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SAMPLE - DRAFT FOR COUNSEL REVIEW. Not yet executed by JIL Sovereign Technologies, Inc. or binding on any party.
Governance

Bad-Actor Registry Inclusion & Appeals

Due-process inclusion process: 30-day notice, response, optional hearing, council vote, anchor.

Effective: 2026-05-04Last updated: 2026-05-04Version 1.0 (sample)

1. Purpose

The Bad-Actor Registry is a shared cross-Foundation registry of organizations and individuals whose conduct on the Platform warrants restriction. Inclusion follows a due-process procedure to ensure fairness. Inclusion at the “Restricted” or “Excluded” level is publicly listed; the “Watch” level is internal.

2. Inclusion Criteria

An entity may be included if at least one of the following has occurred and the conduct has been substantiated through the inclusion process: (a) substantiated fraud against any Platform participant; (b) material misrepresentation in a grant application or milestone submission; (c) misappropriation of grant funds; (d) beneficial owner appears on sanctions lists discovered after grant award; (e) pattern of governance failures; (f) refusal to provide audit access or evidence after credible request; (g) court findings of fraud, embezzlement, or related charitable misconduct.

3. Inclusion Process

  1. Submission by a Foundation, Operating Co, or the Advisory Council, with supporting evidence.
  2. Operations review within 10 business days; assembly of evidence package.
  3. Notice to the entity with 30 days to respond.
  4. Entity response period; entity may submit evidence or request a hearing.
  5. Optional Council hearing if requested; conducted within 60 days of request.
  6. Council decision by majority vote of voting members; two-thirds for material levels (Restricted/Excluded).
  7. CourtChain anchor of the decision.
  8. Notice of decision to the entity within 5 business days.

4. Inclusion Levels

  • Watch: heightened scrutiny on future applications. Internal flag visible to Foundations during vetting. Not public.
  • Restricted: cannot receive new grants from any participating Foundation. Existing grants continue under heightened monitoring. Public listing. Default 36 months.
  • Excluded: cannot receive grants. Existing grants reviewed for termination. Public listing. Default 60 months. Re-application only with successful appeal.

5. Appeals

An entity may appeal: (a) inclusion at any time after the initial decision; (b) level (e.g. Excluded → Restricted) after 50% of the inclusion period elapses; (c) removal at any time after the inclusion period elapses. Appeals are reviewed by the Advisory Council; new evidence may be considered. Council decisions on appeals are CourtChain-anchored.

6. Removal

An entity is removed when (a) the inclusion period has elapsed AND (b) the entity has demonstrated remediation (governance changes, restitution, third-party attestation) AND (c) Council approves removal. Removal does not erase the registry history; past inclusions remain on the audit trail but no longer affect eligibility.