CGPH Group General Collaboration Policy
Effective Date:
June 1, 2026
-
Purpose and Scope
This Policy governs the relationship between CGPH Group Ltd. and its subsidiaries, affiliates, and related entities (collectively, the "Group") and any individual or entity acting as an Ambassador.
The purpose of this Policy is to permit exclusively a limited role of institutional brand representation and passive referral, while strictly prohibiting any activity that may constitute, directly or indirectly:
(a) solicitation of investors or prospective investors;
(b) promotion, marketing, distribution, or placement of investment services, financial products, or similar opportunities;
(c) solicitation, promotion, arrangement, or intermediation of credit, loans, financing, or deferred payment solutions;
(d) misleading, aggressive, or otherwise non-compliant commercial conduct.
This Policy shall be interpreted restrictively. Nothing contained herein authorizes the performance of reserved, regulated, or otherwise controlled activities requiring a licence, registration, authorization, or other enabling title in any jurisdiction.
2. Definitions
For the purposes of this Policy:
Ambassador means an independent external individual or entity engaged by the Group exclusively for limited brand representation activities and strictly permitted referral activities.
Permitted Referral means exclusively the following activities:
providing general, factual, and non-promotional information about the existence of the Group;
sharing only materials previously approved in writing by the Group;
transmitting to the Group the contact details of an individual who has independently requested to be contacted, without any recommendation, pressure, persuasion, or discussion of economic or contractual terms.
A Permitted Referral does not include any activity aimed at inducing, encouraging, or facilitating the conclusion of investments, financing arrangements, credit transactions, or similar transactions.
Prohibited Solicitation means any action, communication, or conduct that, directly or indirectly, invites, encourages, persuades, or exerts pressure on any person to make an investment, request or extend credit, transfer funds, or enter into similar transactions, whether through the internet, social media, brochures, telephone calls, messages, meetings, or events.
Approved Materials means exclusively communications, scripts, presentations, posts, messages, invitations, brochures, slides, visual elements, or other content expressly approved in writing by the Group prior to use.
3. Nature of Role and Relationship
Ambassadors operate exclusively as independent contractors. This Policy and any underlying engagement do not create any employment relationship, partnership, joint venture, agency, permanent representation, fiduciary relationship, or any similar relationship.
In order to preserve the limited nature of the role:
no exclusive territory shall be assigned;
no client portfolio shall be assigned;
no minimum targets for sales, placement, investor acquisition, credit origination, or credit promotion shall be established;
no continuing obligation to promote the conclusion of an indefinite series of transactions shall exist.
Any language, practice, or conduct inconsistent with the foregoing is prohibited.
4. Core Principle: No Solicitation, No Promotion, No Distribution
Unless the Group provides a separate, express, specific, and written authorization for a particular activity, an Ambassador shall not solicit, promote, market, distribute, place, or otherwise encourage any person to:
invest with or through the Group;
subscribe to any financial products, instruments, services, or opportunities;
enter into any loan, credit, financing, deferred payment, or indebtedness arrangement;
transfer funds, assets, or financial instruments to the Group or to any third party affiliated with the Group.
This prohibition applies regardless of the communication channel used, including:
websites and landing pages;
social media posts, stories, reels, livestreams, comments, and content;
direct messages, emails, newsletters, and group chats;
telephone calls, audio messages, and video messages;
webinars, podcasts, roundtables, and online or in-person events;
individual meetings, presentations, and gatherings.
5. Strictly Permitted Activities
Subject at all times to any required prior approval, an Ambassador may exclusively:
describe the Group in general, institutional, and corporate terms;
refer to the Group's public identity, official website, and officially approved public information;
present the Group in neutral terms, without discussing economic terms, returns, pricing, investment structures, credit terms, or other transactional matters;
transmit to the Group the contact details of a person who has independently requested such contact;
participate in approved public or institutional events, exclusively in a non-commercial and non-selling capacity.
An Ambassador must immediately discontinue any interaction in which the conversation moves from a purely institutional level to matters relating to investments, credit, returns, pricing, financing, fund transfers, or the conclusion of transactions.
6. Prohibited Activities
6.1 No Investor Solicitation
An Ambassador shall not invite, induce, or encourage any person to invest, subscribe, commit funds, transfer assets, or enter into any investment-related relationship with the Group or with any person affiliated therewith.
6.2 No Credit or Financing Solicitation
An Ambassador shall not promote, offer, present, arrange, negotiate, or encourage any person to enter into any credit, loan, financing, indebtedness, or deferred payment contract. An Ambassador shall not represent the Group as a source of credit or as a party that arranges or procures financing.
6.3 No Personalized or Persuasive Communications
An Ambassador shall not:
make recommendations;
express suitability or appropriateness assessments;
discuss expected returns, profitability, or capital protection;
minimize, obscure, or omit risks;
create urgency, scarcity, pressure, or emotional leverage;
state or imply that any opportunity is exclusive, time-limited, guaranteed, or low-risk.
6.4 No Involvement in Transactional Steps
An Ambassador shall not:
collect or transmit subscription forms, orders, or operational instructions;
assist in the completion of transactional documents;
receive or transmit instructions relating to investments, redemptions, credit arrangements, financing, or fund transfers;
undertake any preparatory or executive act directed toward the conclusion of a transaction.
6.5 No Receipt of Funds or Assets
An Ambassador is strictly prohibited from collecting, receiving, holding, transmitting, or managing any sums of money, cheques, banking instruments, payment instructions, financial instruments, or other assets belonging to clients, prospective clients, or third parties on behalf of the Group.
Any attempt by a third party to make payment to an Ambassador must be immediately reported to the Group.
6.6 No Binding Authority
An Ambassador has no authority to bind the Group, enter into agreements, assume commitments, negotiate terms, confirm acceptances, promise benefits, or make binding statements in the name of or on behalf of the Group.
6.7 No Reverse Solicitation Workaround
An Ambassador shall not use, procure, or rely upon any contractual clause, disclaimer, click-box, or client statement asserting that the client acted on his or her own exclusive initiative where any prior activity, whether direct or indirect, involving solicitation, promotion, or advertising has taken place.
6.8 No Aggressive or Misleading Conduct
An Ambassador shall not engage in conduct that is misleading, incomplete, obscure, ambiguous, coercive, oppressive, or likely to exert undue influence, including unsolicited repeated contacts, pressure tactics, exploitation of vulnerability, or omission of material information.
6.9 No False Appearance of Authority
An Ambassador shall not represent himself, herself, or itself as:
an employee, officer, or partner of the Group;
an authorized adviser, broker, tied agent, financial promoter, or credit intermediary;
a person authorized to accept funds, instructions, orders, or commitments.
Titles, biographies, email signatures, digital profiles, business cards, and social media descriptions must be approved in writing by the Group in advance.
6.10 No Sub-Delegation
An Ambassador may not appoint sub-ambassadors, referral partners, introducers, agents, channel partners, or similar persons without the Group's prior written approval.
7.Communications and Social Media
All public or private communications by an Ambassador concerning the Group require the Group's prior written approval, unless they consist exclusively of previously approved content used without any modification.
The following rules apply in all circumstances:
no original promotional content may be created without prior approval;
no paid advertising may be used;
no direct outreach targeting investors, prospective investors, credit applicants, or prospective credit applicants is permitted;
no statements may be made regarding performance, returns, profitability, safety, risk reduction, credit availability, pricing, or suitability;
all approved communications must be accurate, clear, transparent, and not misleading.
8.Conflicts of Interest, Gifts, and Third-Party Benefits
An Ambassador must promptly disclose to the Group any actual, potential, or even perceived conflict of interest, including personal, financial, commercial, or family relationships that may affect his, her, or its independence or impartiality.
An Ambassador may not accept, solicit, or receive gifts, commissions, fees, compensation, reimbursements, advantages, or other benefits from third parties in connection with his, her, or its role, except with the Group's prior written authorization.
The Group shall adopt and maintain procedures adequate for the identification, management, and recording of conflicts of interest.
9. Compensation Structure
Compensation of Ambassadors, where applicable, shall be governed exclusively by the relevant written Ambassador Agreement.
It is understood, in any event, that:
the compensation structure shall not incentivize activities involving the promotion, placement, solicitation, or commercial pressure relating to investments, financing, or credit;
the compensation structure shall not be linked to assigned territories, client portfolios, or minimum transaction volumes;
no client or third party may pay any amount to an Ambassador on behalf of the Group.
10. Training, Procedures, and Recordkeeping
Prior to carrying out any activity, each Ambassador must complete any onboarding and compliance training required by the Group.
The Group may develop scripts, FAQs, prohibited-language lists, approval matrices, and channel-specific or context-specific operational instructions. Ambassadors are required to comply with them fully.
The Group may further require Ambassadors to:
maintain records of approved communications and interactions;
use exclusively authorized channels;
submit to periodic checks, compliance reviews, and audits;
periodically confirm that they have not engaged in any prohibited activities.
11. Complaints, Incidents, and Escalation
An Ambassador must immediately notify the Group in the event of:
any complaint or dispute from a client or prospective client;
any request for clarification regarding investments, credit, returns, products, or economic terms;
any request for transactional assistance;
any request for payment or transfer of money or assets to the Ambassador;
any suspected violation of this Policy or of applicable local law;
any request for information, warning, inspection, or investigation by a regulatory authority or supervisory body.
In such cases, the Ambassador must immediately cease the relevant activity and await instructions from the Group.
12. Confidentiality and Data Handling
An Ambassador must maintain strict confidentiality with respect to all non-public information received in connection with the relationship with the Group, including commercial information, client data, strategies, financial data, internal processes, and confidential materials.
Personal data and contact information may be processed exclusively in accordance with the Group's instructions and solely for authorized purposes. Unauthorized copying, reuse, retention, transfer, or disclosure is prohibited.
13. Monitoring, Controls, and Audit Rights
The Group reserves the right to monitor Ambassador activities in order to verify compliance with this Policy, applicable agreements, and issued instructions.
Such monitoring may cover, among other things:
public and private communications;
digital and social media content;
event participation;
information flows;
activity logs;
compensation records;
reports, incidents, and complaints.
Ambassadors are required to cooperate fully with any audit, review, or inspection.
14. Breach, Suspension, and Termination
Any breach of this Policy constitutes a material breach of the engagement.
The Group may, with immediate effect:
suspend the Ambassador's activities;
order the removal of communications or content;
require corrections or corrective statements;
terminate the engagement;
withhold or suspend unpaid compensation to the extent permitted by the applicable agreement;
exercise any further contractual or legal remedy available.
Unauthorized statements or conduct by an Ambassador shall not be binding upon the Group. The Ambassador shall nonetheless be required to cooperate fully with all remedial, investigative, and mitigation activities required by the Group.
15. Local Law and Stricter Rule Prevails
Each Ambassador remains solely responsible for compliance with the laws, regulatory restrictions, platform rules, and market practices applicable in the jurisdiction where the Ambassador operates or where the relevant communication is received.
Where local laws, internal instructions, platform rules, or market practices impose standards more stringent than those set forth in this Policy, the more stringent rule shall prevail.
Nothing in this Policy authorizes conduct that is prohibited, restricted, or subject to prior authorization in any given jurisdiction.
16. Governing Law and Jurisdiction
This Policy and any non-contractual obligations arising out of or in connection with it shall be governed by the laws of England and Wales.
17. Publication, Access, and Updates
This Policy is published on the Group's official website and is freely accessible to Ambassadors, prospective Ambassadors, clients, prospective clients, and other stakeholders.
Publication of this Policy is intended to promote transparency, provide information, and clearly define the operational boundaries applicable to the Ambassador role.
The Group reserves the right to modify, update, or replace this Policy at any time. Unless otherwise expressly indicated, the version published on the Group's official website from time to time shall be the operative version.
For Ambassadors formally engaged by the Group, compliance with this Policy constitutes a condition of the engagement as set forth in the relevant Ambassador Agreement, the Group's written instructions, and any other applicable internal procedures.
For any questions or clarifications regarding this Policy, please contact: info@cgph.info