Code of Conduct — Referrals Addendum

This addendum supplements the Virely LLC Master Code of Conduct with rules specific to the Dealsby Referrals platform. All provisions of the master policy apply in addition to the platform-specific rules below. In the event of a conflict, the more restrictive provision governs.

Dealsby Referrals is a referral marketing automation platform that enables businesses to create, manage, and track customer referral programs. Businesses are responsible for the ethical operation of their referral programs and all communications sent through the platform.

Businesses must ensure that their referral programs are operated honestly, transparently, and in compliance with all applicable laws:

• Authentic Referrals Only: All referrals tracked through the platform must originate from genuine customer relationships. Fabricated, self-referred, or bot-generated referrals are strictly prohibited.
• Transparent Incentives: All referral incentives (discounts, credits, rewards, cash) must be clearly disclosed to both the referrer and the referred party at the time of invitation. Hidden terms or bait-and-switch reward structures are prohibited.
• Incentive Fulfillment: Businesses must honor all referral rewards as advertised. Failure to fulfill promised incentives to customers constitutes a violation of this Code of Conduct.
• No Incentivized Deception: Businesses must not incentivize customers to leave fake reviews, provide false testimonials, or misrepresent their experience as a condition of receiving a referral reward.
• Program Terms Disclosure: Every referral program must include publicly accessible terms and conditions that outline eligibility, reward structure, expiration, and any limitations.

All referral-related communications sent through the Dealsby Referrals platform must adhere to the following standards:

• Opt-In Requirement: Referral invitations may only be sent to individuals who have been personally referred by an existing customer. Businesses must not use the referral system to send unsolicited messages to purchased, scraped, or rented contact lists.
• Clear Identification: All referral messages must clearly identify the sending business and the referring customer. Messages must not impersonate individuals or disguise the commercial nature of the communication.
• Opt-Out Compliance: All referral communications must include a clear, functioning opt-out mechanism. Opt-out requests must be honored within 24 hours.
• Frequency Limits: Businesses must not send more than two (2) referral follow-up messages per referred individual per referral event. Excessive messaging constitutes spam and is a violation.
• Truthful Content: Referral messages must not contain false claims, misleading offers, or deceptive urgency tactics (e.g., fabricated deadlines or false scarcity).

Dealsby Referrals provides businesses with referral tracking, analytics, and Referral Pulse insights. Businesses must not manipulate these systems:

• No Artificial Inflation: Businesses must not create fake accounts, use bots, or employ click farms to artificially inflate referral counts, conversion rates, or engagement metrics.
• Accurate Attribution: Businesses must not tamper with referral attribution to claim credit for organic traffic or non-referral conversions.
• Honest Reporting: Any data exported from the platform for use in marketing materials, investor reports, or public disclosures must accurately reflect actual platform performance without manipulation.

Businesses offering monetary or tangible rewards through their referral programs must comply with the following:

• Tax Disclosure: Businesses are solely responsible for any tax reporting obligations related to referral rewards (e.g., 1099 reporting for rewards exceeding IRS thresholds). Virely LLC does not provide tax advice or manage tax reporting on behalf of businesses.
• Reward Expiration: If referral rewards carry an expiration date, the expiration must be clearly communicated at the time of issuance and must provide a minimum of 90 days for redemption.
• No Illegal Incentives: Referral incentive structures must not violate industry-specific anti-kickback laws, referral fee regulations, or professional licensing rules (e.g., healthcare, legal, financial services referral restrictions).
• Reward Revocation: Businesses may only revoke a referral reward for legitimate cause (e.g., fraudulent referral, returned purchase). Arbitrary or retaliatory revocation of earned rewards is a violation.

Dealsby Referrals includes SMS and email messaging capabilities subject to plan limits. Businesses must adhere to the following usage standards:

• Plan Limits: Starter plan includes 1,000 SMS and 5,000 email per month. Growth plan includes 2,000 SMS and 10,000 email per month. Overages are billed per the applicable add-on or pay-as-you-go rates.
• No Shared Credentials: Platform messaging credentials must not be shared with or used by third parties not authorized on the account.
• Content Restrictions: Messages must not contain malware links, phishing attempts, or redirect to fraudulent or harmful websites.
• Carrier Compliance: SMS messages must comply with all applicable carrier guidelines(10DLC registration, A2P messaging standards).Virely LLC may suspend messaging privileges if carrier violations are detected.

In addition to the enforcement framework outlined in the Master Code of Conduct, the following actions carry specific enforcement consequences on the Dealsby Referrals platform:

• Tier 1 — Warning: First instance of excessive messaging frequency; incomplete referral program terms; minor reward fulfillment delays resolved within 14 days.
• Tier 2 — Suspension: Repeated failure to honor referral rewards; use of referral tools for non-referral bulk messaging; failure to maintain opt-out compliance; two or more unresolved Tier 1 violations within 90 days.
• Tier 3 — Removal: Referral fraud or fabrication; use of purchased/scraped lists through referral tools; systematic metric manipulation; violation of anti-kickback or referral fee laws.