Modere Social Marketer Education and Compliance Department

Modere consider it a priority for Social Marketers to have a proper understanding of the Modere Social Marketer Agreement (“Agreement”). Social Marketers who have a good understanding of the Agreement would be in a good place to comply with the terms of the Agreement, which is to the benefit of Modere, the Social Marketer and the Social Marketer organisation.

The Agreement consists of the Application for a Social Marketer Agreement, the Policies and Procedures and the Compensation Plan.

We understand that you may sometimes find the language in the Agreement rather vague. If you are in doubt on the Application or the Policies and Procedures, the Social Marketer Education and Compliance department is the place to turn to with your questions. So if you are asking yourself, for instance, whether you can post income claims or try to sell Modere product from a social media site, publish a personal Social Marketer website, or sell your Social Marketer account, make a good effort to consult the Policies and Procedures first and submit an email to compliance@modere.eu for anything that is not clear. It is best to detail your questions so that our response may be targeted appropriately.

The Modere Social Marketer Education and Compliance department also investigates reports of breaches of the terms of the Agreement as per clause 5.7 of the Policies and Procedures (see below). These reports must also be sent directly to compliance@modere.eu. In order for Modere to act on the reports, the reports should include sufficient details related to the allegation, such as: the full name of the Social Marketer who is deemed to be in breach, the nature of the deemed breach and the date of the occurrence. If the report concerns solicitation we also need the full name of the Social Marketer(s) who was (were) solicited preferably with evidence of the solicitation attempt. For screenshots of a conversation or a message, we need to know the date of the conversation or the message and the names of the Social Marketers who received the message. Without sufficient details we may not always be able to start an investigation.

Social Marketers may send compliance@modere.eu an email from the email address saved in their Modere account, or they may send us a silent whistle. The silent whistle functionality is available in the Back office on the Shifting Retail website. Note, silent whistles are anonymous. If they do not contain the details that we need to start an investigation, we cannot act on them.

We’d also like to make you aware that investigations can take a long time, as well as our processes to address breaches. And if a Social Marketer account has been found to be in breach, the process remains entirely confidential between that Social Marketer and Modere.

Policies and Procedures

5.7 REPORTING POLICY VIOLATIONS

Social Marketers observing a policy violation by other Social Marketers should submit a written report of the violation directly to the attention of the Modere Social Marketer Education & Compliance Department. Details of the incidents, such as dates, number of occurrences, persons involved, and any supporting documentation, should be included in the report. Because of the difficulties of investigating and asserting appropriate remedies for stale claims, any complaint for breach of the terms and conditions of the Agreement other than Non-Solicitation must be brought to the Company’s attention for review within eighteen (18) months of the start of the alleged violation; Non-Solicitation violations must be brought to the Company’s attention within six (6) months of the alleged violation. Failure to report a violation within that time period may result in the Company not pursuing the allegations in order to prevent the business from being negatively impacted due to stale claims. However, this policy does not waive the Company’s right to investigate and discipline Social Marketers found guilty of the stale claims.