Here you go, only this makes it an instant security as promising dividends would be investment contract.
Usually people have messed it up right on the advertising, all it needs is expectation of a profit. Even hinting there could be some is enough.

Frankly i am worried that you need to ask legal advice from here. Not from the actual legal professionals. I mean there's nothing wrong asking but take the answers with a grain of salt.

Asking legal advices from pseudonyms and making financial decisions based on that makes me think you are going to mess something up. Hire a professional for a professional work.
Or you might end up paying way more then their salary.