Whistleblower & Reporting Policy

Purpose

AVERICO Holdings LLC is committed to maintaining the highest ethical standards. This policy provides a framework for reporting suspected misconduct, fraud, or violations of law, regulation, or company policy without fear of retaliation.

Scope

This policy applies to all AVERICO employees, contractors, agents, and business partners across all jurisdictions (United States, Liberia, China).

What to Report

• Fraud, embezzlement, or financial irregularities
• Bribery or corruption (see Anti-Corruption & FCPA Policy)
• Conflicts of interest
• Violations of law or regulation
• Health and safety concerns
• Environmental violations
• Discrimination or harassment
• Retaliation against previous reporters
• Any violation of AVERICO policies

Reporting Channels

1. Direct Supervisor or Manager -- for non-sensitive matters
2. Chief Compliance Officer -- compliance@averico.com
3. Anonymous Reporting -- ethics@averico.com (monitored by independent counsel)
4. External Authorities -- Nothing in this policy prevents reporting to governmental agencies

Confidentiality

Reports will be treated with the highest degree of confidentiality consistent with conducting a thorough investigation. The identity of reporters will be protected to the fullest extent possible.

Non-Retaliation

AVERICO strictly prohibits retaliation against any person who, in good faith:

• Reports suspected misconduct
• Participates in an investigation
• Refuses to participate in suspected illegal or unethical activity

Retaliation includes termination, demotion, harassment, intimidation, or any adverse action. Violations of this non-retaliation provision will result in disciplinary action.

Investigation Process

1. Reports are acknowledged within 48 hours
2. Preliminary assessment determines scope and resources
3. Investigations are conducted by qualified, independent personnel
4. Findings are documented and reported to appropriate leadership
5. Corrective action is taken as warranted
6. Reporter is informed of the outcome to the extent permissible

Record Retention

Investigation records are retained for a minimum of seven (7) years.