Diligence

Corporate & legal documents

Entity structure, incorporation records, governance, IP, capitalization, treasury, and regulatory materials

Corporate structure

Steer uses four entities to separate ecosystem governance, token administration, commercial operations, and engineering and intellectual property. Registry references are taken from the linked incorporation artifacts, which also record legal form and formation date. Operating roles are management-reported.

EntityJurisdictionRegistry referenceOperating roleArtifact
Steer FoundationCayman IslandsCP-418776Ecosystem governance, grants, and ecosystem treasury oversightCertificate
Steer Digital Assets Ltd.British Virgin Islands2172619Token lifecycle administration and reserve managementCertificate
Steer Labs Inc.PanamaMercantile Record 155722340Customer contracting, billing, and commercial operationsRegistry certificate
Ciphergrid Labs PTE. LTD.SingaporeUEN 202347858NEngineering, security, DevOps, and core intellectual propertyCertificate

The linked artifacts establish formation and legal form as of their issue dates. Current good standing, ownership, directors, officers, and signing authority require current registry extracts and statutory records.

Intellectual property and intercompany structure

The company’s current structure assigns core protocol engineering and intellectual property to Ciphergrid Labs, with operating and commercial rights documented across the affiliated entities.

MaterialPurposeAccess
Founder, employee, and contractor IP assignmentsEstablish contribution and ownership chainRestricted
Repository and license registerMap code, license, version, and owning entityNDA
Ciphergrid Labs ↔ Steer Labs services agreementEngineering services and commercial-deployment supportRestricted
Ciphergrid Labs ↔ Steer Labs IP licenseProduction deployment and commercialization rightsRestricted
Ciphergrid Labs ↔ Steer Digital Assets token-development licenseToken-related development and confidentialityRestricted
Trademark, domain, and brand registerOwnership and operating rightsNDA

Governance, treasury, and authority

Management materials describe the following responsibility and treasury-control model:

AreaResponsible entityReported control model
Ecosystem governance and grantsSteer FoundationBoard oversight and multisignature treasury approval
Token lifecycle and protocol reservesSteer Digital Assets Ltd.Entity-level multisignature approvals for issuance and reserve activity
Customer contracts and commercial treasurySteer Labs Inc.Commercial contracting authority and finance-approved treasury transactions
Engineering, security, and operating expenditureCiphergrid Labs PTE. LTD.Operating treasury policy and multisignature approvals

Board records, delegated-authority schedules, treasury policies, and signer records control the legal authority analysis. Wallet addresses, signer identities, and recovery procedures are not reproduced in this room.

Capitalization and financing

MaterialAccess
Fully diluted capitalization by entityRestricted
Shareholder and member registersRestricted
SAFEs, notes, warrants, side letters, and amendmentsRestricted
Option plan, grants, vesting, and available poolRestricted
Prior financing history and investor rightsRestricted
Current $3M SAFE, token warrant, and approvalsRestricted
Token rights associated with financingsRestricted

These documents are shared only with qualified recipients because they contain investor, ownership, and personal information.

Product and regulatory materials

Steer’s legal treatment depends on the product, wrapper, entity, jurisdiction, custody model, operator discretion, distribution path, and token involvement. The regulatory folder therefore organizes review by product rather than relying on one universal characterization.

MaterialAccess
Product and entity responsibility matrixNDA
Jurisdiction, eligibility, and KYC/KYB analysisRestricted legal review
Custody, discretion, advisory, brokerage, fund, derivatives, and money-transmission analysisRestricted legal review
Product terms, disclosures, risk factors, and governing lawNDA / restricted
Distribution-partner responsibility matrixNDA
Token utility, allocation, vesting, governance, and regulatory analysisRestricted legal review

Corporate document index

FolderIncluded recordsAccessAvailability
Entity formation and standingIncorporation, registry, good standing, and constitutional recordsLink access / NDACorporate structure; current standing records controlled
Ownership and governanceOwnership chart, statutory registers, board records, and authorityRestrictedGovernance, treasury, and authority; statutory records controlled
IP and intercompanyAssignments, licenses, services, repositories, and brandsNDA / restrictedIP and intercompany structure; executed agreements controlled
Financing and capitalizationCap table, instruments, rights, grants, approvals, and closing recordsRestrictedCapitalization and financing; detailed financing records controlled
Product and regulatoryProduct-specific legal analyses, terms, eligibility, and distributionRestrictedProduct and regulatory materials; token design; legal analyses controlled

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