Sponsorship Acknowledgment Policy — Automate the Cloud Inc.

1. Purpose

To ensure that payments the Corporation receives from sponsors qualify as tax-free "qualified sponsorship payments" under IRC § 513(i), and are not recharacterized as taxable unrelated business income (UBI) from advertising.

2. The Key Distinction: Acknowledgment vs. Advertising

Permitted acknowledgment (tax-free) — the Corporation may recognize a sponsor with:

• The sponsor's name, logo, and established slogan;
• The sponsor's locations, telephone numbers, and web address (as a link);
• Value-neutral descriptions of the sponsor's products or services;
• Product displays or the sponsor's brand/trade names.

Prohibited advertising (creates taxable income) — the Corporation shall not provide, in exchange for a payment:

• Qualitative or comparative language ("the best," "#1");
• Price information, indications of savings, or other inducements to buy;
• Endorsements of the sponsor's products or services;
• Calls to action to purchase, sell, or use the sponsor's products.

3. No Return Benefit Beyond Acknowledgment

A payment is a qualified sponsorship payment only if the sponsor receives no substantial return benefit other than the acknowledgment above. Benefits of nominal value (goods/services worth not more than 2% of the payment, or token items) are disregarded.

4. Contingent Payments

A payment is not a qualified sponsorship payment if its amount is contingent on attendance, broadcast ratings, or other indicators of public exposure to an event. Contingent arrangements shall be avoided or reviewed with a tax advisor.

5. Written Sponsorship Agreements

Sponsorship arrangements should be documented in writing, describing the acknowledgment to be provided and confirming that no advertising or substantial return benefit is included.

6. Documentation and Review

The Treasurer shall retain sponsorship agreements and track sponsorship revenue. If any arrangement approaches advertising, the Corporation shall consult a tax advisor before proceeding, as such income may be taxable and (if substantial) may affect Form 1023-EZ gross-receipts limits.