Cali Fund Prozomix Q&A
Prozomix and the Cali Fund in just 25 Quickfire Q&As:
Q1. What is the Cali Fund?
ANS: The Cali Fund is a global mechanism for companies responsibly exploiting digital sequence information (DSI; i.e. DNA, RNA and / or protein sequences from public global databases), the privilege of such access can be paid for by contributing cash to this fund.
Q2. What happens to the funds?
ANS: They are used to contribute to arresting global biodiversity decline, for example, at least 50% goes to Indigenous Peoples and local communities, the collective custodians of significant swathes of highly biodiverse regions of the planet.
Q3. Why did Prozomix become the first biotech in the world to contribute to the Cali Fund?
ANS: We recently acquired a sequence space mining / engineering AI company, Insiligence Limited, and we believe all such businesses, no matter of their size, should contribute.
Q4. How much did Prozomix contribute?
ANS: 0.1% of our total revenue/capital inflow for 2025/2026(est.), in this instance US $5000.
Q5. Did Prozomix have to contribute according to current Cali Fund guidance?
ANS: No, established, profitable and expanding companies like Prozomix are not currently being asked to contribute. Current rules curiously only suggest companies that meet two of the following very acute financial metrics should pay:
-total assets ≥US $20M
-annual sales/revenue ≥US $50M
-annual profit ≥US $5M
Q6. So why did Prozomix feel it necessary to contribute?
ANS: We feel companies of our size, and at any and all stages of development, should pay for the privilege of exploiting public DSI, especially as we are not exempt from any other similar biodiversity exploitation mechanisms, such as the Nagoya Protocol, High Seas Treaty, ITPGRFA or PIP, it’s as simple as that!
Q7. Now you have contributed, does that mean customers of Prozomix also need to contribute?
ANS: Not at all, our recent acquisition of the AI company Insiligence Limited means we now feel we should contribute. The rationale behind that acquisition was to put us in an ideal position to build advanced AI-driven enzyme mining and engineering tools, but only for future potential application. Commercial deployment of these new tools, i.e. when sufficient clarity regarding the Cali Fund is realised globally and accepted by all, will still come with a clear disclaimer that public DSI was used in its development, and thus any commercial use should bear that carefully in mind. We are sure much needed clarity on this topic is just around the corner. The reason we are developing our new tools ahead of Cali Fund clarity, is that it will take significant time and resources to develop and benchmark such technologies against our current methodologies, and there would simply be no quick way to do that in the future once the Cali Fund has bedded in globally.
Q8. But what about your collaborators, will you still work with them if they have not contributed to the Cali Fund?
ANS: Our collaborators in large organisations are totally governed by their own stringent corporate responsibility processes. We work with them currently, and thus we are satisfied that they are responsible partners, and thus potentially contributing to the Cali Fund is something for them to work through themselves. Our SME collaborators, new and existing, on the other hand, who work within sequence space, and use public DSI at any level, will be asked to contribute to the Cali Fund before we execute any new, or extend any existing, agreements with them. We will allow them three months to complete the process of making a contribution, which is plenty of time given our recent experience of doing the same (took literally no more than a few weeks from start to finish). Such collaborators will be asked to contribute at the 0.1% of total revenue/capital inflow level, and specifically not on profit basis. Failure to comply will result in non-execution of new agreements or termination of existing ones. Indeed, this process actually began in July 2026 and will be largely complete by the end of 2027.
Q9. But being blunt, what is the point, hardly anybody else has contributed yet, right?
ANS: Initial practical guidance of who should pay into the Cali Fund only became available from early 2025, and these things, while looking very simple on paper, are actually extraordinarily complex to execute in large organisations, explaining why no large entity has yet contributed, but this situation will probably change quite soon. While smaller entities such as Prozomix can move much faster, or even instantly, they are not currently being asked to contribute at all, so no one can really blame them for any inaction at this stage!
Q10. Is there a chance the Cali Fund will be abandoned and resigned to history?
ANS: Anything can happen of course, but for an example of almost perfect context, all we need to do is go back in time about 15 years ago when scientific circles started to hear more and more about the Nagoya Protocol. Many scientists at the time (to be honest…) thought there was no chance it would ever be ratified and enforced, given the impact on the scientific and business communities that were targeted. Well…, they were very wrong! Actually, a significant driving force bringing about change at that time was co-ordinated action by the UK government and the EU. Wind the clock forward 15 years to now and you will observe the exact same phenomenon with respect to increasing support from the same for the Cali Fund, only this time many more additional countries are also involved!
Q11. Who are the “Friends of the Cali Fund” and is it really called that?
ANS: Yes, it’s a thing, a most significant thing – essentially a coalition of the willing was founded by the UK and Chile governments in June 2025, to promote support for, and visibility of, the Cali Fund globally. That initial gesture has morphed very significantly since, especially most recently, when championed by the German government. The entire EU are now members of this growing and most influential biodiversity club, which also features Armenia, Columbia, the Netherlands, Norway, and South Africa.
Q12. OK, with global momentum on the rise for the Cali Fund, what will happen next?
ANS: On a balance of probabilities basis, it is only logical, no matter what your view, that continued hesitation from large companies will soon result in severe ESG compliance, or other, pressure, being applied in numerous key global territories.
Q13. What might the effect be of forcing large companies to pay into the Cali Fund if they use DSI?
ANS: In our view, from a number of fundamental large company business standpoints the current Cali Fund contribution structure raises more risks than rewards with respect to custodians of global biodiversity through to the global consumer in general, and all those who fall in between. A quick answer would be large company site closures in certain territories could very easily result, or business units closed/moved, at the very least. Why that would be results from the current lack (well… total absence) of granular detail with respect to the rules, where the current broad strokes affect so many levels of how large companies are formed and how they operate. For instance, under current guidelines the whole M&A piece would be materially affected. Consider for instance, if the purchase of a small biotech (say Prozomix), by a large US $100B company, meant that such a huge business that had no prior exposure to public DSI, is now immediately asked to pay either 0.1% of their overall turnover for their entire operation, or 1% of their overall profits, into the Cali Fund. Here, most obviously, the acquisition would simply not take place! For the sake of this quickfire Q&A section we will stop here, but clearly the implications for every business are currently at numerous intractable levels.
Q14. Suggested Cali Fund contribution levels seem to have worked for Prozomix, are they suitable across the board?
ANS: 100 % of the activities of Prozomix are linked to biotechnology, specifically to DNA and protein sequences. Whilst to date we have actually focused on generating and mining our own private metagenomic DSI from UK samples which lies outside the remit of the Cali Fund, we acknowledge the future will almost certainly involve exposure to public DSI one way or another, especially given we have recently acquired an AI bioinformatics company. Thus 0.1% of our entire income is a very reasonable price to pay (or 1% of our overall profit) for such flexible access for such an SME! However, such contribution levels being asked over an entire large organisation, whilst very appealing from a biodiversity preservation standpoint, given increased flux to Cali Fund, is unfortunately going to be counterproductive at best, and at worst, well, see Q13.
Q15. Do large companies actually even believe in the Cali Fund?
ANS: It is, perhaps, not obvious, but by their very nature (structure, shareholders, stakeholders), large companies, especially Big Pharma, are amongst the most responsible entities in the world. As a most relevant example, whilst it took them a few years to get to grips with the Nagoya Protocol, Big Pharma now routinely audit their suppliers, such as Prozomix, for Nagoya Protocol compliance. This is one of the reasons, in our mind, that they will become Cali Fund compliant as soon as they possibly can, but it was never going to be instant.
Q16. How should large companies be dealt with then?
ANS: That is not the way to look at this problem at all, we think at this stage it is actually time for large companies to take the bull by the horns, and demonstrate highly innovative novel pragmatic solutions that they will initially need to lead, even unilaterally if necessary.
Q17. How could such a pragmatic large-company-led Cali Fund contribution solution work?
In order to proactively (i) demonstrate their respect for global biodiversity efforts, and (ii) simultaneously break the impasse with respect to contributing to the Cali Fund, a “tick all the necessary boxes” solution is required, that at least gets (i) and (ii) done, and very fast. Such structures, or certainly major elements of, have been proposed already, but now if all of the many sides in the Cali-Fund-impasse ramp up their pragmatism to the very max we all can, for the sake of the billions of years of evolutionary effort it took to, well, literally create ourselves, along with the rest of global biodiversity, then what about:
(i) Barclays Bank in London manage a Large Company Cali Fund Escrow Account (LCCFEA), fees being more than covered by interest accrued.
(ii) Large companies build in-house multidisciplinary teams comprising existing expert biology, chemistry, and business heads, with global remit to quickly (<three months) determine what percentage of the overall organisation’s revenue and profit is significantly (in their own expert unaudited, view), derived from DSI, thus calculating their “Relevant Revenue” and “Relevant Profit”.
(iii) Each large company then selects either 0.1% of their Relevant Revenue or 1% of their Relevant Profit, and pays that amount into the LCCFEA, using their last year-end numbers, and then again on each anniversary.
(iv) Given the LCCFEA structure strictly holds onto the funds until legal clarity has been achieved with respect to double charging from other mechanisms, or unilateral actions from individual territories, etc, as declared solely by the ICC, large companies are 100% shielded from their current major issue with the Cali Fund.
(v) If no such legal clarity has been declared by the ICC after three years’ worth of contributions have been received from a large company, on making their fourth contribution, they simultaneously get their first years’ contribution back. Similarly, should they make a fifth contribution and still no resolution has been achieved, they simultaneously get their second payment back. Also included in the very simple provisions is a 10-year backstop date, if no resolution is achieved by then, after which no more contributions are provided, and all monies are returned to the large companies that made them, including remaining interest.
(vi) Should legal clarity be achieved, all monies are immediately released to the Cali Fund. However, if legal clarity is subsequently lost, contributions are held in the LCCFEA again as above.
Q18. Why would such a solution work for all sides?
ANS: Essentially, we are all on the same side here, we just have very different day jobs. What the above structure enables though, is an evolutionary process all of its own to take place:
(i) Large companies can calculate what they owe rapidly, the key point being they are being asked what they probably owe, so don’t have to worry about audits etc, enabling them to move fast (i.e. within three months).
(ii) The Cali Fund will know what is coming, what each year will probably yield, and can start planning distribution.
(iii) The global consumer can see which large company is contributing what, and just as important, each large company can see what the others are contributing, leading to evolution of balanced and fair contributions from all as time goes by.
Q19. If large companies are not charged at 0.1% of their entire revenue or 1% of profit, the Cali Fund will not receive what it is expecting?
ANS: Large companies can always pay more if they like, but the hole can be plugged to some extent by removing the current smaller company exclusion, i.e. that means SMEs such as Prozomix are not expected to contribute to the Cali Fund. This current situation is very difficult to understand rationally given no such exemption has ever existed with respect to the Nagoya Protocol, for example?
Q20. Why do you specifically believe all companies using AI driven by LLMs should pay into the Cali Fund?
ANS: It is as simple as this – publicly accessible data is, and has been for many years now, exploited by the biotech sector at large by widespread application of LLMs developed via the absolutely necessary, yet fundamentally indiscriminate, exploitation of DSI. Thus, we firmly believe that all established SMEs in this sector that use DSI should also be contributing to the Cali Fund regardless of their size, at a 0.1% of total revenue / capital inflow level, as that would only be fair, and collectively generate meaningful support for the Cali Fund.
Q21. To avoid the Cali Fund can companies use alternative technologies?
ANS: Maybe not alternative technologies yet, but one could imagine building foundational models from scratch using nothing other than private metagenomic data. That would be very costly and potentially have missing sequence space information, but over time such datasets will get ever more massive, and concomitantly ever cheaper, and thus there is an inevitability, especially if private collections from around the world were pooled in a private consortium towards such an end. Such a development is currently very unlikely, and a working Cali Fund will mean there would be no point building such likely inferior LLMs.
Q22. What about ab initio protein design, could that replace the need for use of DSI?
ANS: Unlike generative AI, which is wholly dependent on DSI, ab initio methods are fundamentally not, but you are not going to replicate alternative solutions that are better than what mother nature spent billions of years evolving, no matter how good you get at it. Remember, the best molecular biology on earth has already been performed millions of years ago in most cases!
Q23. I went on the CBD website but could see nothing about the Cali Fund, only links to the Nagoya Protocol, but this is a different thing, right?
ANS: Yes, a clear link would be useful for the process of convincing all stakeholders of the urgency of getting the Cali Fund up and running properly so that critical support can be achieved sooner to minimise the decline in biodiversity. There is actually a nice logo for the Cali Fund, so a link to the official stand-alone Cali Fund website from that logo placed in a prominent above-the-fold position on the CBD homepage would be a very good idea, and drive traffic for the many stakeholders who are yet to become aware of this mechanism.
Q24. Some people say the Nagoya Protocol has yet to yield the significant benefit sharing it was intended to provide, is this true?
ANS: Yes, the Nagoya Protocol has unfortunately very little over the twelve years it has been running, only some US $5M per year essentially, thus to achieve the Cali Fund ambition of US $1B per year would mean garnering 200x more support from global commercial enterprises……so it’s time to get going!
Q25. The final question is for you – if you use and commercially exploit public DSI, what is your rationale for not paying something back to where the data originated for that privilege?
ANS: https://thecalifund.org/get-involved/