Independence and Conflicts of Interest Policy

Adopted: [DATE] by Par & Reserve LLC (in formation), a wholly owned subsidiary of Block Bridge, Inc. ("Publisher") · Policy owner: [Head of Research / Compliance Lead] · Review: at least annually

1. Purpose

Our assessments are useful only if readers can trust that they are disinterested. This policy sets rules that keep our scores, grades and research free from commercial influence. It also requires us to disclose the relationships readers need to know about, including those of our affiliate Block Bridge, Inc. and of our personnel.

2. Scope

This policy applies to Publisher; its officers, employees and contractors who take part in research, analysis, editing or publication ("Research Personnel"); and, as stated, to Block Bridge, Inc. and its other businesses (together, "Affiliates").

3. Core rules

3.1 Issuers cannot pay for scores. Publisher will not request or accept any payment, fee, sponsorship, advertising, grant, token allocation, airdrop, revenue share, referral fee, "methodology review fee," or other thing of value from any Issuer (a person that issues, sponsors or administers a stablecoin or other asset we cover), or from its affiliates, in connection with an assessment, score, grade or coverage decision. This also applies to vendors we assess in vendor scorecards.

3.2 Issuer subscriptions. An Issuer or vendor may buy a standard subscription at published list prices under standard terms. A subscription: (a) gives no right to influence, preview, approve or delay any content; (b) doesn't change coverage, scheduling or methodology; and (c) is disclosed in aggregate (for example, "X issuers/vendors are subscribers"). It is disclosed specifically if the subscription revenue from a single Issuer group exceeds [2]% of Publisher's annual revenue.

3.3 No pay-to-be-covered, no pay-to-be-removed. Coverage is decided under our published coverage criteria. Requests to add, remove, delay or soften an assessment are logged and are never granted for consideration.

3.4 Methodology first. Every score is produced by applying the current published methodology. Any analyst override must be (a) documented in writing with reasons and evidence, (b) approved by a second qualified reviewer who did not make the override, and (c) disclosed in the issue as "analyst adjustment applied."

3.5 Same content for everyone. All subscribers receive the same content at the same time. No subscriber, Issuer, Affiliate, investor or other person gets early access to scores or grades, except for the factual-accuracy check sent to the assessed Issuer under the Corrections and Right-of-Reply Policy. That check covers facts only, and never shows the score or grade.

4. Affiliate firewall: Block Bridge, Inc. / Trust Bridge Network

4.1 Disclosure. Block Bridge, Inc. is developing stablecoin settlement infrastructure (Trust Bridge Network, "TBN"). TBN may in the future support particular stablecoins or blockchains, or have commercial relationships with Issuers, custodians or other service providers that we cover.

4.2 Information barrier. TBN commercial personnel: (a) may not take part in, review, or comment on assessments before publication; (b) receive Report content only as ordinary subscribers, at the same time as everyone else; and (c) may not use non-public research information, including draft scores and Issuer fact-check correspondence.

4.3 Overlapping personnel. While any individual works on both research and TBN (including the founder), that individual: (a) logs every TBN commercial relationship or active negotiation with a covered Issuer, blockchain or vendor in the Conflicts Register; (b) does not act as the final approver of any assessment of an asset or entity on the Conflicts Register, and an independent second reviewer must approve it; and (c) certifies quarterly that this policy was followed.

4.4 Treatment of conflicted coverage. If the Conflicts Register shows a material relationship (for example, a signed commercial agreement, integration partnership, revenue share, investment, or a negotiation at term-sheet stage or later) between an Affiliate and an Issuer or asset, Publisher will either: (a) mark the asset NR – Conflict and publish only factual profile information; or (b) publish the assessment with the independent-review process in 4.3(b) and a prominent "Affiliated – see disclosure" flag next to the score, describing the relationship. [Drafting note: counsel to advise which approach is required for the "bona fide/disinterested" publisher analysis (legal-analysis.md Q19).]

4.5 No TBN marketing in the Report. The Report won't promote TBN or any Affiliate product. Any mention of an Affiliate is limited to disclosures.

5. Personal trading and holdings

5.1 Restricted instruments: (a) equity or debt securities of Issuers or their parents; (b) governance, utility or yield tokens tied to a covered stablecoin system; (c) yield-bearing or derivative versions of covered stablecoins; (d) derivatives on any of these.

5.2 Blackout: Research Personnel and their household members may not trade Restricted Instruments during the period from 5 business days before through 5 business days after publication of any issue or change that discusses the relevant Issuer or asset, or at any time while they have non-public knowledge of a pending score change.

5.3 Pre-clearance and disclosure: trades in Restricted Instruments outside the blackout require pre-clearance by the Compliance Lead (the founder's trades are pre-cleared by [an independent adviser/board designee]). Research Personnel disclose holdings of Restricted Instruments on joining and annually. Material holdings by Research Personnel in covered assets are disclosed in aggregate on the Disclosures page.

5.4 Operational stablecoin balances. Holding covered fiat-backed stablecoins in modest amounts for operational payments or testing is allowed, but must be disclosed to the Compliance Lead.

5.5 Investors. Publisher will ask Block Bridge's significant investors (≥[10]% ownership) to disclose material positions in, or board roles with, Issuers, and will disclose known material overlaps on the Disclosures page.

6. Financial-institution official roles: Awakon Federal Credit Union

6.1 Disclosure. Bradley W. Smith, founder of Block Bridge, Inc., serves as a member of the Supervisory Committee of Awakon Federal Credit Union ("Awakon"). As a Supervisory Committee member he is an "official" of Awakon under NCUA rules (12 CFR 701.33(a); 12 CFR 712.8(a)).

6.2 Recusal at Awakon. In his Awakon role, he will disclose this business to Awakon's board and Supervisory Committee and recuse himself from any Awakon discussion, decision, vote, audit or review about: subscribing to the Report; any Block Bridge, TBN or Publisher product; any stablecoin, digital-asset or vendor decision where Report content is a material input; and any investment in a CUSO that would acquire or operate the Service.

6.3 Sales to Awakon. Publisher will not sell to Awakon unless: (a) Awakon's board or management, acting without his participation, approve the purchase under Awakon's conflict-of-interest policy; (b) pricing and terms are no more favorable than those offered to similar subscribers; (c) the relationship is disclosed on the Disclosures page (with Awakon's consent) or in aggregate ("a credit union where a Publisher principal serves as an official is a subscriber"); and (d) counsel has confirmed it is permitted (legal-analysis.md Q21).

6.4 Information barrier. No Awakon confidential information (including examination findings, member or financial data, ALCO materials, vendor proposals, audit or Supervisory Committee materials, or board deliberations) may be used in the Report, in marketing, or in TBN. Awakon member, staff, board or committee contact lists will not be used for marketing.

6.5 Coverage of Awakon-related entities. If Awakon issues, invests in, or partners with a covered stablecoin, issuer or vendor, that asset is added to the Conflicts Register and handled under Section 4.4.

6.6 Future CUSO. Before any CUSO transaction, Publisher will get counsel's advice on 12 CFR 712.8 (compensation limits for officials of FCUs that invest in or lend to a CUSO) and structure the transaction to comply (legal-analysis.md Q22).

6.7 The same rules apply to any other financial-institution board, committee or advisory role held by Research Personnel.

7. Gifts, entertainment and outside activities

7.1 Research Personnel may not accept gifts or entertainment from Issuers or assessed vendors worth more than $[100] per person per year, travel or lodging paid by an Issuer, or speaking fees from Issuers. Attending conferences where Issuers sponsor is fine, provided Publisher pays its own way.

7.2 Outside employment, advisory roles, or token or equity compensation from any Issuer or covered vendor is prohibited.

8. Consulting and briefings

8.1 Paid board briefings and education sessions are educational and based on published content. They give no institution-specific recommendations.

8.2 Any consulting engagement (for example, custom scenario work) requires a separate written statement of work reviewed under this policy. It may not be performed for an Issuer or assessed vendor, and it may not change published content.

9. Disclosures page

Publisher maintains a public Disclosures page, updated at least with each issue, listing:

• Affiliate businesses (TBN) and material relationships with covered entities;
• board and committee seats (for example, Supervisory Committee) held by Research Personnel at financial institutions;
• the aggregate number of Issuer or vendor subscribers;
• any NR – Conflict designations;
• any overrides applied in the period; and
• the date of the last policy review.

10. Records, monitoring and breaches

• Keep the Conflicts Register, override logs, pre-clearance records, gift logs, and Issuer correspondence for at least 5 years.
• The Compliance Lead reviews compliance quarterly and reports annually. Once one exists, the report goes to an outside advisory panel with no Issuer ties.
• Breaches are documented, remediated, and disclosed where material to readers. Breaches may lead to discipline up to termination.

11. Questions and reporting

Report concerns to [compliance@DOMAIN]. Publisher will not retaliate against anyone who raises a concern in good faith.