Financial Conflict of Interest Policy





HeartPoint Global Financial Conflict of Interest Policy

HeartPoint Global Financial Conflict of Interest Policy

Document No.: CP-001
Revision: 000
Effective Date: 07-16-2025
Issued: 16 July 2025

Table of Contents

1. INTRODUCTION

The Federal Department of Health and Human Services has developed regulations (42 CFR Part 50 Subpart F and 45
CFR Part 94) on Promoting Objectivity in Research. The regulations were first developed in 1995, and in 2011,
the regulations were revised. The 2011 revised regulations describe the actions an individual and an
organization must take to promote objectivity in Public Health Service (PHS) funded research. The regulations
apply to all PHS (e.g., National Institutes of Health [NIH]) funded grants, cooperative agreements, and research
contracts. The regulations are not applicable to Phase 1 Small Business Innovation Research or Small Business
Technology Transfer applications and/or awards.

This policy implements the regulatory requirements provided in 42 CFR Part 50 Subpart F for HeartPoint Global
Inc. (hereinafter “HPG”).

The implementation of the regulation through the issuance of this policy ensures that the design, conduct, and
reporting of PHS/NIH-funded research will be protected from bias resulting from an Investigator’s financial
conflict of interest (FCOI). In addition, the policy serves to protect the safety of animals and human research
participants, the reputation of the recipient institution and of the Investigator who participates in
PHS/NIH-funded research. These requirements work together to preserve the public’s trust that the research
supported by the PHS/NIH is conducted without bias and with the highest scientific and ethical standards.

2. DEFINITIONS

For the purpose of these policies and procedures, the following definitions apply:

a. Financial conflict of interest (FCOI): A significant financial interest that could
directly and significantly affect the design, conduct, or reporting of PHS-funded research.

b. Financial Interest: Financial Interest means anything of monetary value, whether or not
the value is readily ascertainable.

c. Institutional Responsibilities: Institutional responsibilities are the professional
activities an investigator performs on behalf of HPG, which includes to: research, clinical development,
research, publication, consulting, administration, or institutional committee memberships.

d. Designated Official (DO): The Designated Official(s) has been designated by HPG as an
Official to oversee the financial conflicts of interest process, including solicitation and review of
disclosures of significant financial interests and investments on a periodic basis to identify FCOIs per the
regulatory criteria provided in 42 CFR 50.604(f) and as stated within the policy below.

e. Investigator: The Project Director or Principal Investigator and any other person,
regardless of title or position, who is responsible for the design, conduct, or reporting of research funded
by an award or proposed for funding, which may include, for example, collaborators or consultants. HPG will
consider the individual’s role rather than the title of those involved in the research and the degree of
independence with which the individual works when determining who is responsible for the design, conduct, or
reporting of the PHS-funded research.

f. Research: Research implies a systematic investigation, study, or experiment designed to
develop or contribute to generalizable knowledge relating broadly to public health, including behavioral and
social sciences research. The term encompasses basic and applied research (e.g., a published article, book,
or book chapter) and product development (e.g., a diagnostic test or therapeutic drug).

g. PHS-Funded Research: The term includes any such activity for which research funding is
available from a PHS Awarding Component through a grant, cooperative agreement, or contract, whether
authorized under the PHS Act or other statutory authority.

h. PHS: The Public Health Service of the U.S. Department of Health and Human Services, and
any components of the PHS to which the authority involved may be delegated, including the National
Institutes of Health (NIH).

i. NIH: The biomedical research agency of the PHS.

j. Senior/key personnel: Senior/key personnel means the PD/PI and any other person
identified as Senior/key personnel by the Institution in the grant application, progress report, or any
other report submitted to the PHS/NIH by the Institution. This term is defined only as it relates to the
public accessibility requirements of identified FCOIs held by Senior/key personnel, as described under
section 8.

k. Significant Financial Interest (SFI):

1. A domestic or foreign financial interest of the Investigator (and those of the
Investigator’s spouse and dependent children) consisting of one or more of the following that reasonably
appear to be related to the Investigator’s institutional responsibilities performed on behalf of HPG:

  • With regard to any 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, is greater
    than $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;
  • With regard to any non-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, 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); or
  • With regard to intellectual property rights and interests (e.g., patents, copyrights), a significant
    financial interest exists upon receipt of income of greater than $5,000 in the twelve months
    preceding disclosure that is related to such rights and interests.

2. Investigators must disclose the occurrence of any reimbursed or sponsored travel that
exceeds $5,000 (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 the
Investigator’s institutional responsibilities. The initial disclosure of reimbursed or sponsored travel
should include income received over the previous twelve months. The details of this disclosure will
include, at a minimum, the purpose of the trip, the identity of the sponsor/organizer, the destination,
and the duration.

The disclosure requirement does not apply to travel that is reimbursed or sponsored by the following:

  • a federal, state, or local government agency located in the United States;
  • a United States Institution of higher education;
  • an academic teaching hospital;
  • a medical center; or
  • a research institute affiliated with a United States Institution of Higher Education.

3. The term “significant financial interest” does not include, and therefore
investigators are not required to disclose, the following types of financial interests:

  • Salary, royalties, or other remuneration paid by HPG to the Investigator if the Investigator is
    currently employed or otherwise appointed by HPG, including intellectual property rights assigned to
    HPG and agreements to share in royalties related to such rights.
  • Any ownership interest in HPG held by the Investigator, since HPG is a for-profit organization. This
    exclusion only applies if the applicant or recipient (including a sub-recipient) is a for-profit or
    commercial institution.
  • 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 located in the United States, a US Institution of higher education, an academic
    teaching hospital, a medical center, or a research institute that is affiliated with a U.S.
    Institution of higher education; or
  • Income from service on advisory committees or review panels for a federal, state, or local
    government agency located in the United States, a US Institution of higher education, an academic
    teaching hospital, a medical center, or a research institute that is affiliated with a U.S.
    Institution of higher education.

Foreign Financial Interests: Investigators must disclose all foreign financial interests
(which include income from seminars, lectures, or teaching engagements, income from service on advisory
committees or review panels, and reimbursed or sponsored travel) received from any foreign entity,
including foreign Institutions of higher education or a foreign government (which includes local,
provincial, or equivalent governments of another country) when such income meets the threshold for
disclosure (e.g., income in excess of $5,000).

3. SIGNIFICANT FINANCIAL INTEREST DISCLOSURE REQUIREMENTS

a. At the time of application: The Principal Investigator and all other individuals who meet
the definition of ‘Investigator’ must disclose their SFIs to the Designated Official(s). Any new
Investigator who, after applying to NIH for funding from NIH or during the course of the research project,
plans to participate in the project must similarly disclose their SFI(s) to the Designated Official(s)
promptly and prior to participation in the project.

b. Annual Disclosure: Each Investigator who is participating in research under an NIH award
must submit an updated disclosure of SFI at least annually, on or before July 01, during the period of the
award. Such disclosure must include any information that was not disclosed initially to HPG pursuant to this
Policy or in a subsequent disclosure of SFI (e.g., any financial conflict of interest identified on an
NIH-funded project directly as an NIH Grantee and/or indirectly through a sub-award) that was transferred
from another Institution and must include updated information regarding any previously disclosed SFI (e.g.,
the updated value of a previously disclosed equity interest).

c. New SFIs during the award: Each Investigator participating in PHS/NIH-funded research
must submit an updated disclosure of SFI within thirty (30) days of discovering or acquiring a new SFI
(e.g., through purchase, marriage, or inheritance). In addition, Investigators must submit an updated
disclosure of reimbursed or sponsored travel within 30 days of each occurrence.

4. REVIEW OF SFI DISCLOSURES BY HPG DESIGNATED OFFICIAL(S)

A Designated Officials Committee (consisting of: Dr. Elena Amin, Chief Medical Officer; Hannalore Ilesan, Ph.D.,
Chief Operating Officer; Brian William Seidman, Director) has been assigned at HPG who will conduct reviews of
SFI disclosures. The Designated Officials Committee will review any SFI that has been identified in a
disclosure; these interests will be compared to each PHS/NIH research application and/or award on which the
Investigator is identified as responsible for the design, conduct, or reporting of the research to determine if
the SFI is related to the PHS/NIH-funded research and, if so, whether the SFI creates a Financial Conflict of
Interest (FCOI) related to that research award as explained in Section 5.

a. Prior to the issuance of a new award: The Designated Officials Committee will review the
Investigator’s SFI(s) prior to the NIH issuing a new award and if an FCOI is identified, the institution
will submit an FCOI report to the NIH via the eRA Commons FCOI Module prior to the expenditure of funds
under the new award.

b. Annual SFI disclosure: The annual disclosure will require the Investigator to disclose
updated values of any previously disclosed SFIs (e.g., the updated value of a previously disclosed equity
interest). The Designated Officials Committee will review the Investigator’s annual disclosure and will use
the updated information to determine if any changes are needed to an existing management plan. Any changes
to the existing management plan will be reported to the NIH when the next Annual FCOI report is due, if
applicable.

c. During award period: Whenever in the course of an ongoing NIH-funded research project, an
Investigator who is new to participating in the research project discloses a SFI, or an existing
Investigator discloses a new SFI, the Designated Officials Committee will within 60 days: review the
disclosure of SFI, determine whether the SFI is related to the NIH-funded research, determine whether an
FCOI exists, and if so, implement on at least an interim basis, a management plan that shall specify the
actions that have been and will be taken to manage the FCOI. The institution will submit the FCOI report to
the NIH within 60 days of identifying the FCOI.

5. GUIDELINES FOR DETERMINING ‘RELATEDNESS’ OF SFI TO PHS/NIH-FUNDED RESEARCH AND A FINANCIAL
CONFLICT OF
INTEREST

The Designated Officials Committee will determine whether an Investigator’s SFI is related to the research under
an NIH award and, if so, whether the SFI is a financial conflict of interest.

Relatedness Test: An Investigator’s SFI is “related” to the research when the designated
Official(s) reasonably determines the SFI:

  • Could be affected by the PHS/NIH-funded research; or
  • Is in an entity whose financial interest could be affected by the PHS/NIH-funded research.

The Designated Officials Committee may involve the Investigator in determining whether an SFI is related to
the research supported by the PHS/NIH-funded award.

FCOI determination: A financial conflict of interest exists when the Designated Officials
Committee reasonably determines that the SFI could directly and significantly affect the design, conduct, or
reporting of the PHS/NIH-funded research (“significantly” means that the financial interest would have a
material effect on the research).

6. MANAGEMENT OF SIGNIFICANT FINANCIAL INTERESTS THAT POSE FINANCIAL CONFLICT OF INTEREST

If a financial conflict of interest exists, the Designated Officials Committee will determine what management
conditions and/or strategies will be put in place to manage the FCOI. Examples of conditions that might be
imposed to manage a financial conflict of interest include, but are not limited to:

  1. Public disclosure of financial conflicts of interest (e.g., when presenting or publishing the research, to
    research personnel working on the study, to the Institution’s Institutional Review Board, Institutional
    Animal Care and Use Committee, Data Safety and Monitoring Board);
  2. For research projects involving human subjects research, disclosure of financial conflicts of interest
    directly to human participants in the informed consent document;
  3. Appointment of an independent monitor capable of taking measures to protect the design, conduct, and
    reporting of the research against bias resulting from the financial conflict of interest;
  4. Modification of the research plan;
  5. Change of personnel or personnel responsibilities, or disqualification of personnel from participation in
    all or a portion of the research;
  6. Reduction or elimination of the financial interest (e.g., sale of an equity interest);
  7. Severance of relationships that create financial conflicts.

If the Designated Officials Committee determines that a conflict exists, it will communicate its determination
and the means it has developed for managing the FCOI in writing to the individual, to the relevant Principal
Investigator/Project Director, and to the appropriate direct supervisor.

Important: No expenditures on an NIH award will be permitted until the Investigator has
complied with the Disclosure requirements of this Policy and has agreed in writing to comply with any plans
determined by the designated Official necessary to manage the Financial Conflict of Interest.

The FCOI Designated Officials Committee of HPG will submit the FCOI report to NIH via the eRA Commons FCOI
Module.

7. MONITORING INVESTIGATOR COMPLIANCE

HPG will monitor investigators’ compliance with the management plan for the duration of the NIH award or until
the FCOI no longer exists during the period of an NIH-funded award. Monitoring public disclosure requirements
will include reviewing publications and presentations to confirm that the investigator disclosed the FCOI in
such communications. To facilitate additional monitoring, Investigators will be required to disclose the FCOI in
writing to research personnel in the study and send a copy of the communication to the Designated Officials
Committee.

8. PUBLIC ACCESSIBILITY OF FCOI POLICY AND INFORMATION RELATED TO A FCOI

a. FCOI Policy: A copy of the FCOI policy is posted on HPG’s public website per the NIH
requirements in the NIH grants policy statement section Financial Conflict of Interest at: https://grants.nih.gov/grants/policy/nihgps_html/section_4_financial_conflict_of_interest.htm.

b. Identified FCOIs held by Senior/key Personnel: Prior to the expenditure of any funds
under an NIH award, HPG will ensure public accessibility by written response to any request within five
business days of a request for information concerning any SFI disclosed that meets the following three
criteria:

  1. The SFI was disclosed and is still held by the Senior/key personnel (are the PD/PI and any other person
    identified as senior/key personnel by HPG in the award application, progress report, or any other report
    submitted to the NIH);
  2. HPG has determined that the SFI is related to the research funded through an award; and
  3. HPG has determined that the SFI is a financial conflict of interest.

The information that HPG will make available via a publicly accessible website or in a written response to
any request within five days of request will include, at a minimum, the following:

  1. The Investigator’s name;
  2. The Investigator’s title and role with respect to the research project;
  3. The name of the entity in which the Significant Financial Interest is held;
  4. The nature of the Significant Financial Interest; and
  5. The approximate dollar value of the Significant Financial Interest in the following ranges: $0-$4,999;
    $5,000-$9,999; amounts between $10,000-$19,999 by increments of $5,000; amounts above $20,000 by
    increments of $10,000; or a statement that the interest is one whose value cannot be readily determined
    through reference to public prices or other reasonable measures of fair market value.

Information concerning an individual’s SFI, as limited by this Policy, will remain available for responses to
written requests or for posting via HPG’s publicly accessible website for at least three years from the date
that the information was most recently updated.

9. REPORTING OF FINANCIAL CONFLICTS OF INTEREST

Prior to the expenditure of any funds under an award funded by NIH, HPG will provide to NIH a FCOI report
compliant with NIH regulations regarding any Investigator’s Significant Financial Interest found to be
conflicting and will ensure that the Investigator has agreed to and implemented the corresponding management
plan.

HPG will assign an institutional Official to serve as the FCOI SO (signing Official) within the eRA Commons FCOI
Module. The FCOI SO has the authority to submit FCOI reports to the NIH.

FCOI reports are submitted to the NIH only when a grant or cooperative agreement is active and an FCOI is
identified (i.e., no active award = no FCOI report and no identified FCOI = no FCOI report).

Initial or original FCOI reports

  • Prior to the Expenditure of Funds: When an FCOI is identified upon the issuance of a new
    NIH award, the FCOI SO will submit a NIH “FCOI” (Original) report prior to the expenditure of any funds
    under the award as required by the regulation.
  • Within 60 days of Identifying a new FCOI During Award Period: When an FCOI is identified
    during the period of an NIH-funded award (e.g., a new SFI is identified for an Investigator who is
    participating in the NIH-funded research, upon the participation of an Investigator who is new to the
    research project), the Institution will provide to NIH within 60 days of identifying the FCOI an Original
    FCOI report regarding the financial conflict of interest.

Annual FCOI reports

While the award is ongoing (including any extensions with or without funds), the Institution will provide NIH
with an annual FCOI report that addresses the status of the previously reported FCOI (i.e., an indication
whether the FCOI is still being managed or if it no longer exists) and any changes in the management plan, if
applicable.

REVISION or Mitigation FCOI REPORTS

Following the completion of a retrospective review, the Institution will provide NIH with a Revision if new
information is discovered or a Mitigation Report if bias is found.

Types of FCOI Reports Summary Chart for NIH

REPORT CONTENT WHEN?
New FCOI Report (Initial submission) Grant Number, PI Name, Name of Entity with FCOI, Nature of FCOI, Value of financial interest in
increments, Description of how FI relates to research, Key Elements of Management Plan.		 Prior to the expenditure of funds; Within 60 days of any subsequently identified FCOI
Annual FCOI Report Status of FCOI (i.e., whether FCOI is still being managed or no longer exists) and Changes to
Management Plan, if applicable		 Annual report due at the same time as when the Institution is required to submit annual progress
report, multi-year progress report, or at time of extension
Revised FCOI Report If applicable, update a previously submitted FCOI report to describe actions that will be taken to
manage FCOI going forward or make changes to the originally submitted FCOI report.		 Following the completion of a retrospective review when there is noncompliance with the regulation,
if needed
Mitigation Report Project Number, Project Title, Contact PI/PD, Name of Investigator with FCOI, Name of Entity with
FCOI, Reason for review, Detail, Methodology, Findings and Conclusion		 When bias is found retrospective review.

10. TRAINING REQUIREMENTS

Each Investigator will be informed about HPG’s Financial Conflict of Interest Policy and be trained on the
Investigator’s responsibility to disclose foreign and domestic SFIs per this policy and of the FCOI regulation
at 42 CFR Part 50 Subpart F. FCOI training will occur prior to an Investigator engaging in PHS/NIH-funded
research, at least every four years, and immediately as defined below, when any of the following circumstances
apply:

  1. HPG revises this Policy or procedures related to this Policy in any manner that affects the requirements of
    Investigators;
  2. An Investigator is new to HPG research under an NIH award (training is to be completed prior to his/her
    participation in the research); or
  3. HPG finds that an Investigator is not in compliance with this Policy or a management plan issued under this
    Policy (training is to be completed within 30 days in the manner specified by the Designated Official(s)).

In fulfillment of the FCOI training requirement of the FCOI regulation, HPG requires its investigators to
complete the National Institutes of Health’s Financial Conflict of Interest tutorial located at https://grants.nih.gov/grants/policy/coi/tutorial/story_html5.html
in accordance with the requirements and expectations of this Policy.

11. FAILURE TO COMPLY WITH HPG’S FINANCIAL CONFLICT OF INTEREST POLICY APPLICABLE TO NIH FUNDED
AWARDS

Whenever HPG identifies an SFI that was not disclosed, identified, reviewed, or managed in a timely manner, the
Designated Officials Committee will, within 120 days, review the SFI, determine whether the SFI is related to
research; determine whether an FCOI exists, and if so, implement on at least an interim basis, a management plan
that shall specify the actions that have been and will be taken to manage such FCOI going forward. HPG will also
submit an FCOI report to the PHS/NIH via the eRA Commons FCOI Module.

In addition, whenever an FCOI is not identified or managed in a timely manner, including:

  • failure by the Investigator to disclose an SFI that is determined by the Institution to constitute an FCOI;
  • failure by the Institution to review or manage such an FCOI; or
  • failure by the Investigator to comply with a management plan;

HPG will within 120 days of determining non-compliance:

  1. Complete a retrospective review of the Investigator’s activities and the PHS/NIH-funded research project to
    determine whether any NIH-funded research or portion thereof conducted during the period of the
    noncompliance was biased in the design, conduct, or reporting of research;
  2. Document the retrospective review consistent with the regulation at 42 CFR 605(a)(3)(ii)(B) or as described
    in NIH’s FAQ I.2. at https://grants.nih.gov/faqs#/financial-conflict-of-interest.htm?anchor=52888.

If bias is found, HPG shall notify NIH promptly and submit a mitigation report per the regulation at 42 CFR
50.605(a)(3)(iii) or as described in NIH’s FAQ I.3. at https://grants.nih.gov/faqs#/financial-conflict-of-interest.htm?anchor=52896
to NIH via the eRA Commons FCOI Module that shall address the following:

  1. Impact of the bias on the research project; and
  2. HPG’s plan of action or actions taken to eliminate or mitigate the effect of the bias.

Thereafter, HPG shall submit FCOI reports annually to NIH in accordance with the regulations and terms and
conditions of the award agreement. Depending on the nature of the Financial Conflict of Interest, HPG may
determine that additional interim measures are necessary with regard to the Investigator’s participation in the
research project between the date that the Financial Conflict of Interest is identified and the completion of
HPG’s independent retrospective review. If bias is not found, no further action is required.

12. CLINICAL RESEARCH REQUIREMENTS

If HHS determines that one of its funded clinical research projects whose purpose is to evaluate the safety or
effectiveness of a drug, medical device, or treatment has been designed, conducted, or reported by an
Investigator with a Financial Conflict of Interest that was not managed or reported by HPG, HPG shall require
the Investigator involved to disclose the Financial Conflict of Interest in each public presentation of the
results of the research and to request an addendum to previously published presentations.

13. SUBRECIPIENT REQUIREMENTS

A subrecipient relationship is established when federal funds flow down from or through HPG to another individual
or entity, and the subrecipient will be conducting a substantive portion of a PHS-funded research project and is
accountable to HPG for programmatic outcomes and compliance matters. Subrecipients, who include but are not
limited to collaborators, consortium members, consultants, contractors, subcontractors, and sub-awardees, are
subject to HPG’s terms and conditions, and as such, HPG will take reasonable steps to ensure that any
subrecipient Investigator is in compliance with the federal FCOI regulation at 42 CFR Part 50 Subpart F.

HPG will incorporate as part of a written agreement with the subrecipient terms that establish whether HPG’s FCOI
Policy or that of the subrecipient’s institution will apply to the subrecipient Investigator(s). See the NIH
Grants Policy Statement Section: Written Agreement at https://grants.nih.gov/grants/policy/nihgps_html/section_4_administrative_and_other_requirements.htm.

If the subrecipient’s FCOI policy applies to the subrecipient Investigator, the subrecipient institution will
certify as part of the agreement with HPG that its policy is in compliance with the federal FCOI regulation. In
this situation, the agreement shall specify the time period for the subrecipient to report all identified FCOIs
to HPG in sufficient time to enable HPG to provide timely FCOI reports as necessary to the PHS/NIH as required
by the regulation (i.e., prior to the subrecipient’s expenditure of funds and within 60 days of the
subrecipient’s identification of an FCOI during the period of an award). Therefore, the written agreement may
establish a reporting requirement of FCOIs identified during the period of an award to be submitted to HPG
within 50 or 55 days of the subrecipient’s identification of an FCOI to allow HPG to report the FCOI within the
60-day period. The HPG assigned FCOI DO will submit the FCOI report (subrecipient report) to the NIH via the eRA
Commons FCOI Module.

If the subrecipient cannot provide the certification of compliance with the FCOI regulation, the agreement shall
state that the subrecipient Investigator is subject to HPG’s FCOI Policy for disclosing SFI(s) that are directly
related to the subrecipient’s work for HPG. Therefore, HPG will require the submission of all Investigator
disclosures of SFIs to HPG. The agreement will include sufficient time period(s) to enable HPG to comply timely
with its review, management, and reporting obligations under the regulation. When an FCOI is identified, HPG
will develop a management plan, monitor subrecipient Investigator compliance with the plan, and submit an FCOI
report (subrecipient report) to the NIH through the eRA Commons FCOI Module for any FCOIs identified for a
subrecipient Investigator.

14. MAINTENANCE OF RECORDS

The Institution will keep all records of all Investigator disclosures of financial interests and the
Institution’s review of or response to such disclosure, whether or not a disclosure resulted in the
Institution’s determination of a Financial Conflict of Interest, and all actions under the Institution’s policy
or retrospective review, if applicable. Records of financial disclosures and any resulting action will be
maintained by the Institution for at least three years from the date of submission of the final expenditures
report or, where applicable, from other dates specified in 45 C.F.R. 75.361 for different situations. HPG will
retain records for each competitive segment as provided in the regulation.

15. ENFORCEMENT ACTIONS: INVESTIGATOR NONCOMPLIANCE WITH THIS POLICY

Compliance with this policy is a condition of employment and/or participation for all applicable Investigators.
Therefore, such Investigators who fail to comply with this policy are subject to discipline, including letters
of reprimand, restriction on the use of funds, termination of employment or contract, and/or disqualification
from further participation in any PHS/NIH-funded research, etc., as may be deemed appropriate.

16. USEFUL FCOI AND NIH RECORDS

17. POINT OF CONTACT

If you have a question related to the Financial Conflict of Interest Policy of HPG or would like to disclose
a financial interest, contact us using the information below. Contact HeartPoint Global Inc. Brian Seidman
at info@heartpointglobal.com.

18. PUBLIC AVAILABILITY

A copy of the current version of HeartPoint Global Inc.’s Financial Conflict of Interest Policy is available on
the HPG website at www.heartpointglobal.com/FCOI.

REVISION HISTORY RECORD

Rev # Section/Page Reason for Change Effective Date
000 N/A Initial release 16 July 2025

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