CONFLICT OF INTEREST POLICY

Last Revised: July 18, 2025

1. PURPOSE AND SCOPE

This Conflict of Interest Policy ("Policy") is established by Boundless Impact Research & Analytics ("Boundless" or "Company") to ensure compliance with applicable regulations and to maintain the highest standards of integrity in all business operations. This Policy applies to all employees, officers, directors, consultants, and subcontractors ("Covered Persons") of Boundless.

Boundless is committed to conducting business with transparency, objectivity, and without conflicts of interest that could compromise our professional judgment or the integrity of our services across all client relationships and business activities.

2. DEFINITION OF CONFLICT OF INTEREST

A conflict of interest exists when a Covered Person's personal, financial, or professional interests could reasonably be expected to:

  • Impair their objectivity in performing work for Boundless
  • Create an unfair competitive advantage
  • Compromise the integrity of Boundless' research, analysis, or recommendations
  • Violate federal contracting regulations or client requirements

Types of Conflicts Include:

Financial Conflicts:

  • Direct or indirect financial interest in client companies, competitors, or related entities
  • Investment in securities of companies being analyzed or assessed
  • Receiving compensation, gifts, or benefits from clients, suppliers, or competitors
  • Personal financial arrangements that could benefit from Boundless' work product

Professional Conflicts:

  • Serving on boards or advisory positions with client companies or competitors
  • Consulting relationships with entities that could benefit from Boundless' proprietary data
  • Employment or consulting arrangements with competing firms
  • Academic or research collaborations that could compromise objectivity

Personal Conflicts:

  • Family relationships with employees or decision-makers at client or competitor organizations
  • Personal relationships that could influence professional judgment
  • Outside activities that compete with Boundless' business interests

3. FEDERAL CONTRACTING COMPLIANCE

Organizational Conflicts of Interest (OCI)

Boundless recognizes three categories of OCIs as defined by federal regulations:

Biased Ground Rules: When a contractor's involvement in drafting specifications or requirements could provide unfair competitive advantage.

Impaired Objectivity: When a contractor's objectivity in performing work could be compromised by other activities or relationships.

Unfair Competitive Advantage: When a contractor has access to non-public information that provides competitive advantage.

Compliance Measures

  • All federal contract proposals will include required OCI representations
  • Potential OCIs will be identified and disclosed during the proposal process
  • Mitigation plans will be developed and implemented as required
  • Ongoing monitoring for emerging conflicts throughout contract performance

4. DISCLOSURE REQUIREMENTS

Annual Disclosure

All Covered Persons with potential conflicts of interest must complete an annual Conflict of Interest Disclosure Statement covering:

  • Financial interests in relevant companies or sectors
  • Board positions, consulting arrangements, or other professional relationships
  • Family relationships that could create conflicts
  • Any other circumstances that could reasonably create a conflict

Other Covered Persons may complete the disclosure statement voluntarily or when requested by management.

Ongoing Disclosure

Covered Persons must promptly disclose any potential conflicts that arise during the year, including:

  • New investments or financial interests
  • Changes in family circumstances
  • New professional relationships or opportunities
  • Any situation that could reasonably create a conflict

Project-Specific Disclosure

Before beginning work on any project, team members must disclose any potential conflicts specific to that engagement.

5. REVIEW AND EVALUATION PROCESS

Disclosure Review Committee

The Boundless leadership team, with input from legal counsel as needed, will review all disclosures and determine:

  • Whether a conflict exists
  • The severity and nature of the conflict
  • Appropriate mitigation measures
  • Whether participation in specific projects should be restricted

Mitigation Strategies

When conflicts are identified, the following mitigation measures may be implemented:

  • Recusal: Removing the individual from specific projects or decisions
  • Divestiture: Requiring disposal of conflicting financial interests
  • Screening: Implementing information barriers to prevent access to sensitive information
  • Monitoring: Enhanced oversight of the individual's involvement in relevant matters
  • Disclosure: Transparent disclosure to clients when required

6. PROHIBITED ACTIVITIES

Gifts and Entertainment

Covered Persons may not accept gifts, entertainment, or hospitality from clients, suppliers, or competitors with a value exceeding $25 per occasion or $100 annually from the same source, except:

  • Promotional items of nominal value
  • Widely distributed promotional materials
  • Hospitality extended to multiple participants at industry events

Insider Information

Covered Persons must not:

  • Use confidential information obtained through Boundless for personal gain
  • Trade securities based on material non-public information
  • Disclose proprietary methodologies, data, or client information

Competing Activities

Without prior written approval, Covered Persons may not:

  • Provide similar services to competitors
  • Develop competing products or services
  • Solicit Boundless clients for outside business

7. SPECIFIC PROVISIONS FOR FEDERAL CONTRACTS

Procurement Integrity

For federal contracts, additional restrictions apply:

  • No solicitation or acceptance of gratuities from offerors
  • No disclosure of proprietary or source selection information
  • No acceptance of employment discussions with offerors during procurement
  • Strict compliance with cooling-off periods for former federal employees

Subcontractor Requirements

All subcontractors must:

  • Acknowledge this COI Policy
  • Provide conflict disclosures as required
  • Comply with all applicable federal contracting requirements
  • Report potential conflicts immediately

8. TRAINING AND AWARENESS

Initial Training

All new Covered Persons will receive COI training covering:

  • Policy requirements and procedures
  • Disclosure requirements
  • Consequences of violations

Ongoing Training

Training will be provided as needed to ensure continued compliance with policy requirements.

9. ENFORCEMENT AND CONSEQUENCES

Violations

Failure to comply with this Policy may result in:

  • Disciplinary action up to and including termination
  • Legal action to recover damages
  • Referral to appropriate government authorities
  • Disqualification from federal contracting opportunities

Good Faith Reporting

Boundless encourages good faith reporting of potential conflicts and prohibits retaliation against individuals who report suspected violations.

10. RECORD KEEPING

Documentation Requirements

Boundless will maintain records of:

  • All disclosure statements
  • Review committee decisions
  • Mitigation measures implemented
  • Training completion records
  • Any conflict-related incidents

Retention Period

Records will be retained for a minimum of five years or as required by applicable regulations.

11. REVIEW AND UPDATES

This Policy will be reviewed annually and updated as necessary to reflect:

  • Changes in federal regulations
  • Evolution of business activities
  • Lessons learned from implementation
  • Best practices in conflict management

12. POINT OF CONTACT

For questions regarding this Policy or to report potential conflicts: [email protected].

This document contains confidential and proprietary information of Boundless Impact Research & Analytics. Unauthorized distribution is prohibited.