(Democratic Republic of the Congo · Platform-Level Compliance Document)

I. Document Positioning and Purpose Statement (Must Be Placed at the Beginning)

1.1 Document Nature

This document is a specialized compliance firewall explanatory document formulated by the CongoSupply platform to address "pyramid schemes, fund pools, and high-risk viral referral models." It is intended for:

• Bank and payment institution due diligence (KYC/KYB);

• Partner compliance reviews;

• Responding to external inquiries regarding "Is this a pyramid scheme/fund pool?";

• Internal platform risk control and policy formulation;

• Legal and regulatory environment explanatory material.

This document is not for marketing purposes, does not constitute a user earnings promise, and is solely for compliance explanation and risk isolation.

1.2 Applicable Region Explanation (Specificity of the DRC)

Given the following realities in the Democratic Republic of the Congo (DRC):

• The financial regulatory system is fragmented, with uneven enforcement;

• Investment fraud, fund pools, and illegal fundraising frequently occur;

• The public is highly sensitive to "recruiting members" and "multi-level commissions";
  the platform has proactively, preemptively, and systematically introduced an "anti-pyramid scheme firewall mechanism" during its design phase, rather than relying on post-incident remediation.

II. Underlying Compliance Logic of the Platform's Business Model

2.1 CongoSupply’s Sole Profitability Foundation

The platform's commercial foundation is singular: real transactions of goods or services.

Platform revenue sources include, but are not limited to:

• Reasonable service fees from goods/service transactions;

• Merchant-paid services (e.g., technical service fees).

These do not include, involve, or derive from the following revenue forms:

• User membership fees;

• Promotion qualification fees;

• Investment-type fund deposits;

• Operation of user fund pools.

2.2 Legal Characterization of the Promotion and Distribution Mechanism (Regulatory Focus)

The platform's promotion and distribution mechanism is strictly defined as:
A marketing incentive mechanism based on real transactions (Marketing Incentive Mechanism).

It is not the following high-risk structures:

III. Structural Disavowal of the Three Elements of Pyramid Schemes (Core Chapter)

This is the section most scrutinized by banks and regulators.

3.1 Element 1: Is There an Entry Fee or Disguised Threshold Fee?

Conclusion: No.

The platform explicitly implements the following policies:

• Registration is free;

• Participation in promotions is free;

• There is no form of "payment to obtain qualification";

• There are no payment thresholds required for "level upgrades."

Policy Significance:
This fundamentally severs the pyramid scheme structure based on "paying for status."

3.2 Element 2: Are Unlimited Levels or Viral Referral Commissions Allowed?

Conclusion: No.

The platform implements the following hard limits at the system level:

• Referral relationships are calculated up to a maximum of three levels;

• Beyond three levels, the system does not calculate, record, or display any relationships;

• No manual intervention or exceptions are permitted.

Policy Significance:
Through technical means, the possibility of "profiting from unlimited recruitment" is directly negated.

3.3 Element 3: Are Earnings Primarily Based on the Number of Recruited Members?

Conclusion: No.

The sole trigger for earnings and rewards on the platform is:
A genuinely completed transaction of goods or services.

The following behaviors, even if they involve member recruitment, will not generate any earnings:

• Registration without consumption;

• Invitation without an order;

• Orders followed by refunds;

• Abnormal orders.

Policy Significance:
Earnings are completely decoupled from "headcount" and tied exclusively to "real transactions."

IV. Dual Design of the Anti-Pyramid Scheme Firewall: "Policy Layer + Technical Layer"

4.1 Policy Layer Firewall (Text and Rules)

The platform has established the following "firewall components" at the policy level:

1. Official Script Whitelist System

   • Only fixed phrasings are permitted;

   • Personal interpretation of earnings is prohibited.

2. Promoter Examination System

   • No promotion is allowed without passing the exam;

   • Failure to understand the rules results in disqualification.

3. Tiered Violation Penalty Mechanism

   • Warning → Freeze → Permanent Ban;

   • No ambiguous enforcement.

4. Non-Employment/Non-Agency Declaration

   • Severs organizational liability transmission.

4.2 Technical Layer Firewall (System-Level Constraints)

The platform implements the following risk control logic at the system level:

• Banned keyword monitoring (e.g., "investment," "guaranteed profit," "capital protection");

• Algorithmic monitoring of abnormal orders;

• Device/IP multi-account identification;

• Analysis of abnormal fund flow in wallets;

• Clustering analysis of complaints and behaviors.

All bans can be triggered automatically by the system, rather than relying on subjective human judgment.

V. Essential Differences from the Characteristics of "Fund Pools"

5.1 The Platform Lacks the Core Characteristics of Fund Pools

5.2 Compliance of User Fund Flows

• User funds are directly used for transactions of goods or services;

• Promotion rewards originate from platform settlements after transaction completion;

• The platform does not engage in fund reinvestment or fund pool operations.

VI. Platform's Unified External Anti-Pyramid Scheme Declaration (For Banks/Partners)

CongoSupply does not provide any investment or wealth management services,
does not charge any form of membership fees,
does not base earnings on the number of recruited members,
and promotion rewards are generated solely based on real transactions of goods or services,
with reward levels capped at a maximum of three.

The platform employs dual risk control mechanisms—technical and policy-based—to proactively prevent pyramid schemes, fund pools, and illegal fundraising risks.

VII. Platform’s Proactive Compliance and Cooperation Statement

The platform commits to:

• Proactively accepting compliance reviews from banks and payment institutions;

• Cooperating with regulatory inquiries within legal boundaries;

• Continuously optimizing risk control and anti-abuse capabilities;

• Maintaining zero tolerance for non-compliant behavior.

VIII. Ultimate "Firewall Summary Clause" (Extremely Important)

CongoSupply's design objective is not "maximum viral growth" but "maximum security."

We would rather sacrifice growth speed than breach legal and compliance boundaries.