Thinkline

Legal

Effective date: May 6, 2026

This Thinkline Expert MNPI and Compliance Policy (this “Policy”) explains the rules that apply when experts use Thinkline's platform, participate in onboarding, publish content, or provide consultations, interviews, calls, or other services through Thinkline. This Policy is incorporated into the Thinkline Expert Terms and any applicable engagement-specific terms.

The purpose of this Policy is simple: Thinkline is designed to help clients access lawful, ethical, high-value expertise without receiving material non-public information, confidential information, trade secrets, or other information that should not be shared. Thinkline expects every expert to understand and comply with these rules before, during, and after every interaction through the platform.

1. Core Rule

Do not disclose or confirm material non-public information (“MNPI”), confidential information, trade secrets, personal data, or any other information that you are not authorized to share.

If there is any doubt, do not answer the question, do not upload the content, do not confirm the assumption, and do not continue the discussion until the issue has been clarified with Thinkline.

2. What Is MNPI?

For purposes of this Policy, MNPI means information that is both:

  • Material — a reasonable investor would likely consider the information important in making an investment decision; and
  • Non-public — the information has not been broadly disseminated to the market in a way that makes it available to ordinary investors.

Examples may include non-public information about a public company's or issuer's:

  • financial results or trends before public release;
  • earnings guidance, margins, pricing, bookings, pipeline, or sales performance not yet public;
  • mergers, acquisitions, financings, restructurings, layoffs, or major contracts not yet announced;
  • clinical trial data, product launches, regulatory actions, inspections, approvals, or setbacks not yet public;
  • supply constraints, customer wins/losses, production data, or strategic shifts that are not public; or
  • any other non-public information that could affect the price of securities if disclosed.

MNPI can be shared improperly even if no specific number is given. Confirming, validating, narrowing, signaling, or indirectly implying non-public facts can create the same risk.

3. What Else You Must Not Share

Even if information is not MNPI, you must not disclose:

  • confidential or proprietary information of any current or former employer, client, customer, supplier, counterparty, or other third party;
  • trade secrets or internal know-how not authorized for disclosure;
  • information covered by an NDA, confidentiality clause, employment policy, or fiduciary duty;
  • non-public government information or restricted information obtained through public service, advisory roles, or regulated positions;
  • personal data, health data, or other protected information about an identifiable individual; or
  • any content or information that would cause you to violate applicable law, contract, or professional duty.

4. What You May Discuss

Experts are expected to share high-level, experience-based, non-confidential insights drawn from lawful sources and personal expertise, such as:

  • public information and your interpretation of it;
  • industry trends discussed at a high level;
  • your historical experience, provided it does not reveal confidential or non-public information;
  • workflows, market structure, customer behavior, and operational observations described in generalized terms; and
  • opinion, judgment, and analysis that do not rely on restricted information.

When responding, think in terms of patterns, frameworks, and general observations, not internal facts, unpublished metrics, or confidential documents.

5. Topics That Require Extra Caution

The following situations present elevated risk and require special care:

  • you are a current employee, officer, director, consultant, or contractor of a public company or regulated entity;
  • you recently left a company and still possess non-public knowledge that may remain sensitive;
  • you serve on a board, advisory board, expert committee, audit committee, or investment committee;
  • you have access to non-public information through diligence, deal work, clinical work, regulatory processes, procurement, or enterprise sales;
  • the client appears to be seeking near-term company performance data, unreleased product or pipeline information, or deal-specific information; or
  • you are asked repeated narrowing questions intended to triangulate non-public facts.

In these situations, you should decline the topic or end the discussion unless you are certain you can respond at a sufficiently high level without using restricted information.

6. Red-Flag Questions

You must stop and decline to answer questions such as:

  • “What are this quarter's numbers before earnings?”
  • “Can you tell us whether demand is above or below guidance?”
  • “Has the company already decided to acquire or divest a business?”
  • “What are the unpublished results of the trial/inspection/launch?”
  • “Can you tell us what your employer's top customers are doing right now?”
  • “Is it fair to say margins are down materially this month?”
  • “Even if you can't give a number, are we directionally right?”
  • “Off the record, can you confirm what management is seeing internally?”

These are examples only. The rule is broader: if the question calls for non-public, confidential, or otherwise restricted information, do not answer it.

7. Your Obligations Before Each Engagement

Before participating in any call, interview, written response, or publication through Thinkline, you must:

  • consider whether you are subject to any employer, board, client, fiduciary, legal, or contractual restriction;
  • decline the engagement if the topic creates an unreasonable risk that you would need to disclose restricted information;
  • disclose to Thinkline any relevant conflict, restriction, or risk issue if requested or if doing so is necessary to avoid a compliance problem;
  • review any engagement-specific instructions or client restrictions presented through the platform; and
  • be prepared to refuse any question or topic that crosses the line during the engagement.

Thinkline may ask you to complete pre-engagement attestations, screenings, or certifications. You must answer those truthfully and completely.

8. Your Obligations During an Engagement

During any call, interview, AI onboarding session, written response, or publication workflow, you must:

  • answer only from lawful, non-confidential sources;
  • stay at a high level when discussing sensitive topics;
  • refuse to answer any question that would require disclosure of MNPI, confidential information, trade secrets, or personal data;
  • avoid confirming or validating a client's non-public thesis, assumption, rumor, or model;
  • avoid discussing unpublished data points, internal documents, or protected communications; and
  • end or pause the discussion if the client continues to press for restricted information.

A helpful script is: “I can discuss that only at a high level based on public information and general experience; I cannot share non-public or confidential information.”

9. Your Obligations for Published Content and AI Interviews

The same compliance rules apply to content you publish or make searchable through Thinkline, including profile text, written answers, uploaded materials, transcripts, and AI-generated or AI-assisted onboarding interviews.

Do not upload, approve, or publish any content that includes or reflects:

  • unpublished internal metrics or performance information;
  • confidential project details, deal terms, strategy documents, or customer-specific information;
  • restricted product, regulatory, clinical, or transaction information;
  • personal data or other legally protected information; or
  • information copied from materials you do not have the right to share.

If Thinkline provides a review or approval step before publication, you are responsible for reviewing the content carefully and withholding approval if the content includes restricted information.

10. If a Problem Arises

If you believe you may have disclosed restricted information, or if a client asks for information you should not provide, you must act immediately.

You must:

  • stop the discussion or publication workflow;
  • tell the client or Thinkline representative that you cannot discuss that topic;
  • promptly notify Thinkline at compliance@thinkline.co or through the designated platform workflow; and
  • cooperate reasonably with any follow-up review, correction, takedown, or investigation.

Prompt escalation is important. Compliance frameworks for expert networks emphasize acting quickly on red flags and maintaining processes for training, review, and intervention.

11. Screening, Monitoring, and Enforcement

To protect experts, clients, and Thinkline, Thinkline may use screening, training, attestations, keyword review, matching controls, conflict checks, moderation tools, logging, or other compliance processes in connection with the Services.

Thinkline may, in its discretion:

  • reject or remove experts, topics, or engagements;
  • require additional certifications or employer-related confirmations;
  • remove or edit content;
  • suspend payouts associated with problematic content or conduct;
  • suspend or terminate accounts; and
  • make disclosures or reports where required by law or reasonably necessary to protect Thinkline, clients, markets, or third parties.

These measures are consistent with industry practice emphasizing written restrictions, training, certifications, screening, and rapid action on red flags.

12. No Advice to Circumvent Rules

Do not attempt to work around this Policy by:

  • speaking “off platform” or “off the record”;
  • using coded language, hints, or partial confirmations;
  • sharing documents outside the platform;
  • asking a client to infer an answer from narrowed ranges, directional cues, or body language; or
  • routing information through another person, account, or medium.

If the information should not be shared directly, it also should not be shared indirectly.

13. Expert Certifications

By using Thinkline as an expert, and each time you participate in an engagement or publish content through Thinkline, you certify that:

  • you understand this Policy;
  • you will not disclose MNPI, confidential information, trade secrets, personal data, or other restricted information;
  • you will comply with your legal, contractual, and professional obligations;
  • you will decline or stop any interaction that would require improper disclosure; and
  • you will promptly report any actual or suspected issue to Thinkline.

14. Questions

If you are unsure whether something may be discussed or published, treat the issue as restricted until clarified. Do not guess.

Questions about this Policy or specific compliance concerns should be directed to compliance@thinkline.co before proceeding.