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GLOBAL ALGAE

GIFT GIVING POLICY AND DISCLOSURE

 

Thank you!

 

Thank you for your interest in supporting Global Algae and its mission!  The purpose of this Gift Giving Policy and Disclosure ("Policy") is to inform you about Global Algae and how we use any monetary contributions that you give to Global Algae.  

 

Who Are We and What is Our Vision?

 

"Global Algae", "us", "our" and "we" refers to Global Algae Holdings, Inc. and its affiliates and subsidiaries Global Algae Equipment, Global Algae Innovations and Global Algae Technology.  The organizations that make-up Global Algae are for-profit organizations.  Our vision is to harness the productivity of algae to provide food and fuel for the world, improving the environment, economy, and quality of life for all people.  Please see our website found at www.globalgae.com for more details. 

 

Gifts We Accept.

 

We appreciate your support, and we accept financial gifts via cash or check, as well as through the methods made available on our website.  

 

What Do We Do With Your Gift?

 

If you send us a gift in the form of a monetary contribution, we will use that money to support Global Algae's ongoing research and development, with the ultimate goal of improving the technology surrounding algae cultivation to bring it to a commercial scale.  This work includes projects related to CO2 capture, improving algae cultivation, harvesting, and extraction technologies.  All funds will be used solely within Global Algae's discretion.  We cannot guarantee that your gift will go to any specific project.  A non-inclusive list of examples with regard to how money you gift us could be used includes:  scaling up and improving our technology so that it will function on a larger, commercial scale; research and development; matching funds for government supported research grants and to help pay our business expenses.

 

Your Personal Information.  

 

We use any personal information that you provide in accordance with our Privacy Policy, found here.

 

Disclosure / Notices.

  • Your monetary contribution/gift is non-refundable and non-cancellable.

  • We do not provide goods or services in exchange for your contribution.

  • You are not permitted to impose restrictions on the use of any contribution provided through our website.  If you would like to discuss a targeted grant or would like to sponsor specific research, please contact us directly to discuss such sponsored research.

  • We are not responsible for any fees or charges you incur based on the payment method you use, including if your payment method is denied.

  • Although we will use all gifts to support our vision described in this Policy, all gifts will be used for purposes as determined in Global Algae's sole direction.

  • All gifts should be made directly to Global Algae Holdings, Inc., and if your gift does not indicate who the gift is directed to, we will accept the gift on behalf of Global Algae Holdings, Inc.

  • Gifts should not be made to individual employees, stakeholders, board members or other personnel of Global Algae.

 

Processing Fees.

 

If you agree to cover the processing fees at check-out, any processing fees for charging your payment method online will be deducted from your payment method in addition to the gift amount you indicate. 

 

Tax Considerations.   

 

Global Algae is a for-profit company and therefore your gifts are not tax deductible.  We suggest that you seek the advice of a legal or tax advisor to determine if and how your gift may be taxed.

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GLOBAL ALGAE INNOVATIONS AND AFFILIATES

FINANCIAL CONFLICT OF INTEREST (COI) POLICY

EFFECTIVE: 1/22/22

 

This policy complies with the Department of Energy (DOE) Financial Assistance Regulations No. FAL 2022-02 (12/20/2021).

 

Definitions

Team member means any person who is employed by Global Algae Innovations (GAI) or an affiliate of GAI.

Designated official means the Team member designated with the authority and responsibility to ensure compliance with the Conflict of Interest Policy. 

Disclosure of significant financial interests means a Team members disclosure of Significant financial interests to GAI.

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

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.

FCOI report means a GAI’s report of an unmanaged or unmanageable Financial conflict of interests to the DOE program office. 

Investigator means a Team member who is 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 DOE or proposed for funding by DOE. For clarity, an Investigator at GAI is further defined as either the i) PI, ii) business and reporting official and/or, iii) a Team Member who is assigned the purchase approver for a Federal Award.

Investigator’s responsibilities mean an Investigator's professional responsibilities on behalf of the GAI, which may include activities such as research, research consultation, teaching, professional practice, institutional committee memberships, and service on panels such as Institutional Review Boards or Data and Safety Monitoring Boards.

Manage means taking action to address a Financial or Organizational conflict of interest which can include mitigating or eliminating the conflict, to ensure, to the extent possible, that the purpose, design, conduct, and reporting of a project will be free from bias.

Management official means the Team member designated with the authority and responsibility to develop and assure compliance with management plans for Financial or Organizational conflicts of interest.

Organizational conflict of interest means a situation where because of relationships with a parent company, affiliate, or subsidiary organization, the organization appears to be unable to be impartial in conducting a procurement action involving a related organization.

Potential conflict of interest exists when an impartial observer reasonably believes that actual or apparent past, present, or currently planned interests could constitute a Financial or Organizational conflict of interest with a project funded under a DOE award. 

Project means the interdependent activities funded wholly or in part under a DOE 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 cost share as part of the approved budget, activities funded with cost share are included.

Senior/key personnel means the PI; any other person who significantly influences the design, conduct, or reporting of a project funded under a DOE award; and any other person identified as senior/key personnel in the application for financial assistance, approved budget, progress report, or any other report submitted to the DOE.

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. The non-Federal entity's FCOI policy will specify the details of this disclosure, which will include, at a minimum, the purpose of the trip, the identity of the sponsor/organizer, the destination, and the duration. In accordance with the non -Federal entity's FCOI policy, the non-Federal entity official(s) will determine if further information is needed, including a determination or disclosure of monetary value, in order to determine whether the travel constitutes a FCOI with the project funded under the DOE award.

(3) The term Significant financial interest does not include the following types of financial interests: salary, royalties, or other remuneration paid by GAI or an affiliate to the Investigator if the Investigator is currently employed or otherwise appointed by GAI or the affiliate, including intellectual property rights assigned to the GAI or an affiliate and agreements to share in royalties related to such rights; any ownership interest in GAI or an affiliate 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.

Subrecipient investigator means the principal investigator and any other person, regardless of title or position, at a subrecipient to GAI or an affiliate, who is responsible for the purpose, design, conduct, or reporting of a Project funded by DOE or proposed for funding by DOE. 

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Policy

A.    Designated Official Responsibilities

(1)    Solicit and review disclosures of significant financial interests from each Investigator who is planning to participate in, or is participating in, the project funded under a DOE award, including disclosures of Subrecipient investigators pursuant to Section D of this policy.

(2)    Maintain records relating to all Investigator Disclosures of financial interests and the review of and response to such disclosures (whether or not a disclosure resulted in the non-Federal entity's determination of a financial conflict of interest) for the time period specified in 2 CFR 200.334 or, where applicable, from other dates specified in the individual award terms and conditions

(3)    Notify the Management official of any new or modified Financial or Organizational conflicts of interest.

(4)    Provide the DOE program office with initial and ongoing FCOI reports, which identify any unmanaged or unmanageable Financial conflicts of interest prior to the expenditure of funds and within sixty days of any subsequently identified FCOI.

(5)    Provide FCOI reports to the DOE program office regarding all unmanaged or unmanageable Financial conflicts of interest of all Subrecipient investigators prior to the expenditure of funds and within sixty days of any subsequently identified FCOI. 

(6)    Inform each Investigator of the policy on financial conflicts of interest, the Investigator's responsibilities regarding Disclosure of significant financial interests, and of Department of Energy (DOE) Financial Assistance Regulations No. FAL 2022-02 (12/20/2021); and require each Investigator to complete training regarding the same prior to engaging in projects related to any DOE financial assistance award and at least every four years, and immediately when any of the following circumstances apply:

(i)    The financial conflict of interest policy is modified in any manner that affects the requirements of Investigators;

(ii)    An Investigator is a new Team member; or 

(iii)    An Investigator is found to not be in compliance with the financial conflict of interest policy or a management plan.

(7)    Certify, prior to award, that the GAI and affiliates: 

(i)    Has in effect an up-to-date, written, and enforced administrative process to identify and manage conflicts of interest with respect to all projects for which financial assistance funding is sought or received from DOE;

(ii)    Shall promote and enforce Investigator compliance with this Policy's requirements including those pertaining to disclosure of significant financial interests; 

(iii)    Shall manage financial conflicts of interest and provide initial and ongoing FCOI reports to DOE consistent with this Policy; 

(iv)    Agrees to make information available, promptly upon request, to DOE relating to any Investigator disclosure of financial interests and the non-Federal entity's review of, and response to, such disclosure, whether or not the disclosure resulted in the non-Federal entity's determination of a financial conflict of interest; and

(v)    Shall fully comply with the requirements of this Policy. 

(8)    Prior to the expenditure of any funds under a DOE award, consistent with Section E: review all Investigator disclosures of significant financial interests; determine whether any of the disclosures relate to the project funded under the DOE award; determine whether a financial conflict of interest exists; and, if so, notify the Management official. 

(9)    Whenever, in the course of an ongoing project funded under a DOE award, an Investigator who is new to participating in the Project Discloses a significant financial interest or an existing Investigator discloses a new Significant financial interest, shall, within sixty days, review the disclosure; determine whether a financial conflict of interest exists pursuant to Section E; and, if so, notify the Management official of the financial conflict of interest.

(10)    Disclose in writing any potential or actual organizational conflict of interest to the DOE program office in an application for financial assistance or prior to engaging in a procurement or transaction using DOE funds with a parent, affiliate, or subsidiary organization. The elements of the disclosure shall include, but are not limited to the following:

(i)    The name, address, and website (as applicable) of the entity that presents a potential or actual organizational conflict of interest;

(ii)    relationship between the non-Federal entity and the entity at issue;

(iii)    The nature of the anticipated procurement or other transaction with the parent, affiliate, or subsidiary organization; the anticipated value of the procurement or other transaction; and the basis for making the procurement or other transaction with a parent, affiliate, or subsidiary organization.

(iv)    The basis for the non-Federal entity’s determination regarding the existence of an organizational conflict of interest; and

(v)    How the non-Federal entity will avoid, neutralize, or mitigate the organizational conflict of interest.

(11)    Whenever a non-Federal entity identifies a Significant financial interest that was not disclosed timely by an Investigator or, for whatever reason, was not previously reviewed during an ongoing project funded under a DOE award (e.g., was not timely reviewed or reported by a subrecipient), shall, within sixty days: review the Significant financial interest; determine whether it is related to the project funded under a DOE award; determine whether a financial conflict of interest exists; and, if so notify the Management official of the Financial or Organizational conflict of interest that was not disclosed in a timely manor.

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B.    Investigator Responsibilities

(1)    Each Investigator who is planning to participate in a DOE award shall disclose to the Designated official the Investigator's Significant financial interests (and those of the Investigator's spouse and dependent children) no later than the time of application for the DOE award. In the event an Investigator is added after the time of application, the Investigator shall make such disclosures prior to participating in a project funded under a DOE award.

(2)    Each Investigator who is participating in the DOE award shall submit an updated Disclosure of significant financial interests annually during the period of the award. Such disclosure shall include any information that was not disclosed initially pursuant to paragraph (1) of this section, or in a subsequent Disclosure of significant financial interests (e.g., any Significant financial conflict of interest identified on a later DOE award), and shall include updated information regarding any previously disclosed significant financial interest (e.g. the updated value of a previously disclosed equity interest).

(3)    Each Investigator who is participating in the DOE award shall submit an updated Disclosure of significant financial interests within thirty days of discovering or acquiring (e.g., through purchase, marriage, or inheritance) a new Significant financial interest. 

(4)    Each disclosure and updated disclosure shall be signed and dated by the Investigator and include a certification statement that reads: 

“I understand that this Disclosure is required to obtain funding from the U.S. Government. I, [Full Name and Title], certify to the best of my knowledge and belief that the information contained in this Disclosure Statement is true, complete, and accurate. I understand that any false, fictitious, or fraudulent information, misrepresentations, half-truths, or omissions of any material fact, may subject me to criminal, civil or administrative penalties for fraud, false statements, false claims, or otherwise. (18 U.S.C. §§ 1001 and 287, and 31 U.S.C. 3729 -3730 and 3801-3812). I further understand and agree that (1) the statements and representations made herein are material to U.S. Government’s funding decision, and (2) I have a responsibility to update the disclosures during the period of performance of the award should circumstances change which impact the responses provided above.”

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C.    Management Official Responsibilities

(1)    Develop a management plan to Manage each Financial or Organizational conflict of interest including Subrecipient investigators pursuant to Section D, and, if necessary, a retrospective review and a mitigation report pursuant to this Section C(9). The management plan shall specify the actions that have been, and shall be, taken to manage the Financial or Organizational conflict of interest. A nonexclusive, non-exhaustive list of conditions or restrictions, one or more of which might be imposed to manage a Financial or Organizational conflict of interest, includes:

(i)    Public disclosure of the financial conflict of interest (e.g., when presenting or publishing the project);

(ii)    For projects involving human subjects, disclosure of financial conflicts of interest directly to participants;

(iii)    Appointment of an independent monitor or oversight committee capable of taking measures to protect the purpose, design, conduct, and reporting of the project against bias resulting from the financial conflict of interest

(iv)    Modification of the project plan;

(v)    Change of personnel or personnel responsibilities, or disqualification of personnel from participation in all or a portion of the project;

(vi)     Reduction or elimination of the financial interest (e.g., sale of an equity interest);

(vii)    Severance of relationship(s) that create financial conflicts of interest;

(viii)    Restrictions to control procurements that create organizational conflicts of interest such that they are free from bias, e.g. requiring direct pass-through of costs without adding indirect costs or pricing based on list prices or sales/quotes of identical items to non-affiliated commercial customers; and

(2)    Monitor Investigator compliance with the management plan on an ongoing basis until the completion of the DOE award. If the failure of an Investigator to comply the financial conflict of interest policy or a management plan appears to have biased the purpose, design, conduct, or reporting of the project funded under a DOE award, the non-Federal entity shall promptly notify the DOE of the failure to comply and of the corrective action taken or to be taken.

(3)    Establish adequate enforcement mechanisms and provide for employee sanctions or other administrative actions to ensure Investigator compliance as appropriate.

(4)    Maintain records of all actions to manage and retrospective reviews, if applicable, for all Financial or Organizational conflicts of interest including Subrecipient investigators.

(5)    Inform all Team members impacted by a management plan of their responsibilities for implementation of the mitigation or elimination of the Financial or Organizational conflict of interest.

(6)    Inform the Designated official of whether each Financial conflict of interest is managed, unmanaged, or unmanageable. Prior to expenditure of funds and for a period of at least three years after it is updated for the award, ensure public accessibility through written response within five business days of a request of information concerning any Significant financial interest of held by Senior/key personnel that is related to the award and is a Financial conflict of interest. Written response to include Investigator's title and role with respect to the project; the name of the entity in which the significant financial interest is held; the nature of the significant financial interest; and the approximate dollar value range as well as the statement, “the information provided is current as of the date of the correspondence and is subject to updates, on an annual basis and within sixty days of the non-Federal entity's identification of a new financial conflict of interest, which should be requested subsequently by the requestor.”

(7)    Maintain GAI and affiliates financial conflict of interest policy and make it available via the www.globalgae.com website.

(8)    Whenever a Financial or Organizational conflict of interest is not identified or managed in a timely manner, including failure by an Investigator to disclose a Significant financial interest that is determined to constitute a Financial conflict of interest; failure to review or manage such a Financial conflict of interest; or failure by the Investigator to comply with a Financial conflict of interest Management plan, shall, within 120 days of the determination of noncompliance:

(i)    complete a retrospective review of the Investigator's activities and the project funded under the DOE award to determine whether any project activity, or portion thereof, conducted during the time period of the noncompliance, was biased in the purpose, design, conduct, or reporting of such project.

(ii)    document the retrospective review; such documentation shall include, but not necessarily be limited to, all of the following key elements:

a.    DOE award number;

b.    Project title;

c.    PI or contact PI if a multiple PI model is used;

d.    Name of the Investigator with the FCOI;

e.    Name of the entity with which the Investigator has a financial conflict of interest;

f.    Reason(s) for the retrospective review;

g.    Detailed methodology used for the retrospective review (e.g., methodology of the review process, composition of the review panel, documents reviewed);

h.    Findings of the review; and

i.    Conclusions of the review.

(iii)     Based on the results of the retrospective review, if appropriate, update the previously submitted FCOI report, specifying the actions that will be taken to manage the financial conflict of interest going forward. If bias is found, notify the DOE program office promptly and submit a mitigation report to the DOE program office. The mitigation report must include, at a minimum, the key elements documented in the retrospective review above, a description of the impact of the bias on the project, and the non-Federal entity's plan of action or actions taken to eliminate or mitigate the effect of the bias (e.g., impact on the project; extent of harm done, including any qualitative and quantitative data to support any actual or future harm; analysis of whether the project is salvageable).

(iv)    Depending on the nature of the financial conflict of interest, may determine that additional interim measures are necessary with regard to the Investigator's participation in the project funded under the DOE award between the date that the conflict of interest or the Investigator's noncompliance is determined and the completion of the retrospective review.

 

D.    Subrecipient Responsibilities

(1)    Incorporate as part of a written agreement with the subrecipient terms that establish whether the financial conflict of interest policy of the GAI and affiliates or that of the subrecipient will apply to the subrecipient's Investigators. 

(2)    If the subrecipient's Investigators must comply with the subrecipient's financial conflict of interest policy, the subrecipient shall certify as part of the agreement referenced above that its policy complies with the Department of Energy Financial Assistance Regulations No. FAL 2022-02 (12/20/2021), and the subrecipient shall make such policy available via a publicly accessible website. If the subrecipient does not have any current presence on a publicly accessible website (and only in those cases), the subrecipient shall make its written policy available to any requestor within five business days of a request. If the subrecipient cannot provide such certification, the agreement shall state that subrecipient Investigators are subject to the financial conflict of interest policy of GAI and affiliates for disclosing financial conflicts of interest.

(3)    Additionally, if the subrecipient's Investigators must comply with the subrecipient's financial conflict of interest policy, the agreement referenced above shall specify time period(s) for the subrecipient to report all identified financial conflicts of interest to GAI or an affiliate. Such time period(s) shall be sufficient to enable the Designated official to provide timely FCOI reports, as necessary, to DOE. 

(4)    Alternatively, if the subrecipient's Investigators must comply with the GAI and affiliates’ conflict of interest policy, the agreement referenced above shall specify time period(s) for the subrecipient to submit all Investigator disclosures of significant financial interests to the Designated official. Such time period(s) shall be sufficient to enable the Designated official to comply timely with its review, management, and reporting obligations.

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E.    Guidelines for Determination of Financial Conflict of Interest

An Investigator's Significant financial interest is related to a project funded under a DOE award when it is reasonably determined that the Significant financial interest could be affected by the project, could affect the Project, is in an entity whose Financial interest could affect the Project, or is in an entity whose Financial interest could be affected by the Project.

The Investigator may assist the designated official in the determination of whether a Significant financial interest is related to the project funded under the DOE award. A financial conflict of interest exists when the non-Federal entity, through its designated official(s), reasonably determines that the Significant financial interest could directly and significantly affect the purpose, design, conduct, or reporting of the project funded under a DOE award.

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