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

Recovery Operations Procedure

Six-stage recovery workflow with cost cap, statute-of-limitations tracking, vault routing.

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

1. Six-Stage Workflow

  1. Investigation (60-day target): operations and Foundation collaborate on evidence collection; Grantee receives notice and opportunity to respond.
  2. Determination: Foundation makes a recovery determination (full clawback, partial clawback, no action) supported by evidence; reviewable by Council if disputed.
  3. Demand: Foundation issues a demand letter specifying amount, evidence, and 30-day response period.
  4. Voluntary Recovery: Grantee may return funds voluntarily. Voluntary recovery is documented but does not preclude registry inclusion if warranted.
  5. Legal Action: if voluntary recovery fails, Foundation may pursue legal action. Operating Co provides CREB evidence packages admissible under FRE 902(14) at no incremental cost on Comprehensive engagements.
  6. Settlement: recovery proceeds (net of legal and recovery costs, capped at 25% of recovered) route to the originating Vault per the Charitable Allocation Schedule.

2. Cost Cap

Recovery costs (legal fees, third-party investigators, settlement negotiators) are capped at 25% of the recovered amount. Excess recovery costs draw from the originating Vault's Operations sub-account.

3. Statute of Limitations

Recovery actions are subject to applicable statutes of limitations. The Platform tracks the limitation clock from the date of disbursement and notifies Foundations approaching expiration (90 / 60 / 30 days before).