Civil (CVL) Transparency Scorecard Summary This scorecard attempts to assess the quality of Civil’s statements and documentation based on the Transparency Goals outlined in The Brooklyn Project’s Consumer Token Framework. This assessment focuses on the completeness, clarity and consistency of the disclosures; it does not attempt to opine on the veracity of the disclosures or the merits or substance of the practices described. We invite you and the community to participate in verifying and diligencing these disclosures with us. LEGAL NOTICE - MUST BE READ PRIOR TO USE This document should be viewed as starting a conversation to help improve the transparency of projects. This document does not create an attorney-client relationship or privilege with or among anyone, and no one should rely on this document as legal advice. Likewise, this document is not the final authority on what Civil and its associated persons have said or will say about any particular topic. If you are interested in purchasing CVL tokens, you must conduct your own due diligence and analysis of CVL tokens to determine if they are appropriate for you. Consumer Token Framework Scorecard
Principle Score Consumer Token Design 10 Project Governance and Operation 8 Responsible Token Distribution 9 Purpose of Token Distribution 9 Token Supply 10 Mitigation of Conflicts and Improper Trading 8 Token Safety and Security 8 Marketing Practices 9 Protecting and Empowering Consumers 9 Compliance with Applicable Laws 10 OVERALL TRANSPARENCY SCORE 9
The transparency score is a reflection of the following three factors:
Completeness: Does the project describe its complete approach to the relevant topic? Are all facts on the table or are some important pieces of information missing?
Clarity: Are the disclosures easy to understand? Consumer tokens can be complex, so it is important to consider how easy it is to comprehend the information being disseminated.
Consistency: Does the project describe its approach consistently, or are there conflicting pieces of information that could lead to confusion about the project’s approach?
Judged on these factors, the following scores and symbols are assigned within the scorecard to indicate the quality of relevant statements for each topic.
Not applicable. Not applicable at the time of assessment. 1-2 Red flag. Disclosures are non-existent or contain directly conflicting information. 3-4 Poor. Disclosures fail to reveal any useful information. 5-6 Present but lacking. Disclosures are only partially complete or lacking in clarity or completeness. 7-8 Good. Disclosures meet standards, but have room for improvement. 9-10 Very good. Disclosures are complete, clear, easy to understand and consistent.
Sources:
The primary sources of information used to compile this Transparency Scorecard include:
Civil Whitepaper Civil Website The Civil Project Page on the Token Foundry website (TF), Civil’s Medium Page, and other publicly available sources were used as secondary sources. In addition, the Civil Constitution is mentioned as a key governance document.
Principle 1: Consumer Token Design Transparency score: 10/10
Disclosure Status Source Description of token’s intrinsic features and operation
Whitepaper, Abstract, Introduction, Applying to Start a Civil Newsroom, The Civil Registry, Core Product, The CVL Token Economy, An Overview of the Civil Registry, Technical Details of the Civil Registry, Listing Definition, Contract Design Overview; Civil Website - Terms of CVL token sale and use, CVL tokens: Why they matter, and what they do; Medium Post - CVL Tokens: A Primer, The CVL Token Sale is LIVE!, Announcing the CVL Token Launch - CVL Token Metrics The Brooklyn Project Token Taxonomy classification
Statement from Civil (below); Civil Website - Help and support - FAQs - CVL Token Sale - Is CVL a security?, CVL tokens: Why they matter, and what they do - 6 Key Considerations for Using CVL - CVL is a consumer token; Medium Post - The Civil Cryptoeconomic Whitepaper; Whitepaper, Core Product, The CVL Token Economy, An Overview of the Civil Registry
Analysis:
Description of token’s intrinsic features and operation:
The Civil Media Company discloses that activity on the Civil platform will be managed by an Ethereum blockchain-based token, CVL. Whitepaper, Abstract.
CVL is described as “the software that connects the Civil platform to the Ethereum blockchain — and which manages all transactions tied to the platform’s self-governance.” Whitepaper, Applying to Start a Civil Newsroom. The Terms of CVL token sale and use provided on the Civil Website also clarify that “Ownership of CVL carries no rights, express or implied, other than the right to use CVL as a means to participate in the Platform as provided in our Terms of Service.”
CVL can be used to:
Compensate newsmakers via web wallets. Whitepaper, Introduction “[S]erve as a peer-to-peer payments system that will allow readers to directly support journalists publishing on the Civil platform.” Medium Post - The CVL Token Sale is LIVE! Stake to apply for a newsroom on Civil platform. Whitepaper, Applying to Start a Civil Newsroom Stake to challenge ability of newsroom to appear on Civil Registry. Whitepaper, Applying to Start a Civil Newsroom Vote on challenges to newsroom applications. Whitepaper, Applying to Start a Civil Newsroom Stake to appeal outcome of community vote to Civil Council. Whitepaper, An Overview of the Civil Registry - Appeals & Vetos Stake to initiate veto challenge to Civil Council decision. Whitepaper, An Overview of the Civil Registry - Appeals & Vetos Stake to propose and challenge changes to Civil’s dynamic parameters. Whitepaper, An Overview of the Civil Registry - Parameters & Amendments Stake to propose and challenge Amendments to the Civil Constitution. Whitepaper, An Overview of the Civil Registry - Parameters & Amendments Stake to initiate a veto challenge to Civil Council’s decisions re: Amendment proposals. Whitepaper, An Overview of the Civil Registry - Parameters & Amendments
The Civil Media Company describes CVL’s intrinsic features and operation as part of a “token-curated registry process [that] introduces economic incentives for ensuring a high-quality filter for all journalism published on Civil.” Whitepaper, Applying to Start a Civil Newsroom, The Civil Registry. Company also notes that such token-curated registry model “will expand significantly and be the self-governance system for every organization operating within the Civil ecosystem.” Whitepaper, The Civil Registry. Additional details could be provided regarding the role of CVL token holders (if any) in such expanded self-governance functions in Civil ecosystem for better completeness and clarity.
The Civil Media Company further clarifies Civil’s token-curated registry process and ecosystem with simple graphics and concept of the Waterline, Whitepaper, The CVL Token Economy, as well as illustrative examples of how this cryptoeconomic model incentivizes participation, adherence to “good behavior,” and makes it “prohibitively difficult” for bad actors and actions to disrupt the Civil platform. Whitepaper, An Overview of the Civil Registry. Company also provides a good amount of detail over this process in the Whitepaper section, An Overview of the Civil Registry, as well as through additional graphical representations of the Civil token-curated registry process—Civil Registry - Newsroom Listing Lifecycle.
The Civil Media Company also describes the CVL token as based on the ERC-20 protocol, and as a “value stored in a decentralized database that’s managed by Civil’s smart contracts, which allows the Civil platform to interact with the CVL token,” and “bridges Civil with the Ethereum blockchain.” In this manner, the Company elaborates that CVL “unlocks two vital business features for newsmakers: self-governance and permanent archiving,” which is “vital to Civil’s overall model.” Whitepaper, Core Product. Adding clarity, a Civil blog post discloses that the “CVL token exists to provide functionality with respect to the Civil Registry only at this time.” Medium Post - Announcing the CVL Token Launch - CVL Token Metrics.
Company further provides technical details related to the token-curated Civil Registry. Whitepaper, Technical Details of the Civil Registry, Listing Definition, Contract Design Overview.
Civil Website (particularly, explanatory page, CVL tokens: Why they matter, and what they do), Civil Project Page via Token Foundry (TF) and Civil’s Medium Page also provide clear and complete explanations of CVL, consistent with representations of Civil Whitepaper and Civil Constitution. In particular, a dedicated blog post clearly summarizes CVL as:
the software with which journalists will launch independently owned and operated Newsrooms; CVL will also enable citizens to enforce and advance Civil’s ethical journalism standards across the entire network. They are the utility with which the Civil community will be able to impact the network’s long-term growth and evolution as a hub for quality, sustainable journalism.
Medium Post - CVL Tokens: A Primer.
The Brooklyn Project Token Taxonomy classification:
The Civil Media Company discloses that “CVL tokens will only be sold to registered purchasers that intend to use them to run Newsrooms and contribute to the long-term development of the Civil protocol. The CVL token sale has been designed as part of the Brooklyn Project Framework and intends to implement certain relevant provisions from the Token Foundry Standards for consumer tokens.” Civil Website - Help and support - FAQs - CVL Token Sale - Is CVL a security?. Similarly, the explanatory page regarding the CVL token provides this more detailed description: CVL is a consumer token, based on the framework produced by the Brooklyn Project. To ensure that the Civil Media Company follows all responsible steps in building a decentralized network, all CVL owners will be required to verify their identities before acquiring CVL. If they choose to sell CVL on the secondary market, they must prove they have used CVL for its intended purposes. For a minimum of 12 months, only users who plan to use CVL tokens for their intended purpose and have completed a Know Your Customer (KYC) process on either Token Foundry or civil.co will be able acquire CVL tokens, including via direct transfers from other CVL token holders.
Civil Website - CVL tokens: Why they matter, and what they do - 6 Key Considerations for Using CVL - CVL is a consumer token.
Statement from Civil: CVL was designed as a consumer token, per the Brooklyn Project (@TheBKP_Official) framework. This means that CVL is meant to be a consumer good that serves a specific utility in the Civil marketplace, not a speculative instrument. More info here. https://framework.thebkp.com/project/CVL/document/2/version/3 …
Source: Twitter - @Join_Civil - https://twitter.com/Join_Civil/status/1042121470715953152
These descriptions provide a complete and clear disclosure re: CVL token taxonomy classification, consistent with representations of Civil Whitepaper, Civil Constitution and related blog posts, such that a purchaser can understand CVL as “[t]okens that are inherently consumptive in nature, because their intrinsic features and primary use are to represent, or provide access to, a limited set of goods, services, and/or content,” as defined in the The Brooklyn Project Token Taxonomy. Better clarity and consistency could be reached here if adherence to Brooklyn Project Framework and Token Taxonomy was also made explicit in Civil Whitepaper and Civil Constitution.
Principle 2: Project Governance and Operation Transparency score: 8/10
Disclosure Status Source How and by whom the project will be governed
Whitepaper, Abstract, Introduction, Waterline, Civil Registry - Newsroom Listing Lifecycle, Applying to Start a Civil Newsroom, Community Checks and Balances, Civil Foundation, The CVL Token Economy, The Civil Ecosystem Vision, Pioneering a New Approach, An Overview of the Civil Registry - Parameters & Amendments, Community Checks and Balances - Civil Council Initial Iteration; TF, Decentralization, Resources - 4 Ways to Use CVL; Civil Constitution - Civil’s Governance; Medium Post - CVL Tokens: A Primer, 100 Percent Pledge, The CVL Token Sale is LIVE!, The Civil Foundation — A New Fund to Support Ethical Journalism Around the World Relevant holding or operating company and jurisdiction
Whitepaper, Abstract, The Civil Ecosystem Vision; Civil Website - About - The Civil Ecosystem; Medium Post - How The Civil Media Company Makes Money, And Why It’s Good for Journalism; Civil Constitution - Civil’s Governance; Civil Website - Terms of CVL token sale and use Backgrounds of key people
Whitepaper, Who’s Behind Civil; Civil Website - Our Team; TF, Team; Medium Post - Who’s the team behind Civil?, Meet the Advisors Helping to Shape Civil Description of what part of the project is decentralized, centralized, open-sourced, or “forkable”.
Whitepaper, Community Checks and Balances, The Civil Ecosystem Vision, The CVL Token Economy - Incentivizing Community Developers; TF, Decentralization; Civil Website - Terms - Description of Platform, Access, Proprietary Rights in Content in the Platform, User Feedback, Availability of the Platform, Modifications and Updates; Medium Post - How The Civil Media Company Makes Money, And Why It’s Good for Journalism, Announcing the CVL Token Launch, The Civil Foundation — A New Fund to Support Ethical Journalism Around the World Project roadmap, including key technical and project milestones
TF, Timeline; Whitepaper, Community Checks and Balances - Civil Council Initial Iteration; Civil Website - Terms of CVL token sale and use; Medium Post - The CVL Token Sale is LIVE!, The Civil Foundation — A New Fund to Support Ethical Journalism Around the World Updates on milestone progress and funds
Whitepaper, Community Checks and Balances - Civil Council Initial Iteration; Medium Post - The Civil Foundation — A New Fund to Support Ethical Journalism Around the World.
Analysis:
How and by whom the project will be governed:
The Civil Media Company describes how the Civil project will be mediated via the Ethereum blockchain and CVL token among “consumers, content creators, fact checkers and publishers,” together curating network content and organization of newsrooms. Whitepaper, Abstract. Company further elaborates that this operating model involves two key features: economically incentivized self-governance and permanent recording of authorship and content (“and soon, reputation”), Whitepaper, Introduction.
Regarding project self-governance and token-curation, Company clearly and completely outlines how CVL holders can stake their tokens to apply to list a newsroom on the Civil Registry, challenge similar applications, and vote on such network challenges, suggesting certain governance rights, with such curation process governed by the Civil Constitution (itself subject to community amendment), and appeals available to Civil Council (independent body). Whitepaper, Waterline, Civil Registry - Newsroom Listing Lifecycle, Applying to Start a Civil Newsroom, Community Checks and Balances, The CVL Token Economy, The Civil Ecosystem Vision. In particular, a related blog post clearly summarizes CVL tokens and their role in governance as:
the software with which journalists will launch independently owned and operated Newsrooms; CVL will also enable citizens to enforce and advance Civil’s ethical journalism standards across the entire network. They are the utility with which the Civil community will be able to impact the network’s long-term growth and evolution as a hub for quality, sustainable journalism.
Medium Post - CVL Tokens: A Primer.
In addition to disclosing such self-governance and appeal measures (see above), Company gives detailed descriptions regarding related third-party organizations, specifically, that “The Civil Media Company pledges to build and develop the software to power [ ] community-driven conflict resolution . . . .” Whitepaper, Community Checks and Balances. Further, a Civil blog post describes The Civil Media Company as a “a for-profit, venture-backed blockchain tech company that will build and monetize enterprise and self-service software for newsrooms on Civil and the ecosystem overall.” Medium Post - 100 Percent Pledge.
In terms of historical involvement with Civil’s development and the CVL token sale, a blog post discloses that The Civil Media Company “initially developed the protocol and the platform it powers,” and is “implementing a cooperative model in which decision-making authority will be turned over to a larger community,” via “the launch of CVL, a uniquely designed cryptocurrency,” Medium Post - CVL Tokens: A Primer, while the project Whitepaper also discloses that The Civil Media Company has “allocated $1MM USD in grants to support a ‘First Fleet’ of more than 100 full-time, veteran journalists across approximately 15 newsrooms.” Whitepaper, Pioneering a New Approach. Another Civil blog post discloses that The Civil Media Company has spent “more than a year building a working product, recruiting more than 100 journalists across 14 independent newsrooms and, most importantly, rallying the global community that will form the foundation of the Civil economy,” in preparation for the CVL token sale. Medium Post - The CVL Token Sale is LIVE!.
Further, the project Whitepaper discloses The Civil Media Company’s primary mandates and that it will form (i) the Civil Foundation, an independent, non-profit organization dedicated to upholding the Civil Constitution and supporting the Civil Council, “a protocol oversight body comprised of free speech lawyers, veteran journalists and journalism scholars,” (ii) Civil Newsroom Mutual, “a media liability insurance company cooperatively owned by newsrooms,” (iii) Civil Studios, a for-profit entity “motivated to pilot and fund marquee works of journalism,” and (iv) Civil Labs, a for-profit entity “developing software apps, tools and widgets for the Civil ecosystem.” Whitepaper, The Civil Ecosystem Vision.
Additionally, the project Whitepaper discloses that The Civil Media Company will “create a Civil Constitution contract to which the Civil Registry links,” and thereafter, “put the Civil Council in charge of that contract.” Whitepaper, An Overview of the Civil Registry - Parameters & Amendments. A Civil blog post goes into greater detail on the relationship between The Civil Media Company and the Civil Foundation, also providing a clear graphical representation of Civil ecosystem governance. Medium Post - The Civil Foundation — A New Fund to Support Ethical Journalism Around the World.
Further, the project Whitepaper discloses certain governance milestones, including a two-year timeline for community-led evolution of the Civil Foundation and Civil Council according to proposed goals. Whitepaper, Community Checks and Balances - Civil Council Initial Iteration. Likewise, a Civil blog post announces that the “Civil Foundation is on its way to being an entirely independent, 501(c)(3) not-for-profit entity,” with a “hope to have all this completed by the end of the year.” Medium Post - The Civil Foundation — A New Fund to Support Ethical Journalism Around the World.
Regarding other parties related to the Civil project and CVL token sale, the project Whitepaper discloses the key people behind The Civil Media Company, as well as its key investors and partners, including ConsenSys, Old Town Media, Morris Manning and Martin, and Klaris Law. More complete detail could be provided regarding ConsenSys’s role as “deep technology partner and lone investor,” as well as the other named partners. Similarly, greater detail could be provided regarding the structure of The Civil Media Company, such as whether the disclosed “primary mandates” are contained in corporate governance documents.
These important disclosures appear consistent with simplified explanations provided on secondary sources, such as the Civil Project Page on the Token Foundry website and Civil Constitution.
Relevant holding or operating company and jurisdiction:
Civil Whitepaper, Civil Website, Civil’s Medium Page, and Civil Constitution provide disclosures regarding the role of The Civil Media Company and the Civil Foundation in supporting the Civil ecosystem and managing CVL token sale proceeds. More complete information could be provided, however, regarding the state of formation, corporate structure and governance of The Civil Media Company and the Civil Foundation, though the Terms of CVL tokens sale and use discloses that The Civil Media Company is a Delaware corporation.
Backgrounds of key people:
Civil Whitepaper, Civil Website, the Civil Project Page on the Token Foundry website, and Civil’s Medium Page provide complete, clear and consistent descriptions of the background of key people involved in The Civil Media Company and Civil ecosystem.
Description of what part of the project is decentralized, centralized, open-sourced, or “forkable”:
Civil Whitepaper and the Civil Project Page on the Token Foundry website disclose key actors involved in the Civil project initiation, including comprehensive descriptions of the Civil ecosystem that help gauge the project’s current and projected levels of decentralization. Whitepaper, Community Checks and Balances, The Civil Ecosystem Vision; TF, Decentralization.
Providing additional detail, the project Whitepaper notes that The Civil Media Company shall serve as “core maintainers” at the Civil “protocol level” (Civil Registry, CVL token software), while elaborating that such development efforts shall be open-sourced and that “vast community involvement” will be encouraged. Whitepaper, The Civil Ecosystem Vision - The Civil Media Company. Specifically, the Whitepaper also provides a link to The Civil Media Company’s GitHub page, and states the Company’s commitment to “open source the code for all of its citizen-facing software and make it accessible” at such link. Whitepaper, The CVL Token Economy - Incentivizing Community Developers.
Additional clarity could be provided on The Civil Media Company’s role as “core maintainers” of the Civil protocol. For example, the Terms section of the Civil Website discloses that The Civil Media Company has various controls over the operation of the Civil platform and discretion that could be made more clear in other Civil sources and public channels. Civil Website - Terms - Description of Platform, Access, Proprietary Rights in Content in the Platform, User Feedback, Availability of the Platform, Modifications and Updates. Similarly, a Civil blog post discloses that “The Civil Media Company will soon publish its Civil Constitution, which upon our token launch, will assume authority over our token-operated protocol,” while the Civil Whitepaper details a plan for community-driven amendments and greater decentralization. Medium Post - How The Civil Media Company Makes Money, And Why It’s Good for Journalism. In addition, a blog post makes the following disclaimer regarding prospective decentralization:
Disclaimer: Although the Civil protocol will be deployed in complete and decentralized form, only the Civil Registry and its associated actions listed above will be initially available for Newsrooms and Citizens through the Civil protocol and network. Further potential use cases may emerge over time as Civil evolves, since this governance mechanism is meant to serve as the foundation for the entire Civil ecosystem. These additional utilities (direct or indirect) depend on a variety of factors, including the pace of Civil Newsroom adoption, the organic community-driven expansion of the network, and the requisite addition of new technologies as yet unknown built on the Civil protocol. As such, if or when new utilities emerge for the CVL token is not fully within the control of The Civil Media Company and cannot be stated with any certainty.
Medium Post - Announcing the CVL Token Launch.
A Civil blog post also announces that the “Civil Foundation is on its way to being an entirely independent, 501(c)(3) not-for-profit entity,” with a “hope to have all this completed by the end of the year,” while such details could be better clarified in other Civil sources. Medium Post - The Civil Foundation — A New Fund to Support Ethical Journalism Around the World. For example, there is an apparent inconsistency between an earlier blog post that describes the Civil Foundation as “independent” and the later post that discloses that it “is on its way to being an entirely independent.”
Project roadmap, including key technical and project milestones:
The Civil Project Page on the Token Foundry website provides a clear timeline detailing key background events leading up to CVL token sale, as well as projected near-term technical and project milestones (also noting that dates are provided as an “estimate”). Likewise, a Civil blog post states that the (i) “Civil platform will launch on Ethereum mainnet within one week of the sale’s completion,” Medium Post - The CVL Token Sale is LIVE!, while the Terms of CVL token sale and use more specifically provides that “[e]xpected mainnet launch of the Civil network is October 7, 2018, however there is a chance that the Civil network launch could get delayed.”
Further, the Civil Whitepaper discloses certain governance milestones, including a two-year timeline for community-led evolution of the Civil Foundation and Civil Council according to proposed goals. Whitepaper, Community Checks and Balances - Civil Council Initial Iteration.
In addition, a Civil blog post announces that the “Civil Foundation is on its way to being an entirely independent, 501(c)(3) not-for-profit entity,” with a “hope to have all this completed by the end of the year.” Medium Post - The Civil Foundation — A New Fund to Support Ethical Journalism Around the World. This stated goal and the Civil Foundation’s current status could be made more explicit in other Civil sources to aid clarity.
Updates on milestone progress and funds:
Civil Whitepaper describes a timeline and commitment by the “Civil Council Initial Iteration” and Civil Foundation to publish updates and proposals related to the amendment of Civil Constitution for community feedback. Whitepaper, Community Checks and Balances - Civil Council Initial Iteration.
A Civil blog post discloses that the Civil Foundation will “communicate all [ ] numbers transparently via 990 filings” regarding its overhead, out-of-pocket expenses, and grant-making from CVL token sale proceeds. Medium Post - The Civil Foundation — A New Fund to Support Ethical Journalism Around the World.
More complete information and additional clarity could be provided regarding The Civil Media Company’s commitment to update community on progress towards planned technical and project milestones, as well as where to reliably receive such information after the CVL token sale.
Principle 3: Responsible Token Distribution Transparency score: 9/10
Disclosure Status Source Purpose of any token distributions
Civil Website - Partners, CVL tokens: Why they matter, and what they do - 6 Considerations for using CVL - Initial CVL Network Participants, Terms of CVL token sale and use; Medium Post - 100 Percent Pledge, The CVL Token Sale is LIVE!, Announcing the CVL Token Launch - CVL Token Metrics; TF, Timeline - CVL Token Launch Legal entity that distributed tokens
Civil Website - CVL tokens: Why they matter, and what they do - Introducing CVL tokens, Help and Support - FAQs - How CVL tokens work; Medium Post - The CVL Token Sale is LIVE!, The Fastest Way to Buy CVL Tokens, 100 Percent Pledge Conditions a token purchaser must meet to receive tokens
Civil Website - Help and support - FAQs - CVL Token Sale - Is there a minimum and a maximum contribution or purchasing level?, What should I do to prepare for the token sale prior to September 18? Do I need to complete a KYC (Know Your Customer) like other token sales?, CVL tokens: Why they matter, and what they do - 6 Key Considerations for Using CVL - CVL is a consumer token, Token Sale Flow; Medium Post - The CVL Token Sale is LIVE!, Proof of Use and Transferability Terms of token distributions (e.g., lockups, vesting)
Statement from Civil (below) Stage of development of the project at time of token distribution
TF, Timeline - CVL Platform Launch (October 2018); Medium Post - The CVL Token Sale is LIVE!, Announcing the CVL Token Launch - CVL Token Metrics; Whitepaper, An Overview of the Civil Registry - Parameters & Amendments
Steps to limit sale to individuals who do not intend to consume token
Civil Website - Token Sale Flow; Medium Post - The CVL Token Sale is LIVE!, Proof of Use and Transferability, The CVL Token Sale Will Begin September 18 — Here’s Why - Adjusting Our Hard Cap, or the Maximum Value We’ll Accept for CVL Specification of whether (or not) anyone owes duties to increase token price
Token Foundry Registration Process (see below) Restrictions and plans for secondary trading
Medium Post - Proof of Use and Transferability Whether lockups or vesting schedules are enforced through smart contracts or company policy.
Statement from Civil (below)
Analysis:
Purpose of any token distributions:
The Civil Website discloses that The Civil Media Company will “allocate CVL tokens to mission-aligned organizations to ensure the network’s growth and the continued, healthy development and decentralization of Civil's token-based economy.” Civil Website - Partners. Further, the Civil Website states that “each of Civil’s First Fleet Newsrooms will possess CVL tokens and will be actively participating in the network’s governance from day one.” Civil Website - CVL tokens: Why they matter, and what they do - 6 Considerations for using CVL - Initial CVL Network Participants.
The Civil Media Company also pledged through a dedicated blog post that “100% of net proceeds received in [the] upcoming CVL token sale will go to the Civil Foundation to fuel grants for worthy journalism projects, with direct input and ongoing involvement from CVL token holders,” and elaborated that the “Civil Foundation will oversee a multi-million dollar grant fund that will initially come from the CVL token sale. Grants will be made to worthy recipients to help expand the quality, breadth and diversity of journalism on Civil.” Medium Post - 100 Percent Pledge. This “100% Pledge” is also clearly reflected throughout the Civil Website and additional Civil sources.
Regarding the CVL token sale, the Civil Project Page on the Token Foundry website discloses that The Civil Media Company is “mak[ing] CVL tokens available for purchase for the first time in an effort to distribute tokens to as many mission-aligned people as possible and fulfill its vision for a decentralized media platform purpose-built for journalism.” TF, Timeline - CVL Token Launch.
Similarly, a Civil blog post explains:
We are conducting a token sale to responsibly and effectively decentralize the network, not to capitalize a private company. In this spirit that we were pleased to announce the 100 Percent Pledge: 100 percent of net proceeds from the CVL token sale will go to the Civil Foundation, the non-profit entity that will write grants to Newsrooms on the Civil platform.
Medium Post - The CVL Token Sale is LIVE!.
Providing clarity, the Terms of CVL token sale and use states:
At the conclusion of the token sale, the unsold CVL will be allocated to the Company (the “Retained Tokens”). The Company anticipates using the Retained Tokens to fuel adoption and decentralization of the Civil network. 33,000,000 CVL will be kept by the founding company, its employees and advisors. 33,000,000 CVL will be distributed to strategic institutional partners, standout newsrooms and important projects, and third-party dapp developers. The Company reserves the right to use Retained Tokens for purposes at its sole discretion.
Likewise, a blog post summarizes the distribution of CVL token supply:
There will be a total of 100 million CVL tokens. 34% of total CVL supply will be available for purchase during the public token sale. The Civil Media Company will retain 33% of the CVL token supply for compensatory and reserve purposes. The remaining 33% of the CVL token supply will be sold or granted to mission-aligned, third-party partner organizations (think: media companies, journalism schools, technology companies that wish to help build out Civil’s discovery/sharing/discourse ecosystem).
Medium Post - Announcing the CVL Token Launch - CVL Token Metrics.
Legal entity that distributed tokens:
Civil Website discloses that The Civil Media Company is “implementing a cooperative model in which decision-making authority will be turned over to a larger community,” and that such process will occur “via the launch of CVL, a uniquely designed cryptocurrency.” Civil Website - CVL tokens: Why they matter, and what they do - Introducing CVL tokens. Civil Website separately discloses that “CVL tokens can be only purchased through our partner Token Foundry. Token Foundry is part of ConsenSys, the world's leading Ethereum venture studio and an investor / close partner with Civil.” Civil Website - Help and Support - FAQs - How CVL tokens work. To aid consistency, this official website disclosure could be updated to conform with Civil’s recent announcement via Medium Posts that, starting October 2, 2018, “many participants will be able to complete the entire CVL purchase process on civil.co,” through the payment processor Wyre. Medium Post - The CVL Token Sale is LIVE!; The Fastest Way to Buy CVL Tokens.
Additionally, greater detail and clarity could be provided regarding the involvement of The Civil Media Company and Token Foundry in launching the CVL token sale, due to their shared relation to ConsenSys. The Civil Media Company also pledged through a blog post that “100% of net proceeds received in [the] upcoming CVL token sale will go to the Civil Foundation to fuel grants for worthy journalism projects, with direct input and ongoing involvement from CVL token holders.” Medium Post - 100 Percent Pledge.
Conditions a token purchaser must meet to receive tokens:
The Civil Website discloses that CVL token purchasers (i) “can contribute a minimum of $20 USD,” and that “[p]urchases over $10,000 must be approved through additional screening,” and (ii) “will be required to go through a registration and whitelisting process hosted by ConsenSys’s Token Foundry that will take place from August 3 - September 15, 2018,” which will involve “a KYC section and a Civil ‘Intent to Use’ section.” Civil Website - Help and support - FAQs - CVL Token Sale - Is there a minimum and a maximum contribution or purchasing level?, What should I do to prepare for the token sale prior to September 18? Do I need to complete a KYC (Know Your Customer) like other token sales?. Likewise, the Civil Website provides this brief statement on an explanatory page regarding the CVL token:
To ensure that the Civil Media Company follows all responsible steps in building a decentralized network, all CVL owners will be required to verify their identities before acquiring CVL. If they choose to sell CVL on the secondary market, they must prove they have used CVL for its intended purposes. For a minimum of 12 months, only users who plan to use CVL tokens for their intended purpose and have completed a Know Your Customer (KYC) process on either Token Foundry or civil.co will be able acquire CVL tokens, including via direct transfers from other CVL token holders. Civil Website - CVL tokens: Why they matter, and what they do - 6 Key Considerations for Using CVL - CVL is a consumer token.
Clear and detailed instructions related to these procedures and restrictions are also provided on the Civil Website, via a graphic titled Token Sale Flow. Related blog posts further disclose that “only individuals who have verified their identity on either Token Foundry or civil.co can acquire CVL tokens for the next year, even if they acquire them on secondary markets.” Medium Post - The CVL Token Sale is LIVE!; Proof of Use and Transferability.
Terms of token distributions (e.g., lockups, vesting):
Statement from Civil: In response to “Tderms of token distributions (e.g., lockups, vesting)” and “Whether lockups or vesting schedules are enforced through smart contracts or company policy,” initial allocations of CVL tokens to employees, partners, and newsrooms are subject to the following restrictions, all of which are enforced by smart contract: Employee allocations: All tokens released at end of sale. Limited availability for sale/transfer starting at 3 months with 1/24th being available on the last day of each month Prior to sale/transfer, must meet the same “proof of use” requirements as initial purchasers of CVL Once sale/transfer is available, until at least October 2019, sale/transfer is available only to other individuals who have (i) verified their identity on either Token Foundry or civil.co, and (ii) proven they understand how CVL tokens are used and that they actually intend to use the CVL tokens for their intended purpose. Partner allocations: All tokens released at end of sale Limited availability for sale/transfer starting at 6 months with 1/6th being available on the last day of every 6th month No proof of use requirement Once sale/transfer is available, until at least October 2019, sale/transfer is available only to other individuals who have (i) verified their identity on either Token Foundry or civil.co, and (ii) proven they understand how CVL tokens are used and that they actually intend to use the CVL tokens for their intended purpose. Newsroom allocations: All tokens released at end of sale No proof of use requirement Once sale/transfer is available, until at least October 2019, sale/transfer is available only to other individuals who have (i) verified their identity on either Token Foundry or civil.co, and (ii) proven they understand how CVL tokens are used and that they actually intend to use the CVL tokens for their intended purpose. Founding Council members allocations: All tokens released at end of sale No proof of use requirement Limited availability for sale/transfer starting at 6 months with 1/4th being available on the last day of every 6th month Once sale/transfer is available, until at least October 2019, sale/transfer is available only to other individuals who have (i) verified their identity on either Token Foundry or civil.co, and (ii) proven they understand how CVL tokens are used and that they actually intend to use the CVL tokens for their intended purpose. Stage of development of the project at time of token distribution:
The Civil Project Page on the Token Foundry website discloses that in October 2018:
Civil launches the Civil protocol on Mainnet, opening the Civil Registry to Newsrooms around the world and enlisting CVL tokens to uphold the Civil Constitution. Civil will also launch its open-source publishing plugins, enabling registered Newsrooms to “fingerprint” their content for authentication and eventual licensing opportunities.
TF, Timeline - CVL Platform Launch (October 2018).
A Civil blog post provides additional details about the Civil Mainnet launch, announcing that “The Civil Registry, the core part of the CVL token holder experience, will launch on the Ethereum mainnet (aka, Civil’s general launch) within one week of the [CVL token] sale’s completion.” Medium Post - The CVL Token Sale is LIVE!. A related blog post also discloses that the “CVL token exists to provide functionality with respect to the Civil Registry only at this time.” Medium Post - Announcing the CVL Token Launch - CVL Token Metrics.
Civil Whitepaper further explains and clarifies that Civil’s “‘Amendment’ system will not be implemented at launch; it will come shortly after.” Whitepaper, An Overview of the Civil Registry - Parameters & Amendments.
Steps to limit sale to individuals who do not intend to consume token:
Clear and detailed information is provided on the Civil Website regarding requirements that purchasers confirm their intent to use CVL tokens on platform and complete a related knowledge questionnaire (ensuring that they understand how CVL tokens work), via a graphic titled Token Sale Flow. Additional details are provided in related blog posts, describing the requirements that a purchaser (i) “[d]emonstrate an understanding of how to responsibly acquire cryptocurrency, ” (ii) “[p]rove you understand the basics of how CVL works — and that you intend to use it for its stated purpose,” as well as (iii) “‘prove use’ before selling CVL on the secondary market through at least October 2019.” Medium Post - The CVL Token Sale is LIVE!; Proof of Use and Transferability. Further, The Civil Media Company disclosed via blog post that:
As we announced two weeks ago, we’re selling CVL as a consumer token. That means that anybody who purchases CVL must demonstrate they understand how CVL works and that they intend to use it for its stated purpose: curating a network of high quality, ethical newsrooms. We are explicitly seeking users for this network, and reserve the right to block anybody who appears to be acquiring CVL for passive investment or speculative purposes
Medium Post - The CVL Token Sale Will Begin September 18 — Here’s Why - Adjusting Our Hard Cap, or the Maximum Value We’ll Accept for CVL.
Specification of whether (or not) anyone owes duties to increase token price:
The Token Foundry registration process for the CVL token sale requires users to attest that they “understand that nobody (including but not limited to anyone associated with the CVL token, the Civil Network, or the CVL token sale) is obligated to, or responsible for, creating any type of financial return for you in association with your purchase of CVL tokens.”
Restrictions and plans for secondary trading: Through a dedicated blog post, clear and complete detail is provided regarding the Civil “proof of use” restriction on secondary trading of CVL tokens and related terms, such that “before each purchaser in the token sale can transfer or resell any CVL tokens, they will be required to ‘prove use’ of a portion of the tokens they purchase.” Medium Post - Proof of Use and Transferability.
Whether lockups or vesting schedules are enforced through smart contracts or company policy:
Statement from Civil: In response to “Terms of token distributions (e.g., lockups, vesting)” and “Whether lockups or vesting schedules are enforced through smart contracts or company policy,” initial allocations of CVL tokens to employees, partners, and newsrooms are subject to the following restrictions, all of which are enforced by smart contract: Employee allocations: All tokens released at end of sale. Limited availability for sale/transfer starting at 3 months with 1/24th being available on the last day of each month Prior to sale/transfer, must meet the same “proof of use” requirements as initial purchasers of CVL Once sale/transfer is available, until at least October 2019, sale/transfer is available only to other individuals who have (i) verified their identity on either Token Foundry or civil.co, and (ii) proven they understand how CVL tokens are used and that they actually intend to use the CVL tokens for their intended purpose. Partner allocations: All tokens released at end of sale Limited availability for sale/transfer starting at 6 months with 1/6th being available on the last day of every 6th month No proof of use requirement Once sale/transfer is available, until at least October 2019, sale/transfer is available only to other individuals who have (i) verified their identity on either Token Foundry or civil.co, and (ii) proven they understand how CVL tokens are used and that they actually intend to use the CVL tokens for their intended purpose. Newsroom allocations: All tokens released at end of sale No proof of use requirement Once sale/transfer is available, until at least October 2019, sale/transfer is available only to other individuals who have (i) verified their identity on either Token Foundry or civil.co, and (ii) proven they understand how CVL tokens are used and that they actually intend to use the CVL tokens for their intended purpose. Founding Council members allocations: All tokens released at end of sale No proof of use requirement Limited availability for sale/transfer starting at 6 months with 1/4th being available on the last day of every 6th month Once sale/transfer is available, until at least October 2019, sale/transfer is available only to other individuals who have (i) verified their identity on either Token Foundry or civil.co, and (ii) proven they understand how CVL tokens are used and that they actually intend to use the CVL tokens for their intended purpose.
Principle 4: Purpose of Token Distribution Transparency score: 9/10
Disclosure Status Source Planned and actual use of proceeds by function line
Medium Post - 100 Percent Pledge Token sale proceeds
TF Updates on the project’s progress and funds
4Medium Post - The Civil Foundation — A New Fund to Support Ethical Journalism Around the World The aggregate amount of tokens reserved for the remuneration of team members
Medium Post - Announcing the CVL Token Launch; Civil Website - Terms of CVL token sale and use
Analysis:
Planned and actual use of proceeds by function line:
The Civil Media Company pledged via blog post that “100% of net proceeds received in [the] upcoming CVL token sale will go to the Civil Foundation to fuel grants for worthy journalism projects, with direct input and ongoing involvement from CVL token holders,” and elaborated that the “Civil Foundation will oversee a multi-million dollar grant fund that will initially come from the CVL token sale. Grants will be made to worthy recipients to help expand the quality, breadth and diversity of journalism on Civil.” Medium Post - 100 Percent Pledge. This “100% Pledge” is also clearly reflected throughout the Civil Website and additional Civil sources.
Token sale proceeds:
The Civil Project Page on the Token Foundry website provides a comprehensive overview of CVL token sale proceeds, including “Live Sale Stats” and a link to verify such amounts on Etherscan.
Updates on the project’s progress and funds:
A blog post discloses that the Civil Foundation will “communicate all [ ] numbers transparently via 990 filings” regarding its overhead, out-of-pocket expenses, and grant making from CVL token sale proceeds. Medium Post - The Civil Foundation — A New Fund to Support Ethical Journalism Around the World. More information could be provided on how these progress updates will be communicated to the Civil community.
The aggregate amount of tokens reserved for the remuneration of team members:
A Civil blog post provides the following disclosure:
The Civil Media Company will retain 33% of the CVL token supply for compensatory and reserve purposes.
Medium Post - Announcing the CVL Token Launch - CVL Token Metrics.
The Terms of CVL token sale and use also discloses that:
At the conclusion of the token sale, the unsold CVL will be allocated to the Company (the “Retained Tokens”). The Company anticipates using the Retained Tokens to fuel adoption and decentralization of the Civil network. 33,000,000 CVL will be kept by the founding company, its employees and advisors. 33,000,000 CVL will be distributed to strategic institutional partners, standout newsrooms and important projects, and third-party dapp developers. The Company reserves the right to use Retained Tokens for purposes at its sole discretion.
Principle 5: Token Supply Transparency score: 10/10
Disclosure Status Source Initial token supply and eventual supply changes
Medium Post - Announcing the CVL Token Launch - Civil Token Metrics; Civil Website - Help and support - FAQs - CVL Token Sale - How many CVL tokens will be created? Will more be created later? Differences between token supply and tokens in circulation (e.g. due to lockups)
Medium Post - Announcing the CVL Token Launch - Civil Token Metrics; Civil Website - Help and support - FAQs - CVL Token Sale - How many CVL tokens will be created? Will more be created later?
Analysis:
Initial token supply and eventual supply changes:
A Civil blog post discloses that “[t]here will be a total of 100 million CVL tokens.” Medium Post - Announcing the CVL Token Launch - Civil Token Metrics.
The Civil Website FAQs further clarifies that “[n]o additional CVL will ever be created.” Civil Website - Help and support - FAQs - CVL Token Sale - How many CVL tokens will be created? Will more be created later?.
Differences between token supply and tokens in circulation (e.g. due to lockups):
A Civil blog post discloses that:
34% of total CVL supply will be available for purchase during the public token sale. The Civil Media Company will retain 33% of the CVL token supply for compensatory and reserve purposes. The remaining 33% of the CVL token supply will be sold or granted to mission-aligned, third-party partner organizations (think: media companies, journalism schools, technology companies that wish to help build out Civil’s discovery/sharing/discourse ecosystem).
Medium Post - Announcing the CVL Token Launch - Civil Token Metrics.
Similarly, the Civil Website FAQs further explains that:
The total inventory of CVL tokens across all public sales is 34% or 34,000,000 tokens. During the CVL token sale that begins on September 18, 2018, tokens will be sold to public purchasers who demonstrate an intent to use, thereby establishing a CVL token fair market value for the first time. No additional CVL will ever be created.
Civil Website - Help and support - FAQs - CVL Token Sale - How many CVL tokens will be created? Will more be created later?.
Principle 6: Mitigation of Conflicts and Improper Trading Transparency score: 8/10
Disclosure Status Source Steps to identify, manage, mitigate conflicts
Whitepaper, Waterline, Civil Registry - Newsroom Listing Lifecycle, Applying to Start a Civil Newsroom, Community Checks and Balances, The CVL Token Economy, The Civil Ecosystem Vision; TF, Decentralization, Permanent Archives; Statement from Civil (below). Prevention of improper trading
Civil Website - Token Sale Flow; Medium Post - Proof of Use and Transferability; Statement from Civil (below).
Analysis:
Steps to identify, manage, mitigate conflicts:
The Civil Media Company clearly and completely outlines the Civil ecosystem self-governance, including how CVL holders can stake their tokens to apply to list a newsroom on the Civil Registry, challenge similar applications, and vote on such network challenges, suggesting certain governance rights, with such curation process governed by the Civil Constitution (itself subject to community amendment), and appeals available to Civil Council (independent body). Whitepaper, Waterline, Civil Registry - Newsroom Listing Lifecycle, Applying to Start a Civil Newsroom, Community Checks and Balances, The CVL Token Economy, The Civil Ecosystem Vision.
In addition to describing Civil’s self-governance and appeal measures (see above), the Company gives detailed descriptions regarding related third-party organizations, project governance, key individuals involved with Civil, and also notes specifically that “Civil Media Company pledges to build and develop the software to power [ ] community-driven conflict resolution . . . .” Whitepaper, Community Checks and Balances - The Civil Constitution.
The Civil Project Page on the Token Foundry website also briefly summarizes these features, noting that the Civil platform: “uses a foundational ruleset called the Civil Constitution to establish the platform’s purpose, values and ethics, then enforces and evolves these standards using blockchain and cryptoeconomics,” and that journalists “own their content outright” on the Civil platform, and through blockchain technology, are able to resist censorship. TF, Decentralization, Permanent Archives.
Greater detail could be provided regarding potential conflicts-of-interest between The Civil Media Company and other Civil stakeholders.
Statement from Civil: In response to “Steps to identify, manage, mitigate conflicts,” Civil Media Company will work with its attorneys to implement policies to prevent employees from engaging in improper business dealings and token trading.
Prevention of improper trading:
Clear and detailed instructions regarding initial filters in CVL Token Sale to prevent improper trading are provided on the Civil Website, via a graphic titled Token Sale Flow (see also supra, Principle 3).
Through a dedicated blog post, clear and complete information is also provided regarding the Civil “proof of use” restriction on secondary trading of CVL tokens and related terms, such that “before each purchaser in the token sale can transfer or resell any CVL tokens, they will be required to ‘prove use’ of a portion of the tokens they purchase.” Medium Post - Proof of Use and Transferability.
Statement from Civil: In response to “Steps to identify, manage, mitigate conflicts,” Civil Media Company will work with its attorneys to implement policies to prevent employees from engaging in improper business dealings and token trading.
Principle 7: Token Safety and Security Transparency score: 8/10
Disclosure Status Source Report of independent technological audit of the token and related code
Statement from Civil (below) Mechanisms for notifying users of security risks
Whitepaper, An Overview of the Civil Registry - Technical Details of the Civil Registry, The Civil Ecosystem Vision - The Civil Media Company Links to project github repositories
Whitepaper, An Overview of the Civil Registry - Technical Details of the Civil Registry, Contract Design Overview - TCR fork; Civil Project GitHub
Analysis:
Report of independent technological audit of the token and related code:
Statement from Civil: In response to “Report of technological audit,” Civil Media Company has engaged ConsenSys Diligence to perform a code audit of its smart contracts, following which the results will be published. The audit is expected to be completed prior to or on or about the start of the token sale.
Mechanisms for notifying users of security risks:
The Civil Media Company provides links to relevant GitHub repositories in the Civil Whitepaper and discloses that the Company shall act “as core maintainers [at the protocol level] to ensure the scalability and security of our CVL token software, though this will also be open-sourced and we’ll encourage vast community involvement.” Whitepaper, An Overview of the Civil Registry - Technical Details of the Civil Registry, The Civil Ecosystem Vision - The Civil Media Company. Additional details could be provided regarding how The Civil Media Company may communicate with Civil stakeholders regarding protocol security risks and related updates, as well as how the open-source and self-governance features of the Civil platform may relate to such notifications and/or security actions (if at all).
Links to project github repositories:
The Civil Whitepaper discloses links to relevant GitHub repositories.
Principle 8: Marketing Practices Transparency score: 9/10
Disclosure Status Source Steps taken to comply with the marketing principles outlined in this document.
Statement from Civil (below); Civil Website - Help and support- FAQs - CVL Token Sale - Is CVL a security? Explanations of the relationship between promises made in marketing materials about a token’s governance provisions and a project’s actual smart contracts (e.g. related to token supply, insider vesting schedules, modifiability of the governance rules).
Whitepaper, An Overview of the Civil Registry - Technical Details of the Civil Registry, Contract Design Overview; Civil Website - Help and support- FAQs - CVL Token Sale Links to project website(s) and accounts
Civil Website; Medium Page; Telegram; Slack; Twitter; Youtube; Linkedin Mechanisms for the community to identify marketing or sales issues
Civil Website; Medium Page; Telegram; Slack; Twitter; Youtube; Linkedin; Scorecard feedback expected to facilitate this.
Analysis:
Steps taken to comply with the marketing principles outlined in this document:
Statement from Civil: In response to “Steps taken to comply with the marketing principles outlined in this document,” Civil Media Company has taken extensive steps, including supporting and responding to this scorecard, to ensure that it markets the CVL token as a consumer token that enables purchasers to participate in the Civil protocol rather than as a financial investment. Civil Media Company has included in its documents and marketing initiatives the fact that CVL tokens are subject to various restrictions, including in its smart contracts, such as proof of use and limiting resales to qualified consumers, that are designed to mitigate speculative and passive secondary trading profits.
The above statement is reflected in additional Civil sources. For example, the Civil Website FAQs provide that:
The design of the CVL token sale process makes clear that the CVL token is not intended to be an investment and that every participant in the CVL first-edition token sale will pay the same price. CVL tokens will only be sold to registered purchasers that intend to use them to run Newsrooms and contribute to the long-term development of the Civil protocol. The CVL token sale has been designed as part of the Brooklyn Project Framework and intends to implement certain relevant provisions from the Token Foundry Standards for consumer tokens.
Civil Website - CVL Token Sale - Is CVL a security?
Explanations of the relationship between promises made in marketing materials about a token’s governance provisions and a project’s actual smart contracts (e.g. related to token supply, insider vesting schedules, modifiability of the governance rules):
The Civil Whitepaper and Civil Website describes the platform’s smart contract design, community-driven governance mechanisms, and further provides links to relevant GitHub repositories. Whitepaper, An Overview of the Civil Registry - Technical Details of the Civil Registry, Contract Design Overview; Civil Website - CVL Token Sale. More clear and complete explanations could be provided regarding how Civil’s token governance directly relates to such smart contracts.
Links to project website(s) and accounts:
Civil project websites and accounts are clearly listed in communications related to CVL token sale.
Mechanisms for the community to identify marketing or sales issues:
The Civil Media Company has made multiple public channels available for the community to identity and communicate issues. The “Transparency Scorecard” delivered by the Brooklyn Project is also expected to provide a direct mechanism for the community to raise issues with the CVL token sale.
Principle 9: Protecting and Empowering Consumers Transparency score: 9/10
Disclosure Status Source Rights and obligations of token holders
Civil Website - Terms of CVL token sale and use; Whitepaper, Appeals & Vetoes, Parameters & Amendments Refund policies, conditions and procedures, if any
Civil Website - Terms of CVL token sale and use; Statement from Civil (below) Risks related to project completion; refund measures if project is scaled down or cancelled
Civil Website - Terms of CVL token sale and use, Help and support - FAQs - Key concepts to understand before purchasing CVL - Why is it important to diversify your portfolio, including crypto and non-crypto assets?, Help and support- FAQs - CVL Token Sale - What happens if CVL’s minimum funding level is not reached?; Statement from Civil (below)
Privacy policy
Civil Website - CVL Privacy Policy Analysis:
Rights and obligations of token holders:
The Terms of CVL token sale and use states that:
Ownership of CVL carries no rights, express or implied, other than the right to use CVL as a means to participate in the Platform as provided in our Terms of Service.
The Civil Whitepaper also provides complete and detailed descriptions of how CVL token holders will participate in platform governance. Whitepaper, Appeals & Vetoes, Parameters & Amendments.
Refund policies, conditions and procedures, if any:
The Terms of CVL token sale and use states that:
[I]f $8,000,000 worth of CVL tokens are not purchased during the token sale, the token sale will be cancelled and Purchasers will receive a full refund.
Civil Website - Terms of CVL token sale and use.
Statement from Civil: In response to “Refund measures if project is scaled down,” if the token sale does not hit its ‘soft cap’ during the allotted sale period, then any purchase contributions will be automatically refunded. This process is trustless and will be automated by the smart contracts handling the sale.
After a successful sale, the terms of sale will govern this point. By purchasing CVL, a purchaser acknowledges that neither Civil Media Company, its affiliates, directors nor shareholders are required to provide a refund or allow a cancellation for any reason except as may be required by applicable law or regulation. It may be possible for token holders to resell their tokens to other purchasers who intend to use them and pass the applicable screening requirements; however, there is no guarantee that such resales will be possible or, if they are, that they would allow the token holder to receive the equivalent of a “full refund.” Risks related to project completion; refund measures if project is scaled down or cancelled:
The Civil Website FAQs describe some risks common to sales of cryptographic tokens, including that “you must be ready to lose some or all of the money you’ve put into crypto assets.” Civil Website - Help and support- FAQs - Key concepts to understand before purchasing CVL - Why is it important to diversify your portfolio, including crypto and non-crypto assets?. A more complete and clear statement could be provided regarding project completion risks specific to Civil.
The Civil Website FAQs also discloses that if “CVL does not meet its minimum funding level, all ETH contributions will be refunded to the contributors’ addresses.” Civil Website - Help and support- FAQs - CVL Token Sale - What happens if CVL’s minimum funding level is not reached?.
Civil’s Terms of CVL token sale and use similarly states that:
[I]f $8,000,000 worth of CVL tokens are not purchased during the token sale, the token sale will be cancelled and Purchasers will receive a full refund.
Statement from Civil: In response to “Refund measures if project is scaled down,” if the token sale does not hit its ‘soft cap’ during the allotted sale period, then any purchase contributions will be automatically refunded. This process is trustless and will be automated by the smart contracts handling the sale.
After a successful sale, the terms of sale will govern this point. By purchasing CVL, a purchaser acknowledges that neither Civil Media Company, its affiliates, directors nor shareholders are required to provide a refund or allow a cancellation for any reason except as may be required by applicable law or regulation. It may be possible for token holders to resell their tokens to other purchasers who intend to use them and pass the applicable screening requirements; however, there is no guarantee that such resales will be possible or, if they are, that they would allow the token holder to receive the equivalent of a “full refund.” Privacy policy:
The Civil Website provides a link to the CVL Privacy Policy as well as contact information for related inquiries.
Principle 10: Compliance with Applicable Laws Transparency score: 10/10
Disclosure Status Source Statement of Good Faith affirming compliance with applicable laws and regulations
Statement from Civil (below) Legal and professional advice on Statement of Good Faith
Statement from Civil (below)
Analysis:
Statement of Good Faith affirming compliance with applicable laws and regulations; Legal and professional advice on Statement of Good Faith:
Statement from Civil: In response to “Statement of Good Faith affirming compliance with applicable laws and regulations” and “Legal and professional advice on Statement of Good Faith,” Civil Media Company has engaged and consulted legal counsel and is working tirelessly to not only comply with its legal obligations but also, as evidenced by its participation with this scorecard and its token sale practices, help establish new industry best practices.
For additional clarity, a similar statement could be provided in Civil’s public channels related to the CVL token sale.