Conflict of Interest Policy for DOE Financial Assistance Projects

1. Purpose
This Conflict of Interest (COI) Policy is established by Carbon Capture, Inc. (“CarbonCapture”) to comply with the Department of Energy (DOE) Interim Conflict of Interest Policy for Financial Assistance, FAL 2022-02 dated Dec. 20, 2021 (“DOE Interim COI Policy”). The purpose of this policy is to ensure that the design, conduct, and reporting of projects wholly or in part funded under DOE financial assistance awards will be free from bias resulting from financial conflicts of interest or organizational conflicts of interest.  These requirements supplement CabonCapture’s generally applicable Conflict of Interest Guidelines.

By ensuring adherence to this policy, CarbonCapture commits to maintaining the highest standards of integrity and transparency in all its operations and activities, particularly in DOE-funded projects.

2. Definitions

• Financial Conflict of Interest (FCOI): A situation in which a significant financial interest could directly and significantly affect the design, conduct, or reporting of DOE-funded research or projects.
• Organizational Conflict of Interest (OCI): A situation in which, because of other activities or relationships, an organization is unable to render impartial assistance or advice, or its objectivity in performing the work is or might be otherwise impaired, or it has an unfair competitive advantage.
• Covered Persons: All directors, officers, employees, consultants, and subcontractors of CarbonCapture Inc. involved in proposing, design, conduct or reporting on DOE-funded projects.
• Significant Financial Interest (SFI): A financial interest consisting of one or more of the following interests of the Covered Person (and those of the Covered Person’s spouse or dependent children) that reasonably appears to be related to the Covered Person’s responsibilities to CarbonCapture:
  • Equity interest in a publicly traded entity exceeding $5,000 or 5% ownership.
  • Equity interest in a non-publicly traded entity.
  • Receipt of income exceeding $5,000 from a single entity in the past 12 months.
  • Intellectual property rights and interests.
  • Travel expenses covered by or honoraria received from a non-governmental third party.
    
    

3. Disclosure Requirements
Covered Persons must disclose their significant financial interests and any organizational conflicts of interest:

• Prior to participating in DOE-funded projects.
• Annually, through the completion of a Conflict of Interest Disclosure Form.
• Within 30 days of discovering or acquiring a new significant financial interest or organizational conflict.
  
  

4. Review and Management of Conflicts
(As of December 2024, the Compliance Officer function is fulfilled by the Director, People)
The Compliance Officer will review all disclosures of significant financial interests and organizational conflicts of interest. If a conflict is identified:

• The Compliance Officer will determine the appropriate course of action to manage, reduce, or eliminate the conflict.
• In complex cases, the Compliance Officer may refer the matter to a Conflict of Interest Review Committee for further evaluation and recommendation.

• Requiring the Covered Person to recuse themselves from decision-making processes related to the conflict.
• Modifying the Covered Person’s job responsibilities to eliminate the conflict.
• Implementing additional oversight or review of the research or project.
• Divestiture of the conflicting financial interest.
• Termination of conflicting relationships or activities.

5. Documentation and Reporting
All disclosures, reviews, and actions taken to manage conflicts of interest will be documented and maintained in CarbonCapture’s records. These records will be reviewed periodically to ensure ongoing compliance.

• Reporting FCOIs prior to the expenditure of any funds under a DOE financial assistance award.
• Providing updates on any previously reported FCOIs and OCIs annually or as new conflicts arise.
  
  

6. Training and Awareness
CarbonCapture will provide training to all Covered Persons on this Conflict of Interest Policy and their responsibilities under it. Training will be conducted:

• Upon hiring or engagement and prior to participating in DOE-funded projects.
• Annually, as a refresher.
• As needed, to address changes in the policy or specific conflict of interest situations.
  
  

7. Compliance with DOE Interim COI Policy
This policy is designed to comply with the DOE Interim COI Policy. In case of any conflict between this policy or the CarbonCapture Conflict of Interest guidelines and DOE requirements, the DOE requirements will prevail.

8. Violations
Violations of this Conflict of Interest Policy may result in disciplinary action, up to and including termination of employment or engagement with CarbonCapture. All violations will be investigated promptly and fairly.

9. Policy Review
This policy will be reviewed annually and updated as necessary to ensure it remains in compliance with DOE requirements and addresses the needs of CarbonCapture.

10. Applicable Forms

• Conflict of Interest Disclosure Form
  
  

CARBONCAPTURE, INC.
1242 PALMETTO ST., LOS ANGELES, CA 90013

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