HIGHGIFT AI CORPORATION RESEARCH COMPLIANCE, SECURITY & FUNDING POLICIES
HIGHGIFT AI CORPORATION RESEARCH COMPLIANCE & SECURITY POLICY
1.1 PURPOSE
Highgift AI Corporation is committed to upholding the highest standards of research integrity, security, and compliance with U.S. federal regulations. This policy establishes guidelines for employees, subcontractors, and research partners to ensure compliance with conflict of interest (COI), conflict of commitment (COC), and foreign influence disclosure requirements. Compliance with these policies is a condition of employment, contract award, or research collaboration.
1.2 APPLICABILITY
This policy applies to all employees, officers, directors, contractors, and subcontractors engaged in research and development activities under Highgift AI Corporation, including those collaborating with universities, government agencies, private entities, or non-governmental grant-making organizations.
1.3 CONFLICT OF INTEREST (COI) & CONFLICT OF COMMITMENT (COC) REQUIREMENTS
1.3.1 Employees, directors, and subcontractors must disclose any financial interests, external commitments, or affiliations that could present a conflict with their work at Highgift AI Corporation.
1.3.2 Disclosures must include, but are not limited to, any:
- External employment, consulting agreements, or advisory roles.
- Ownership or equity interest in companies or research entities.
- Direct or indirect financial relationships with foreign or domestic entities.
- Roles in non-profit organizations or academic institutions conducting similar research.
- Any situation where an individual’s external obligations may interfere with their duties at Highgift AI Corporation.
1.3.3 All disclosures must be submitted in accordance with Highgift AI Corporation’s compliance reporting process, which begines with an email to the Highgift AI Corporation's current CEO, and ends with return confirmation from the CEO that the disclosure processs has been completed, and that the individual is cleared, before engaging in any work, or billable hours are spent on federally funded or investor-supported research.
1.3.4 Annual updates to these COI/COC disclosures are required to be submitted proactively by each individual, along with immediate updates when a material change occurs.
1.3.5 Failure to formally disclose conflicts of interest or conflicts of commitment may result in disciplinary action, including but not limited to forfiture of unvested shares of Company stock, termination of employment or contract.
1.4 FOREIGN INFLUENCE & MALIGN FOREIGN TALENT RECRUITMENT PROGRAMS (MFTRP)
1.4.1 In compliance with Section 10632 of the CHIPS and Science Act of 2022 and relevant DoD, NSF, NIH, and DOE regulations, participation in any Malign Foreign Talent Recruitment Program (MFTRP) is strictly prohibited.
1.4.2 Employees, directors, and subcontractors must report all foreign funding, foreign research collaborations, honorary appointments, or any agreement that involves the transfer of knowledge, data, or intellectual property to a foreign entity.
1.4.3 Highgift AI Corporation reserves the right to review, restrict, or terminate engagements with foreign entities that pose a security risk or conflict with U.S. federal research security policies and/or are not in keeping with standards that meet or exceed best-practice investment guidelines.
1.4.4 The acceptance of undisclosed or unapproved foreign funding is a violation of U.S. federal law and may lead to civil and criminal penalties.
1.5 DISCLOSURE & REPORTING PROCESS
1.5.1 All required disclosures must be submitted via Highgift AI Corporation’s compliance process, or portal provided for such use, before participating in externally funded research.
1.5.2 Employees, directors, and subcontractors must update disclosures within 30 days of any change in financial interests, external commitments, or foreign engagements that are or may be reasonably understood to be a violation of Company Research Compliance and Security or US Government research funding or contract award Policies.
1.5.3 The compliance team, is led by the Company's CEO, and will review all disclosures and determine if additional action, conflict management plans, or recusal from projects is necessary.
1.5.4 Certain high-risk engagements may require fully executed formal approval from the CEO or the Company's Research Compliance Office before proceeding.
1.6 INTELLECTUAL PROPERTY (IP) & DATA SECURITY
1.6.1 Employees and subcontractors must adhere to Highgift AI Corporation’s policies on intellectual property (IP) protection and cybersecurity best practices. Where such policies are not formally agreed to by any employees or sub-contractors, they shall, nevertheless, be bound by the policies represented on this page, to the fullest extent enforcable by federal, state or local law. Any individual receiving a copy of this text, or a PDF version of it, and acknolwedges agreement to be bound by these policies.
1.6.2 Unauthorized disclosure, transmission, or commercialization of company-owned or federally funded research data or property which is identified as "Condidential," or which may reasonably be infered to be confidential, to unauthorized entities is prohibited.
1.6.3 Any suspected breach of data security or unauthorized transfer of intellectual property must be reported to the Chief Compliance Officer immediately.
1.7 TRAINING & AWARENESS
1.7.1 All employees and subcontractors must complete mandatory training on:
- Research security and federal compliance requirements.
- COI/COC disclosure and foreign influence risks.
- Highgift AI Corporation’s proprietary research and data protection policies.
- Federal funding agency-specific guidelines, where applicable.
1.7.2 Training materials and certification records will be maintained by the compliance department.
1.8 ENFORCEMENT & PENALTIES
1.8.1 Non-compliance with this policy may result in disciplinary action, including but not limited to:
- Termination of employment or contract.
- Legal action, including referral to federal authorities for violations of U.S. research security laws.
- Loss of eligibility to participate in federally funded or investor-backed research projects.
1.8.2 In addition to other consequences, employees and subcontractors found to have knowingly concealed foreign affiliations or financial relationships in violation of U.S. law may be subject to civil and criminal penalties under U.S. law.
1.9 REPORTING VIOLATIONS & WHISTLEBLOWER PROTECTION
1.9.1 Employees, directors, and subcontractors are encouraged to report any suspected violations of this policy.
1.9.2 Reports can be made confidentially through the Highgift AI Corporation Compliance Hotline at [insert email or phone number].
1.9.3 Retaliation against individuals who report compliance concerns in good faith is strictly prohibited.
1.10 CONTACT INFORMATION
1.10.1 For questions, disclosures, or compliance assistance, contact the Research Compliance Office via email or LinkedIn Private Message (PM) to the Chief Executive Officer of the Company. If you are without access to these CEO contact details, the CEO can be reached by Certified US mail to the Company's Registered Agent for the State of Delaware. The Company's Registered Agent for Delaware can be found via the Delaware Secretary of State's website.
1.10.2 Anonymous reporting of compliance concerns is available by addressing correspondence to the Company's Registered Agent for Delaware and clearly marking the outside of the envelope with the word, "Anonymous" written or printed on it.
2. HIGHGIFT AI CORPORATION ETHICAL RESEARCH & FUNDING COMPLIANCE
2.1 TRANSPARENCY IN FUNDING SOURCES
2.1.1 Highgift AI Corporation publicly discloses its primary sources of research funding and maintains records of all grants, contracts, and subcontracts.
2.2 CODE OF ETHICS IN RESEARCH
2.2.1 All research conducted under Highgift AI Corporation must adhere to the highest ethical standards, including integrity in data reporting, compliance with human and animal research protections, and prohibition of research misconduct (fabrication, falsification, or plagiarism).
2.3 INVESTOR & PARTNER DUE DILIGENCE
2.3.1 Highgift AI Corporation conducts due diligence on potential investors, partners, and funding sources to ensure alignment with U.S. national security interests and ethical research practices.
2.4 CERTIFICATION OF COMPLIANCE
2.4.1 Employees and subcontractors working on federally funded or investor-backed research projects must certify annually that they have reviewed and comply with Highgift AI Corporation’s policies on research integrity and security.