PROMOTER / REFERRER CODE OF CONDUCT
1. PURPOSE & SCOPE
1.1 Purpose
This Code of Conduct establishes the mandatory behavioural, ethical, and
compliance standards for all Promoters and Referrers associated with STCNET
Private Limited.
This Code is designed to:
- protect consumers from misleading, deceptive, unfair, or coercive
practices; - ensure truthful and transparent communication about STCNET products,
services, and the compensation structure; - maintain the integrity of STCNET’s product-centric, sale-only business
model; - prohibit recruitment-centric, pyramid-style, money-circulation, or
investment-style conduct; and - provide a clear enforcement framework for violations.
1.2 Legal Basis
This Code is framed with reference to applicable Indian law and recognised
direct-selling compliance standards, including:
| Law / Rule / Standard | Compliance Relevance |
|---|---|
| Consumer Protection Act, 2019 | Consumer rights and unfair trade |
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| Law / Rule / Standard | Compliance Relevance |
|---|---|
| practices | |
| Consumer Protection (Direct Selling) | Obligations of Direct Selling Entities |
| Rules, 2021 | and Direct Sellers |
| Consumer Protection (Direct Selling) | Network of sellers and sale-based |
| Amendment Rules, 2023 | consideration framework |
| Consumer Protection (E-Commerce) | Online consumer protection and |
| Rules, 2020 | platform disclosures |
| Prize Chits and Money Circulation | Prohibition of money-circulation |
| Schemes (Banning) Act, 1978 | schemes |
| Information Technology Act, 2000 | Digital communication and online |
| conduct | |
| Digital Personal Data Protection Act, | Personal data handling and privacy |
| 2023 | compliance |
| IDSA Code of Ethics | Industry ethical reference for direct |
| selling conduct | |
This Code must be read together with STCNET’s published policies, including the
Direct Selling Compliance Statement, Compensation Structure & Commission
Disclosure, No Income Guarantee Disclaimer, and Grievance Redressal &
Consumer Complaints Policy.
1.3 Applicability
This Code applies to:
- all individuals registered as Promoters or Referrers with STCNET;
- all communications, representations, promotions, referrals, and
interactions relating to STCNET products, services, or referral programme; - all online and offline activities connected with STCNET;
- all platforms including social media, messaging applications, websites,
landing pages, video platforms, short-video platforms, advertisements,
events, meetings, and in-person communications.
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2. STATUS & LEGAL CAPACITY
2.1 Independent Contractor Status
Promoters and Referrers are independent participants. They are not:
- employees of STCNET;
- salaried workers of STCNET;
- agents authorised to bind STCNET contractually;
- franchisees;
- partners;
- legal representatives of STCNET; or
- authorised spokespersons of STCNET unless expressly authorised in
writing.
Participation as a Promoter / Referrer does not create any employment,
partnership, agency, franchise, joint venture, or employer-employee relationship
with STCNET.
2.2 No Authority to Bind the Company
No Promoter / Referrer shall:
- enter into contracts on behalf of STCNET;
- modify, waive, interpret, or override Company policies;
- make commitments beyond information published or authorised by
STCNET; - promise delivery timelines, refunds, compensation, income, discounts, or
benefits not approved by STCNET; - collect payments, deposits, fees, or cash on behalf of STCNET;
- issue invoices, receipts, order forms, undertakings, certificates, or
authorisation letters on behalf of STCNET.
All official transactions must be processed only through STCNET’s authorised
website, checkout system, payment gateway, invoice system, or other official
channel.
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2.3 Written Contract Requirement
Every Promoter / Referrer must have a prior written contract, electronic
acceptance, or platform-based agreement with STCNET before undertaking any
authorised referral, promotional, or sale-related activity.
This Code forms an integral part of the Promoter / Referrer participation terms
and must be complied with at all times.
3. CONSUMER INTERACTION STANDARDS
3.1 Identification and Disclosure
At the initiation of any sales representation, referral communication, product
discussion, or promotional interaction, every Promoter / Referrer shall truthfully
and clearly:
- identify themselves by their full name;
- disclose their status as an independent Promoter / Referrer associated with
STCNET; - disclose that they are not an employee, agent, or official spokesperson of
STCNET; - disclose the identity of STCNET Private Limited as the Direct Selling Entity /
platform operator; - disclose the nature of goods or services being offered; and
- state the purpose of the communication.
No Promoter / Referrer shall conceal their identity, misrepresent their role, or
create the impression that they are an officer, employee, director, franchisee,
authorised agent, or official representative of STCNET.
3.2 Accurate and Complete Information
Every Promoter / Referrer shall provide only accurate, complete, factual, and
verifiable information regarding:
- product features, specifications, and benefits;
- product limitations, if any;
- price, taxes, charges, and payment terms;
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- return, refund, cancellation, and exchange policies;
- delivery timelines, where applicable;
- warranty, guarantee, and after-sales service terms, where applicable;
- cooling-off, cancellation, or buy-back rights, where applicable;
- grievance redressal channels; and
- the sale-only nature of the compensation structure.
No Promoter / Referrer shall exaggerate, suppress, distort, or misrepresent any
product, service, policy, commission structure, legal status, or consumer right.
3.3 Order Placement & Order Information
Where applicable, orders shall be placed through STCNET’s official ordering
system, invoice system, and checkout process.
The Company’s official ordering system, invoice, order confirmation, or checkout
process shall contain the information required under applicable law, including:
- description of goods or services;
- quantity and price payable;
- applicable taxes and charges;
- payment method;
- estimated delivery information;
- return, refund, and cancellation information;
- grievance redressal details; and
- any other statutory disclosure applicable to the product or service.
Promoters / Referrers shall direct consumers to complete purchases through the
official STCNET platform and shall not create, issue, alter, modify, or circulate any
unofficial order form, invoice, receipt, payment confirmation, or contractual
document on behalf of STCNET.
3.4 Product Delivery Matching Description
Promoters / Referrers shall not make any product description, product claim,
performance claim, ingredient claim, benefit claim, warranty claim, or usage
claim that is inconsistent with the description published by STCNET or the
relevant manufacturer / brand owner.
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Where a consumer receives a product that does not match the order, description,
invoice, quantity, condition, or applicable statutory information, the Promoter /
Referrer shall direct the consumer to STCNET’s official grievance, return, refund,
or support channel.
3.5 Data Protection
Every Promoter / Referrer shall handle consumer personal information only to
the extent necessary for authorised business purposes and shall comply with the
Company’s Privacy Policy, applicable data protection laws, and any instructions
issued by STCNET regarding the collection, use, storage, disclosure, and
protection of personal information.
Promoters / Referrers shall not misuse, sell, share, publish, transfer, harvest,
scrape, store, or disclose consumer data except as expressly authorised by
STCNET and permitted by applicable law.
4. PROHIBITED CONDUCT
4.1 Absolute Prohibitions — “DO NOT SAY”
A Promoter / Referrer shall never say, imply, hint, suggest, publish, advertise,
forward, or represent any of the following:
| Category | Prohibited Statements |
|---|---|
| Income Guarantees | “This is a job.” / “This is |
| employment.” / “You will earn fixed | |
| income.” / “Income is guaranteed.” / | |
| “Minimum income is assured.” / “You | |
| can replace your salary.” | |
| Passive or Automatic Income | “Income is passive.” / “You earn |
| without work.” / “You earn even if you | |
| do not sell.” / “Automatic income will | |
| come.” | |
| Recruitment Claims | “You earn just by joining.” / “You earn |
| because people join under you.” / | |
| “Your position decides your income.” / | |
| “Downline income is assured.” | |
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| Category | Prohibited Statements |
|---|---|
| Pressure Tactics | “Join now or you will miss the |
| opportunity.” / “This position will be | |
| lost.” / “Only early people will benefit.” | |
| Government Approval | “Government approved.” / “Regulator |
| approved.” / “Government endorsed.” / | |
| “This is legal because others are doing | |
| it.” | |
| Investment Language | “This is an investment.” / “This is a |
| chain.” / “This is a scheme.” / “This | |
| gives returns.” / “Money doubles.” | |
| Lifestyle Claims | “Financial freedom guaranteed.” / |
| “Earn from home without effort.” / | |
| “Become rich quickly.” / “No selling | |
| required.” | |
| Comparative Misrepresentation | “This is like another company but |
| better.” / “Everyone in the industry | |
| does this.” / “This model cannot fail.” | |
No Promoter / Referrer shall use any language that creates the impression of
guaranteed income, employment, investment return, recruitment income,
passive earning, pyramid income, or money-circulation benefit.
4.2 Absolute Prohibitions — “DO NOT DO”
A Promoter / Referrer shall never do any of the following:
| Category | Prohibited Actions |
|---|---|
| Fees & Payments | Charge or collect any joining fee, |
| registration fee, renewal fee, training | |
| fee, event fee, subscription fee, | |
| deposit, cash, or unofficial payment. | |
| Unauthorised Materials | Create or circulate unofficial income |
| charts, projections, calculators, | |
| screenshots, simulations, | |
| presentations, brochures, PDFs, | |
| videos, or sales scripts. | |
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| Category | Prohibited Actions |
|---|---|
| Policy Misrepresentation | Modify, reinterpret, simplify, translate |
| inaccurately, or override the | |
| Compensation Plan, Return Policy, | |
| Refund Policy, Code of Conduct, or any | |
| Company policy. | |
| False Claims | Make product, income, legal, tax, |
| government, business, or | |
| compensation claims not authorised | |
| by STCNET. | |
| Fake Reviews | Falsely represent themselves as |
| customers, post fake reviews, create | |
| fake testimonials, or induce others to | |
| do so. | |
| Recruitment Abuse | Use misleading, false, deceptive, |
| emotional, or unfair recruiting | |
| methods. | |
| Brand Misuse | Create pages, groups, handles, ads, |
| domains, landing pages, or channels | |
| using STCNET’s name, logo, brand, or | |
| identity without written approval. | |
| Paid Advertising | Run paid advertisements, sponsored |
| posts, campaigns, influencer | |
| promotions, or lead-generation | |
| campaigns without written approval. | |
| Offline Activities | Conduct unauthorised meetings, |
| seminars, training sessions, home | |
| visits, or public events in STCNET’s | |
| name. | |
| Unfair Practices | Use fraud, coercion, harassment, |
| undue influence, mis-selling, | |
| concealment, or unconscionable | |
| methods. | |
| Referral Selling Abuse | Induce consumers to buy by claiming |
| that they can recover or reduce the | |
| price merely by referring others. | |
| Data Misuse | Collect, store, transfer, sell, misuse, or |
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| Category | Prohibited Actions |
|---|---|
| disclose consumer data without | |
| authority. | |
4.3 Self-Consumption & Purchase Manipulation — Prohibited
A Promoter / Referrer shall not:
- represent self-purchase as a method of earning income;
- encourage bulk buying or inventory loading;
- suggest purchase merely to remain eligible;
- require or pressure any person to purchase goods or services;
- encourage any person to buy products in unreasonable quantities;
- create fake orders, proxy orders, circular purchases, artificial purchases, or
manipulated customer purchases; - place orders only to generate commission;
- induce family, friends, or associates to buy only for commission
generation.
STCNET’s model is based on genuine product sales to genuine consumers.
4.4 Cooling-Off Period, Return & Buy-Back
Promoters / Referrers shall accurately explain and facilitate the Company’s
applicable cancellation, cooling-off, return, refund, and buy-back policies.
No Promoter / Referrer shall deny, suppress, misstate, discourage, delay, or
misrepresent any consumer right available under applicable law or Company
policy.
5. SOCIAL MEDIA & DIGITAL CONDUCT
5.1 Core Principle
All digital conduct must be:
- truthful;
- factual;
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- product-centric;
- consistent with STCNET’s sale-only remuneration model;
- consistent with the 2% capped commission structure; and
- compliant with Company-approved communication standards.
Social media is not to be used as a misleading “business opportunity” channel.
5.2 Mandatory Identification
On all social media and digital platforms, every Promoter / Referrer must clearly
disclose that they are:
- an independent Promoter / Referrer associated with STCNET; and
- not an employee, agent, authorised spokesperson, franchisee, legal
representative, or official officer of STCNET.
Where a social media profile, page, group, channel, or account primarily
promotes STCNET, it must clearly identify the individual as an independent
Promoter / Referrer and not as an employee or official spokesperson of the
Company.
All digital communications shall comply with applicable consumer protection,
advertising, intellectual property, data protection, and information technology
laws.
5.3 Absolute Prohibitions Online
No Promoter / Referrer shall post, share, publish, forward, upload, circulate, or
advertise:
- income claims;
- earning screenshots;
- commission screenshots;
- bank screenshots;
- payout screenshots;
- projections;
- income testimonials;
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- lifestyle inducement content showing cars, houses, travel, luxury goods, or
wealth implying income; - “side income,” “financial freedom,” “passive income,” or “work from home
income” framing; - recruitment language;
- network growth claims;
- misleading success stories;
- unauthorised brand-named pages, handles, groups, domains, or channels;
- comparisons with other direct selling companies;
- claims that STCNET is Government approved or regulator endorsed;
- content implying that income can be earned without product sales.
5.4 Permitted Content
Promoters / Referrers may share only:
- product-centric, factual information;
- official STCNET product links;
- Company-approved product descriptions;
- Company-approved marketing content;
- official policy links;
- official website links;
- factual information that is not misleading, exaggerated, or unauthorised.
No content may be edited, cropped, modified, translated, republished, or
recontextualised in a misleading manner.
5.5 Monitoring and Takedown
STCNET may monitor public digital content, social media pages, advertisements,
messages, posts, groups, channels, and other publicly available promotional
material connected with STCNET.
STCNET may require immediate removal, correction, modification, clarification,
or withdrawal of any non-compliant content.
Failure to comply with takedown or correction instructions shall constitute a
material breach of this Code.
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6. COMPENSATION & COMMISSION — TRUTHFUL
REPRESENTATION
6.1 Sale-Only Remuneration
Promoters / Referrers shall represent the Compensation Structure accurately and
truthfully.
Accordingly:
- commission, where applicable, arises only from eligible completed product
or service sales; - no sale means no commission;
- commission is not guaranteed, fixed, assured, automatic, or passive;
- commission is variable and depends on actual eligible sales, compliance
checks, return/refund adjustment, statutory deductions, and Company
policy; - registration, joining, network size, position, level, rank, or referral alone
does not generate income.
Past earnings, examples, illustrations, or success stories, if shared by the
Company, are for informational purposes only and shall not be construed as a
promise, guarantee, assurance, or prediction of future earnings.
6.2 No Recruitment Income
Promoters / Referrers shall never represent that income can be earned by:
- recruiting others;
- enrolling others;
- adding people into a network;
- occupying a position;
- maintaining a downline;
- having a particular level or rank;
- joining early;
- sponsoring members; or
- growing a network without product sales.
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STCNET does not pay recruitment income, joining income, enrolment income, or
position income.
6.3 Compensation Plan Misrepresentation Prohibited
Promoters / Referrers shall not:
- modify, reinterpret, exaggerate, or simplify the Compensation Plan;
- create unofficial income charts, calculators, projections, PDFs, screenshots,
videos, or presentations; - make earnings or sales representations not based on documented and
substantiated facts; - claim guaranteed, fixed, minimum, passive, or assured income;
- represent commission as salary, return, investment income, bonus for
joining, or recruitment reward.
Any explanation of commission must remain consistent with the official
Compensation Structure & Commission Disclosure Policy published by STCNET.
7. ENFORCEMENT & CONSEQUENCES
7.1 Monitoring
STCNET may monitor Promoter / Referrer conduct, including:
- consumer interactions;
- digital and social media activity;
- sales patterns;
- referral activity;
- promotional content;
- complaints;
- KYC and account usage;
- payment-related conduct; and
- compliance with this Code.
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7.2 Breach Categories
| Category | Examples | Possible Action |
|---|---|---|
| Minor Breach | First-time inadvertent | Written warning, |
| error, minor wording | correction instruction, | |
| issue, correctable | mandatory retraining | |
| misstatement | ||
| Serious Breach | Income claim, | Suspension, |
| recruitment claim, | investigation, content | |
| unauthorised material, | takedown, freezing of | |
| misleading post, | pending payouts | |
| repeated non- | ||
| compliance | ||
| Material Breach | Fraud, mis-selling, | Immediate termination, |
| coercion, unauthorised | forfeiture/reversal | |
| fee collection, brand | where lawful, | |
| misuse, impersonation, | blacklisting, regulatory | |
| data misuse, consumer | reporting where | |
| harm | required | |
7.3 Enforcement Actions
Depending on the nature and severity of the breach, STCNET may take one or
more of the following actions:
- issue a written warning;
- require correction or removal of content;
- require mandatory retraining;
- suspend referral privileges;
- freeze commission payouts pending investigation;
- reject pending commission;
- reverse commission already credited where linked to cancelled, refunded,
fraudulent, or non-compliant transactions; - terminate Promoter / Referrer status;
- permanently blacklist the person from participation;
- restrict access to platform features;
- report the matter to competent authorities where required by law;
- initiate civil, criminal, or other legal action where appropriate.
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7.4 No Warning Required
STCNET reserves the right to take immediate action without prior warning in
cases involving:
- fraud;
- mis-selling;
- income guarantee claims;
- recruitment income claims;
- pyramid or money-circulation representations;
- unauthorised fee collection;
- impersonation;
- brand misuse;
- fake reviews;
- consumer harassment;
- data misuse;
- payment fraud;
- regulatory risk; or
- any act causing consumer harm or platform integrity risk.
7.5 Cooperation with Investigation
Every Promoter / Referrer shall fully cooperate with any investigation conducted
by STCNET.
Failure or refusal to cooperate, concealment of facts, destruction of records, false
statements, non-response, or obstruction of investigation shall constitute a
separate and independent breach of this Code.
7.6 Fair Opportunity to Respond
Except where immediate action is reasonably necessary to protect consumers,
prevent fraud, comply with applicable law, preserve evidence, or safeguard the
integrity of the Company’s platform, STCNET may provide the concerned
Promoter / Referrer a reasonable opportunity to explain or respond before taking
final disciplinary action.
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Nothing in this provision limits STCNET’s right to take immediate interim or final
action in cases involving fraud, consumer harm, mis-selling, impersonation,
unauthorised fee collection, data misuse, brand misuse, regulatory risk, or any
material breach of this Code or applicable law.
8. GRIEVANCE HANDLING & ESCALATION
8.1 Consumer Grievances
Promoters / Referrers shall:
- direct consumers to STCNET’s official grievance channels;
- not create parallel grievance mechanisms;
- not offer unauthorised concessions, refunds, replacements, discounts,
compensation, or assurances; - promptly report any consumer complaint received by them to STCNET;
- cooperate with STCNET in resolving consumer complaints where required.
8.2 Promoter / Referrer Grievances
Promoters / Referrers having grievances, including commission disputes, account
issues, suspension issues, KYC issues, or policy interpretation concerns, shall:
- use STCNET’s official grievance channels;
- provide supporting documents;
- avoid public allegations, threats, harassment, or consumer-facing
escalation; - not misuse social media to pressure the Company, consumers, or other
Promoters / Referrers; - cooperate with lawful internal investigation and resolution procedures.
8.3 Non-Retaliation
Retaliation, harassment, intimidation, victimisation, or adverse treatment of any
consumer, Promoter / Referrer, employee, officer, vendor, or person who raises a
complaint in good faith is strictly prohibited.
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False, malicious, fabricated, or bad-faith complaints may themselves be treated as
a violation of this Code.
9. ACKNOWLEDGEMENT & DEEMED ACCEPTANCE
9.1 Acceptance
Registration, continued participation, referral activity, acceptance of platform
terms, or use of Promoter / Referrer facilities constitutes:
- acceptance of this Code;
- agreement to comply with this Code;
- acknowledgement that violation may result in disciplinary action;
- acknowledgement that commission is subject to eligibility, compliance,
verification, return/refund adjustment, and applicable law; - acknowledgement that STCNET may update this Code from time to time.
9.2 Awareness of the Code
Every Promoter / Referrer is expected to read, understand, and comply with this
Code.
Failure to read, understand, remember, or correctly interpret this Code shall not
ordinarily excuse non-compliance with its provisions.
9.3 Updates
STCNET may update this Code from time to time to reflect changes in applicable
law, business operations, platform controls, regulatory guidance, consumer
protection requirements, or Company policy.
Continued participation after publication of the updated Code shall constitute
acceptance of the updated Code.
10. RELATED POLICIES
This Code should be read together with:
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1. Legal Entity & Statutory Disclosures
2. Consumer Protection (Direct Selling) Compliance Statement
3. Compensation Structure & Commission Disclosure
4. Grievance Redressal & Consumer Complaints
5. Returns, Refunds & Cancellation
6. Pricing, Payments & Charges
7. Shipping, Delivery & Fulfilment
8. Privacy Policy
9. Terms & Conditions (Website Use)
10. Product / Service Regulatory Disclosures
11. Cookie & Tracking Consent Policy
12. No Income Guarantee Disclaimer
13. Compliance Index & Statutory Mapping
11. SEVERABILITY
If any provision of this Code is held to be invalid, illegal, or unenforceable by a
court, regulator, or competent authority, the remaining provisions shall continue
to remain valid and enforceable to the fullest extent permitted by applicable law.
The invalid or unenforceable provision shall be interpreted, modified, or
replaced in a manner that most closely reflects the original intent while
remaining lawful and enforceable.
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12. POLICY UPDATES
This Policy may be amended, revised, or updated from time to time to reflect
changes in applicable law, regulatory requirements, internal compliance
practices, technology systems, consumer protection standards, or business
operations.
The latest version published on the STCNET website shall prevail.
End of Policy #3 – Promoter / Referrer Code of Conduct
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