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

DMCA Agent & Counter-Notice (EE. UU.)

Requirements for covers/remixes/samples

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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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Good-Faith Appeals. Users exercising appeal rights in good faith shall not be subject to retaliation. All UM3–UM4 decisions will receive human review prior to final sanctions.

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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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• To contest a hold or rejection, submit one or more of the following: (i) Master license or proof of ownership (artist–label agreement, producer agreements); (ii) Publishing license/mechanical clearance for compositions and derivatives; (iii) Split sheets firmados; (iv) License chain con sublicencias y territorios; (v) Original stems/session files o huellas acústicas (fingerprints); (vi) ISRC/ISWC/UPC y metadatos verificables; (vii) Authorization letters del titular; (viii) Invoices/receipts de adquisición de derechos.Insufficient Evidence. Unilateral declarations, screenshots without metadata, unverifiable emails, or documents without signatures or traceability will, on their own, be insufficient.

• Set-Off and Chargebacks. UMW may offset any amounts due to UMW (including fraud-related clawbacks, DSP adjustments, fines, or chargebacks) against any royalties or other sums payable to the user, across all accounts under common control. Users remain liable for any resulting negative balances, which must be repaid within 30 days of notice.

• Evidence Preservation. UMW will preserve relevant logs, detection reports, and financial records for 36 months from case closure, maintaining chain-of-custody (timestamping and cryptographic hashing where applicable) to support audits and legal proceedings.

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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. Case Communications. UMW will (i) acknowledge receipt of a user response or appeal within 2 business days; (ii) provide a substantive update within 15 business days; and (iii) aim to resolve standard cases within 30–45 days, subject to complexity and third-party cooperation.

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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.

‍Precedence. In the event of conflict, the following order of precedence applies: (1) Terms & Conditions, (2) Anti-Fraud Policy, (3) Acceptable Use Policy, (4) EULA, (5) other guidelines. Specific distribution/publishing agreements with UMW or DSPs may supersede the foregoing where expressly stated.

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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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Derivative and Cover Content. Uploads involving remixes, edits, mashups, samples, or covers must include documentation of permissions (master/publishing) and accurate metadata (credit lines, ISRC/ISWC, underlying work identifiers). UMW may block releases lacking such documentation.

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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

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21. DMCA Agent & Counter-Notice (EE. UU.)

21.1. DMCA Agent. UMW designates the following DMCA Agent to receive notifications of claimed infringement: Carlos Holguin (Av. Francisco de Orellana, Guayaquil, 090512, Ecuador, Email: dmca@umwrecordingsinc.com Takedown / Counter-Notice. Upon receipt of a compliant notice under 17 U.S.C. §512, UMW may remove or disable access to the allegedly infringing material. Affected users may submit a counter-notice containing the elements required by §512(g)(3). Unless the original complainant seeks court action within 10–14 business days, UMW may restore the material at its discretion. Misrepresentation. Parties submitting materially false notices acknowledge liability under §512(f).

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22. Requirements for covers/remixes/samples

22.1. Derivative and Cover Content. Uploads involving remixes, edits, mashups, samples, or covers must include documentation of permissions (master/publishing) and accurate metadata (credit lines, ISRC/ISWC, underlying work identifiers). UMW may block releases lacking such documentation.