The purpose of this policy is to provide:

• A clear definition of what we mean by "fraud".
• A summary to End Users of their responsibilities for avoiding fraudulent activities.
• Guidance to all parties involved as to actions which should be taken when we, the DSP or any other third party suspect any fraudulent activity.
• Clear guidance as to responsibilities for conducting investigations into fraud related activities.
• Protection to rights holders in circumstances where they may be victimized as a consequence of fraudulent activities.

This document is intended to provide guidance and should be read in conjunction with:

• The Terms of Use
• The Privacy Policy

Definitions

• End User: The person or legal entity that has entered into a contractual relationship with Company for the use of the Platform, accepting the Terms of Use and providing content that will be made available on DSP(s) (as defined in the Terms of Use).
• User Account: Accounts owned by End Users
• Fraud: the unauthorized exploitation of material protected by copyright (Copyright Infringement); the infringement of any law that regulates the ownership of legal right holders; the use of (modified) artist, band or label names or artwork which may create confusion or false expectations related to content which is served to consumers by DSP (i.e., Musical Spam); the use of automated digital bots or other means to "click" on payment-generating links pretending to be consumers (i.e., Click Fraud), producing artificial or manipulated Gross Receipts; the upload of distorted music for the purpose of generating artificial or manipulated Gross Receipts and other unauthorized activities that violate the Terms of Use, this Policy, or the agreements we have with DSPs.
• DSP(s), Gross Receipts, Net Income, Company, We, and Us have the meanings assigned to them in the Terms of Use.

Policy

Fraud in all its forms is wrong, and is unacceptable to Us.

This is because where fraud occurs:

• It is not just a loss to Us and the DSP, but ultimately to other content creators, damaging their copyrights, reputation or reducing the royalty pool which is made available by the DSP to content creators.
• It may have a major impact on our reputation, our contracts with DSP and therefore again on other End Users using our Services.

Our objective is to avoid and, if necessary, eliminate fraudulent usage of our Services.

Any indications of fraud will be rigorously investigated and dealt with in a firm and controlled way.

What DSPs are doing about it

Most DSPs use a mix of algorithms and humans to scan their catalog to avoid potential fraud or unauthorized use of their service. Once they have identified fraudulent streaming they may take down the content and inform Us about the case, including by exercising rights to reverse, adjust, offset, reclaim, or claw back amounts previously reported or credited in connection with suspicious activity.

What we are doing about it

We are actively taking action in the following fields:

• We are automatically monitoring (historic) sales data to combine this with other information (i.e., artist profiles, End User information, social media, etc.), to detect possible irregular activity.
• Our entire back catalog and all new tracks are fingerprinted and matched against several databases to avoid multiple uploads of the same song, uploads of "white noise", "empty songs", uploads of already copyrighted materials and, in general, any unauthorized activity.
• Our quality control (QC) processes are designed to track down the use of metadata that can be misleading, resulting in Musical Spam or any other unauthorized activity.

How we deal with suspected Fraud

• In case we detect or have suspicions of any unauthorized activity (including bot-generated streams, click fraud, music spam, etc.) from a specific Account, we will require the corresponding End User to cease such activities and warn the End User via a 3-strike policy system, resulting in blocking of the End User account in case our warnings are ignored.
• Company may decline to allocate Net Income, retain Gross Receipts or otherwise adjust revenue treatment for content that Company determines, in its sole discretion, violate the Terms of Use or this Policy.
• Blocked accounts can only be unblocked following the strict protocol described below.

The consequences of Fraudulent use of our Platform or Services

• If an End User is deemed breaching the Terms of Use, we will have the right to terminate the contractual relationship.
• Any Net Income allocations attributable to fraudulent or unauthorized activity may be reversed, declined, retained, offset, recouped, or permanently withheld or applied against future allocations in Company's sole discretion.
• To the extent any fraudulent and/or infringing activities are determined to be caused by the End User's actions, any costs incurred by Us or our providers (including legal fees and expenses) in connection therewith may, in addition to other remedies, be deducted, offset, or applied against future Net Income allocations or Gross Receipts in Company's sole discretion.

Severity, Strike Policy and Blocking of Accounts

Severity Either during our QC process, the sales confirmation process or through notifications received from DSP, we may detect issues of possible fraudulent content or Accounts. We divide these issues into 3 severity tiers:

• F0: Critical issues related to an End User account
• F1: Issues related to Click Fraud
• F2: Issues related to Musical Spamming and Copyright issues

F0 and F1: Critical issues related to an End User account, Issues related to Click Fraud

Once possible fraudulent content or Accounts are detected, a strike will be applied (see below) and the User Account may be blocked preventively in the following cases which we consider very severe:

F0: Applicable cases

• A User Account profile contains fake or incorrect information or unauthorized content that belongs to a third party
• Repeated, inconsistent IP activity versus declared country of origin on an Account

F1: Applicable cases

• An Account contains releases from unknown artists which are generating a considerable number of streams or views and subsequently substantial Gross Receipts in a short period of time without a minimum fanbase (listeners or viewers) to support it.
• Any sudden uplift in sales without corresponding numbers in profile views or social media to support it.
• An account generating Gross Receipts without having any detailed customer information.

F2: Issues related to Musical Spamming and Copyright issues

F2: Applicable cases

An Account receives a strike when one or more of the following problems are detected:

• A release contains misleading artist names or track titles, etc., to attract consumers to click.
• Whenever the impersonation of any artist, recording company, etc. is confirmed.
• A release contains copyrighted material from someone else who did not grant publishing permission to the User Account.
• We received a content infringement ticket from a DSP or from any PRO in relation to content that has been sent to DSP.
• We receive a direct infringement claim from the original Rights holder or his or her representative.

In case we detect one or more of these issues in the content of an User Account, the End User will receive a ticket or notice, indicating we have detected potential infringing or unauthorized activity

Strike Policy

In case We detect an F1 or F2 issue in an User Account, a strike is applied to the Account and the End User will receive a ticket or notice, indicating we have detected potential infringing or unauthorized activity and additional information from the End User may be required. In case a strike is applied and the End User cannot or refuses to provide the requested information within 5 working days, or if infringing or unauthorized activity is confirmed, a Strike will be applied to the User Account, which will have the following consequences:

Strike One:

• End User is informed.
• Takedown of questioned content.
• Warning of delay on 2nd strike and block on 3rd strike.

Strike Two:

• End User is informed.
• Takedown of questioned content.
• Warning that account is blocked on the third strike.

Strike Three:

• End User is informed.
• End User account is blocked.
• All End User content is taken down.
• Revenue allocations associated with such content may be declined, adjusted, or retained for any period Company determines in its sole discretion, including multi-year periods consistent with DSP contractual clawback and audit windows.

Once an End User has received three Strikes, we will block the End User's account.

Notwithstanding anything to the contrary contained herein, Company may accelerate or bypass any strike level at any time in its sole discretion where the conduct is material, egregious, repeated, or exposes Company to legal or commercial risk.

Blocked account policy

• In case an End User cannot, or refuses to provide the requested information and/or needed documentation within 5 working days, we may block access to the Account and decline to allocate Net Income or retain Gross Receipts associated with content that we determine, in our sole discretion, violates our Terms of Use or the agreements we have with DSP.
• We may discontinue the contractual relationship with the End User.
• The blocked Accounts will not be able to access the Platform and, therefore, utilize our Services.
• If the End User does not provide any kind of response, all content from the involved Account may be taken down.

Financial Withholding Independent of Strike Status

• Notwithstanding the foregoing strike framework, Company reserves the right at any time, including prior to the issuance of any strike, to suspend access to the Account, decline to allocate Net Income, retain Gross Receipts, establish reserves, reverse allocations, offset amounts, permanently withhold, recoup, or otherwise adjust revenue treatment, where Company determines, in its sole discretion, that activity is fraudulent, artificial, invalid, manipulated, or otherwise policy-violating, or where such action is required or recommended by any Digital Music Service, payment processor, or third-party partner.
• Revenue allocation and risk-protection measures are independent of and not conditioned upon the issuance of any strike and may be imposed at any time, including immediately and without prior notice in Company's sole discretion and consistent with the Terms of Use.

Unblocking an account

In case an End User provides the requested information within 5 working days, and the information can be verified, the account can be unblocked. We may request End Users to take the following steps in order to unblock the account:

• The End User information must be fully completed.
• The End User has to send Us a copy of an identification document (passport or national ID).
• In most cases we also request artist profiles, website urls, Twitter, Facebook, Instagram, etc., profile information from the artist in order to contrast this with the sales data. These profiles must have historical data to support the sales data.

Resolving a Strike

Once a Strike has been applied, we may request the End User to take the following steps in order to release the Strike and reduce the risk of blocking their Account and/or takedown of the uploaded tracks:

• Correcting the release metadata.
• In case there is doubt about the ownership of the uploaded tracks, the End User must provide proof of this, by sending Us a license, contract or ownership certificate.
• Acquiring the applicable licenses

In case the provided information suffices, the Strike will be resolved. In case the information requirements are not met, the Strike will remain applied and will be added to the existing ones.

Revenue Adjustments, Retention and Allocation Determinations in Fraud Cases

Where Company determines, in its sole discretion, that Gross Receipts are attributable to fraudulent, artificial, manipulated, infringing, or policy-violating activity, Company may decline to allocate Net Income and may permanently retain, reverse, reallocate, offset, recoup or apply such amounts to offset liabilities, refunds, DSP clawbacks, legal expenses, penalties, or other exposure. Company's revenue retention rights apply regardless of whether fraudulent activity is ultimately confirmed, if Company determines, in its sole discretion, that retention is necessary to mitigate legal, contractual, regulatory, or commercial risk.

Company may also establish reserves or retain revenue consistent with Digital Music Service clawback rights and contractual audit periods without any time limitation to the extent permitted under the Terms of Use.

No revenue allocation shall vest prior to payout approval.

For clarity, all Gross Receipts are Company revenue unless and until Company approves a Net Income allocation for payout. Nothing herein creates any trust, escrow, custodial, fiduciary, or ownership interest in favor of the End User prior to payout approval.

Revenue associated with such content may be retained, reserved, reversed, or reallocated in order to address the following situations:

• Company may, in its sole discretion, determine whether to approve allocation of Net Income.
• A claim from DSP is received, asking for reversal of Gross Receipts or previously allocated Net Income in case any DSP deems it was generated through unauthorized or fraudulent activity. Please note that DSPs may have contractual clawback, audit, or adjustment rights extending over multi-year periods, and Company may retain or reserve revenue consistent with such rights and related risk exposure.
• A claim from legitimate rights holders is received, claiming the reallocation of Gross Receipts or Net Income that have been retained, plus Net Income allocations previously approved and paid to End Users in connection with such activity.

Takedowns

We will initiate takedowns of confirmed infringing content for User Accounts and all content that is involved in F0, F1 or F2 issues.

However, please also note that any content may be marked as suspicious by DSP at their sole discretion and may be taken down at their discretion.

Independence of Enforcement Remedies

Company's investigation, enforcement, suspension, restriction, withholding, claw back, or termination actions under this Anti-Fraud Policy are independent of and not conditioned upon any copyright enforcement assistance, DMCA notice, Platform dispute, or other Enforcement Action described in the Terms of Use. Company's decision to provide, decline, suspend, or withdraw copyright enforcement assistance shall not limit or affect Company's rights under this Anti-Fraud Policy, and vice versa.

No enforcement action or accommodation provided by Company shall create any obligation of consistency, uniformity, reciprocity, or ongoing assistance.

This Anti-Fraud Policy is incorporated into and forms part of the Terms of Use. In the event of any conflict, inconsistency, or ambiguity between this Policy and the Terms of Use, the Terms of Use shall govern and control. Nothing in this Policy shall be construed to limit, narrow, or condition Company's rights, discretion, or remedies under the Terms of Use, all of which are expressly preserved.