Effective Date: [1 January 2026]

1. Policy Statement and Purpose
   Initiate Global Foundation, Inc. (“Initiate Global,” the “Foundation,” “we,” “us,” or “our”) is a non-stock, non-profit organization that acts as a foundation and as a conduit between donors, partner foundations, campaign creators, and beneficiaries.

   As a steward of donated funds and a platform that allows campaign creators to post content subject to Foundation oversight, Initiate Global is committed to the highest standards of transparency, accountability, and ethical governance. While campaign creators may initiate and manage campaigns, Initiate Global retains the authority to monitor, audit, restrict, suspend, or remove campaigns to protect donor trust, ensure legal compliance, and uphold fiduciary duties.

   This Audit and Reporting Framework (“Framework”) establishes the structure, standards, and procedures for financial audits, operational reviews, reporting, and oversight across all Foundation and platform activities.

2. Objectives
   This Framework is designed to:
   
   1. Ensure that all funds raised through the platform are used strictly for their stated and approved purposes;
   2. Promote transparency and accountability across campaigns, partner activities, and Foundation operations;
   3. Detect, prevent, and address fraud, misuse, diversion, or misallocation of funds;
   4. Provide accurate, timely, and accessible reporting to donors, regulators, and stakeholders; and
   5. Align with applicable standards, including Philippine Financial Reporting Standards (PFRS), International Standards on Auditing (ISA), and relevant Philippine laws and regulations.
3. Annual Independent External Audit
   3.1 External Audit of Financial Statements
   Initiate Global shall engage an independent and duly licensed external auditor accredited by the Securities and Exchange Commission (SEC) and/or the Bureau of Internal Revenue (BIR) to conduct an annual audit of the Foundation’s financial statements.

   The external audit shall cover, at a minimum:

   1. Total funds raised through the platform and other sources;
   2. Allocation, custody, and disbursement of campaign and program funds;
   3. Administrative costs, platform fees, and operating expenses;
   4. Compliance with tax laws, Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) requirements, and data protection obligations.

   The auditor’s report shall be reviewed by Management and presented to the Board of Trustees. Copies shall be made available to regulators and donors as required by law or donor agreements.

   3.2 Audit Scope, Standards, and Record Retention

   • External audits shall be conducted in accordance with the Philippines Standards on Auditing (PSA).
   • Complete audit trails, accounting records, and supporting documents shall be maintained for a minimum of five (5) years, or longer if required under Republic Act No. 9160 (Anti-Money Laundering Act), Republic Act No. 10173 (Data Privacy Act), or applicable regulations.
   • Audit findings and recommendations shall be documented, and Management shall implement corrective actions within prescribed timelines, subject to monitoring by the Compliance function.
4. Campaign-Level Audits and Verification
   4.1 Audit Rights Over Campaign Creators and Partners
   As a conduit and fiduciary intermediary, Initiate Global reserves the right to audit, verify, and monitor campaign creators, partner foundations, and beneficiaries receiving funds through the platform.

   Such audits may include:

   1. Review of financial records, receipts, contracts, and bank statements;
   2. Verification of project implementation and deliverables;
   3. Interviews or virtual meetings with campaign teams or beneficiaries; and
   4. On-site or remote inspections, where reasonably necessary.

   4.2 Enforcement Powers
   Where discrepancies, misrepresentations, or non-compliance are identified, Initiate Global may, without prejudice to other remedies:

   • Require corrective disclosures or supplemental reporting;
   • Suspend or remove campaign content;
   • Freeze, withhold, recover, or reallocate undistributed funds in accordance with donor intent and applicable agreements;
   • Terminate access to the platform; and/or
   • Refer matters to appropriate regulatory or law enforcement authorities.
5. Transparency and Public Reporting
   5.1 Annual Transparency Report
   Initiate Global shall publish an Annual Transparency Report to reinforce public accountability. The report may include aggregated and non-identifying information on:
   
   1. Total funds raised across all campaigns;
   2. Funds disbursed, refunded, or reallocated;
   3. Platform fees, administrative, and operational expenses;
   4. Number and status of active, completed, suspended, or cancelled campaigns; and
   5. High-level donor and campaign performance statistics.

   5.2 Disclosure Standards

   1. Transparency reports shall be published within ninety (90) days after the close of each fiscal year.
   2. Reports shall be made publicly accessible through the Foundation’s official website.
   3. Personal data and sensitive financial information shall be anonymized or redacted in compliance with the Data Privacy Act of 2012.
6. Real-Time Dashboards and Ongoing Reporting
   6.1 Platform Transparency Tools
   Initiate Global may maintain dashboards or reporting tools that provide donors and the public with visibility into:
   
   1. Campaign fundraising progress and milestones;
   2. Aggregate donation volumes and donor participation;
   3. Fund disbursement status and reporting timelines; and
   4. Updates submitted by campaign creators, subject to moderation and verification.

   6.2 Data Integrity and Controls

   1. Dashboard data shall be derived from verified transaction records and reconciled regularly with payment service provider reports.
   2. Creator-submitted updates are subject to review, verification, editing, or removal by Initiate Global to ensure accuracy, legality, and compliance with platform policies.
7. Internal Audit, Controls, and Compliance Reviews
   7.1 Internal Review Functions
   Initiate Global shall maintain an internal audit or compliance function responsible for conducting quarterly reviews covering:
   
   1. Fund receipt, custody, and disbursement controls;
   2. AML/CTF and sanctions screening procedures;
   3. Fraud detection, incident management, and whistleblower reports;
   4. Data protection and information security compliance; and
   5. Adherence to campaign reporting and disclosure requirements.

   7.2 Reporting and Escalation

   1. Internal audit findings shall be reported to Senior Management and the Board of Trustees or its designated committee.
   2. Deficiencies shall be recorded in a Corrective Action Log with defined remediation timelines and responsible officers.
   3. Material breaches, suspected fraud, or legally reportable incidents shall be escalated to the Anti-Money Laundering Council (AMLC), National Privacy Commission (NPC), or law enforcement agencies, as required by law.
8. Governance and Board Oversight
   8.1 Board Responsibility
   The Board of Trustees provides strategic oversight of this Framework, reviews audit results, and ensures that identified risks and compliance gaps are addressed in a timely manner.

   8.2 Continuous Improvement
   Audit outcomes and reporting insights shall be integrated into the Foundation’s risk management and continuous improvement processes, including updates to policies, systems, and staff training.

   8.3 Public Accountability
   Initiate Global affirms its commitment to ethical governance and responsible stewardship, ensuring that all funds entrusted to the Foundation are traceable, justified, and properly reported.

9. Review and Amendments
   This Framework shall be reviewed at least annually by Management and the Compliance function, and approved by the Board of Trustees. Updates shall reflect changes in law, regulatory guidance, audit recommendations, and evolving best practices for non-profit organizations and crowdfunding intermediaries.

   Material amendments shall be published on the platform and communicated to relevant stakeholders.

10. Acknowledgement
    By using or participating in the Initiate Global platform, donors, campaign creators, partners, and beneficiaries acknowledge and support the Foundation’s audit and reporting standards as a condition of participation.

Prepared by Management, 2026