Instructions for Use

This log is the Compliance Officer's register of every conflict of interest disclosure and its determination. POL-009 (Conflicts of Interest), Section 5.0, Steps 4 and 6, requires the Compliance Officer to record routine determinations in a disclosure log and to report a summary of disclosures and management plans to the Compliance Committee at least annually. This register satisfies those requirements.

Who maintains this log: the Compliance Officer. The log is retained in the compliance program files and is not circulated.

How to use this log:

1. Record one row for every disclosure received (CFM-002), including annual "no conflicts" attestations.
2. Enter the workforce member's name and role, the date of the disclosure, and the trigger (at hire, annual refresh, or change within 10 business days).
3. Summarize what was disclosed in one or two lines. For a "no conflicts" attestation, record "No conflicts attested."
4. Record the determination, conflict or no conflict, and the date it was made.
5. Where a conflict exists, record the management plan reference (CFM-003) and keep the plan status current (Active, Under review, or Closed).
6. At least annually, use this log to prepare the summary report of disclosures and management plans for the Compliance Committee (see the note below the register).
7. Disclosures involving the Compliance Officer are logged by the Executive Director; disclosures involving the Executive Director are logged by the Compliance Committee, consistent with the routing in POL-009, Section 5.2.

Form Realization and Fallback

This is the canonical, authoritative version of Form CFM-004, maintained in the compliance documentation. It defines the columns, fields, and structure that any realization of the log must capture.

ABAS may maintain this log through an electronic realization: a spreadsheet, a database, or a compliance management system that records submissions directly to company files. Any electronic realization must capture the same content and carry the form identifier CFM-004, so the policy and SOP refer to the log by its identifier rather than to any one channel.

The documented log here is always available as a fallback. It can be printed and maintained on paper whenever the electronic register is unavailable or a paper record is otherwise needed, for example during a system outage or a loss of internet access.

Alternate-language and electronically read (screen-reader) versions are derived from this canonical form and must match it, so the same content stays authoritative across every realization.

Disclosure Log

Conflict of Interest Disclosure Log

Maintained by: Compliance Officer · Location: Compliance program files

Record one row per disclosure received. The trigger is one of: At hire, Annual, or Change (within 10 business days). The determination is Conflict or No conflict. Plan status applies only where a conflict exists: Active, Under review, or Closed.

Annual Summary Report to the Compliance Committee

At least annually, the Compliance Officer prepares a summary from this log for the Compliance Committee (POL-009, Section 5.0, Step 6). The summary reports counts and themes, not individual identities unless the Committee requires them.

Form CFM-004 · Owning policy: POL-009 (Conflicts of Interest). Version number and effective date are set in ABAS's document-control record at adoption.

Retention

The disclosure log is part of the compliance program files. Per POL-009, Section 5.0, Step 6:

• The Compliance Officer retains the log, the underlying disclosure forms (CFM-002), and any management plans (CFM-003) in the compliance program files.
• The log is the source for the at-least-annual summary report to the Compliance Committee.

The Compliance Officer is custodian of the disclosure log and maintains it at a company-owned level, consistent with the compliance program's records practices.