CONFLICTS OF INTEREST POLICY

Last Updated: January 3, 2026 | Effective Date: January 1, 2026

Platform Structure & Affiliations

Mazipan OS is operated by 54 Projects LLC, which also serves as General Partner of 54 IDI Fund, an infrastructure development fund.

Portfolio companies of 54 IDI Fund may list capacity on this platform. Such companies are majority-owned by the fund's limited partners (external investors), not by the platform operator.

1. COMMITMENT TO NEUTRALITY

Mazipan OS is committed to operating a fair, transparent, and neutral marketplace for all participants. This policy outlines how we manage potential conflicts of interest arising from our corporate structure.

2. AFFILIATED ENTITIES

2.1 Fund-Affiliated Sellers

Companies majority-owned by 54 IDI Fund may list forward capacity on this platform. These include:

Mazipaninfra IDI SPV LLC (subsea fiber infrastructure)
Other portfolio companies of 54 IDI Fund

2.2 Clear Identification

All fund-affiliated sellers are clearly identified with a "Fund Portfolio Company" badge on their listings.

3. EQUAL TREATMENT POLICY

3.1 Platform Fees

Fund-affiliated sellers pay the same 1.5% platform fee as all other sellers
No fee discounts, waivers, or preferential payment terms
All platform fees are disclosed in annual LP reports

3.2 Approval Process

Fund-affiliated declarations undergo the same approval process as third-party sellers
No expedited approval or relaxed requirements
All approvals logged in public audit trail

3.3 Search Rankings & Visibility

No preferential placement in search results
No "featured listing" privileges for affiliated sellers
Ranking determined solely by objective criteria (capacity, price, project stage)

4. INFORMATION BARRIERS

4.1 Data Protection

Buyer data and platform transaction information are not shared with the fund investment team. We maintain strict information barriers between:

Platform Operations Team: Manages marketplace, cannot influence fund investments
Fund Investment Team: Manages portfolio companies, cannot access buyer data

4.2 Independent Valuation

Any material transactions between the platform and fund-affiliated entities are subject to independent third-party valuation.

5. FIDUCIARY DUTIES

As General Partner of 54 IDI Fund, 54 Projects LLC owes fiduciary duties to the fund's limited partners. This includes:

Duty of loyalty (no self-dealing)
Duty of care (prudent marketplace operations)
Duty of good faith and fair dealing

These duties legally require us to treat all marketplace participants fairly. Breach of these duties would expose us to lawsuits from fund investors.

6. OVERSIGHT & COMPLIANCE

6.1 Annual Conflicts Audit

We conduct an annual review of all platform transactions involving affiliated entities, including verification of:

Arms-length pricing and terms
Equal fee treatment
No preferential rankings or visibility

6.2 LP Disclosure

All platform fees paid by fund portfolio companies are disclosed to fund limited partners in quarterly and annual reports.

7. DISPUTE RESOLUTION

Any participant who believes they have been treated unfairly due to conflicts of interest may file a formal complaint at: conflicts@mazipanos.com

Complaints will be reviewed by independent counsel and addressed within 30 business days.

8. POLICY UPDATES

This policy may be updated from time to time. Material changes will be posted prominently on the platform and communicated to all registered users.