I sent an email to the board about this in June, because the COI applies to some moderators but not others. I haven’t heard back.
The OSM Foundation board approved on 2023-06-24 the following resolution: 2023/12 “Update the Working Group Conflict of Interest policy to extend to moderators etc.”
Update the Working Group Conflict of Interest policy to change the first sentence to state “By board decision, this document is used as the default Conflict of Interest policy for any Working Group, committee, special committee, similar OSM Foundation body, or moderators of an OSMF-hosted communications channel.”