Table of Contents:

Introduction

Definitions

Policy Statement

Fraud Detection and Prevention Measures

Response to Suspected Fraud

Consequences of Fraudulent Activity

Severity Levels and Warning Policy

Royalty Retention and Escrow Policy

Content Removal

End User License Agreement (EULA)

Appeal and Review Process

Jurisdiction and Governing Law

Policy Review and Update

Contact and Support

Compliance Program for Labels andAggregators

Content Authenticity Declaration

Specifically Prohibited Practices

Royalty Refunds in Case of System Error

Mutual Indemnity Clause

Use of Third-Party Detection Technologies

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1. Introduction

Welcome to our Anti-Fraud Compliance Framework. Thisdocument represents our commitment to a fair, safe, and transparent environmentfor creators, partners, and users.

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2. Definitions

• User: Any individual or entity using our platform under our Terms of Use.
• Fraud: Intentional deception to gain financial or personal benefit.
• Royalties: Revenue generated from the legitimate exploitation of content.
• Fraudulent   Content: Any material infringing copyright, using artificial plays, or employing deceptive  practices.

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3. Policy Statement

We uphold a zero-tolerance stance on fraud. Our mission isto detect, prevent, and sanction any fraudulent activity to protect the rightsof legitimate creators.

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4. Fraud Detection and PreventionMeasures

• Automated  Monitoring: Algorithms detecting  unusual activity, artificial spikes, or data discrepancies.
• Manual  Review: Dedicated teams that  audit alerts and user reports.
• Education: Continuous user training on safe and lawful practices.
• Collaboration  with DSPs: Data sharing for cross-verification and fraud control.

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5. Response to Suspected Fraud

• Immediate   Investigation: Review of data, history, and behavioral patterns.
• User   Notification: Formal notice of suspicion, with opportunity for response.
• Access   to Evidence: Users shall have the right to access, upon request, the relevant evidence and   technical indicators used in support of the suspected fraudulent activity.
• Temporary   Measures: Partial suspension and     provisional royalty withholding. Suspensions shall be reviewed within a     reasonable timeframe not exceeding 60 days, subject to extension with     justification.
• Privacy   Assurance: All investigations  shall be conducted in accordance with our Privacy Policy and applicable   data protection laws.

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6. Consequences of FraudulentActivity

• Account   Termination: Permanent  removal for proven fraud.
• Confiscation   of Fraudulent Royalties:  Withholding and eventual redirection to rightful owners.
• Legitimate   Revenue Protection: If both  fraudulent and legitimate royalties are identified, the latter will be  disaggregated and paid unless prevented by legal or technical constraints.
• Legal  Action: Potential claims for  damages.
• Reputational   Impact: Internal record of  infringement.

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7. Severity Levels and WarningPolicy

• UM1: Minor issue (metadata errors). Sanction: warning and correction.
• UM2: Moderate deception. Sanction: review and temporary  suspension.
• UM3: Artificial plays. Sanction: functionality block and  royalty freeze.
• UM4: Recurrence or deliberate fraud. Sanction: account  closure and full royalty retention.
• EC1     to EC4: Progressive warning     stages with formal notification at each step.

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8. Royalty Retention and Escrow Policy

Royalties suspected of fraud will be held for up to 24months, with biannual reviews. Users may request earlyreassessment with valid evidence.

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9. Content Removal

• Criteria: Unauthorized use of protected works, spam, or  deceptive engagement.
• Process: Detection, notification, removal, and income  adjustment.

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10. End User License Agreement (EULA)

Users must accept the EULA to access services. It outlineslicensing, usage limits, IP ownership, updates, and liability disclaimers.

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11. Appeal and Review Process

Users may submit a formal appeal within 15 business days ofnotification. An independent team will review the decision.

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12. Jurisdiction and Governing Law

This policy shall be governed by and construed in accordancewith the laws of Ecuador. Any dispute arising herefrom shall be subject to theexclusive jurisdiction of the competent courts of Guayaquil, Ecuador.

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13. Policy Review and Update

This policy will be reviewed at least annually or whenmaterial changes to the technological or legal landscape arise. Updateswill be published on our website.

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14. Contact and Support

• Email: antifraud@umwrecordingsinc.com
• Phone: +593 96 801 6285
• Live Chat: Available during business hours

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15. Compliance Program for Labels and Aggregators

15.1. All labels, secondary distributors, and aggregatorsusing our platform must implement internal anti-fraud compliance policies.
15.2. We reserve the right to audit or request documentation of internalverification processes and rights management.

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16. Content Authenticity Declaration

16.1. By uploading content, users declare and warrant that:

• They  own or are duly authorized to distribute the content.
• They  have not used traffic manipulation tools (bots, click farms, misleading     VPNs, etc.).
• Metadata  is accurate and truthful. 16.2. False declarations may result in immediate  suspension and legal liability.

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17. Specifically Prohibited Practices

Explicitly prohibited:

• Using  famous artist names for misleading traffic.
• Uploading unauthorized or edited versions of protected works.
• Manipulating  monetization systems (e.g., automation loops, multiple fake accounts).
• Promoting  content via unverified third-party tools.

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18. Royalty Refunds in Case of System Error

18.1. If a false positive or erroneous sanction isidentified, the company shall:

• Fully  refund legitimately earned royalties.
• Issue  a formal apology and restore the profile without reputational harm.
• Notify  the user of the error and corrective measures.

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19. Mutual Indemnity Clause

19.1. The company shall not be liable for damages arisingfrom user misuse.
19.2. Users agree to indemnify and hold harmless the company from third-partyclaims related to their content.
19.3. Likewise, the company agrees to act in good faith to prevent unjust harmto users.

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20. Use of Third-Party Detection Technologies

20.1. The platform may use third-party tools (e.g.,fingerprinting, machine learning) as part of its anti-fraud system.20.2. Users agree that reports generated by such tools may be used as validindicators in investingations