1. Scope

These C42 Token Program Terms (“Terms”) govern participation in the C42 Program Reward System (“Program”), operated by the relevant C42 group entity or designated operator (“Operator”).

The Program currently centers on Whistle42 as the core whistleblower and intelligence-intake platform of the C42 Ecosystem. In some cases, C42 may also be used as a reward, recognition or access layer in connection with downstream ecosystem platforms such as FinTelegram, FinCrime Observer, and RatEx42, to the extent compatible with these Terms.

These Terms do not govern any purchase, sale, transfer, or trade of C42 Tokens on secondary markets, nor do they govern any future security-token structure, including any project that may in the future be referred to as C42S.

2. Definitions

• C42 Token or C42: a non-financial, program-based reward, recognition and access token issued under these Terms.
• Participant: any individual or entity interacting with Whistle42 or another designated C42 ecosystem service who may become eligible for C42 allocations.
• Operator: the relevant C42 group entity operating the Program, directly or through a designated affiliate or contractor.
• Whistleblower Submission: any tip, report, document, evidence package, communication or follow-up submitted via Whistle42, whether anonymously or through an account-based workflow.
• Ecosystem Contribution: any documented and eligible contribution that supports the C42 Ecosystem, including research support, structured evidence work, ratings-relevant input, intelligence clarification, or campaign participation.
• Information Request: a structured inquiry submitted by an information seeker such as a law firm, compliance team, journalist, NGO, investigator, regulator or similar user through Whistle42 or another designated ecosystem channel.
• Program Ledger: the on-chain and/or off-chain system used by the Operator to record eligibility decisions, allocation decisions, issuance records and related compliance notes.
• Program Partner: a certified, affiliated or otherwise approved partner participating in separate ecosystem or partner arrangements who may receive C42 rewards or utilities in accordance with these Terms and any additional partner documentation.

3. Eligibility for C42 Allocations

Participants may become eligible to receive C42 Tokens under the Program for:

• providing whistleblower submissions on Whistle42 that are verified, relevant, actionable or otherwise materially useful;
• contributing to information quality, including documentation, clarification, follow-up, corroboration or evidence structuring in ongoing matters;
• participating in structured campaigns, research tasks, community initiatives or intelligence programs announced by the Operator;
• providing ratings-relevant, evidence-based or research-based input that supports ecosystem platforms such as RatEx42, FinTelegram or FinCrime Observer;
• Program Partner activities in accordance with separate partner terms, where those activities are verified and accepted by the Operator.

Eligibility is always subject to:

• verification and fraud checks by the Operator;
• jurisdictional, sanctions and compliance restrictions;
• Program budgets, caps, campaign limits and technical capacity;
• compliance with these Terms and other applicable site policies;
• the Operator’s legal, editorial, security and risk-assessment standards.

C42 allocations are discretionary. No Participant has a right, entitlement or guarantee to receive C42 for any action, even if similar actions were rewarded in the past.

4. Issuance Rules

C42 Tokens are issued only when all conditions determined relevant by the Operator are satisfied, including where applicable:

• a verified action occurs, such as a validated whistleblower submission, accepted ecosystem contribution, completed task or accepted campaign action;
• fraud, abuse, security and compliance checks are passed to the Operator’s satisfaction;
• issuance does not exceed internal caps, campaign budgets or technical limits for the relevant period;
• the action is consistent with the C42 Whitepaper, Program Terms, published reward logic and applicable law.

The Operator may delay, reduce, cancel, suspend, reverse or claw back any C42 allocation or issuance at its discretion, including for technical reasons, compliance review, sanctions review, adverse information, fraud concerns, updated risk assessments, or legal constraints.

5. Fraud, Misuse and Clawback

The Operator may withhold, cancel, reverse or claw back C42 allocations and restrict access in cases of suspected or confirmed:

• fraudulent, fabricated, manipulated or misleading submissions;
• duplicate submissions, multi-account abuse, collusion or identity manipulation;
• geo-spoofing, VPN misuse, proxy abuse or sanctions circumvention;
• harassment, threats, intimidation or abuse directed at whistleblowers, victims, staff, reviewers, editors, analysts or partners;
• attempts to buy coverage, influence ratings, manipulate investigations, or interfere with editorial or analytical independence;
• any activity reasonably considered incompatible with the mission of the ecosystem, public-interest integrity, or applicable law.

Sanctions may include suspension or termination of access, exclusion from future allocations, removal from partner programs, and where appropriate referral to enforcement or regulatory authorities.

6. Multi-Platform Use within the C42 Ecosystem

C42 is a program reward, recognition and access token used across elements of the C42 Ecosystem.

• Whistle42: rewards or recognition for verified, actionable whistleblower submissions and qualifying follow-up work;
• FinTelegram and FinCrime Observer: rewards or recognition for intelligence that materially supports investigations, case work, forensic reporting or evidence development, always subject to editorial independence;
• RatEx42: rewards or recognition for structured, documented inputs that improve ratings quality, risk mapping, evidence trails, or compliance intelligence.

Editorial, analytical and ratings decisions remain fully independent from C42 allocations. C42 cannot be used to buy coverage, suppress coverage, alter ratings, secure favorable treatment, or otherwise influence public-interest decisions.

ClaimBack42 remains part of the broader ecosystem roadmap as a possible future project. It is not a current operational core of these Terms. If ClaimBack42 or any comparable claims-intake module is launched in the future, the Operator may publish updated Terms, supplementary rules, or a new version of these Terms.

7. Jurisdictional and Sanctions Restrictions

The Operator may restrict or exclude Participants from certain countries, territories or regions, including but not limited to:

• countries or persons subject to EU, US, UK, UN or other relevant sanctions regimes;
• jurisdictions where token-based rewards are prohibited, restricted, or require licensing not held by the Operator;
• regions classified as high-risk or non-compliant under the Operator’s internal risk policy.

Participants may be required to undergo KYC/AML, identity, wallet, source-of-funds, IP or device verification checks before receiving C42 rewards, particularly for larger allocations, repeated participation, partner activity or elevated-risk cases.

8. Program Partners and Separate Purchase Arrangements

Certain operators, platforms, service providers, NGOs, investigators or other approved participants may become C42 Program Partners under separate agreements.

Program Partners may:

• receive C42 rewards for verified ecosystem contributions;
• receive access-oriented utilities or partner privileges where approved by the Operator;
• enter into separate commercial or token-related arrangements with the Operator under standalone contracts.

Any purchase, sale, service, placement or partner arrangement involving C42 outside the reward logic of these Terms is governed by separate contracts and not by these Program Terms.

9. No Rights, No Guarantees

C42 Tokens:

• are not legal tender, securities, deposits or e-money;
• do not entitle holders to dividends, profit shares, recoveries, damages, settlements or asset proceeds;
• do not provide any claim against the Operator’s assets, reserves, treasury or any program fund;
• do not grant any right to receive any future token, including any possible future security token;
• do not create any expectation of listing, liquidity, transferability, buy-backs or market value.

The Operator makes no guarantee that C42 will have any market value, be listed on any venue, retain access utility, or remain available in any given jurisdiction or technical environment.

10. Modification, Suspension and Termination

The Operator may modify, suspend or terminate:

• these Program Terms;
• the C42 Reward Program, in whole or in part;
• eligibility criteria, allocation logic, utilities, campaigns or program categories;
• access to certain features, jurisdictions, partner workflows or technical components.

Updates will be published on c42token.com and, where appropriate, referenced in a changelog, update notice, whitepaper revision or related disclosure.

11. Limitation of Liability

To the maximum extent permitted by law, the Operator and its affiliates are not liable for:

• loss of access to C42, including wallet, credential, account or key-related loss;
• errors, delays, disputes or inconsistencies in eligibility review, allocation logic or issuance processing;
• security incidents, smart-contract issues, hacks, exploits, outages or infrastructure failures;
• losses arising from regulatory incompatibility, jurisdictional restrictions or compliance actions;
• the unavailability, deprecation or non-launch of any future ecosystem module.

12. Contact

For questions about these Terms or the C42 Program, please contact:

legal@c42token.com

Whistleblower submissions: whistle42.com

13. Governing Law and Versioning

These Terms are governed by the laws designated by the Operator in the applicable legal notice, imprint or corporate disclosure, unless mandatory law requires otherwise.

This is Program Terms version 1.2. Future changes may be documented through dated updates, archived versions, changelog notices or related disclosure updates published on c42token.com.