Galaxy ESG Report 2022

AnnualESG Report2022

Published October 2023
Galaxy’s 2022 ESG Report provides a detailed overview of Environmental, Social, and Governance (ESG) issues that matter mostto Galaxy and our stakeholders. The data included in this report is as of December 31, 2022, unless otherwise noted.

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Galaxy ESG Report 2022

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Table of Contents
01 Overview

3

04 Environmental

42		

Message From Our Founder & CEO
About Galaxy
Our Mission, Vision, and Values
Our ESG Strategy
Our First ESG Materiality Assessment
About the Artwork in This Report

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5
6
7
8
10

Bitcoin Mining
Galaxy's Carbon Footprint
Waste Reduction and Recycling

43
45
46

05 Appendix

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02 Governance11

Corporate Governance
ESG Program OversightBusiness Ethics and ComplianceBusiness Resilience and Risk Management
Cybersecurity
Public Policy Practices and Government Engagement

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17
19
21
22
24

Supporting the United Nations Sustainable Development Goals (SDGs)
Global Reporting Initiative (GRI) and Sustainable Accounting Standards Board (SASB) Index
Task Force on Climate-Related Financial Disclosures (TCFD) Index
Apex Group Assurance Letter

49
52
57
65

03 Social

26

Employee Development, Engagement, and Retention
Employee Diversity, Equity, Inclusion, and Belonging
Financial Inclusion and Education
Human Rights

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37		41			Overview

GovernanceSocialEnvironmental

Appendix

Overview
001

002

Message from
Our Founder & CEO

About Galaxy

003

004

Our Mission,
Vision, and Values

Our ESG Strategy

005

006

Our ESG Materiality
Assessment

About the Artworkin This Report

Galaxy ESG Report 2022

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Galaxy ESG Report 2022

Message From Our Founder & CEO
We at Galaxy recognize that the journey to revolutionize financial systems
goes hand in hand with our responsibility to cultivate a more sustainable,transparent, and equitable future. The work we do plays a critical role in
the new digital economy, and our dedicated team of nearly 400 employees
around the world is united by a singular purpose: accelerating the institutional
adoption of digital assets and blockchain technology in a sustainable manner.

To this end, I am excited to share our 2022 ESG Report –a testament to our unwavering commitment to harness
the power of digital assets and blockchain technology
to create lasting positive impacts that extend far beyond
financial markets.

We believe that our commitment to cultivating a sustainable businessmodel is not only integral to our responsibility as corporate citizens, but also
paramount to generating long-term value for our shareholders. Sustainability
is a strategic imperative that enhances operational efficiency, mitigates risks,and paves the way for positive innovation.

Just as ESG seeks to create an ecosystem of long-term sustainability andwell-being, the digital assets space – built on the tenants of transparency,
decentralization, and empowerment – mirrors the same fundamental pursuits.

In this context, Galaxy’s ESG Program – and our continued commitment to
responsible environmental practices, a robust governance strategy, and an
equitable, inclusive environment for our employees and the communities inwhich we operate – anchors our ability to offer long-term value creation andgrowth that optimizes returns for our valued shareholders.
Mike Novogratz, Founder & CEO, Galaxy

Message from Our Founder & CEO

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Galaxy ESG Report 2022

About Galaxy
Galaxy (TSX: GLXY) is a digital asset andblockchain leader providing access to
the growing digital economy. We serve a
diversified client base, including institutions,startups, and qualified individuals. Since 2018,
Galaxy has been building a holistic financial
platform spanning three complementary
operating businesses: Global Markets, AssetManagement, and Digital Infrastructure
Solutions. Our offerings include, amongst
others, trading, lending, strategic advisory
services, institutional-grade investment
solutions, proprietary bitcoin mining andhosting services, network validator services,and the development of enterprise custodial
technology. The company is headquarteredin New York City, with offices across North
America, Europe, and Asia.

Operating Businesses

The Company is headquartered in New York City, with offices in Dickens County (Texas),
Chicago, San Francisco, Tel Aviv, London, Hong Kong, and the Bahamas.

Global Markets
Trading · Lending · Derivatives · Advisory

Asset Management
Passive · Active · Venture Strategies

Digital Infrastructure Solutions
Mining · Validator Services · Custodial Technology

About Galaxy

Locations5Overview

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Galaxy ESG Report 2022

Our Mission, Vision, and Values
Our mission is to engineer a new economic paradigm, a globallyinterconnected digital economy that democratizes access toownership through decentralized networks and blockchain
technologies. In this new paradigm, technology and finance work as
one, creators connect with their communities, and users become
partners with builders. By merging Wall Street savvy with Silicon
Valley ingenuity, we enable innovations that will democratize access toownership, reestablishing trust and transparency within communities
and markets.
As we execute our mission, we do so with a responsibility to generate
long-term shareholder value, while capturing opportunities andmitigating risks that may arise from ESG factors. Our core principles
are the driving forces powering our mission and establish thefoundation of our vision for a society where value and ownership flow
as freely as information.

Our Mission, Vision, and Values

To engineer a new economic paradigm.

At Galaxy, we are connecting
financial expertise withtechnological sophistication,
institutions with Web3 innovations,and Silicon Valley agility with
Wall Street savvy.

A globally interconnected digital economy that
democratizes access to ownership throughdecentralized networks and blockchain technologies.

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Our ESG Strategy
Galaxy is a young company in hyper-growth mode, operating at the forefront of the rapidly maturing
digital asset ecosystem. As a leader in the space, Galaxy is committed to developing this new
frontier in a sustainable manner that prioritizes the issues that matter most to our business andstakeholders.
Our ESG program focuses on the following three key tenets:

Environmental

SocialGovernanceManaging and improving our environmental
and carbon footprint by integrating
sustainable practices and increasing the useof sustainable energy across our operations.

Investing in our people by fostering a diverse,
equitable and inclusive culture and ensuring
our employees are inspired by our mission.

Establishing strong corporate governanceto maintain a culture of integrity, all while
creating value for all our stakeholders.

Our ESG Strategy

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Our First ESG Materiality Assessment
On a biennial basis, Galaxy conducts an
ESG materiality assessment to deepen our
understanding of the ESG-related topics
that matter most to our stakeholders.
Our last materiality assessment was
conducted in 2021, and included the steps
as listed on the right. The results of the ESG
materiality assessment help shape our
ESG program strategy, prioritize our focus,
and ensure that our reporting is alignedwith addressing the ESG issues of greatest
importance to our stakeholders.

001 ·Identify

We reviewed ESG frameworks, standards, rating agencies, and ourpeers to better understand the current ESG landscape and focus
areas of each of these groups.
002 ·Categorize

We refined a list of potentially material ESG topics and categorized
them as Environmental, Social, or Governance issues.
003 ·Assess Impact

We researched each ESG topic in detail to understand its relevanceto our business and our stakeholders.

Our First ESG Materiality Assessment

004 ·Gather Feedback

We engaged key stakeholders to collect feedback on what ESG
topics they felt were most material to the long-term sustainability ofour business. After gathering feedback, the results were plotted on agraph to create an ESG Materiality Matrix.
005 ·Engage Management

The ESG Materiality Matrix was reviewed by Galaxy’s ESG Steering
Committee, a group of senior executives across business lines andregions who are charged with ensuring the effective implementationand oversight of the Company’s ESG strategy at the business level. The
Matrix was also reviewed and approved by Galaxy’s Board of Directors,
who have overall responsibility for oversight of Galaxy’s ESG strategy.

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Galaxy ESG Report 2022

ESG Materiality Matrix

HIGH

Business Resilienceand Risk Management

Corporate Governance
Cybersecurity

SocialGovernance(Prioritization Level)

Environmental

External Stakeholder Perspective

ESG Material Topic Categories:

Public Policy
Practices andGovernment
Engagement

Climate Change, Energy,
and GHG Emissions

Employee Diversity, Equity,
Inclusion, and Belonging

Employee Development,
Engagement, and Retention

ESG/Sustainability Strategy

Human Rights
Employee Health and Safety
and Working Conditions

Waste Reduction
and Recycling

LO W

HIGH

Internal Stakeholder Perspective(Prioritization Level)

Our First ESG Materiality Assessment

Business Ethics
and Compliance9Overview

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Appendix

ABOUT THE ARTWORK IN THIS REPORTAn Intersection of Art,
Technology, and History
Claudia Pawlak is the artist behind the artwork in Galaxy’s ESG Report. This collection ofimages, “Imprints of Existence,” explores the intricate relationship between communities andtheir environment by leveraging AI to generate botanical specimens. These digital renditions,consistent in their pale pink tones, yet varied in shape and size, represent a confluence of natureand technology, reflecting our simultaneous physical and digital existences.
Each AI-generated plant specimen conveys a narrative – some whisper tales of hope, showcasing
resilience and adaptation amidst challenges; others murmur warnings, their forms marred by theimprints of pollution, climate change, and the inexorable march of human progress. Together, theyecho the symbiosis between humanity and technology, reminding us of our shared responsibility
in shaping and preserving our world.
This collection is more than just a visual exploration; it's a reflection on the dual roles communities
play in the Anthropocene. We are both the preservers of history and the architects of the future.
In the vast diversity of AI-rendered flora, one sees a parallel to our own communities: a richtapestry of individual entities coming together in unity, each with a unique role, each essential.
As you journey through this digital archive, let it serve as an invitation to ponder our place in thisepoch, our shared narratives, and the footprints we leave in the sands of time. We hope you enjoy
her work as you read our report.

About the Artwork in This Report

Galaxy ESG Report 2022

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Governance
Governance
001

004

001
Corporate GovernanceBusiness Resilienceand Risk Management

Corporate Governance002

ESG Program Oversight

002

005
Business Ethics and Compliance003

ESG Program Oversight
004

Cybersecurity

Business Resilience and Risk Management005

003
Business Ethics
and Compliance

Cybersecurity
006

006

Public Policy
Practices andPublic Policy Practices
and Government
Engagement
Government Engagement

Galaxy ESG Report 2022

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Corporate Governance
The strength of Galaxy’s results and resilience of our business model are directly linked to our strong corporate governanceframework and diverse, experienced, and engaged Board of Directors.
Galaxy’s corporate governance framework is a set of principles and practices that we believe will drive growth in each of
our operating businesses, consistent financial performance, and long-term value for all our stakeholders. Our framework
reflects federal and local regulatory requirements in each of the jurisdictions in which we operate, Toronto Stock Exchange(TSX) listing standards, and effective oversight by our senior leadership team and Board of Directors. We recognize that
corporate governance standards evolve over time, which is why our Board reviews our corporate governance framework,
Committee Charters, and other governance policies periodically, and approves them as necessary and appropriate. The
Board met 16 times in 2022.
Galaxy’s Board of Directors is committed to maintaining the highest standards of corporate governance at the Company.
Our Board plays an integral role in the development of our strategy and acts as a key governing body that challenges ourleadership team to continually evolve, execute on our mission, and build for a more decentralized future, so that we candeliver value for all our stakeholders. Galaxy’s Board of Directors possesses deep expertise in capital markets, digitalassets, risk management, cybersecurity, and technology. Galaxy’s Compensation, Corporate Governance and Nominating
Committee (CGN) oversees the Director nomination and evaluation process, and considers a wide variety of skills,
professional experience, and diverse backgrounds and perspectives as critical components to a strong and effective Board.

Corporate Governance

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Board of Directors
Michael Daffey
Chairman & Senior Advisor
Mike spent over 25 years in the financial services sector at Goldman Sachs. Most recently, he was a Partner, Chairmanof the Global Markets Division and a member of the Management Committee at Goldman Sachs. Mike built his careerin the trading division at Goldman Sachs, rising to top roles, including leading equities sales globally as well as fixedincome and foreign exchange sales for Europe, Middle East, and Africa. He also served as a member of Goldman’s
European Management Committee, Firmwide Client and Business Standards Committee, and Global Markets Executive
Committee. Prior to this, Mike was the Global Co-Chief Operating Officer of Goldman’s Equities business. Mike holds abachelor’s degree in economics and finance from the University of New South Wales.

Jane Dietze
Independent Director
Jane is a tenured investment professional with more than three decades of investing experience globally across numerous
asset classes. She is the Chief Investment Officer and Vice President in the Investment Office of Brown University. Prior to
Brown, she was the Director of Private Equity at Bowdoin College. Jane joined Bowdoin from Fortress Investment Group,
where she was a Managing Director in the Credit Funds Group. Before joining Fortress, Jane was a General Partner in venture
capital funds, Nextpoint Partners, an early-stage, technology focused fund, and Columbia Capital Corporation, an IT andcommunications focused private equity fund, where she was a member of the Investment Committees and held Board roles
in over a dozen companies. Jane came to venture capital after founding, leading and eventually selling a software company.
Preceding Jane’s experience as an entrepreneur and investing in entrepreneurs, she spent several years working in Russia
and Central Europe as an Investment Officer at the International Finance Corporation, the private investment arm of theWorld Bank. She began her career as an analyst in the Mergers and Acquisitions Department of Goldman Sachs. Janereceived a bachelor’s degree in Politics from Princeton University and a master’s degree in International Economics andRussian Studies from The Johns Hopkins School of Advanced International Studies.

Corporate GovernanceDominic Docherty
Independent Director
Dominic is a British entrepreneur, and he has built several businesses in the Middle East and Asia. Since 2002, Dominic
has been founder of BIOS Middle East (BIOSME.com), a Managed Service & Cyber Security Provider. Since 2013, Dominic
has held his role as founder and Managing Director of CloudHPT.com, an infrastructure cloud business which serves
the Middle East and North Africa. These businesses were recently sold to ZainTech, a subsidiary of Zain Group. Since
2014, Dominic has also served as founder of CapitalAssured.com, which is active in the real estate sector identifying
development opportunities and disposing of institutional portfolios. Dominic holds a bachelor’s degree in economics anda master’s degree in business/managerial economics, both from University of Portsmouth.

Bill Koutsouras
Lead Independent Director & Chair of Audit Committee
Bill has been the principal of Kouts Capital since 2011, an advisory services company providing assistance tocompanies with corporate finance and capital markets related transactions including providing strategic advice,
introduction to capital providers and transaction structuring and implementation. Previously Bill was the Executive
Vice President and Chief Financial Officer of Endeavour Financial Corporation, a mining focused merchant banking
business. Bill is a Chartered Professional Accountant and Chartered Financial Analyst and is a member of theChartered Professional Accountants of Canada and the CFA Institute. Bill holds a bachelor’s degree in Economics fromthe University of Toronto. Bill has served as Lead Independent Director of Galaxy’s Board of Directors since July 2018.
Bill provides a source of leadership for the Board, complementary to that of the Chair of the Board, but independent ofmanagement of the Company. Bill enables strong leadership, creates clear accountability, and enhances our ability tocommunicate Galaxy’s message and strategy clearly and consistently while ensuring robust, independent oversight.

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Board of Directors
Richard Tavoso
Independent Director & Chair of Compensation, Corporate Governanceand Nominating Committee
In addition to being a Director, Rich has served as a Manager on the General Partner of GDH LP attending joint Board
meetings since 2018. He previously served as the President of Galaxy until December 2018. Prior to his time at Galaxy,Rich was a Managing Director at RBC Capital Markets, Head of the Global Arbitrage & Trading Division, and a memberof the Capital Markets Operating Committee. Over his 20 years at RBC, he was responsible for running the firm’s
proprietary trading division and oversaw the Central Funding group which offered secured balance sheet funding
solutions to clients. Previously, he spent 7 years at Kidder Peabody, where he built and managed the Tokyo equity
derivatives group. He holds a bachelor’s degree in History from Princeton University.

Damien Vanderwilt
Senior Advisor & Director
In addition to being a Director, Damien Vanderwilt is a Senior Advisor at Galaxy and previously served as Co-President andHead of Global Markets from 2020 until February 2023. Prior to joining the Company, he spent 20 years at Goldman Sachs,
becoming a Partner in 2016. At Goldman Sachs, he held several leadership positions across both Equities and Fixed Income,Currency and Commodities. He holds a Bachelor of Commerce (B.Com) in Finance & Economics from Bond University.

Corporate GovernanceMike Novogratz
Founder, CEO & Director
Mike founded Galaxy Investment Partners, a family office, prior to founding Galaxy, and was also formerly Partner
and President at Fortress Investment Group LLC. Mike joined Fortress in 2002 after spending more than a decade atGoldman Sachs, where he was elected Partner in 1998. Mike also served on the New York Federal Reserve’s Investment
Advisory Committee on Financial Markets from 2012 to 2015. Mike received an A.B. degree from Princeton University in
Economics and served as a helicopter pilot in the United States Army. He is also on the Board of Directors for Beat theStreets, Inc., the Jazz Foundation, Friends of Hudson River Park, the Bail Project, Princeton Varsity Club and the Board ofOverseers for New York University Hospital. As the CEO, Mike is responsible for the overall management of the businessand affairs of Galaxy. He establishes the strategic and operations priorities of the Company and provides leadership forthe effective overall management of the Company.

In light of Mike’s significant ownership interest in Galaxy and alignment
with other long-term shareholders of Galaxy, it was agreed by the
CGN Committee that, consistent with 2019 through 2021, Mike would
not be paid a base salary in 2022.

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Board of Directors Overview1
Diversity2 *Independence2

DiverseIndependent

Not Diverse

Management

53

Average Age2

Average Tenure2

2.6

4 Directors
50

3 Directors

5

14%

57%

0

2 Directors

2 Directors

2 Directors

2.1-4.0

4.1+

5

1 Director

0
5
0

45-50
*Female and/or Racially/Ethnically Diverse.

51-55

Age

[1] Directors of Galaxy Digital Holdings Ltd., the Public Company. Galaxy Digital Holdings GP LLC., our Operating Company, has two additional board members: Chris Ferraro and Rhonda Adams Medina.
[2] As of 10/11/2023, unaudited.

Corporate Governance56-60

0.0-2.0

Years

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Galaxy ESG Report 2022

Committee Composition1
Members

Pubco Board

Michael Daffey

Jane Dietze

Dominic Docherty

Bill Koutsouras

Mike Novogratz

Richard Tavoso

Damien Vanderwilt

Lead Independent Director[1] As of 10/11/2023, unaudited.

Corporate Governance

Chair

MemberBoard Diversity Disclosure Matrix1
Audit Committee
Pubco

Compensation,
Corporate
Governanceand Nominating
Committee

Total Number
of Directors

7

Director Gender Identity
Female1

Male

6

Non-Binary

0

LGBTQ+
Did Not Disclose Gender01

Director Demographic BackgroundFemaleMale

African American or Black00

Alaskan Native or Native American

0

0

Asian

0

0

Hispanic or Latino

00Native Hawaiian or Pacific Islander

0

0

White

1

6

Two or More Races or Ethnicities

00

Did Not Disclose Demographic Background

0

0

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ESG Program
Oversight
Our Board of Directors is actively engaged in the oversight of Galaxy’s ESG program. Our
Compensation, Corporate Governance and Nominating (CGN) Committee oversees Galaxy’s
ESG framework, strategy, and objectives and, along with the broader Board, is informed on key
ESG-program initiatives and updates through Board meetings and annual reports from the ESG
Steering Committee. Our ESG Steering Committee is comprised of senior executives acrossbusiness lines and regions and is charged with ensuring the effective implementation andoversight of the Company’s ESG strategy at the business level. Our ESG strategy is developedand executed by Galaxy’s Investor Relations team, who regularly meet to review and evolve theCompany’s ESG strategy for the benefit of all our stakeholders.
Corporate governance documents and policies are publicly available on investor.galaxy.com.

[1] ESG Steering Committee as of 10/11/2023.

ESG Program Oversight

Galaxy ESG Report 2022

ESG Steering Committee Members1

Veronica Adgate
Director, Office of the CEO

Sebastian Benkert
Chief Marketing Officer

Erin Brown
Chief Operating Officer

Francesca Don Angelo
Deputy General Counsel& Corporate Secretary

Jonathan Goldowsky
Head of Investor Relations

Leinee Hornbeck
Chief People Officer

Teresa Iemma
Investor Relations

Steve Kurz
Global Head of AssetManagement (Chair)

Edward Schwartz
Chief Security Officer

Tessa Wilson
Investor Relations

Brian Wright
Galaxy Mining

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Galaxy Public Company
Board of Directors

Compensation, Corporate Governanceand Nominating Committee

ESG Steering Committee1

Galaxy ESG Report 2022

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Board OversightOversees ESG program framework, strategy, and objectives. Informed through quarterly Boardof Director meetings and annual reports from the ESG Steering Committee.
Delegated ESG program oversight authority from the Board of Directors.

Management & Implementation
Responsible for ensuring the effective implementation andoversight of Galaxy's ESG strategy at the business level.

Galaxy Investor Relations[1] Chair: Global Head of Asset Management | Membership: Director, Office of the CEO, Chief Marketing Officer, Chief Operating Officer,
Deputy General Counsel and Corporate Secretary, Chief People Officer, Chief Security Officer, Galaxy Investor Relations, Galaxy Mining.

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Business Ethics and Compliance
Galaxy is committed to operating its business in accordance with the highest standards of
ethical business conduct, as we believe a culture of integrity reduces risk and builds a strong
foundation for success. It is imperative that we remain focused at all times on business ethics
and compliance – only by doing so can we maintain the trust of our clients, shareholders,
employees, regulators, and the public.
Our Board of Directors and its Audit Committee set a “tone from the top” and play a criticalrole in our efforts to foster and maintain a culture of ethics within the Company. Our GeneralCounsel & Chief Compliance Officer (CCO) and Deputy General Counsel & Corporate Secretarylead our Compliance and Ethics functions and provide updates to the Audit Committee
quarterly or more frequently, as needed.
Our approach to business ethics and compliance begins with our Global Code of Conduct,
which is certified annually by all employees. The Global Code of Conduct applies to all directors,
partners, officers, and employees of Galaxy and establishes principles for ethical, professional,
and responsible business conduct expected by Galaxy. The Global Code of Conduct, our
Employee Handbook, Global Policies on Use of Confidential Information, and Code of Business
Ethics and Conduct provide clarity and guidance on our policies for responsible business conduct.
We encourage our employees to practice sound judgment and speak up promptly whenquestions or concerns arise. A Whistleblowing Policy is in place to enable employees, officers,

Business Ethics and Complianceand directors of Galaxy, as well as other stakeholders, including third-parties, to raise concerns
on a confidential basis, free from discrimination, retaliation, or harassment for accounting,internal accounting controls or auditing matters. We take allegations of misconduct seriously
and do not tolerate retaliation against anyone raising a concern in good faith.
Due to the nature and nascency of digital assets and the broader blockchain industry, Galaxy
is subject to rigorous oversight and regulation throughout its business lines. Galaxy seeks tocomply with all applicable laws and regulations. We implement a robust risk-based Anti-Money
Laundering (AML), anti-corruption, antitrust, and competition policies, procedures, and controls inaccordance with laws around the world, including the U.S. Foreign Corrupt Practices Act (FCPA)
and Bank Secrecy Act of 1970. We conduct mandatory annual firmwide Compliance, AML/KnowYour Customer (KYC), Insider Trading & Market Manipulation, and Cybersecurity training.
We have instituted compliance standards to monitor all employees’ personal trading activities.
Galaxy employees may from time to time, become aware of important corporate developments,
significant plans or other material information before such matters are made public, therefore,
the Company has established an Insider Trading Policy and Personal Trading Accounts Policy
to assist in complying with the applicable legal requirements and prohibitions. In addition,
Galaxy maintains a Restricted Trading List that is continually updated.

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To avoid any trade in securities by Galaxy employees that may contravene or be perceived
to contravene applicable securities laws, all employees are required to obtain pre-clearance
from an Insider Trading Policy Administrator of any proposed trade of securities of Galaxy
before effecting the trade in order to confirm that there is no inside information that has notbeen generally disclosed. Such pre-clearance may be requested by submitting a request toCompliance through its online pre-clearance system, ComplySci. In addition, in line with theCompany’s Insider Trading Policy, the Company maintains scheduled blackout periods. No
company personnel shall trade in securities of Galaxy during the period commencing on the
day after the last month of each fiscal quarter and ending upon completion of one full trading
day following the date on which a press release has been issued in respect of Galaxy’s interim
or annual financial statements. An Insider Trading Policy Administrator will circulate a reminderof the scheduled blackout period before the first day of the blackout period.
Similarly, the Company has established a Personal Trading Accounts (PTA) Policy. Under the
PTA Policy, employees and any family or household member are required disclose personal
trading accounts and holdings information via ComplySci. All transactions in securities anddigital assets must be precleared in writing or electronically using ComplySci, or such otherform approved by the CCO. Employees and any family or household member must provide aquarterly holdings report using ComplySci with respect to security or digital asset holdings asof the last day of each calendar quarter.

Galaxy ESG Report 2022

Training Completion Rates1

100%

AML / KYC

Delivered over
2,000 phishing
simulation
campaigns.

100%

Insider Trading& Market
Manipulation

100%[1] As of 12/31/2022, unaudited.

Business Ethics and Compliance

Cybersecurity

Compliance

100%

20

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Business Resilience and Risk Management
We deliver a wide breadth of services and solutions, including a sophisticated digital assets
financial platform – with a strong focus on compliance and risk management. Our exacting
standards help even the most judicious businesses gain exposure to digital assets. Managing andmitigating risk in a constantly evolving environment is fundamental to our ability to run our businessand serve our clients. We approach risk management as an essential business process integrated
throughout our business lines and corporate functions. We believe risk management is the
responsibility of everyone at Galaxy.

Galaxy’s business and any changes in its risk profile over time. Our risk management program isbased on a structured and systemic process which considers Galaxy’s internal and external risks.
The risk management program includes the following steps:
001 · Identify

004 · Manage

002 · Analyze

005 · Monitor

We identify when, where, why, and how events
could prevent, degrade, delay, or otherwise
threaten the achievement of Galaxy’s objectives.

The Audit Committee oversees the management of risk to achieve a proper balance between risk
incurred, shareholder returns, and long-term business resilience. Our Chief Operating Officer (COO)and Chief Risk Officer (CRO) lead our risk functions, including the development and maintenanceof policies and procedures to identify, assess, monitor, manage, and mitigate risk. The COO reports
to the Board of Directors on principal risks and the steps implemented by management to manage
them. The CRO ensures operational procedures and controls are implemented to effectively treat
each risk area and is responsible for the implementation of risk reduction strategies.

We analyze risks to determine the likelihood,potential consequences, and overall impact of

Our risk management program seeks to minimize potential adverse effects with the implementationof a resilient and well-tested strategy supervised by dedicated professional staff and deploymentof appropriate risk monitoring tools. Our risk strategy leverages the Company’s product, legal,
compliance, risk and operations teams, as well as the relationships with third-party custodiansand other service providers. Our risk management approach is dynamic and designed to adapt to

We evaluate estimated levels of risk against preestablished criteria and consider the balance
between potential benefits and adverse outcomesto enable effective decision-making and risktreatment. Evaluate whether existing controls areadequate to mitigate risk, in line with risk tolerance.

Business Resilience and Risk Management

We manage risk and implement strategies andaction plans to mitigate risk and capitalize on risk
opportunities.

identified risks.

We monitor risk factors and the effectiveness of
the risk management process to confirm effective
risk mitigation.

003 · Evaluate

006 · Communicate

We communicate to management the risks acrossthe organization through reports.

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Cybersecurity
The sophistication and volume of the cyber threat landscape continues to accelerate every
year. Effective cybersecurity is a key tenet of Galaxy culture, customer commitment, andday-to-day operation.
Galaxy’s Chief Security Officer (CSO) is a member of the Management Committee and reports
regularly to the Board of Directors. The CSO informs the Board of Directors on privacy andcybersecurity matters, including cybersecurity policies and practices, ongoing efforts to improvesecurity, and threats to the company, its clients, and shareholders. The Audit Committee annuallyreviews the Company’s risk profile with respect to cybersecurity matters.
The CSO directly manages a dedicated, in-house Galaxy Security Team responsible for corporate
security policies and standards; mandatory security training for all employees; secure systems
development and lifecycle management; robust security monitoring, alerting, and incident
response; third-party security assurance; security penetration testing, threat intelligence andvulnerability countermeasures.
Our security program is guided by well-established industry frameworks such as FFIEC CAT
and NIST 800-53, and the team is focused on ensuring compliance with corporate policies andregulatory and legal obligations. We ensure our policies, standards, and controls keep pace withthe cyber threat landscape and regulatory environment.

Cybersecurity

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Secure Operation and Training

Secure by Design

Galaxy’s Security Operations Team works to detect and respond to threats in real-time using a
combination of automated analytics, human threat hunting techniques, and a variety of internaland external sources of threat intelligence.

Any internally developed software, systems, infrastructure, or third-party services andintegrations are required to follow “Secure by Design” SDLC processes, including a combinationof design and threat model reviews, code review and scanning, periodic penetration testing using
both internal and vendor security experts, and testing and validation of open-source libraries.
We have established numerous tactical cybersecurity processes and procedures, including
ongoing software updates, escalation of suspicious emails and phone calls, encryption at restand over-the-wire for sensitive material, privileged access management via multiple independent
services, reverse proxy for internet-facing systems, multi-factor authentication, broad use of
single-sign-on with restrictions limiting internal access to managed devices, and threat intel andindustry monitoring.

Despite any defensive technical countermeasures today, most adversaries begin cyber-attacks
by targeting the workforce. Our employees are our first line of defense and play a key role inhelping us stay ahead of the latest cyber threats. We deploy significant resources to securing andscaling our cybersecurity program and to upskill our workforce continuously. Annually, we provide
our employees with training on how to protect and ensure the security and privacy of Galaxy’s andour clients’ information.

All third-party vendors that comprise our supply chain, whether for software as a service (SaaS),
managed services, or professional services undergo a third-party cyber risk review by the
Security Team. This risk-based, tiered review process is just one of several checkpoints that also
involve Legal, Compliance, Finance, and other parties to ensure Company, customer, and investor
cyber risk is managed.

Cybersecurity Training Completion1
Delivered over 2,000 phishing simulation campaigns.

100%[1] As of 12/31/2022, unaudited.

Cybersecurity

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Appendix

Galaxy ESG Report 2022

Public Policy Practices andGovernment Engagement
Galaxy is subject to rigorous oversight andregulation throughout its business lines.
Today, we are regulated by nearly 40 federal,state, and international regulators.

US Federal Regulators
Securities and Exchange Commission (SEC)
Financial Industry Regulatory Authority (FINRA)
Commodities Futures Trading Commission (CFTC)
National Futures Association (NFA)
Financial Crimes Enforcement Network (FinCEN)

US State Regulators
Alabama (AL)

Nebraska (NE)

Arkansas (AK)New Hampshire (NH)Arizona (AZ)

New Jersey (NJ)

California (CA)New Mexico (NM)Connecticut (CT)

North Carolina (NC)District of Columbia (DC)North Dakota (ND)

Florida (FL)

Ohio (OH)

Georgia (GA)Oklahoma (OK)Idaho (ID)

Oregon (OR)Iowa (IA)South Carolina (SC)Kansas (KS)Texas (TX)

Maine (ME)

Virginia (VA)

Maryland (MD)West Virginia (WV)

Mississippi (MS)Public Policy Practices and Government Engagement

International Regulators
BAHAMAS
Securities Commission of the Bahamas (SCB)
CANADA
Toronto Stock Exchange (TSX)
Canadian Securities Administrators
Investment Industry Regulatory Organization of Canada (IIROC)
CAYMAN ISLAND
Cayman Island Monetary Authority
UNITED KINGDOM
Financial Conduct Authority (FCA)24

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Appendix

Given this complexity, Galaxy has built a best-in-class legal and compliance team—with nearlytwenty legal and compliance professionals globally. Further, Galaxy has structured its public
policy and advocacy efforts through its Legal Team.
The U.S. regulatory structure for financial institutions and market participants is complex,
with many touchpoints across the federal government depending on an individual firm’s legal
structure, business, and product offerings. Not dissimilar from that, in the digital asset and crypto
economy, the regulatory systems are fragmented at a state and federal level in the U.S. In the U.K.
the regulatory structure differs such that there is less fragmentation of regulatory stakeholders
and rulesets, however that does not diminish the level of complexity or need to engage.
Galaxy is committed to doing business in the U.S. and other relevant jurisdictions, and working
within the legal and regulatory bounds prescribed. The digital asset industry is in the early stagesof development and, because of that, the industry writ large has become more active in its
engagement with policymakers. Galaxy believes strongly that the core tenets of democratization,
decentralization, and individual sovereignty can be accretive to regulatory standards andenhance the delivery of regulators objectives.
Galaxy is committed to engaging with legislative and regulatory stakeholders at both a federal
and state level in the U.S. and internationally and has added individuals to its legal and compliancedepartment to represent the Company before the governments on both an advocacy andeducation basis.
Galaxy also believes that it is in the best interest of our shareholders to be thoughtfully engaged
in the public policy and political processes—with an eye toward advancing the short- and longterm interests of the company and digital asset industry, broadly. As previously discussed, theindustry is in its early stages, which necessitates a heightened level of engagement from a policy
education and advocacy perspective.

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25

Third-Party Code of Business Conduct and Ethics
In 2023, Galaxy took a meaningful step towards reinforcing our commitment to ethical andresponsible business practices by drafting and piloting a Third-Party Code of Business Conduct
and Ethics Policy.
The Third-Party Code of Business Conduct and Ethics Policy reflects our expectation of service
providers to conduct their operations in alignment with these standards and adhere to all
relevant laws, rules, regulations, and standards within the regions they operate. Over the courseof the next year, Galaxy expects to disseminate the Third-Party Code of Business Conduct
and Ethics Policy to our service providers and validating their commitment to abide by thestandards espoused therein.

03
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AppendixSocialSocial
001

03

003

001
Employee Development,
Financial Inclusion and
Employee Development, Engagement, and Retention
Engagement, and Retention
Education
002

Employee Diversity, Equity, Inclusion, and Belonging

002

004
Financial Inclusion
and Education
003

Employee Diversity, Equity,
Human Rights
004
Inclusion, and Belonging
Human Rights

Galaxy ESG Report 2022

26

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27

Employee Development, Engagement, and Retention
Galaxy operates in an innovative and dynamic industry, andour hiring and talent needs are growing accordingly. We haveestablished strategies to ensure diverse hiring, development,
advancement, and retention, and our ability to attract top-tiertalent is at the forefront of how we operate.
As a part of our New Hire Onboarding Program, all new hires
are assigned onboarding buddies and advisor networks to help
acclimate them into the Company. Buddies are designatedemployees that take new hires out to coffee and lunch during
their first week, conduct an office tour, introduce them toco-workers, and answer any office-related questions. Advisor
networks are groups of employees that a new hire can look
to for advice on navigating the Company.
Each summer, we bring on an intern class which is designed
to help these individuals gain valuable skills, experiences, andinsights into their chosen field. Their summer programming
consists of hands-on experience, mentorship and guidance,
training and workshops, networking opportunities, and feedback
and evaluation.

Employee Development, Engagement, and Retention

Employee Benefits
Galaxy believes a well-rounded selection of employee benefits are essential in fostering an inclusive culture and retaining a diverse
workforce. Benefits may vary based on location; Galaxy’s baseline benefits include:
001

006

002

007

003

008

004

009

005

010

Competitive and equitable compensation
Equity exposure401(k) company contribution
Paid flexible time off
Company-paid health insurance

Company-paid mental health support
Paid parental leave
Career development tools
Employee Resource Groups
Life and accident insuranceOverview

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Appendix

We provide opportunities for our employees to learn and develop in both formal andinformal settings. As part of ongoing learning and development, all Galaxy employees
have access to Galaxy Research newsletters, Galaxy Brains podcast episodes, Galaxy
Academy sessions, and other continued education resources.
Galaxy allocates significant resources to employee development and training.
Employees participate in goal setting, feedforward (mid-year check-ins), and year-end
reviews as part of our performance management cycle. This cycle then feeds into ourannual promotion process to recognize employee growth and achievement. Our People
Team also regularly measures employee feedback through focus groups and Employee
Engagement Surveys, which we conduct on an annual basis.
Galaxy views succession planning as an integral component of our business continuity,which is why we have established succession plans for key persons at our Company forboth emergencies and long-term succession. An important element of our succession
plan is our commitment to building leadership from within.
Our programs and resources promote health and productivity to unlock our people’s
potential. We offer competitive and equitable compensation and forward-looking
benefits to best serve our employees in all areas of their lives. We view compensation
and benefits as critical tools for attracting, developing, engaging, and retaining ourworkforce.

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390

Total Number of Employees1

Employees by Region1

Employees by Corporate Title1

100%

100%
88%

80%

80%

60%

60%

40%

40%
25%

20%

20%
5%

7%

0%

0%
United States

Asia
Pacific

Europe, theMiddle East
and Africa[1] As of 12/31/2022, includes Helios (41 employees), unaudited.
[2] Leadership metrics include employees who are Managing Directors and Directors.
[3] Non-Leadership metrics includes all employee levels except Managing Directors and Directors.

Employee Development, Engagement, and Retention

75%

Leadership2

Non-Leadership328

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Appendix

Galaxy ESG Report 2022

29

Employee Diversity, Equity, Inclusion, and Belonging
We are a dynamic team united by our passion for empowering investors and creators to drive
positive change in the global economy. Our commitment to Diversity, Equity, and Inclusion (DEI)
is deeply ingrained in our corporate ethos, reflecting our core principles, culture, and businessphilosophy. Oversight of our DEI strategy lies with our Board of Directors and the ESG Steering
Committee.
Our DEI strategy embraces a comprehensive approach that encompasses both top-down andbottom-up initiatives. We acknowledge that diversity is not merely a social responsibility but also
a strategic imperative, essential for achieving our goals and delivering value to all stakeholders.
Diverse perspectives not only safeguard against groupthink but also unlock the full spectrum of
talent, fortifying our problem-solving capabilities, organizational resilience, and innovation potential.
This holistic framework provides a clear and strategic direction for our ongoing DEI endeavors.
Our industry faced both macroeconomic and industry-specific headwinds over the course of 2022,
which impacted the size and composition of our workforce. Through a challenging year for markets
and companies operating in the digital asset industry, we proved our resilience and continued toinvest in our people, products, and technology, which we believe positions Galaxy to capture market
share and be a leader in our space over the long-term. We continue to expand our global footprint
and the diversity of our workforce and recognize the imperative of advancing our DEI principles. Our
DEI journey is a collective one, involving each member of our organization as we work collaboratively
towards a more inclusive industry.

Employee Diversity, Equity, Inclusion, and Belonging

Employee Gender and Ethnic Diversity1
Female2

U.S. Ethnic Diversity3

50%

50%

40%

40%

30%

30%

26%

24%

20%

10%

10%

0%

0%
Leadership4

Average
Employee Age1

35

28%

21%

20%

Overall

42%

38%

Non-Leadership5

Overall

Leadership4

Non-Leadership5[1] As of 12/31/2022, includes Helios (41 employees), unaudited.
[2] Four employees prefer not to disclose gender.
[3] Diversity metrics include U.S. based employees who identify as Asian, Black, LatinX and Twoor More Races. 22 employees prefer not to disclose ethnicity.
[4] Leadership metrics include employees who are Managing Directors and Directors.
[5] Non-Leadership metrics includes all employee levels except Managing Directors andDirectors.

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30

Employee Resource Groups
Galaxy provides forums and opportunities for employees with diverse backgrounds, experiences,and perspectives to connect with one another through Employee Resource Groups (ERGs).
These ERGs are sponsored by senior leaders and reflect the diversity of Galaxy. We added four
additional ERGs over the course of 2022 and 2023, bringing our total to six ERGs globally. EachERG works closely with its executive sponsor to help Galaxy continue to foster a global cultureof inclusion and belonging. ERGs receive dedicated resources, including an annual budget andsupport for executing initiatives and events.

Our ERG-hosted events provide a safe space for employees to connect, share their perspectives,and collaborate on programming and policies that advance inclusion and belonging. In regularly
held ERG meetings, members are empowered to voice their concerns and propose solutions,driving meaningful change from within the organization while providing awareness and education
on important topics.
Approximately 50% of Galaxy employees globally are involved in at least one ERG.

001 · Women at Galaxy

002 · APN at Galaxy

Women at Galaxy is a resource for women and allies internally and externally to makea change. The role of the group is to mentor, elevate and support women. This group is
outcome-oriented and aims to be known for actions over words. The ERG's goal is to
give women a unified voice and avenue to make a difference with each other and at theCompany.

Asian Professionals Network’s mission is to bring awareness to the diversity of Pan-Asian
cultures and values. To achieve this, the group's goals are to:
1. Address key philanthropic, cultural and businessconcerns of importance to the Pan-Asian community.
2. Support Pan-Asian business professionals
through all stages of the career lifecycle.
3. Facilitate increased interaction, communication andexchange of ideas among colleagues of all cultures and races.

Employee Diversity, Equity, Inclusion, and Belonging

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Appendix

Employee Resource Groups (Continued)
003 · Out in the Galaxy
Out in the Galaxy’s mission is to celebrate and amplify LGBTQIA+ voices at Galaxy, foster
community, drive discussion around LGBTQIA+ needs in the workplace, and provide LGBTQIA+
employees with resources for growth and development.

004 · Black at Galaxy
Black at Galaxy is a resource dedicated to the celebration and elevation of Black employees
and allies. This ERG's goal is to build a community, both internally and externally, that provides
a safe space and encourages the advancement of Black people in finance and crypto.

005 · Las Galaxias
Las Galaxias' goal is to amplify Hispanic and LatinX voices at Galaxy to foster careerdevelopment across the Company and mentorship opportunities in our local community.
This ERG's mission is to bring the Hispanic and LatinX community at Galaxy and our local
community together to increase mentorship opportunities inside and outside of Galaxy.

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Appendix

Employee Resource Groups (Continued)
006 · Mental Health ERG
In honor of Mental Health Awareness Month in May 2023, Galaxy announced the formationof a new Employee Resource Group focused on mental health and neurodiversity. The aim of
this group is to provide a safe and inclusive space for employees to share their experiences
and support each other in their journey towards improved mental health and wellbeing. This
group also hopes to promote greater understanding and awareness of neurodiversity in theworkplace and create a more supportive environment for neurodivergent employees.
Building off Galaxy's Year of Emotional Wellbeing in 2022, we hope this new ERG will continue
to promote a culture of openness and support, while raising awareness and reducing thestigma surrounding mental health and neurodiversity.

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33

DEI Speaker Series and ERG-sponsored Events

Employee Engagement Survey

We acknowledge the powerful role storytelling and idea-sharing play in our commitment
to fostering a diverse, equitable, and inclusive culture at Galaxy. In 2023, we continued our
tradition of hosting diverse speakers from across various industries and backgrounds aspart of our ongoing DEI Speaker Series. Our speaker series gives employees accessto engage with thought leaders on topics such as leadership, innovation, and diversity
itself, allowing us to challenge assumptions, understand different life experiences andperspectives, and collectively envision a more equitable and inclusive future, both within
and outside our organization.

In 2022, Galaxy conducted our first annual Employee Engagement Survey. We recognize that ourpeople are our most valuable asset and want to give them a platform to anonymously provide
important feedback on topics such as engagement, company confidence, management andleadership. This data-driven approach empowers us to make informed decisions, identify areasfor enhancement, and implement targeted initiatives that resonate with our dynamic workforce.
As we continue to expand and adapt, these surveys provide invaluable insights, directing ourefforts and actions to align with employee needs and aspirations.

In 2023, we invited Galaxy Operating Company Board Member, Rhonda Adams-Medina, andformer Chipotle Chief Diversity, Inclusion and People Officer, Marissa Andrada, to discuss
their life and career experiences as diverse women navigating senior roles at Fortune 100
Companies.
Women at Galaxy, our first Employee Resource Group, was instrumental in organizing various
social and educational events, and coaching and mentorship opportunities over the course of2022 and 2023. These included a lesson with Power Poker, which connects the game of poker
to key leadership themes such as discipline, risk taking, courage and resilience by creating asafe space for female-identifying and non-binary individuals to learn, laugh, network and play,
executive coaching sessions, and a Women in Crypto Panel, which brought together womenwith diverse backgrounds and expertise working across the digital asset space for a dynamic
discussion.

Employee Diversity, Equity, Inclusion, and Belonging

A notable insight from our Employee Engagement Survey highlighted a desire for increased
communication, both from management and across teams within Galaxy. In response, we
introduced a monthly all-hands meeting designed to deliver consistent industry-wide andbusiness-specific updates in a structured manner. These meetings also serve as a platform foreducating our employees about cross-functional projects and initiatives while acknowledging andcelebrating the achievements of individual employees and teams across the entire organization.

Galaxy Sponsorship of the International
Women of Blockchain Conference
In March of 2023, Galaxy committed $15,000 to the International Women of Blockchain Conference,
which took place in Washington D.C. that month. Olayinka Odeniran, the Founder and CEO of theBlack Women Blockchain Council, hosted the event, and Galaxy was proud to support Olayinka
and her broader mission of promoting a diverse, inclusive culture within digital assets.

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Appendix

Galaxy Partnership with Real Bedford Ladies
Football ClubIn June of 2023, Galaxy proudly announced its role as the inaugural sponsorof the Real Bedford Ladies Football Club in the UK. The Football Club is led
by Peter McCormack, who in addition to managing the organization, leads
a popular podcast, "What Bitcoin Did," with Bitcoin education at its core.
With aspirations to reach the Premier League, Real Bedford embodies aburgeoning success story within the Bitcoin community.
In a significant development in 2023, Bedford Girls & Ladies FC has joined
forces with the club, becoming Real Bedford Ladies. Galaxy is deeply
honored to support this expansion into women's football, recognizing thepressing need to bridge gender disparities both in the crypto world and therealm of sports.
Real Bedford Ladies currently boasts a roster of 50 senior players and
200 girls aged 7-16 set to join The Pirates in the upcoming season. Oursponsorship will be instrumental in procuring new playing and training
kits for all teams, covering expenses for senior players, and establishinga hardship fund to ensure that financial constraints do not impede young
girls' participation in football. Just as we firmly believe in championing
equality on the pitch, we remain committed to advancing diversity, equity,and inclusion within our industry, which is still evolving. As Galaxy continues
to expand globally, we want to help shoulder the responsibility to foster
positive change.

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Appendix

ESG in Crypto

Philanthropy
In May 2023, a group of employees from Galaxy, Coinbase, and Figment came together to tackle
the grueling Murph fitness challenge, a workout consisting of a mile-long run, 100 pull-ups, 200
push-ups, 300 air squats - all performed while wearing a 20lb vest. The motivation behind thiseffort was profound, as participants sought to pay tribute to the brave US service members
who lost their lives during Operation Red Wings in Afghanistan on June 28, 2005. On that day,a team of four Navy SEALs, including Lieutenant (Lt.) Michael Murphy, fell victim to a Taliban
ambush, resulting in the loss of three of those SEALs. Tragically, an additional 16 servicemen
perished when their helicopter was downed by an enemy rocket-propelled grenade while
attempting to aid Lt. Murphy's team. This event marked the most devastating single-day death
toll for US Forces during Operation Enduring Freedom and the most significant loss of life forNaval Special Warfare since World War II.
In the years since that day in 2005, the 'Murph' workout, which was Lt. Michael Murphy's favorite,
has been performed annually on Memorial Day as a powerful act of remembrance and respectfor his and his SEAL team's enduring legacy.
This Galaxy-sponsored event served as an opportunity to raise funds for The Navy SEAL
Foundation, a nonprofit organization committed to offering vital support to warriors, veterans,
and families associated with Naval Special Warfare. The community rallied behind this noble
cause, with the first $12,500 raised being matched in part by Galaxy employees Chris Ferraro,

Employee Diversity, Equity, Inclusion, and Belonging

Galaxy ESG Report 2022

$58,375 raised
For the Navy Seal Foundation.

Steve Kurz, and Veronica Adgate. In total, all participants across our three companies raised
nearly $60K for the Navy Seal Foundation.

35

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36

Research Report

Bitcoin’s Role in the ESG Imperative
In August 2022, KPMG released a research report on Bitcoin’s role in the ESG imperative,
where it evaluates the ESG impact of Bitcoin, highlighted various misconceptions regarding thetechnology, and showcases the variety of impactful use cases that Bitcoin offers that generatevalue for both users and society-at-large.
Environmental: The report discusses Bitcoin’s electricity usage and the emissions associatedwith the production of energy from the burning of fossil fuels relative to other industries.
KPMG’s research shows that the metric tons of carbon dioxide (MtCO2e) emitted from Bitcoin’s
operations is significantly smaller than industries such as tourism, fashion, air conditioning,
livestock and manure, and TVs, TV networks and electronics. The report also discusses four
strategies for Bitcoin to reduce its carbon footprint: 1) the use of renewable energy to lower
costs and incentivize further production of renewables; 2) the participation in demand response
programs that help balance electrical grids; 3) recycling heat from Bitcoin mining machines forother purposes such as heating homes and commercial buildings and; 4) reducing the impact of
methane being released directly.
Social: KPMG highlights various examples of the public utility that Bitcoin can offer. This includes
payments, where Bitcoin can replace cross-border payments via money transmitters. Citizens ofdeveloping countries throughout the world often travel hours to the nearest money station, pay
high transaction and currency conversion fees and can be exposed to violence, as gang members

Employee Diversity, Equity, Inclusion, and Belonging

notoriously wait outside these centers to target users. Bitcoin provides the ability for thesepayments to take place nearly instantaneously, so long as users have a device and access to theinternet, and with far cheaper transaction fees. The report also highlights how Bitcoin propels
financial inclusion, by providing simple and affordable access to financial services. The WorldBank estimates that nearly 1.4 billion people around the world do not have access to financial
services such as bank accounts. Bitcoin can serve as an access point for these individuals, while
also offering an exit ramp to poor economic stewardship by governments and central banks,
which erode people’s savings and purchasing power.
Governance: The report details one of Bitcoin’s most prominent features: decentralization. Thereis no central authority or decision-making body that controls the Bitcoin network or has the ability
to alter the protocols rules. Governance is built into the Bitcoin network through rules that arecoded into the protocol, which results in a network that cannot be abused or misused by any
individual who may possess nefarious motives.

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Appendix

Financial Inclusion and Education
Blockchain and digital assets are already expanding access to ownership and enabling more people to participate inmarkets. This technology has the potential to create a new economic paradigm that is more transparent and egalitarian.
It is this new paradigm that we are working every day to help engineer. We have developed several world class educational
resources that are free and publicly available to all.

Transforming the global financial system, Galaxy Solstice Summit
In 2023, Galaxy brought together over 80 thought leaders across traditional finance and digital assets at our New York headquarters
for our inaugural Galaxy Solstice Summit. Over the course of a day, attendees shared insights into how digital assets andblockchain technology will transform the global financial system and reshape the global economy.
Conviction in digital assets and the pivotal role blockchain technology will play in finance and beyond was on full display. Througha series of debates, participants engaged in lively discussions around tokenizing real-world assets and what’s still needed to bring
the world on chain, the state of bitcoin mining, custody of digital assets, the future of gaming and Web3, and the evolution of crypto’s
market structure beyond just CeFi and DeFi.
Attendees also got to hear Galaxy Founder and CEO Mike Novogratz’s latest view of the macro landscape and the impact it’s havingon digital assets. Lastly, attendees converged on the issue of regulation in the U.S. and beyond. While the regulatory landscaperemains challenging and uneven, attendees agreed on the need for thoughtful rules that protect consumers and investors while
promoting innovation through blockchain-enabled services and solutions.

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Appendix

Investing in Texas at Helios
In December 2022, Galaxy announced its acquisition of the Helios bitcoin mining facility and its related operations
from Argo Blockchain. While Galaxy utilizes Helios’ capacity to mine Bitcoin, Galaxy is also passionate about ourcommitment to support our newfound community in the town of Spur, located in Dickens County, Texas.
Bringing skilled and high-paying jobs to America’s heartland: Galaxy is one of Dickens County’s
top employers, employing over 40 residents and with plans to expand as we continue to build out the
Helios facility.
Collaborating with and supporting growth: Galaxy sees itself as an integral part of the local community.
Through Galaxy’s newly formed Community Committee, we work closely with local leaders to educate, enrich,and serve the communities in which we operate. We regularly conduct educational tours of our Helios facility,
helping the community understand bitcoin mining and the broader digital asset ecosystem. We also created a local
internship program, which we successfully launched in the summer of 2023, to enable high school students to gethands-on experience at Helios, opening the door to future employment opportunities. We also work closely with
first responders in the event of an emergency by providing access to the Helios facility and its resources, and, in
2023, in the wake of the tornado in Matador, TX, we supplied resources, equipment and our team members in therecovery efforts.
Building infrastructure for a flourishing community: As we scale, so does our commitment to the community.
As part of our commitment to Helios and Dickens County, we’re in the process of refurbishing the public swimming
pool in Spur, Texas, giving residents access to a local pool for the first time in over a decade. We have also
committed to upgrading the county road that leads to Helios, promoting further economic activity within Dickens
County.

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Appendix

Galaxy ESG Report 2022

A sample of our most viewed episodes

Galaxy Brains Weekly Podcast
Galaxy Brains is a weekly podcast providing insights and analysis on trends andevents across the digital asset ecosystem and is hosted by Alex Thorn, Galaxy’s Headof Firmwide Research. Every week Alex is joined by Beimnet Abebe from Galaxy’s
trading team to talk markets and is frequently joined by an industry expert from
Galaxy’s network. Galaxy Brains dives into the major developments and trending
topics throughout digital assets to keep you entertained and up to dateon the latest happenings.

001 - July 22, 2022005 - Mar 17, 2023

Featuring Nic Carter from Castle Island Ventures.

Featuring Omid Malekan, professor at Colombia Business
School.

002 - Aug 05, 2022

006 - May 05, 2023

Featuring Alex Gladstein, Chief Strategy Officer
at the Human Rights Foundation.

Featuring Dan Held, longtime Bitcoin advocate.

003 - Feb 03, 2023

007 - June 02, 2023

Featuring Casey Rodarmor, Bitcoin dev, host of SF BitDevs,
and creator of Ordinals.

Featuring Nathaniel Whittemore, host of The Breakdown,
a popular crypto podcast.

004 - Feb 17, 2023

008 - June 09, 2023

The Future of Blockchains

Bitcoin Activism

Ordinals & Inscriptions (Bitcoin NFTs)

Alex Thorn
Head of Firmwide Research

Biemnet Abebe
Director of Principal Trading

The Galaxy Brains podcast is available on Amazon, Apple, Google Podcasts, Spotify, Stitcher, or YouTube.

Financial Inclusion and Education

Stablecoins & Regulation
Featuring Austin Campbell, current adjunct professor atColombia Business School and former head of portfolio
management at Paxos.

Trust & Finance

Bitcoin History & Culture

Shifting Crypto Narratives

American Crypto Policy
Featuring Ryan Selkis, CEO of Messari and Chairman of
Digital Freedom Alliance.

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40

Galaxy experts focus on the digital asset developments that matterin first annual Watch this Space Report
At Galaxy, we understand that assessing the digital asset market can be complex. That’s
why we’re committed to providing you with the latest insights on digital assets, and thisyear we were excited to share our first annual Watch this Space research piece.
Our research team examined the latest developments in the digital asset ecosystem,
including what's next for Bitcoin and Ethereum, the future of decentralized finance, anddevelopments in the Web3 space. We've also taken a dive into the regulatory landscape,analyzing the latest guidance from global regulators and what it means for investors.

001 · Bitcoin

005 · Venture Investing

The recent global banking crisis puts thefocus back on Bitcoin

Funds raised, capital deployed-driving
innovation in a bear market

002 · Ethereum006 · Bitcoin Mining

003 · DeFi

007 · Regulation

Lending trading innovations drive adoption
and the on-chain experience

US Regulatory environment gets more

Becoming the “world computer” able tosupport decentralized applications

004 · Stablecoins
Extending the dollars reach around the world

Financial Inclusion and Education

The heartbeat of the world’s leading
decentralized money

challenging while the world opens up

Trust and Transparency — Promoting the responsible institutional
adoption of digital assets since 2018
Trust within crypto hit all-time lows in 2022. We witnessed a denouncement of crypto’s
centralized firms, while some held up decentralized finance as the only viable way to savethe industry. Galaxy took the stance that both decentralized and centralized firms must
work together if we ever want to realize crypto’s potential as a decentralized replacement
for the global financial system. While we continue to seek coexistence—we emphasize theimportance of change and the radical commitment to transparency and offer access to all
relevant information on galaxy.com/trust-and-transparency.

Don’t just trust. Verify.

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Appendix

Human Rights
We have a zero-tolerance approach to human rights violations. Galaxy’s UK Modern Slavery Act
Transparency Statement, along with our Global Code of Conduct, Code of Ethics and Business Conduct,and our Employee Handbook reflect our commitment to conducting business in accordance with the highest
standards of ethical business conduct and integrity.
All our employees are required to complete compliance training at the time of hire and on an annual basis
thereafter. In addition, when hired, employees are required to attest to relevant policies and procedures,
including but not limited to, the Global Code of Conduct. These policies are also subsequently acknowledgedby employees on a quarterly basis thereafter.
Galaxy conducts business on a global scale, and, through our activities, we interact with a number of different
parties. Galaxy does not tolerate slavery, forced labor, or human trafficking in any form and is committed
to preventing slavery, forced labor, and human trafficking in all aspects of our business. Third parties must
not participate in or benefit from any form of slavery, forced labor, or human trafficking. Third parties are
expected to fully comply with all applicable slavery, forced labor and human trafficking laws. Galaxy will notknowingly work with third parties who engage in these practices. We consider the risk of modern slavery or
human trafficking existing within our business or our supply chains to be low.

Human Rights

Galaxy ESG Report 2022

41

04
Overview

GovernanceSocialEnvironmental

Appendix

Environmental
Environmental
001

Bitcoin Mining

001

003

Bitcoin Mining Waste Reduction

and Recycling

002

Galaxy's Carbon Footprint

002

003

Waste Reduction and Recycling

Galaxy's Carbon Footprint

Galaxy ESG Report 2022

0442

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Appendix

Galaxy ESG Report 2022

43

Bitcoin Mining
Galaxy launched its Mining business in 2021, with a focus on providing financial services to
Bitcoin miners including trade and risk management solutions, asset-backed lending, equity
investments, and M&A advisory services. Over the past two years, the business has grownin scale and capabilities, notably following our acquisition of the Helios Bitcoin mining facility
in December 2022. The acquisition significantly increased our proprietary and hosting
Bitcoin mining operations and shifted the geographic location and sustainable energy mixof our mining activities. Importantly, the Helios facility is located in West Texas, where there
is high marginal wind production and solar farms are currently being built. While these are
multi-year projects, we are encouraged by the production of new renewable energy sourcesin the region, which offer Galaxy a path to increase its sustainable energy mix.1
Galaxy is a founding member of the Bitcoin Mining Council (BMC), a voluntary andopen forum of Bitcoin miners committed to the network and its core principles. The BMC
promotes transparency, shares best practices, and educates the public on the benefits of
Bitcoin and Bitcoin mining. The BMC believes that transparency around energy usage formining is important and agree to voluntarily share their energy mix and total hashrate forresearch and educational purposes.

Galaxy Mining remains committed to achieving its long-term goal of
expanding its use of sustainable energy2, which we believe will help
drive down our marginal cost of production, while also indirectly
helping decarbonize our Scope 2 greenhouse gas (GHG) emissions.
Galaxy formed a dedicated Environmental Sub-Committee of our ESG Steering Committee tohelp the Company manage our environmental sustainability strategy and execute on ourcommitment to expand our use of sustainable energy. The Environmental Sub-Committee
maintains representation from Galaxy’s Mining, Investor Relations, and Global Markets teams.

[1] "Sustainable Energy Mix” is defined by the BMC as energy sourced from hydro, wind, solar, nuclear and geothermal energy sources.
[2] The BMCs "Sustainable Energy" definition is based on the principles brought forward by the U.S. Energy Information Administration (EIA) Net Zero by 2050 Report. The definition was updated in the fourth quarter 2022 to exclude carbon-based energy with net carbon credits.

Bitcoin Mining

Overview

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Appendix

GalaxyESG Report Report
2022 44
GalaxySustainability

Research Report

Bitcoin Mining’s Environmental Impacts
MIT's Center for Energy and Environmental Policy Research released a report on the Climate Impacts of
Bitcoin Mining in the U.S., casting a spotlight on the industry's potential benefits. The paper underscores Bitcoin
mining's significant role in supporting the Electric Reliability Council of Texas' (ERCOT) curtailment program
for large flexible loads (LFL)1 - a program implemented formally in 2022. The role of Bitcoin miners in managing
energy consumption during unexpected demand surges emerges as a critical contribution to maintaining
energy grid stability. A notable instance of this occurred on December 24, 2022, when Winter Storm Elliott
swept across North America, causing Bitcoin miners to curtail approximately 100 exahash per second (EH/s) at
the peak of their curtailment activity. This amounted to 38% of the total Bitcoin network hashrate for that day,showcasing their role as dependable flexible load sources for energy grids within the U.S.
Leading up to and during Winter Storm Elliott, grid operators across the nation (ERCOT, SPP, MISO, PJM,
TVA, and others) were concerned with their ability to reliably operate their respective grids due to theprojected extreme cold weather and the effect it would have on available power generation and transmission
infrastructure.
The extreme cold weather conditions were projected to result in power supply shortages, which occur when
grid operators are unable to reliably match electrical system demand with available generation supply. These
shortages, if severe enough, leave the grid operators no choice but to implement controlled, rolling blackouts
to protect critical grid infrastructure at the expense of families and businesses left stranded without electrical
power for hours or sometimes days.
While some large industrial consumers of electricity (e.g., steel mills, refineries, and traditional datacenters)
have always been able to reduce consumption with some notice, Bitcoin miners are a unique buyer of electricity
with the ability to instantly modify their power consumption with no critical disruption to the underlying
business. This allows Bitcoin miners to consume power during low-risk hours of grid operations and shut down
preemptively or rapidly when called upon during high-risk hours of grid operations.
[1] Electric Reliability Council of Texas’s (ERCOT) Large Flexible Load Task Force (LFLTF) defines large flexible loads (LFL) as stand-alone loads
greater than 75 MW or co-located loads greater than 20MW that can strategically shift electricity demand and restore balance to thegrid during peak events.

Research Report

By voluntarily curtailing Bitcoin mining operations prior to Winter Storm Elliott, Bitcoin miners reduced theirconsumption of power to provide grid operators with greater operating reserve margins, making it easier forthem to reliably operate the electricity grid during those high-risk periods and keep power flowing to families
and businesses during extreme weather conditions.
The report focuses on the climate advantages potentially offered by Bitcoin mining. One significant benefit,
as indicated by MIT researchers, is the capacity of Bitcoin mining to reduce global methane emissions, a
byproduct of natural gas extraction often deemed uneconomical for oil producers to use or transport due tocostly and insufficient infrastructure. As a result, this gas is often vented or flared on-site, releasing detrimental
methane into the atmosphere. However, the report proposes that if this gas were to be combusted in electricalgenerators, the Bitcoin mining sector could reduce equivalent carbon dioxide (CO2) emissions by up to 25%,
with potential reductions of up to 63% if accounting for flare outages.
Another positive environmental impact put forward by the researchers is Bitcoin mining's potential utilizationof abandoned oil and gas wells. The report states that 59% of the 3.7 million abandoned oil and gas wells in
the U.S are left unplugged, emitting 6.9 million tons of CO2 annually. By establishing operations near theseorphaned wells, Bitcoin miners could subsidize the cost of sealing these wells, harnessing the otherwise
wasted energy to generate electricity. This strategy could generate revenue to fund well-sealing initiatives,consequently mitigating climate impact. Given its location-agnostic requirements, Bitcoin mining is wellpositioned to leverage flared gas and abandoned oil and gas wells, marking a transformative moment in theindustry's trajectory towards sustainable operations.
The report also highlights the increasing incorporation of renewable energy into Bitcoin mining activities,
which suggests that the industry could play a pivotal role in bolstering the renewable energy market by driving
up demand. Concrete evidence of this trend is the landmark partnership between Tesla, Block, andBlockstream, who collaborated to establish a 3.5 megawatt (MW) off-grid, solar-powered Bitcoin mining
operation in Texas. MIT researchers state that through creating partnerships like these, investments in new
renewable energy infrastructure can become more economically feasible.

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Galaxy ESG Report 2022

45

Galaxy's Carbon Footprint
We again engaged Apex Group to conduct Galaxy’s greenhouse gas (GHG) assessment covering Scope,
1, 2, and 3 emissions. Apex Group follows the GHG Protocol methodology for calculating emissions anduses nationally recognized emissions factors, published by regulated authorities, to ensure the robustnessof calculations. Where necessary, Apex Group may build bespoke models for unique emissions sources,
grounded in best-in-class data and scientific approaches. Apex Group conducted this GHG assessment andverification of data independently, as a third-party, with no conflicts of interest with Galaxy. Galaxy’s Scope 1, 2,
and 3 GHG emissions were approximately 31,950 metric tonnes of carbon dioxide equivalent (mtCO2e).
Apex Group's assurance letter is located in the Appendix.
2022 was a transformational year for Galaxy, particularly for our mining business. We saw a fundamental
change to our mining operations with the purchase of Helios, which significantly increased our proprietary
Bitcoin mining scale and unlocked a new revenue stream for Galaxy as a Bitcoin mining hosting provider.
The Helios acquisition on December 28, 2022 included the purchase of machines and electrical infrastructurefrom Argo Blockchain. In 2022, our annual GHG emissions increased, driven primarily by spend-based
emissions calculations attributed to supply chain expenditure associated with this acquisition. Given this,
our annual increase in emissions was expected and provides us with a comprehensive baseline to measureagainst as we strive for operational efficiency and work to reduce our carbon footprint.
To better understand our impact, we also analyzed our total carbon footprint excluding the supply chain
expenditure from the Helios acquisition. Mining continues to be our largest contributor to emissions
consumptions which is the result of the electricity we utilize to help secure the Bitcoin network, support the
infrastructure of the industry, and provide a service to the network by facilitating and processing transactions.
We will continue to disclose our GHG emissions on an annual basis and are committed to increasingtransparency around our impact.

Galaxy's Carbon Footprint

Galaxy is committed to managing and improving our environmental and carbon footprint byintegrating sustainable practices and increasing the use of sustainable energy across ourbusinesses.

Total Carbon Footprint1
Transmission & Distribution Network Loss:0%

Waste Generation:

0%

Purchased Goods & Services:51%

Employee Commute & Work From Home:

0%Business Travel:

2%

Electricity Consumption2:

47%(includes Hardware, Servers, Software, Victuals, and Machinery & Electrical
Infrastructure associated with the Helios Mining acquisition)

31,950
mtCO2e(includes Electricity & Fuel Consumption)(includes Commercial & Private Air Travel, Car Rental & Ride Share, Hotel)(includes BTC Mining Electricity Consumption and Electricity Consumption
across Galaxy's Offices)

Scope 1 3

0 mtCO2e

Scope 2 4

15,042.40 mtCO2e

Scope 3 5

16,907.40 mtCO2e

Emissions Intensity

81.9 mtCO2e/Employee6[1] As of 12/31/2022. Some estimations were used to cover electricity consumption of coworking spaces outside of the United States.
Financed emissions and water consumption were not covered in this assessment.
[2] Derived from Galaxy's Bitcoin mining energy mix across our onshore third-party facility operator, as provided. As of 12/31/2022, unaudited.
[3] Scope 1: Direct emissions from owned or controlled sources.
[4] Scope 2: Indirect emissions from the generation of purchased energy.
[5] Scope 3: All other indirect emissions sources including supply chain spend, employee commute, work from home and business travel.
[6] Emissions Intensity/Employee = total carbon footprint/total number of employees.

Overview

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Appendix

Waste Reduction
and Recycling
Our headquarters in New York City holds a LEED Gold Certification and WELL Health
Safety Ratings and is equipped with EnergyStar and WaterSense fixtures that help
minimize our energy and water intensity. In 2023, Galaxy took a significant step forwardin our commitment to sustainability by implementing a composting program at our New
York office. Recognizing the importance of reducing our environmental footprint, we
introduced this initiative to divert organic waste away from landfills, thereby minimizing
greenhouse gas emissions. Through dedicated composting bins placed in our officecafeteria, employees are empowered to responsibly dispose of organic materials
including food scraps and biodegradable items. By adopting this program, we not only
reduced our contribution to landfill waste but also enriched the soil and supported local
agricultural efforts through the conversion of composted materials.
Across our other locations we maintain our commitment to reducing waste andrecycling. Our team in Chicago recently moved to a new office that holds a LEEDGold Certification and our Hong Kong office holds a LEED Silver Certification andachieved an excellent rating in accordance with the Hong Kong Building Environmental
Assessment Method. Additionally, we have established paper, plastic, and electronic
waste reduction strategies, alongside our wide-scale recycling efforts, to better manage
natural resources.

Waste Reduction and Recycling

Galaxy ESG Report 2022

46

Waste Diversion1
Organics

2%

Landfill
Diversion
Rate

57%

Landfill
Diversion
Rate

Recycling

55%

Including W-T-E

100%

Waste-to-Energy (W-T-E)2

43%[1] As of 12/31/2022, unaudited. Landfill diversion rate for New York office. Waste diversion rate calculated by percentage of building space 		
occupied by Galaxy.
[2] As defined by the U.S. Environmental Protection Agency (EPA), Waste-to-Energy is the conversion of non-recyclable waste materials into
usable heat, electricity, or fuel through a variety of processes, including combustion, gasification, pyrolization, anaerobic digestion andlandfill gas recovery.

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47

Galaxy Earth Week
For the second consecutive year, Galaxy volunteers engaged in a gardening and horticultural
maintenance project along Hudson River Park’s Tribeca Boardwalk, in celebration of Earth Day.
This initiative not only strengthened our commitment to environmental stewardship, but also
reinforced our ties to the Park and its neighboring community, located next to our New York
City headquarters. Through this immersive team-building experience, 30 Galaxy volunteers
gained valuable insights into the Park's distinctive urban ecology while dedicating their timeand effort to collecting, composting and redistributing five cubic yards of debris and preparing
one of the primary grassland beds for the upcoming spring planting season. As a testament toour dedication, Galaxy made a generous donation of $5,000 to the Hudson River Park Friends
organization, formerly led by our Chairman and CEO, Mike Novogratz.
In 2022, Galaxy introduced Bevi machines in our New York office, marking an additional stride
towards our commitment to sustainability. By offering a wide range of flavored and sparklingwater options, Bevi reduces the need for single-use plastic bottles and minimizes transportation
emissions associated with beverage delivery. The introduction of Bevi machines has enhanced our
workplace well-being while we actively work to reduce our carbon footprint and minimize waste.
In honor of Earth Day, we invited Bevi CEO Sean Grundy to our NY office for a conversation onbuilding a mission-driven company that champions sustainable practices and a greener future.

Galaxy Earth Week

05

Appendix
Appendix
001

001

05

003

Supporting the United
Task ForceonSustainable
Climate- Development Goals (SDGs)
Supporting the United
Nations
Nations Sustainable
Related Financial
Development Goals002(SDGs)
Disclosures (TCFD) Index

Global Reporting Initiative (GRI) and Sustainable Accounting Standards Board (SASB) Index

002

004
Task Force on Climate-Related
Financial Disclosures (TCFD) Index
003

Global Reporting Initiative
Apex Group Assurance
004(GRI) and Sustainable
Letter Letter
Apex Group Assurance
Accounting Standards
Board (SASB) Index005
About the Artist and Her Process005

About the Artist and
Her Process

Overview

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Appendix

Supporting the United
Nations Sustainable
Development Goals(SDGs)The United Nations Sustainable Development Goals (SDGs) are a set of 17
global goals adopted by all United Nations Member States in 2015, designed
to further peace and prosperity. We believe the digital asset revolution has thepotential to drive the SDGs forward. Blockchain and digital assets are alreadyexpanding access to ownership and enabling more people to participate
in markets. This technology has the potential to create a new economic
paradigm that is more transparent and egalitarian. It is this new paradigm
that we are working every day to help engineer. Initiatives across Galaxy help
advance 9 of the 17 goals, each of which are highlighted in black on the right.

Galaxy ESG Report 2022

Galaxy Advances 9 of 17 Goals
1

2

NO
HUNGERGOOD
HEALTH

67

8NO
POVERTY4

QUALITYEDUCATION

9

CLEAN WATER
AND SANITATIONRENEWABLE
ENERGYGOOD JOBS
AND ECONOMICGROWTH

INDUSTRY,INNOVATION AND
INFRASTRUCTURE

11

12

13

14

16

17

SUSTAINABLE
CITIES ANDCOMMUNITIESPEACE ANDJUSTICE

Supporting the United Nations Sustainable Development Goals (SDGs)

3

RESPONSIBLE
CONSUMPTIONPARTNERSHIPSFOR THE GOALSCLIMATEACTION

LIFE BELOW
WATER

5

GENDEREQUALITY

10

REDUCEDINEQUALITY

15

LIFE ON LAND

49

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Galaxy ESG Report 2022

Supporting the United Nations Sustainable Development Goals (SDGs)
GOOD
HEALTH

Goal 3
Ensure healthy lives and promote
well-being for all at all ages

Target 3.4
Launched a mental health focused
employee resource group, with the goal of
fostering mental health and neurodiversity
within our company. All employees haveaccess to coaching and mental healthsupport 24/7 via text and video sessions

Target 3.8
Introduced a Health Care Travel andLodging Assistance Program for U.S.
employees, offering reimbursement for
eligible transportation and lodging
expenses incurred for in-network healthservices covered by the medical plan
where the plan member cannot access aprovider within a 100-mile radiusSupporting the United Nations Sustainable Development Goals (SDGs)

QUALITYEDUCATION

Goal 4
Ensure inclusive and equitable quality education and promote lifelong
learning opportunities for all

Target 4.4

Continued producing our Galaxy Brains
podcast to provide free insights andanalysis on trends and events taking placeacross the digital asset ecosystem
Launched the Galaxy Academy to promoteinternal education on topics most relevant
to our company and industry
Established a Community Committee
through which we regularly conducted toursof our Helios bitcoin mining facility, helping
the community understand bitcoin mining
and the digital asset ecosystem

GENDEREQUALITY

Goal 5
Achieve gender equality and empower
women and girls

CLEAN
WATER ANDSANITATION

Goal 6
Ensure availability and sustainable
management of water andsanitation for all

Target 5.5

Target 6.3

Expanded scope of the Women at Galaxy
Employee Resource Group (ERG) to amplify
the voices of women across the company,
serving as a central think tank to drive
equality, make an impact, and provide asense of belonging

Installed Bevi machines in the New York
office, supporting the mission to reduce theneed for single-use plastic water bottles
and minimize transportation emissions
associated with beverage delivery

50

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Galaxy ESG Report 2022

Supporting the United Nations Sustainable Development Goals (SDGs)
RENEWABLE
ENERGY

Goal 7
Ensure access toaffordable, reliable,
sustainable, andmodern energy for all

Target 7.2
Galaxy’s Mining business remains
committed to achieving its longterm goal of expanding its use ofsustainable energy

Target 7.3
Achieved LEED Gold Certification
at New York and Chicago officelocations and LEED Silver
Certification at Hong Kong officelocation
Held WELL Health Safety Ratings
at New York office location

GOOD JOBSANDECONOMICGROWTH

Goal 8Promote sustained,
inclusive and sustainableeconomic growth, full andproductive employment
and decent work for all

Target 8.3

Brought skilled and high paying
jobs to Dickens County, Texas,
employing nearly 40 residents andwith plans to expand through theacquisition of the Helios bitcoin
mining facility

Target 8.7

Committed to a zero-tolerance
approach to human rights
violations via UK Modern Slavery
Act Transparency Statement

Target 8.10

Expanded access to banking andfinancial services via investments
in Acorns and Gyroscope, among
othersSupporting the United Nations Sustainable Development Goals (SDGs)

INDUSTRY,INNOVATION
AND INFRASTRUCTURE

Goal 9Build resilient infrastructure, promote inclusive
and sustainableindustrialization andfoster innovation

Target 9.1
Helped stabilize local power gridin West Texas through Helios via
flexible consumption of electricity
based on grid conditions andconsumer demand

REDUCEDINEQUALITY

Goal 10
Reduce inequality within
and among countries

Target 10.2

Donated nearly $60,000 to 501(c)(3) organizations in partnershipwith Coinbase and Figment.
The group selected The Navy
SEAL Foundation, a nonprofit
organization committed to offeringvital support to warriors, veterans,
and families associated with Naval
Special Warfare
Donated over 100 gifts and 114
backpacks to families throughWIN, the largest provider of shelterand supportive housing for New
York City’s homeless families,
especially women and children

RESPONSIBLE
CONSUMPTION

Goal 12
Ensure sustainableconsumption andproduction patterns

Target 12.5
Achieved 57% landfill diversion
rate (100% including waste-toenergy) in New York office location
Maintained paper, plastic, andelectronic waste reduction
strategies, alongside our widescale recycling efforts, to better
manage natural resources
Implemented composting
program in New York officelocationTarget 12.6
Integrated sustainability
information into reporting alignedwith GRI, SASB, TCFD, and SDGs

51

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Galaxy ESG Report 2022

Global Reporting Initiative (GRI) and Sustainable
Accounting Standards Board (SASB) Index
This report was prepared with reference to the Global Reporting Initiative (GRI) standards and the Value Reporting Foundation’s Sustainability Accounting Standards Board (SASB) standards for the
Financial Sector Asset Management & Custody Activities (FN-AC) and Investment Banking & Brokerage (FN-IB) industries.

GRI and SASB Index

GRI

SASB

GRI/SASB Description

FY 2022 Disclosure Location

2-1–

Organizational details

About Galaxy, Page 5
Galaxy Digital Holdings Ltd. Annual Information Form 2022, Page 10-12

2-2–

Entities included in the organization’ssustainability reporting

About Galaxy, Page 5

2-3–

Reporting period, frequency andcontact point

This report was published on 10/11/2023 and covers calendar year 2022. Galaxy's
ESG reporting follows an annual cycle. For any related questions, please contact
our Investor Relations team at investor.relations@galaxy.com

2-5–

External assurance

Apex Group Assurance Letter, Page 65-72

2-6–

Activities, value chain andother business relationships

About Galaxy, Page 5

Global Reporting Initiative (GRI) and Sustainable Accounting Standards Board (SASB) Index

52

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Galaxy ESG Report 2022

GRI and SASB Index (Continued)

GRI

SASB

GRI/SASB Description

FY 2022 Disclosure Location

2-7

FN-IB-330a.1
FN-AC-330a.1

Employees

Employee Development, Engagement, and Retention, Page 27-28
Employee Diversity, Equity, Inclusion, and Belonging, Page 29-36

2-9–

Governance structure and composition

Corporate Governance, Page 12-16
ESG Program Oversight, Page 17-18

2-10

–

Nomination and selection of thehighest governance body

Corporate Governance, Page 12-16
Board of Directors Mandate

2-11

–

Chair of the highest governance body

Corporate Governance, Page 12-16

2-12

–

Role of the highest governance body inoverseeing management of impacts

ESG Program Oversight, Page 17-18

2-13

–

Delegation of responsibility for managing
impacts

ESG Program Oversight, Page 17-18

2-14

–

Role of the highest governance body insustainability reporting

Our First ESG Materiality Assessment, Page 9-10
ESG Program Oversight, Page 17-18

2-15

FN-IB-510b.4

Conflict of interest

Business Ethics and Compliance, Page 19-20
Global Code of Conduct

2-17

–

Collective knowledge of the highest
governance body

Corporate Governance, Page 12-16
ESG Program Oversight, Page 17-18

2-21

–

Annual total compensation ratio

Corporate Governance, Page 14

Global Reporting Initiative (GRI) and Sustainable Accounting Standards Board (SASB) Index

53

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Galaxy ESG Report 2022

GRI and SASB Index (Continued)

GRI

SASB

GRI/SASB Description

FY 2022 Disclosure Location

2-22

–

Statement on sustainable
development strategy

Message From Our Founder & CEO, Page 4

2-23

FN-IB-510b.4

Policy commitments

Business Ethics and Compliance, Page 19-20
Global Code of Conduct
Whistleblowing Policy
Insider Trading Policy
Human Rights, Page 412022 UK Modern Slavery Act Transparency Statement

2-24

–

Embedding policy commitments

Business Ethics and Compliance, Page 20
Public Policy Practices and Government Engagement, Page 25

2-26

FN-IB-510a.2
FN-AC-510a.2

Mechanisms for seeking advice andraising concerns

Business Ethics and Compliance, Page 19-20
Whistleblowing Policy

2-28

–

Membership associations

Bitcoin Mining, Page 43

2-29

–

Approach to stakeholder engagement

Our First ESG Materiality Assessment, Page 9

3-1–

Process to determine material topics

Our First ESG Materiality Assessment, Page 9

3-2–

List of material topics

Our First ESG Materiality Assessment, Page 10

Global Reporting Initiative (GRI) and Sustainable Accounting Standards Board (SASB) Index

54

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Galaxy ESG Report 2022

GRI and SASB Index (Continued)

GRI

SASB

GRI/SASB Description

FY 2022 Disclosure Location

3-3–Management of material topics

Employee Diversity, Equity, Inclusion, and Belonging, Pages 29-36
Financial Inclusion and Education, Pages 37-40
Human Rights, Page 41
Bitcoin Mining’s Environmental Benefits, Page 44
Galaxy's Carbon Footprint, Page 45
Waste Reduction and Recycling, Page 46

201-1

–

Direct economic value generated
and distributed

Galaxy Announces 2022 Financial Results-

FN-AC-000.A

AUM

Galaxy Asset Management: December 2022 Month End AUM

201-2

–

Financial implications and other risks andopportunities due to climate change

Task Force on Climate-Related Financial Disclosures (TCFD) Index,
Page 57-64

205-2

–

Communication and training about anticorruption policies and procedures

Business Ethics and Compliance, Page 19-20
Global Code of Conduct

305-1

–

Direct (Scope 1) GHG emissions

Galaxy's Carbon Footprint, Page 45

305-2

–

Energy indirect (Scope 2) GHG emissions

Galaxy's Carbon Footprint, Page 45

305-3

–

Other indirect (Scope 3) GHG emissions

Galaxy's Carbon Footprint, Page 45

305-4

–

GHG emissions intensity

Galaxy's Carbon Footprint, Page 45

306-3

–

Waste generated

Waste Reduction and Recycling, Page 46

Global Reporting Initiative (GRI) and Sustainable Accounting Standards Board (SASB) Index

55

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Galaxy ESG Report 2022

GRI and SASB Index (Continued)

GRI

SASB

GRI/SASB Description

FY 2022 Disclosure Location

306-4

–

Waste diverted from disposal

Waste Reduction and Recycling, Page 46

306-5

–

Waste directed to disposal

Waste Reduction and Recycling, Page 46

401-2

–

Benefits provided to full-time employees thatare not provided to temporary or part-time
employees

Employee Benefits, Page 27

401-3

–

Parental leave

Employee Benefits, Page 27

403-6

–

Promotion of worker health

Employee Benefits, Page 27

404-2

–

Programs for upgrading employee skills andtransition assistance programs

Employee Development, Engagement, and Retention, Page 27-28

405-1

FN-IB-330a.1
FN-AC-330a.1

Diversity of governance bodies and employees

Corporate Governance, Page 15-16
Employee Diversity, Equity, Inclusion, and Belonging, Page 29

408-1

–

Operations and suppliers at significant risk forincidents of child labor

Human Rights, Page 412022 UK Modern Slavery Act Transparency Statement

409-1

–

Operations and suppliers at significant risk
for incidents of forced or compulsory labor

Human Rights, Page 412022 UK Modern Slavery Act Transparency Statement

Global Reporting Initiative (GRI) and Sustainable Accounting Standards Board (SASB) Index

56

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57

Task Force on Climate-Related
Financial Disclosures (TCFD) Index
As part of Galaxy’s inaugural Sustainability Report, we have detailed our alignment to the Task Force on Climate-Related Financial Disclosures (TCFD). TCFD recommendations are organized into fourpillars that allow for a consistent, standardized approach to analyzing climate-related risks and opportunities: (1) Governance, (2) Strategy, (3) Risk Management, and (4) Metrics and Targets. Galaxy’s TCFD
response represents our efforts towards implementing the recommendations of the TCFD. More in-depth information can be found in our full 2022 Sustainability Report.

Governance

Recommended Disclosure

GLXY Response

Describe the board’s oversight of climaterelated risks and opportunities

Galaxy’s Board of Directors and its Compensation, Corporate Governance, and Nominating (CGN) Committee areresponsible for overseeing our sustainability framework, strategy, and objectives. The Board of Directors and its CGN
Committee are informed on key ESG program initiatives and updates through Board of Director meetings and annual reports
from the ESG Steering Committee. Updates to the Board of Directors and its CGN Committee may include climate-relatedrisks and opportunities that may materially affect Galaxy.

Describe management’s role in assessing
and managing climate-related risks andopportunities

Our ESG Steering Committee is comprised of senior executives across business lines and regions and is charged withensuring the effective implementation and oversight of the Company’s ESG strategy at the business level. Our ESG strategy
is developed and executed by Galaxy’s Investor Relations team, who regularly meet to review and evolve the Company’s
ESG strategy for the benefit for all of our stakeholders, which may include climate-related risks and opportunities that may
materially affect Galaxy.

Task Force on Climate-Related Financial Disclosures (TCFD) Index

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Task Force on Climate-Related Financial Disclosures (TCFD) Index
As a technology-driven financial services and investment management firm in the digital asset ecosystem, climate-related risks are unlikely to substantially impact Galaxy’s diverse business lines andoperations. However, we understand climate-related risks may lead to potential shifts in the operations of our business lines. TCFD identifies two categories of risks, transition risks and physical risks.
Transition risks are those associated with transitioning to a lower-carbon economy, particularly the policy, legal, technological, and market changes that may require mitigation and adaptation. Physicalrisks can be event-driven (acute) or longer-term shifts in climate patterns (chronic).
We consider each risk and opportunity across three time horizons: short-term (ST; 0-3 years), medium-term (MT; 3-5 years), and long-term (LT; 5+ years). The table below exhibits Galaxy’s identified
climate-related risks and opportunities and discusses their potential impact based on TCFD guidelines.

Strategy – Climate Related Risks

Potential Risk

Potential Impact on GLXY

TRANSITION RISK: POLICY & LEGAL
Increased pricing of GHG emissions

MT-LT

Introduction of mandatory carbon pricing may result in increased operating and/or compliance costs.

Enhanced emissions-reporting obligations

ST-MT

Introduction of new or enhanced climate-related reporting obligations may result in increased operating
and/or compliance costs.

Mandates on and regulation of existingproducts and services

MT-LT

Introduction of climate-related mandates on and regulation of digital assets may result in increased operating and/or
compliance costs and reduced demand for digital asset products and services, investor appetite, and capital availability.

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Strategy – Climate Related Risks (Continued)

Potential Risk

Potential Impact on GLXY

TRANSITION RISK: MARKET
Uncertainty in market signals

ST-MT

Reference Galaxy Digital Holdings LTD. Annual Information Form 2022, Risk Factors, Page 85 - 86

Increased cost of raw materials

MT-LT

Increased cost of raw materials may affect energy and supply-chain costs. This may result in increased operating costs.
Reference Galaxy Digital Holdings LTD. Annual Information Form 2022, Risk Factors, Page 116, 118 - 119

TRANSITION RISK: REPUTATION
Shifts in client preferences
Stigmatization of sector
Increased stakeholder concern

ST

Reference Galaxy Digital Holdings LTD. Annual Information Form 2022, Risk Factors, Page 92

MT-LT

Reference Galaxy Digital Holdings LTD. Annual Information Form 2022, Risk Factors, Page 103

PHYSICAL RISK: ACUTE & CHRONIC
Increased severity of extreme weather events
Rising mean temperatures
Rising sea levels

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Strategy – Climate Related Opportunities

Potential Opportunity

Potential Impact on GLXYOPPORTUNITIES: RESOURCE EFFICIENCYResource efficiency

ST-MT

Enhancing our operational efficiency presents an opportunity to decarbonize.
Our New York office location hosts the majority of our workforce, and holds a LEED Gold Certification, WELL Health Safety
Ratings, and is equipped with EnergyStar and WaterSense fixtures that help minimize our energy and water intensity. Our
team in Chicago recently moved to a new office that also holds a LEED Gold Certification, and our Hong Kong office holds
a LEED Silver Certification and achieved an excellent rating in accordance with the Hong Kong Building Environmental
Assessment Method. Additionally, we have established paper, plastic, and electronic waste reduction strategies, alongside
our wide-scale recycling efforts and composting program in our New York office, to better manage natural resources.

OPPORTUNITIES: ENERGY SOURCE
Use of lower-emission sources of energy

ST-MT

Use of lower-emission sources of energy present an opportunity to decarbonize and reduce risk exposure to the potential
introduction of carbon pricing. This may reduce operating costs and increase revenue, capital availability, and reputation.
Galaxy’s Mining business remains committed to achieving its long-term goal of expanding its use of sustainable energy,
which we believe will help drive down our marginal cost of production, while also indirectly helping decarbonize our Scope 2
GHG emissions.

Use of new technologies

MT

Blockchain technology and digital assets may play a role in the transition to a low carbon economy.

Shift toward decentralized energy generation

MT-LT

Bitcoin miners may have the potential to enhance the shift toward decentralized energy generation by co-locating nearrenewable energy producers and acting as an off-taker for excess energy production. This may lead to a de-stigmatization of
the asset class, increased capital availability, and enhanced reputation.

Task Force on Climate-Related Financial Disclosures (TCFD) Index

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Strategy – Climate Related Opportunities (Continued)

Potential Opportunity

Potential Impact on GLXYOPPORTUNITIES: PRODUCTS & SERVICES
Shift in client preferences

MT-LT

Introduction of climate-related and broader mandates on and regulation of digital assets may lead to a shift in client
preference and facilitate institutional adoption of digital assets.
As Galaxy has one of the first and most comprehensive sustainability programs in the digital asset ecosystem, stakeholders
may perceive us as adequately addressing climate-related issues resulting in increased demand for products and services,
revenue, investor appetite, and capital availability to grow the ecosystem.

OPPORTUNITIES - RESILIENCE
Participation in renewable energy programs

MT

Bitcoin miners offer flexible load and through participation in demand-response programs may present an opportunity tohelp balance electricity grids and encourage investment in renewable projects.

Strategy

Recommended Disclosure

GLXY Response

Describe the resilience of the organization’s
strategy, taking into consideration different
climate-related scenarios, including a 2°C or
lower scenario

We have not conducted a climate-related scenario for our 2022 TCFD report. We may consider conducting a climaterelated scenario in future iterations of TCFD reporting as we remain focused on business resilience.

Task Force on Climate-Related Financial Disclosures (TCFD) Index

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Risk Management

Recommended Disclosure

GLXY Response

Describe the organization’s processes for
identifying and assessing climate-related risks

When identifying the potential climate-related risks Galaxy may face, we utilized our established risk-management
framework and leveraged management’s key role in our sustainability program’s governance structure. Additionally,
our first ESG materiality assessment identified key focus areas that are essential to our long-term business strategy,
consequently informing our climate-related risk identification process. Our climate-related risk identification processincluded the following steps:• Identify: We reviewed Galaxy’s business lines and risk factors, TCFD guidelines and recommendations, ESG frameworks,
standards, raters, and our peers to understand the current climate-related risk landscape and identified potential material
climate-related risks.
• Categorize: We refined a list of potentially material climate-related risks, which were categorized under TCFD guidelines
and recommendations.
• Assess Impact: We explored each potential climate-related risk in detail to understand its potential impact on ourbusiness.
• Gather Feedback: We engaged key internal stakeholders to receive feedback on potential climate-related risks,
including our Chief Operating Officer (COO) and Chief Risk Officer (CRO), who lead our risk functions.
• Engage Management: Galaxy’s TCFD response, including potential climate-related risks, was reviewed by the ESG
Steering Committee, and approved by the Board of Directors.

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Risk Management (Continued)

Recommended Disclosure

GLXY Response

Describe the organization’s processes for
managing climate-related risks

Managing and mitigating risk in a constantly evolving environment is fundamental to our ability to run our business and serve
our clients. We approach risk management as an essential business process integrated throughout our business lines andcorporate functions. We believe risk management is the responsibility of everyone at Galaxy.

Describe how processes for identifying,assessing, and managing climate-related risks
are integrated into the organization’s overallrisk management

The Board of Directors Audit Committee oversees the identification, assessment, and management of risk to achieve aproper balance between risk incurred, shareholder returns, and long-term business resilience. Our COO and CRO lead ourrisk functions, including the development and maintenance of policies to identify, assess, monitor, manage, and mitigate risk.
While Galaxy does not formally integrate climate-related risks into our overall risk management, all climate-related risk ismanaged through our sustainability program’s governance structure, which includes the Board of Directors, COO, and othersenior executive members of the Risk Committee. Additionally, Galaxy indirectly manages climate-related financial risks bycontinuously hedging our exposure through a macro approach that considers a wide array of scenarios.

Metrics & Targets

Recommended Disclosure

GLXY Response

Disclose the metrics used by the organization
to assess climate-related risks andopportunities in line with its strategy and risk
management process

To assess climate-related risks and opportunities in line with our strategy and risk management process, we measure thefollowing climate-related metrics:

Task Force on Climate-Related Financial Disclosures (TCFD) Index• Scope 1, 2, and 3 greenhouse gas (GHG) emissions• GHG emissions intensity per employee• Bitcoin mining energy mix• Global offices operational efficiency

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Metrics & Targets

Recommended Disclosure

GLXY Response

Disclose Scope 1, Scope 2 and, if appropriate, Scope 3
greenhouse gas emissions, and the related risks

We engaged Apex Group to conduct Galaxy’s second GHG assessment covering Scope, 1, 2, and 3 emissions. Apex
Group follows the GHG Protocol methodology for calculating emissions and uses nationally recognized emissions
factors, published by regulated authorities, to ensure the robustness of calculations. Where necessary, Apex Group may
build bespoke models for unique emissions sources, grounded in best-in-class data and scientific approaches. Apex
Group conducted this GHG assessment and verification of data independently, as a third-party, with no conflicts ofinterest.
Galaxy’s Scope 1, 2, and 3 GHG emissions were approximately 31,950 metric tonnes of carbon dioxide equivalent(mtCO2e).
We will continue to disclose our GHG emissions on an annual basis and are committed to increasing transparency
around our impact.

Describe the targets used by the organization to
manage climate-related risks and opportunities andperformance against targets

Task Force on Climate-Related Financial Disclosures (TCFD) Index

Our GHG calculations and assessment are essential to helping us to understand our impact, find opportunities to enhance
our operational efficiency, and implement best practices to reduce our footprint. Our Mining business remains committed
to achieving its long-term goal of expanding its use of sustainable energy, which we believe will help drive down our
marginal cost of production, while also indirectly helping decarbonize Galaxy’s Scope 2 GHG emissions.

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Appendix

Apex Group Assurance Letter

Galaxy ESG Report 2022

GALAXY DIGITAL
30.08.2023

APEX ESG Rating and Advisory
GHG Emissions Data Assurance
Galaxy Digital
30.08.2023

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GHG Emissions Data Assurance

Appendix

GHG Emissions Data Assurance
Company: Galaxy Digital
Sector: Financials

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Company: Galaxy Digital

Headquarters: New York, NY

Sector: Financials

Full Time Employees: 390

Headquarters: New York, NY

Galaxy Digital GHG Emissions Data Summary

Full Time Employees: 390

Apex has conducted a formal assessment of the Scope 1, 2 and 3 greenhouse gas (GHG) emissions

Galaxy Digital GHG Emissions Data Summary

Digital for the year 2022. Apex set the framework and organizational boundary for Galaxy Digicollection. Apex then reviewed all data, used its bespoke models and applied the relevant emission

Apex has conducted a formal assessment of the Scope 1, 2 and 3 greenhouse gasto(GHG)
emissionsof Galaxyaccurately
quantify
the 2022 carbon footprint of Galaxy Digital. The data assessed covered theDigital for the year 2022. Apex set the framework and organizational boundaryfor Galaxy
Digital’s data
emissionssources:collection. Apex then reviewed all data, used its bespoke models and applied the relevant emissions factors
i. Electricity consumption at all sites, including shared workspaces
to accurately quantify the 2022 carbon footprint of Galaxy Digital. The data assessed covered the following
ii. Electricity consumption of Bitcoin mining activities
emissions sources:i.

Electricity consumption at all sites, including shared workspacesii.

Electricity consumption of Bitcoin mining activitiesiii. Fuel consumption
iv. Employee commutingv.

WFH electricity and fuel consumption

vi. Food and drinkvii. IT software and hardware
viii. Business traveliii. Fuel consumption
iv. Employee commutingv.

WFH electricity and fuel consumption

vi. Food and drinkvii. IT software and hardware
viii. Business travelix. Waste productionx.

Hotel stays

ix. Waste production✔ Apex can confirm that all of the data collected had no inconsistencies or outliers.

x.

Galaxy Digital GHG 2022 Emissions

Hotel stays✔ Apex can confirm that all of the data collected had no inconsistencies or outliers.

Scope

GHG Protocol Category

Emissions (tCO2e)ix. Waste production

Overviewx.

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✔ Apex can confirm that all of the data collected had no inconsistencies or outliers.

Galaxy Digital GHG 2022 Emissions
Scope

GHG Protocol Category

Emissions (tCO2e)

1

Direct fuel consumption

0Electricity location-based

15,042.4

Electricity market-based

15,042.4

3

1 – Purchased goods and services

16,2963

5 - Waste generated in operations

1.4

3

6 – Business travel

513.3

3

7 – employee commuting

96.7

2

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GHG Emissions Data Assurance
MethodThe Apex ESG carbon footprint method uses the GHG Protocol methodology (WRI/WBCSD GHG protocol
Corporate accounting and Reporting Standard) for calculating the emissions of our clients. Under thismethodology, we use nationally recognized emissions factors, published by regulated authorities, to ensure
the robustness of our calculations. The assessment is aligned with standards and frameworks such as: CDP,
TCFD, ISO.
The emissions factors database includes over 1 million time-stamped, activity-specific emissions factors
from sources including but not limited to:•

GHG Protocol•

EPA (USA)•

NGA (Australia)•

Defra (UK)•

CEA (India)•

Bilan Carbone (France)•

IEA (International)

Where necessary Apex ESG also builds bespoke models where clients have unique emissions sources,
grounded in best-in-class data and scientific approaches.

Limitations
The following emissions sources used some estimations to cover the data:

Galaxy ESG Report 2022

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Overview

IEA (International)
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Where necessary Apex ESG also builds bespoke models where clients have unique emissions sources,
grounded in best-in-class data and scientific approaches.

Limitations
The following emissions sources used some estimations to cover the data:•

Electricity consumption outside of the US for shared office spaces

The following emission sources were not applicable under the scope of the assessment:•

Fuel consumption in office buildings

Exclusions
The following emissions sources were not covered in this assessment:•

Water consumption•

Financed emissions (Scope 3, category 15 – Investments)

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GHG Emissions Data Assurance
Data journey
All emissions data that Apex collects goes through our triple-lock check: three analysts independently
assess and verify all of the data, so that there are very high assurances of its accuracy and validity.

Independence

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Independence
Based on the process and procedures conducted, Apex can confirm that the emissions calculated are a fair
representation of GHG data and information provided by Galaxy Digital and that the GHG calculations has

been prepared in accordance with related International Standards on GHG quantification. Any estimations used
to plug data gaps are based on best practices and the standards used throughout our carbon footprint
assessment methodology.
Apex has conducted this assessment of the carbon footprint data independently, with no conflicts of interest
with Galaxy Digital.

This statement and opinion expressed herein, is provided Galaxy Digital and is solely for its benefit in accordancewith the terms of the agreement between Galaxy Digital and Apex. Apex’s release of this statement, is done without
assuming any responsibility or liability on Apex’s part to any third party whatsoever.

For further questions and enquires please contact: esg@theapexgroup.com

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Forward-Looking Disclaimer

Additional Relevant Disclaimers

This report contains certain forward-looking information and forward-looking statements, as defined in applicable securities

This document, and the information contained herein, has been provided to you by Galaxy Digital Holdings LP and its affiliates

laws (collectively referred to herein as “forward-looking statements”). These forward-looking statements relate to the future of(“Galaxy”) solely for informational purposes. This document may not be reproduced or redistributed in whole or in part, in any

the industry, environmental, social or governance initiatives, or the Company’s future plans or opportunities. All statements otherformat, without the express written approval of Galaxy. Neither the information, nor any opinion contained in this document,

than statements of historical fact are forward-looking statements. Often, but not always, forward-looking statements can beconstitutes an offer to buy or sell, or a solicitation of an offer to buy or sell, any advisory services, securities, futures, options or

identified by the use of words such as “plans”, “expects”, “budget”, “scheduled”, “estimates”, “continues”, “forecasts”, “projects”,

other financial instruments or to participate in any advisory services or trading strategy. Nothing contained in this document“predicts”, “intends”, “anticipates” or “believes”, “seeks” or variations of, or the negatives of, such words and phrases, or state that

constitutes investment, legal or tax advice or is an endorsement of any of the stablecoins mentioned herein. You should make yourcertain actions, events or results “may”, “could”, “would”, “should”, “might” or “will” be taken, occur or be achieved. The forward-

own investigations and evaluations of the information herein. Any decisions based on information contained in this document arelooking statements contained in this report are based on our current expectations and beliefs concerning future developments

the sole responsibility of the reader. Certain statements in this document reflect Galaxy's views, estimates, opinions or predictions

and their potential effects on us taking into account information currently available to us. There can be no assurance that future(which may be based on proprietary models and assumptions, including, in particular, Galaxy's views on the current and future

developments affecting us will be those that we have anticipated. Forward-looking statements involve known and unknown risks,market for certain digital assets), and there is no guarantee that these views, estimates, opinions or predictions are currently

uncertainties and other factors that may cause actual results to differ materially from those anticipated in such forward-looking

accurate or that they will be ultimately realized. To the extent these assumptions or models are not correct or circumstances

statements. Inherent in forward-looking statements are risks, uncertainties and other factors beyond the Company’s ability tochange, the actual performance may vary substantially from, and be less than, the estimates included herein. None of Galaxy

predict or control. Forward-looking statements are subject to the risk that the industry or the Company’s businesses do not

nor any of its affiliates, shareholders, partners, members, directors, officers, management, employees or representatives makes

perform as anticipated or meet the ESG goals as outlined in the report. They are also subject to the risks described in the Risk

any representation or warranty, express or implied, as to the accuracy or completeness of any of the information or any other

Factors section of the Annual Information Form (“AIF”) dated March 28, 2023 of Galaxy Digital Holdings Ltd. Factors that could

information (whether communicated in written or oral form) transmitted or made available to you. Each of the aforementioned

cause outcomes to differ materially from those described in such forward-looking statements include, but are not limited to, aparties expressly disclaims any and all liability relating to or resulting from the use of this information. Certain information

decline in the digital asset market or general economic conditions; a delay or failure in developing ESG process or implementing

contained herein (including financial information) has been obtained from published and non-published sources. Such information

goals; and changes in applicable law or regulation. Readers are cautioned that such risk factors, uncertainties and other factors

has not been independently verified by Galaxy and, Galaxy, does not assume responsibility for the accuracy of such information.

are not exhaustive. Actual results and developments are likely to differ, and may differ materially, from those expressed or implied

Affiliates of Galaxy may have owned or may own investments in some of the digital assets and protocols discussed in thisby the forward-looking statements contained in this report. The forward-looking statements in this report are applicable only as of

document. Except where otherwise indicated, the information in this document is based on matters as they exist as of the date ofthe date of this report or as of the date specified in the relevant forward-looking statement and the Company does not intend, andpreparation and not as of any future date, and will not be updated or otherwise revised to reflect information that subsequently

does not assume any obligation, to update these forward-looking statements, except as required by applicable securities laws.

becomes available, or circumstances existing or changes occurring after the date hereof. This document provides links to other

Investors are cautioned that forward-looking statements are not guarantees of future performance and are inherently uncertain.

Websites that we think might be of interest to you. Please note that when you click on one of these links, you may be moving to a

Accordingly, investors are cautioned not to put undue reliance on forward-looking statements.

provider’s website that is not associated with Galaxy. These linked sites and their providers are not controlled by us, and we are notresponsible for the contents or the proper operation of any linked site. The inclusion of any link does not imply our endorsement or
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investor.relations@galaxy.com. ©Copyright Galaxy Digital Holdings LP 2023. All rights reserved.

©Copyright Galaxy Digital Holdings LP 2023. All rights reserved.
For all inquiries, please email investor.relations@galaxy.com