DECENTRAL MEDIA INC.
NEW PERSONAL INVESTMENTS AND TRADING POLICIES
1) All employees shall disclose all positions and amounts of cryptocurrencies owned, directly or indirectly, by each of them upon commencing employment at Decentral Media Inc. (the “Company”), with last date(s) of acquisition. This includes positions in BTC, ETH and USDT.
2) By the 15th day of the end of each calendar quarter, each employee shall provide updated reports of all cryptocurrencies holdings owned by him or her with detailed information concerning any purchases and sales during the quarter.
3) The Company reserves the right to request cryptocurrencies positions information from the immediate family members of employees.
4) The Company reserves the right to request from any employee any mining arrangements he or she has, and his or her immediate family members have, in place with any projects and/or cryptocurrencies.
5) No one in the Research Department (which includes all research analysts, researchers, administrators and designers), nor the Company’s CEO, may purchase a cryptocurrency without prior written approval, whose request sets forth the intended quantity and USD value of the purchase of the coin and intended purchase date.
6) The Company reserves the right to withdraw its approval of an employee’s purchase of a cryptocurrency and require corrective action such as a sale.
Outside Business Activities
7) All employees must obtain prior written approval to have any business or contractual relationships with any businesses that involve blockchain technology, including consulting, advisory and directorships.
8) All employees must immediately disclose if, where and when any immediate family members are employed, with their titles, if employed at a company or project involving blockchain technology.
Holding Periods/Trading Activities
9) Research analysts and the Company’s CEO must hold any cryptocurrency they own for at least thirty (30) days.
10) All employees must hold cryptocurrencies they own for at least sixteen (16) days.
11) In certain cases of financial or personal hardship, an employee may apply to the Company’s CEO for waiver of a portion of the holding period.
12) Research analysts and the Company’s CEO cannot take short positions in cryptocurrencies.
13) No employee shall knowingly purchase or sell any cryptocurrency within sixteen (16) days of the publication by the Company of a research report concerning or identifying the cryptocurrency.
14) No employee assigned an editorial piece or involved in its publication (such as designer, researcher, administrator or other reviewer in the publication process) shall, once assigned, purchase or sell any cryptocurrency to be mentioned in the piece and for at least two days after publication.
15) If an employee is assigned editorial work or a research report regarding a company or project in which he or she or an immediate family member have a financial interest (through stock, business or family relationship, and/or cryptocurrencies), he or she must immediately notify his or her supervisor in writing of the nature of the financial interest, so it can be assessed whether he or she should be reassigned.
16) From time to time, an employee may receive bonus or reward tokens. Once received, these tokens are subject to the same policies herein for other cryptocurrencies.
17) The policies set forth in paragraphs 9-16 above do not apply to BTC, ETH, or USDT.
18) The Company has a policy of imposing information barriers to prevent the misuse of material, non-public information about a cryptocurrency. This includes market and business information about the coin and publication of research reports which may impact the coin’s market price.
19) The Research Department employees are geographically and physically disbursed from the other departments and employees at the Company.
20) The Company does not have companywide email “groups” on its email system so that emails of employees of the Research Department are not easily available to the other departments of the Company.
21) The Company restricts on its publishing platform access to the work of the Research Department from its other employees.
22) The Research Department is prohibited from disclosing, orally or in writing, the names of the cryptocurrencies which are the subject of its research reports.
23) All employees are prohibited from seeking access to Research Department emails, and any improper or unauthorized access is subject to disciplinary action and possible termination.
Required Disclosures by Authors
24) It is the responsibility of any author or writer of an editorial piece or research report to submit along with his or her proposed article or report a written disclosure at the conclusion of the piece or report identifying any interest, or conflict of interest, he or she may have in the cryptocurrencies which are the subject of the publication. The interest may include a business or family relationship with the project, or a current or recent ownership interest in the cryptocurrencies.
25) As the Company and it’s published content becomes more influential, what is said in our editorial pieces and research reports may have an impact on the market price of certain cryptocurrencies we write about. Accordingly, there is the temptation by wrongdoers to obtain early access or information about our content in advance of its publication, to personally benefit financially from trading on the possible market movement caused by the issuance of our pieces and reports. It is therefor imperative that all employees keep their work for the Company, and in particular assignments on the subjects of certain cryptocurrencies, be kept on the stricter of confidence. Such information is confidential and your failure to maintain that confidentially could cause damage to the Company’s reputation, and possibly subject you to civil and criminal liability for violations of the Federal Securities Laws.
26) As an employee of the Company, you owe it a duty of care and loyalty in the course of your employment. This includes the duty of acting in good faith and always in the best interests of the Company. A key part of fulfilling these duties is adhering to the policies above. We appreciate your cooperation in ensuring an ethical and fair marketplace for all investors in cryptocurrencies.