1. Core rule
A person must not trade, direct another person to trade, or beneficially participate in a Kapolly market when that person has a prohibited connection to the outcome, the official source used to resolve the market, or material information that is not publicly available.
This policy applies whether the person trades directly, through an entity, through another account, or through an arrangement intended to hide the person’s economic interest.
2. Who is restricted
- A person who can directly or materially influence the event or reported value that determines the market.
- An employee, officer, contractor, adviser or agent of an authoritative source where the person has access to the relevant unpublished data, decision process or release.
- A person who possesses material non-public information that would reasonably be expected to affect the market price or outcome.
- A person acting for, sharing profits with, or taking instructions from a restricted person.
- A person placed on a market-specific restricted participant list by Kapolly under the Rulebook.
3. What counts as material non-public information
Information is material when a reasonable market participant would likely consider it important in deciding whether, when or at what price to trade. Information is non-public when it has not been made broadly available through the relevant authoritative release or another lawful public channel.
Examples may include an unpublished central bank decision, a company announcement not yet released to the market, unreleased official statistics, a confidential regulatory decision, a private tender result, an embargoed index value or advance knowledge of a corporate action.
4. Outcome influence
A person is treated as able to influence an outcome when the person has decision authority, voting authority, operational control, editorial or publication control, data production responsibility, official certification responsibility or another practical ability to cause or materially shape the result used by the contract.
Being generally employed by a large organisation does not automatically prohibit every market. Kapolly may apply a narrower or broader restriction based on the role, information access and market risk.
5. User obligations
- Review the restriction notice shown on each market before trading.
- Disclose any role, relationship or information conflict requested by Kapolly.
- Do not trade after receiving material non-public information, even if the account was previously eligible.
- Cancel open orders when a new conflict arises and notify Kapolly compliance promptly.
- Do not tip another person, share restricted information for trading, or arrange indirect participation.
6. Kapolly controls
- Each market must identify at least one authoritative source before opening.
- Market Operations must classify source risk and identify restricted participant classes.
- Surveillance may block, hold or investigate accounts linked to source entities or outcome controllers.
- Trading activity around scheduled data releases and determinations is subject to enhanced review.
- Kapolly may request employment, role, beneficial ownership or relationship information to assess a conflict.
- Breaches may result in order cancellation, trading restriction, account suspension, disciplinary action, settlement treatment permitted by the Rulebook, regulatory reporting or referral to law enforcement.
7. Dynamic Restricted Source Register
Kapolly maintains a restricted source register for relevant markets. The register records the market, authoritative source, restricted roles, restriction period, responsible reviewer and last review.
| Register field | Required content |
|---|---|
| Market ID / ticker | Unique Kapolly market identifier |
| Market question | Plain market wording |
| Primary authoritative source | Named agency, exchange, company, index administrator or other source |
| Fallback source | Only if preapproved in the contract rules |
| Restricted roles | Roles or persons who may possess unpublished information or influence the outcome |
| Restriction type | Source employee, outcome controller, MNPI holder, related person, other |
| Restriction period | Start, end and any post release buffer |
| Compliance owner | Kapolly reviewer responsible for the classification |
| Last review | Timestamp and version |
8. Examples
| Situation | Likely treatment |
|---|---|
| Statistics agency analyst working on an unreleased CPI print | Restricted from a market settling on that CPI release. |
| Company employee with no access to an unreleased board decision | Not automatically restricted, but may be restricted if role or information changes. |
| Director who will vote on a corporate action that determines the market | Restricted because the person can influence the outcome. |
| Journalist who receives an embargoed official release before publication | Restricted while the information remains non-public. |
| Ordinary customer who reads the public release after publication | Not restricted merely because the information is useful. |
9. Questions and voluntary disclosure
Users who are unsure whether they are restricted should not trade the affected market until Kapolly confirms the account’s status. Contact the Kapolly market integrity contact shown in the platform before live regulated trading.