Last Updated: December 9, 2024
1. INTRODUCTION
Aegis DAO Foundation (“Foundation,” “we,” “our,” or “us”), a Cayman Islands foundation company, maintains zero tolerance for bribery and corruption. This Policy establishes standards for ensuring ethical conduct in the execution of DAO decisions and protection of DAO assets.
2. SCOPE AND APPLICATION
This Policy applies to:
- Foundation Directors
- Foundation Supervisor Council
- Service providers
- Representatives and agents
3. DEFINITIONS
3.1 Bribery
Offering, promising, giving, accepting, or soliciting an advantage as an inducement for action which is illegal, unethical, or a breach of trust.
3.2 Corruption
The abuse of entrusted power for private gain.
4. FOUNDATION’S ROLE
4.1 Core Functions
The Foundation:
- Executes DAO decisions
- Protects DAO assets
- Manages institutional relationships
- Implements governance decisions
4.2 Operational Boundaries
The Foundation:
- Does not interact with users directly
- Acts only on DAO mandate
- Operates through regulated entities
- Maintains strict controls
5. PROHIBITED CONDUCT
5.1 General Prohibitions
- Offering or accepting bribes
- Facilitation payments
- Kickbacks
- Improper advantages
5.2 Specific Restrictions
- Unauthorized payments
- Undocumented transactions
- Political contributions
- Charitable donations without approval
6. RISK AREAS
6.1 High-Risk Activities
- Custodian relationships
- Exchange partnerships
- Service provider engagement
- Regulatory interactions
6.2 Risk Mitigation
- Due diligence procedures
- Approval processes
- Documentation requirements
- Regular monitoring
7. DUE DILIGENCE
7.1 Third Party Due Diligence
Required for:
- Service providers
- Business partners
- Consultants
- Intermediaries
7.2 Assessment Criteria
- Reputation check
- Ownership structure
- Conflict checks
- Compliance history
8. RECORDKEEPING
8.1 Documentation Requirements
Maintain records of:
- All transactions
- Due diligence
- Approvals
- Decision documentation
8.2 Record Retention
- Minimum 5 years
- Secure storage
- Accessibility for audit
- Proper indexing
9. REPORTING PROCEDURES
9.1 Internal Reporting
Report concerns to:
- Foundation Supervisor Council
- Compliance Officer
- Legal Department
9.2 Investigation Process
- Initial assessment
- Evidence collection
- Investigation
- Corrective action
10. TRAINING AND AWARENESS
10.1 Training Requirements
Regular training on:
- Policy requirements
- Red flags
- Reporting procedures
- Best practices
10.2 Documentation
- Training records
- Acknowledgments
- Assessments
- Updates
11. MONITORING AND REVIEW
11.1 Regular Monitoring
- Transaction review
- Relationship assessment
- Compliance checks
- Risk evaluation
11.2 Policy Review
- Annual review
- Risk assessment
- Control evaluation
- Update implementation
12. CONSEQUENCES OF VIOLATION
12.1 Internal Consequences
- Disciplinary action
- Contract termination
- Legal action
- Reporting to authorities
12.2 External Impact
- Regulatory penalties
- Reputational damage
- Legal liability
- Financial loss
13. GOVERNING LAW
This Policy is governed by the laws of the Cayman Islands.