Version Control
| Version | Date | Description of Change / Action | Notes / Feedback Cycle Duration |
|---|---|---|---|
| v0.1 (Initial Draft) | June 25, 2025 | Draft version prepared and circulated internally for preliminary review. | Baseline document to kick off the discussion in the HoS telegram group |
| v0.2 (Forum Post) | July 1, 2025 | The policy draft was formally posted to the governance forum for community review and feedback. | Beginning of the public feedback period. |
| v0.3 (Public Feedback collected) | Aug 30, 2025 | End of the feedback cycle: document closed to reflect stakeholder input. | Total feedback cycle: 60 days. |
- All iterations are maintained for transparency and auditability.
- The feedback cycle duration, counted from the initial forum posting (July 1) to the final revision date (August 30), totaled 60 days.
- Subsequent updates will be logged with version increments (v1.0, v1.1, etc.) as ratified by the House Of Stake governance system.
Feedback Analysis
The document has been in the public domain for over 60 days. It collected over 93 text edits, nearly 30 comments, and formed the feedback input for this final draft. To ensure that such stakeholder concerns are not missed, I manually copied every single comment, transcribed them into a separate database of questions. Then I clustered these questions based on topical similarity and filtered them according to the scope limitations of the current COI policy. To ensure the focus remains on the core function of a COI policy, I filtered out the questions that were primarily related to behavioral norms, community participation, and dispute resolution (as these issues fall within the Code of Conduct’s purview).
Filter:
| Scope | Clusters | Rationale |
|---|---|---|
| Within COI Policy Scope | Reporting & Disclosure Procedures, Transparency & Information Access, Assessment & Enforcement Mechanisms, Independence & Third-party Oversight, Policy Review & Amendment | These clusters address the formal processes and enforcement mechanisms that are fundamental for managing COIs. |
| Within the scope of the Code of Conduct Policy | Recusal, Challenges & Community Role | These concern ethical behavior, participatory fairness, and disputes—issues best addressed in the CoC. |
This filtering process resulted in a cluster of the following 6 key themes that are resolved in this final policy draft
| Clusters | Number of questions | Representative Question |
|---|---|---|
| Reporting & Disclosure Procedures | 10 | What is the process of reporting COI incidents for endorsed delegates? What is the expected Code of Conduct? |
| Transparency & Information Access | 6 | What COI filings, assessments, and enforcement records should be public? What about disclosures with privileged information? |
| Recusal, Challenges & Community Role | 5 | Can community members challenge or comment on recusal decisions made by Delegates? |
| Assessment & Enforcement Mechanisms | 7 | What is the process of COI assessments by the screening committee? What are the expectations? |
| Independence & Third-party Oversight | 5 | Should a third-party resolution mechanism be used if Screening Committee/Security Council members have a perceived COI? |
| Policy Review & Amendment | 3 | How is this policy reviewed and amended? |
Policy Reforms
Addressing feedback and input received from the community, please find below the policy reforms (and feedback that triggered such reforms)
Cluster 1: Reporting & Disclosure Procedures
Feedback:
- What is the process for reporting COI incidents by Delegates?
- Who must file disclosures and when?
- Should disclosures be required before assuming office?
- Should community members be able to report on potential COIs?
- What should the disclosure template include?
Policy Reforms:
Mandatory Initial & Ongoing Disclosures: All Delegates (endorsed/non-endorsed), Screening & Security Council members must file (i) prior to assuming office and (ii) update quarterly or upon material changes.
Community Reporting: Allow community members to submit concerns via an official channel with whistleblower protections.
Standard Template: All COI disclosures must follow a governance-approved template capturing:
- Nature of the interest (financial, personal, professional).
- Related party or organization.
- Type of decision/governance area potentially affected.
- Relevant roles of the individual.
Cluster 2: Transparency & Information Access
Feedback:
- What portion of COI filings and records should be public?
- Can privileged information be withheld?
- Should all COI-related actions be published in governance forums?
Policy Reforms:
Public Conflict Registry: Create a governance portal where all COI disclosures, recusals, and enforcement decisions are logged.
Redaction Rule: Sensitive information (e.g., personal identifiers, legally privileged details) may be redacted, but each entry must state:
- That a conflict occurred,
- General category of conflict,
- Governance area affected, and
- Resolution (disclosure, recusal, sanction).
Regular Transparency Reports: Publish quarterly summaries on the forum/registry outlining the number of disclosures, recusals, sanctions, and appeals.
Cluster 3: Assessment & Enforcement Mechanisms
Feedback:
- How should the Screening Committee review conflicts?
- What is the process from disclosure to outcome?
- What enforcement measures should exist, and what durations?
Policy Reforms:
Standardized Process: Screening Committee follows a 4-step timeline:
- Receive disclosure/report
- Conduct review & evidence gathering (14 days)
- Issue recommendation/outcome (No Conflict, Minor Conflict, Material Conflict, Severe Conflict)
- Document reasoning in governance log
Tiered Sanctions:
- Level 1: Warning – for late/incomplete disclosures.
- Level 2: Suspension (1–3 months) – for repeated failures/minor concealment.
- Level 3: Extended Suspension (up to 12 months) – for significant concealment or repeated breaches.
- Level 4: Removal – permanent loss of governance rights for severe/intentional misconduct.
Appeal Rights: Sanctioned individuals may appeal to the Security Council within 14 days. Council decision is final.
Cluster 4: Independence & Third-party Oversight
Feedback:
- What happens if the Screening Committee or the Security Council themselves are conflicted?
- Should an independent entity handle such cases?
- Who pays, and what authority do arbiters hold?
Policy Reforms:
- Third-party Trigger: If 40% or more of the Screening Committee or Security Council declare conflicts in a case, that case must be referred to an independent arbiter.
- Arbiter Pool: Maintain a pool of pre-approved auditors/governance experts.
- Arbiter Powers: An Independent arbiter may recommend/decide enforcement, issue a binding resolution, and publish a public summary (with redactions).
- Costs: All third-party arbitration funded via the Administrative Budget Wallet, capped per governance budget approvals.
Cluster 5: Policy Review & Amendment
Feedback:
- How often should the policy be reviewed?
- How should amendments be tracked and adopted?
Policy Reforms:
- Annual Review: Policy reviewed once per year, with mandatory consultation on the governance forum.
- Ad-hoc Reviews: May be triggered by major incidents, recommendations from Screening/Security Council, or community petitions with ≥5% tokenholder support.
- Version Control: All amendments must be logged in a transparent, version-controlled registry with rationale documented.
House Of Stake Foundation- Conflict of Interest Policy (v1.0 Draft)
Article 1: Purpose
This Conflict of Interest Policy is adopted to ensure the integrity, transparency, and legitimacy of decision-making within the House of Stake and the NEAR Protocol ecosystem. Its purpose is to identify, disclose, manage, and enforce measures related to personal, professional, and financial conflicts of interest, thereby upholding the community’s trust and ensuring that governance decisions always prioritize the protocol-first principle.
Article 2: Scope & Persons Concerned
This policy applies to all individuals empowered to participate in or influence decisions on behalf of the House of Stake, including:
- Delegates (endorsed and non-endorsed).
- Members of the Screening Committee.
- Members of the Security Council.
- HoS Foundation Directors and Supervisors (where relevant).
- Contractors, Service Providers, and Program managers engaged with HoS Foundation via the proposal process
- Community members who, by taking leadership roles, working group responsibilities, or proposal ownership, materially influence outcomes.
Article 3: Definitions
Conflict of Interest (COI): A situation where an individual’s personal, professional, or financial interests interfere with, or could be reasonably perceived to interfere with, their ability to act impartially and in the best interests of the House of Stake and NEAR ecosystem. Both actual conflicts and perceived conflicts are covered.
Interested Person: Any individual identified in Article 2 who has the ability, either directly or indirectly, to influence the decisions, discussions, or outcomes of the House of Stake governance process.
Article 4: Procedures for Managing Conflicts
4.1: Discovery
Conflicts may be identified in three ways:
- Self-disclosure by the Interested Person.
- Community reporting, filed through the official reporting portal with whistleblower protections.
- Review initiated by the Screening Committee or Security Council.
4.2: Assessment Matrix
| Conflict Status | No Perception of Conflict | Perception of Conflict Exists |
|---|---|---|
| No Conflict | Level 1: Participate freely | Level 2: Disclose publicly and consider voluntary recusal |
| Real Conflict | Level 3: Disclosure + mandatory recusal | Level 4: Full disclosure and complete abstention from related discussions, deliberations, and votes |
Explanation of Levels
| Level 1 (No Conflict) | Participation permitted without restrictions. |
|---|---|
| Level 2(Perceived Conflict) | Must disclose circumstances publicly; encouraged to step back if impartiality could be questioned. |
| Level 3 (Real Conflict) | Disclosure required. A person must recuse from leading the discussion or voting on the matter. Delegates/committees may appoint an alternate if needed. |
| Level 4 (Real + Perceived Conflict) | Full recusal required. Must disclose, abstain from voting, and physically (or virtually) remove themselves from deliberation spaces |
4.3: Disclosure Requirements
- Initial disclosure is required before assuming office.
- Quarterly disclosure updates are mandatory for all Interested Persons.
- Ad-hoc disclosures must be made within 14 days of any material change.
All disclosures must follow the respective standardized template, as defined in the Addendum, Section A: Disclosure Templates.
4.4: Recusal
- Any Interested Person with a Level 3 or Level 4 conflict must recuse themselves.
- Recusal requires leaving the room/meeting/discussion forum (physical or digital).
- Recusals will be captured in meeting records and governance logs.
4.5: Review Process
- The Screening Committee must review disclosures or reported conflicts within 14 days.
- Determination categories: No Conflict, Minor/Perceived Conflict, Material Conflict, Severe Conflict.
- If ≥40% of the Committee or Security Council are conflicted in the same case, referral to an Independent Arbiter is mandatory (see Article 5).
4.6: Ongoing Disclosures
All persons subject to this policy must reaffirm their COI disclosures quarterly, even if “No new conflicts” exist.
4.7: Investigations and Recourses
- The Screening Committee or the Security Council may interview involved parties, request evidence, and gather documentation.
- If misconduct is found, the matter is escalated for enforcement (Article 5).
- Cases may be referred to independent arbiters in high-conflict situations.
Article 5: Enforcement
Tiered Sanctions
| Tier 1 | Warning: For administrative lapses or late filing. |
|---|---|
| Tier 2 | Short Suspension (1–3 months): For repeated errors or non-disclosure of minor interests. |
| Tier 3 | Extended Suspension (3–12 months): For intentional concealment or repeated misconduct. |
| Tier 4 | Removal: Permanent removal of the Delegate/Committee role for severe or recurring violations |
Appeals:
Individuals may appeal enforcement decisions to the Security Council within 14 days. The Council’s decision is final and must be documented publicly.
Independent Oversight:
- If enforcement cannot be impartially managed internally, the matter must be referred to an Independent Arbiter.
- The Arbiter may review, recommend sanctions, and issue binding rulings.
- Costs shall be funded from the HoS Budget(caps subject to governance approval).
Article 6: Transparency
Conflict Registry:
- A public Conflict of Interest Registry will be maintained on the House of Stake portal.
- Every case (disclosure, recusal, enforcement action) must be logged.
Redaction Rule:
Sensitive data may be redacted, but each record must minimally display:
- That a conflict exists;
- Its category (financial/personal/professional) & Level
- Governance area affected.
- Resolution/action taken.
Public Reports:
Quarterly transparency reports summarizing disclosures, recusals, sanctions, and appeals shall be published.
Article 7: Review and Amendments
Annual Review: Formal review once per year, with community consultation.
Ad-hoc Reviews: May be triggered by:
- Major governance incidents.
- A petition by ≥5% of tokenholders.
- Recommendations from the Screening Committee or the Security Council.
Amendments:
Must be recorded in a version-controlled public log. Every change requires open publication of rationale and formal ratification by governance procedures.
Article 8: Declaration and Adoption
We, the members of House of Stake Governance, hereby adopt this Conflict of Interest Policy v1.0 on behalf of the governance community, affirming our commitment to uphold impartiality, transparency, and accountability in all actions and decisions affecting the NEAR Protocol ecosystem.
Signature and Adoption
Date of On‑Chain Vote: ______________________
On‑Chain Vote Link: _________________________
Outcome: Adopted / Rejected
Addendum
Section A: COI Disclosure Templates
All disclosures shall follow the standardized template format for consistency, comparability, and transparency.
- Initial Disclosure Template: T1 (to be filed before assuming office)
Purpose: Capture baseline interests before assuming governance responsibilities.
Template fields:
| Nature of Interest: | e.g., financial, personal, professional. |
|---|---|
| Party/Organization Involved: | Identify the related entity or individual. |
| Governance Area Impacted: | Specify proposal, working group, or committee decisions possibly affected. |
| Relevant Roles Held: | offices, jobs, advisory, or board positions held by the discloser. |
- Quarterly Disclosure Template: T2 (to be filed every quarter)
Purpose: Confirm existing interests or add new disclosures.
Template fields:
| Reaffirmation: | “No material changes” |
|---|---|
| Update disclosures: | Same capture fields as above if there are new conflicts. |
- Ad-hoc Disclosure: T3 (Material Change, within 14 Days)
Purpose: React to a new conflict arising during a term.
| Nature of the new conflict. | |
|---|---|
| Party/Organization Involved: | |
| Governance Area Impacted: | |
| Date conflict was identified. | |
| Steps taken by the Interested Person (e.g., voluntary recusal) |
All disclosures must be public either via the official COI Portal or through the Governance Forum and logged into the Conflict Registry (as per Article 6).
Section B: Guidelines for Interested Persons to Determine COI
This section provides practical guidance to help determine when disclosure or recusal is necessary. It replaces the traffic‑light model with the four policy “Levels of Conflict”.
Level 1: No Conflict (No conflict + No Perception of conflict)
Participation Allowed — no restrictions apply.
Examples:
| Voting: | Working Groups: |
|---|---|
| Technical upgrades to the NEAR protocol. | Reviewing grants from applicants you have no ties with. |
| House of Stake operational procedures. | Selecting service providers you are unrelated to. |
| Budget allocations unrelated to your compensation. |
Level 2: Perceived Conflict (No conflict, But Perception Exists)
Action: Disclose publicly, consider voluntary recusal.
Examples:
| Voting: | Working Groups: |
|---|---|
| You were previously employed by a project seeking funding (no ongoing interest). | A friend or former colleague’s team applies for grants. |
| You own NFTs from a project applying for grants. | You are part of the same online community as an applicant. |
| You’ve publicly endorsed a project that is now under evaluation. |
Guidance:
Default to disclosure + recusal. If participation is essential (e.g., quorum shortage), disclose thoroughly, and allow fellow Delegates to decide whether you may remain involved.
Level 3: Real Conflict (Actual Conflict, But Not Widely Perceived)
Action: Disclosure and mandatory recusal.
Examples:
| Voting: | Working Groups: |
|---|---|
| You are an unpaid advisor for the project under vote. | Your spouse/partner is a grantee staff member. |
| You hold token/equity in a project that is a direct proposal beneficiary. | You have agreed to accept compensation in the future from the funding applicant. |
| You hold a stake in a competing project strategically affected by an HoS decision. | You’re informally consulting with a service provider under consideration. |
Guidance:
Disclose, recuse, and leave the room/forum. Allow other Delegates to handle the matter, refer to the screening committee
Level 4: Real + Perceived Conflict (Actual Conflict + Clear Perception)
Action: Full recusal required — disclose, abstain, and exit deliberations completely.
Examples:
| Voting: | Working Groups: |
|---|---|
| Voting to set or change your own term’s compensation. | Reviewing your own organization’s grant application. |
| Voting on a proposal that gives you tokens or delegations directly. | Serving as an advisor/employee of an applicant. |
| Your company/project seeks House of Stake funding. | Evaluating a service provider you currently work for. |
| Proposals directly tied to Near Foundation where you are affiliated. | Immediate financial gain or token distribution to yourself. |
Guidance:
Recusal must be absolute. Do not influence outcomes. Peers will document the recusal and proceed without you.
Important Distinction: Drafting vs. Voting
You may participate in drafting and discussing proposals, even if they could indirectly benefit you.
You must abstain from the vote itself to remove any perception of bias.
The Guiding Principle
If a reasonable person could argue that your impartiality is compromised, you should recuse.
- Ask: “Would I directly or indirectly benefit?”
- Ask: “Could a neutral observer assume I benefit?”
If either is “yes,” recuse.
Recusal Process
| STEP 1 | Announce your conflict to the group. |
|---|---|
| STEP 2 | Step back fully — avoid participating or influencing discussions. |
| STEP 3 | Allow peers to manage resolution or appoint alternatives. |
| STEP 4 | Ensure documentation — recusal noted in governance logs. |
| STEP 5 | Stay out until resolved; do not check progress or influence indirectly. |
Why it matters:
Every time you recuse, you strengthen trust in House of Stake governance, set a precedent for ethical standards, and protect the legitimacy of governance outcomes.
Signature and Adoption
Date of On‑Chain Vote: ______________________
On‑Chain Vote Link: _________________________
Outcome: Adopted / Rejected
Next Steps
Delegate Feedback:
To ensure effective implementation, it is crucial to build awareness and consensus among all Interested Persons. Though the document has collected extensive community input, none of the delegates (or HoS Governance Team) has provided any feedback on the document. Before it goes to a vote, it is imperative that the policy sources a consensus from these stakeholders.
Consensus and Adoption:
Upon activation of the House of Stake voting platform, a formal proposal should be submitted to adopt this Conflict of Interest Policy via an on-chain vote.