Whistleblowing Policy

1. OVERVIEW

EVOTEK, Inc. (“EVOTEK,” “we,” “our,” or “us”) is committed to honest, ethical, and lawful conduct. This Whistleblowing Policy promotes, encourages, requires, and provides the means for employees, vendors, suppliers, and customers to come forward with credible information about suspected wrongdoing, illegal conduct, or violations of EVOTEK policies or contracts for the purpose of creating a transparent and responsible corporate environment. This policy provides that the EVOTEK will investigate credible reports, will act on credible information, and will protect any reporting individual from retaliation.

2. WHAT TO REPORT

You should report concerns about:

• Fraud, theft, or misuse of company resources;
• Safety or health violations;
• Harassment or discrimination;
• Legal or regulatory violations;
• Any attempt to hide wrongdoing;
• Personal complaints unrelated to wrongdoing (like pay disputes) should follow the usual Human Resources process; and
• Other serious misconduct.

3. HOW TO REPORT

Protection applies whether you disclose concerns:

• Internally:
  • A supervisor or any member of management;
    • Human Resources;
    • Legal Department at legal@evotek.com; or

• Externally:
  • Any government, regulatory, or law enforcement agency; or
  • Any public body conducting an investigation, hearing, or inquiry

• Anonymously:
  • You may report anonymously by mail to EVOTEK, Inc., 462 Stevens Avenue, Suite 308, Solana Beach, CA 92075, marked as confidential with attention to General Counsel.

4. PROTECTION

We will not tolerate retaliation against anyone who reports a concern in good faith. Retaliation includes firing, demotion, harassment, or any negative treatment. You are also protected if you refuse to participate in activity you reasonably believe violates a law, regulation, or public policy. You are protected even if EVOTEK believes you made or may make a report, regardless of whether you actually did. Protection extends to individuals engaging in protected activity before hire, participating in investigations, or who reported issues during former employment.

5. INVESTIGATION

All reports will be reviewed and investigated fairly and promptly. We will take appropriate action if wrongdoing is confirmed.

6. IMPORTANT NOTES

Reports must be reasonable, honest and made in good faith and deliberately false claims may lead to disciplinary action.