About this Statement
Coinsquare Capital Markets Ltd. (“Bitbuy”) is offering crypto contracts to purchase and sell Hedera (HBAR) in reliance on a prospectus exemption granted by the Canadian Securities Administrators (CSA) in the amended and restated exemptive relief decision dated October 11, 2024. The statutory rights of action for damages and the right of rescission in section 130.1 of the Securities Act (Ontario) and similar legislation in the other CSA jurisdictions do not apply in respect of a misrepresentation in this statement to the extent that a crypto contract is distributed under the above-noted prospectus relief.
No securities regulatory authority in Canada or any other jurisdiction has expressed an opinion about any of the crypto assets (or crypto contracts) that are available through Bitbuy’s platform, including an opinion that the crypto assets are not themselves securities and/or derivatives.
Bitbuy has compiled the information contained in this Crypto Asset Statement to the best of its ability based on publicly available information.
About Hedera
Hedera is a blockchain platform, which is open-source, that has its own cryptocurrency, called HBAR. The Hedera Network can be used to create tokens natively and supports arbitrary Smart Contracts written in Solidity, providing full compatibility with the Ethereum Virtual Machine (EVM) through its integration of the Hyperledger Besu EVM. Hedera leverages the open-source “hashgraph” consensus model, which is designed to allow high throughput and low latency for transactions on the network. In 2025, the core codebase was transitioned to a community-governed project under the Linux Foundation’s Hiero initiative to enhance decentralization and transparency. The network is secured via a proof of stake protocol. HBAR tokens were initially sold via Simple Agreement for Future Tokens (SAFT) open to insiders, advisors, friends and family in December 2017. Another SAFT round took place in Q1 2018. A third SAFT sale occurred in August 2018, and was only open to accredited investors.1 The genesis block of the chain was not produced until September 13th, 2019.
Risks
As with all assets, investing in HBAR is not without some general risks. All of the risks of tranding and staking crypto that are identified and explained in our Risk Statement apply to HBAR. In addition to the general risks, we outline some risks that are specific to Hedera below. While we make an effort to identify every source of risk, we encourage you to do your own research and ensure you are comfortable investing in Hedera.
Governance By Private Council
Hedera has a group of 39 large companies and funds which govern the token and network development called the Hedera council. Token holders do not get to vote for governance changes. As of January 2026, 31 of the 39 available council seats are filled by a diverse group of global organizations, including Google, IBM, Boeing, Dell, and Repsol. A complete and current list of council members can be found here: https://hedera.com/council.
Petition by HBAR holders regarding declining price
In early 2024, a community petition was launched by HBAR holders addressed to the Hedera Governing Council, expressing concerns regarding governance transparency and the market performance of the token at that time. The petition highlighted a perceived disconnect between the network’s institutional backing—which includes entities like Google, IBM, and Boeing—and the token’s value. While the network has since seen renewed institutional interest and technical milestones into 2026, this historical event reflects the potential for friction between the Governing Council and the broader token-holder community. Investors should be aware of this petition when evaluating HBAR.
To be made available for trading on Bitbuy’s platform, a digital asset must pass the following due diligence reviews:
Bitbuy undertakes these three levels of due diligence in order to determine whether the digital asset is compliant with our legal and regulatory obligations, is secure, and has historical data supporting a beneficial business case. Bitbuy’s New Product Committee must provide final approval for a new digital asset to be made available on the platform.
Last updated: March 24, 2026
