KPUGI CREATOR COMPLIANCE, QUALITY STANDARDS & OPERATING RULES

Document Identifier: KPUGI-DOC-CR-2026-V2.4
Classification: Official Source of Truth & Regulatory Compliance Manual
Effective Date: September 1, 2026
Applicable Jurisdiction: Federal Republic of Nigeria & International Cross-Border Deployments
Governing Entities: Kpugi Technologies Ltd., Advertising Regulatory Council of Nigeria (ARCON), Federal Competition and Consumer Protection Commission (FCCPC), Central Bank of Nigeria (CBN/NIBSS), Nigeria Data Protection Commission (NDPC).

PREAMBLE & BINDING NATURE

This document constitutes the definitive, legally binding Source of Truth, Operating Rules, and Compliance Framework for all digital content creators, influencers, videographers, and brand ambassadors (collectively referred to as "Creators") registered on the Kpugi marketplace platform ("Kpugi", "Platform", "We", "Us").

By creating an account, connecting social media handles, claiming campaign briefs ("Drops"), uploading content, or requesting payouts, you acknowledge that you have read, understood, and irrevocably agreed to comply with all provisions herein.

Failure to adhere to these rules constitutes a material breach of contract, resulting in immediate disciplinary consequences up to and including audit disqualification, earnings forfeiture, wallet freezing, account termination, and formal blacklisting across participating advertiser networks.

SECTION 1: PLATFORM OPERATING MODEL & RELATIONSHIP

1.1 Performance-Based Pay-Per-View (CPM) Model

Kpugi operates exclusively on an automated, verified, performance-based advertising model denominated in Cost-Per-Mille (CPM—earnings per 1,000 verified organic impressions). Unlike traditional influencer marketing contracts predicated on upfront guarantees, creator compensation on Kpugi is directly proportional to authentic view volume delivered to the advertiser's campaign.

1.2 Independent Contractor Status

Nothing in these Rules or in your participation on Kpugi establishes an employment relationship, joint venture, partnership, or agency between you and Kpugi or any advertiser. Creators operate strictly as independent contractors responsible for their own tax filings, business expenses, mobile data, equipment, and regulatory permits.

1.3 The Open Brief Marketplace (Zero Gatekeeping)

Kpugi believes in radical democratisation of monetisation. Campaign drops are open to all verified creators on the platform who satisfy specific drop demographic tags. Kpugi does not employ manual creator selection gatekeepers; any creator who has completed identity verification and connected their social channels may claim an active drop until the advertiser's total view budget is exhausted.

SECTION 2: CREATOR ELIGIBILITY, IDENTITY & ACCOUNT SECURITY

2.1 Minimum Age & Capacity

• All creators must be at least eighteen (18) years of age at the time of registration.
• Creators aged sixteen (16) to seventeen (17) may participate solely with documented, written consent from a parent or legal guardian who must co-sign KYC documentation and own the registered bank account.

2.2 Account Ownership & Identity KYC (Know Your Customer)

• One Human, One Account: A creator may register and operate exactly one (1) Kpugi creator profile. Registering multiple accounts, creating dummy accounts, or acting as an unregistered agency intermediary without written enterprise authorization is strictly forbidden.
• Identity Verification: All creators must successfully complete electronic Know Your Customer (eKYC) verification via Didit before initiating their first withdrawal. Acceptable forms of government-issued identification are:
  1. Nigerian National Identification Number (NIN) Slip / Virtual NIN (vNIN)
  2. Nigerian International Passport (Data Page)
  3. Nigerian Federal Road Safety Corps (FRSC) Driver’s License
  4. Independent National Electoral Commission (INEC) Permanent Voter’s Card (PVC)
• Document Integrity: Uploading expired, tampered, forged, or third-party identification documents triggers an immediate, permanent fraud freeze.

2.3 Legal Name Matching Mandate (NUBAN Bank Match)

Under Central Bank of Nigeria (CBN) regulations and anti-money laundering (AML) compliance:

• The legal first, middle, and last name verified during your eKYC identity check must match precisely the account holder name returned by the Nigerian Inter-Bank Settlement System (NIBSS) for your provided 10-digit NUBAN bank account.
• Payouts will not be routed to third-party bank accounts, corporate accounts of unrelated entities, or accounts belonging to friends, relatives, or spouses.
• Any discrepancy between the KYC name and the bank account name will automatically halt Friday payout disbursements until verified by human compliance officers.

2.4 Social Account Verification via "Code-in-Bio" Protocol

Kpugi places user privacy and security at the forefront. Kpugi will NEVER ask for your social media passwords, 2FA codes, or OAuth account management access.

• To connect a channel (TikTok, Instagram, YouTube Shorts, X/Twitter, Facebook, or LinkedIn):
  1. The creator enters their public profile handle under Settings > Connected Accounts.
  2. Kpugi generates a unique, cryptographically random verification string (e.g., kpugi-v8f2a9x1).
  3. The creator pastes this verification string into the public biography/description of their social media profile.
  4. Kpugi's public scraper reads the profile bio, confirms account control, and instantly verifies the handle.
  5. Once verified, the code may be immediately removed from the bio.
• Account Transfer Prohibited: Creators may not verify social accounts they do not personally create and curate. Leasing, renting, or selling verified accounts leads to immediate revocation of verified status.

SECTION 3: CAMPAIGN PARTICIPATION & BRIEF COMPLIANCE

3.1 Reviewing and Accepting Campaign Drops

Before creating content, creators must thoroughly inspect the active campaign brief ("Drop Card"). Each drop specifies:

• Campaign CPM Rate: The gross Naira rate paid per 1,000 verified views.
• Campaign Budget & Max View Goal: The total view pool funded by the brand.
• Individual Creator View Cap: The maximum number of views an individual creator can be compensated for on that specific drop.
• Mandatory Deliverables: Exact video format, minimum video length (typically 15 to 60 seconds), required talking points, and specific visual or audio demonstrations.
• Campaign Window: Start time and strict cutoff deadline for post submission and view auditing.

3.2 Creative Adherence & Key Talking Points

• Authentic Framing: Creators are expected to present the brand's value proposition in their native creative tone (humour, education, storytelling, dance, skits, tutorials, or lifestyle).
• Mandatory Brand Hooks: If a brief requires a specific visual demonstration (e.g., showing an app interface, unboxing a product, or tasting a beverage), the demonstration must be clearly visible, in focus, and sustained on screen for at least three (3) uninterrupted seconds.
• Prohibited Derogation: Creators must never mock, disparage, insult, or make false or unsubstantiated medical, financial, or performance claims regarding the advertiser or its competitors.
• Competitor Exclusions: A Kpugi campaign post must not feature or mention direct commercial competitors of the sponsoring brand within the same video.

3.3 Link-in-Bio & Prelander Routing (/go/...)

• If a campaign brief includes a mandatory tracking link, the creator must place the designated Kpugi smart prelander link (https://kpugi.com/go/{campaign_id}/{creator_id}) in their social media bio or pinned comment during the entire active campaign period.
• Circumventing or stripping tracking parameters, using link shorteners that strip referrer data, or redirecting traffic to unapproved destinations is grounds for view invalidation.

SECTION 4: MANDATORY TAGGING, AD DISCLOSURES & AUDIO LICENSING

4.1 Strict Tagging & Mention Rules

Every submitted post must contain the exact mentions and tags specified in the brief:

• Primary Brand Handle: Must be properly tagged in the video caption using the exact spelling provided (e.g., @BrandNigeria).
• On-Screen Tagging: Where required by the brief, use the platform's native on-screen tag/mention tool so viewers can directly tap to visit the sponsor profile.
• Campaign Hashtags: Include the exact primary campaign hashtag (e.g., #KpugiDrop, #BrandSummerFest). All hashtags must be spelled with absolute accuracy.

4.2 Regulatory Ad Disclosure Standards (ARCON & Global Compliance)

Pursuant to the Advertising Regulatory Council of Nigeria (ARCON) Code of Advertising Practice, the Federal Competition and Consumer Protection Commission (FCCPC) Influencer Guidelines, and global fair advertising standards:

• Prominent Ad Identifier: Every sponsored post must feature a clear and conspicuous commercial disclosure within the first three (3) lines of the caption (before the "See more" / fold cutoff).
• Acceptable Disclosures: #ad, #sponsored, or #paidpartnership. Ambiguous abbreviations such as #sp, #partner, or #collab are strictly invalid.
• Native Platform Toggles: Where available (e.g., TikTok "Paid Partnership" toggle, Instagram "Branded Content" label, YouTube "Paid Promotion" banner), creators must enable the platform's native commercial disclosure feature.
• Deceptive Endorsements: Under Nigerian law, presenting a sponsored commercial endorsement as an unsolicited, organic consumer review without disclosure constitutes unlawful deceptive marketing.

4.3 Commercial Audio & Music Licensing

• Commercial Audio Libraries Only: Creators must use sounds, tracks, and background music designated for commercial/business use within the respective platform's commercial audio library.
• Muted Videos Void Payouts: If a video is muted or removed by TikTok, Meta, YouTube, or X due to copyright infringement, all views accumulated on that video are immediately voided (₦0.00 payout), as unviewable or silent ad content provides zero commercial value to the advertiser.
• Original Audio: Creators speaking directly to the camera using their own original voice or copyright-cleared voiceover tracks are highly encouraged.

SECTION 5: THE 1,000-VIEW MINIMUM THRESHOLD (THE HARD CLIFF RULE)

5.1 The Zero-Follower Democratisation Rule

Kpugi does not impose arbitrary follower count thresholds. A creator with fifty (50) followers has the exact same contractual right to participate and earn as a creator with five hundred thousand (500,000) followers. Payouts are determined strictly by verified views delivered.

5.2 The 1,000-View Hard Cliff

To protect advertiser capital from low-reach or abandoned submissions, Kpugi enforces an absolute, non-negotiable minimum milestone:

• The Hard Cliff Threshold: A submitted video must reach a minimum of one thousand (1,000) verified organic views before the campaign cutoff window closes to qualify for any payout.
• Payout for < 1,000 Views: If a post finishes the campaign with 999 views or fewer, the recorded earnings are strictly ₦0.00. No prorated compensation is issued for sub-1,000 performance.
• Automatic Budget Return: Any escrow funds reserved for a sub-threshold submission automatically unlock and return to the advertiser's active drop budget pool.

5.3 Earnings Mathematical Formula & Fee Breakdown

Once a submission crosses the 1,000 verified view threshold, earnings are calculated using the following standard equation:

$$\text{Gross Payout} = \left( \frac{\text{Verified Organic Views}}{1,000} \right) \times \text{Campaign CPM Rate}$$

$$\text{Platform Facilitation Fee} = \text{Gross Payout} \times 10%$$

$$\text{Net Creator Take-Home Payout} = \text{Gross Payout} \times 90%$$

5.4 Illustrated Payout Examples

Note: If an individual creator view cap applies to a drop (e.g., capped at 50,000 views), verified views exceeding that cap will not generate incremental earnings.

SECTION 6: AUTOMATED VIEW AUDITING & QUALITY CONTROL

6.1 Hourly 60-Minute Recurring Scrapes

From the moment a creator pastes their live submission URL into Kpugi until the campaign concludes:

• Kpugi’s automated scraping and computer vision audit engine inspects the post every sixty (60) minutes.
• The engine checks live availability, view counter progression, like-to-view ratios, comment activity, caption stability, and audio status.

6.2 The 72-Hour Public Retention Rule

• Mandatory Live Period: Every post submitted for a Kpugi drop must remain publicly accessible, active, and live for a minimum of seventy-two (72) continuous hours, or the remaining duration of the active campaign, whichever is longer.
• Early Deletion / Archival Breach: Setting a post to "Private", "Friends Only", "Archive", or deleting the post within this window constitutes immediate contract breach.
• Consequences: All pending, approved, or escrowed earnings for that submission are instantly revoked (reverted to ₦0.00), and a Level 2 Compliance Strike is logged against the creator profile.

6.3 Post Alterations

Creators must not edit the caption post-submission to remove brand tags, delete tracking links, or replace campaign hashtags with unrelated tags. Post alterations detected by the audit engine will freeze the submission pending manual compliance review.

SECTION 7: ZERO-TOLERANCE ANTI-FRAUD & TRAFFIC INTEGRITY POLICY

Kpugi maintains an uncompromising, zero-tolerance policy regarding fraudulent, artificial, incentivised, or bot-generated traffic. Advertisers pay exclusively for authentic, real human eyes.

7.1 Expressly Prohibited Traffic Mechanisms

The following actions represent fraud under Nigerian criminal law (Cybercrimes Prohibition, Prevention, etc. Act, 2015) and platform regulations:

1. Bot Networks & Headless Emulators: Utilizing automated scripts, Puppeteer, Selenium, headless browsers, or device farms to simulate video views.
2. Paid SMM Panels & Click Farms: Purchasing views, impressions, likes, or saves from third-party Social Media Marketing (SMM) vendor panels, telegram bots, or Russian/Asian click farms.
3. Loop Auto-Refreshers & Browser Extensions: Installing extensions, tab reloaders, or automated scripts designed to replay or loop videos artificially.
4. Traffic Exchanges & Pods: Participating in "view-for-view", "like-for-like", "retweet-for-retweet", or WhatsApp engagement pods designed to manufacture artificial metric momentum.
5. Hidden Iframe Embedding: Embedding campaign video URLs inside invisible 1x1 pixel website iframes, pop-under ads, or deceptive auto-playing blog banners.
6. Incentivised Traffic: Offering viewers monetary rewards, airtime giveaways, cryptocurrency, or lottery entries conditioned upon viewing or commenting on the post.

7.2 Anomaly Detection Heuristics

Kpugi’s proprietary fraud detection algorithms flag submissions displaying:

• Velocity Spikes: Unnatural, instantaneous vertical view spikes with zero corresponding organic distribution trajectory.
• Geographic Divergence: High view concentrations originating outside the advertiser's target market (e.g., a drop targeted at Nigerian banking users receiving 90% of views from Bangladesh, Vietnam, or Turkey).
• Ghost Engagement Profiles: Videos displaying tens of thousands of views with near-zero likes, zero genuine comments, or comments consisting solely of bot emojis.
• Referrer Spoofing: Direct API pings lacking standard mobile device signatures and organic algorithmic routing tokens.

7.3 Disciplinary Penalties for Fraudulent Activity

Submissions flagged for artificial traffic trigger immediate, irreversible administrative action:

• Level 1 (Submission Disqualification): The submission is permanently disqualified with ₦0 payout.
• Level 2 (Wallet Confiscation): Any unwithdrawn balance earned from fraudulent drops is forfeited and returned to the impacted advertiser escrow.
• Level 3 (Permanent Blacklisting): The creator's profile, connected social handles, National Identity Number (NIN), phone number, and NUBAN bank account are permanently banned from Kpugi and shared across anti-fraud marketplace registries.
• Legal Prosecution: Kpugi reserves the right to formally report severe bot-farming syndicates to law enforcement authorities (EFCC/Nigeria Police Cybercrime Unit) for criminal investigation and recovery of illicit funds.

SECTION 8: PAYMENTS, ESCROW & AUTOMATED FRIDAY SETTLEMENTS

8.1 100% Upfront Advertiser Escrow Guarantee

Creators never have to chase clients for payment. Before any drop goes live on Kpugi:

• The sponsoring brand deposits 100% of the maximum campaign budget into platform-protected escrow via Paystack.
• Once a creator hits the 1,000-view minimum and completes the audit period, their net earnings are secured and guaranteed by platform escrow.

8.2 Weekly Friday Settlement Routine

• Settlement Window: Payout batches are processed automatically every Friday afternoon between 12:00 PM and 6:00 PM (West Africa Time - WAT).
• Automated Clearing: Earnings accumulated from campaigns that successfully concluded their audit cycle before Thursday 11:59 PM WAT are included in that Friday’s disbursement batch.
• Payment Method: Direct electronic bank transfer via Paystack and NIBSS Instant Payments (NIP) directly into the creator’s verified Nigerian bank account.

8.3 Zero (₦0.00) Withdrawal Fees

Kpugi charges zero (₦0) withdrawal fees. The 10% platform facilitation fee deducted from the gross earnings covers all payment processing, NIP transfer fees, and banking gateway surcharges. The net amount displayed in your Kpugi wallet is the exact amount deposited into your bank account.

8.4 Supported Banking Institutions

Withdrawals are supported across all licensed financial institutions in Nigeria:

• Commercial Banks: GTBank, Zenith Bank, Access Bank, First Bank of Nigeria, United Bank for Africa (UBA), Stanbic IBTC, FCMB, Fidelity Bank, Union Bank, Sterling Bank, Wema Bank, Providus Bank, etc.
• Licensed Fintechs & Neobanks: OPay, Kuda Bank, PalmPay, Moniepoint MFB, Carbon, FairMoney MFB, VFD Microfinance Bank, Gomoney, etc.

8.5 Failed Transfers & Retry Protocol

If a Friday transfer fails due to commercial bank network downtime, invalid NUBAN, or bank-side credit restrictions:

• Funds are safely rolled back to your Kpugi wallet balance.
• An automated alert is sent via email and in-app notification.
• Transfers are automatically re-queued for the next settlement clearing cycle once the creator updates or re-confirms their bank details.

SECTION 9: INTELLECTUAL PROPERTY, CONTENT RIGHTS & USAGE

9.1 Content Ownership

The creator retains the primary copyright and intellectual property rights to the raw original video created and posted on their social media channel.

9.2 Commercial License Grant to Kpugi & Sponsor

By submitting a video link to a Kpugi drop, the creator grants Kpugi Technologies Ltd. and the sponsoring advertiser a:

• Perpetual, Worldwide, Royalty-Free, Non-Exclusive License to:
  • Repost, embed, reference, quote, and display the video across official digital channels, corporate websites, investor presentations, case studies, and marketing materials.
  • Track, measure, and audit performance metrics publicly accessible via social media platform APIs.
• Spark Ads / Whitelisting Rights: If a campaign brief explicitly includes paid amplification permissions (e.g., TikTok Spark Ads code or Meta Branded Content Partnership access), the creator agrees to generate and provide the platform advertising authorization code within twenty-four (24) hours of request.

9.3 Third-Party Copyright Indemnity

The creator warrants that all video footage, audio, graphics, fonts, voiceovers, and performances contained within the submitted content are either original works created by the creator or properly licensed for commercial usage. Creators agree to indemnify Kpugi and the advertiser against any third-party copyright or trademark infringement claims arising from their content.

SECTION 10: COMMUNITY GUIDELINES & BRAND SAFETY STANDARDS

Content submitted to Kpugi drops must adhere to the highest standards of safety, dignity, and public decency. Content containing or promoting any of the following elements is strictly disqualified:

1. Sexually Explicit Content: Nudity, pornographic media, sexually suggestive conduct, or escort services.
2. Hate Speech & Discrimination: Content promoting violence, hatred, or discrimination against any group based on ethnicity, tribe, religion, sexual orientation, disability, gender, or nationality.
3. Defamation & Character Assassination: Unverified allegations, slanderous remarks, or defamatory claims targeting individuals or corporate entities.
4. Dangerous or Illegal Goods: Promotion of illegal narcotics, unregulated pharmaceuticals, unregistered financial investment schemes, pyramid/Ponzi schemes, unauthorized sports betting, firearms, or counterfeit currency.
5. Violence, Self-Harm & Harassment: Gratuitous violence, gore, intimidation, cyberbullying, or content glorifying self-harm.
6. Deceptive & Misleading Practices: Phishing, social engineering, impersonation of public officials, or fabricated news.

Advertisers reserve the absolute right to request immediate takedown of any submission violating these core brand safety standards without liability or compensation to the creator.

SECTION 11: DISPUTES, AUDIT APPEALS & SUPPORT TICKETING

11.1 Grounds for Valid Audit Appeals

A creator may appeal an automated audit decision only under the following verifiable conditions:

• Scraper Latency: The creator’s post reached the required milestone (e.g., crossed 10,000 views) before the campaign deadline, but third-party platform API rate limits delayed Kpugi’s scraper from recording the final count.
• Tagging False Positive: The required brand tag or campaign hashtag was present and visible in the caption from initial publication, but an algorithmic parsing glitch failed to detect it.
• Video Privacy Misclassification: The video was continuously public, but a temporary platform server glitch caused a false "private/unavailable" status check.

11.2 Ineligible Appeals

Appeals will be summarily rejected if:

• The video finished below the 1,000-view hard cliff (e.g., 950 views).
• The creator added missing tags or hashtags after the campaign cutoff time.
• The video was deleted, muted for copyright, or archived during the 72-hour retention window.

11.3 Formal 48-Hour Appeal Procedure

1. Filing Window: Creators must lodge an appeal within forty-eight (48) hours of the campaign drop closing or audit rejection notification.
2. Channel: Appeals must be submitted directly through KpugiBot AI Chat on the dashboard or by creating a ticket at the official support portal:
   ? https://support.kpugi.com/support/tickets/new
3. Mandatory Evidence: The ticket must contain:
   • Campaign Name and Submission ID
   • Direct live URL of the post
   • Unedited, full-screen recording showing the social platform's native in-app analytics dashboard with timestamps and reach metrics.
4. Resolution Timeline: Compliance officers investigate and deliver a final, binding determination within two (2) business days.

SECTION 12: VIOLATION STRIKE SYSTEM & ENFORCEMENT MATRIX

To maintain accountability, Kpugi operates a transparent, three-strike disciplinary enforcement matrix:

┌─────────────────┐     ┌─────────────────┐     ┌─────────────────┐ │     STRIKE 1    │ ──> │     STRIKE 2    │ ──> │     STRIKE 3    │ │ Formal Warning  │     │  14-Day Freeze  │     │  Permanent Ban  │ │ Drop Rejection  │     │  Audit Review   │     │  Blacklisting   │ └─────────────────┘     └─────────────────┘     └─────────────────┘

12.1 Strike Classification

12.2 Summary Termination Right

Kpugi explicitly reserves the right to bypass the tiered strike schedule and effect immediate, permanent account termination in cases involving criminal activity, hate speech, identity fraud, extortion, or intentional cyber attacks against the platform infrastructure.

SECTION 13: AMENDMENTS & PLATFORM MODIFICATIONS

Kpugi Technologies Ltd. reserves the right to amend, augment, or modify these Rules and Compliance Guidelines periodically to reflect changes in regulatory directives (ARCON, NDPC, CBN), evolving platform security measures, or market mechanics.

• Notice of material revisions will be published on the official support portal (support.kpugi.com) and communicated via in-app dashboard banners and registered email at least seven (7) days prior to taking effect.
• A creator’s continued use of the platform and participation in drops following the effective date of updated rules constitutes unequivocal acceptance of the amended terms.

OFFICIAL COMPLIANCE CONTACT & SUPPORT DIRECTORY

For compliance inquiries, legal notices, or formal audit escalation, creators may consult the following dedicated channels:

• Official Knowledge Base & Platform Rules:
  https://support.kpugi.com/support/solutions
• Submit a Compliance Support Ticket:
  https://support.kpugi.com/support/tickets/new
• General Support Portal Home:
  https://support.kpugi.com/support/home
• Interactive AI Support Assistance:
  Available 24/7 via the KpugiBot chat launcher in the creator dashboard.
• Corporate Headquarters:
  Kpugi Technologies Ltd., Lagos, Federal Republic of Nigeria.

© 2026 Kpugi Technologies Ltd. All Rights Reserved. This document is proprietary to Kpugi and protected under Nigerian and international intellectual property legislation.