🔶 PROVISIONAL — grounded in DRAFT legal documents pending execution. This page is extracted from the Master Vendor Agreement v2.0 (pre-counsel draft), the Seal Credential Terms v1.0 (draft for Vicente LLP review), and the Entity Bifurcation Memo (preliminary view, pending Vicente LLP opinion). It becomes binding doctrine only on (a) Vicente LLP execution of those agreements and (b) founder sign-off. Until then, treat as the intended model, not settled law.
Owner: Jonathan (Founder) + Ayisha (Compliance) · Department: Executive/Compliance · Status: Draft (provisional) · Version: 0.1
Effective Date: on execution · Last Reviewed: 2026-06-13 · Next Review Date: on Vicente LLP opinion
Source of Truth: MVA v2.0 §§2–8, Seal Credential Terms v1.0 §§1–7 · Maturity: 3 (Usable)
The single rule every SOP inherits: HempDash's authority is platform-scoped. It controls what happens on HempDash; it does not control the vendor's business.
| Action | Source |
|---|---|
| Issue / suspend / revoke the Compliance Seal | MVA §4.7; Seal Terms §4 |
| Delist or suspend a vendor's products on the Platform | MVA §2.5, §3.5, §8.5 |
| Remove / modify / restrict noncompliant Vendor Content | MVA §8.5 |
| Withhold payouts / apply holdback reserve | MVA §2.5 |
| Suspend or terminate the vendor's HempDash account / Agreement | MVA §2.3, §2.4 |
| Update the public Seal verification endpoint status | Seal Terms §4.4 |
| Notify the vendor; cooperate with / produce records to regulators | Seal Terms §4.5; Bifurcation Memo §3.3 |
| HempDash cannot… | Why |
|---|---|
| Stop the vendor's off-platform sales (their own store/POS) | MVA governs only 'the Platform' (§1.8) |
| Halt the vendor's manufacturing / cultivation / processing | HempDash is not in the supply chain (Memo §2.3) |
| Order product destruction | Not a granted power |
| Mandate or compel a recall | Vendor owns the recall; HempDash's only lever is Seal revocation if the vendor 'has not cooperated with recall procedures' (MVA §4.7.3(iv)) |
| Be the regulated party / hold the hemp license | Vendor is the regulated party (Memo §2.4) |
| Make a government compliance determination | Seal is not a government approval (Seal Terms §2.2; MVA §4.7.5) |
Seller of record; all product + IP ownership (MVA §8.2); sole independent compliance obligation (MVA §3.1, §4.6; Seal Terms §6.3); ownership of any recall; their licenses; all off-platform operations.
Means: a records-on-file attestation as of the issuance date — Free tier = required documents on file and unexpired; Premium tier = additionally passed a structured COA review against the §300.301 schema (Seal Terms §1).
Does NOT mean: product safety, regulatory approval, current compliance, document authenticity, or legal advice — and it cannot be asserted as a defense to enforcement (Seal Terms §2, §6.3).
Auto-suspension triggers (Seal Terms §4.1 / MVA §4.7.2): COA expired and not replaced within 5 business days; license lapse/suspension/revocation; insurance lapse; known DSHS enforcement action.
The vendor initiates and owns the recall. HempDash's role is platform-side coordination: delist the product on the Platform, revoke the Seal if the vendor does not cooperate (MVA §4.7.3(iv)), fan out notifications to affected HempDash-channel customers, document, track effectiveness, and report. HempDash does not approve or mandate the recall. See Recall Execution.
HempDash is a non-party record-holder. It may receive a subpoena or record request as an interested party and cooperates per obligation; it is not the enforced party (Bifurcation Memo §3.3–3.4). Regulator communications route per §17.5 Regulator Direct Contact (specific authority provisional, pending the answer sheet).
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