Anti-Corruption & FCPA Compliance Policy

Purpose

AVERICO Holdings LLC and all subsidiary entities are committed to conducting business ethically and in compliance with all applicable anti-corruption laws, including the United States Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and all local anti-corruption laws in the jurisdictions where we operate.

Scope

This policy applies to:

• All AVERICO employees, officers, and directors across all entities
• All agents, consultants, representatives, and business partners acting on AVERICO's behalf
• All operations in the United States, Liberia, and China

Prohibited Conduct

No person subject to this policy shall, directly or indirectly:

• Offer, promise, authorize, or make any payment or transfer of anything of value to any government official, political party, or candidate for political office to obtain or retain business or secure an improper advantage
• Make facilitation or "grease" payments of any kind
• Offer or accept kickbacks, bribes, or improper inducements
• Falsify books, records, or accounts
• Fail to maintain accurate and transparent financial records

Government Official Definition

"Government official" includes any officer or employee of a government or any department, agency, or instrumentality thereof, including:

• Officials of the Government of Liberia (all ministries and agencies, including the National Investment Commission)
• Officials of the People's Republic of China (all levels of government, including SAMR/AMR)
• Officials of United States federal, state, and local government
• Employees of government-owned or government-controlled enterprises (including LTC - Liberia Telecommunications Corporation)
• Officers of public international organizations

Due Diligence Requirements

Before engaging any third-party agent, consultant, or business partner:

1. Conduct background due diligence appropriate to the risk level
2. Obtain written anti-corruption compliance certifications
3. Include FCPA compliance clauses in all agreements
4. Monitor ongoing compliance through periodic audits

Gifts, Hospitality & Entertainment

• All gifts, hospitality, and entertainment must be reasonable, proportionate, and transparent
• Pre-approval is required for any gift exceeding USD $100 in value
• Detailed records must be maintained for all expenditures

Reporting

• All suspected violations must be reported immediately to the Chief Compliance Officer
• Reports can be made through confidential channels (see Whistleblower Policy)
• AVERICO prohibits retaliation against any person who makes a good-faith report

Record Keeping

All transactions must be accurately and fairly recorded in AVERICO's books and records. No off-book accounts, undisclosed funds, or false entries are permitted.

Training

All personnel receive mandatory anti-corruption training upon onboarding and annually thereafter, with jurisdiction-specific modules for Liberia and China operations.

Penalties

Violations of this policy may result in disciplinary action up to and including termination, and may subject individuals to criminal prosecution and civil penalties under applicable law.

Contact

compliance@averico.com

Chief Compliance Officer, AVERICO Holdings LLC