1) Purpose and scope
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Purpose: Ensure Community Council-funded projects are lawful, ethically aligned, and reputationally safe, while preserving Community Council’s independent funding decisions.
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Scope: Applies to all proposals, recipients, payouts (incl. compensation/bonuses), communications, and deliverables funded from the Community Council budget.
2) Roles, authority, and “two-key” control
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Community Council: Evaluates merit, impact, feasibility; votes final funding decision subject to compliance.
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Team Nimiq: Only checks proposals against:
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Law & regulation (incl. sanctions/AML as applicable)
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Ethical standards (below)
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Internal Community Council rules (below)
If compliant → executes payout. If not → returns with specific violated rule(s).
- Designated signatory: Administrative “release” step after compliance passes (no content-based judgment).
3) Core ethical principles (non-negotiables)
Projects must align with:
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Do no harm: avoid facilitating fraud, exploitation, harassment, unsafe behavior, or illegal conduct.
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Transparency: honest claims, clear scope/budget, verifiable progress reporting.
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Fairness & inclusion: no discrimination; respectful community conduct.
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Privacy & security by design: minimize data collection; protect users; responsible disclosure.
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Accountability: clear ownership, milestones, and consequences for misuse.
4) Hard prohibitions (automatic rejection unless the proposal is fundamentally changed)
The Community Council must not fund any proposal that involves, enables, promotes, or materially supports:
4.1 Illegal activity
- Any criminal activity, stolen funds, hacking for harm, evasion techniques intended for crime, IP infringement/piracy, or unlawful surveillance.
4.2 Gambling and wagering
- Casinos/slots/roulette, betting, lotteries, or anything requiring gambling licenses where not held.
4.3 Financial-advice-style projects
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Trading signals, “buy/sell/hold” calls, personalized portfolio guidance, “guaranteed returns,” copy-trading promotion, pump groups, paid alpha rooms, or marketing that induces investment decisions.
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Exceptions: neutral education (e.g., how staking works), developer tooling & research, as long as it includes clear disclaimers and avoids prescriptive recommendations.
4.4 Regulated financial services without licensing
- Unlicensed exchange/brokerage, custody-as-a-service, money transmission, structured yield products, token sales promising profit, or anything that plausibly triggers licensing/securities obligations without an appropriate compliance plan.
4.5 Sanctions / restricted jurisdictions
- Payments to sanctioned individuals/entities or prohibited regions, or projects designed to evade sanctions/controls.
4.6 Fraud and deception
- Misrepresentation of team identity, fake metrics, plagiarism, hidden conflicts, undisclosed paid endorsements, or deceptive marketing.
4.7 Harmful or extreme content
- Hate/harassment, incitement to violence, terrorist propaganda, or content whose primary purpose is harm.
5) Conflicts of interest, integrity, and recusal (Community Council governance ethics)
5.1 Disclosure
- Community Council members must disclose any financial, professional, or close personal ties to applicants (including “I will benefit from this grant”).
5.2 Recusal
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A member with a conflict of interest must not participate in deliberation or voting on that proposal.
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“Self-dealing” (funding your own project) is not automatically banned, but requires:
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full disclosure,
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recusal,
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heightened transparency (public rationale and budget scrutiny).
5.3 Gifts and undue influence
- No gifts, payments, or favors to Community Council members from applicants (beyond nominal swag). Any attempt = grounds for rejection and escalation.
6) Compliance requirements for recipients (what proposals must include)
Every proposal must provide, at minimum:
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Identity & contact of responsible lead (individual or entity).
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Budget and use-of-funds breakdown (including any compensation).
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Deliverables and milestones with dates.
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Public-facing communications plan (what will be claimed/promised).
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Wallet address for payout + acknowledgement of sanctions/AML screening where applicable.
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Risk notes: if code deployment, data handling, or custody-like functionality is involved.
7) Payout controls
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Default: milestone-based payments (e.g., 50/50 or 40/30/30) for larger grants.
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Receipts/invoices: required for reimbursements and service-like work (as feasible).
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Clawback / suspension: Team Nimiq may pause future tranches if:
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funds are misused,
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reporting is materially false,
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prohibited activity emerges,
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sanctions/compliance issues arise.
8) Transparency & recordkeeping (minimum standard)
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Public forum thread must include: proposal, decision, vote tally, short rationale, and any required mitigations.
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Team Nimiq compliance response must cite the specific rule section when returning/rejecting.
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Keep internal records of: payout amounts/dates, recipient details, compliance checks performed, and any incident reports.
9) Review workflow
Step A - Community Council decision (≤ 2 weeks): vote + rationale posted.
Step B - Compliance gate (≤ 1 weeks): Team Nimiq returns one of:
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Compliant → payout execution
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Compliant with conditions → list conditions (e.g., add disclaimer, adjust copy, remove wagering element)
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Non-compliant → cite violated sections and required changes
10) Enforcement and escalation
Any Community Council member can escalate suspected:
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conflict-of-interest violations,
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harassment/misconduct,
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fraud,
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attempts to bribe/influence decisions,
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repeated non-compliance
to the Nimiq Board.
- Sanctions can include: recusal enforcement, removal per your probation rule, proposal bans for repeat bad actors, and public notice where appropriate.
11) Minimal “Applicant Attestation” (paste into every proposal template)
Applicants must affirm:
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“My project and requested funding comply with the Community Council guidelines (legal, gambling, financial advice, sanctions, fraud).”
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“I will not use funds for prohibited purposes.”
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“I will disclose conflicts, sponsorships, and material risks.”
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“I accept milestone reporting and the possibility of payout suspension for non-compliance.”
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“I’m not from a sanctioned country or a sanctioned individual”