Whistleblower Policy

1. About This Policy

1.1 ElevateAI is committed to conducting business lawfully, honestly and ethically. That commitment depends on people speaking up when something looks wrong. This policy exists so that anyone can raise a serious concern safely, and so that every report is handled seriously, confidentially and without retaliation.

1.2 This policy is issued by ElevateAI, 8 The Green, Ste R, Dover, Delaware 19901, United States.

2. What to Report

2.1 Use this policy to report a good-faith concern about suspected:

• (a) violations of law or regulation by ElevateAI or anyone acting on its behalf;
• (b) fraud, theft, bribery, corruption or financial irregularities, including inaccurate books and records;
• (c) misuse of customer data, unauthorized access, or concealment of a data or security incident;
• (d) misuse of our AI features by ElevateAI personnel, or concealment of harm caused by them;
• (e) danger to the health or safety of any person;
• (f) discrimination, harassment or retaliation within ElevateAI; and
• (g) attempts to conceal any of the above.

2.2 This policy is for serious misconduct concerns. For other matters, use the right channel: billing problems go to billing@elevatenext.ai, privacy requests to privacy@elevatenext.ai, and reports that another user's content or conduct violates our rules go through the Acceptable Use Policy, Section 11.

3. How to Report

3.1 Send your report to legal@elevatenext.ai with "Whistleblower Report" in the subject line, or by mail marked "Confidential: Whistleblower Report" to ElevateAI, 8 The Green, Ste R, Dover, Delaware 19901, United States.

3.2 You may report anonymously, either by mail or by email to legal@elevatenext.ai (you may use an anonymous email address). Please understand that anonymity can limit our ability to investigate or to update you, so include as much detail as you can: what happened, when, where, who was involved, and any supporting documents.

3.3 A helpful report describes the facts as you know them. You do not need proof; a reasonable, good-faith belief is enough.

4. Confidentiality

4.1 We treat the identity of a reporter, and the contents of a report, as confidential. We share them only with the people who genuinely need them to investigate, or where disclosure is required by law. If legal disclosure becomes necessary, we will tell you first where the law permits.

5. No Retaliation

5.1 ElevateAI does not tolerate retaliation of any kind against anyone who, in good faith, reports a concern, provides information or assists in an investigation, whether or not the concern is ultimately substantiated. Retaliation includes termination, demotion, harassment, threats, exclusion and any other adverse action taken because of a report.

5.2 Anyone who retaliates will face disciplinary action, up to and including termination of employment or of their business relationship with ElevateAI. If you believe you have experienced retaliation, report it under Section 3, and it will be treated as a new report under this policy.

6. How We Handle Reports

6.1 We acknowledge non-anonymous reports promptly, normally within five business days.

6.2 Reports are reviewed by a member of management designated to handle them, who decides how each is investigated. Where a report concerns that person, it is escalated to the founder, and where it concerns the founder, it may be referred to outside counsel, so that no one investigates a concern about themselves.

6.3 Investigations are conducted as promptly, fairly and discreetly as the circumstances allow. Everyone involved is expected to cooperate and to keep the matter confidential.

6.4 Where the report allows it, we will tell the reporter when the matter is concluded. Legal and privacy obligations may limit the detail we can share about outcomes.

6.5 We keep records of reports and investigations only as long as needed for legal, regulatory and governance purposes, consistent with our retention practices.

7. Good Faith

7.1 No one will be penalized for a good-faith report that turns out to be mistaken. Knowingly making a false or malicious report, however, is itself misconduct and may lead to disciplinary or legal action.

8. Your Rights Under Law

8.1 Nothing in this policy limits your right to report suspected violations of law directly to a government agency or regulator, to participate in an agency investigation, or to receive an award under an applicable government whistleblower program. You do not need ElevateAI's permission to do any of these things, and you are not required to notify us first.

8.2 This policy adds to, and does not replace, any protections you have under applicable whistleblower-protection laws.

9. Changes to This Policy

9.1 We may update this policy from time to time. The updated version will be posted on this page with a new date at the top.

10. Prior Versions

10.1 This version takes effect on the date at the top of this page and replaces all earlier versions.

11. Contact

Whistleblower reports: legal@elevatenext.ai (subject line "Whistleblower Report"). Mail: ElevateAI, 8 The Green, Ste R, Dover, Delaware 19901, United States, marked "Confidential: Whistleblower Report". Phone: +1 212 287 9171.