ClaimKey Program Terms

1. Scope

These ClaimKey Program Terms (“Terms”) govern participation in the ClaimKey reward, access and utility program (“Program”).

The Program is operated by the ClaimKey issuer or by a designated ClaimKey infrastructure operator acting on behalf of or in coordination with the issuer (“Operator”). The issuer and Operator details will be specified in the final ClaimKey whitepaper, legal notice and related disclosures.

The Program is intended to operate through designated ecosystem interfaces, including Whistle42 and ClaimBack Hub. External partners such as EFRI may connect to the ClaimKey infrastructure under written agreements for specific operational roles.

These Terms do not govern any separate purchase agreement, strategic partner round, trading venue terms, wallet provider terms, crypto-asset service provider terms, or any third-party service agreement. Such arrangements may be governed by separate documentation.

2. Definitions

• ClaimKey or CKT means the ClaimKey utility, reward and access token issued within the ClaimKey ecosystem.
• ClaimKey Infrastructure means the technical, contractual, operational and programmatic framework through which ClaimKey utilities, rewards and access functions are made available.
• Issuer means the legal entity issuing ClaimKey, to be specified in the final whitepaper and legal documentation. The intended structure is an EU-based issuer, with the final jurisdiction and details to be confirmed.
• Operator means the issuer or designated entity responsible for operating, coordinating or administering the ClaimKey infrastructure and Program.
• Participant means any individual or entity interacting with Whistle42, ClaimBack Hub or another designated ClaimKey ecosystem interface who may become eligible for ClaimKey utilities or allocations.
• Whistleblower Submission means a tip, report, document, evidence package, communication or follow-up submitted through Whistle42.
• Claim Registration means the submission of claim-related information, documents or supporting materials through ClaimBack Hub for intake into the ecosystem workflow.
• Claim Intake Reward means a ClaimKey allocation that may be granted for the qualified registration of a claim through ClaimBack Hub, subject to these Terms.
• Ecosystem Contribution means a documented and eligible contribution that supports the ClaimKey ecosystem, including evidence clarification, research support, structured intake, partner support or other accepted actions.
• Program Partner means an approved partner, platform, NGO, investigator, service provider, media partner, research partner or other organization participating under separate written arrangements.
• Program Ledger means the on-chain and/or off-chain system used by the Operator to record eligibility decisions, allocation decisions, issuance records, compliance notes and related program activity.

3. Program Architecture

ClaimKey is designed around the ClaimKey infrastructure. The issuer or Operator makes token-based utilities, rewards and access functions available through designated ecosystem interfaces.

• Whistle42 serves as the whistleblower and protected intelligence intake interface.
• ClaimBack Hub serves as the claim intake and coordination interface.
• EFRI may act as an independent partner organization connected under written agreements for claim review and related support functions.
• Other ecosystem interfaces, partners or workflows may be added over time through updated documentation.

EFRI and other external partners are not the issuer of ClaimKey and do not determine the legal nature of ClaimKey. Their roles, if any, are governed by written partner agreements and applicable law.

4. Eligibility for ClaimKey Allocations

Participants may become eligible to receive ClaimKey allocations under the Program for:

• providing qualified whistleblower submissions through Whistle42 that are verified, relevant, actionable or otherwise materially useful;
• providing follow-up information, documents, clarification, corroboration or structured evidence in connection with an accepted whistleblower submission;
• registering a claim through ClaimBack Hub in a complete, eligible and program-compliant form;
• supporting claim intake workflows, documentation, research, evidence structuring or partner routing where accepted by the Operator;
• participating in approved ecosystem campaigns, partner programs or structured contribution initiatives;
• performing Program Partner activities under separate written agreements.

Eligibility is always subject to verification, fraud checks, sanctions screening, jurisdictional restrictions, technical availability, budget limits, campaign caps and compliance review.

ClaimKey allocations are discretionary unless expressly stated otherwise in a specific written agreement. No Participant has a guaranteed right to receive ClaimKey for any action, even if similar actions have previously resulted in allocations.

5. Whistleblower Rewards

ClaimKey may be allocated as a reward or recognition for qualified whistleblower submissions through Whistle42.

A Whistleblower Submission may be considered eligible where it is relevant, verifiable, actionable, non-fabricated, not abusive, not submitted in violation of law, and materially useful for an accepted ecosystem purpose.

The Operator may consider factors such as originality, evidentiary value, completeness, timeliness, relevance and risk level. However, no single factor creates an automatic entitlement to ClaimKey.

6. Claim Intake Reward

ClaimKey may be allocated as a Claim Intake Reward for the qualified registration of a claim through ClaimBack Hub.

The Claim Intake Reward is linked to the intake action itself — meaning the complete and eligible submission of a claim into the ClaimBack Hub workflow — and not to the claim’s economic value, enforceability, recoverability, monetization potential or ultimate recovery outcome.

A claim registration may be considered eligible where the Participant provides required information, supporting documents, truthful representations, contact details where required, and any confirmations or consents requested by the Operator.

A later assessment of a claim by EFRI or another partner does not determine the legal nature of ClaimKey and does not create any claim to additional ClaimKey, unless expressly stated in a separate published program rule or written agreement.

7. Role of EFRI and Other Partners

EFRI or other partner organizations may connect to the ClaimKey infrastructure under written agreements for defined roles, including claim review, support, assessment, routing, documentation or related operational functions.

Unless expressly stated in a written agreement, external partners do not act as issuer, token distributor, crypto-asset service provider, custodian or guarantor of ClaimKey.

Any partner review of a claim is separate from the Claim Intake Reward. A review of enforceability, evidence quality or recovery prospects does not convert ClaimKey into a financial instrument and does not give Participants rights to proceeds.

8. Issuance and Allocation Rules

ClaimKey allocations may be issued only when the Operator determines that all relevant conditions have been satisfied, including where applicable:

• an eligible action has occurred;
• verification and fraud checks have been completed to the Operator’s satisfaction;
• required participant data, wallet data or account information has been provided;
• jurisdictional and sanctions restrictions do not prevent issuance;
• internal caps, campaign limits, reward budgets or technical limits have not been exceeded;
• the allocation is consistent with the ClaimKey whitepaper, these Terms and applicable law.

The Operator may delay, reduce, cancel, suspend, reverse or claw back any ClaimKey allocation or issuance for technical, operational, compliance, fraud, legal, sanctions, security, governance or risk-management reasons.

9. Fraud, Misuse and Clawback

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

• false, fabricated, manipulated, misleading or incomplete submissions;
• duplicate claims, duplicate submissions, identity manipulation or multi-account abuse;
• collusion, bot activity, automated abuse, fake documents or artificial activity;
• sanctions circumvention, geo-spoofing, VPN abuse or restricted-jurisdiction activity;
• harassment, threats, intimidation or abuse directed at whistleblowers, victims, staff, reviewers, partners or other Participants;
• attempts to buy coverage, influence investigations, manipulate ratings, alter claim review outcomes or interfere with partner independence;
• conduct that is unlawful, reputationally harmful or incompatible with the purpose of the ClaimKey ecosystem.

Sanctions may include exclusion from the Program, account suspension, loss of access, cancellation of allocations, clawback claims and, where appropriate, referral to relevant authorities.

10. Program Partners and Separate Arrangements

Approved organizations may become Program Partners under separate written agreements. Program Partners may include NGOs, investigative organizations, compliance providers, legal teams, media partners, claim support organizations, technical providers or other ecosystem participants.

Program Partners may, subject to separate documentation:

• receive ClaimKey allocations for verified ecosystem contributions;
• receive access-oriented utilities or partner privileges;
• participate in claim intake, whistleblower, research, routing or support workflows;
• enter into commercial, technical, token-related or operational arrangements with the Operator.

Any purchase, sale, service, placement, subscription, strategic partner round or other commercial arrangement involving ClaimKey outside the reward logic of these Terms is governed by separate documentation.

11. Jurisdictional, KYC and Sanctions Restrictions

The Operator may restrict, exclude, delay or condition participation from certain countries, territories, regions, persons, entities or wallet addresses.

• countries, territories, persons or entities subject to EU, US, UK, UN or other relevant sanctions regimes;
• jurisdictions where token-based rewards, crypto-assets or related services are prohibited, restricted or require authorization not held by the Operator;
• regions or participants classified as high-risk under the Operator’s internal risk policy;
• participants who fail to provide required information, confirmations, KYC documents or wallet data.

Participants may be required to complete KYC, AML, sanctions, wallet, device, IP, identity, source-of-funds or source-of-wealth checks before receiving ClaimKey, particularly for larger allocations, repeated activity, Program Partner arrangements or elevated-risk cases.

12. No Rights, No Guarantees

ClaimKey does not provide or represent:

• shares, bonds, securities or other financial instruments;
• legal tender, e-money, deposits or asset-referenced tokens;
• dividends, profit shares, interest, repayment rights or redemption rights;
• claims on issuer assets, treasury assets, reserves, recoveries, damages, settlements or partner proceeds;
• ownership rights, governance rights or voting rights in the issuer, Operator, Whistle42, ClaimBack Hub, EFRI or any partner organization;
• guaranteed access, perpetual utility, guaranteed listing, transferability, liquidity, buy-backs or market value.

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

13. ClaimKey and Claim-Related Workflows

ClaimKey is not a claim token, not a claim certificate, not a claim assignment, not a debt instrument, and not an economic participation right in any registered claim.

Registration of a claim through ClaimBack Hub does not guarantee that the claim will be reviewed, accepted, pursued, financed, monetized, settled or recovered.

ClaimKey allocations, including Claim Intake Rewards, are independent from any decision by EFRI or another partner regarding enforceability, recovery prospects, evidentiary strength, claim value or case strategy.

14. Data, Confidentiality and Evidence Handling

Participants may submit sensitive information, documents, evidence or claim-related materials through ecosystem interfaces. Such materials may be handled under applicable privacy notices, platform terms, partner agreements and legal obligations.

The Operator may share relevant materials with designated partners, including EFRI, where necessary for intake, review, routing, support, compliance or other permitted ecosystem purposes.

Participants must not submit unlawful, stolen, fabricated, manipulated, malicious or unauthorized materials. The Operator may reject, remove, quarantine or report materials where required or appropriate.

15. Modification, Suspension and Termination

The Operator may modify, suspend or terminate:

• these Terms;
• the ClaimKey Program, in whole or in part;
• eligibility criteria, allocation logic, reward rules, utilities or campaign categories;
• access to ecosystem interfaces, partner workflows, dashboards, forms, token functions or technical components;
• availability of ClaimKey in specific jurisdictions or for specific participant categories.

Updates may be published on claimkey.io and, where appropriate, referenced in a changelog, update notice, whitepaper revision, legal notice or related disclosure.

16. Limitation of Liability

To the maximum extent permitted by applicable law, the Operator, issuer, affiliates, service providers and partners are not liable for:

• loss of access to ClaimKey, wallets, accounts, credentials, private keys or platform features;
• delays, errors, disputes or inconsistencies in eligibility review, allocation logic or issuance processing;
• non-issuance, cancellation, reduction, suspension or clawback of ClaimKey allocations;
• security incidents, smart-contract issues, hacks, exploits, outages or infrastructure failures;
• regulatory restrictions, jurisdictional unavailability, sanctions actions or compliance decisions;
• the unavailability, non-launch, discontinuation or modification of any ecosystem module, partner role or platform function;
• any claim value, claim enforceability, claim review outcome, recovery result, settlement result or partner decision.

17. Governing Law and Versioning

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

ClaimKey is intended to be structured as an EU-facing utility-token project. The final issuer jurisdiction, competent authority and filing route will be specified in the final whitepaper and related legal documentation.

This is ClaimKey Program Terms version 1.0. Future changes may be documented through dated updates, archived versions, changelog notices, whitepaper revisions or related disclosure updates published on claimkey.io.

18. Contact

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

legal@claimkey.io

Whistleblower submissions: whistle42.com
Claim intake interface: claimback-hub.com