Modern Slavery & Human Trafficking Statement

Commitment

AVERICO Holdings LLC and all subsidiary entities have zero tolerance for modern slavery, human trafficking, forced labor, and child labor in any part of our business or supply chains.

Our Operations

AVERICO operates across the United States, Liberia, and China, providing advisory, consulting, and infrastructure services. We recognize that our trilateral operations span jurisdictions with varying levels of modern slavery risk.

Risk Assessment

We assess modern slavery risks across:

• Direct Operations: All employees and contractors across three jurisdictions
• Supply Chains: Equipment procurement (particularly China-sourced materials for infrastructure projects), subcontractors, and service providers
• Client Engagements: Due diligence on clients and projects to ensure our services do not facilitate exploitation

Policies and Controls

• Pre-engagement due diligence on all suppliers and subcontractors
• Contractual requirements for suppliers to comply with anti-slavery standards
• Right to audit supply chains
• Whistleblower channels for reporting suspected violations (see Whistleblower Policy)
• Mandatory training for procurement and operations personnel

Infrastructure Projects

For Project LIGHTHOUSE and subsequent infrastructure deployments in Liberia:

• All construction contractors are required to demonstrate compliance with ILO Fundamental Conventions
• Labor conditions are monitored through regular site inspections
• Workers have access to grievance mechanisms in local languages
• Fair wage standards are enforced per local labor law and international standards

Due Diligence for China Operations

• Factory audits for equipment suppliers
• Verification of labor practices in manufacturing facilities
• Compliance with China's Labor Contract Law and relevant ILO conventions
• Supply chain mapping and transparency requirements

Reporting

Suspected instances of modern slavery should be reported to compliance@averico.com or through the anonymous reporting channel.

This statement is reviewed and updated annually.