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Exodus Movement, Inc.

For the period ended Dec 31, 2025. Filed Mar 11, 2026.

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A company's yearly report to the SEC, with audited financial statements. It is the fullest account a company gives of its business, its finances and the risks it sees.

FY2025 · Filed Mar 11, 2026

EXOD$4.48+10.1%Stored close · as of Nov 9, 2026

Extracted filing text, with the paragraph anchors used by the comparison.

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Contents

Item 9A. Controls and Procedures

Evaluation of Disclosure Controls and Procedures

Our management, with the participation of, and under the supervision of, our Chief Executive Officer ("Principal Executive

Officer") and Chief Financial Officer ("Principal Financial Officer"), evaluated the effectiveness of the Company's

disclosure controls and procedures as defined in Rules 13a-15(e) and 15d-15(e) under the Exchange Act as of December

31, 2025. Based upon that evaluation, our Chief Executive Officer and Chief Financial Officer concluded that, as of

December 31, 2025, the Company’s disclosure controls and procedures were effective.

Management's Report on Internal Control over Financial Reporting

Management is responsible for establishing and maintaining adequate internal control over financial reporting, as defined

in Rules 13a-15(f) and 15d-15(f) under the Exchange Act. Internal control over financial reporting is a process designed

by, or under the supervision of, the Company's Chief Executive Officer and Chief Financial Officer and effected by the

Company's board of directors, management, and other personnel, to provide reasonable assurance regarding the reliability

of financial reporting and the preparation of financial statements for external purposes in accordance with accounting

principles generally accepted in the United States of America.

Management assessed the effectiveness of the Company's internal control over financial reporting as of December 31,

2025, based on the criteria established in the Internal Control - Integrated Framework (2013) issued by the Committee of

Sponsoring Organizations of the Treadway Commission ("COSO Framework"). Based on this assessment, management

concluded that the Company maintained effective internal control over financial reporting as of December 31, 2025.

Previously Reported Material Weaknesses

We identified errors in our previously reported financial information as of and for the year ended December 31, 2021. As a

result of the errors that were identified, we identified a material weakness in the Company’s control environment whereby

the Company did not design and maintain effective internal control over financial reporting with respect to the expertise

and quantity of its resources. Specifically, we did not effectively execute a strategy to hire, train, and retain a sufficient

quantity of personnel with an appropriate level of training, expertise, and experience in certain areas important to financial

reporting. In addition, we also identified a material weakness whereby we did not design and implement effective control

activities based on the criteria in the Internal Control - Integrated Framework (2013) issued by the Committee of

Sponsoring Organizations of the Treadway Commission ("COSO Framework"). Specifically, the control activities did not

adequately (i) address relevant risks, (ii) provide evidence of performance, (iii) provide appropriate segregation of duties,

or (iv) operate at a level of precision to identify all potentially material errors.

Remediation Update of Previously Reported Material Weakness

Management has fully executed its remediation plan as of the period ended December 31, 2025, to address the previously

reported material weaknesses in internal control over financial reporting. Throughout the current fiscal year 2025, the

Company has added experienced accounting leadership, enhanced control design and documentation, and implemented

review and approval processes to further strengthen oversight of our financial reporting processes. Key remediation actions

completed as of December 31, 2025 include:

Hiring and training additional accounting personnel with appropriate level of training and technical expertise and

experience to improve segregation of duties and oversight within the financial reporting process;

Replacing certain key accounting leadership positions to enhance supervision and control accountability;

Engaging an external consulting firm with digital asset industry expertise to assist with process improvement,

control design, and documentation;

Implementing enhanced financial close procedures, workflow controls, and review-level documentation to

increase control precision and evidence of performance;

Strengthening entity-level and process-level controls, including segregation of duties and IT-related controls, in

alignment with the COSO Framework.

The remediated controls were implemented during fiscal year 2025 and operated for a sufficient period of time to allow

management to evaluate their design and operating effectiveness.The Company performed testing to confirm the operating

effectiveness of these enhanced controls throughout 2025.

Management further evaluated whether any remaining deficiencies, individually or in the aggregate, represent a material

weakness and concluded that no material weaknesses in internal control over financial reporting exist as of December 31,

Changes in Internal Control over Financial Reporting

Except for the remediation activities described above, there have been no changes in our internal control over financial

reporting that occurred during the three months ended December 31, 2025, that have materially affected, or are reasonably

likely to materially affect, our internal control over financial reporting.

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