This policy binds every employee, contractor, advisor, Ambassador, KOL, community moderator, and community bot ("Insider") of Varyom Foundation, and every user who chooses to promote $MEPR or any launchpad-listed token.
1. Anti-touting (Section 17(b))
Section 17(b) of the U.S. Securities Act makes it unlawful to publish or circulate paid promotion of a security without disclosing the compensation received. Because digital-asset classification is unsettled, MEPR applies the Section 17(b) standard to every paid promotion of $MEPR or launchpad-listed tokens: paid Promoters must always disclose the amount and nature of the consideration received.
2. Prohibited market conduct
- Pump-and-dump schemes and coordinated buying signals.
- Wash trading — buying and selling to inflate volume.
- Spoofing, layering, or other order-book manipulation.
- Front-running launchpad allocations, unlock events, or protocol transactions using non-public information.
- Coordinated FUD attacks on competing projects.
- Distributing false or misleading statements about $MEPR.
3. Insider blackout windows
Insiders are prohibited from buying or selling $MEPR during blackout windows announced by the Foundation, which include the periods immediately before and after token unlocks, exchange listings, material governance votes, and material product launches. Violations are handled under our Acceptable Use Policy.
4. Material non-public information ("MNPI")
Insiders may not trade on, or share, MNPI. Examples include unannounced listings, unannounced partnerships, unannounced audits or exploits, unannounced tokenomics changes, and unannounced launchpad campaigns.
5. KOL & Ambassador program
KOLs and Ambassadors must accept this policy before their first paid campaign, must include a clear paid-promotion disclosure on every post, and may not make price predictions. Repeated violations result in removal from the program, clawback of rewards, and referral to regulators when warranted.
6. Reporting
Report suspected market manipulation, undisclosed paid promotion, or insider-trading violations to trust@varyom.com or via our anonymous Whistleblower channel. MEPR prohibits retaliation against good-faith reporters.