Conflict of Interest & Dual Role Disclosure Policy

1. Purpose

This policy ensures that all decision-makers, board members, committee chairs, and advisors operate in alignment with the mission of CrownThrive LLC and ThriveAlumni without personal, financial, or political conflicts interfering with the governance process.

2. Scope

Applies to: Board Members and Executive Directors Committee Chairs, Vice Chairs, and Appointees Special Advisors, Investigators, and Delegates ThriveFund applicants, grantees, and sponsors Members with direct influence over nominations, elections, or contracts

3. Definition of Conflict of Interest

A conflict of interest includes, but is not limited to: Financial interest in an entity being voted on or contracted with Close personal/familial ties to nominees or business partners Simultaneous service in roles that audit, supervise, or fund each other Voting or decision-making power that could benefit one’s own ventures or affiliated groups

4. Mandatory Disclosure

4.1 Disclosure Timing All newly appointed roles must submit a signed Conflict Disclosure Form within 7 days Disclosures must be updated annually or when circumstances materially change 4.2 Failure to Disclose May result in immediate suspension pending investigation Will render that individual ineligible for reelection until cleared by the Compliance Committee

5. Dual Role Restrictions

5.1 Prohibited Overlaps A person may not serve as Chair or Vice Chair on more than one standing committee simultaneously No individual may hold a voting seat on a committee and also serve as an independent auditor for that same body Serving as a ThriveFund decision-maker while applying for a grant is prohibited 5.2 Permissible Exceptions (with Oversight) At-Large members or Advisors may serve on up to two committees if both Chairs sign off and Compliance Committee reviews the approval Emergency Appointees may temporarily hold overlapping seats (max 90 days) with special approval

6. Recusal & Abstention

6.1 Recusal Requirement Any member who has a conflict must recuse themselves from: Voting on the matter Leading discussions Participating in scoring or evaluations 6.2 Recusal Logging All recusals must be recorded in meeting minutes Repeated failure to recuse may be treated as a breach of ethics

7. Review & Investigation Protocol

All conflict concerns must be submitted to the Judicial or Compliance Committee. Investigations may include: KYC-based asset tracing Interviews with relevant parties Public statement requests from involved members Penalties may include: Public censure Role reassignment Suspension or removal

8. Whistleblower Protection

Members who report potential conflicts in good faith are protected from retaliation under the ThriveAlumni Whistleblower Shield. Reports may be submitted anonymously through the [Legal Depot Form] or to the Judicial Committee Chair directly.

9. Publication & Enforcement

This policy is available to all members via the CrownThrive Legal Depot and must be included in all nomination packages, onboarding packets, and committee election guidelines. Violations are enforceable under ThriveAlumni’s Governance Framework and CrownThrive's internal Member Agreements. 📌 Document Version: v1.0 📅 Effective Date: July 30, 2025 📁 Maintained by: Compliance & Ethics Committee with oversight by the Judicial Committee