This Token & Rewards Risk Disclosure(“Disclosure”) applies to your participation in the Mālama network, including any interaction with Hex Nodes, MLMA tokens, validation rewards, environmental assets, or blockchain-enabled features (collectively, “Rewards”).
This Disclosure is incorporated into the Mālama Terms and Conditions and the Hex Node Purchase & Preorder Agreement. By purchasing a Hex Node, connecting a wallet, or participating in the network, you acknowledge and accept the risks described below.
Participation in the Mālama network does not guarantee that you will receive any Rewards. Any potential Rewards:
- Are not guaranteed and may be zero in any given period.
- May vary substantially over time.
- Depend on factors outside your control, including network size, data volume, MLMA market price, and protocol governance decisions.
- May be reduced to zero if your node fails to maintain required uptime, data quality standards, or audit compliance.
Mālama does not promise income, yield, return on investment, appreciation in value, or resale opportunity. You should not purchase a node or participate in the network with an expectation of profit.
Rewards, tokens, credits, or similar instruments made available through the network:
- Are not offered as securities and are not offered with a promise of profit from the efforts of others.
- Are not investment contracts.
- Are not deposits or savings products.
- Are not insured by any government, agency, or financial institution.
Nothing in Mālama materials constitutes financial advice, investment advice, or a recommendation to purchase or hold any digital asset. You are solely responsible for your decisions.
MLMA is classified as a digital tool under the March 17, 2026 SEC-CFTC Joint Interpretation (S7-2026-09): an asset used to perform a function in the network, not held as an investment instrument. Its functions are:
Mālama classifies MLMA as a digital tool under S7-2026-09: an asset used and consumed to perform a function in the network, not a security, investment contract, share, deposit, savings product, or claim on revenue. MLMA is not a “utility token” in the loose pre-Interpretation sense, which is not a category under S7-2026-09. The Company does not undertake managerial efforts for the benefit of MLMA holders and does not guarantee token value.
The regulatory classification of any digital asset is inherently uncertain and depends on facts and circumstances that may change, including how the token is marketed, traded, and perceived by purchasers.
Mālama’s legal partner, Beneficial Technology, is conducting an ongoing Howey test analysis. You should not rely on Mālama’s intended characterization as a determination of how regulators or courts in your jurisdiction will classify MLMA. You must consult your own qualified legal counsel before acquiring MLMA or participating in the network.
If Rewards include MLMA tokens or other transferable digital assets:
- Their value may be highly volatile and may decline to zero.
- Liquid secondary markets may not exist or may become illiquid at any time.
- Trading or transfer may be restricted or prohibited in your jurisdiction.
- Prices may be influenced by external factors entirely unrelated to Mālama’s business or the protocol’s performance.
- The MLMA emission schedule is fixed. The protocol cannot and will not issue additional tokens to stabilize price or compensate for price decline.
Mālama does not control secondary markets and does not guarantee that any MLMA token can be sold or exchanged at any particular price or at all.
The legal and regulatory treatment of tokens, digital assets, environmental credits, and decentralized infrastructure is evolving rapidly. Risks include:
- Tokens being reclassified as securities or other regulated instruments by regulators.
- Restrictions on use, transfer, or trading in your jurisdiction.
- Licensing or compliance requirements that affect Mālama’s ability to operate.
- Tax treatment changes, including retroactive changes.
- Enforcement actions affecting availability, functionality, or value of Rewards.
Mālama may modify or discontinue token-related features, restrict access in certain jurisdictions, delay or limit distributions, or change reward structures in response to legal requirements. Such changes do not constitute a breach of any agreement with you.
Validation rewards, if any, depend on:
- Node uptime above 90%. Nodes below this threshold earn zero validation rewards for that period.
- Your hex’s Hex Type multiplier (0.95× to 1.30×: Urban Core, Urban, Suburban, Rural, Remote), governance-reviewed and subject to change.
- Your hex’s Data Demand Score multiplier (0.70× to 1.30×), recomputed quarterly from independent demand signals, not operator behavior.
- Cohort composition - rewards are cohort-normalized to the 25M Genesis pool, relative and not fixed.
- Protocol updates, third-party sensor deployments, and enterprise data demand in your hex zone.
Failures or underperformance in any of these areas may reduce or eliminate Rewards.
The following risks are specific to the Genesis 200 program and should be understood before reserving a node.
Competitive reward dilution
Rewards are competitive and relative to the entire active validator set, not fixed per node. Each operator’s Final Earned MLMA is their Calculated Eligibility divided by the cohort total, scaled to the fixed 25M Genesis pool. As more Genesis operators qualify, each operator’s share of the fixed 25M pool adjusts proportionally. Joining early does not lock in a specific reward amount. Final amounts depend on the full cohort’s composition.
Allocation forfeiture risk
Failure to deploy your Hex Node within 90 days of hardware delivery results in permanent forfeiture of your 125,000 MLMA allocation and your NFT-HEX License, with no refund.
The 90-day window begins at hardware delivery, not at reservation. Hardware is estimated to ship by end of December 2026. If you cannot physically install and register your node within 90 days of receiving it, you risk losing both the hardware value and the entire MLMA allocation.
Extensions require written request to Mālama before the window expires.
Audit gate before emissions
MLMA validation rewards do not begin automatically at hardware boot. They begin following a Genesis Hex Sale audit in early 2027 that confirms your node is operational, compliant, and properly registered. If your node does not pass the audit initially, rewards are withheld until compliance is confirmed. Your 125,000 MLMA vesting allocation is not affected by audit status. Only validation rewards are withheld during the period of non-compliance.
Genesis phase non-steady-state
Year 1 reward levels are a deliberately temporary bootstrapping mechanism. The 1.5× Genesis Multiplier, constrained early validator competition, and front-loaded emission taper and the Year 1 Genesis multiplier produce elevated reward weight during the cold-start phase. These economics are not sustainable or representative of long-term returns. The Genesis Multiplier expires permanently at the end of Year 1. Emissions follow a fixed 8-year smooth taper (60M MLMA total: 12 / 14 / 12 / 9 / 6 / 4 / 2 / 1M), winding down to zero after Year 8. Any projected earnings based on Year 1 Genesis phase economics will not persist beyond that phase.
Emission taper and revenue transition
Scheduled emissions follow a fixed 8-year smooth taper (60M MLMA total: 12 / 14 / 12 / 9 / 6 / 4 / 2 / 1M), winding down to zero after Year 8. The network transitions to revenue-funded operator distributions by Years 4-5; from Year 9 all operator rewards come from protocol revenue only.
If protocol revenue in Years 4-5 is lower than projected. Whether due to slower enterprise customer adoption, registry acceptance delays, or competitive pressure. Operator rewards will be proportionally lower. Emissions taper toward zero over this period, so later-year distributions increasingly depend on actual protocol revenue.
Operators who model later-year economics based on peak early-year emission levels are modeling a different regime.
Slashing penalty
Fraudulent, manipulated, or falsified attestations may trigger a 10% MLMA slashing penalty applied to your staked or allocated MLMA. This includes spoofed sensor data, location fraud, double-signing, or any other attempt to manipulate the validation consensus. Slashing is protocol-enforced and is not reversible. Operators are responsible for ensuring their node software is correctly configured and that they have not tampered with the hardware or firmware.
veMLMA lock illiquidity
MLMA tokens voluntarily locked as veMLMA are illiquid for the duration of the lock period (3 to 24 months). If you lock your allocation or validation rewards as veMLMA, you cannot access, transfer, or sell those tokens until the lock expires, regardless of market conditions, personal financial need, or changes in your circumstances. veMLMA locking is entirely voluntary but the illiquidity risk is absolute once the lock is committed.
PONO governance eligibility
Participation in veMLMA governance votes requires a PONO non-transferable eligibility credential issued by the Mālama Foundation, in addition to holding veMLMA. PONO is issued based on KYB completion, active hardware deployment, and operating history. Holding MLMA or veMLMA alone does not entitle you to governance participation. PONO criteria will be published before mainnet governance goes live. PONO may be revoked for violations of network rules.
Participation in the network involves technical risks, including:
- Hardware failure, connectivity issues, power interruptions.
- Firmware or software bugs and security vulnerabilities.
- Incorrect configuration or installation errors.
- Data transmission errors affecting data quality and validation acceptance.
- Incompatibility with required firmware or software updates.
- Physical damage from weather, flooding, or other environmental conditions.
Mālama is not responsible for losses resulting from improper setup or maintenance, failure to follow operating instructions, or environmental conditions affecting hardware performance.
The network uses Cardano and Base. If Rewards or system components interact with any of these blockchain networks:
- Transactions are generally irreversible. Errors cannot be undone.
- Smart contracts may contain bugs or vulnerabilities not detected by audit.
- Networks may experience congestion, hard forks, downtime, or deprecation.
- Transaction fees (gas) may fluctuate significantly.
- Data recorded on-chain. Including your geographic hex cell assignment. Is permanent and publicly readable.
- The ATECC608B Device DID provisioned in your node is non-exportable. Loss of the physical device without backup documentation may result in loss of network identity.
You are responsible for understanding how blockchain systems work before participating.
If you use a digital wallet to receive MLMA or hold your NFT-HEX License, you are solely responsible for securing your private keys and credentials. Loss of keys may result in permanent, irreversible loss of access to your tokens, License NFT, and any associated Rewards.
Mālama does not store private keys, recover lost wallets, reverse transactions, or provide custody services except through the limited custodial checkout option described in the Terms and Conditions.
If Rewards relate to environmental data, carbon markets, or sustainability metrics:
- Environmental measurements may be estimated, modeled, or subject to inherent sensor uncertainty.
- Verification standards applicable to carbon credits may evolve or tighten.
- Acceptance of Mālama-attested data by registries (Isometric, Puro.earth, Verra, or others) is not guaranteed and depends on registry-specific methodology approval.
- Environmental credits produced from data validated by your node may not be issued, accepted, or monetized.
- Methodologies may be challenged, revised, or discontinued.
- Carbon market prices and demand are outside Mālama’s control.
Participation in the Mālama network does not guarantee issuance of carbon credits, acceptance by any registry, or the ability to sell environmental assets. The protocol validates data; it does not guarantee the downstream carbon market outcome.
Mālama and the veMLMA governance system reserve the right to modify reward formulas, change Hex Type or Data Demand Score coefficients, alter distribution schedules, adjust eligibility requirements, or discontinue Rewards entirely. For technical optimization, fraud prevention, regulatory compliance, or network sustainability.
Immutable parameters. The 500M MLMA hard cap, the 8-year emission schedule (60M total), the Genesis 200 supply cap, and hex exclusivity. Cannot be changed through governance. All other reward parameters are subject to governance modification with notice as described in the Hex Node Purchase Agreement.
You are solely responsible for determining whether Rewards are taxable in your jurisdiction, reporting any income, gains, or losses, and complying with all applicable tax laws. Mālama does not provide tax advice and may not provide tax reporting documentation unless required by law.
U.S. participants should be aware that the IRS has issued guidance on the taxation of cryptocurrency received through validation-like activities, including Revenue Ruling 2019-24 (hard forks and airdrops) and Revenue Ruling 2023-14 (staking rewards treated as ordinary income at fair market value when the taxpayer obtains dominion and control). The IRS has not issued specific guidance on DePIN operator rewards, but the ruling framework may be analogous.
Operators receiving MLMA through vesting events (boot tranche, PONO tranche, or operational milestone tranches) may recognize ordinary income at the time tokens become subject to the operator’s control, valued at the MLMA fair market value on that date, with a separate capital-gain or -loss event on later sale. The 18,750 MLMA boot tranche, the 18,750 MLMA PONO tranche, and each subsequent milestone tranche (25,000 / 25,000 / 37,500 MLMA at the 6-, 9-, and 12-month milestones) would each separately trigger a potential income recognition event under this framework.
State and local tax treatment varies. This note is informational only and does not constitute tax advice. You must consult a qualified tax professional familiar with digital assets before participating.
You agree that you are not relying on any of the following as a basis for your participation decision:
- Statements about future MLMA value or price.
- Projected earnings, reward estimates, or cost recovery timelines published by Mālama or any third party.
- Marketing materials suggesting specific returns.
- Third-party commentary, social media, or community discussion.
You are making an independent decision based on your own assessment of the risks described in this Disclosure, the whitepaper, and the operator documentation, after consulting your own advisors.
The network relies on third-party systems including cloud infrastructure providers, Cardano and Base blockchain networks, hardware component manufacturers, environmental data registries, oracle networks, LayerZero cross-chain bridge infrastructure, and external APIs. Failures, changes, or discontinuation in any of these systems may affect Rewards or functionality. Mālama is not responsible for third-party failures, upgrades, or policy changes.
To the fullest extent permitted by law, Mālama is not liable for: loss of tokens or Rewards, loss of expected earnings, market losses, wallet or key compromise, blockchain-related issues, hardware failure, data quality penalties, slashing events, regulatory changes affecting value or usability, or any other loss arising from participation in the Mālama network.
This limitation supplements the limitations set forth in the Terms and Conditions and the Hex Node Purchase Agreement.
By reserving a Hex Node, connecting a wallet, or participating in the network, you acknowledge that:
- You have read and understand all risks described in this Disclosure.
- You are not relying on Mālama for financial, investment, tax, or legal advice.
- You understand that participation may result in no financial return and may result in a complete loss of your $2,000 entry cost.
- You understand that Year 1 Genesis phase economics are a temporary bootstrapping mechanism and are not indicative of steady-state returns.
- You understand that MLMA rewards are competitive and relative to the active validator set and are not fixed per node.
- You understand that failure to deploy your node within 90 days of hardware delivery results in permanent forfeiture of your 125,000 MLMA allocation and License without refund.
- You understand that MLMA’s regulatory classification is subject to ongoing legal review and varies by jurisdiction, and you have consulted your own legal counsel.
- You are solely responsible for your decisions, actions, and tax obligations arising from participation.
Questions about this Disclosure or the risks of participation can be directed to the contacts below.
8 The Green, Suite A
Dover, Delaware 19901
Mālama Labs, Inc. · Token & Rewards Risk Disclosure · Effective April 11, 2026 · Last Updated April 28, 2026 (v2)
This Disclosure does not constitute investment, legal, or tax advice. MLMA regulatory classification is subject to ongoing legal review.