COI V13 BONIXER · Conflicts of Interest · KCF Integration · CRM Mapping

V13 COI ADDITIONS

V13 adds KCF integration and CRM mapping to every COI entry. COI score is now co-rated with KCF: a high-KCF actor with a COI is a structural risk. A low-KCF actor with a COI is a watch, not a block. The CLO AND gate logic is unchanged — any red blocks the decision path. V13 maps every COI to a CRM domain so the CLO bench can see relationship context alongside the conflict.

V13 COI FORMULA

COI_risk = COI_severity × KCF_weight / γ₁

COI_severity: RAW score 0.0 (clean) → 1.0 (full conflict)
KCF_weight: KCF score (0–10) of the actor — higher KCF = higher structural COI risk
γ₁ = 14.134725141734693 (normalizer — keeps COI risk bounded)
Result: COI_risk ∈ [0.0, 1.0] — GREEN < 0.3 · YELLOW 0.3–0.6 · RED > 0.6
CLO AND gate triggers when any actor COI_risk > 0.6

COI REGISTER V13

CLEAN — NO ACTIVE COI

GREEN ✅

Kay Joffe (CEO/CTO): No external board seats. No competing ventures. EOSE Labs Inc. + DESEOF + PEMOS are the fleet — no outside overlap. Previous employers (Westpac, TD, CTC) all fully separated. No residual IP claims.

KCF: 10 · COI severity: 0.0 · COI_risk: 0.0 / γ₁ = 0.000
CRM domain: kayyo@pemos.ca · msi01/pemos.ca
SOSTLE: L0 (public) — COI clean status is public knowledge

CLEAN — DUAL ROLE DECLARED

GREEN ✅

Amani Joffe (GC): EOSE Labs Inc. + Scarborough Transit Connect (~$10B SSE subway project). Both infrastructure, non-competing. Declared and clean. STC is a public infrastructure contract — no technology IP overlap with EOSE fleet. Dual role publicly disclosed.

KCF: 9 · COI severity: 0.05 · COI_risk: 0.45 / γ₁ = 0.032 (GREEN)
CRM domain: ayyo@eose.ca · msclo/eose.ca
SOSTLE: L1 (internal) — dual role disclosed internally

WATCH — OSS GATE ACTIVE

YELLOW ⚡

JOHN (OSS Library): If OSS candidates overlap with employer IP, COI gate opens. Declare before any public release. Any tokenmonster/jsondec contribution must be reviewed by CLO bench before open-sourcing. Watch gate is preventive, not triggered.

KCF: 7 · COI severity: 0.15 (potential) · COI_risk: 1.05 / γ₁ = 0.074 (YELLOW)
CRM domain: john@eose.ca · msi01/pemos.ca
SOSTLE: L2 — OSS declarations at L2 gate before L0 publication

WATCH — CONSULTING GATE

YELLOW ⚡

SIGNALS (PEMCLAU): GraphRAG methods used internally — any external consulting using PEMCLAU methodology would be a COI. CLO bonixer watches both fleet IP exposure and consulting engagement scope. No current consulting active — preventive watch only.

KCF: 8 · COI severity: 0.10 (potential) · COI_risk: 0.80 / γ₁ = 0.057 (YELLOW)
CRM domain: signals@eose.ca · yone/pemos.io
SOSTLE: L2 — consulting scope declared at L2 before engagement

SOSTLE L3 WALL

SOSTLE L3 🔒

Any information shared between CLO bench members that could create a COI is walled at SOSTLE L3. The wall is maintained by msclo (yLAW) as the legal silo. msi01 (yUNI) does not carry L3+ CLO information unless explicitly promoted through the AND gate.

Wall keeper: msclo · yLAW
AND gate: CLO (Amani) + one crew member must both approve promotion
SOSTLE: L3 — need-to-know · not surfaced in L0-L2 views

CRM × COI MAPPING V13

Actor	COI Status	KCF	CRM Domain	SOSTLE Gate	V13 Action
Kay Joffe (CEO)	CLEAN ✅	10	kayyo@pemos.ca	L0 (public)	None — monitor annually
Amani Joffe (GC)	CLEAN ✅	9	ayyo@eose.ca	L1 (internal)	Dual role re-declared at each contract renewal
JOHN (OSS)	WATCH ⚡	7	john@eose.ca	L2 → L0	OSS release checklist: CLO review before publish
SIGNALS (PEMCLAU)	WATCH ⚡	8	signals@eose.ca	L2 → L0	Consulting scope agreement before any external engagement
Harvey Specter (CLO bench)	CLEAN ✅	8	harvey@eose.ca	L3	L3 wall maintained · no external clients with fleet overlap
Ruth Ginsburg (CLO bench)	CLEAN ✅	9	ruth@eose.ca	L3	L3 wall maintained
Thurgood Cochran (CLO bench)	CLEAN ✅	8	cochran@eose.ca	L3	L3 wall maintained
IMHOTEP (Admiral)	CLEAN ✅	10	imhotep@pemos.ca	L1	Fleet-internal only · no external overlap

CLO AND GATE RULES — V13

AND GATE RULE: Any COI_risk > 0.6 triggers CLO AND gate. Two signatures required: CLO (Amani) + one crew member.
V13 ADDS: KCF weight in COI formula. High-KCF actors with any COI get elevated to WATCH automatically.
SOSTLE L3 WALL: Maintained by msclo (yLAW). msi01 (yUNI) carries L0-L2 only.
ESCALATION PATH: L0 (public) → L1 (internal) → L2 (declared gate) → L3 (CLO only) → L4 (AND gate) → L5 (closed)
COI DATA LIVES: SOSTLE L3+ — not surfaced in L0-L2 views. COI bonixer is a health signal, not a disclosure document.
CLEAN AS OF: Day 97 (2026-05-11) · No active COIs · All watches are preventive, not triggered.