Conflict of Interest Disclosure & Recusal Policy

1. Purpose

To protect the decision-making integrity of CrownThrive, ThriveAlumni, and affiliated entities by ensuring transparency, accountability, and fairness in the presence of real or perceived conflicts of interest.

2. Scope

This policy applies to: Founders and Board Members Committee Chairs, Directors, and Officers Advisors, Investors, and Strategic Partners Any individual with governance power or fiduciary responsibility within the CrownThrive ecosystem

3. Definition of Conflict of Interest

A conflict of interest occurs when personal, financial, or relational interests: Compete with the individual’s duty to CrownThrive Compromise objective judgment or priority of duty Create the appearance of impropriety or biased influence Examples include: Voting on contracts where family/friends are involved Hiring decisions involving romantic or familial relations Investment rounds where one stands to profit directly Platform decisions affecting one’s own brand, product, or affiliate interests

4. Disclosure Requirements

All stakeholders must: Submit an Annual Disclosure Form identifying potential conflicts Update their disclosure if material changes arise Disclose verbally and in writing any new conflict before participating in related votes, decisions, or collaborations Disclosures are logged by the Secretary & Compliance Officer and stored in CHLOM’s Compliance Ledger.

5. Recusal Protocol

If a conflict exists or is reasonably suspected: The individual must recuse themselves from discussion, voting, and any influence over the matter Their vote is disqualified on record If the issue is significant, the Board or Founders may temporarily suspend their access to deliberations regarding the matter Failure to recuse may lead to disciplinary action or removal per the Judicial or Ethics Committees.

6. Third-Party Contracts & Investments

Any partnership, vendor relationship, or investment involving a conflict must: Be reviewed by the Legal and Finance Committees Be ratified by a 2/3 majority of the Executive Committee excluding the conflicted party Include transparency statements when disclosed to members or public

7. Appeals & Investigations

Suspected violations can be: Reported to the Ethics Committee Investigated by the Judicial Committee Appealed to the Board for final determination Investigations will include evidence review, conflict logs, and formal written findings.

8. Public Disclosure Threshold

Conflicts involving elected officers, high-level fiduciary roles, or major ecosystem funds must be disclosed publicly via: ThriveAlumni dashboard (for member visibility) CHLOM public ledger CrownThrive Help Center Governance Reports

9. Consequences of Non-Disclosure

Failure to disclose or recuse may result in: Censure or formal warning Suspension of designation or vote Termination of role or contract Legal action if fiduciary harm or fraud occurred

10. Enforcement & Amendment

This policy is enforceable by the Governance, Compliance, and Judicial Committees. Amendments require: 2/3 approval from the Board Majority consent of Founders Notice via ThriveAlumni and CHLOM audit update 📌 Document Version: v1.0 📅 Effective Date: July 30, 2025 📁 Maintained by: CrownThrive General Counsel · Judicial Committee · Compliance Officer