Programme Marketing and Claims Policy

This policy governs everything said publicly about a programme running on XEX: by the operator, by its staff, by its members, by affiliates and by influencers it engages or rewards. It forms part of the Platform Terms.

It exists because an earnings claim is the most common way a compensation programme becomes unlawful, and because the person who makes that claim is usually not the person who signed the platform agreement. This policy makes the operator answerable for both.

By running a programme on XEX you give the following covenants. Each is a separate obligation and breach of any one is a breach of the platform terms.

1. 01Lawfulness. You warrant that your plan, your packages and your member relationships are lawful in every market you address, and that you hold every licence, registration or filing required there. This includes, without limitation, direct-selling and multi-level-marketing regimes such as the Korean Door-to-Door Sales Act, the Malaysian Direct Sales and Anti-Pyramid Scheme Act 1993, Vietnamese Decree 40/2018 on multi-level marketing, and Thai consumer-protection and direct-sales regulation. You will provide evidence of registration on request.
2. 02No claims. You will not make, and will not permit, any earnings, income, lifestyle or “opportunity” claim. No projections, no “up to” figures, no per-day or per-month examples, no screenshots of balances or payouts, no countdowns, no scarcity counters, no activity feeds, no leaderboards presented as attainable outcomes, and no imagery implying wealth acquired through the programme.
3. 03Member flow-down. You will impose covenant 2 on every member by binding terms, will monitor member marketing including social, messaging and influencer content, and will operate a takedown process that removes offending material within [[ To be supplied — takedown response time ]] of becoming aware of it.
4. 04Territory. You will market only in the countries you are permitted to, will not target a country the platform does not serve, and will neither circumvent the geographic gate nor instruct anyone else to.
5. 05Sanctions and financial crime. You will not deal with sanctioned persons or territories, will screen where screening is required of you, and accept that XEX may suspend immediately where it reasonably believes otherwise.
6. 06Non-custodial acknowledgement. You will not describe XEX as holding, protecting, insuring or guaranteeing member funds. XEX holds no member funds and no private keys; settlement is your obligation to your members.
7. 07Substantiation and records. You will retain data sufficient to substantiate anything you publish — including participant revenue and participant expenses, not revenue alone — and will furnish it to XEX on request. A claim you cannot substantiate must be withdrawn, not qualified.
8. 08Income disclosure. Where you make any earnings claim at all, you must publish and keep current a typical-results disclosure computed over all participants — including those who earned nothing, counted as zero — with forfeited and reversed amounts excluded. The platform computes exactly this report from your own ledger, so this obligation is one you can meet in a click and one XEX can verify.
9. 09Indemnity. You indemnify XEX, uncapped, against claims, proceedings, penalties and costs arising from your marketing, your members’ marketing, and any compliance, sanctions or intellectual-property breach in either.
10. 10Audit and suspension. XEX may inspect your programme’s marketing, require specific changes, remove a public listing, and suspend a workspace on reasonable suspicion of a breach of this policy, without liability for doing so.
11. 11Data protection. The Data Processing Addendum is incorporated into this policy, and applies to marketing data, tracking identifiers and any audience you build from member data.
12. 12Publicity. You will not state or imply that XEX endorses, licenses, approves, vets, guarantees or regulates your programme. You may state factually that your programme runs on XEX.
13. 13Change control. You will give XEX at least 15 days’ notice of a material change to your member terms or compensation plan that affects what members are told, and will give members a statement of reasons where you restrict, suspend or terminate a member account.

Covenant 2 is where operators most often think they are compliant and are not. The following are prohibited whether or not a disclaimer accompanies them:

• “Earn up to $X a month”, “replace your salary”, “financial freedom”, “passive income”, “retire early”.
• A screenshot of a dashboard, balance, claim or bank credit, whether real or illustrative.
• A worked example — “if you sponsor 3 who each sponsor 3…” — in any form, including a diagram.
• A rank, a car, a trip or a bonus presented as an outcome members can expect rather than as a rule with conditions.
• A countdown, a “only N spots left” counter, a live activity ticker, or any manufactured urgency.
• A testimonial without the required disclosure, and any testimonial at all that states or implies an amount.
• Cryptocurrency price predictions, or any suggestion that a token settlement will appreciate.

The rule that replaces them is simple: describe the rule, not the reward. “Level 3 pays 4% of qualifying volume when the rank condition is met” is a description of a plan. “Level 3 pays $400” is a claim about a person.

A testimonial may not state or imply an amount earned. Where one is used at all, it must carry, adjacent to it and in the same size and prominence as the statement itself:

“Results not typical” is not an acceptable substitute for the disclosure above, and a disclosure placed in a footer, behind a link, in a smaller size, or below the fold does not satisfy this section.

The platform provides an approved-asset library and templated announcements so that compliant material is the easy path rather than the disciplined one:

• An asset must be approved before it can be distributed, and the required disclosures are appended automatically when it is.
• A person holding only the marketing role cannot approve their own asset. Approval requires a different operator — the same maker-checker rule the platform applies to plan versions and payout runs.
• Leader announcements to a downline are sent from approved templates, not free text.

Using the library does not transfer responsibility. An approved asset that turns out to breach this policy is still your claim, and covenant 7 still requires you to be able to substantiate it.