Anti-Fraud Policy – Support Center

Anti-fraud policy last revision: 24th February 2023. All modifications to this anti-fraud policy has retro-active effects.

1. Introduction
This Anti-Fraud Policy sets a course of action for End Users of our platform and services, and defines the actions taken and the consequences of fraudulent behaviour.

Specifically, the purpose of this Policy is to provide:

- A clear definition of what is considered as “Fraud”.
- A summary of the End User’s responsibilities in avoiding fraud-related activities.
- Guidance to all parties involved as to action which should be taken when there is a strong suspicion or evidence of fraudulent activity.
- Protection to right holders in circumstances where they may be penalized as a consequence of fraudulent activities.

2. Definitions
End User: Is the person or legal entity that has entered into a contractual relationship with Sepulchral Silence for the use of the platform, accepting the Terms of Use and providing content that will be made available on DSP.
End User Account: Accounts owned and/or created by End Users.
DSP: Digital Streaming Platforms (such as Spotify, Apple Music, Tidal, etc.) or any other channel connected to the Sepulchral Silence Network.
MDFS: Monetization through Digital Fingerprinting Systems (i.e. YouTube Content ID, Facebook Rights
Manager, among others).
Fraud: Any activity contrary to the Law, the DSP Policies and/or our own. Particularly, but non-exclusively, the following activities will be categorized as Fraud:
- The unauthorized exploitation of material protected by Copyright.
- The infringement of any Law that regulates the ownership of legal right holders.
- The use of any artist, band or label names or artwork in a misleading way, which may create confusion or false expectations related to content which is served to consumers by DSP (i.e., spam, misleading content, fake artists).
- The use of automated, digital bots or other means to “click” on royalties-generating links pretending to be consumers (artificial streams), producing unnatural and irregular incomes.
- The upload of low audiovisual quality content, distorted music, silenced songs, or any other deceptive material.
Royalties: Economic income/revenue generated after the rightful exploitation of any repertoire.
Strike: A strike is a warning applied to any account that violates industry best practices, DSP guidelines
and/or our Anti-Fraud Policy. They are separated into three tiers (strike 1, 2 and 3), and applied
cumulatively with the particularities displayed in Section 4.2. Strike Policy.

3. State of Affairs
Fraud in all its forms is not tolerated when using our services. This is because when fraud occurs:
- It is not just a loss for Us and the DSP, but ultimately to content creators, damaging their reputation and reducing the royalty pool which is made available by the DSPs to financially compensate creators for a legitimate, commercial use of their work.
- It may have a major impact on our reputation, our contracts with DSP and therefore again on the End Users using our Services.

Our objective is to detect, prevent and whenever possible eliminate any fraudulent usage of our Services. Any indications of fraud will be rigorously investigated and dealt with in a firm and controlled way.

3.1. What DSP are doing about it
Most DSP use a mix of algorithms and human resources to scan the content uploaded into their repository to avoid potential fraud, unauthorized and/or artificial streams and abusive use of their service. Once they have identified fraudulent activity they take down the content and inform Us about the case, reserving the right to withhold from future payments any amounts generated from suspicious or illegal activities.

3.2. What We are doing about it
We are actively taking action in the following fields:
- Monitoring historic sales data to combine this with other information in order to detect potentially irregular activities.
- Content uploaded into our platform is fingerprinted and matched against several databases to avoid multiple uploads of the same song, uploads of white noise, empty songs, copyrighted materials and any unauthorized type of content.
- Our Quality Control processes are designed to track down the use of assets or metadata that could potentially result in musical spam (repeated submissions), misleading content, copyright infringement and any other type of irregular activity.

3.3. How We deal with Fraud
- In case we detect or have strong suspicions of any unauthorized activities by a specific account, we will apply our Strike Policy, as displayed in Section 4.2., which could ultimately result in blocking the involved account from accessing our service.
- Revenues received in connection with activities violating the Terms of Use, this Anti-Fraud Policy and/or the DSP guidelines may be blocked and retained by DSP.

3.4. The consequences of a Fraudulent use of Our Platform or Services
- If an End User is deemed breaching the Terms of Use and/or the Anti Fraud Policy, we will have the right to unilaterally ban the End User from our services.
- Any amounts due to an End User from any DSP derived from any fraudulent or unauthorized use
of the service will be put in escrow for 5 years to deal with possible economic claims by the person and/or company affected by the irregularity of the end user.
- To the extent any fraudulent and/or infringing activities are determined to be caused by the End User’s actions, the End User will be held responsible for any costs incurred by us or our providers (including legal fees and expenses) in connection therewith. These costs, in addition to other remedies, may be deducted from royalties in escrow.

4. Severity, Strike Policy and Account Blocking
4.1. Severity
Either during our QC processes, the sales confirmation process or through notifications received from DSP
and/or third parties, we may detect fraudulent content, activities and/or accounts. Once detected, these issues are classified into three categories:
- F1: Issues related to Use of Samples.
- F2: Issues related to Copyright, Intellectual Property, Trademark or Artificial Streams.
- F3: Issues related to Abusive Usage of MDFS.

F1: 1st distribution attempt. Issues related to Copyright, Intellectual Property, Trademark or Artificial Streams.
Particularly, but non-exclusively, we will categorize as F1 the following:

- Whenever an impersonation of any artist, recording company, unauthorized use of trademarks, distinctive signs, song or album titles, etc., is confirmed.
- A release containing copyrighted material from a rights-holder who did not grant distribution permission to that end.
- Whenever a copyright infringement notification from a DSP and/or any third party is received in relation to a content that has been sent to DSP.
- We receive an infringement claim from the original rights-holder or his/her representative.

- Repertoires generating a considerable number of streams and/or views and, subsequently, revenues in a short period of time without a minimum, credible background to support it.
- Any suspicious uplift in sales without corresponding numbers or facts to support it.
- To hire shady promotion services in order to generate streams, views and/or followers in an artificial manner (bot-generated).

F2: Issues related to Copyright, Intellectual Property, Trademark or Artificial Streams.
Particularly, but non-exclusively, we will categorize as F2 the following:
- Whenever an impersonation of any artist, recording company, unauthorized use of trademarks, distinctive signs, song or album titles, etc., is confirmed.
- A release containing copyrighted material from a rights-holder who did not grant distribution permission to that end.
- Whenever a copyright infringement notification from a DSP and/or any third party is received in relation to a content that has been sent to DSP.
- We receive an infringement claim from the original rights-holder or his/her representative.

F3: Issues related to Abusive Usage of MDFS
Particularly, but non-exclusively, we will categorize as F3 the following:
- The insertion of an original content within or among a third party’s original copyrighted content, with the intention of taking advantage of such content’s popularity, in order to generate higher income.
- Any sudden, suspicious uplift in sales related to MDFS, without proper historical consistency or plausible reason.

Whenever We, at our sole discretion or through notifications received by DSP and/or third parties detect any of these issues on any account, our Strike Policy will be triggered, as described in Section 4.2.

Problematic Content
In addition to the severities displayed above We may proceed to brand as Problematic Content the following:
- Offensive/Abusive/Defamatory/Obscene/Pornographic content.
- Nazi propaganda, Hate content, Terrorism apology.
- Cultural Sensitivities.
- Repeated submissions/flooding.
- Generic or Fake artists.
- Generic content with low editorial value.
- Public Domain.
- Poor quality sound recording/artwork.

This will trigger the appliance of our Strike Policy, when pertinent and with the consequences displayed below.

4.2. Strike Policy

a) Unresolved Quality Control (QC) tickets regarding 1st distribution attempt and issues releated to possible copyright infringement. (F1).

Our Quality Control (QC) department review all releases before final approval. If they detect that the content to be distributed is a possible case of copyright infringement, you will always receive an email in order to provide the corresponding documentation in order to review that you are the content owner and consequently is legit to be distributed. In case you don't answer QC tickets or the documentation provided is not valid, we will apply a strike into the end user's account and then the royalties will be decreased according to the following table:

1 unresolved ticket: FIRST strike applied into end user's accout AND the account will be permanently blocked.

b) Unresolved Quality Control (QC) tickets regarding a possible copyright infringement (F2):

1 unresolved ticket: FIRST strike applied into end user's accout AND the percentage of royalties will be decreased to 50% during the next 5 years.
2 unresolved tickets: SECOND strike applied into end user's account AND the account will be permanently blocked.

c) Unresolved Rights Management Department (RM) tickets regarding a possible copyright infringement (F3):

When our Rights Management (RM) department receives a claim against your content from a claimant or directly from a DSPs, you will always receive an email in order to provide the corresponding documentation in order to review that you are the content owner and consequently is legit to be distributed. In case you don't answer RMD tickets or the documentation provided is not valid, we will apply a strike into the end user's account and then the royalties will be decreased according to the following table:

1 unresolved ticket: FIRST strike applied into end user's account AND the percentage of royalties will be decreased to 15% during the next 5 years.
2 unresolved tickets: SECOND strike applied into end user's account AND the account will be permanently blocked.

d) If your account has been applied with 1 strike type F2 and 1 strike type F3:

The account will be permanently blocked.

4.3. Strike Policy Table
The following table summarizes how its applied our strike policy and it's implications:

Nº Strikes

Severity F1

Severity F2

Severity F3

Severity F2 + F3

(1 Strike F2 + 1 Strike F3)

Account Blocked

Royalties decreased to 50%

Royalties decreased to 15%

Account Blocked

4.4. Blocked Account Policy
As previously displayed, whenever any violation of our Terms of Use, this Anti-Fraud Policy and/or the
agreements we have with DSP happens, the involved account will be blocked.
This will have the following implications:
- If the end user's account is under an investigation started by any DSP for possible violation of rights, then its entire catalog will be in escrow until the investigation process ends.
- Blocked accounts will not be able to access the platform and, therefore, use our services.
- Any amounts due to an End User's Blocked Account will be put in escrow for 5 years to deal with possible economic claims by the person and/or company affected by the irregularity of the end user.

- After 5 years, Sepulchral Silence shall give the respective royalties in escrow the destination provided for by Spanish Law, normally for social causes and aid to the most vulnerable community, among others.

5. Takedowns
We will initiate takedowns of any fraudulent content found in any account, according to section 4. Severity, Strike Policy and Account Blocking.

We, at our sole discretion, may also initiate takedowns for the entire repertoire of any account involved in
irregular activities. Please also note that any content detected as infringing or content guidelines will be taken down proactively by DSP at their sole discretion.

Anti-fraud policy last revision: 24th February 2023. All modifications to this anti-fraud policy has retro-active effects.