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IM & Public Copy — Guardrail Screening Checklist
Internal working tool. Drafted 24 June 2026 (Hermes-generated, human-reviewable). Serves issue #86 (IM quality review) and any future public-copy or external-document pass. Not published to /admin/ unless explicitly added to ADMIN_DOCS.
Stage 1: Gauging Interest. All copy must read as “we are asking whether this is worth exploring” — never as an investment offer or financial product pitch. Authority for the underlying rules:
AGENTS.md(canonical) andCLAUDE.mdnon-negotiable guardrails.
Property & Owner Availability
| # | Rule | RED-FLAG phrases to search | Compliant rewrite pattern |
|---|---|---|---|
| 1 | Must NOT state or imply the property is available for purchase unless verified | "the property is for sale", "the hotel is on the market", "available for acquisition", "we are purchasing the pub" | ”We are exploring whether acquiring a property like this could be feasible — subject to owner willingness and due diligence.” |
| 2 | Must NOT state or imply the owner/receiver is willing to sell unless verified | "the owner has agreed to sell", "the receiver welcomes our offer", "the vendor is ready to negotiate", "the owner is open to offers" | ”Any transaction would require the owner’s willingness to sell, which has not been confirmed. This document assumes no such willingness.” |
| 2a | Must NOT represent the property as having a separable residential component or a land-sale offset unless verified against the registered title — this is the highest-probability false-statement risk flagged by the legal memo (§F14) and DD register B1: the listing/IM describe ~2,400–2,500 m² “residential surplus” but the verified title search (parcel 163869/1) shows the hotel parcel is wholly Local Business | "residential surplus", "residential land component", "surplus land", "land sale offset", "residential parcel", "sell off the residential land" | ”The verified title shows the hotel parcel is wholly Local Business zone with no confirmed residential component. Any residential/land-sale value is unconfirmed (DD register B1, OPEN) and must not be modelled, offered, or stated as a realisable asset until reconciled against survey plan SP163869.” |
Returns, Dividends & Repayment
| # | Rule | RED-FLAG phrases to search | Compliant rewrite pattern |
|---|---|---|---|
| 3 | Must NOT state the co-op can pay a specific dividend unless legally modelled and approved | "members will receive a dividend", "expected return of X%", "annual dividend of $Y", "shareholders can expect returns", "projected payout" | ”Any surplus distribution would be subject to legal advice, financial modelling, and board approval. No specific dividend is promised or implied.” |
| 4 | Must NOT state investor capital will be repaid on a fixed schedule unless legally modelled and approved | "capital returned within N years", "repaid on a fixed schedule", "your investment will be returned by", "guaranteed repayment timeline", "principal repaid over X years" | ”Capital return, if any, would depend on financial performance and legal structure — no fixed schedule is offered or implied.” |
| 5 | Must NOT offer or imply fixed returns, guaranteed dividends, or repayment promises | "guaranteed return", "guaranteed interest rate", "we offer X% interest", "fixed/guaranteed return", "assured yield", "risk-free investment", "your capital is safe", "you will be paid back" — before flagging "fixed interest", "capped interest", or "returnable deposit", read the compliant-usage carve-out below | ”Returns are indicative and subject to feasibility. This is an exploration of interest, not a financial product offer.” |
| 6 | Must NOT use “forever” or “guaranteed” claims about any outcome | "guaranteed forever", "permanent community ownership", "the pub will always be", "secured in perpetuity", "forever protected" | ”Community ownership is a long-term aspiration subject to ongoing viability, not a guarantee of permanence.” |
⚠️ Compliant-usage carve-out — do NOT auto-flag these. Three phrases are prescribed compliant framings in the anticipated legal/accountant advice memos, and a naïve grep pass (Step 1 below) will produce false positives against the very language designed to keep the project on the safe side of the debt-vs-distribution line. The red-flag is the promise to a contributor, not the mechanism descriptor:
- “returnable deposit” — compliant when describing the mechanism (“held in trust as a returnable deposit”, per the accountant brief, anticipated accountant advice Q5, legal advice G15–G17, and
finance_assumptions_book.md§1B.3). Red-flag only when offered to a contributor as a guarantee of repayment.- “fixed or capped interest” — compliant in the exact form the accountant advice prescribes: “interest at a fixed or capped rate set independently of the co-op’s profits, payable whether or not the co-op makes a profit” (
anticipated_accountant_advice.mdlines 90, 107). This is the permissible contrast to a profit-linked return. Red-flag only as an offered rate to the public ("guaranteed interest rate","we offer X% interest") implying a guaranteed return — flag those phrasings, not the descriptor.- “community debenture” — compliant when described as a future loan instrument subject to disclosure and advice. Red-flag when it reads as a live offer (see Rule 10).
When a hit is the compliant descriptor, log it as not a violation and move on. Do not rewrite memo language that the simulated advice deliberately uses to define the compliance boundary.
Licensing & Legal Structure
| # | Rule | RED-FLAG phrases to search | Compliant rewrite pattern |
|---|---|---|---|
| 7 | Must NOT assume a liquor licence can be held by the co-op without checking Tasmanian law | "the co-op will hold the liquor licence", "we can transfer the licence", "licence transfer is straightforward", "our licence application" | ”Whether a co-operative can hold a liquor licence in Tasmania requires legal confirmation (Liquor Licensing Act 1990 (Tas); board members are ‘associates’ of the licensee). This has not been verified.” |
| 8 | Must NOT state members can receive surplus if the chosen legal structure forbids it | "members share in profits", "surplus distributed to members", "profits returned to shareholders", "co-op members receive the surplus" | ”Whether surplus can be distributed to members depends on the chosen legal structure (distributing vs non-distributing co-op) and relevant legislation. No distribution is promised.” |
Case Studies & Analogies
| # | Rule | RED-FLAG phrases to search | Compliant rewrite pattern |
|---|---|---|---|
| 9 | Must NOT present a case study as real or analogous without verification | "just like <venue>", "as proven by X community", "based on the successful Y model", "this has worked before at" | ”Published examples of community ownership (e.g., Grong Grong, Lockington — both verified analogues in case_study_cleaned.md) are illustrative only; comparability limitations apply (size, demographics, building condition all differ). Verify every named case against internal/research/case_study_cleaned.md before use.” |
Financial Product / ASIC Caution
| # | Rule | RED-FLAG phrases to search | Compliant rewrite pattern |
|---|---|---|---|
| 10 | Must NOT read as a financial product offer under ASIC caution — no offer to issue, deal in, or arrange interests requiring a prospectus or CSF offer document | "invest now", "buy shares", "secure your stake", "offer of shares in the co-op", "apply for membership today", "minimum investment $X", "register your interest to invest" | ”This document is not a financial product offer. It asks whether community ownership of a local pub is worth exploring. No shares, interests, or securities are being offered. If the project proceeds, a compliant offer document would be prepared.” |
| 10a | Must NOT present a community debenture / community loan as a live or imminent offer — a debenture is a financial product under the Corporations Act, and a public offer engages Ch 6D disclosure (and a trustee) regardless of how low the interest rate is (anticipated accountant advice Q3–Q4; legal advice A2 — “the single easiest way to accidentally create a regulated financial product”) | "community debenture", "debenture offer", "co-operative debenture", "invest in our debenture", "our debenture pays", "lend to the co-op for X%" | ”If the project proceeds, any community lending mechanism (e.g. a debenture structured as a loan) would be designed later, with compliant disclosure documents and after legal and accounting advice — it is not offered now. Keep debenture design and description in Stage 2 (legal advice A2). The descriptor ‘community debenture (a loan to the co-op)’ is fine in internal/explanatory copy; an offer to the public is not.” |
Mandatory Uncertainty Markers
At least one of each (or a semantic equivalent) must appear in any externally-circulated document:
| Required marker | Why |
|---|---|
| ”subject to feasibility” | Flags that the project may not proceed |
| ”subject to legal advice” | Flags unresolved legal questions |
| ”indicative only” / “for discussion purposes” | Qualifies all financial figures |
| ”if it proceeds” | Every forward-looking claim is conditional |
| ”not a financial product offer” | Disclaims ASIC-regulated offer status |
How to Run This Pass
- Search — grep every RED-FLAG phrase across the target document and all public copy (
docs/,src/pages/,docs/website_content/,README.md). - Classify — tag each hit blocking (direct guardrail violation), serious (ambiguous), or minor (tone).
- Rewrite — replace every blocking and serious hit with the compliant rewrite pattern; keep intent, remove the claim.
- Log — record file, line, original phrase, classification, rewrite applied.
- Escalate — any change to dividend/return/licence/legal-structure language, any new financial figure, or any case-study claim requires human sign-off before publication (CLAUDE.md sign-off gates).