Conflict of Interest Policy

Scope

This policy applies to every member of the Legal Department, every State Coordinator, every Disputes officer, and every member of the Platform Operations team who can influence an approval, decline, or dispute outcome.

Disclosable relationships

A reviewer or coordinator must declare any of the following with respect to a developer, investor, vendor, carrier, or related party in a matter they are assigned:

1. Family — spouse, parent, child, sibling, in-law, or cohabitant.
2. Employment — current or within the past 24 months.
3. Financial — any ownership interest, lending relationship, or

substantial expected economic benefit.

1. Professional — having acted as counsel, agent, or consultant for

the party within the past 24 months.

1. Political / social — any relationship that a reasonable observer

would think could influence the decision.

Required action

1. Declare the relationship in the platform's Conflict Declaration

form before any work on the matter.

1. Recuse unless the Head of the relevant function (Head of Legal,

Head of Coordinator Network) explicitly authorises the reviewer to continue with disclosure.

1. Reassign the matter to another qualified reviewer; if no qualified

reviewer is available, the matter pauses until one is found.

1. Audit-log every declaration, recusal, and reassignment.

Consequences of non-disclosure

Knowingly failing to declare a disclosable relationship is grounds for immediate termination and criminal referral if the decision benefited the undisclosed party.

Quarterly conflict audit

Every quarter, the Head of Legal samples 5% of approved decisions and re-runs an independent conflict check. Findings are reported to the Board and any material issues are published in the Trust & Safety Report (with personal details redacted).