SuperStrat Curator Due Diligence Policy

Version 1.0.0 Date of last revision: 2026-09-02 Effective from: publication on the Interface

This Policy is an integral part of the SuperStrat Terms of Use (the "Terms") and is referenced in Section 3.4(ii) of the Terms and in Section 3.1 of the Curator Terms. Capitalized terms have the meanings given in the Terms.

1. Purpose

1.1. The Operator operates a technical eligibility screening that determines which Curators may create Vaults through the Protocol's factory. This Policy describes what that screening consists of, so that Curators know what is asked of them and depositors know what the screening does and does not mean.

1.2. Screening is a technical eligibility check. It is not an endorsement, an audit, a suitability assessment, or a view on any Curator's strategy, honesty or skill (Terms, Sections 3.4 and 3.5). A Vault's presence on the Interface means only that its Curator has passed the checks listed in Section 2 at the time of authorization.

2. Checks performed before authorization

Before a Curator is authorized to create a Vault, the Operator verifies each of the following:

2.1. Identity. The Curator has completed the identity verification described in Section 1.4 of the Curator Terms: a government-issued identity document and a proof of address for an individual, and in addition the constitutional documents and the identity of the persons acting for it for an entity. Verification is performed by the Operator itself at the date of this version; the Operator may engage a specialised provider, in which case the Privacy Policy is updated and re-versioned before or at activation.

2.2. Restricted Person and sanctions check. The Curator, and every wallet address that will hold a privileged role in the Vault (admin, curator, oracle, trading account), are checked against the definition of Restricted Person in the Terms, including the Restricted Jurisdictions Policy and the sanctions lists referenced in it. A Curator who is a Restricted Person, or who proposes a role address that the Operator reasonably associates with a Restricted Person, is not authorized.

2.3. Key hygiene. The Curator attests to the key arrangements of the Vault. The Operator recommends, and records whether, the admin role is held on a hardware wallet that is not used for day-to-day transactions. For a Vault open to deposits from persons other than the Curator, the curator role and the oracle role must be held by different persons (Terms, Section 4.2; Curator Terms, Section 3.4); a Vault that does not meet this condition is authorized only as a RESTRICTED Vault, with a TVL cap of at most 50,000 USDC.e and no promotion on the Interface.

2.4. Stake commitment. The Curator confirms the deposit it will hold in its own Vault under Section 7.2 of the Curator Terms (the greater of USD 5,000 and 5 percent of the Vault's net asset value), and the wallet address from which it will be held.

2.5. Vault Sheet. The Curator has completed the Vault Sheet for the Vault and signed it with the wallet holding the curator role. The Operator checks that every field is completed and consistent with the parameters submitted to the factory. The Operator does not verify the strategy description or the track record stated by the Curator.

2.6. Strategy description. The strategy description and the Curator's profile are reviewed only for prohibited statements: guarantees of performance, statements that deposits are safe or insured, statements that the Operator endorses, audits or supervises the strategy, and unsubstantiated track-record claims (Curator Terms, Section 4). The review does not assess the merits, risk or coherence of the strategy.

2.7. Prediction Market Venue account. The Curator represents that its account on each Prediction Market Venue it intends to use is in good standing, and that its use of that venue for the Vault complies with the venue's terms, including any restriction on trading for the account of third parties (Curator Terms, Section 2.2(h)). The Operator relies on that representation and does not verify it with the venue.

3. Outcome

3.1. Authorization is granted, denied, conditioned or revoked at the Operator's sole discretion. The Operator does not owe reasons for a denial or a revocation, and a denial is not a statement about the Curator.

3.2. Authorization may be conditioned, including by a lower TVL cap, a RESTRICTED label, a higher stake, or additional disclosures on the Vault Sheet.

3.3. Authorization concerns the creation of Vaults through the factory. It does not transfer any obligation of the Curator to the Operator and does not make the Operator responsible for the Vault's operation.

4. Ongoing review

4.1. Annual re-confirmation. At least once every twelve months, the Curator re-confirms the representations in Section 2.2 of the Curator Terms and the accuracy of its Vault Sheet, and provides updated identity documents where the Operator requests them.

4.2. Event-driven review. The Operator reviews a Curator's authorization on the occurrence of any of the following: a change in role holders; a breach of the settlement undertaking in Section 3.5 of the Curator Terms; a shortfall in the stake under Section 7.2 of the Curator Terms; a complaint from a depositor that the Operator considers credible; a regulatory event affecting the Curator, its jurisdiction or a Prediction Market Venue it uses; or any indication that a representation in Section 2.2 of the Curator Terms has ceased to be true.

4.3. Consequences. Where a review is adverse, the Operator may act under Section 6 of the Curator Terms, including by removing the Vault's visibility, revoking authorization for future Vaults, exercising any protective function it holds in accordance with the Emergency Powers Policy, and publishing the fact and the reason of the measure.

5. What screening is not

5.1. Screening is not an audit of the Curator, of its strategy, or of its past performance. The Operator does not verify track records.

5.2. Screening is not a suitability assessment for any depositor. The Operator does not assess whether any Vault is appropriate for any person.

5.3. Screening is not a view on the Curator's skill, honesty or solvency, and it does not reduce any risk described in the Risk Disclosure, including the risk that a Curator loses, mismanages or misappropriates allocated assets.

6. Records and retention

6.1. The Operator keeps a record of each screening, including the documents provided, the checks performed, the outcome and any conditions, and of each ongoing review.

6.2. Identity verification records are retained for 5 years after the closure of the Curator's last Vault, or longer where Applicable Law requires, as stated in the Privacy Policy. They may be disclosed to a competent authority where Applicable Law requires it, or to a court or arbitral tribunal in connection with a claim brought by a depositor in the Curator's Vault (Curator Terms, Section 1.4).

7. Review of this Policy

This Policy is reviewed at least annually and on any change to the Protocol, to the Curator Terms or to Applicable Law that affects it. Each review is dated and the version number incremented. Because the Terms incorporate this Policy by reference, a change to this Policy is an amendment governed by Section 18 of the Terms and takes effect on publication.

SuperStrat Curator Due Diligence Policy, Version 1.0.0. The authoritative version of this document and its cryptographic hash are published at superstrat.io/curator-due-diligence.