Fraud & Conduct

Purpose and Scope

This Fraud Prevention & Staff Conduct policy is issued by Chubby Club LLC (“Chubby Club,” “we,” “us,” or “our”) and sets forth the conduct standards for Location staff who interact with the Program, the supervision and reporting obligations of participating Locations, and the consequences of fraudulent conduct. This policy applies in the United States and Canada.

Definitions

• Member means an individual enrolled in the Program through the Chubby Club App.
• Partner means the business entity that has entered into the Partner Terms (MSA) with Chubby Club under a signed Order Form.
• Location means each venue operated by or on behalf of a Partner and identified in the applicable Order Form as participating in the Program.
• Program means the Chubby Club loyalty program, including the PLUS membership tier, operated by Chubby Club.
• Order Form means the signed ordering document between Chubby Club and a Partner that identifies participating Locations and sets forth the economic and transaction-specific terms of participation.
• Valid Redemption means a redemption presented through the Chubby Club App or partner portal that has not expired and complies with the Points Earning & Redemption Rules.
• Fraud means obtaining, issuing, or redeeming points or benefits through deception, manipulation, self-dealing, or violation of the Points Earning & Redemption Rules.
• Staff means a Location’s employees, contractors, and other personnel who interact with the Program.

1. Prohibited Conduct

Staff may not:

• Misuse referral codes — use or distribute a referral code that is not their own for personal gain.
• Process unauthorized receipt scans — process receipts for rewards except when the receipt is presented by the actual Member.
• Inflate points — manually adjust transactions, scan duplicate receipts, or issue illegitimate refunds to generate points.
• Misuse Member identifiers — use phone numbers, email addresses, or other identifiers that are not their own to claim rewards or benefits.
• Otherwise engage in Fraud or assist any person in engaging in Fraud.

2. Disciplinary Framework (Minimum)

Each Location must apply, at minimum, the following progressive discipline for violations of this policy by its Staff:

1. First violation: documented written warning.
2. Second violation: removal from Program-related duties.
3. Third violation: termination of the individual’s access to the Chubby Club platform.

Chubby Club may require a Location to accelerate these steps — including immediate removal of platform access — for serious or willful Fraud. Nothing in this framework limits the Location’s own employment decisions, which remain the Location’s responsibility.

3. Financial Responsibility and Restitution

• Chubby Club may require reimbursement of losses caused by fraudulent conduct to the extent permitted by applicable law.
• Any recovery from Staff wages is solely between the Location and its employees and must comply with applicable labor law. Chubby Club does not direct or participate in wage deductions.
• The Partner is responsible for losses arising from its Staff’s fraudulent conduct where the Location failed to implement the supervision measures required by this policy.

4. Reporting and Supervision

• Staff and Location management must report suspected Fraud within 24 hours of discovery to both Location management and legal@chubbyclub.com. Failure to report within 24 hours is itself a violation of this policy subject to the disciplinary framework above.
• Location managers must conduct periodic audits of Program activity at their Location for compliance with this policy.
• Location managers and supervisors must acknowledge in writing that they have read, understood, and agree to comply with this policy. Acknowledgment records must be retained by the Location and made available to Chubby Club on request.

5. Investigation and Legal Action

• Chubby Club may investigate suspected Fraud, and Locations must reasonably cooperate with any investigation, including providing relevant records and access to relevant systems.
• Severe or willful Fraud may be referred to law enforcement and may result in civil and/or criminal action. Locations must cooperate fully with any resulting proceedings.
• Chubby Club may suspend platform access for individuals or Locations pending investigation of credible Fraud allegations.

6. Support and Escalations

Fraud reports, questions, and escalations relating to this policy should be directed to legal@chubbyclub.com or submitted through the partner portal.

7. Changes to This Policy

Chubby Club may update this policy from time to time. Material changes will be communicated to Partners through the partner portal or by email at least 30 days before they take effect, except where a shorter period is required to address fraud, security, or legal compliance. The “Effective date” above reflects the current version. Continued participation in the Program after a change takes effect constitutes acceptance of the change.

8. Relationship to Other Agreements

This policy is incorporated by reference into the Partner Terms (MSA) and applies to each Location identified in the applicable Order Form. In the event of a conflict, the order of precedence is: the signed Order Form, then the Partner Terms (MSA), then this policy.