Conflict of Interest and Financial Conflict of Interest Policy

Effective date: 25 September 2026; as amended by Amendment No. 1, effective 26 September 2026

Approved by: Alex Balmaseda, sole member, Founder & CEO, BTC Media Labs LLC

Applies to: everyone who works for or on behalf of BTC Media Labs LLC, across all its products and programs: EverHeard, Myth MacroMKR, ResumeCraft_AI, any future product, and any program the company runs. That means the owner, employees, contractors, and anyone named as senior/key personnel or an Investigator on a funded project.

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1. Purpose

BTC Media Labs builds human-first technology: products people rely on, built with care for their privacy and dignity. That work, and any public or donated funds that support it, only deserves trust if personal financial interests never shape decisions about products, research or money. EverHeard, our accessibility app for people who are Deaf or hard of hearing, is one example of why this matters. People act on what it tells them.

This policy puts Code §2 into practice. It sets out:

• Part A: one ethics and conflict-of-interest standard for the whole company;
• Part B: related parties, meaning the sibling company, family, and our own products;
• Part C: the extra requirements when we apply for or receive federal funding, from PHS (NIH, ACL/NIDILRR) under 42 CFR Part 50, Subpart F, from NSF under its PAPPG, Chapter IX.A, and under the federal award rules in 2 CFR Part 200 (as adopted for HHS in 2 CFR Part 300).

One rule, the stricter one. Where federal sponsors set different thresholds or timelines, BTC Media Labs applies the stricter one across the company. For example, it uses PHS’s $5,000 significant-financial-interest threshold rather than NSF’s $10,000.

Part A: Company-wide standard

2. Commitments

Everyone covered by this policy will:

1. Put the mission and the people we serve first. Personal gain never shapes a product, research or funding decision.
2. Never offer, give, request or accept a bribe, kickback, or anything of value meant to influence a decision, anywhere in the world (Code §3; the U.S. Foreign Corrupt Practices Act applies).
3. Gifts and hospitality follow Code §3 (and its detailed policy, when adopted):
   • nothing of value to a government official involved in any decision about us;
   • otherwise only modest, customary and infrequent gifts, under $50 and never cash or cash equivalents, disclosed on request;
   • nothing accepted from anyone while a decision involving them is open.
4. Disclose any relationship that could look like a conflict before taking part in a related decision, and step back from that decision where appropriate. Examples: a family member at a partner organization, a role on a funding board, or a financial stake in a supplier.
5. Disclose outside activities before they begin when they touch the company’s work, including board roles, advisory work, investments and other employment (Code §2).
6. Keep partners’ roles separate from funding decisions. If a collaborator also serves on a body that awards funds we apply for, we disclose the collaboration and never ask them to influence that decision.
7. Protect confidential information and people’s data. This covers funders’, partners’, reviewers’, clients’, customers’ and users’ information, whatever a product’s design (company ethos principle 3; Code §6):
   • Keep nothing beyond what people asked us to keep. A product that works on the person’s own device keeps their data there. For example, EverHeard processes speech on the device and does not send audio or conversations to us. A product that stores data by design, such as ResumeCraft_AI keeping a person’s career record at their request, stores only what they asked it to keep.
   • People can export and delete their data at any time.
   • Never sold, and never used to train AI models.
   • Any third party that processes data for a product is named, with its terms stated. We do not make promises on its behalf.
   • Information is used only for the purpose it was given, and shared inside the company only with those who need it.
8. No product is paid by those who benefit from its users’ decisions (Code §2). No product accepts payment, referral fees, placement fees or preferential arrangements from anyone who benefits from what its users decide, and nothing of that kind ever changes what a product recommends. Any such relationship that might arise is disclosed before it begins, and handled as a conflict under this policy.

3. How to disclose

Disclose in writing (email is fine) to the Designated Official (Section 9). Alex’s own disclosures go to the Independent Reviewer (Section 9). Disclosures are kept according to the retention schedule in Code Appendix 1.

Part B: Related parties and our own products

4. Business Transformation Consulting LLC (the sibling company)

Business Transformation Consulting LLC (“BT Consulting”) is owned 100% by Alex Balmaseda. The IP of shipped products passed through it, and it shares some systems with BTC Media Labs, such as the Workspace and cloud organization. It is therefore a related party. BT Consulting adopts the same Code of Business Conduct with its own annex, and treats BTC Media Labs as a related party in the same way; this section is the BTC Media Labs side of that mirrored arrangement. Any money, service, license, IP transfer, shared cost or use of assets between BTC Media Labs and BT Consulting:

• is disclosed in writing and recorded;
• is set out in a written agreement at fair market value or below;
• is approved by the Independent Reviewer whenever grant, contract, charitable or client funds are involved, directly or indirectly.

Grant or charitable funds never pay BT Consulting without all three. Shared systems are documented so that costs charged to an award can be separated.

5. Family members

Any role a family member of a covered person plays in company accounts, products or programs is recorded in the disclosure file. That includes spouses, domestic partners, dependent children, and any relative with a company account or role. Any payment to a family member is a related-party transaction under Section 4.

6. Company income and accounts

All income from any BTC Media Labs product goes to company accounts only (Code §8). That includes sales, subscriptions, tips and “support” contributions. Product-income links (for example the PayPal or Ko-fi links for Myth MacroMKR, or the EverHeard support page) must pay into a BTC Media Labs LLC account, and public pages say plainly that the recipient is BTC Media Labs LLC and that payments are not tax-deductible donations. Company and personal money are never mixed.

7. Research on our own products (institutional conflict)

When BTC Media Labs does or funds research that evaluates one of its own products, the company has an institutional interest in a favorable result. To make sure that interest never shapes the findings:

1. Disclose the ownership to every partner institution, its conflict-of-interest office, and any IRB reviewing the study.
2. Define outcomes before the study starts, including what would count as the product not working.
3. Use independent analysis or validation where feasible. Examples: a university partner, or validation with Deaf and hard-of-hearing community partners for EverHeard.
4. Publish or report negative and null results, not just favorable ones.
5. Never present product marketing as research findings.

Part C: Federally funded research

8. Definitions

• Senior/key personnel, Investigator: the PD/PI and anyone responsible for the design, conduct or reporting of the funded research, including subrecipients and collaborators, as each sponsor defines them.
• Significant Financial Interest (SFI): follows 42 CFR 50.603 and applies company-wide. It covers the financial interests of the covered person, their spouse and dependent children that relate to their company responsibilities:
  • Publicly traded entity: remuneration plus equity together exceeding $5,000 in the prior 12 months.
  • Non-publicly traded entity: remuneration exceeding $5,000, or any equity.
  • Intellectual property: income from IP rights not paid by BTC Media Labs.
  • Travel: reimbursed or sponsored travel related to company responsibilities, except as the regulation excludes.
• Ownership of BTC Media Labs itself:
  • NSF expressly excludes “any ownership interests in the organization, if the organization is an applicant under the SBIR or STTR” (PAPPG IX.A).
  • PHS: whether an Investigator’s equity in the applicant small business is an SFI is to be confirmed with NIH before any application that PHS FCOI rules cover.
  • Either way, ownership is always disclosed in applications and to partners (Section 7).
• Conflict of interest: an SFI that the reviewer decides could directly and significantly affect the design, conduct or reporting of the funded research.

9. Designated Official and Independent Reviewer

• Designated Official: Alex Balmaseda, Founder & CEO. Receives disclosures from everyone except himself, decides on conflicts, and oversees management plans.
• Independent Reviewer: a qualified professional accountant from the company’s accounting service provider, or another qualified independent person. No particular firm is required, and no standing retainer. The reviewer is engaged when a review is needed, and paid for that task. The reviewer must have no financial interest in BTC Media Labs or BT Consulting, and their name and the date of engagement are recorded in the disclosure file (not published). The Independent Reviewer:
  • reviews all of Alex’s disclosures, under Part A, Part B and Part C;
  • approves the related-party transactions described in Section 4;
  • approves and monitors any management plan that concerns Alex;
  • has authority to report a concern directly to the funding agency;
  • must agree in writing to any waiver of this policy for Alex (Code §15).
• The Independent Reviewer is engaged in writing before the company submits its first federal proposal (disclosures must be reviewed by then), and in any case before any federally funded work begins.

10. Obligations of senior/key personnel

1. Being informed. The company informs each Investigator of this policy, of their disclosure responsibilities, and of 42 CFR Part 50 Subpart F, before they take part in PHS-funded research (42 CFR 50.604(b)).
2. Training.
   • FCOI training: before starting PHS-funded research, and at least every 4 years, or sooner if this policy changes, a new person joins, or someone is found not to comply.
   • Research security training: within the 12 months before any NSF proposal is submitted. Certified by each senior/key person and by the organization’s authorized representative (NSF PAPPG II, effective December 2, 2025), and repeated as sponsors require.
3. Certify and disclose. Certify in writing, on joining and every year, that you have read the Code and this policy and disclosed any conflicts (Code §15). In addition, disclose SFIs:
   • by the time an application or proposal is submitted;
   • at least once a year during an award;
   • within 30 days of acquiring or discovering a new SFI.
4. Foreign relationships and research security.
   • Truthfully complete every sponsor disclosure about foreign affiliations, appointments, support and relationships. For SBIR/STTR proposals that includes the disclosures required by 15 U.S.C. 638(g)(13), such as ownership by, or relationships with, foreign countries of concern and foreign talent recruitment programs.
   • Never take part in a malign foreign talent recruitment program. Each senior/key person certifies this before submission and every year during an award.
5. Current and pending (other) support. Disclose all current and pending support as each sponsor requires. That includes in-kind contributions: for NSF, any in-kind resource worth $5,000 or more that requires a commitment of the person’s time. Free compute or cloud credits (for example GPU grants or startup-program credits) are assessed against this test and disclosed when they meet it.
6. Follow any management plan.

11. Review, management and reporting

1. Before any award funds are spent, and within 60 days of any new disclosure during an award, the Designated Official decides whether a disclosure is a conflict (or the Independent Reviewer does, for Alex’s disclosures).
2. Management plans are written and may include public disclosure, independent monitoring, changing a role, or divestment. Research proceeds only under the plan, and the Designated Official (or the Independent Reviewer, for Alex) monitors compliance with each plan until the project is completed (42 CFR 50.604(g), 50.605(a)(4)).
3. Interests not disclosed or reviewed on time. When the company identifies a significant financial interest that was not disclosed on time, or not previously reviewed, it reviews it, determines whether it is a conflict, and puts an interim management plan in place within 60 days (42 CFR 50.605(a)(3)).
4. Reporting to sponsors.
   • PHS: report each identified FCOI before spending funds, within 60 days of a new one, and every year, as 42 CFR 50.605 requires. If an FCOI was missed, complete a retrospective review within 120 days and, where required, a mitigation report.
   • NSF: tell NSF’s Office of the General Counsel if the company cannot satisfactorily manage a conflict of interest (PAPPG IX.A).
   • Any federal award: disclose in writing any potential conflict of interest to the awarding agency, as its policies require (2 CFR 200.112).
5. Mandatory disclosure. Report promptly and in writing to the awarding agency and its Office of Inspector General any credible evidence of federal criminal fraud, conflict-of-interest, bribery or gratuity violations, or a civil False Claims Act violation, connected with an award (2 CFR 200.113).
6. Public accessibility.
   • This policy is posted on the company website.
   • For PHS-funded projects, before any funds are spent, information about FCOIs of senior/key personnel is made available by written response within five business days of a request, or on the website (42 CFR 50.605(a)(5)). It includes the minimum elements the regulation lists, states the date it is current as of, is updated at least annually and within 60 days of a newly identified FCOI, and remains available for at least three years from its most recent update.
   • FCOI and significant-financial-interest information, including the company’s reviews and determinations, is made available to HHS promptly on request.
7. Subrecipients and contractors.
   • Subrecipients (for example a university partner on an STTR) are bound by a written agreement that states whether the subrecipient follows its own FCOI policy or this one (42 CFR 50.604(c)). If it follows its own, the company obtains the subrecipient’s certification that its policy complies with the regulation, and the agreement requires it to report identified FCOIs in time for the company to report them to NIH. If it follows this one, the agreement requires its Investigators to disclose to the company so the company can identify, manage and report them.
   • Before any contractor or subrecipient is paid with award funds, check SAM.gov for exclusions.
8. Lobbying. No federal award funds are used for lobbying. For awards over $100,000, the company files the lobbying certification required by 31 U.S.C. 1352.

11A. Government research grants and the company’s other funding

Government research grants are awarded to BTC Media Labs LLC for research the company performs; under an STTR, the research institution does its share. Therefore:

1. Grant money pays the approved research scope only. It never pays for work funded from any other source, such as product operations, other grants or charitable funds. No cost is charged to more than one funder.
2. Time is tracked as it happens. Everyone’s time is recorded as the work is done, split across grant research and other work, so every hour charged to a grant can be shown to be grant work.
3. Results belong to the company, under the data and intellectual-property rights SBIR/STTR gives awardees.
4. Related programs and support are disclosed. Every grant application discloses any program or organization related to the company whose work connects to the research, and lists any support it provides as current and pending support.

11B. Clinical research

If HHS determines that PHS-funded clinical research whose purpose is to evaluate the safety or effectiveness of a drug, medical device or treatment was designed, conducted or reported by an Investigator with an FCOI that was not managed or reported as required, the company requires that Investigator to disclose the FCOI in each public presentation of the results and to request an addendum to previously published presentations (42 CFR 50.606(c)). BTC Media Labs’ products are accessibility tools, not medical devices, but this requirement is part of the policy in case any funded research falls within it.

12. Whistleblower protection

Employees and contractors of federal awardees are protected from reprisal for reporting gross mismanagement, gross waste of federal funds, abuse of authority, a substantial and specific danger to public health or safety, or a violation of law related to a federal award (41 U.S.C. 4712). BTC Media Labs informs every employee in writing of these rights, and never retaliates against anyone who raises a concern in good faith.

13. Enforcement

Failing to follow this policy can lead to corrective action. That may include removal from a project, ending a contract, and reporting to the sponsor as its rules require. If noncompliance biased the design, conduct or reporting of federally funded research, the company notifies the sponsor and takes the corrective steps it requires.

14. Questions and review

The owner is responsible for this policy (Code §15). Send questions to alex@btcmedialabs.com. This policy is reviewed at least once a year, and whenever regulations or the company’s structure change.

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Governing law and jurisdiction

BTC Media Labs LLC is a New York limited liability company. This policy is written to meet, and is interpreted under:

• the U.S. federal regulations it cites, which govern any federally funded work; and
• the laws of the State of New York, including New York’s whistleblower protections (NY Labor Law §740), which apply once the company has employees or contractors.

Where federal rules, New York law and this policy differ, the strictest applicable requirement governs. The policy was adopted by written consent of the sole member (NY LLC Law §407), before attorney review, as the owner decided on 2026-09-25. Counsel reviews it as soon as practical, and it is amended if counsel advises. (NY citations to be confirmed by counsel.)

Appendix A: Records retention

Records under this policy are kept under the single retention schedule in Appendix 1 of the Code of Business Conduct, which covers the Code and every policy beneath it. Where more than one period applies, the longest one is used.

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Parent: BTC Media Labs Code of Business Conduct (§2, §3, §4, §8, §14, §15). References (checked against source text 2026-09-25; NIH FCOI Policy Development Checklist rev. 4/21/2020 applied 2026-09-26): 42 CFR Part 50 Subpart F (incl. 50.602–50.606); NSF PAPPG 24-1 Ch. IX.A and Ch. II (Supplements 1–2); 15 U.S.C. 638(g)(13); 2 CFR 200.101, 200.112, 200.113; 2 CFR Part 300; 41 U.S.C. 4712; 31 U.S.C. 1352.