> For the complete documentation index, see [llms.txt](https://admin-services.docs.intersectmbo.org/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://admin-services.docs.intersectmbo.org/governance/policies-and-guidance/administrator-conflict-of-interest-and-ethics-policy.md). # Administrator Conflict of Interest & Ethics Policy **1. Policy** **Title:** Intersect Administrator Conflict of Interest and Ethics Policy **2. Version:** 1.0 **3. Effective Date:** 08/05/2026 **4. Review Date:** 08/05/2027 **5. Policy Owner:** Operations Director **6. Policy Sponsor:** Intersect Executive Director *** **7. Purpose:**\ The objectives of this policy are to define ethical benchmarks for Intersect staff in their management of operations, vendor partnerships, and the governance of digital assets. By upholding high standards of transparency and integrity in contract and project management, Intersect ensures that all administrative actions serve the organization’s primary interests rather than individual gain. Ensuring compliance with US federal laws ([BSA](https://www.fincen.gov/resources/statutes-regulations/bank-secrecy-act), [SEC Acts](https://www.sec.gov/about/laws/securities-act-1933), [Financial Innovation and Technology for the 21st Century Act](https://www.govinfo.gov/app/details/BILLS-118hr4763eh) (FIT21 Act)) and international standards ([IOSCO](https://www.bis.org/fsi/fsisummaries/ioscoprinciples.htm), [MiCA](https://finance.ec.europa.eu/regulation-and-supervision/financial-services-legislation/markets-crypto-assets-mica_en),[ ELI](https://www.europeanlawinstitute.eu/projects-publications/projects/eli-principles-on-blockchain-technology-smart-contracts)). We believe that ethical governance is not simply a compliance requirement; it is a cornerstone of Intersect's integrity and a reflection of the trust placed in us by the Cardano community and the wider ecosystem we serve. **8. Scope:** This policy mandates disclosure of personal, financial, or other such relationships that could impair Intersect’s objective judgement, with the aim of preventing corruption, favoritism and reputation damage. This applies to all Intersect’s Administrators, Advisors, Committee members and anyone with delegated authority. This covers actual, potential, or perceived conflicts, including financial interests, secondary employment, and personal relationships to support Intersect’s governance integrity and protect Intersect and the wider Cardano ecosystem.\ \ This Policy applies across all administrative activities, including: * Vendor Onboarding; * Smart Contract Deployment and Refinements; * Digital Asset Issuance; * Milestone Acceptance; * Third Party Assurer (TPA) nomination and review; * Oversight Committee member activities; * AML/KYC/KYB Oversight; * Reporting and Transparency obligations; and * Governance decisions affecting global stakeholders. This Policy acts as the definitive guideline on when and how Intersect Administrators must identify, disclose, and escalate any actual, potential, or perceived conflict of interest to the relevant authorised personnel. **9. Principles:** The following principles underpin this Policy and must guide all administrative decision-making at Intersect: Independence: Intersect shall maintain its independence and take all reasonable steps to avoid undue influence from vendors, suppliers, validators, committee members, or ecosystem partners; Administrative Integrity: Intersect shall uphold administrative integrity consistent with the IOSCO Principles; Transparency: Intersect shall ensure transparency in all decisions affecting digital asset issuance or governance; and Regulatory Compliance: Intersect shall avoid any actions that could trigger disclosure obligations or give rise to liability under applicable US or international regulatory frameworks, including the Securities Act of 1933 and the Securities Exchange Act of 1934. **10. Definitions:** * Conflict of Interest - Any situation where actual, potential, or perceived interests may compromise the ability to perform a service independently. * Intersect - any individual performing administrative functions on behalf of Intersect, including those with delegated authority. * Personal Interest - Financial, relational or reputational benefit to Intersect or Associated party. * Material Benefit - Financial gain, preferential treatment or influence that could be beneficial to an associated party * Related Party - Any Affiliated entities, Individuals and overseers. * Ethical Conduct - Integrity, fairness and transparency within Intersects’ Administrative Business dealings. * Legal Contract - The legal contract, being a contract entered into by Intersect in its capacity as Administrator on behalf of the Cardano ecosystem. * Smart Contract - The on-chain contract that holds and controls funds transparently with limited, permissioned actions. * Third Party Assurer (TPA) - An independent entity nominated to verify that vendor project deliverables meet the technical requirements and standards agreed under the relevant PSSC. * Oversight Committee (OC) - The body responsible for overseeing Intersect's performance as an Administrator and for ensuring compliance with applicable standards. **11. Policy Statements:** **11.1 Integrity, Impartiality, and Transparency** Interesect strives to uphold the integrity of the Cardano ecosystem through impartiality and transparency in Administrative relationships and governance activities. **11.2 Ethical Conduct and Governance Standards** Intersect is committed to maintaining the highest standards of ethical conduct in Administrative and governance activities in business relationships to business partnerships, suppliers, vendors and any such relationships with other third parties. Intersect shall conduct its activities in accordance with applicable legal, regulatory, and industry standards, including obligations arising under: * Bank Secrecy Act (BSA) * Financial Innovation and Technology for the 21st Century Act (FIT21) * International Organization of Securities Commissions (IOSCO) Principles * Securities Act of 1933 (SEC) * European Law Institute (ELI) Principles * Markets in Crypto-Assets Regulation (MiCA) **11.3 Conflicts of Interest** Intersect must disclose, avoid and appropriately manage any actual, potential or perceived conflicts of interests, and must ensure that vendors adhere to Intersect’s ethical standards throughout the duration of the process, particularly when dealing with third parties and verification overseers. Intersect’s Administrators must act in the best interests of Cardano ecosystem and its community, prioritising fairness, administrative integrity and responsible governance. Intersect must not use their position, access to information, or any authority entrusted to them for personal gain or to confer a Material Benefit on any Related Party. **11.4 Third-Party Assurer Independence and Integrity Requirements** Third-Party Assurers (TPAs) are critical in ensuring that vendor deliverables meet the agreed technical, legal, and smart contract defined for each project. To maintain the integrity and impartiality of the assessment process, TPAs must adhere to the following ethical standards: * Third-Party Assurers (TPAs) must be genuinely independent of the delivery team and must not be part of the same organisation, subsidiary, or contractor group. * TPA’s must not hold any interests; direct or indirect, that could influence or appear to influence their judgement. * TPAs must maintain complete separation from any group responsible for approving, funding or directing the work they are assessing. * TPAs must not report to, be influenced by or be a member of any committees that may have direct influence over the project being assessed. * TPAs must also be independent of any Intersect Committees. **11.5 Responsible Conduct and Due Diligence in External Relationships** Intersect must ensure that vendors, suppliers, contractors, verification overseers, and other third parties adhere to Intersect’s ethical standards throughout the duration of any engagement or contractual process. Intersect shall not act as Administrator for any entity or individual that: * Is subject to sanctions; or * Is associated with adverse AML, KYB, KYC or related compliance concerns, as further described in Intersect’s Due Diligence Policy. **11.6 Ethical Operational and Smart Contract Governance** Ethical governance practices must be embedded into all operational, financial, and smart‑contract‑related decisions made by Intersect and its staff.\ \ Intersect must ensure that appropriate safeguards are established and maintained to support proper oversight and verification of the progress and completion of milestones under all applicable legal and Smart Contracts . **11.7 Oversight Committee and Restrictions** Oversight Committee members must avoid any situation that could reasonably be perceived as a Conflict of Interest with their assigned Assurance Task. Where such a situation arises, the relevant OC member must promptly disclose it and recuse themselves from the relevant decision-making process.\ \ Members of the Oversight Committee are prohibited from acting as a vendor under any PSSC. Where such a situation cannot be avoided, the OC member must make a full disclosure, step back from all related decisions, and remain transparent about the nature of the situation throughout. **12. Roles and Responsibilities:**\ This section clarifies the roles and responsibilities of all parties involved in the administrative process. * Intersect- Responsible for providing oversight, maintaining adherence to compliance standards, and upholding accountability across all administrative activities. Intersect are the primary point of responsibility for identifying, disclosing, and managing Conflicts of Interest as they arise. * Third- Party Assurers - TPAs are responsible for ensuring that vendor project deliverables meet the technical requirements and agreed standards set out under the relevant legal and Smart Contracts. TPAs must operate with full independence of direct or indirect influence as outlined above. * Oversight Committee (OC) - The OC is responsible for overseeing Intersect's performance as an Administrator and for ensuring that Intersect adheres to applicable compliance standards. The OC acts as a critical check on administrative processes and must operate with independence and integrity. * Executive Leadership/Board - Executive Leadership and the Board are responsible for approving policy updates, ensuring that adequate resources are allocated to compliance and monitoring activities, and providing strategic direction on ethical governance matters. **13. Procedures** **13.1 Conflict Disclosure Procedure:**\ Intersect and Oversight Committee members must promptly disclose any relationship, association, or personal interest that may give rise to, or be perceived as giving rise to, a Conflict of Interest. Such disclosures must be made as soon as the potential conflict is identified and must include, as a minimum: * Any financial interests in vendors, suppliers, or other counterparties; * Any relationships relevant to AML/KYC/KYB oversight activities; and * Any relationships with validators connected to a relevant legal or Smart Contract. Disclosures must be made in writing, or by email to . **13.2 Third-Party Assurer Nomination**\ Intersect must ensure that vendors nominate a TPA that has no prior affiliation with, or personal responsibility to, the nominating vendor. * Intersect are responsible for requesting all relevant information about the nominated TPA and for confirming that the TPA maintains ethical independence and transparency in accordance with Intersect's compliance guidelines. * Where a Conflict of Interest risk is identified in respect of a nominated TPA, Intersect must require the vendor to nominate a replacement TPA before any assessment work commences. **13.3 Escalation procedures**\ Intersect retains full liability for all vendor proposal contracts, including sole responsibility for pausing and resuming milestone payments as appropriate. * Nothing in this Policy, or in the processes it envisages, shall operate to transfer any of Intersect's responsibilities or liabilities to the Oversight Committee (OC). * When Intersect becomes aware of a serious or unresolved Conflict of Interest, it must be reported immediately to Executive Leadership. **13.4 Conflict Review Procedure** * The Executive Leadership must review all submitted conflict disclosures within ten (10) working days of receipt. * Mitigation actions identified during the review must be documented clearly, along with any steps required to manage or resolve the conflict. * A record of all disclosures, reviews, and mitigation actions must be retained in accordance with Intersect's documentation standards. **14. Monitoring and Compliance:** **14.1 Oversight Committee Composition** * The Oversight Committee (OC) shall consist of no fewer than five (5) and no more than seven (7) members at any given time. This range is intentionally designed to balance the risk of conflicts of interest against operational efficiency and cost. * Intersect must ensure that the Oversight Committee is maintained and operated in the best interests of the Cardano community at all times. * It is Intersect's responsibility to identify and appoint a suitable replacement where any Oversight Committee member voluntarily leaves or is formally removed from their role. **14.2 Documentation and Record-Keeping** * All conflict disclosures, compliance reviews, TPA nomination records, and escalation outcomes must be documented and retained in a manner consistent with Intersect's internal documentation standards and applicable regulatory requirements. **15. Review and Amendment:**\ This Policy must be reviewed at least annually. Reviews must take into account any updates to relevant compliance guidelines, applicable law, and regulatory frameworks. Amendments to this Policy must be approved by Executive Leadership before taking effect. All Intersect staff must be notified of any updates in a timely manner, and any associated training requirements must be communicated clearly. Significant regulatory changes; such as material updates to the FIT21 Act, MiCA, or IOSCO Principles; may trigger an out-of-cycle review at any time, at the discretion of Executive Leadership or the Compliance Officer. **16. Related Documents/References:**\ [Intersect Due Diligence Policy
](https://admin-services.docs.intersectmbo.org/governance/policies-and-guidance/due-diligence-policy)[Technical Review Policy
](https://admin-services.docs.intersectmbo.org/governance/policies-and-guidance/technical-review-policy)[Transparent Dealings Policy](https://docs.intersectmbo.org/intersect-knowledge-base/legal/policies-and-conditions/intersect-members-policies/transparent-dealings-policy)\ [Delivery Assurance Process and Best Practice Policy](https://admin-services.docs.intersectmbo.org/governance/policies-and-guidance/delivery-assurance-process-and-best-practice-policy) [Financial Innovation and Technology for the 21st Century Act](https://www.govinfo.gov/app/details/BILLS-118hr4763eh) --- # Agent Instructions This documentation is published with GitBook. GitBook is the documentation platform designed so that both humans and AI agents can read, navigate, and reason over technical content effectively. Learn more at gitbook.com. ## Querying This Documentation If you need additional information that is not directly available in this page, you can query the documentation dynamically by asking a question. Perform an HTTP GET request on the current page URL with the `ask` query parameter, and the optional `goal` query parameter: ``` GET https://admin-services.docs.intersectmbo.org/governance/policies-and-guidance/administrator-conflict-of-interest-and-ethics-policy.md?ask=&goal= ``` `ask` is the immediate question: it should be specific, self-contained, and written in natural language. `goal` is optional and describes the broader end goal you are ultimately trying to accomplish on behalf of the user. GitBook uses it to tailor the answer towards what is most useful for that goal. The response will contain a direct answer to the question and relevant excerpts and sources from the documentation. Use this mechanism when the answer is not explicitly present in the current page, you need clarification or additional context, or you want to retrieve related documentation sections.