Anti-Fraud Policy

Identity Music stands firmly against all forms of fraud, misrepresentation and infringement in the music industry. Through thorough vetting processes at all stages of the distribution and publishing processes (pre-agreement, pre-distribution and post-distribution), we take pride in doing everything in our power to ensure that only content that meets our stringent criteria is delivered to, kept live on, and earns money from DSPs.

This Policy will outline our stance on fraudulent and illegitimate behaviour, our processes for detecting such activity, and the consequences of committing fraudulent activity while distributing content with Identity Music Ltd.

Note: this Policy is regularly reviewed and may be updated at any time without prior notice.

Fraudulent Activity

Our Anti-Fraud Policy applies to any fraudulent behaviour that results in copyright infringement, illegitimate earnings, or misrepresentation of identity or content. This includes but is not limited to:

• Attempting to distribute or claim rights to content that infringes on a third party’s copyright, including using samples or beats without appropriate licenses and/or permissions from the relevant rights holders;
• Using misleading or deceptive artist, band or label names to mislead listeners and/or service providers;
• Attempting to distribute or claim rights to content that contains deceptive features, including, but not limited to, distorted sounds and silenced tracks;
• The use of automated or digital bots to artificially ‘click’ on payment-generating links to generate illegitimate revenue;
• The use of automated or digital bots to artificially stream music on DSPs to generate illegitimate revenue;
• Any breach of industry regulations, including but not limited to those of industry bodies, such as Merlin, Music Fights Fraud Alliance (MFFA), and others;
• Any breach of UK laws;
• Any breach of a DSP’s own Terms of Service or Identity Music Ltd’s Terms of Service.

Detecting & Preventing Fraudulent Activity

Identity Music Ltd relies on comprehensive Quality Assurance processes and third party data, including that provided by DSPs themselves, to identify, assess and combat fraudulent activity.

Prior To Offering A Distribution or Publishing Agreement

Our A&R Team follow an in-depth Know Your Client (KYC) process to vet all potential Identity Music Ltd clients. The process includes but is not limited to:

• Validating an applicant’s identity, through ID verification, video calls to confirm identity, or other means;
• Using third-party tools to assess music content for copyright infringement or AI usage;
• Assessing streaming data and trends to identify potential artificial streaming violations.

Only applicants who pass our A&R KYC process will be offered access to Identity Music Ltd’s services. In the case where ID verification is performed, Identity Music Ltd may use a third-party verification service to confirm identity and securely process identity documentation.

Identity Music Ltd reserves the right to re-evaluate or revoke distribution or publishing agreements at any time, subject to the terms and conditions laid out in a distribution or publishing agreement.

Prior To Music Distribution

Our internal Quality Assurance process is conducted prior to distribution of content uploaded to our platform by clients or assertion of publishing rights over content and includes but is not limited to:

• Reviewing client-provided metadata to ensure it conforms to best practices and complies with DSP requirements;
• Listening to audio files to identify low quality or extended periods of silence;
• Using third party software to review audio files to identify undisclosed use of samples, beats, lyrics, or other matches to copyrighted material;
• Ensuring only content uploaded to accounts that have an active distribution agreement with Identity Music Ltd (and have therefore been approved by the A&R team) is distributed to platforms;
• Removing specific non-Rights Management platforms from distribution where content does not meet platform requirements;
• Removing Rights Management platforms from distribution where content does not meet platform requirements.

Any content that does not meet our Quality Assurance standards will be returned to the client to rectify prior to distribution or will not be claimed through publishing administration. We withhold the right to refuse distribution or publishing of any content that does not meet our standards.

After The Distribution Of Music

After the distribution of music to platforms, Identity Music Ltd monitors content to ensure that it remains compliant with our Quality Assurance standards and the requirements of DSPs.

Fraudulent activity may be identified through:

• The receipt of a copyright infringement notice from a third party;
• Streaming data provided by DSPs;
• Receipt of on-platform copyright notices or strikes.

The Consequences of Fraudulent Activity

If fraudulent activity is detected by any means the consequences of that activity remain at Identity Music’s sole discretion. Identity Music Ltd reserves the right to share data or details of fraudulent activity with relevant industry or regulatory bodies where necessary.

Artificial Streaming Offences

In the case of receiving Artificial Streaming data from DSPs, Identity Music Ltd may take the action that includes but is not limited to:

• Issue of written notification to artists and/or labels, alerting them to the presence of Artificial Streaming on their releases;
• Issue of a formal written warning to artists and/or labels, highlighting the consequences of reoffence;
• Temporary withholding (up to 5 years to allow for legal claims by DSPs or rights holders to be fully processed) of earned revenue from fraudulent streaming;
• Issue of monetary fines applied to a user’s distribution account;
• Immediate and irreversible distribution account and contract termination.

Copyright Offences

In the case of copyright infringement being identified prior to distribution of content, Identity Music Ltd may:

• Request additional copyright information to assess the user’s rights to distribute the identified content;
• Deny distribution to Rights Management platforms and/or other DSPs if full rights are not held to that identified content;
• Refuse distribution to any platforms;
• Immediately and irreversibly relinquish publishing rights to identified content;
• Immediately and irreversibly terminate a user’s distribution account and contract.

In the case of Identity Music Ltd being notified of a copyright infringement after the distribution of content, Identity Music Ltd will conduct an investigation into the legitimacy of the copyright claim. If it is found that content distributed by Identity Music Ltd does infringe on another party’s copyright, consequences may include but are not limited to:

• The immediate takedown of offending content from all DSPs;
• Temporary withholding (up to 5 years to allow for legal claims by DSPs or rights holders to be fully processed) of earned revenue from fraudulent activity;
• Issue of monetary fines applied to a user’s distribution account;
• Immediate and irreversible distribution account and contract termination.

Right To Appeal

All Identity Music Ltd clients have the right to appeal a decision made by Identity Music Ltd where fraudulent activity has been detected. Appeals will be reviewed on a case-by-case basis and Identity Music Ltd reserves the right to uphold or revoke its original decision. Appeals can be submitted by contacting Identity Music Ltd and outlining the reasons for your appeal.