Legal

Legal & Marketing Disclaimer

Working draft v0.1-draft — presented for review; final wording follows legal review.

ARCBDS LEGAL & MARKETING DISCLAIMER

Document No.: 13 of 14

Version: 1.0

Effective Date: [●]

Last Updated: [●]

Document Owner: Legal / Compliance / Marketing Compliance

Approved By: [●]

IMPORTANT LEGAL & RISK NOTICE

ARCBDS is a digital asset operating within an evolving digital-capital ecosystem.

Information published by ARCBDS through:

websites;

presentations;

whitepapers;

brochures;

videos;

social media;

advertisements;

events;

webinars;

articles;

interviews;

podcasts;

community channels;

referral materials;

partner materials; or

other promotional communications

must not be interpreted as a guarantee of:

profit;

investment return;

capital preservation;

liquidity;

exchange listing;

token appreciation;

business performance;

future allocation;

ecosystem success;

Participant Protection Reserve settlement; or

any other financial outcome.

ARCBDS may lose some or all of its market value.

ARCBDS may be highly volatile.

ARCBDS may be illiquid.

You may be unable to sell or transfer ARCBDS when you want to do so.

You may lose some or all of the economic value associated with your participation.

The ARCBDS Participant Protection Reserve is a separate conditional contractual mechanism and does not constitute:

guaranteed capital protection;

insurance;

a government protection scheme;

guaranteed redemption;

guaranteed buyback;

guaranteed liquidity; or

guaranteed recovery.

Potential Participants must review the full ARCBDS legal documentation before participating.

1. PURPOSE

This Legal & Marketing Disclaimer establishes:

a. the legal status of ARCBDS marketing materials;

b. required risk disclosures;

c. standards for promotional communications;

d. prohibited marketing representations;

e. regulatory-status disclosures;

f. rules governing Founding Circle marketing;

g. rules governing the Protection Reserve;

h. social-media requirements;

i. KOL and influencer requirements;

j. referral marketing requirements;

k. event requirements;

l. media and press requirements;

m. website marketing requirements;

n. video and audiovisual requirements;

o. comparison and performance requirements;

p. forward-looking statement controls;

q. business-partner representation controls;

r. jurisdiction controls;

s. approval procedures; and

t. marketing recordkeeping requirements.

2. SCOPE

This Disclaimer applies to marketing or promotional content produced, commissioned, authorised, distributed or materially influenced by:

a. ARCBDS;

b. the ARCBDS operating entity;

c. ARCB Investment LLC where applicable;

d. ARCBDS employees;

e. directors;

f. officers;

g. marketing agencies;

h. advertising agencies;

i. consultants;

j. designers;

k. video producers;

l. social-media managers;

m. KOLs;

n. influencers;

o. community leaders;

p. referral partners;

q. event organisers;

r. authorised representatives; and

s. other persons acting on behalf of ARCBDS.

3. COVERED COMMUNICATIONS

Marketing may include:

a. advertisements;

b. invitations;

c. inducements;

d. solicitations;

e. offers;

f. promotional communications;

g. social-media posts;

h. Telegram messages;

i. WhatsApp messages;

j. videos;

k. livestreams;

l. podcasts;

m. presentations;

n. slide decks;

o. brochures;

p. whitepapers;

q. banners;

r. posters;

s. landing pages;

t. email campaigns;

u. event presentations;

v. webinars;

w. media articles;

x. sponsored articles;

y. influencer content;

z. referral presentations;

aa. testimonials;

ab. educational materials containing promotional elements;

ac. comments made by authorised personnel;

ad. community announcements;

ae. QR-code landing pages; and

af. other communications that may reasonably have a promotional purpose.

4. RELATIONSHIP WITH OTHER ARCBDS DOCUMENTS

This Disclaimer should be read together with:

ARCBDS Founding Circle Participation Agreement;

ARCBDS Founding Circle Terms & Conditions;

ARCBDS Risk Disclosure Statement;

ARCBDS Participant Protection Reserve Terms;

ARCBDS Website Terms of Use;

ARCBDS Privacy Policy;

ARCBDS Cookie Policy;

ARCBDS KYC, AML & Sanctions Policy;

ARCBDS Payment, Allocation & Blockchain Transaction Policy;

ARCBDS Cancellation & Refund Policy;

ARCBDS Eligibility & Restricted Jurisdiction Policy;

ARCBDS Electronic Communications & E-Sign Consent;

this Legal & Marketing Disclaimer; and

ARCBDS Referral & Rewards Terms.

Where marketing content conflicts with legally effective contractual documentation, the legally effective documentation shall prevail according to its applicable document hierarchy.

5. MARKETING DOES NOT REPLACE THE AGREEMENT

Marketing content is intended to explain ARCBDS in an accessible manner.

Marketing does not independently create Participant rights unless a legally binding document expressly incorporates the relevant promise.

social-media post;

presentation;

video;

community message;

poster;

banner;

press article; or

verbal presentation

does not amend the Participation Agreement.

6. FAIR, CLEAR AND NOT MISLEADING

All ARCBDS marketing must be:

FAIR

CLEAR

ACCURATE

BALANCED

NOT MISLEADING

in both substance and presentation.

Marketing should consider the overall impression created, not merely whether each isolated sentence is technically correct.

7. SUBSTANCE OVER DISCLAIMER

A disclaimer cannot cure fundamentally misleading marketing.

ARCBDS must not publish a large prominent claim such as:

“CAPITAL GUARANTEED”

and attempt to correct it through small print stating:

“subject to risk.”

The overall marketing message must itself be accurate.

8. PLAIN LANGUAGE

Marketing directed to the general public should use language reasonably understandable to the intended audience.

Technical terminology should be explained where necessary.

Complex legal qualifications must not be deliberately hidden.

9. PROMINENCE

Material risk information must be reasonably:

a. visible;

b. legible;

c. audible where applicable;

d. proximate to the relevant claim; and

e. understandable.

Risk information must not be deliberately obscured through:

a. tiny fonts;

b. low-contrast colours;

c. excessively fast video frames;

d. inaudible speech;

e. hidden footnotes;

f. collapsed text; or

g. unrelated links.

10. BALANCED PRESENTATION

Marketing must not emphasise benefits while concealing material risks.

Where a benefit is communicated, relevant limitations should also be communicated where necessary to avoid a misleading impression.

11. MARKETING IDENTIFICATION

Where promotional intent is not obvious, content should be clearly identified as:

Advertisement;

Promotional Content;

Sponsored by ARCBDS

Paid Partnership with ARCBDS

#Ad

or another appropriate legally recognised disclosure.

The disclosure should be prominent.

88. DISCLOSURE IN BIO IS NOT ENOUGH

A general statement in an influencer's profile that “some posts may be sponsored” does not necessarily replace disclosure on the specific compensated post.

89. KOL PRE-APPROVAL

ARCBDS-sponsored KOL content should be reviewed before publication where required.

No KOL should independently create new tokenomics, protection, price or regulatory claims.

90. KOL RECORDS

ARCBDS should retain:

a. content;

b. publication date;

c. platform;

d. audience;

e. compensation arrangement;

f. disclosure;

g. approval;

h. risk warning; and

i. distribution information

for the required legal period.

91. REFERRAL MARKETING

Referral participants are subject to the same marketing restrictions.

Referral status does not authorise a Participant to:

a. provide investment advice;

b. guarantee returns;

c. vary contractual terms;

d. collect money personally;

e. promise refunds;

f. promise Protection Reserve claims; or

g. make regulatory representations.

92. REFERRAL COMPENSATION DISCLOSURE

Where a referrer may receive value when another Participant joins, that economic relationship should be disclosed where required.

93. REFERRAL INCENTIVES

Any referral incentive relating to virtual-asset participation must undergo Legal and Compliance review before launch.

Where regulator confirmation or approval is required, ARCBDS must obtain it before offering the incentive.

94. INCENTIVES

An incentive must not distract users from consideration of risk.

Examples potentially requiring enhanced review include:

a. joining bonus;

b. token bonus;

c. referral bonus;

d. special allocation;

e. cashback;

f. gift;

g. prize;

h. competition; or

i. limited-time reward.

95. ALIGNMENT REWARD AS COMMERCIAL TERM

The Founding Circle Alignment Reward is part of the approved commercial allocation structure.

Its marketing treatment must nevertheless be reviewed under applicable virtual-asset incentive requirements.

The term should remain:

Additional ARCBDS Allocation

and not be marketed as guaranteed profit.

96. NO CREDIT-BASED PROMOTION

ARCBDS marketing should not encourage Participants to:

a. borrow money;

b. use credit cards;

c. take high-interest loans;

d. mortgage property; or

e. incur debt

to participate.

97. “INVEST WHAT YOU CAN AFFORD TO LOSE”

Risk communications may encourage Participants not to participate with funds they cannot afford to place at risk.

98. EVENTS

ARCBDS event marketing and presentations must comply with applicable rules governing:

a. venue;

b. audience;

c. jurisdiction;

d. onboarding;

e. solicitation;

f. promotional materials;

g. speakers; and

h. sign-up activity.

99. DUBAI / UAE EVENTS

Participation-related activity at events in Dubai or targeting UAE residents must undergo UAE regulatory review before the event.

No event organiser or presenter should assume that an exhibition exemption permits unrestricted onboarding or solicitation.

100. EVENT PRESENTATIONS

Presentation slides must not contain prohibited claims merely because they are shown verbally rather than published online.

101. LIVE SPEAKERS

Speakers must receive approved talking points.

A speaker should not improvise statements such as:

“Your money is guaranteed.”

“The token will definitely list at $1.”

or:

“VARA has approved us.”

unless factually and legally correct.

102. EVENT RECORDS

ARCBDS should retain:

a. presentation decks;

b. brochures;

c. videos;

d. attendee targeting criteria where relevant;

e. event disclaimers;

f. speaker materials; and

g. approvals.

103. INTERNATIONAL EVENTS

Marketing conducted outside the UAE must comply with the laws of the target jurisdiction.

UAE compliance does not automatically make marketing compliant elsewhere.

104. TARGETED ADVERTISING

ARCBDS must ensure that targeted advertising is directed only to audiences legally eligible to receive it.

Where a product or service is restricted to a particular investor class, advertising should not knowingly target the general public.

105. GEO-BLOCKING

Geo-blocking or location-based filtering may be used where required to prevent marketing or participation in prohibited jurisdictions.

106. VPN CIRCUMVENTION

ARCBDS must not encourage users to bypass geo-restrictions using:

a. VPNs;

b. proxies;

c. false addresses; or

d. nominee Accounts.

107. TRANSLATED MARKETING

All translated marketing must preserve:

a. meaning;

b. risk warnings;

c. limitations;

d. legal qualifiers; and

e. sponsorship disclosures.

108. MANDARIN MARKETING

Chinese-language marketing must not use stronger profit, protection or guarantee language than the approved English version.

109. MACHINE TRANSLATION

Machine translation may assist production but material legal or financial marketing claims should receive human review before publication.

110. AI-GENERATED CONTENT

ARCBDS may use generative AI in marketing production.

AI-generated content must be reviewed for:

a. factual accuracy;

b. fabricated claims;

c. fake partner names;

d. fake statistics;

e. regulatory misstatements;

f. misleading imagery;

g. inaccurate tokenomics;

h. prohibited promises; and

i. intellectual-property issues.

111. AI AVATARS

An AI avatar presenter must not be presented as:

a. a real regulator;

b. a real executive;

c. a real investor;

d. a real satisfied Participant; or

e. another real person

unless appropriate disclosure and permission exist.

112. SYNTHETIC TESTIMONIALS

ARCBDS must not generate fictitious “customers” using AI and present their statements as genuine Participant testimonials.

113. GENERATED BUSINESS IMAGERY

Conceptual images of:

a. offices;

b. businesses;

c. infrastructure;

d. cities;

e. institutional facilities; or

f. investment assets

should not be used in a manner falsely suggesting ARCBDS owns those specific assets.

114. BRANDING IMAGERY

Abstract or cinematic visuals may be used as branding.

Where necessary, conceptual imagery may be identified as:

Illustrative Visual

or:

Conceptual Representation

to prevent factual misunderstanding.

115. COMPETITOR COMPARISONS

Any comparison with another project or product must be:

a. accurate;

b. current;

c. meaningful;

d. fairly presented; and

e. supportable.

ARCBDS must not publish deliberately misleading comparisons.

116. SUPERLATIVE CLAIMS

Claims such as:

world's first;

safest;

biggest;

best;

only;

most secure;

number one; or

industry leading

must be supportable.

Where evidence is unavailable, such wording should be avoided.

117. SECURITY CLAIMS

ARCBDS may describe verified security measures.

It must not imply absolute security.

118. FIXED SUPPLY DOES NOT MEAN FIXED VALUE

Marketing must clearly distinguish:

FIXED SUPPLY

from:

FIXED PRICE

ARCBDS does not have a guaranteed fixed market price merely because maximum supply is fixed.

119. THE BRIDGE

ARCBDS may use:

THE BRIDGE

as its strategic ecosystem concept connecting traditional business and digital capital.

This phrase describes intended ecosystem architecture and does not by itself create legal rights to underlying businesses.

120. SLOGANS

Brand slogans such as:

ONE FOR ALL, ALL IN ONE

may be used as brand expressions.

A slogan does not override the legal terms.

121. WHITEPAPER

The Whitepaper may explain:

a. project concept;

b. architecture;

c. tokenomics;

d. ecosystem strategy;

e. roadmap; and

f. intended utility.

It must not be treated as replacing required legal agreements or regulatory disclosures.

122. WHITEPAPER UPDATES

Material changes to the project should be reflected in updated public documentation where required.

Previous versions should be retained where legally necessary.

123. WEBSITE FAQ

FAQ responses must remain consistent with official legal documents.

An FAQ must not simplify a conditional protection mechanism into:

“Yes, your capital is guaranteed.”

124. CUSTOMER SUPPORT

Support personnel should use approved explanations.

Support personnel must not:

a. provide guaranteed return projections;

b. provide personal investment advice;

c. promise listings;

d. promise Reserve Claim approval; or

e. alter contractual terms.

125. PRIVATE MESSAGES

The fact that a statement is sent privately does not make it acceptable.

Authorised ARCBDS personnel must follow these rules in:

a. DMs;

b. WhatsApp;

c. Telegram;

d. email;

e. voice notes; and

f. private presentations.

126. VERBAL PROMISES

Participants should not rely on verbal promises inconsistent with official documents.

Unauthorised oral representations do not amend the Participant's contract.

127. SALES TRAINING

Persons communicating with prospective Participants should receive training concerning:

a. token terms;

b. risks;

c. Protection Reserve limits;

d. prohibited claims;

e. regulatory status;

f. jurisdiction restrictions;

g. refund policy; and

h. referral rules.

128. NO PERSONAL INVESTMENT RECOMMENDATION

Unless appropriately licensed and authorised, ARCBDS representatives should not tell an individual:

“You should invest US$50,000.”

“Legacy is definitely the best investment for you.”

or otherwise give personalised regulated investment advice.

129. EXPLAINING CATEGORIES

Representatives may factually explain differences among:

Access;

Growth; and

Legacy

without guaranteeing which will produce the best economic outcome.

130. MARKETING TO VULNERABLE OR INEXPERIENCED PERSONS

Marketing must not exploit:

a. lack of financial knowledge;

b. economic distress;

c. desperation;

d. age-related vulnerability;

e. misunderstanding of digital assets; or

f. other vulnerability.

131. EASY-MONEY MESSAGING

Messaging such as:

“Anyone can become rich.”

“No knowledge needed to make money.”

“Easy passive income.”

or equivalent claims should not be used.

132. EMPLOYMENT AND PART-TIME LANGUAGE

ARCBDS participation must not be marketed as:

a. employment;

b. a job;

c. salary;

d. guaranteed part-time income; or

e. guaranteed livelihood

unless an actual employment relationship exists.

133. MEDIA INTERVIEWS

Executives participating in interviews should avoid introducing unapproved:

a. token prices;

b. listing dates;

c. guarantees;

d. partner claims;

e. reserve mechanics; or

f. regulatory claims.

134. PUBLIC SPEAKING

Public-speaking scripts and presentations concerning Founding Circle participation should receive Legal/Compliance review where appropriate.

135. SOCIAL MEDIA BIOS

Official bios should accurately describe the project.

A bio should not state:

“Guaranteed Digital Investment Platform”

or another prohibited description.

136. HASHTAGS

Hashtags form part of the overall marketing message.

Problematic examples may include:

#GuaranteedProfit

#RiskFree

#100xGuaranteed

#GuaranteedIncome

Approved general branding hashtags may include appropriate project and ecosystem terms.

137. HEADLINES

A disclaimer cannot fully correct a misleading headline.

Headlines must independently avoid materially false impressions.

138. THUMBNAILS

Video and social-media thumbnails form part of marketing.

Thumbnails must not contain misleading statements such as:

“100X CONFIRMED”

when the actual video contains a small disclaimer.

139. BANNERS

Banner space limitations do not justify misleading claims.

If a message requires substantial qualification to be fair, ARCBDS should use a more suitable communication format.

140. QR CODES

Where a physical advertisement uses a QR code linking to a detailed page, the advertisement must still satisfy applicable headline and risk-warning requirements.

The QR code cannot be used merely to hide material disclosures.

141. RISK WARNING PLACEMENT

Risk warnings should be reasonably close to the marketing claim.

A risk warning buried several clicks away may be insufficient for a prominent high-risk claim.

142. DISCLAIMERS IN VIDEO

For video:

a. disclaimer font must be readable;

b. screen duration must be sufficient;

c. spoken disclaimers must be understandable;

d. background music must not obscure them; and

e. mobile presentation should be considered.

143. SMALL PRINT

Small print may explain details.

It may not contradict the main message.

144. REGULATORY DISCLAIMER

Where appropriate and factually correct, marketing may state:

Regulatory status and availability vary by jurisdiction. Access to ARCBDS materials does not mean participation is legally available in your location.

145. JURISDICTION DISCLAIMER

A general jurisdiction warning may state:

ARCBDS participation is subject to eligibility, KYC/KYB, sanctions screening, jurisdictional restrictions and Applicable Law. Services are not available in every jurisdiction.

146. NO OFFER WHERE UNLAWFUL

Marketing should include where appropriate:

Nothing in this communication constitutes an offer, solicitation or invitation in a jurisdiction where such activity would be unlawful.

147. LEGAL CLASSIFICATION

Until ARCBDS's legal classification is conclusively established for the relevant jurisdiction, marketing must not definitively state:

“ARCBDS is not a security anywhere.”

or:

“ARCBDS is legally a share.”

Classification may differ between jurisdictions.

148. TAX

Marketing must not promise:

a. tax-free returns;

b. tax exemptions;

c. tax avoidance; or

d. guaranteed tax treatment

without legally supportable jurisdiction-specific advice.

149. NO LEGAL OR TAX ADVICE

General marketing information does not constitute personal:

a. legal;

b. tax;

c. financial; or

d. investment advice.

150. PROFESSIONAL ADVICE

Potential Participants may be encouraged to obtain independent professional advice where appropriate.

151. DATA PRIVACY IN MARKETING

Marketing databases and campaigns must comply with applicable:

a. privacy law;

b. electronic communications law;

c. cookie rules; and

d. marketing-consent requirements.

152. PURCHASED MARKETING LISTS

ARCBDS should not use third-party personal-data marketing lists without appropriate due diligence concerning:

a. lawful collection;

b. consent;

c. jurisdiction;

d. data source; and

e. opt-out rights.

153. MARKETING OPT-OUT

Optional marketing recipients should be provided with an appropriate opt-out mechanism where required.

154. UNSUBSCRIBE

Unsubscribing from marketing does not prevent ARCBDS from sending:

a. contractual;

b. security;

c. transaction;

d. legal; or

e. regulatory communications.

155. MARKETING APPROVAL

Material ARCBDS marketing should follow an approval process.

Approval levels may vary according to risk.

156. LOW-RISK BRAND CONTENT

Examples may include:

a. generic brand visuals;

b. non-financial company announcements;

c. team updates;

d. technology education without product inducement; and

e. factual ecosystem news.

These may follow streamlined approval.

157. HIGH-RISK MARKETING CONTENT

Legal/Compliance approval should be mandatory for content concerning:

a. token price;

b. tokenomics;

c. Founding Circle packages;

d. Alignment Rewards;

e. Protection Reserve;

f. exchange listing;

g. regulation;

h. custody;

i. insurance;

j. returns;

k. financial projections;

l. referral rewards;

m. incentives;

n. jurisdictional offers; or

o. Participant testimonials involving results.

158. PROHIBITED CLAIM OVERRIDE

No executive, founder, salesperson or marketing director may instruct personnel to publish a prohibited claim merely because it is commercially attractive.

159. MARKETING EVIDENCE FILE

For material claims, ARCBDS should maintain evidence supporting:

a. statistics;

b. partnerships;

c. licences;

d. tokenomics;

e. business metrics;

f. audits;

g. custody;

h. insurance;

i. regulatory statements; and

j. other verifiable claims.

160. MARKETING RECORDKEEPING

Where applicable VARA requirements apply, marketing records and distribution details should be retained for at least:

EIGHT (8) YEARS

from the last date the relevant marketing is conducted.

Longer retention may apply where legally required.

161. RECORD CONTENT

Marketing records should include:

a. final content;

b. draft where relevant;

c. publication date;

d. platform;

e. target audience;

f. target jurisdiction;

g. paid distribution;

h. KOL or sponsor;

i. approval;

j. supporting evidence;

k. risk warning;

l. withdrawal date; and

m. amendment history.

162. SOCIAL-MEDIA EDITS

Where a material social-media claim is corrected, ARCBDS should retain:

a. original version;

b. corrected version;

c. date;

d. reason; and

e. remediation actions.

163. WITHDRAWAL OF NON-COMPLIANT CONTENT

If marketing is found to be inaccurate or non-compliant, ARCBDS should promptly consider:

a. removal;

b. correction;

c. suspension;

d. clarification;

e. affected-user notification;

f. regulator notification where required; and

g. retraining.

164. CORRECTIVE STATEMENT

Where a misleading claim has materially circulated, removal alone may be insufficient.

A corrective communication may be necessary.

165. THIRD-PARTY UNAUTHORISED MARKETING

ARCBDS may request removal of unauthorised third-party content that:

a. misrepresents ARCBDS;

b. promises guaranteed returns;

c. uses logos without authority;

d. conducts scams;

e. impersonates ARCBDS; or

f. falsely claims partnership.

166. COMMUNITY-GENERATED CONTENT

ARCBDS does not automatically control all independent Participant speech.

However, where ARCBDS:

a. pays;

b. instructs;

c. approves;

d. materially edits;

e. republishes; or

f. otherwise adopts

content, additional marketing obligations may arise.

167. REPOSTING

ARCBDS should not repost an independent user's prohibited claim merely because the original user made it.

Reposting may create an impression of endorsement.

168. COMMENTS FROM FOUNDERS OR EXECUTIVES

Statements by senior personnel can reasonably be attributed significant weight.

Executives must therefore avoid informal speculative statements likely to be interpreted as Company commitments.

169. CONFIDENTIAL INFORMATION

Marketing must not disclose:

a. confidential partner negotiations;

b. Participant Personal Data;

c. unreleased business information;

d. security-sensitive wallet information;

e. confidential regulatory correspondence; or

f. other protected information

without authority.

170. INTELLECTUAL PROPERTY

Marketing must respect:

a. copyright;

b. trademarks;

c. publicity rights;

d. third-party images;

e. music rights;

f. stock-asset licences; and

g. other intellectual-property rights.

171. CELEBRITIES AND PUBLIC FIGURES

ARCBDS must not use a celebrity or public figure's:

a. image;

b. voice;

c. likeness;

d. name; or

e. synthetic replica

to imply endorsement without permission.

172. DEEPFAKES

AI-generated or altered content must not falsely depict a person endorsing ARCBDS.

173. MARKET MANIPULATION

Marketing must not be designed to artificially manipulate ARCBDS market activity through:

a. false rumours;

b. fabricated exchange news;

c. fake partnerships;

d. coordinated deceptive hype;

e. fake trading volume claims; or

f. misleading scarcity claims.

174. “SOLD OUT” CLAIMS

Claims such as:

“90% SOLD OUT”

must be based on accurate programme data.

ARCBDS must not manufacture false scarcity.

175. PARTICIPATION COUNTERS

Website counters displaying:

a. tokens allocated;

b. Participants joined;

c. remaining allocation; or

d. funds raised

must reflect genuine data or be clearly identified as illustrative.

176. LIVE TRANSACTION FEEDS

A displayed transaction feed must not contain fabricated transactions designed to create urgency or social proof.

177. FAKE REVIEWS

ARCBDS must not purchase or manufacture fake positive reviews.

178. NEGATIVE REVIEWS

ARCBDS may respond factually to criticism but should not retaliate against legitimate users.

179. COMPLAINT DISCLOSURE

Complaints should not be selectively hidden where doing so would create a materially false public impression, subject to moderation policies and legal rights.

180. OFFICIAL MARKETING CHANNELS

ARCBDS should maintain an official register of:

a. websites;

b. social-media accounts;

c. Telegram channels;

d. email domains;

e. marketing partners;

f. KOLs; and

g. approved regional channels.

181. MARKETING FROM UNOFFICIAL CHANNELS

A person should not rely on an unofficial channel as an authoritative source of ARCBDS terms.

182. CONTACT VERIFICATION

Potential Participants should verify material claims through:

Official Website:

www.arcbds.com

and applicable official legal documents.

183. NO PERSONAL WALLET COLLECTION

Marketing representatives must not instruct Participants to send Founding Circle Contributions to:

a. community leader wallets;

b. referral wallets;

c. personal employee wallets; or

d. unofficial collection wallets.

184. PAYMENT CTA

Where legally permitted, any payment or participation call-to-action must link to the official participation process and required legal disclosures.

Where Applicable Law prohibits calls to acquire a Virtual Asset in marketing, ARCBDS must use a compliant informational approach instead.

185. UAE VIRTUAL-ASSET MARKETING

Where ARCBDS marketing is:

a. conducted in the UAE; or

b. targets the UAE,

it must comply with applicable UAE and Dubai virtual-asset marketing rules.

Legal and Compliance approval is required before launching UAE-facing acquisition or participation campaigns.

186. MARKETING OF VA ACTIVITIES

Where a communication promotes a regulated Virtual Asset Activity, the activity must only be marketed by or on behalf of an appropriately authorised entity where Applicable Law requires this.

187. MARKETING OF ARCBDS ITSELF

Where applicable Dubai rules treat the communication as marketing of a Virtual Asset itself, ARCBDS must comply with the specific requirements applicable to such token marketing, including restrictions concerning direct calls to acquire the asset.

188. UAE RISK DISCLAIMER

Where required for UAE-facing ARCBDS marketing, a prominent disclaimer should be approved by UAE regulatory counsel and may include substantially:

VIRTUAL ASSET RISK WARNING

Virtual assets may lose their value in part or in full and are subject to extreme volatility. You can lose all or part of the money or other value associated with your participation. Virtual assets may be illiquid and may not always be transferable.

The exact regulator-required wording in effect at publication shall control.

189. FINANCIAL PROTECTION WORDING

Because applicable virtual-asset marketing rules may impose specific statements concerning financial protection, ARCBDS must obtain regulatory legal approval before combining mandatory regulatory risk wording with descriptions of the Participant Protection Reserve.

The existence of a private contractual Reserve must not be used to imply:

a. statutory investor protection;

b. deposit protection;

c. insurance;

d. regulatory compensation; or

e. guaranteed recovery.

190. EVENTS IN DUBAI

Where an entity is not appropriately licensed to provide the relevant VA Activity in Dubai, any event-related marketing must comply strictly with applicable event exemptions and restrictions.

No event exemption should be interpreted as authorising unlicensed regulated activity.

191. NO UAE ONBOARDING WITHOUT LEGAL AUTHORITY

ARCBDS must not allow UAE residents to be onboarded into a regulated activity merely because they attended an event, unless the applicable legal authority exists.

192. INCENTIVE REGULATORY CONFIRMATION

Where applicable VARA rules require compliance confirmation before a monetary or non-monetary virtual-asset incentive is offered, the incentive must not launch until the required confirmation has been obtained.

193. TARGET AUDIENCE

Marketing must be appropriate to its target audience.

Institutional materials should not automatically be repurposed for inexperienced retail audiences without review.

194. RETAIL RISK COMMUNICATION

Retail-facing materials may require more prominent explanation of:

a. loss risk;

b. volatility;

c. liquidity;

d. blockchain risks;

e. token release restrictions; and

f. absence of guaranteed outcomes.

195. INSTITUTIONAL MATERIAL

Institutional marketing may contain greater technical detail but must remain accurate and balanced.

Sophisticated audiences do not justify false claims.

196. COMMUNICATIONS WITH MEDIA

Only authorised spokespersons should provide official statements concerning:

a. token economics;

b. regulatory status;

c. Protection Reserve;

d. fundraising;

e. partnerships;

f. token listing; and

g. financial matters.

197. CRISIS COMMUNICATION

Following a:

a. cybersecurity incident;

b. token-price disruption;

c. regulatory event;

d. partner failure;

e. Reserve issue; or

f. material technical failure,

public communication must prioritise accuracy over marketing optics.

198. CORRECTION OF FALSE RUMOURS

ARCBDS may correct false market rumours.

However, correction must itself be accurate and must not disclose confidential information improperly.

199. MARKET-SENSITIVE INFORMATION

Personnel must not selectively disclose material confidential information to favoured Participants, KOLs or traders where doing so would violate Applicable Law or market-integrity rules.

200. PERSONAL RESPONSIBILITY OF MARKETING PARTNERS

Any person authorised to market ARCBDS must comply with:

a. approved messaging;

b. applicable law;

c. this Disclaimer;

d. referral terms; and

e. written marketing instructions.

201. BREACH BY MARKETING PARTNER

A marketing partner who makes prohibited claims may face:

a. content removal;

b. retraining;

c. suspension;

d. termination;

e. reward cancellation where contractually permitted;

f. indemnity claims where applicable; and

g. regulatory or legal reporting where required.

202. NO AUTHORITY TO MODIFY TERMS

Marketing personnel cannot:

a. change allocation price;

b. change Alignment Reward;

c. change release schedule;

d. promise additional rights;

e. change Refund rights;

f. change Protection Reserve rules; or

g. waive KYC.

Only authorised written programme documents may establish such terms.

203. DISCLAIMERS DO NOT CREATE RIGHTS

A disclaimer explains limitations.

It does not itself grant:

a. token ownership;

b. Refund rights;

c. insurance rights;

d. Reserve rights;

e. business equity; or

f. regulatory rights.

Those rights arise only under applicable legal documents and law.

204. LEGAL REVIEW

This Disclaimer does not replace jurisdiction-specific advice.

ARCBDS should obtain external legal review before material launches in new markets.

205. CHANGES TO REGULATION

Virtual-asset marketing regulation evolves.

ARCBDS shall update this framework where required.

The rules in effect at the time marketing is conducted shall govern.

206. CHANGES TO THIS DISCLAIMER

This Disclaimer may be amended because of:

a. regulatory changes;

b. legal changes;

c. product changes;

d. tokenomics changes;

e. Protection Reserve changes;

f. business-model changes;

g. marketing-channel changes; or

h. compliance improvements.

207. VERSION CONTROL

ARCBDS should maintain:

a. Disclaimer version;

b. effective date;

c. previous version;

d. change summary;

e. approval record; and

f. distribution record.

208. GOVERNING LAW

This Disclaimer shall be interpreted consistently with the governing law of the applicable ARCBDS agreement and any mandatory marketing law applicable to the communication.

Primary Governing Law: [●]

209. CONTACT

ARCBDS LEGAL & MARKETING COMPLIANCE

Official Website:

www.arcbds.com

Legal Entity:

[●]

Legal:

[●]

Compliance:

[●]

Marketing Compliance:

[●]

Participant Support:

[●]

Registered Address:

[●]

SCHEDULE 1

MASTER PUBLIC DISCLAIMER

The following may be used as the long-form public disclaimer, subject to jurisdiction-specific adjustment:

ARCBDS LEGAL DISCLAIMER

ARCBDS is a digital asset within the ARCBDS digital-capital ecosystem.

Information contained on this website or in related materials is provided for general information and does not constitute personal financial, investment, legal or tax advice.

ARCBDS involves substantial risk. The value of ARCBDS may rise or fall and may become highly volatile or illiquid. You may lose some or all of the economic value associated with your participation.

Founding Circle allocation prices are used to calculate ARCBDS entitlement and do not guarantee future market price.

Alignment Rewards are additional ARCBDS allocations and are not interest, dividends or guaranteed financial returns.

The involvement of real-world businesses in the ARCBDS ecosystem does not automatically mean that ARCBDS holders own shares, assets, revenues or profits of those businesses.

The ARCBDS Participant Protection Reserve is a separate, conditional and finite contractual mechanism. It is not insurance, does not guarantee capital, does not guarantee liquidity, does not guarantee market price, and does not guarantee that every claim will be approved or fully settled.

Exchange listing, liquidity, ecosystem development, partnerships and future features are not guaranteed.

ARCBDS participation is subject to KYC/KYB, sanctions screening, jurisdictional eligibility and Applicable Law.

Services are not available in every jurisdiction.

Please read the ARCBDS Founding Circle Participation Agreement, Risk Disclosure Statement and other applicable legal documents before participating.

SCHEDULE 2

SHORT WEBSITE DISCLAIMER

RISK WARNING

ARCBDS is a digital asset and involves substantial risk. Its value may rise or fall, and you may lose some or all of the economic value associated with your participation. Liquidity and exchange listing are not guaranteed. The Participant Protection Reserve is conditional, finite and subject to separate Terms; it does not constitute guaranteed capital protection.

Read the full Risk Disclosure before participating.

SCHEDULE 3

SOCIAL MEDIA DISCLAIMER

For appropriate promotional posts:

Risk Warning: ARCBDS is a digital asset. Its value can rise or fall and liquidity is not guaranteed. You may lose some or all of the value associated with your participation. Terms, eligibility and jurisdiction restrictions apply.

Where required:

Advertisement / Promotional Content

SCHEDULE 4

VIDEO DISCLAIMER

SHORT VIDEO VERSION

ARCBDS involves digital-asset risk. Value and liquidity are not guaranteed. Review the full Risk Disclosure and applicable terms before participating.

EXTENDED VIDEO VERSION

ARCBDS is a digital asset and may experience significant volatility or illiquidity. You may lose some or all of the economic value associated with participation. Allocation prices and Alignment Rewards do not guarantee financial returns. The Participant Protection Reserve is conditional and does not guarantee capital or liquidity. Eligibility and jurisdiction restrictions apply.

SCHEDULE 5

EVENT DISCLAIMER

ARCBDS EVENT NOTICE

Information presented during this event is for general informational and promotional purposes and must be read together with applicable ARCBDS legal documentation.

Nothing presented guarantees:

returns;

token appreciation;

liquidity;

listing;

capital preservation; or

Protection Reserve settlement.

ARCBDS participation may not be available to all attendees and remains subject to KYC/KYB, jurisdiction restrictions, regulatory requirements and Applicable Law.

Where required by local law, no participation or onboarding will take place at this event.

SCHEDULE 6

FOUNDING CIRCLE DISCLAIMER

FOUNDING CIRCLE RISK NOTICE

The ARCBDS Founding Circle is the initial structured participation stage of the ARCBDS ecosystem.

Fixed allocation prices determine ARCBDS entitlement and are not guarantees of future market price.

Alignment Rewards are additional ARCBDS allocations and are not guaranteed profits.

Applicable Cliffs and release schedules restrict availability of ARCBDS.

The value of ARCBDS may decrease substantially, liquidity may be unavailable and exchange listing is not guaranteed.

Review the Participation Agreement and Risk Disclosure before participating.

SCHEDULE 7

PROTECTION RESERVE MARKETING DISCLAIMER

PARTICIPANT PROTECTION RESERVE

The ARCBDS Participant Protection Reserve is intended as a limited conditional mechanism for qualifying circumstances under separate Protection Reserve Terms.

The reserve-funding framework currently contemplates an amount equivalent to 20% of Qualifying Founding Circle Purchase Funding.

This does not mean:

20% of your Contribution is guaranteed;

every Claim receives 20%;

ARCBDS has a 20% price floor;

your capital is guaranteed;

ARCBDS is insured;

ARCBDS is guaranteed liquid; or

ARCBDS is subject to an unconditional buyback.

Claims are subject to eligibility, verification, applicable limits and available Reserve assets.

SCHEDULE 8

PROHIBITED CLAIMS

The following wording must not be used unless Legal confirms a genuine lawful basis:

RETURNS

❌ Guaranteed Profit

❌ Guaranteed Return

❌ Guaranteed ROI

❌ Fixed Income

❌ Guaranteed Passive Income

❌ Guaranteed Yield

SAFETY

❌ Risk Free

❌ Zero Risk

❌ 100% Safe

❌ Cannot Lose

❌ No Possibility of Loss

CAPITAL

❌ Capital Guaranteed

❌ Principal Guaranteed

❌ 100% Capital Protected

LIQUIDITY

❌ Guaranteed Liquidity

❌ Sell Anytime Guaranteed

❌ Instant Exit Guaranteed

BUYBACK

❌ Guaranteed Buyback

❌ ARCB Will Always Buy It Back

PRICE

❌ Guaranteed Listing Price

❌ Guaranteed Floor Price

❌ Guaranteed Appreciation

❌ Guaranteed 10X / 100X

EXCHANGES

❌ Guaranteed Exchange Listing

❌ Confirmed Listing unless genuinely confirmed

REGULATION

❌ Government Guaranteed

❌ VARA Endorsed

❌ Regulator Approved Investment

❌ Licensed by VARA unless factually true

INSURANCE

❌ Fully Insured

❌ ARC Insurance Guarantees Your ARCBDS

❌ Insurance-Protected Capital

unless actual valid insurance documentation expressly supports the claim.

SCHEDULE 9

APPROVED POSITIONING LANGUAGE

Subject to factual accuracy and jurisdictional review:

✅ Digital Capital Ecosystem

✅ Connecting the Real Economy with Digital Capital

✅ The Bridge

✅ Built Around Business

✅ Fixed Maximum Supply

✅ Real-World Business Ecosystem

✅ Founding Circle

✅ Initial Structured Participation Stage

✅ Fixed Allocation Price

✅ Additional ARCBDS Alignment Reward

✅ Linear Daily Release

✅ Participant Protection Reserve

✅ Subject to Eligibility and Terms

✅ KYC Required

✅ Market Value May Rise or Fall

✅ Liquidity Is Not Guaranteed

✅ Exchange Listing Is Not Guaranteed

✅ No Fixed ROI

✅ No Guaranteed Return

✅ Conditional Reserve Mechanism

SCHEDULE 10

MARKETING CLAIM APPROVAL MATRIX

Claim Type

Marketing

Compliance

Legal

Senior Approval

Brand slogan

Yes

As required

Ecosystem description

Yes

As required

Founding Circle terms

Yes

As required

Token price / allocation

Yes

As required

Alignment Reward

Yes

As required

Protection Reserve

Yes

Mandatory

Yes

Insurance

Yes

Mandatory

Yes

Regulatory status

No independent change

Mandatory

Yes

Exchange listing

Yes

Mandatory

Yes

Partner announcement

Yes

As required

Yes

As required

Financial projection

Yes

Mandatory

Yes

Incentive

Yes

Mandatory

Yes

Referral compensation

Yes

Mandatory

Yes

KOL campaign

Yes

Mandatory

As required

New jurisdiction

Yes

Mandatory

Yes

SCHEDULE 11

MARKETING APPROVAL FORM

Campaign: [●]

Content: [●]

Channel: [●]

Jurisdiction: [●]

Target Audience: [●]

Publication Date: [●]

Does Content Mention?

☐ Founding Circle

☐ Allocation Price

☐ Alignment Reward

☐ Token Price

☐ Protection Reserve

☐ Insurance

☐ Exchange Listing

☐ Regulatory Status

☐ Partners

☐ Business Assets

☐ Performance

☐ Projection

☐ Incentive

☐ Referral Reward

☐ KOL / Influencer

☐ Participant Testimonial

Evidence Attached

[●]

Risk Warning Included

Yes / No

Jurisdiction Approved

Yes / No

Approval

Marketing: [●]

Compliance: [●]

Legal: [●]

Senior Management: [●]

SCHEDULE 12

INFLUENCER / KOL AGREEMENT REQUIREMENTS

Every compensated KOL arrangement should require the KOL to:

☐ Disclose sponsorship clearly

☐ Use approved facts

☐ Include required risk warning

☐ Avoid guaranteed return claims

☐ Avoid personal investment advice

☐ Avoid unauthorised regulatory claims

☐ Avoid unauthorised listing claims

☐ Avoid unauthorised Protection Reserve claims

☐ Avoid false urgency/FOMO

☐ Follow jurisdiction restrictions

☐ Submit material content for approval

☐ Retain or provide publication records

☐ Correct misleading content promptly

☐ Stop campaign if instructed for compliance reasons

SCHEDULE 13

MARKETING RECORD

Campaign ID: [●]

Campaign Name: [●]

Content Version: [●]

Platform: [●]

Target Jurisdiction: [●]

Target Audience: [●]

Start Date: [●]

End Date: [●]

Risk Warning: [●]

Regulatory Disclosure: [●]

Sponsor / KOL: [●]

Compensation: [●]

Approval: [●]

Evidence File: [●]

Distribution Record: [●]

Archived: [●]

Retention Until: [●]

SCHEDULE 14

MARKETING COMPLIANCE CHECKLIST

Before publication:

☐ Is the content factually accurate?

☐ Is it fair and balanced?

☐ Is it clearly promotional where required?

☐ Is the target jurisdiction approved?

☐ Is the target audience eligible?

☐ Are all token terms current?

☐ Is regulatory status correct?

☐ Are partner claims supported?

☐ Are business claims supported?

☐ Are statistics sourced?

☐ Is the risk warning prominent?

☐ Does the content avoid guaranteed returns?

☐ Does it avoid “risk-free”?

☐ Does it avoid guaranteed liquidity?

☐ Does it avoid guaranteed listing?

☐ Does it avoid guaranteed buyback?

☐ Does it correctly describe the Protection Reserve?

☐ Does it avoid implying insurance?

☐ Does it avoid FOMO tied to profits?

☐ Are real deadlines genuine?

☐ Is sponsored content disclosed?

☐ Is KOL compensation disclosed?

☐ Have incentives received required approval?

☐ Are translations accurate?

☐ Are AI-generated facts verified?

☐ Are images non-misleading?

☐ Is there no fake social proof?

☐ Are logos authorised?

☐ Is personal data handled lawfully?

☐ Has Compliance approved where required?

☐ Has Legal approved where required?

SCHEDULE 15

MARKETING RED-FLAG WORDS

Any content containing the following should automatically trigger enhanced review:

guaranteed

risk-free

safe investment

fixed ROI

passive income

profit

capital protection

insured

insurance

buyback

liquidity guarantee

listing confirmed

100x

10x

price target

government approved

VARA approved

regulated

licensed

equity

shareholder

dividend

revenue share

asset backed

reserve backed

stable

stablecoin

no loss

last chance

don't miss out

get rich

financial freedom

retire

These words are not all absolutely prohibited in every context, but they require careful review.

SCHEDULE 16

ARCBDS MARKETING HIERARCHY

Marketing teams must work from the following authority hierarchy:

1. Applicable Law / Regulatory Requirements

↓

2. Final Legal Structure

↓

3. Participation Agreement

↓

4. Risk Disclosure

↓

5. Protection Reserve Terms

↓

6. Founding Circle Terms

↓

7. Approved Whitepaper

↓

8. Approved Marketing Master Copy

↓

9. Campaign Copy

↓

10. Community / KOL Content

Lower levels must never contradict higher levels.

SCHEDULE 17

FOUNDING CIRCLE WEBSITE FOOTER

A suitable footer disclosure may state:

ARCBDS is a digital asset and involves substantial risk. Its value may rise or fall and liquidity is not guaranteed. Fixed Founding Circle allocation prices do not guarantee future market prices. Alignment Rewards are additional token allocations, not guaranteed returns. The Participant Protection Reserve is conditional, finite and subject to separate Terms. Participation is subject to KYC/KYB, eligibility, jurisdiction restrictions and Applicable Law.

SCHEDULE 18

MEDIA ARTICLE DISCLOSURE

Where an article is paid:

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