Environmental Impact Policy

Last updated on September 1, 2025

1. INTRODUCTION

BURVIX Sp. z o.o., company incorporated under number 0001131882, having its registered address at ul. Żurawia 43, lok. 8a, 00-680 Warszawa, Republic of Poland (hereinafter – “Company”, “We”, “Our”, “Us”) issues this Environmental Impact Policy (hereinafter – “Policy”).

Currently, the Company is registered as a virtual asset service provider (VASP) under Polish law and is preparing for transition to authorisation as a crypto-asset service provider (CASP) under Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on markets in crypto-assets (hereinafter – “MiCA”). Therefore, references to MiCA obligations in this Policy describe the Company’s alignment and readiness efforts, rather than current legal status.

This Policy establishes the Company’s internal framework for meeting these obligations. It sets out the methodologies, data sources, and sustainability indicators used for measuring and disclosing the environmental footprint of supported virtual currencies.

The Policy is designed in alignment with the following EU legal instruments, which together define the emerging framework for sustainability-related disclosures, in particular:

  • MiCA – Article 66(5), which obliges crypto-asset service providers (CASPs) to make publicly available, in a prominent place on their website, information on the principal adverse impacts on the climate and other environment-related adverse impacts of the consensus mechanisms used by the crypto-assets in relation to which they provide services;
  • Commission Delegated Regulation (EU) 2025/422 of 17 December 2024, supplementing Regulation (EU) 2023/1114 of the European Parliament and of the Council with regard to regulatory technical standards specifying the content, methodologies and presentation of information in respect of sustainability indicators in relation to adverse impacts on the climate and other environment-related adverse impacts (hereinafter – “Commission Delegated Regulation (EU) 2025/422”).

The Policy is reviewed and updated at least annually or upon any material change in network consensus mechanisms, the availability of sustainability data, or applicable EU regulatory requirements.

2. METHODOLOGY AND DATA SOURCES

The Company discloses sustainability indicators in accordance with Table 2 of the Annex to Commission Delegated Regulation (EU) 2025/422, which specifies the content, methodologies, and presentation of information on principal adverse impacts related to the climate and environment.

For each supported virtual currency, data is derived from publicly available, verifiable, and blockchain-specific sources, including but not limited to:

  • Cambridge Centre for Alternative Finance (CCAF) – Bitcoin and comparable Proof-of-Work (PoW) network electricity models;
  • Digiconomist Energy Consumption Index – benchmark data for PoW networks;
  • Crypto Carbon Ratings Institute (CCRI) – electricity and emission benchmarks for Proof-of-Stake (PoS) networks;
  • official network sustainability reports and foundation disclosures;
  • technical documentation and white papers of the respective protocols; and
  • empirical estimations using recognised methodologies:
    • top-down economic modelling (for PoW chains, based on hashrate, hardware efficiency, and miner economics);
    • bottom-up node-based modelling (for PoS and DPoS networks, based on validator counts and measured power demand).

Where multiple data sources exist, the Company applies a precautionary principle, adopting the most conservative (higher-impact) estimate to avoid underreporting.

Where precise figures are unavailable, the Company provides a best-effort estimate using transparent assumptions and clearly indicates such estimates in the respective disclosure tables.

3. SUSTAINABILITY INDICATORS

3.1. Bitcoin (BTC)

FieldValue
S.1 NameBURVIX Sp. z o.o.
S.2 Relevant legal entity identifierKRS 0001131882
S.3 Name of the virtual currencyBitcoin
S.4 Consensus mechanismProof of Work (PoW) with SHA-256; blocks produced approximately every 10 minutes.
S.5 Incentive mechanisms and applicable feesMiners receive block rewards (new BTC, subject to “halving”) and transaction fees paid by users; fees vary by network demand.
S.6 Beginning of the period to which the disclosed information relates2024-10-20
S.7 End of the period to which the disclosed information relates2025-10-20
S.8 Energy consumption≈ 200,200,000,000 kWh – current annualized estimate for the Bitcoin network.
S.9 Energy consumption sources and methodologiesTop-down economic approach linking miner revenues and operating costs; PoW networks’ energy use is estimated from network-wide mining economics and observed market data. Primary reference for S.8: Digiconomist Bitcoin Energy Consumption Index (annualized electricity ≈200.20 TWh at time of disclosure). Methodology aligns with MiCA RTS principle to use rigorous, systematic, and verifiable methods; where ranges exist, we disclose the best available point estimate and will update annually.

3.2. Ethereum (ETH)

FieldValue
S.1 NameBURVIX Sp. z o.o.
S.2 Relevant legal entity identifierKRS 0001131882
S.3 Name of the virtual currencyEthereum
S.4 Consensus mechanismProof of Stake (PoS) since “The Merge” (September 2022); validators propose/attest blocks based on staked ETH.
S.5 Incentive mechanisms and applicable feesValidators earn protocol rewards and priority fees (tips); base fee is burned (EIP-1559). Slashing applies for misbehavior.
S.6 Beginning of the period to which the disclosed information relates2024-10-20
S.7 End of the period to which the disclosed information relates2025-10-20
S.8 Energy consumption≈ 2,600,860 kWh – post-Merge annualized benchmark.
S.9 Energy consumption sources and methodologiesBottom-up node-level measurements for PoS: Crypto Carbon Ratings Institute (CCRI) “The Merge – Implications on the Electricity Consumption and Carbon Footprint of the Ethereum Network” (2022); corroborated by EU Blockchain Observatory summary and Ethereum.org’s sustainability page citing CCRI. CCRI reports a ~99.988% reduction vs. PoW and an annualized electricity use of ~2.6 GWh; we adopt this as the best available audited benchmark pending newer official updates; we will review yearly.

3.3. Litecoin (LTC)

FieldValue
S.1 NameBURVIX Sp. z o.o.
S.2 Relevant legal entity identifierKRS 0001131882
S.3 Name of the virtual currencyLitecoin
S.4 Consensus mechanismProof of Work (Scrypt), ~2.5-minute blocks.
S.5 Incentive mechanisms and applicable feesMiners receive block rewards and transaction fees; Scrypt-ASIC hardware profiles differ from SHA-256 (BTC/BCH).
S.6 Beginning of the period to which the disclosed information relates2024-10-20
S.7 End of the period to which the disclosed information relates2025-10-20
S.8 Energy consumptionEstimated — to be calculated via Scrypt PoW top-down model using LTC network hashrate, contemporary Scrypt-ASIC fleet efficiency and miner revenue. No widely-accepted audited kWh/year benchmark is maintained by our primary sources; we will publish a quantified estimate with assumptions in the forthcoming review cycle.
S.9 Energy consumption sources and methodologiesMethod consistent with top-down PoW models (profitability + hardware basket). As an interim reference for hardware/parameters we consider reputable mining calculators and literature, while avoiding non-audited press claims; final estimates with assumptions will be disclosed and reviewed annually.

3.4. Solana (SOL)

FieldValue
S.1 NameBURVIX Sp. z o.o.
S.2 Relevant legal entity identifierKRS 0001131882
S.3 Name of the virtual currencySolana
S.4 Consensus mechanismProof of Stake (PoS) with Proof of History (PoH) as a verifiable delay function; high-throughput PoS validator set.
S.5 Incentive mechanisms and applicable feesValidators earn protocol rewards and transaction fees; stake-based selection with potential penalties for misbehavior.
S.6 Beginning of the period to which the disclosed information relates2024-10-20
S.7 End of the period to which the disclosed information relates2025-10-20
S.8 Energy consumptionProjected ≈ 8,755 MWh (8,755,000 kWh) for 2024 snapshot (Sept 4, 2024). We use this best available recent benchmark and will update on an annual basis.
S.9 Energy consumption sources and methodologiesChain-published benchmark from the Solana Foundation Energy Use Report (Sept 2024); PoS figures reflect validator/node power profiles and network parameters. Where activity materially changes, figures will be revisited in the next annual review.

3.5. NEAR Protocol (NEAR) 

FieldValue
S.1 NameBURVIX Sp. z o.o.
S.2 Relevant legal entity identifierKRS 0001131882
S.3 Name of the virtual currencyNEAR Protocol
S.4 Consensus mechanismSharded Proof of Stake (Nightshade); validators secure shards based on stake.
S.5 Incentive mechanisms and applicable feesValidators and delegators earn protocol rewards; fees are paid by users and partially burned.
S.6 Beginning of the period to which the disclosed information relates2024-10-20
S.7 End of the period to which the disclosed information relates2025-10-20
S.8 Energy consumptionBest-available estimate pending audited kWh figure. As a PoS network, NEAR’s total electricity use is expected to be orders of magnitude below PoW systems; we will publish a quantified annualized kWh figure upon availability of an audited benchmark and update annually.
S.9 Energy consumption sources and methodologiesWe apply a PoS bottom-up approach (validator/node counts × measured/typical node power) aligned with CCRI PoS methods; NEAR reports climate-neutral status validated by South Pole, but public audited kWh/year figures are not yet available from primary sources. We disclose assumptions transparently and will update once a kWh benchmark is published.

3.6. XRP Ledger (XRP)

FieldValue
S.1 NameBURVIX Sp. z o.o.
S.2 Relevant legal entity identifierKRS 0001131882
S.3 Name of the virtual currencyXRP Ledger
S.4 Consensus mechanismXRP Ledger Consensus Protocol (federated Byzantine agreement-style).
S.5 Incentive mechanisms and applicable feesNo block rewards; minimal fees primarily act as anti-spam and are adjusted by network load.
S.6 Beginning of the period to which the disclosed information relates2024-10-20
S.7 End of the period to which the disclosed information relates2025-10-20
S.8 Energy consumption≈ 463,851 kWh (network total, annualised), per XRPL sustainability dashboard.
S.9 Energy consumption sources and methodologiesXRPL Commons Sustainability Dashboard publishes network-level electricity use and per-transaction intensity; we adopt the latest annualised network figure and will update annually.

3.7. TRON (TRX)

FieldValue
S.1 NameBURVIX Sp. z o.o.
S.2 Relevant legal entity identifierKRS 0001131882
S.3 Name of the virtual currencyTRON
S.4 Consensus mechanismDelegated Proof of Stake (DPoS), ~27 Super Representatives rotate block production (~3s blocks).
S.5 Incentive mechanisms and applicable feesSRs and voters are rewarded per protocol; users pay resource-based fees (bandwidth/energy), with partial subsidy via staking.
S.6 Beginning of the period to which the disclosed information relates2024-10-20
S.7 End of the period to which the disclosed information relates2025-10-20
S.8 Energy consumption≈ 162,868 kWh (as of July 1, 2022) – CCRI audited benchmark; used as an order-of-magnitude reference pending newer audited figures.
S.9 Energy consumption sources and methodologiesCCRI: “Energy Efficiency and Carbon Footprint of the Tron Blockchain” (2022) – node-level measurements and validator count. Given PoS/DPoS networks’ low absolute demand, we disclose the latest audited figure and will update upon release of a newer benchmark.

3.8. Bitcoin cash (BCH)

FieldValue
S.1 NameBURVIX Sp. z o.o.
S.2 Relevant legal entity identifierKRS 0001131882
S.3 Name of the virtual currencyBitcoin cash
S.4 Consensus mechanismProof of Work (SHA-256), similar to Bitcoin; ~10-minute target block interval.
S.5 Incentive mechanisms and applicable feesMiners receive block rewards and transaction fees; economics and hardware are comparable to other SHA-256 PoW chains.
S.6 Beginning of the period to which the disclosed information relates2024-10-20
S.7 End of the period to which the disclosed information relates2025-10-20
S.8 Energy consumptionEstimated – to be calculated via SHA-256 top-down model using BCH hashrate, ASIC efficiency basket and miner revenue; no continuously maintained audited BCH-specific kWh benchmark is published by primary sources we rely on. Figure will be published in the next update window with methodology and assumptions disclosed.
S.9 Energy consumption sources and methodologiesWe will apply the CBECI-style top-down approach (hybrid profitability model) adapted to BCH (hashrate × efficient hardware set × electricity price bounds), aligned with MiCA RTS (rigorous, systematic, verifiable; estimates allowed with transparent assumptions). Annual review will include updated hashrate and hardware profiles.

3.9. BNB Chain (BNB)

FieldValue
S.1 NameBURVIX Sp. z o.o.
S.2 Relevant legal entity identifierKRS 0001131882
S.3 Name of the virtual currencyBNB Chain
S.4 Consensus mechanismProof of Staked Authority (PoSA): validator set elected by stakers produces blocks.
S.5 Incentive mechanisms and applicable feesValidators and delegators earn rewards from block production and gas fees; users pay gas for transactions.
S.6 Beginning of the period to which the disclosed information relates2024-10-20
S.7 End of the period to which the disclosed information relates2025-10-20
S.8 Energy consumption≈ 492,203 kWh (annualised), per CCRI indices snapshot.
S.9 Energy consumption sources and methodologiesBenchmark from the Crypto Carbon Ratings Institute (CCRI) Indices (annualised electricity consumption for BNB Chain). Figures reflect PoS/PoSA validator power demand and are periodically updated by CCRI; we adopt the published annualised value and will review yearly.

4. Disclaimer

This Policy is prepared and published on a voluntary and informational basis, to align with upcoming MiCA environmental disclosure standards and to support transparency regarding the environmental footprint of virtual currencies.

The data, figures, and forecasts contained herein are estimates based on currently available information and are subject to change as networks evolve and new data emerges. Actual emissions and energy consumption may vary depending on technological developments and measurement updates.

The Company does not guarantee that any virtual currency or network will be entirely “green” or that all emissions can be fully eliminated. Nothing in this Policy constitutes investment, legal, or environmental advice.

The Company will periodically update this Policy to reflect new information, technological progress, and regulatory developments.