Module 9 — Legal, compliance, and brand

Section 1 · Tier 1 — The 60-second brief

The legal and brand rails are the floor under every public-facing thing HiON says, writes, or signs. Kevin Hein at Akerman LLP is the outside counsel position. The Akerman redline is the source of truth for what HiON can and cannot say in public. The brand voice — two facts, no adjectives, operator-fluent — is the rubric every piece of writing passes against.

1. The FDD. Franchise Disclosure Document. The legal product. Delivered to prospective franchisees in compliance with the FTC Franchise Rule and applicable state laws.
2. 15 regulated states. California, Hawaii, Illinois, Indiana, Maryland, Michigan, Minnesota, New York, North Dakota, Oregon, Rhode Island, South Dakota, Virginia, Washington, Wisconsin. No offer or sale until registered / exempted / qualified.
3. Disclosure block + regulated states notice. Verbatim from §3.5 below. Required on any material that offers or describes the franchise.
4. Kevin Hein. Co-chair of Akerman LLP Franchise & Licensing Sector Team. Outside General Counsel. Owns FDD, registration posture, and the redline.
5. The Akerman redline. The “don’t say / say instead” table — every phrasing item from V2 marketing that triggers a compliance issue. Full table in §3.4. Binding.
6. Incentives language. Federal / state / utility / local incentives (bonus depreciation, NEVI, state grants, utility rebates, LCFS) are administered by third parties. HiON does not guarantee qualification or amount. Always hedge.
7. Brand identity rails. Orange is the only chromatic hue. Three orange tones. Everything else grayscale. Geist (sans) + Geist Mono. Sentence case. Em-dashes structural. Numerals over spelled-out numbers. “HiON” capitalization fixed.
8. Voice rules. Two facts, no adjectives. Assume sophisticated multi-unit operator / investor audience. Use historical anchors (1905). Zero politics. No exclamation points anywhere ever.

What you must be able to say without notes: the 15 regulated states (or at least know where to find the list); the disclosure-block requirement; Kevin Hein’s role; the top-five phrasings in the redline table; the four binding voice rules (two facts, no adjectives, operator-fluent, historical anchors, zero politics).

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Section 2 · Tier 2 — Source map

Canonical documents

Document	Path	When to open
Master context brief §§6, 7, 8	~/HiON Franchise Group Site v2/hion-context.md	Any compliance or brand question. The redline table is §7.
Public copy (compliance-redlined)	~/HiON Franchise Group Site v2/site-v3/COPY.md	Any time you’re writing or editing public-facing copy. Pull verbatim.
Brand guidelines (full)	~/HiON Franchise Group Site v2/brand-guidelines/index.html	Visual design, voice deep work, identity application.
FDD	(not in repo) [CONFIRM]	Any conversation crossing into legal substance. Owner: Kevin Hein.
Franchise Agreement template	(not in repo) [CONFIRM]	Any conversation about franchisee contractual obligations.
MSA	(not in repo) [CONFIRM]	Any conversation about equipment supply, network operations, or uptime contractual mechanics.
Lease Addendum + Collateral Assignment	(not in repo) [CONFIRM]	Any franchisee-Site Host lease conversation.

Owners

Person	What they own for M09 questions
Kevin Hein	FDD, registration, the redline. Any new compliance question. The 15 regulated states posture.
Will Frank	Public-facing copy. Updates to site-v3/COPY.md. Brand voice in marketing and PR.
Jim Frank	Strategic compliance decisions; the relationship with Akerman LLP.
Bill O’Connor	Financial-performance representations and Item 19 boundary (see also M06).
Joe Lewis	Operational compliance posture (audit readiness, Compliance Register, incident response — operator-grade detail in franchisee curriculum M14).

Live dashboards / portals

• HiON public site (V3) — hion-v3.vercel.app during redesign; final on hionev.com.
• Partner Portal — Compliance section [CONFIRM].

Related curriculum modules

• M01 — the “what HiON is” framing the compliance rails govern.
• M03 — the four Tesla-relationship phrasings (Coming Soon, dominant, exclusive, first-in-line).
• M05 — the ancillary phrasing and cap-rate effect.
• M06 — the eight financial redlines, plus the FDD Item 19 mechanics.
• M10 — team and capital narrative, subject to the same rails.

Franchisee curriculum overlap

• [M02 · GOVERNANCE · MANUAL · SUPPORT · ESCALATION](https://training.hionsuperchargers.com/curriculum/m02-governance-manual-support-escalation/) — Ops Manual governance, exception requests, audit posture.
• [M03 · BRAND · PROMISE · AND · BRAND · EXECUTION](https://training.hionsuperchargers.com/curriculum/m03-brand-promise-and-brand-execution/) — brand promise and on-site execution.
• [M14 · COMPLIANCE · SAFETY · INSURANCE · RISK](https://training.hionsuperchargers.com/curriculum/m14-compliance-safety-insurance-risk/) — operational compliance for franchisees.

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Section 3 · Tier 3 — Deep dive

3.1 — The FDD: what it is and who delivers it

The Franchise Disclosure Document (FDD) is the federally regulated and state-regulated document a franchisor delivers to a prospective franchisee before any offer or sale of a franchise. The structure is governed by the FTC Franchise Rule (16 CFR Part 436) and by state franchise laws where applicable. It contains 23 Items, each addressing a defined topic — Items 1 (entity), 2 (business experience), 5 (initial fees), 6 (other fees), 7 (initial investment), 11 (training), 19 (financial performance representations), 21 (financial statements) are the most-discussed.

Delivery. A prospective franchisee must receive the FDD at the earliest of:

• 14 calendar days before the prospect signs any binding agreement or pays any consideration, OR
• The first personal meeting to discuss the franchise offering.

Compliance posture. HiON does not offer or sell franchises in any state until the offering has been duly registered, exempted, or otherwise qualified for offer and sale in that state, and the required FDD has been delivered to the prospect.

Who delivers. Joe Lewis (sales motion) coordinates; Kevin Hein at Akerman LLP owns the legal substance of the FDD and the registration / qualification posture; Bill O’Connor signs the financial statements (Item 21).

3.2 — The 15 regulated states

The following states regulate the offer and sale of franchises (verbatim from hion-context.md §7):

California, Hawaii, Illinois, Indiana, Maryland, Michigan, Minnesota, New York, North Dakota, Oregon, Rhode Island, South Dakota, Virginia, Washington, Wisconsin.

In a regulated state, HiON’s offer or sale of a franchise requires the offering to be registered, exempted, or qualified for offer and sale in that state, and the FDD to be delivered to the prospective franchisee. The specific mechanism varies by state — some require registration with a state agency; some require notice filings; some permit reliance on a federal exemption.

Executive working memory. Know the list exists. Know which state a specific prospect is in. Never represent HiON’s franchise as available in a state where the executive hasn’t confirmed the registration / exemption posture. The default routing is “let me confirm with Kevin Hein on the registration in your state before we move forward.”

3.3 — The disclosure block + regulated states notice (verbatim)

Required on any public material that offers or references the franchise. Verbatim from hion-context.md §7:

Franchise-disclosure block.

This communication is for informational purposes only and is not an offer to sell, or the solicitation of an offer to buy, a franchise. A franchise offer is made only by Franchise Disclosure Document (FDD) delivered in compliance with the FTC Franchise Rule and applicable state laws. HiON Franchise Group will not offer or sell franchises in any state until the offering has been duly registered, exempted, or otherwise qualified for offer and sale in that state, and the required FDD has been delivered to the prospective franchisee.

Regulated states notice.

The following states regulate the offer and sale of franchises: California, Hawaii, Illinois, Indiana, Maryland, Michigan, Minnesota, New York, North Dakota, Oregon, Rhode Island, South Dakota, Virginia, Washington, and Wisconsin.

These blocks are not optional. They appear on the public site, on any deck distributed externally that offers or describes the franchise, on any sales material, on any marketing collateral that does more than describe what HiON is at the company level.

3.4 — The Akerman redline table (full)

The “don’t say / say instead” table. From hion-context.md §7 — verbatim, in entirety. Memorize the top-five; know where the full table lives for the rest.

Don’t say	Say instead
”semi-passive, autonomous business"	"operator-light infrastructure business"
"No employees” (as a feature claim)	“Minimal on-site staffing"
"40%+ EBITDA margins”	(omit from public copy)
“3.5-year payback” / “Payback Period: ~3.5 years”	(omit from public copy)
Specific per-site EBITDA dollar figures	(omit from public copy)
Cash-on-Cash ROI percentages	(omit from public copy)
“With 20% Leverage — Payback (ROI 95–121%) — < 1 Year”	(omit from public copy)
”~$2M+ Annual EBITDA”	(omit from public copy)
“100% of profit from all ancillary businesses"	"Any ancillary business operated on your site is independent of the HiON franchise; HiON does not collect royalties on ancillary revenue."
"Recession Resistant — EVs still need charging, always"	"Tied to EV Adoption — Demand grows with the installed EV base, not discretionary spending"
"Autonomous Business — Semi-passive income model"	"Operator-Light — Tesla operates the station; minimal on-site staffing required"
"Truly semi-absentee ownership"	"Operator-light staffing model"
"Truly Autonomous — Tesla software runs the station"	"Tesla-Operated Infrastructure — Tesla software runs the station"
"First-in-line Tesla approval — shown as ‘Coming Soon’ on Tesla maps before construction"	"Tesla approval workflow includes pre-construction visibility on Tesla’s navigation maps, subject to Tesla’s site approval and standards."
"AI-powered site selection using EV registration data"	"Data-driven site selection using EV registration density, traffic flow patterns, and utility capacity analysis"
"On-call maintenance — targeting 98%+ uptime"	"On-call maintenance designed to support high uptime; actual uptime varies by site and equipment"
"drives new traffic — and new sales” / “Increased supercharging means increased sales at your business"	"can attract new visitors during charging sessions"
"most dominant EV charging network on Earth"	"most established EV charging network in the United States"
"$1.85M → $4.2M” example on the Franchise page	(removed from Franchise page; remains only on Host page)
“It’s not just a franchise. It’s a property enhancement tool.” on the Franchise page	(removed from Franchise page; remains only on Host page)

Three rules around the table:

• Verbatim. When the “say instead” column has a specific phrasing, that’s the controlling version. Paraphrasing back toward the “don’t say” version drifts into redline territory.
• Omit means omit. Where the replacement is “(omit from public copy)”, no public-safe substitute exists. Drop the topic, do not soften it.
• Page-specific items. The cap-rate effect and the property-enhancement framing survive on the Host page only. Reintroducing them on the Franchise page is a redline violation.

3.5 — Incentives language (the hedge rule)

Federal, state, utility, and local incentives that may apply to HiON sites include (non-exhaustive):

• Bonus depreciation (federal tax).
• NEVI — National Electric Vehicle Infrastructure formula program (state-administered).
• State grants — varies by state and program cycle.
• Utility rebates — varies by utility.
• Landlord TIA — tenant improvement allowance.
• LCFS credits — Low Carbon Fuel Standard credits in California and adopting states.

Every one of these is administered by third parties and has eligibility requirements that vary by site, equipment, timing, and applicant. HiON does not administer these programs and does not guarantee qualification or award amount.

The compliance rule: always hedge. Refer prospective franchisees, hosts, and capital partners to tax advisors and program administrators for specifics. The verbatim public-safe phrasing template:

“Federal, state, utility, and local incentives may apply to HiON sites — eligibility, amount, and timing vary by site, equipment, applicant, and program cycle. HiON does not administer these programs and does not guarantee qualification or award amount. Prospective participants should consult their tax advisors and the relevant program administrators.”

The Network Boundaries discipline from M08 §3.5 also intersects here: a grant program requiring non-Tesla network operability cannot be accepted. Kevin Hein review on any grant program that includes operational conditions.

3.6 — Brand identity rails

The visual identity is fixed. From hion-context.md §6 and brand-guidelines/index.html:

• Color. Orange is the only chromatic hue in the system. Three orange tones, codified in the brand guidelines. Everything else is grayscale.
• Type. Geist (sans-serif) for interface and body. Geist Mono for labels, eyebrows, and data. No serif body. No display script.
• Logo. The orange “Hi” wordmark. Geometry fixed. Color invariant. No drop shadows, gradients, or outlines.
• Imagery. The canonical HiON-branded charging pillar (stylized concept, not a real V4 unit). See brand-guidelines/assets/ for the canonical reference.
• Layout conventions. Sentence case headlines. Em-dashes structural, not decorative. Numerals over spelled-out numbers. “HiON” capitalization fixed — never “HION,” never “Hi-On,” never “hion” lowercase except in domain references.

Voice = identity. The discipline that keeps the logo geometry fixed is the same discipline that keeps the voice from drifting into hype. Visual sloppiness and voice sloppiness travel together.

3.7 — Voice rules (the four principles + the never list)

From brand-guidelines/index.html and hion-context.md §6:

Four core principles, priority order on conflict:

1. Arithmetic. Numbers earn authority. Adjectives don’t.
2. Operator-fluent. Assume the reader is a sophisticated multi-unit operator or investor. Don’t define DAs, FDDs, royalty rates, or cap rates.
3. Historically anchored. Use recognizable prior buildouts (1905 gas stations, 1956 interstates) to frame the present case.
4. Disciplined conviction. State the thesis without hedging into noise; without adjective stacking.

The never list (no exclamation points, no clichés, no filler):

• No exclamation points. Anywhere. Ever.
• No “amazing,” “incredible,” “game-changing,” “revolutionary,” “cutting-edge,” “disruptive.”
• No filler intensifiers — truly, really, very, simply, basically, honestly, frankly, absolutely, definitely.
• No “we believe / we’re passionate / we’re committed / we’re excited.”
• No climate / sustainability / green / eco / carbon language. Anchor to installed EV base and infrastructure math.
• No politics. EV adoption is a market reality, not a policy outcome.
• No “imagine you’re a successful HiON franchisee” or motivational framing.

The strongest line in HiON’s vocabulary (already cited in M02): “In 1905, someone built the first gas station. The biggest opportunity of the 21st century is building its replacement.” This is the model — two facts, no adjectives, the reader fills in the implication.

3.8 — The default routing on unsure cases

When the executive is unsure whether a phrasing or claim is compliant:

• Default to site-v3/COPY.md — the canonical compliance-redlined snapshot. Pull exact text from there.
• Never paraphrase financial or operational claims. “Strong margins” is not a public-safe paraphrase of “40%+ EBITDA”; the topic doesn’t appear at all in public.
• Route new claims to Kevin Hein. Uptime guarantees, ROI claims, “passive” language, ancillary revenue claims, Canvas Program characterizations — all require Akerman review before going public.
• Always include the disclosure block + regulated states notice on any material that offers or describes the franchise.

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Section 4 · The numbers

Compliance rails are mostly qualitative; the relevant numbers:

Metric	Value	Source
Number of regulated states	15	hion-context.md §7
FDD pre-sale delivery window	14 calendar days OR first personal meeting (earliest)	FTC Franchise Rule [CONFIRM]
Top-line redline table items	20	hion-context.md §7
Voice core principles	4	brand-guidelines §04
Never-list filler intensifiers (count)	9	brand-guidelines §05
Orange tones in identity	3	brand-guidelines

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Section 5 · Why this matters

The rails in M09 are not opinions or preferences. They are legal floors, brand floors, and operational floors that the company functions inside. Every public sentence HiON delivers is delivered under these constraints, including the sentences executives improvise in calls, in dinners, in panels, in press interactions. The redline doesn’t disappear because the audience changes; the FDD obligations don’t disappear because the conversation is informal.

The Acknowledged Elephant: an executive may feel that compliance discipline costs HiON expressiveness — that the redlined phrasings are stronger and easier to deliver than the compliance-safe replacements. The opposite is true at scale. The compliance-safe phrasings are reusable across every audience without rework; the redlined phrasings would each require a remediation cycle the first time they appeared in print. The discipline buys speed at scale.

The brand voice specifically is the second-largest piece of structural differentiation HiON has, after the Canvas Program. Most franchisors and most charging operators write the same hyped, adjective-stacked, motivationally framed copy. HiON does not. The voice is what makes HiON’s writing recognizable to a Steve Wazny-tier prospect, a Bill-tier investor, or a Kevin-tier counsel — and recognizable, in this audience, is the prerequisite to credible.

Two specific risks worth holding in working memory:

• “Private context” drift. An executive uses a redlined phrasing in a private email or a casual call, thinking “this isn’t public.” The audience screenshots. The phrasing appears in a screenshot in a piece three months later. The redline applies to private and public alike.
• Brand sloppiness signaling voice sloppiness. A deck with the wrong “HiON” capitalization, the wrong color, or a stray exclamation point telegraphs to a sophisticated reader that the voice discipline is also fuzzy. Both are the same discipline.

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Section 6 · Decision scenarios

Scenario 1 — The exec writing a LinkedIn post about a recent site opening

Will is drafting a LinkedIn post: “Excited to share that our newest HiON site in [city] is open! Another step toward building America’s most dominant charging network — and our franchisees are seeing incredible economics. 🚀”

What’s wrong, and what does the executive say instead?

Five voice + redline issues in one sentence:

• “Excited to share” — voice violation (we’re excited language).
• “Most dominant” — Akerman redline.
• “Incredible economics” — adjective stacking + implied financial performance representation.
• “America’s” — comparative without source.
• ”🚀” — exclamation-point-equivalent emoji.

Compliance-safe version:

“HiON’s newest site in [city] is now operating on the Tesla Supercharger network. Tesla’s network is the most established EV charging network in the United States, with publicly disclosed 99.9% network uptime. HiON is one of approximately four companies in the US participating in Tesla’s Canvas Program for third-party Supercharger ownership and operation.”

Cited basis: hion-context.md §7 (multiple redlines); brand-guidelines §05 (never list).

Scenario 2 — The franchisee asking which states they can buy a franchise in

A franchisee prospect in Indiana asks Joe Lewis: “Can I buy a HiON franchise in Indiana?”

What does the executive say?

Indiana is on the regulated states list. The default is to confirm the registration posture before any offer.

“Indiana is one of the 15 states that regulate the offer and sale of franchises. Before we proceed, I want to confirm our registration / exemption posture for Indiana with Kevin Hein at Akerman LLP — that’s our outside general counsel for franchise law. I’ll have an answer back to you within one business day. In the meantime, I can send you our public materials describing the HiON system at the company level, which are appropriate to share before formal registration confirmation. The FDD itself comes after we confirm the Indiana posture and after we set up a formal Discovery process — by federal rule the FDD has to be delivered at the earliest of 14 calendar days before any binding agreement or the first personal meeting.”

Cited basis: hion-context.md §7 (15 regulated states); §3.1 FDD delivery rule.

Scenario 3 — The marketing draft from a new vendor

Will receives a draft of a HiON one-pager from a new design vendor. The draft uses HION in all caps, uses two-tone blue accents alongside orange, and the headline reads: “Revolutionizing EV Charging — One Site at a Time.”

What does the executive correct?

Three brand identity errors plus a voice error:

• “HION” all-caps — capitalization is HiON, fixed.
• Two-tone blue — Orange is the only chromatic hue. Blue is out.
• “Revolutionizing” — never list (revolutionary).
• “One Site at a Time” — motivational framing.

Vendor brief correction:

“Three brand-identity items to fix before the next round. (1) Logo / brand mark is ‘HiON’ — sentence-case capitalization, fixed; no ‘HION,’ no ‘Hi-On.’ (2) Orange is the only chromatic hue in our system; everything else is grayscale. The blue accent has to come out. (3) The voice doesn’t use words like ‘revolutionizing’ or motivational framings. The headline should state a fact — ‘HiON operates on the Tesla Supercharger network’ is the kind of headline that works. The brand guidelines at /brand-guidelines/index.html walk all of this; please use those as the rubric for the next draft.”

Cited basis: hion-context.md §6; brand-guidelines/index.html.

Scenario 4 — The NEVI question from a host prospect

A host prospect asks Joe Lewis: “Will the NEVI funding cover most of the build cost?”

What does the executive say?

The incentives-language hedge. NEVI is administered by third parties; eligibility and amount vary; HiON does not guarantee.

“NEVI is the federal formula program administered by each state DOT — eligibility and award amount vary by state program cycle, by site characteristics, and by applicant. Our site teams know how to position a site for NEVI consideration where the program is open, and we have several sites in process under NEVI today. We can’t guarantee qualification or award amount on your specific site — that’s true for any third-party incentive program. The shorter answer to your question: NEVI may apply, the program is competitive and conditional, and we structure the host agreement and the build economics without assuming NEVI dollars in the base case. Your state’s program administrator and your tax advisor are the right next routings for specifics.”

Cited basis: hion-context.md §7 (incentives hedging); §3.5.

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Section 7 · Common executive blind spots

1. Improvising around the disclosure block. Consequence: a public-facing material describes the franchise without the disclosure block; FTC and state-law exposure. Prevention: the block is verbatim, on every material that offers or describes the franchise. No exceptions.

2. “Private context” relaxation of the redline. Consequence: private email or private call uses a redlined phrasing; the phrasing surfaces externally later in screenshot or quote. Prevention: the redline applies in every audience. Internal consistency prevents external mistakes.

3. Brand identity drift in vendor work. Consequence: a vendor delivers a one-pager with wrong color or wrong capitalization; the deliverable goes to a prospect with the brand drift; the perception is one of unserious operations. Prevention: brand guidelines as the rubric for every vendor brief. Sign-off before delivery.

4. Quoting NEVI / state grants as a guaranteed funding source. Consequence: prospect underwrites against incentive amounts that don’t materialize; HiON exposure if the underwriting failure is attributable to HiON’s representation. Prevention: the hedge phrasing, every time. Route to tax advisor and program administrator.

5. Treating voice rules as a marketing preference. Consequence: a hyped, adjective-stacked line in a public deck does double damage — it signals brand sloppiness to sophisticated readers and it pollutes the corpus future copy gets pulled from. Prevention: the voice rules are identity. Apply them in writing, in speech, in vendor briefs.

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Section 8 · Self-check

Pass threshold: 80%. At least three items drill the redline (per template rule for compliance-touching modules — this module is the dictionary).

1. State the 15 regulated states. (§3.2)
2. State the verbatim franchise-disclosure block. (§3.3)
3. Name the four core voice principles in priority order. (§3.7)
4. Identify five filler intensifiers from the never list. (§3.7)
5. Walk the “don’t say / say instead” replacement for these five: (a) “semi-passive, autonomous business,” (b) “most dominant EV charging network on Earth,” (c) “100% of profit from all ancillary businesses,” (d) “First-in-line Tesla approval — shown as ‘Coming Soon’ on Tesla maps before construction,” (e) “40%+ EBITDA margins.” (§3.4)
6. State the rule on cap-rate effect example placement. (§3.4)
7. State the incentives language hedge verbatim. (§3.5)
8. What is the rule on financial paraphrasing in public copy, and why does “strong margins” fail? (§3.8; M06)
9. Identify the brand identity errors: “HION’s revolutionary approach to EV charging combines two-tone blue accents with our signature gold lettering to create a truly disruptive franchise model — one that’s redefining what’s possible!” (§§3.6, 3.7)
10. Scenario. Will is preparing a deck for a Vercel-hosted virtual event where he’ll speak for 15 minutes on HiON’s market position. The host has asked for a slide on “the financials” and a slide on “why Tesla.” Walk the response — what gets included, what gets omitted, what’s the compliance-safe slide language for each, and what disclosure block(s) appear on the deck?

Answer key

1. California, Hawaii, Illinois, Indiana, Maryland, Michigan, Minnesota, New York, North Dakota, Oregon, Rhode Island, South Dakota, Virginia, Washington, Wisconsin. (§3.2)
2. “This communication is for informational purposes only and is not an offer to sell, or the solicitation of an offer to buy, a franchise. A franchise offer is made only by Franchise Disclosure Document (FDD) delivered in compliance with the FTC Franchise Rule and applicable state laws. HiON Franchise Group will not offer or sell franchises in any state until the offering has been duly registered, exempted, or otherwise qualified for offer and sale in that state, and the required FDD has been delivered to the prospective franchisee.” (§3.3)
3. (1) Arithmetic. (2) Operator-fluent. (3) Historically anchored. (4) Disciplined conviction. Priority order on conflict. (§3.7)
4. Any five of: truly, really, very, simply, basically, honestly, frankly, absolutely, definitely. (§3.7)
5. (a) “operator-light infrastructure business.” (b) “most established EV charging network in the United States.” (c) “Any ancillary business operated on your site is independent of the HiON franchise; HiON does not collect royalties on ancillary revenue.” (d) “Tesla approval workflow includes pre-construction visibility on Tesla’s navigation maps, subject to Tesla’s site approval and standards.” (e) (omit from public copy). (§3.4)
6. The $1.85M → $4.2M cap-rate example appears on the Host page only — it was removed from the Franchise page during the V3 redline. Reintroducing it on the Franchise page is a redline violation. (§3.4; M05 §3.6; M06 §3.6)
7. “Federal, state, utility, and local incentives may apply to HiON sites — eligibility, amount, and timing vary by site, equipment, applicant, and program cycle. HiON does not administer these programs and does not guarantee qualification or award amount. Prospective participants should consult their tax advisors and the relevant program administrators.” (§3.5)
8. Never paraphrase financial or operational claims in public copy. “Strong margins” fails because it’s an implied financial performance representation — softer than “40%+ EBITDA” but functionally equivalent for FDD Item 19 purposes. The compliance rule is omit, not soften. (§3.8; M06 §3.7)
9. Five errors: (a) “HION” capitalization (should be “HiON”); (b) “revolutionary” (never list); (c) “two-tone blue accents” (orange is only chromatic hue); (d) “gold lettering” (only orange + grayscale); (e) “truly disruptive” + “what’s possible!” (filler intensifier + cliché + exclamation point). Correct version: “HiON operates on the Tesla Supercharger network — the most established EV charging network in the United States. HiON is one of approximately four companies in the US participating in Tesla’s Canvas Program for third-party Supercharger ownership and operation.” (§§3.6, 3.7)
10. Financials slide: does NOT include EBITDA, payback, ROI, margin, or per-site dollar figures. Includes structural facts only — ~$550K per location, 10-location DA over 3 years, $0.05 royalty + $0.01 tech, 10-year term + 5+5 renewals. Compliance-safe slide language: “HiON’s Franchise product is structured as a 10-location development agreement over 3 years. Per-location investment is approximately $550K. Recurring royalty is $0.05/kWh with a $0.01/kWh technology contribution. Term is 10 years with two 5-year renewals.” Tesla slide: does NOT include “exclusive,” “first-in-line,” “most dominant,” or any claim about HiON’s position beyond the Canvas Program phrasing. Compliance-safe slide language: “HiON is one of approximately four companies in the US participating in Tesla’s Canvas Program for third-party Supercharger ownership and operation. Tesla operates the most established EV charging network in the United States, with ~36,500 Supercharger ports, 52% US fast-charging market share, and 99.9% network uptime. Tesla approval workflow includes pre-construction visibility on Tesla’s navigation maps, subject to Tesla’s site approval and standards.” Disclosure block: the franchise-disclosure block and the regulated-states notice appear on the deck (final slide or footer of every slide). The deck is reviewed by Kevin Hein at Akerman before the event. (§§3.3, 3.4)

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Section 9 · Cross-references

Other exec curriculum modules

• M01–M08 — every module is governed by M09’s rails. M09 is the meta-module.
• M06 — the financial redlines specifically; the Item 19 mechanics.
• M10 — team/capital language under the same brand and voice rules.

External documents

• hion-context.md §§6, 7, 8
• site-v3/COPY.md
• brand-guidelines/index.html
• FDD, FA, MSA, Lease Addendum + Collateral Assignment templates [CONFIRM]

Franchisee curriculum overlap

• Franchisee M02 (Governance, Manual, Support, Escalation) — operator-grade governance.
• Franchisee M03 (Brand Promise and Brand Execution) — operator-grade brand discipline.
• Franchisee M14 (Compliance, Safety, Insurance, Risk) — operator-grade compliance.

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Section 10 · Source verification log

Claim	Current source	Primary source needed	Status	Owner
15 regulated states list	hion-context.md §7	Akerman redline doc + current state law tracking	partially verified	Kevin Hein
Franchise-disclosure block verbatim	hion-context.md §7	Akerman master language	partially verified	Kevin Hein
Akerman redline table (20 items)	hion-context.md §7	Original Akerman redline document on file	partially verified	Kevin Hein / Will
FDD delivery rule (14 days / first personal meeting)	this module §3.1	FTC Franchise Rule (16 CFR 436) + state laws	unverified	Kevin Hein
Four core voice principles in priority order	brand-guidelines + hion-context.md §6	brand-guidelines/index.html	verified	Will
Never list (9 filler intensifiers)	brand-guidelines	brand-guidelines/index.html	verified	Will
Orange-only chromatic hue + 3 tones	hion-context.md §6 + brand-guidelines	brand-guidelines/index.html	verified	Will
Geist + Geist Mono type system	hion-context.md §6 + brand-guidelines	brand-guidelines/index.html	verified	Will
Incentives hedging template	hion-context.md §7 (paraphrased here)	Akerman approved language	unverified	Kevin Hein

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Section 11 · Change log

Version	Date	Author	Changes
v0.1	2026-05-20	Claude	Initial draft. The meta-module — every other module is governed by M09’s rails.