Whistleblowing Policy

1. PURPOSE & SCOPE

VORDR International LLC is committed to maintaining the highest standards of integrity, accountability, operational ethics, and legal compliance.

In alignment with our:

• Code of Ethics

• Anti-Bribery Policy

• ISO 9001:2015 Quality Standards

• NIST SP 800-171 Security Controls

• CMMC Compliance Requirements

we expect all employees, independent contractors (1099 representatives), vendors, subcontractors, clients, and business partners to uphold these standards at all times.

The purpose of this Whistleblowing Policy is to provide a secure, confidential, and reliable mechanism for reporting suspected misconduct, unlawful activity, ethical violations, or security breaches without fear of retaliation, discrimination, intimidation, or professional harm.

This Policy applies to all personnel associated with VORDR International LLC, including:

• Directors

• Officers

• Employees

• 1099 Independent Contractors

• Subcontractors

• Consultants

• Third-Party Partners

2. REPORTABLE CONDUCT

This Policy addresses serious concerns that extend beyond ordinary workplace grievances or routine human resources matters.

Reportable conduct includes, but is not limited to:

Financial Misconduct & Fraud

• Corruption

• Bribery

• Embezzlement

• Money laundering

• Theft

• Fraudulent financial reporting

Violations of Law or Regulatory Requirements

Any breach of applicable federal, state, or international laws, including but not limited to:

• ITAR regulations

• Export control laws

• Cybersecurity regulations

• Security licensing requirements

• Contractual compliance obligations

Human Rights Violations

Breaches of VORDR’s Human Rights Policy, including:

• Physical abuse

• Coercion

• Exploitation

• Harassment

• Severe labor law violations

• Unethical conduct in operational environments

Cybersecurity & Data Protection Violations

Including:

• Intentional bypassing of NIST SP 800-171 or CMMC security controls

• Unauthorized access to Controlled Unclassified Information (CUI)

• Mishandling or disclosure of sensitive client information

• Unauthorized system intrusion or misuse

Health, Safety & Environmental Risks

Any action or negligence that creates a serious threat to:

• Public safety

• Personnel safety

• Operational security

• Environmental protection

Deliberate Concealment

Any attempt to:

• Destroy evidence

• Conceal wrongdoing

• Obstruct an investigation

• Intimidate witnesses or reporting parties

3. SAFEGUARDS, CONFIDENTIALITY & ANONYMITY

VORDR International LLC is fully committed to protecting individuals who report concerns in good faith.

Strict Confidentiality

The identity of any whistleblower will be treated as strictly confidential throughout the investigative process.

Identifying information will not be disclosed without the individual’s consent unless disclosure is required by applicable law, court order, or regulatory obligation.

Anonymous Reporting

Individuals may choose to submit reports anonymously.

While anonymous submissions will be investigated to the fullest extent possible, VORDR encourages the inclusion of detailed evidence and supporting information to facilitate a thorough review.

Protection Against Retaliation

(Zero Retaliation Policy)

VORDR strictly prohibits retaliation in any form against individuals who report concerns in good faith.

Prohibited retaliatory actions include:

• Harassment

• Demotion

• Suspension

• Threats or intimidation

• Discrimination

• Contract termination

• Professional retaliation

Any employee, contractor, or representative found engaging in retaliatory conduct will be subject to immediate disciplinary action, up to and including termination for cause.

4. HOW TO REPORT A CONCERN

VORDR provides multiple secure reporting channels to accommodate varying levels of urgency and sensitivity.

Direct Compliance Email Channel

Reports may be submitted directly to the Compliance Department at:

Support@vordrinternational.net

This mailbox is access-controlled and monitored exclusively by authorized compliance personnel utilizing Multi-Factor Authentication (MFA) protections.

Physical Mail Submission

Confidential written reports may be mailed to:

VORDR International LLC
Attn: Compliance & Legal Department (CONFIDENTIAL)
1005 Congress Avenue, Suite 925
Austin, TX 78701

5. INVESTIGATION PROCESS

Upon receiving a report, VORDR International LLC will conduct a structured, impartial, and confidential review process.

1. Acknowledgment

Receipt of the report will be acknowledged within seven (7) business days whenever possible, unless the submission was anonymous and contained no contact information.

2. Initial Assessment

An initial evaluation will determine:

• Whether the matter falls within the scope of this Policy; and

• Whether a formal investigation is warranted.

3. Formal Investigation

Where appropriate, a confidential and independent investigation will be initiated.

Investigators may request additional information, documentation, or clarification from the reporting individual when necessary.

4. Resolution & Corrective Action

If wrongdoing is substantiated, VORDR will take appropriate corrective measures, which may include:

• Disciplinary action

• Contract termination

• Security remediation

• Referral to federal, state, military, or international law enforcement authorities

5. Outcome Notification

Where legally permissible and operationally appropriate, the whistleblower may be informed of the outcome or resolution of the investigation.

6. FALSE OR MALICIOUS ALLEGATIONS

This Policy is intended to protect individuals who raise legitimate concerns in good faith.

Any person who knowingly submits false, malicious, or intentionally misleading allegations may be subject to disciplinary action, including:

• Employment termination; or

• Immediate cancellation of contractor or vendor agreements.