Planted Solar

Article I – Purpose

The purpose of this policy is to protect the interests of Planted Solar and any governmental or non-governmental agency providing funding to Planted Solar by: (a) preventing the personal interest of Investigators and/or Designated Official(s) from interfering with their duties to the organization and (b) avoiding any unethical financial, professional, or political gain on the part of such individuals. The intent of this policy is to maintain the highest ethical standards and promote transparency and supplement, not replace, any applicable federal, state, or local regulations regarding conflicts of interest.

Article II – Definitions

Designated Official means any Planted Solar manager(s) assigned to administer this policy.

Financial Conflict of Interest (FCOI) means a situation in which an Investigator or the Investigator’s spouse or dependent children has a significant financial interest or financial relationship that could directly and significantly affect the design, conduct, reporting or funding of a project.

Financial Interest means anything of monetary value, whether the value is readily ascertainable or not.

Investigator means the principal Investigator (PI) and any other person, regardless of title or position, who is responsible for the purpose, design, conduct, or reporting of a project funded by a governmental agency or proposed for funding by a governmental agency.

Organizational Conflict of Interest means a situation where because of relationships with a parent company, affiliate, or subsidiary organization, the non-Federal entity is unable or appears to be unable to be impartial in conducting a procurement action involving a related organization. Because Planted Solar only has a single legal entity with no affiliates, Organizational conflicts of interest are not addressed in this policy but will be revisited if other legal entities are added at a future date.

Potential conflict of interest exists when an impartial observer reasonably believes that actual or apparent past, present, or currently planned interests could constitute a conflict of interest.

Project means the interdependent activities funded wholly or in part under a financial assistance award. A project has a defined start and end point with objectives described in an application or in an approved scope that, when attained, signify completion and achievement of a specific goal, and creation of a unique product, service, or result. For awards that include recipient cost share as part of the approved budget, activities funded with that recipient cost share are included.

Related Entity means a vendor, customer, collaborator, or competitor of Planted Solar’s related to the project and whose interests may be significantly impacted by the research.

Significant financial interest means:

(1) A financial interest consisting of one or more of the following interests of the Investigator (and those of the Investigator's spouse and dependent children) that reasonably appears to be related to the Investigator's responsibilities:

(i) With regard to any foreign or domestic publicly traded entity, a significant financial interest exists if the value of any remuneration received from the entity in the twelve months preceding the disclosure and the value of any equity interest in the entity as of the date of disclosure, when aggregated, exceeds $5,000. For purposes of this definition, remuneration includes salary and any payment for services not otherwise identified as salary (e.g., consulting fees, honoraria, paid authorship); equity interest includes any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value;

(ii) With regard to any foreign or domestic non-publicly traded entity, a significant financial interest exists if the value of any remuneration, not otherwise disclosed as current, pending, or other support, received from the entity in the twelve months preceding the disclosure, when aggregated, exceeds $5,000, or when the Investigator (or the Investigator's spouse or dependent children) holds any equity interest (e.g., stock, stock option, or other ownership interest);

(iii) Intellectual property rights and interests (e.g., patents, copyrights), upon receipt of income related to such rights and interests.

(2) Investigators also must disclose the occurrence of any reimbursed or sponsored travel (i.e., that which is paid on behalf of the Investigator and not reimbursed to the Investigator so that the exact monetary value may not be readily available) related to their institutional responsibilities that is not otherwise disclosed in current and pending or other support disclosures, provided that this disclosure requirement does not apply to travel that is reimbursed or sponsored by a Federal, state, or local government agency of the United States; a domestic Institution of Higher Education; or a domestic research institute that is affiliated with a domestic Institution of Higher Education.

(3) The term significant financial interest does not include the following types of financial interests: salary, royalties, or other remuneration paid by Planted Solar to the Investigator if the Investigator is currently employed or otherwise appointed by Planted Solar, including  intellectual property rights assigned to Planted Solar and agreements to share in royalties related to such rights; any ownership interest in Planted Solar held by the Investigator; income from investment vehicles, such as mutual funds and retirement accounts, as long as the Investigator does not directly control the investment decisions made in these vehicles; income from seminars, lectures, or teaching engagements sponsored by a Federal, state, or local government agency of the United States, a domestic Institution of Higher Education, or a domestic research institute that is affiliated with a domestic Institution of Higher Education; or income from service on advisory committees or review panels for a Federal, state, or local government agency of the United States, a domestic Institution of Higher Education, or a domestic research institute that is affiliated with a domestic Institution of Higher Education.

Article III – Procedures

1. Duty to Disclose

Each Investigator is under an obligation to disclose the existence or potential existence of a conflict of interest as it arises. Any individual who becomes aware of an actual or potential conflict of interest should promptly disclose it to the Planted Solar CEO (or if the CEO is disclosing the conflict, to the Head of Finance and Administration). The disclosure should be made in writing within 30 days of becoming aware of the conflict ensuring it includes all relevant details and supporting information. Individuals who make good-faith disclosures of conflicts of interest will be protected against retaliation or adverse consequences as a result of their disclosure. Failure to disclose a conflict of interest, or knowingly providing false or incomplete information, is a serious violation of company policy and may result in disciplinary action, including removal from the position at the organization, termination of employment, or legal proceedings, as appropriate.

Every Investigator must submit a signed Financial Disclosure Report (as shown in Appendix A) no later than 30 days after joining the project. These reports are to be updated annually, or within 30 days of a change, whichever comes earlier.

2. Investigating Conflicts

When a potential conflict of interest is noted, the Planted Solar CEO (or Head of Finance & Administration) will review and assess the disclosed conflict and determine the appropriate course of action. This may involve gathering additional information, interviewing relevant parties, and conducting a thorough examination of the circumstances. Factors considered may include the nature and extent of the conflict, the potential impact on the organization, and applicable laws and regulations. If it turns out that a conflict does not exist, the inquiry will be documented but no further action will be taken. The Planted Solar CEO (or Head of Finance & Administration) shall maintain a record of all disclosed conflicts of financial interest, including the actions taken to manage or resolve the conflicts.

3. Addressing a Conflict of Interest

All conflicts of interest will be reviewed on a case-by-case basis. If the Planted Solar CEO (or Head of Finance & Administration) determines that a conflict of interest exists, they will take the appropriate actions to address the conflict. Actions may include, but are not limited to, recusal from decision-making processes, reassignment of responsibilities, divestment of conflicting interests, seeking independent advice, or terminating employment with Planted Solar.

The affected parties, including relevant stakeholders within and outside the organization, will be notified of the conflict and the actions taken to address it.

If the conflict of interest in question involves a member of the Board, that individual will be excused from deliberations.If an Investigator’s failure to comply with Planted Solar's conflict of interest policy appears to have biased the purpose, design, conduct, or reporting of a project funded under an agency-funded award, Planted Solar shall promptly notify the relevant agency of the failure to comply and the corrective action taken or to be taken. In the event of an unmanaged or unmanageable financial conflict of interest, Planted Solar will submit a Financial conflict of interest (FCOI) report to the relevant agency before expending any funds under the project. Planted Solar shall cooperate with any inquiries made by the funding agency regarding the disclosure and our company's review and response to such disclosure.