Purpose

The purpose of this Conflict of Interest Policy is to protect the interests of LaunchWorks, Inc. (the “Organization”) when it is considering entering into a transaction or arrangement that might benefit the private interest of a director, officer, or other individual with decision-making authority. This policy is intended to ensure transparency, integrity, and compliance with applicable state and federal nonprofit laws.

Covered Persons

This policy applies to all members of the Board of Directors, officers, and any individuals with substantial influence over the affairs of the Organization.

Definition of Conflict of Interest

A conflict of interest exists when a covered person has a direct or indirect financial, business, or personal interest that could reasonably be perceived to interfere with their duty to act in the best interests of the Organization.

Examples may include, but are not limited to:

• A financial or ownership interest in an entity doing business with the Organization

• A compensation arrangement with the Organization or with an entity doing business with the Organization

• A personal or family relationship that could influence decision-making

The existence of such an interest does not automatically constitute a conflict; a conflict exists only if the Board determines that the interest could improperly influence a decision.

Disclosure and Review

Any covered person who becomes aware of an actual or potential conflict of interest must promptly disclose the matter to the Board of Directors.

After disclosure, the interested person shall not participate in discussion or voting on the matter, except to provide factual information if requested by the Board. The remaining disinterested directors shall determine whether a conflict of interest exists and how the matter should be addressed.

Decision-Making

If a conflict of interest is determined to exist, the Board shall take appropriate steps to ensure that any decision is made in the best interests of the Organization. This may include approving the transaction only if it is fair, reasonable, and in furtherance of the Organization’s charitable mission.

Documentation

All disclosures and decisions related to conflicts of interest shall be documented in the minutes of the relevant Board or committee meeting.

Compensation Matters

No director or officer shall participate in decisions regarding their own compensation.

Annual Acknowledgment

Each director and officer shall annually acknowledge in writing that they have read, understand, and agree to comply with this Conflict of Interest Policy.

Administration

The Board of Directors is responsible for the interpretation and enforcement of this policy and may amend it as needed to reflect best practices and legal requirements.

Last update: August 04, 2026