Annual Ethics and Governance Compliance Report

Conflict of Interest and Related Party Transactions
Summary
SECTION 1. Purpose.
(a) Action Requested. This Policy requires members of item is submitted to the Board of Governors and designated Company officers to disclose actual, potential, or perceived Conflicts of Interest and to avoid participating in Board or committee decisions where those conflicts exist. This Policy also establishes approval and recordkeeping requirements for Related Party Transactions.
Control ID Value Policy Number BP1003 Policy Title Conflict of Interest and Related Party Transactions Policy Type Board Policy Responsible Office Office of Board Relations Policy Owner Manager, Board Relations Contact Email: board@blevinsholdings.com
Phone: Available upon request Approved by Board of Governors Effective June 25, 2026 Reviewed June 25, 2026 Sunset June 24, 2027 Next Review Due June 2027 Purpose
This Policy protects information. No action is requested.

SECTION 2. Background.
(a) Corporate Structure & Governing Mandate.
(1) Enterprise Scope. Blevins Holdings LLC from Conflicts of Interest and improper Related Party Transactions. It establishes disclosure, review, approval, recusal, and recordkeeping requirements so that Board (d/b/a Blevins Holdings) operates as a multi-sector holding company platform coordinating enterprise services, business operations, real estate, and committee decisions are made fairly, transparently, governance across its core operating divisions:
(A) Enterprise Operations & Government Contracting;
(B) Technology, Data & Cybersecurity;
(C) Healthcare, Pharmaceutical & Research;
(D) Infrastructure & Energy; and
(E) Regulated Industries & Defense Capabilities.
(2) Oversight Authority. Pursuant to the governance principles established by Executive Leadership and in the best interests Board of the Company.
Scope
This Policy applies to all Governors, the Clerk of Legal, Risk & Compliance function maintains centralized compliance oversight across all holding assets and operational platforms.

(b) Operational Pillars & Compliance Framework.
(1) Four-Stage Operational Model. Given the Board complex, highly regulated nature of Governors, the Chief Executive Officer, platform's portfolio—spanning government procurement, defense-supported manufacturing, health sciences, cloud data architecture, and other officers when they participate in Board or committee decisions.
This Policy applies commercial real estate—compliance controls are structured around a continuous four-stage operational model:
(A) Assess. Systematically evaluating statutory, regulatory, and contractual obligations prior to decisions, approvals, transactions, arrangements, contracts, votes, project initiation and recommendations involving Blevins Holdings LLC, its departments, contract execution;
(B) Organize. Structuring data schemas, access controls, vendor disclosures, and any subsidiary or affiliated entity acting under Board authority.
Policy Statement
The Board of Governors supervisory reporting channels;
(C) Execute. Deploying enterprise management software, docket controls, and each Governor must avoid Conflicts of Interest corporate governance policies across all operating units; and
(D) Improve. Reviewing internal audit outcomes, mitigating operational exposure, and must act in the best interests of Blevins Holdings LLC. A Governor or officer must disclose any actual, potential, or perceived Conflict updating risk controls to ensure organizational resilience.

(c) Scope of Interest before participating in a matter involving the Company.
The Company must review Annual Review.
(1) Reporting Period. This report covers all compliance activities, governance initiatives, risk management audits, and approve any Related Party Transaction before it is executed, unless the Board of Governors or a designated committee determines that an exception applies under this Policy.
Definitions
Board of Governors : The governing body of Blevins Holdings LLC
Company : disclosure cycles completed across Blevins Holdings LLC
Conflict of Interest : Any situation in which a Governor's personal, financial, professional, or other outside interest could improperly influence, or appear to improperly influence, the Governor's judgment or decision-making on behalf of the Company
Governor : A member of the Board of Governors.
Immediate Family : A spouse, domestic partner, parent, child, sibling, or any other individual living in the same household as a Governor or officer.
Material Interest : An ownership, compensation, employment, fiduciary, financial, or other interest that could reasonably affect independent judgment.
Related Party Transaction : Any transaction, agreement, arrangement, or relationship between LLC for the Company preceding fiscal year (FY 2025–2026).

SECTION 3. Discussion.
(a) Division-Specific Compliance & Operational Highlights.
(1) Enterprise Operations & Government Contracting.
(A) Procurement Integrity. Maintained strict vendor qualification and a Governor, the Governor's Immediate Family, or an entity in which the Governor or Immediate Family member has a Material Interest.
Requirements
Duty to Disclose
Each Governor must promptly disclose any actual, potential, or perceived Conflict of Interest contract-alignment controls across all active federal, state, and institutional procurement workflows.
(B) Document Control & Custody. Enforced unified master data management standards to the Board of Governors or the relevant Board committee. Each Governor must complete an annual Conflict of Interest Disclosure Statement ensure absolute chain-of-custody, regulatory access control, and must update that statement when circumstances change.
Review record retention compliance across legal and Recusal
When a Conflict administrative dockets.
(2) Technology, Data & Cybersecurity.
(A) Information Security Frameworks. Continued implementation of Interest is disclosed, the interested Governor must recuse themselves from discussion, deliberation, recommendation, enterprise Shared Responsibility Matrices across cloud environments and voting on the matter unless the disinterested Governors request limited information from the interested Governor.
The disinterested Governors must determine whether the matter is fair, reasonable, digital infrastructure.
(B) Data Management Protocols. Completed full technical reviews of master data location schemas and docket management software architecture, resulting in zero critical data security breaches during the best interests reporting period.
(3) Healthcare, Pharmaceutical & Regulated Industries.
(A) Regulated Venture Review. Maintained compliance oversight, research ethics standards, and risk protocols across all healthcare venture coordination and platform development initiatives.
(B) Defense & Controlled Platforms. Verified strict physical, operational, and digital safeguards surrounding defense-supported production and contract alignment, ensuring adherence to applicable federal security regulations.

(b) Conflict of the Company.
Related Party Transactions
The Company must not enter Interest (COI) & Governance Review.
(1) Executive & Supervisory Completion. Achieved a Related Party Transaction unless disinterested 100% completion rate for annual conflict of interest disclosures across members of the Board of Governors or a Governors, executive officers, and designated committee approve the transaction in advance after full disclosure. The Board of Governors division managers.
(2) Disclosure Evaluation. All declarations involving external business affiliations, property holdings, or designated committee must document the basis for approval, including why the transaction is fair, reasonable, secondary roles were formally reviewed by Legal, Risk & Compliance. Conflict Management Plans (CMPs) were executed where necessary to enforce strict recusal protocols and in the best interests of the Company.
The Office operational independence.

(c) Training, Audits & Metrics Summary.
(1) Program Metrics.
(A) Code of Board Relations must maintain Business Conduct. Achieved a register of approved Related Party Transactions.
Documentation
Meeting minutes or other Board records must reflect the disclosure, the recusal, the disinterested review, and the decision made by the Board of Governors or designated committee.
The Company must retain disclosure statements 98.8% completion rate among all personnel, fulfilling mandatory re-certification across all operating divisions.
(B) Data Security & Privacy Protocols. Achieved a 99.4% completion rate among systems and Related Party Transaction records according IT staff, verifying adherence to applicable records retention requirements.
Prohibited Conduct
A Governor or officer must not use their position cloud security frameworks and data routing rules.
(C) Government Contracting Ethics. Achieved a 100% completion rate among procurement personnel, demonstrating full alignment with the Company federal and state procurement compliance standards.
(D) Third-Party Risk Assessment. Completed comprehensive reviews for improper personal gain. A Governor or officer must not participate in a decision when their independence may reasonably be questioned because of a Conflict of Interest.
Roles key vendors and Responsibilities
Governors : Disclose Conflicts of Interest promptly, complete suppliers, standardizing due diligence and risk screening for all external contractors.

(d) Strategic Initiatives for the Upcoming Fiscal Cycle.
(1) Priority Action Items.
(A) Centralized Compliance Portal. Streamlining subsidiary reporting, vendor onboarding, and annual disclosure statements, update disclosures when circumstances change, filings into an integrated digital management system.
(B) Enhanced Supply Chain Due Diligence. Expanding automated screening for vendor relationships supporting defense and recuse themselves when required.infrastructure platforms.
(C) Policy Framework Harmonization. Reviewing and updating internal employee handbooks, data retention schedules, and corporate governance codes to reflect evolving regulatory standards.