Record and Publication Policy

Version 1.0. Effective Date: the date shown at the top of this page. Operator: Reseated Councils, Inc., a Delaware nonprofit nonstock corporation. Schedule D applies. Order of precedence: Certificate, Bylaws, Program Rules, then this Policy, the Terms and the Privacy Notice. This Policy is part of the Program Rules once the Board adopts it.

1. Purpose

This Policy sets how Reseated collects, reviews, publishes, corrects and archives the Public Record. Its aims are to make the record accurate and useful while limiting harm to Reporters and the people and organizations named in it.

2. Report intake

2.1 Structured fields only. The report form collects these fields, and only these fields are eligible for publication:

2.2 Private fields. Name, email, city, narrative text, attachments and the Other-Party Field are private.

2.3 Other-Party Field. We do not publish the Other-Party Field. It does not appear in any public page, export, feed, search result or interface. Only the Record Editor and staff authorized in writing may see it. We use it to group Reports internally and to check for duplicates. Section 7.3 sets the only other permitted use.

2.4 Accurate wording replaces “anonymous.” The report form removes the words “Keep me anonymous” and “The other side never sees who reported.” It uses this wording instead:

“We do not publish your name, your email or the organization you name. Our authorized staff and service providers can see them. We may be required to disclose them by law, for example under a subpoena or court order. Where the law allows, we will tell you before we do. Details you describe could still allow someone to recognize you, so leave out anything you are not prepared to have linked to you.”

The checkbox reads “Do not publish my name.”

3. Public Summary

3.1 A Record Editor writes or approves each Public Summary. A summary contains no more than 280 characters.

3.2 A Public Summary must not contain:

• names of people or organizations
• exact dates, amounts or locations below the public bands
• product names, contract numbers or any unusual detail that would identify the Reporter or the other party

3.3 No Public Summary is published by automated means alone. We do not currently use AI tools to draft summaries; if we ever do, a person approves the final text.

4. Threshold of 5

4.1 A Public Cell is shown only if it reflects Reports from at least 5 different Program Members.

4.2 We hide, merge or round any other cell that would let someone work out a hidden cell by subtraction.

4.3 Filters cannot be combined to produce a result below the threshold.

4.4 An individual Public Summary is published only when its combination of business type, size band, country, region and problem category matches at least 5 Reports. Otherwise it stays unpublished until that threshold is met, or is published with broader fields.

5. Consultations and Contributions

Consultation comments are published with the attribution the contributor chose and marked “issued without formal editing” (Terms section 7.4). Record Editors may redact personal data about third parties and content that breaches Terms section 9.

6. CEO Seat Files and Signatory files

6.1 Published criteria first. Before we name any organization or Named Executive, the CEO Seat criteria must be published as a dated, versioned page. Each CEO Seat File states which criterion it relies on.

6.2 Facts from cited sources. Every factual statement in a file cites a public source, such as a regulatory filing, a company website or an official register.

• The Record Editor confirms that each Named Executive held the stated role on the file date and on the date of any letter.
• Where a filing shows a future effective date for an appointment, the file names the person who held the role on the relevant date.

6.3 14 days’ notice. We send the organization the draft file at least 14 days before we publish it. The notice goes to its published investor-relations, legal or corporate-communications contact.

6.4 Neutral Statuses only. The permitted Statuses are:

• Invited
• Acknowledged
• Responded
• Declined
• Signed
• Commitment reported met
• Commitment reported not met
• Not kept
• Under review
• Withdrawn

Each Status shows its date. No other labels, ratings or characterizations are used.

6.5 Replies in full. We publish any reply in full alongside the file. We redact only:

• personal data of individuals other than the Named Executive
• unlawful content
• material the sender marks confidential

Each redaction is marked.

6.6 Two-person review. Two people, at least one of them a Record Editor, approve any new file, any change of Status and any edit to a published file. Each approval is logged.

6.7 Right of reply before “Not kept” or “Commitment reported not met.” We assign either Status only after all of the following:

1. written notice to the Signatory stating the evidence relied on
2. at least 14 days for the Signatory to respond
3. two-person review of the response
4. publication of the response with the Status

6.8 A “Verified” label or badge has the narrow meaning in Terms section 14.2.

7. “Practices, not parties”

7.1 Reports, Fixes, consultations and Council documents describe practices. They do not name the organizations involved.

7.2 The only exceptions are CEO Seat Files and Signatory files. They may name an organization and its Named Executive only:

• as an invitee or Signatory
• under published criteria
• for role-related facts

7.3 A CEO Seat File must not state or imply that any Report concerns the named organization. Other-Party Field data may inform internal prioritization only in aggregate. The aggregate must cover at least 5 Reports from at least 5 different Program Members, and it is never published or described as the reason for naming.

8. Corrections and corrigenda

8.1 Anyone may request a correction by emailing legal@reseated.com or using the link on each record.

8.2 Response times:

• acknowledgment within 2 business days
• decision within 10 business days
• if the request alleges a material error about a named person or organization, an interim “Correction requested; under review” note within 2 business days

8.3 A correction is published as a numbered corrigendum (format RC/C/YYYY/n). The original text stays visible with the change marked, except where section 9 or 10 requires removal.

9. Takedown pending review

9.1 We restrict public access to the disputed content within 2 business days of receiving a complaint under Terms section 11 or a privacy objection that:

• identifies specific content
• gives reasons that are not manifestly unfounded

9.2 We tell the contributor, who may respond within 7 days.

9.3 We decide within 15 business days of restricting the content. The outcome is one of: restore, correct, add a response, redact or remove. We give both sides reasons and the review route in Terms section 10.4.

10. Unlisting and archiving

10.1 Unlisting. We remove a name from the Roll or from a public attribution within 30 days of a request.

10.2 Removal requests: four-part test. For requests to remove other content, the Record Editor records answers to four questions:

1. Do we have a lawful basis to keep publishing it?
2. Does it have public-interest value, such as accountability for a public commitment or the integrity of a vote record?
3. What harm does it cause the person?
4. Would a less intrusive step, such as redaction, generalization or removal of contact details, meet the concern?

10.3 Role-related facts in CEO Seat Files generally stay public. Personal details beyond the role are removed on request.

10.4 Non-public archive copies are kept only for the periods in the Privacy Notice. A numbered record may show “withdrawn” or “redacted.”

11. Records of decisions

The Record Editor logs every publication, correction, takedown, Status change and unlisting decision, with reasons and the reviewers involved. Logs are kept for 6 years and reported to the Board each quarter.

12. Changes

Material changes are posted with a new version and Effective Date and notified to account holders by email at least 15 days in advance.