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, and campaign beneficiaries. Trust, accountability, and stewardship of donated funds are central to our mission.

   This Disclosure and Transparency Policy (“Policy”) establishes mandatory standards for openness, ethical conduct, and accountability applicable to all campaign creators, partner organizations, beneficiaries, officers, employees, and volunteers participating in or supported through the Initiate Global platform.

   By launching, managing, or benefiting from a campaign on Initiate Global, all parties agree to comply with this Policy.

2. Scope and Application
   This Policy applies to:
   
   1. Campaign creators and project proponents;
   2. Partner foundations and implementing organizations;
   3. Beneficiaries receiving funds or in-kind support;
   4. Initiate Global officers, employees, and authorized representatives, where applicable.

   The Policy governs disclosures relating to project progress, use of funds, conflicts of interest, audits, and regulatory compliance.

3. Periodic Updates and Use of Funds
   Transparency in the use of donated funds is a core obligation. Campaign creators and implementing partners must provide timely, accurate, and complete information to donors and to Initiate Global.

   3.1 Reporting Obligations
   Campaign creators must publish the following on the Initiate Global platform:

   1. Monthly Progress Updates during the active campaign period and for at least twelve (12) months following fund disbursement, unless the project is completed earlier;
   2. A Final Project Report summarizing:
      • Project objectives and outcomes;
      • Total funds raised;
      • Total funds disbursed and expended;
      • Any remaining or unutilized balances and their proposed disposition, subject to Initiate Global approval.

   All reports must be factual, complete, and presented in a manner that allows donors to reasonably understand how funds were utilized.

   3.2 Financial Documentation and Recordkeeping

   1. Campaign creators and implementing partners must maintain a detailed breakdown of all expenditures, supported by official receipts, invoices, contracts, payroll records, or equivalent documentation.
   2. All financial records must be retained for a minimum of five (5) years from the date of fund disbursement, or longer if required by applicable law or donor agreements.
   3. Upon reasonable request, such documentation must be submitted to Initiate Global, donors (in summarized or redacted form where appropriate), regulators, or authorized third-party auditors.

   Failure to provide accurate reports or supporting documentation may result in fund withholding, suspension, or termination of the campaign.

4. Conflict of Interest and Related-Party Disclosure
   To preserve integrity and public confidence, all actual, potential, or perceived conflicts of interest must be fully disclosed.

   Campaign creators and partners are required to declare any relationship that could influence, or appear to influence, decision-making or fund utilization, including but not limited to:

   1. Engagement of relatives, close associates, officers, or employees;
   2. Procurement of goods or services from entities in which the creator, beneficiary, or related parties have ownership, management, or control;
   3. Financial arrangements that may result in self-dealing, undue benefit, or preferential treatment.

   All conflicts must be disclosed prior to campaign approval and promptly updated if circumstances change. Initiate Global reserves the right to impose safeguards, require independent pricing or procurement processes, or prohibit certain transactions.

   Non-disclosure or misrepresentation of conflicts of interest may result in disciplinary action, campaign removal, restitution of funds, and referral to appropriate regulatory or law enforcement authorities.

5. Verification, Monitoring, and Audit Rights
   As a steward and conduit of donated funds, Initiate Global reserves the right to monitor and verify campaign activities to ensure consistency with donor intent and approved project representations.

   Verification measures may include, without limitation:

   1. Review of financial records, bank statements, and supporting documents;
   2. Interviews or virtual meetings with project teams or beneficiaries;
   3. On-site or remote inspections to confirm project existence and progress;
   4. Engagement of independent auditors, compliance officers, or professional advisers.

   Campaign creators and partners must cooperate fully and provide requested information within reasonable timeframes. Failure or refusal to cooperate may result in:

   1. Suspension or delisting of the campaign;
   2. Forfeiture or reallocation of undistributed funds;
   3. Recovery of misused funds; and/or
   4. Legal action or referral for suspected fraud, misrepresentation, or money laundering.
6. Platform-Level Transparency and Accountability
   Initiate Global is committed to transparency in its own operations. To this end, the Foundation shall publish an Annual Transparency Report, which may include:
   
   1. Aggregate data on funds raised, disbursed, refunded, and retained for administrative or platform costs;
   2. Summaries of governance practices, compliance initiatives, and material platform updates;
   3. Disclosure of any confirmed data breaches, regulatory findings, or significant legal matters affecting fund integrity or user data;
   4. Impact highlights demonstrating community outcomes, partnerships, and beneficiary success stories.

   Such reports shall present aggregated and non-identifying information, unless disclosure is required by law or consented to by affected parties.

7. Data Privacy and Regulatory Compliance
   
   1. All disclosures, audits, and recordkeeping shall comply with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and issuances of the National Privacy Commission.
   2. Financial and transactional monitoring shall adhere to the Anti-Money Laundering Act (Republic Act No. 9160), as amended, and related regulations.
   3. Information collected for transparency, verification, or audit purposes shall be processed lawfully, securely, and only to the extent necessary for compliance, accountability, or legal obligations.
   4. This Policy aligns with applicable NPC circulars, including standards on data retention, audit trails, and documentation integrity.
8. Enforcement and Sanctions
   Violations of this Policy may result in one or more of the following actions, without prejudice to other legal remedies:
   
   1. Issuance of warnings or directives to cure deficiencies;
   2. Temporary suspension or permanent removal from the platform;
   3. Withholding, recovery, or reallocation of funds;
   4. Termination of partnership or accreditation;
   5. Referral to regulatory agencies or law enforcement authorities.
9. Acknowledgement
   By launching, managing, supporting, or benefiting from a campaign on Initiate Global, you acknowledge that you have read, understood, and agreed to comply with this Disclosure and Transparency Policy.

   Transparency is a continuing obligation and a condition of participation in the Initiate Global community.

Prepared by Management, 2026