Governance & Compliance

ValoResearch, Inc. is governed under a formal corporate structure with its ownership and funding restricted entirely within its parent group. The company is a wholly‐owned subsidiary, meaning the parent company holds 100% of its equity. There are no external shareholders, third-party investors, or outside sources of capital. All funding comes via documented intercompany transfers or loans, under the parent’s finance policies. Consistent with U.S. compliance expectations, the beneficial ownership of ValoResearch, Inc. is fully disclosed: the parent entity is identified as the sole beneficial owner in accordance with FinCEN requirements.

Oversight and Governance

The Board of Directors of ValoResearch, Inc. (and by extension its parent) holds ultimate responsibility for governance, though it delegates day-to-day management to executive officers.

In line with Delaware corporate governance standards, the Board has established reporting and information systems to ensure timely review of all material matters. As one authority notes, directors “must first assure [themselves] that the corporation’s information and reporting system is…adequate to assure the board that appropriate information will come to its attention in a timely manner”. ValoResearch, Inc. emulates this by providing regular management reports on its operations (albeit limited to internal research activities), finances, and any compliance issues.

ValoResearch, Inc. ensures that any Compliance or Finance Officer has a direct reporting line to senior governance bodies. The Board (or its designees) reviews budgets, approves intercompany funding, and monitors risk-management processes on an ongoing basis.

Compliance Program and Scope

ValoResearch, Inc. maintains a comprehensive compliance program covering all applicable U.S. laws, regulations, and internal policies. This includes corporate and tax law, anti-money-laundering (AML) and counter-terrorism financing rules, data protection, labor and employment law, and any industry-specific regulations relevant to research activities. Internally, the Company enforces a strict Code of Conduct and ethics policy: all personnel are required to uphold the highest ethical standards and “must comply with all applicable laws”. Key elements of the compliance program include:

• Code of Conduct and Ethics: A written code emphasizes honesty, integrity, and lawful behavior. Employees and directors must avoid conflicts of interest and protect company assets. Any concerns or violations can be reported through established channels.
• Anti-Corruption/AML Policies: Although ValoResearch, Inc. has no commercial dealings with customers or suppliers, it adheres to standard AML/KYC procedures internally. Any intercompany fund transfers are vetted and documented, consistent with KYB best practices such as verifying the source of funding. (All funds originate from the known parent, so the risk of illicit funding is effectively nil.)
• Financial Controls and Accounting Standards: The company follows U.S. GAAP (or IFRS) in maintaining its books and records. All transactions (primarily intercompany charges and expense reimbursements) are recorded accurately and reviewed regularly.
• Internal Policies: Additional policies (IT security, confidentiality, expense approval, and conflict-of-interest declarations) apply to all staff. Training or periodic briefings reinforce that compliance is mandatory, not optional.

ValoResearch, Inc. operates under a closed-system mandate. Its activities are confined to exploratory research, internal prototyping, and epistemic model development. It does not provide services, solicit capital, or manage funds for external entities.

Key Compliance Facts

• No third-party client accounts exist
• No capital is accepted from external sources
• No externally deployed systems, APIs, or integrations
• No services are offered, licensed, or subcontracted
• No public engagement, offerings, or investor relations functions
• No assets are under management, custody, or control for external entities

All financial records, systems access, and research operations are internally audited under ValoCRM group controls.

Financial Governance and Source of Funds

ValoResearch, Inc. is non-commercial: it has no revenue, no sales activities, and it holds no third-party capital. Its financial resources are provided exclusively by internal corporate sources. A formal budget and funding plan is approved by the parent company’s management. All capital injections and expense reimbursements are executed as intercompany journal entries or loans, subject to the parent’s treasury and accounting controls. Each transfer of funds is supported by board-approved documentation. The “source of funds” is fully traceable.

Financial governance follows standard corporate controls: an assigned Finance Officer oversees accounts payable/receivable and bank accounts, and all expenditures require dual approval. The company conducts periodic reconciliations and enforces segregation of duties appropriate to its size.

Many aspects of financial governance are handled by the parent’s shared services or accounting teams. External auditors (if engaged) or internal audit reviews financial statements annually, confirming adherence to policies and control effectiveness.

Legal Disclosures and Reporting

ValoResearch, Inc. complies with all legal and regulatory disclosure requirements. It is duly incorporated and in good standing in Delaware and files required reports, tax returns, and financial statements with relevant authorities. Its certificate of incorporation and bylaws reflect its purpose as an internal R&D entity. The company clearly states in filings that it does not engage in third-party business.

Legal Disclosures & Institutional Position

Compliance Statements

ValoResearch, Inc. is not registered or operating as a financial services entity. It does not engage in banking, trading, investment advisory, custody, tokenization, or regulated fintech activity.

The entity does not offer products or services to the public and does not solicit or receive revenue from any external source.

All operations are conducted under private corporate governance and are aligned with internal R&D objectives only.

No intellectual property, source code, or system output is licensed, sold, distributed, or exposed outside ValoCRM-controlled infrastructure.

Documentation Available Upon Request

• Certificate of Incorporation (Delaware)
• Intercompany Capital Allocation Agreement
• Purpose of Account Statement
• Source of Funds Declaration
• Internal Governance Summary
• Risk Controls Policy
• Internal Use and Non-Commercialization Statement

Compliance Integrity

ValoResearch, Inc. affirms that it operates exclusively within the scope of a private R&D entity. It does not engage in any form of public distribution, client engagement, or third-party contracting. All funds originate from a known corporate parent, all activity is internally scoped, and no technology or service is exposed beyond the internal research environment.

All inquiries related to legal structure, source of funds, or internal operations may be directed to the compliance office of ValoCRM SAS.