Independence, Ethics & Conflict of Interest

PrepGraph's activity has three parts: learning software sold to students, families and schools, from school to first job; an internal research and development function; and this Council. The first two are commercial. This one is not, and the rules in the Charter and the independence policy are what hold the boundary. That sentence is the whole of what this instrument says about the funder's other work. No PrepGraph product is named here and no address for one is given: Charter Article 5 forbids Council material naming a commercial product.

PrepGraph convenes the Council for reasons it states plainly. A market with sober norms about AI in classrooms is the market that lasts, and PrepGraph wants to help set those norms rather than leave them to hype. It wants to hear what principals, correspondents and trustees actually need. And the norms for AI in Indian schools are being settled this decade by whoever troubles to settle them.

None of that requires a single sale traceable to the Council, and this policy forbids attempting to trace one. Nothing said, shown, written or circulated in the course of a Council activity is used in the sale, marketing or promotion of any PrepGraph product or service, in any tender or procurement response, or in product development, roadmap prioritisation, pricing or competitive analysis, and the annual public record answers that as a yes or no question in those words.

The Council carries PrepGraph's name by choice. The name puts the funder in the title, in the descriptor and in the footer of every output, so that the relationship is stated rather than discovered, and it makes any favourable treatment of PrepGraph impossible to hide.

The name and marks are held on the terms of the Charter's entrenched Article on the use of the Council's name and marks, and the treatment of the name if PrepGraph ceases to convene the Council is settled by that Article and by the entrenched Article that constitutes PrepGraph as bare trustee for the Council. This policy does not legislate on the name and cannot vary those Articles.

The Council's neutrality clause is as follows, and is quoted in full inside any Council output that discusses procurement, adoption or supplier choice: "The Council does not endorse individual procurement decisions or technology vendors. Its role is to advance responsible AI readiness, educator capability and evidence-based innovation in schools."

The Council's standing is as follows, and is quoted in full in every public output, including slides shown at Council activities: "The Council is a voluntary, non-statutory initiative. It is not a government, regulatory or accrediting body, and it does not certify, rate or approve schools, curricula or products."

The Council claims no affiliation with, endorsement by, recognition from or review by any ministry, board, statutory authority, university or international body, and no officer may describe it in those terms in writing or in speech. Where Council material refers to public instruments such as the National Education Policy 2020 or the Digital Personal Data Protection Act 2023, it does so because those are instruments a school already works within. Such references describe the context a school operates in and nothing else.

The Council may publish frameworks, questions, checklists and evidence that help a school reach its own decision. It does not reach the decision, and it does not name the answer.

The following are absolute. They bind the Chair, members, fellows, the Secretariat and PrepGraph as convener. They are written as specific acts rather than principles so that a breach is a question of fact, and so that an outsider can check most of them without access to any internal paper.

Where a rule is broken, the breach and the remedy are published, whether or not the breach was discovered internally.

The prohibitions above are only as good as the separation behind them, so the separation is built into the systems rather than left to judgement.

The Council keeps its own register of participants, members, fellows and correspondents, in a system of record separate from PrepGraph's commercial systems. There is no synchronisation, no scheduled export, no shared identifier and no enrichment of one from the other in either direction. Read access is limited to named Secretariat members with Council duties. Council correspondence is sent from council@prepgraph.com and not through PrepGraph's marketing or customer-relationship platform, and it carries no open tracking, click tracking or tracking pixel; a recipient can confirm both from the message itself. Council web pages carry no analytics that identify an individual reader.

PrepGraph's sales, marketing, partnership and customer-success functions have no access to the Council register and receive no extract, summary, count or list from it. A Secretariat member may not tell a commercial colleague that a named school, principal or teacher took part in Council work, and may not confirm it if asked. Where a person is independently a PrepGraph customer or a prospect through ordinary commercial contact, that relationship proceeds entirely on its own footing and no fact originating in the Council enters it, including the bare fact of participation.

Competitor-relationship data is barred from the Secretariat entirely. The Executive Director and Secretary-General, Rekha Sharma, does not collect, receive, hold or record which supplier of AI products to schools a participant's school uses, on what terms, when a contract renews, or whether a negotiation is under way. Declarations of interest are made to the Reviewer of Concerns, who holds and publishes them.

The Executive Convener, Umesh Sharma, may bring research and technology questions to the Council, say where guidance is missing, present implementation evidence from schools with its provenance and limitations stated, fund and organise studies on the terms the research instrument sets, and convene working groups. He may not approve, amend, delay or withhold any Council publication. He holds no vote — on publication, on standards, on membership, on a vendor question or on anything else — and does not count towards quorum. He does not sit on the ethics review panel and takes no part in its decisions. He is not present when the Council decides any matter in which PrepGraph has an interest. The rule is stated in the same words wherever the office is described: "The Executive Convener may contribute research, evidence and proposals. Council recommendations are determined collectively and are not subject to commercial approval by PrepGraph."

The Director, Education Partnerships and National Outreach, Anisha Sarkar, builds participation inside Council activities: she invites and convenes school leaders, works with school groups and associations, and represents the Secretariat. She may not raise, invite, accept or continue a commercial conversation about a PrepGraph product, price, pilot or contract inside a Council activity. Where a school raises commercial interest during a Council activity, she says at that moment that the conversation moves to PrepGraph's ordinary business channel. She may not present, demonstrate or describe a PrepGraph product at a Council convening, in any format, including in answer to a direct question: the answer to the question is the referral. She may not use a Council invitation list, attendee list or contact detail as a prospect list, or pass one to anyone who would.

A Council convening that becomes a product demonstration is a breach of this policy. Anyone may report it, without standing and without permission from the Chair or the Secretariat, and the protection against retaliation in the section on raising a concern applies. The Reviewer of Concerns inspects these arrangements each Council year and publishes the findings in the Reviewer's own words.

The Council holds personal data because people take part in its work, and for no other reason. It collects name, role, institution and one contact address. It does not collect procurement intent, budget, technology in use, contract dates or renewal timing, and the Secretariat discards such information even when a participant volunteers it in a meeting.

The Council collects no personal data relating to children through participation. Where research involves children, data is handled only under the study protocol described in the next section, with the consent of the school and of a parent or guardian, on a minimal-collection basis, and never in a form that identifies an individual child.

Council data is not sold, rented, licensed or shared with any third party, except a processor engaged under written contract to provide a service to the Council, such as hosting or the distribution of a circular. Council data is not transferred into PrepGraph's commercial systems in any circumstances, and its protection on any change of ownership of PrepGraph is settled by the entrenched Charter Article that constitutes PrepGraph as bare trustee for the Council.

Retention runs by category rather than by one rule, because the categories are governed by different instruments. Contact and participation records are kept for the period of participation and twenty-four months afterwards, then deleted. Declarations of interest, minutes, papers and approved outputs are retained for not less than seven years, as the Charter's Article on meetings, records and minutes requires. Research data is retained for the periods set by the research instrument. A deletion request reaches contact and participation records; it does not reach the records the Charter requires be kept, and a person who asks is told which is which at the time of the request.

The Council holds itself to the standard set by the Digital Personal Data Protection Act 2023, the framework its participating schools already work within. That is a statement of a standard, not a claim of registration, certification or approval by any authority. The Council has no legal personality and cannot itself be a Data Fiduciary. For participation data PrepGraph is the Data Fiduciary, holding that data as bare trustee for the Council on the terms of the Charter, and this policy binds it as processing instructions. Data requests and grievances are sent to the grievance contact given in the Council's privacy notice, and are answered within thirty days; a person dissatisfied with the answer may complain to the Data Protection Board of India. Any personal data breach is notified to affected participants and to the Data Protection Board of India within seventy-two hours of the Council identifying it.

Research is where a funder's influence would be hardest to see, so the controls are fixed in advance and procedural, rather than left to the judgement of the people in the room at the time.

Every Council study is registered publicly before data collection begins, in a public research registry maintained outside PrepGraph's control, and a copy is placed on the Council's page. The registration states the question, the method, the analysis plan, the expected sample, the funder, every participating organisation, and the date by which publication will occur, which is not more than twelve months after data collection ends. Once registered, a study is published on or before that date whatever the finding, including a null result, an inconclusive result, or a result adverse to PrepGraph or to AI adoption generally.

The Council does not publish an evaluation of a PrepGraph product funded by PrepGraph. Where the intervention studied is the convener's product, the study is an evaluation of that product whatever it is titled, and the protocol names which product delivered the intervention. PrepGraph may take part as a data or platform partner in a study funded independently of it. That participation is disclosed in the abstract and on the first page, never only in a footnote or an acknowledgement. Where PrepGraph supplies data or platform access, the analysis plan is fixed before any data is seen and the analysis is carried out by a person who is not a PrepGraph employee.

PrepGraph has no editorial review. It may correct factual statements about its own systems within ten working days, and silence publishes. It cannot delay, amend or withhold anything. The Charter, this policy and the research instrument state that in the same terms.

The Council never presents PrepGraph's internal product evidence, benchmarks or case studies as a Council finding, and PrepGraph's commercial claims carry no Council standing. Where children are involved, the protocol is reviewed before it begins by a named reviewer who is not employed by, contracted to or invested in PrepGraph and has not been engaged by PrepGraph in the preceding three years; the reviewer's name and the fact of the review are published with the study.

No document, statement, guidance note, framework or study is published in the Council's name without the approval of the Chair and a majority of the voting members. That is the Charter's rule and this policy states it in the Charter's terms rather than its own. Where the output is a study, the ethics review panel holds a veto over its publication; a veto stops a publication and is not a share in approving one. PrepGraph has no editorial control, no approval step and no editorial review over the substance of any output. The Secretariat drafts and produces; it does not decide what the Council says.

The Chair may publish, in her own name and through the Council's channels, a dissent, a caution or a statement of disagreement with any Council output, with PrepGraph as convener, or with this policy itself. Members and fellows hold the same right in relation to any document to which they contributed, and a dissent submitted before publication is appended to the document rather than answered privately.

Any member, fellow or contributor may refuse the use of their name on any output, may withdraw it at any point before publication, and may require its removal from later editions and from the Council's pages. No reason need be given, and the withdrawal is not characterised in the document as agreement, abstention or anything else. No person's institution or employer is named in Council material without written consent.

Outputs are published free and in full at a public address under the Creative Commons Attribution 4.0 licence, so that a school may use them without any relationship with PrepGraph and without asking the Council's permission. Every output carries a version number and date, earlier versions remain available, and each output is deposited in a public archive that PrepGraph does not control.

Every safeguard in this document rests on a Chair who is not PrepGraph, and the terms of her office are written so that the funder has no hold over it.

The Founding Chair, Ms. Sri Lakshmi, holds office for the inaugural term of twelve months from 29 August 2026. The office carries no honorarium, fee or other payment, so PrepGraph holds no financial hold over the holder. PrepGraph cannot remove the Chair and cannot shorten her term. Removal is available only to the voting members, by two thirds of the voting members other than the Chair, on stated grounds that are recorded and published. Renewal at the end of the term is decided by the voting members; PrepGraph proposes no candidate, holds no vote and holds no veto over it.

A removal attempt, a request to resign, or a decision not to renew is published within fourteen days with PrepGraph's reasons, and the Chair may publish her own account through the Council's channels. PrepGraph waives in advance any confidentiality obligation, non-disparagement term, contractual restraint or other claim that would prevent her from doing so, whether during or after the term.

Succession is decided by the voting members, who elect the successor; PrepGraph takes no part in that election and proposes no candidate.

These duties apply from appointment and continue for twelve months after an office-holder leaves, in respect of matters arising during their term. A person who is an employee, director, shareholder or paid adviser of PrepGraph, or of any other supplier of AI products to schools, or who otherwise derives material income from one, may not hold office as a Founding Member or Expert Fellow. Such a person may be heard as an invited Observer, and nothing more.

Every office-holder declares their interests before first sitting, and updates the declaration when circumstances change. Where an interest is engaged, the office-holder withdraws from the matter.

The Reviewer of Concerns holds and publishes the register of declarations. The Secretariat does not hold it, keeps no copy of it and has no access to it, and the Chair holds no power to edit it. A register recording which supplier each member's school uses is a market map, and keeping it out of the funder's hands is the only sound rule.

Anyone may raise a concern that this policy has been breached: a member or fellow, a participant, a school or teacher who received Council material, a member of the public, a journalist, or a PrepGraph employee. No standing, membership or relationship is required. Concerns go to council@prepgraph.com marked for the Chair. A concern about the Chair is determined by the voting members without the Chair present, and no officer handles a concern about themselves.

The Reviewer of Concerns is the one office in this structure that PrepGraph does not employ, does not appoint and cannot remove. The Reviewer holds and publishes the register of declarations, receives breach reports, inspects the firewall each Council year, and concurs in the appointment of the members of the ethics review panel.

Change of control of PrepGraph, and any sale of its assets, are governed by the entrenched Charter Article that constitutes PrepGraph as bare trustee for the Council and by the deed made under it, so that the Council's records, its research data and its name are protected whatever happens to the funder. A change in PrepGraph's commercial plans does not change this policy.

The annual public record is the one annual report the Charter requires, published under that name. There is no separate closing account, transparency statement or status page, and any other instrument naming one is wrong. It is published at the end of each term and sets out the Council's work, its people, its funding and how the rules in this policy were kept.

This is version 1.0 of the policy, dated 29 August 2026. It takes effect on the Founding Chair's acceptance of office on that date and runs for the inaugural term. It binds the Chair, members, fellows, the Secretariat and PrepGraph as convener, and adherence is a condition both of holding Council office and of PrepGraph's role as convener.

The Charter governs. This policy is subordinate to it and may be amended only on the majority the Charter requires for the Article the amendment touches.