØA is NOT an e-money token (EMT)

An EMT (MiCA Art. 3(1)(7)) "purports to maintain a stable value by referencing the value of one official currency." NØA does not meet this definition because:

• NØA does not reference an official currency (EUR, USD, etc.);
• NØA is not issued in exchange for funds with the purpose of functioning as a means of payment at par with a fiat currency;
• Camelot bv is neither a credit institution nor an electronic money institution, and seeks no licence as such.

Where the project fits in MiCA

Based on the above classification, the following MiCA provisions apply to the offering of NØA:

• Art. 4 — general conditions for offering crypto-assets (other than ART/EMT) to the public;
• Art. 6 — requirement of a crypto-asset whitepaper (this document); content according to Annex I MiCA;
• Art. 7 — marketing communications consistent with the whitepaper and not misleading;
• Art. 8 — duty to notify the whitepaper to the competent authority (FSMA in Belgium) at least 20 working days before public offering;
• Art. 13 — conduct of issuers (honest, fair, professional, in the interest of holders);
• Art. 15 — civil liability for incorrect or misleading information in the whitepaper.

What MiCA does not regulate

MiCA regulates the offering and admission to trading of crypto-assets, not necessarily all aspects of the ecosystem. The following elements fall outside the scope of MiCA and are governed by other regulations:

• Taxes — see Chapter XII ter, regulation per Member State;
• AML/KYC — Regulation (EU) 2023/1113 (Wire Transfers Regulation) and national anti-money-laundering laws;
• Consumer protection — Book VI WER (Belgium) for B2C aspects of membership;
• Personal data — GDPR (see privacy policy).

XII ter. Risks and warnings

Whoever participates in the Camelot ecosystem accepts the risks set out below. This list is not exhaustive.

Market risk — total loss possible

Crypto-assets are volatile. The market value of NØA, HBAR and any related tokens may fluctuate sharply and even fall to zero. You may lose the entire amount you invest. No deposit guarantee, no insurance and no other protection scheme such as those applicable to regulated banking products applies. SØF additionally has no guaranteed counter-value and may at any moment become worthless.

Smart-contract risk

The Camelot Dapp and all associated protocols run on smart-contract code. Although this code is subject to periodic external audits (see Chapter IX bis), audits do not provide a complete guarantee against bugs, exploits, hacks or unforeseen behaviour. Loss due to errors in smart contracts or external attacks falls outside the liability of Camelot Labs.

Hedera network risk

The entire Camelot ecosystem (NØA, SØF, AVALØN, NFT collection, staking, partner payments) depends on the Hedera Hashgraph network. Interruption, slowdown, hard fork, governance change or termination of Hedera may affect the operation of your assets. Camelot Labs has no control over the Hedera Council and is not liable for damages arising from network incidents.

Own responsibility for wallets and keys

You manage your own Hedera wallet and private keys. Loss, theft or compromise of your private key means permanent loss of your NØA, SØF, AVALØN and NFTs. Camelot Labs has no access to your wallet, cannot recover tokens, and cannot restore access to a lost account. Store your seed phrase physically, never share it, and be wary of any party asking for it — even if they claim to be from Camelot.

Taxes — your own responsibility

Receiving, holding, staking, trading or spending NØA, SØF, AVALØN or NFTs may have tax consequences (income tax, capital gains tax, VAT, gift tax, etc.) that vary by country and personal situation. Camelot Labs does not provide tax advice. You are responsible for the proper declaration and payment of any taxes in your country of residence. Consult an independent tax advisor if in doubt.

AML/KYC and anti-money-laundering regulation

Camelot Labs complies with applicable anti-money-laundering (AML) and Know-Your-Customer (KYC) obligations as required by Belgian and European law. Upon onboarding as a customer or accredited Partner, Camelot may request identification details and monitor transaction patterns. Suspicious transactions may be reported to the competent authorities without prior notification to the party concerned, as required by law.

Roadmap — no guarantee

The roadmap (Chapter XI) and all forward-looking statements in this whitepaper are indicative and not a guarantee. Milestones may be delayed, modified or cancelled depending on technical development, market conditions, regulation or community decisions via AVALØN voting.

Regulation — evolution and adaptation

The regulation surrounding crypto-assets, in particular MiCA, is in continuous evolution. Future legal changes may affect the operation, classification or availability of NØA, SØF and AVALØN. Camelot Labs will act reasonably to remain compliant, but is not liable for damages resulting from unforeseen regulatory changes.

"Lifetime" membership — aspirational

The term "lifetime membership" for the Camelot Order NFTs is aspirational: it refers to Camelot Labs' intention to maintain the Camelot Family community for as long as possible. It is not a legal guarantee of perpetual existence. The continuity of the ecosystem depends on technical, financial and community factors.

Liability of Camelot bv

The liability of Camelot bv is in all cases limited to the amount you paid for your membership or order, except in cases of intent or gross negligence. See also Article 9 of the Terms and Conditions. The Camelot Family is an informal community: Camelot Labs is not liable for actions or statements of individual members.

XII quater. Environmental impact and sustainability

MiCA Regulation (EU) 2023/1114 requires transparency about the environmental impact of crypto-assets (Annex I, Part J). This chapter provides the relevant figures for Project NØA on the Hedera network and places them in comparison with other distributed-ledger technologies.

Hedera Hashgraph — energy consumption per transaction

Hedera Hashgraph uses an asynchronous Byzantine Fault Tolerant (aBFT) consensus algorithm via gossip-about-gossip and virtual voting. Unlike Proof-of-Work (Bitcoin) or early Proof-of-Stake implementations, aBFT does not require energy-intensive mining or large-scale validator pools.

Comparison with other DLTs

The figures below are based on publicly available studies (Cambridge Centre for Alternative Finance, Crypto Carbon Ratings Institute, UCL) and are indicative — exact values vary with time, energy mix and network activity.

Hedera ranks among the most energy-efficient distributed-ledger platforms in the world. A Bitcoin transaction is estimated to consume as much energy as 235 million Hedera transactions.

Hedera Hashgraph energy mix

Hedera nodes are operated by the members of the Hedera Council, a board of international organisations (including Google, IBM, Boeing, Deutsche Telekom, LG, Standard Bank). The Hedera Council has publicly committed to a carbon-negative footprint for the network:

• Renewable energy targets at every node operator according to their own sustainability commitments;
• Purchase of renewable energy certificates (RECs) via Terrapass to offset any remaining emissions;
• Quarterly publication of Hedera Sustainability Reports with carbon footprint measurements.

Camelot Labs — choice for Hedera

Camelot Labs deliberately chose Hedera as the technological foundation for Project NØA because of its low environmental impact:

• A Camelot NFT mint, an NØA staking action or an SØF distribution consumes less energy than loading one average web page;
• The complete NØA ecosystem (22,222,222 tokens, NFTs, staking, partner payments) has a projected annual footprint comparable to a few dozen kilowatt-hours — less than the power consumption of a household refrigerator;
• No mining rigs, no ASIC farms, no energy-intensive validator pools.

Reservation — methodology

XIII. Public wallets & addresses

We believe in transparency. All Camelot wallets and token IDs below are publicly accessible via Hedera Mirror Node and HashScan. Every holder can verify at any moment what the realm holds and what is in circulation.

Operational — Camelot Treasury & NFT

Operational — Project NØA wallets

The following wallets form the treasury infrastructure of Project NØA and are all multi-sig protected:

In preparation (will be published here at issuance)