Because contributors may be paid by the DAO for work they also vote on, integrity rules are Phase 1. In the Telegram thread a contributor stressed: "document the conflict of interest and stay away from decisions or payment to yourself." Saul proposed mandatory disclosure for any entity controlling >10% of token supply.
Both documents are written
The two policies this card asks for are drafted and sitting in the ratification set. The Conflict of Interest Policy (16,294 bytes) and the Code of Conduct (12,913 bytes) were last edited on 25 August 2026, in a pre-ratification quality pass across 23 files that stamped every ratified document v1.0.0 and gave GP-PRE-1 a manifest listing all 21 by file, version and SHA-256 – a column whose every cell still reads to be recorded at signing, so the hashes are a slot rather than a commitment. Before that the substantive work was a 5 August commit titled "close the workbook review findings for ratification." They live in Shadaffy/radix-dao-governance, the operative repository, not in Shadaffy/radix-dao, which the framework's own index describes as the reference library of working drafts and activation history.
Neither policy gets its own vote. Under the GP-PRE-1 constitutional ratification proposal, the community ratifies the Charter, the DAO Parameters Registry and nineteen operational policies as one set – twenty-one documents, one YES. The Conflict of Interest Policy and the Code of Conduct are two rows in that table, which means this card is not a separate ballot item but part of the Phase 1 governance document set. A YES on GP-PRE-1 satisfies Activation Condition 6 of the Operating Agreement; it does not form the entity and does not make governance binding, which happens only at the Permanent RAC election and the Activation Vote that follow it.
The >10% threshold was considered and refused
The deliverable this card carried from the Telegram discussion – a disclosure mandate triggered at >10% of token supply – is not in the drafted policy, and its absence is deliberate. On what makes a financial interest material, §3.1 states that "there is no numeric threshold, and none is set in DAO Parameters," on the grounds that a figure would need calibrating against operating history the DAO does not have and against volatile token valuations, and would authorise non-disclosure beneath it. Disclosure is set wider still: §4.1 requires covered persons to declare all current financial interests in ecosystem entities, with no threshold at all.
The policy separates the two bars on purpose. Everything is disclosable; only a material interest forces recusal. Its reasoning is that disclosure is cheap and reversible where recusal costs the DAO a decision-maker, so the expensive act carries the higher bar – and that an undisclosed interest is one nobody but its holder can ever raise. The scope is role-based rather than holdings-based: RAC members, Treasury Signers, Working Group stewards with budget or execution authority, and contractors acting in a decision-making capacity. Token holders casting ordinary votes are outside it entirely.
Two provisions answer the transition directly. §3.5 treats consolidation of delegated functions – the same person elevating a proposal and then executing the treasury action it authorises – as a declaration duty rather than a recusal trigger, because a recusal reading would drop the RAC below its own non-recused floor and make routine oversight unperformable. §7 requires anyone who holds, or has held within three years, equity, a paid role or non-trivial token compensation from a predecessor entity with a material relationship to Radix to register that as a standing conflict, and to recuse from decisions that would benefit those entities or their former principals.
Reporting and enforcement already have a path
The enforcement route this card listed as undefined is set out in Code of Conduct §5 and §6. Reports go to the RAC through a designated channel, or to the Governance & Legal WG where the report concerns a RAC member; reporter identity is protected where disclosure would put them at risk, anonymous reports are accepted with the caveat that they limit what can be investigated, and retaliation against a good-faith reporter is itself prohibited conduct. On the Conflict of Interest side, §10 gives the RAC 30 days to investigate and issue a finding, with the accused heard before it is issued, and remedies that run from invalidating the tainted decision to a governance proposal to recover misappropriated funds.
Sanctions are graded – warning, temporary suspension, recommendation of removal from role, permanent exclusion – and the thresholds are graded with them: a warning or suspension goes under the RAC's routine decision rule, while permanent exclusion and any interim suspension require the emergency threshold. Permanent exclusion carries an appeal whether or not one is brought: where nobody appeals within 14 days, the exclusion is still referred for determination under the Dispute Resolution & Arbitration Policy before it takes effect. The 25 August pass moved the other direction on the same policy: an appellant may now elect in the notice of appeal to have the appeal determined in arbitration rather than by the RAC, and that election is not refusable. It had been available only where the RAC decided it could not seat an impartial panel, which was the RAC judging its own impartiality on an appeal against its own finding.
No sanction reaches the vote
The sharpest line in either document is a limit the Code of Conduct places on itself. §6.3 states that no finding, sanction or interim measure affects a governance participant's eligible voting power, their entitlement to cast a vote, or the counting of a vote already cast. Suspension covers forums, calls, working groups, repositories, grant and compensation processes and candidacy for role – not voting.
That is a limit on this Code, and since 25 August the framework says plainly where the limit ends. The sentence deferring compliance-grounds suspension to legal advice was replaced with a pointer to Compliance Operations Policy §2.4A, a section written in the same commit. It lets the RAC suspend the voting rights attaching to the holdings of a holder who has not met a KYC, beneficial-owner or BOIR requirement under Marshall Islands law and Article X of the Operating Agreement: decided at the emergency threshold, on prior written notice with a 14-day cure period, reaching only that holder's holdings, lapsing the moment the requirement is met or shown not to apply, and challengeable both under the Proposal & Voting Framework and in arbitration. Its closing line is the one that matters for reading this card: it is the only ground on which voting power recognised by the framework may be set aside.
The two provisions do not conflict; they divide. A conduct finding cannot touch the vote, and the one thing that can is not a sanction at all but a statutory gate, with a cure period rather than a penalty at the end of it. Until 25 August the card could say the franchise was beyond the framework's reach, because the framework had left that question to counsel. It has answered it since.
The reason given is constitutional rather than charitable. Charter §12.1 entrenches XRD and LSU as eligible sources of voting power for all DAO governance votes, and Charter §13 voids a conflicting policy provision to that extent – so a code-of-conduct sanction that tried to disenfranchise someone would be unenforceable rather than severe. A DAO whose franchise is defined on-ledger cannot take it away in a moderation decision, and this policy says so rather than leaving it to be discovered.
Deliverables
Draft the Conflict of Interest Policy and the Code of Conduct– both written, both v1.0.0, last revised 25 August 2026.- Ratify both as part of the GP-PRE-1 document set (not as separate votes).
Add the >10% token-supply disclosure mandate– declined in §3.1 in favour of no threshold for materiality and no threshold for disclosure.Define enforcement and the ethics-reporting path– Code of Conduct §5–§6 and CoI §10.- Stand up the machinery the documents assume: a designated reporting channel, a public record for conflicts disclosures, and the RAC seats that receive both.
Dependencies & cross-references
- Operative repository:
Shadaffy/radix-dao-governance,pending/governance/. The reference library holds working drafts and activation history. - Ratified inside the Phase 1 governance document set; gates paid roles referenced in the Permanent RAC and WG stewardship.
- Enforcement depends on the RAC existing to receive reports, so nothing here bites before the election.
