Counterparty Risk

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Abstract

Counterparty + Anti-Corruption risk refers to the potential for a counterparty Endaoment interacts with to not fulfill their end of an agreement or transaction. Counterparty + Anti-Corruption risk also refers to the potential for a third party to do something illegal on Endaoment’s behalf and without Endaoment’s knowledge, or otherwise act in a corrupt manner.

This risk can be further subdivided into two categories: offchain and onchain. Offchain refers to traditional transactions with brokerages and other traditional firms or other vendors, while onchain refers to transactions made on a blockchain. Offchain transactions between Endaoment and other crypto focused entities, unless involving blockchain transactions, should be considered offchain in nature.

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Policy

Endaoment believes in providing financial tooling with access to assets that have definitive settlement through use of blockchain technology. Endaoment additionally believes in compliance with applicable anti-corruption statues. We manage these risks through regular counterparty analysis and code audit/review.

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Scope and Applicability

This policy applied to all Endaoment employees, contractors, board members, and those acting on behalf of Endaoment in any capacity. Non-compliance with this policy may lead to disciplinary action up to and including termination/removal. Should there be a conflict of law, the more stringent of either this policy or the applicable law will be applied.

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Operational Controls + Testing

Internal controls will be monitored and/or tested on a periodic basis determined by risk. Monitoring and testing outcomes will be used to inform the continuous improvement of internal controls in order to appropriately mitigate risk.

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Training

All Endaoment employees will receive training on Legal Compliance + Regulatory Risk to ensure policy continuity and application. New hires will be trained within their first 60 days, and mandatory incumbent trainings will be conducted bi-annually with all current employees.

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Governance

This policy will be reviewed by the executive team and updated semi-annually to ensure it remains up-to-date. Escalation of any questions, concerns, or requests for exceptions regarding this policy must be made to the Endaoment executive team and approved unanimously.