Salvus SAS is a company incorporated under the laws of France with registration number 920 017 134 at the Paris Registry of Commerce and Companies, with its registered office located at 9 rue du Quatre Septembre, 75002 PARIS (“Schuman”). Schuman is licensed by the French Autorité de contrôle prudentiel et de résolution (ACPR) as an electronic money institution (établissement de monnaie électronique) under articles L.526-1 et seq. of the French Monetary and Financial Code.

Terms capitalised in the Redemption Policy are defined as in the EURØP white papers.

In this policy, EURØP is referred to as the “Schuman EMT”. Natural persons holding Schuman EMT, whether EURØP or other EMTs, are identified as “Schuman EMT Holders”. Among these, a natural person acting for personal purposes outside of trade, business, craft, or profession and holding EURØP or other Schuman EMT is referred to as a “Retail Holder”.

1.1. Pursuant to Article 49 of MiCAR2, all Schuman EMT Holders have a right of redemption of their Schuman EMT at any time and at par value, subject to the conditions set out in the present policy.

1.2. Schuman’s Customers, i.e. holders that agreed to the Terms of Use of the Schuman platform or sign a Services Agreement with Schuman (the “Customers”) shall exercise their redemption right in compliance with the Terms of Use of their Schuman Financial Order Management Platform (“Schuman OMP”) Account and/or the applicable Services Agreement directly with Schuman.

1.3. Schuman EMT Holders other than Customers shall exercise their redemption right with respect to the Schuman EMT against Schuman in accordance with the following Sections.

At any time, Schuman EMT Holders may buy and/or sell the Schuman EMT via Crypto-asset Trading Platforms accepting EURØP and/or Schuman EMT trading.

2.1. Schuman EMT Holders (other than Retail Holders)

To redeem their Schuman EMT, Schuman EMT Holders, other than Retail Holders, shall open a Schuman OMP Account to access redemption-only service and agree to the Terms of Use of the Schuman OMP.
Schuman EMT Holders, other than Retail Holders, shall meet the criteria to open a Schuman OMP Account to redeem their Schuman EMT, including but not limited to the previous KYC and KYT, as further specified in this policy.

2.2. Retail Holders

Retail Holders may redeem the Schuman EMT directly from Schuman Financial by filling out the redemption form on Schuman’s website.

Retail Holders shall meet the criteria further specified in the present Redemption Policy to redeem the Schuman EMT. Schuman shall assess the eligibility of the relevant Retail Holder for redemption based on the information provided in such form and in accordance with the criteria set out. This includes the provision of a valid public key of the wallet holding the Schuman EMT.

Upon confirmation of eligibility, Schuman shall perform the mandatory verifications of the identity of the Retail Holder and other checks (KYC and KYT).

2.3. Eligibility criteria for redemption request of Retail Holders

Schuman has to abide by different regulations and Applicable Laws depending on the location of the Retail Holder.

In order to ensure compliance with Applicable Laws, including the anti-money laundering (“AML”) and counter-terrorist financing (“CTF”) requirements, the redemption of Schuman EMT will be performed if the Retail Holder can provide accurate information for the KYC and KYC verifications to be performed and validated by Schuman.

Retail Holder shall also provide an IBAN and BIC/Swift code from an EEA Bank Account for a SEPA transfer of funds.

3.1. Prior to the redemption of the Schuman EMT, Schuman shall perform:

3.1.1. Identification and verification of identity of the Schuman EMT Holders in compliance with Schuman’s AML CFT Policies and Applicable Laws (Schuman will carry out all relevant checks, reviews and internal processes);

3.1.2. Transaction monitoring verifications;

3.1.3. Verifications related to asset freezing measures;

3.1.4. Any other action required for the purpose of complying with all Applicable Laws.

3.2. In cases where the actions referred to in paragraph 3.1 would (upon Schuman carrying out all relevant internal checks, review and internal processes) reveal inconsistencies and/or AML, CFT or sanctions circumvention risks, the redemption of the Schuman EMT will be subject to further assessment in compliance with the applicable laws.

While there is no minimum threshold for redemption, Schuman Financial reserves the right to review and prohibit multiple successive redemption requests if they lack a justifiable reason or are evidently intended to disrupt Schuman Financial’s services or adversely affect the usage or availability of EURØP. If such a prohibition is enacted, Schuman Financial will provide the affected party with a clear explanation of the decision.

4.1. For Schuman EMT Holders, other than Retail Holders, redemption will be performed on the Schuman OMP Account open by the Schuman EMT Holders in accordance with the Terms of Use of the Schuman OMP Account of Schuman.

4.2. For Retail Holders, Schuman will request Retail Holders to provide bank details that comply with the Redemption Policy and sign an electronic form to attest that:

• Their bank account details are correct
• They are the beneficiary on the bank account
• If requesting a EURØP redemption, the bank account is able to accept SEPA payments (only standard acceptable)
• Accept that any potential charges or other fees (e.g. currency conversion or incoming deposit fees) charged by the Holder’s bank are not the responsibility or in the control of Schuman and, therefore, the responsibility of the Holder.

Schuman will provide Retail Holders with a unique deposit wallet address generated by Schuman. Retail Holder shall deposit the Schuman EMT(s) it wishes to redeem to this address.

Upon receipt of the Schuman EMT(s) on the deposit address, Schuman will perform relevant verifications on the Schuman EMT(s) including on previous transactions on the Schuman EMT(s). Once verifications are performed and all redemption eligibility criteria are met, Schuman will provide payment to the Retail Holder to their bank account.

This process is expected to take no more than 5 business days unless discrepancies are identified during the redemption process.

5.1. KYC, KYT, and Asset Freeze

5.1.1. Redemption of Schuman EMT shall be subject to the identity checks, transactions monitoring verifications and other actions referred to in Section 5.

5.1.2. Schuman is required to prevent restricted persons from holding Schuman EMT. A restricted person is any person who is:

a. not able to provide sufficient or consistent information in order to be identified and verified by Schuman in accordance with Applicable Laws;

b. subject or target to sanctions, including persons named at any time in any Sanctions-related list maintained by France, the European Union and any other countries in compliance with Schuman’s AML CFT Policies; or

c. located, organised or resident in a country, territory or geographical region which is itself the subject or target in the Schuman Prohibited Countries List (www.schuman.io/prohibited-countries); or

d. initiating a suspicious transaction according to the meaning of Applicable Laws; or

e. owned or controlled by any such person or persons listed above.

Together, the “Restricted Persons”.

5.1.3. In the event that a Restricted Person has acquired Schuman EMT in breach of the EURØP white paper, Schuman EMT Holder(s) qualified as Restricted Person may not redeem the Schuman EMT.

5.2. Schuman EMT Holders that do not meet redemption requirements as defined in this Redemption Policy will be denied their Schuman EMT redemption request. In case of complaints or disputes with regard to the execution of the Redemption Policy, Schuman EMT Holders shall refer to Section “Complaints & Disputes” of the EURØP white paper.

6.1. Given the decentralised and open-source nature of Schuman’s e-money tokens, it is possible for unaffiliated third parties to develop an alternative or equivalent version of Schuman EMT on a EURØP-supported blockchain or on an unsupported blockchain (a “Copy“), operating independently from Schuman. Likewise, an unaffiliated party may issue an asset that claims to be collateralised by or incorporate Schuman EMT in its structure (a “Wrapper”). Schuman exclusively supports Schuman EMT and bears no obligation to support any Copies of Schuman EMT or Wrappers. Schuman assumes no responsibility for any loss of value that may arise from the use of such Copies or Wrappers.

6.2. Due to the decentralised and open-source nature of the blockchains on which Schuman EMTs are supported, an unaffiliated third party may create an alternative version of the blockchain (“Fork”). In the event of a Fork affecting one of the EURØP-supported blockchains, Schuman may be required to suspend all activities relating to the affected Schuman EMT for an extended period until Schuman, at its sole discretion, determines that full functionality can be restored (“Downtime”). This Downtime may commence immediately upon a Fork, potentially with minimal or no prior notice, during which Schuman EMT Holders will be unable to engage in various activities involving EURØP and/or other Schuman EMTs. In the case of a Fork on one of the EURØP-supported blockchains and/or Schuman EMT-supported blockchains, Schuman reserves the exclusive right, at its sole discretion, to decide which Fork, if any, it will support.

7.1. Schuman reserves the right to amend any provision of this Redemption Policy at any time by posting the updated version, including a revised date, on Schuman’s webpage and following the procedures outlined in Part D of the EURØP white paper.

7.2. Changes to the Redemption Policy will take effect and be deemed accepted by Schuman EMT Holders upon their first access or use of EURØP following the initial posting of the revised policy. These amendments shall apply on a forward-looking basis to transactions initiated after the posting date. If a Schuman EMT Holder does not agree with any such modifications, the Holder’s sole and exclusive remedy will be to cease the use of EURØP/Schuman EMT and close their account on the Schuman platform (if applicable). Schuman EMT Holders acknowledge that Schuman shall bear no liability to them or any third party for any losses incurred as a result of modifications to the Redemption Policy.

7.3. For any Material Change to this Redemption Policy, Schuman shall provide advance notice to Schuman EMT Holders via Schuman’s webpage prior to the change becoming effective. For these purposes, a “Material Change” is a significant modification that does not include (i) changes that benefit Schuman EMT Holders, (ii) amendments necessary to comply with Applicable Laws or regulatory requirements, (iii) the introduction of a new product or service, or (iv) clarifications to existing terms.

7.4. Should any significant new factor, material error, or substantial inaccuracy that could impact the evaluation of Schuman EMT arise within the Redemption Policy, Schuman shall promptly notify the competent authorities with the revised policy.

8.1. This Redemption Policy may be automatically amended or suspended by implementation of the Recovery Plan and/or the Redemption Plan in accordance with Article 55 of MiCAR.

8.2. In this scenario, Schuman EMT redemption will be managed as defined in the Schuman Recovery or Redemption Plans (as required by competent authorities) to ensure the timely implementation of recovery actions.

8.3. Schuman EMT Holders shall refer to Sections 4.3 and 4.4. of the EURØP white paper.

9.1 This Redemption Policy is governed by and shall be construed in accordance with the laws of France (“Applicable Laws”). Any dispute arising under this Redemption Policy shall be subject to the exclusive jurisdiction of the Commercial Courts of Paris, France, except where otherwise restricted by Applicable Laws.

9.2 This Redemption Policy is subject to compliance with the laws, regulations, and rules of any relevant governmental or regulatory authority, including, but not limited to, applicable tax laws, AMF CFT provisions, and sanctions. Schuman EMT Holders agree to adhere to this Redemption Policy and to abide by all Applicable Laws and regulations. Continued compliance with this Redemption Policy, the EURØP white paper, and all Applicable Laws and regulations is a condition of holding and transacting with Schuman EMTs.

1 As defined in MiCAR for “retail holder”.
2 Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on markets in crypto-assets (“MiCAR”)