DECENTRAL MEDIA INC.
NEW PERSONAL INVESTMENTS AND TRADING POLICIES
1. All employees shall disclose the names of which cryptocurrencies they own, directly or indirectly, upon commencing employment at Decentral Media Inc. (the “Company”). This includes positions in BTC, ETH, and stablecoins such as USDT.
2. At least once per quarter, each employee shall provide updated reports of the names of the cryptocurrencies they own, along with the names of cryptocurrencies they have purchased, traded, mined, or disposed of 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 blockchain projects or cryptocurrencies.
Outside Business Activities
5. 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.
6. 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
7. Research analysts and the Company’s CEO cannot take short positions in cryptocurrencies.
8. No employee shall knowingly purchase or sell any cryptocurrency within three days before or after the publication by the Company of a research report concerning or identifying the cryptocurrency. Once a cryptocurrency has been identified as the topic of a report, no employee shall knowingly profit by trading on that information.
9. No employee assigned an editorial piece or involved in its publication (such as designer, researcher, administrator, or other reviewers in the publication process) shall, once assigned, purchase or sell any cryptocurrency to be mentioned in the piece and for at least three days before or after publication.
10. 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), they must immediately notify his or her supervisor in writing of the nature of the financial interest so it can be assessed whether they should be reassigned based on that conflict of interest.
11. 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.
12. The policies set forth in paragraphs 7-11 above do not apply to BTC, ETH, or stablecoins such as USDT, USDC, and DAI.
13. 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 the publication of research reports which may impact the coin’s market price.
14. Employees are prohibited from disclosing, orally or in writing, the names of the cryptocurrencies which are the subject of pending research reports which include a buy or sell recommendation.
Required Disclosures by Authors
15. 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 article 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, recent trading activity, or current or recent ownership interest in any mentioned cryptocurrencies.
16. As the Company and its published content become more influential, what is said in our editorial pieces and research reports may have an impact on the market prices of certain cryptocurrencies. Accordingly, there is a temptation by wrongdoers to obtain information about our content in advance of its publication for personal financial gain. It is therefore imperative that all employees keep their work for the Company, and in particular on assignments on the subject of cryptocurrencies, in strict confidence. Such information is confidential and the failure to maintain that confidentiality could cause damage to the Company’s reputation, and possibly subject you to civil and criminal liability for violations of Federal Securities Laws.
17. Employees of the Company owe a duty of care and loyalty during the course of their employment. This includes the duty of acting in good faith and always in the best interest of the Company, its customers, and its readers. 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 cryptocurrency investors.