Conflict of Interest & Financial Disclosure Compliance Policy

1. Purpose

To uphold transparency, ethical accountability, and fiduciary trust by requiring all governance participants to declare potential conflicts and submit financial disclosures aligned with CrownThrive’s legal obligations and community expectations.

2. Applicability

This policy applies to: Board Members (including At-Large and Executive Seats) Committee Chairs, Vice Chairs, and Assistants Executive Directors and Appointees Advisors, Auditors, and Moderators CHLOM Token Holders with Governance Power ThriveFund Advisors, Investors, and Equity Partners

3. Mandatory Conflict of Interest Declarations

3.1 Timing of Disclosure All individuals must submit a Conflict of Interest (COI) declaration: Upon nomination or appointment to a governance role Annually during Q1 of the fiscal year Within 14 days of any material change (e.g., accepting paid contracts, partnerships, or consulting roles) 3.2 What Must Be Declared Disclosures must include: Ownership in or employment by competitive entities Paid endorsements, content deals, or consulting roles involving CrownThrive competitors Family, spousal, or business relationships with candidates or platform contractors Direct or indirect financial stakes in any affiliated platform, campaign, or funding round

4. Financial Disclosure Requirements

4.1 Required for Roles With Fiduciary Oversight Board Members, ThriveFund Advisors, Committee Treasurers, and Financial Reviewers must: Submit annual financial statements or declarations (template provided) List any investments, affiliations, or assets that may intersect with their governance duties Agree to independent review and secure storage of disclosures 4.2 Optional for General Committee Roles Committee Assistants and non-fiduciary members may opt-in but are not mandated unless asked by Compliance Committee.

5. Oversight, Storage & Enforcement

All COI declarations and financial disclosures are reviewed by the Governance & Compliance Committee Documents are stored securely with access restricted to Founder-level administrators and Compliance Chairs False declarations, material omissions, or failure to submit may result in: Disqualification from nomination or election Suspension or removal from current office Public censure or legal escalation in cases of fraud or fiduciary harm

6. Related Committee Reporting

Each committee’s Annual Report must confirm whether all required disclosures were submitted and reviewed CHLOM-integrated smart contracts may flag non-compliance or voting activity by non-cleared individuals

7. CHLOM Governance Ledger Requirements

For CHLOM-enabled committees or tokenized voting, all relevant disclosures: Must be uploaded to the CHLOM Governance Ledger (private tier) Are referenced in vote-weight assignments and seat activation logs

8. Amendments & Audit Triggers

This policy is reviewed annually by the Compliance Chair If a conflict is discovered post-appointment, an emergency review is triggered Amendments must be approved by the Board and Executive Governance Council 📌 Document Version: v1.0 📅 Effective Date: July 30, 2025 📁 Maintained by: Governance & Ethics Committee · Compliance Division · CHLOM Integrity Board