SELLEXIO INVOICE INTEGRITY & ANTI-FRAUD POLICY Version 2026.08 · Binding on all clients, advisors, partners and personnel This Policy is incorporated by reference into the Terms of Service, the Master Services Agreement, the Pilot Agreement, the Advisory & Consulting Agreement, and the Referral & Success-Fee Agreement. In this Policy, "Participant" means any client, advisor, consultant, referral partner, contractor, or employee interacting with the Sellexio platform or engagement process. 1. PURPOSE. Sellexio recovers money by asserting that specific charges were billed incorrectly. Every recovery depends on the authenticity of the underlying documents. A single fabricated or altered document can void a claim, expose the client and Sellexio to carrier counterclaims, insurance denial, and criminal liability. This Policy exists to protect both sides: the Participant is protected from being blamed for a claim they did not fabricate, and Sellexio is protected from asserting a claim that is not genuine. 2. PROHIBITED CONDUCT. The following are strictly prohibited: (a) Creating, editing, retyping, re-rendering, or "cleaning up" an invoice, bill of lading, statement of fact, gate-in/gate-out record, equipment interchange receipt, arrival notice, tariff page, or bank record so that it no longer matches the original issued document. (b) Back-dating, forward-dating, or altering timestamps, container numbers, vessel names, voyage numbers, free-time terms, currency, or amounts. (c) Submitting the same charge, invoice, or recovery item more than once, across entities, or across engagements, to inflate recovery or commission. (d) Submitting documents relating to shipments, containers, or entities that do not exist, were cancelled, or in which the Participant has no legitimate interest. (e) Submitting documents obtained without authorization, including material taken from a current or former employer, a customer's system, or any account the Participant is not entitled to access. (f) Inflating or fabricating recovery amounts, savings, introductions, meetings, activity records, or expenses. (g) Colluding with a carrier, terminal, forwarder, broker, or employee of a client to generate, split, or conceal a charge or a recovery. (h) Paying, offering, soliciting, or accepting any bribe, kickback, facilitation payment, or improper inducement. (i) Using Sellexio outputs, report templates, or redacted case material to support a claim Sellexio did not audit, or misrepresenting Sellexio's findings. (j) Requesting or directing payment to a bank account other than the Participant's own verified account, or attempting to change banking details by email alone. 3. SOURCE-DOCUMENT STANDARD. Documents submitted for audit must be the original file as issued by the carrier, terminal, agent, or forwarder — the original PDF, EDI, or system export, or a complete, unedited scan or photograph of the paper original. Participants must preserve the original file and the transmission record (email header, portal download, or EDI log) for three (3) years. Redaction of unrelated commercial terms is permitted; alteration of any figure, date, party, or identifier is not. 4. VERIFICATION CONTROLS APPLIED BY SELLEXIO. Sellexio applies automated and human controls to every submission, including: file-hash and duplicate detection across the tenant and the platform; document-metadata and revision inspection; cross-checking invoice line items against carrier tariff schedules and the applicable local charge schedule; reconciliation of demurrage and detention clocks against independent AIS vessel movement and terminal gate data; arithmetic and currency-conversion re-computation; charge-code completeness and expected-charge testing; consistency testing so that identical facts produce identical findings; counterparty sanctions and watchlist screening; and human review of any claim above materiality thresholds. Confidence scores and evidence gaps are disclosed in the audit report rather than concealed. 5. EVIDENCE REQUIREMENTS. A recovery claim is only advanced where the mandatory evidence for that charge family is present — typically the carrier invoice, the bill of lading or waybill, the applicable tariff or local charge schedule, the statement of facts or terminal gate record, and proof of payment. Where mandatory evidence is missing, the finding is marked unsupported and is not asserted as a claim. 6. PARTICIPANT WARRANTIES. By submitting any document or claim, the Participant warrants that: it is genuine, complete, and unaltered; the Participant is lawfully entitled to hold and share it; the charges relate to real shipments in which the client has a commercial interest; no item has been submitted elsewhere for the same recovery; and the Participant has disclosed any known dispute, credit note, or prior settlement affecting the charge. 7. SUSPENSION AND INVESTIGATION. Where Sellexio has reasonable grounds to suspect a breach, Sellexio may immediately suspend the engagement, freeze affected claims, withhold payments and commissions, and preserve all related records. Sellexio will notify the Participant in writing with the reason, and the Participant will have ten (10) business days to respond with evidence. Sellexio will make its determination in good faith and will document it in the audit ledger. Participants are protected in the same way: no finding of fraud is recorded without notice, a stated reason, and an opportunity to respond. 8. CONSEQUENCES OF BREACH. Confirmed breach results in: immediate withdrawal of the affected claim from the carrier or terminal; termination of the applicable agreement for cause; forfeiture of all fees, commissions, and success fees connected to the affected matter; repayment of amounts already paid on the affected matter within fifteen (15) days; permanent removal from the partner and advisor programmes; and, where the conduct appears criminal, referral to law enforcement, regulators, insurers, and affected counterparties. Sellexio may recover its investigation costs and legal fees. These remedies are cumulative and in addition to any other right. 9. CLIENT-SIDE MISCONDUCT. Where a client submits non-genuine documents, Sellexio will withdraw the affected claims, notify the client in writing, and may terminate the mandate. The client remains liable for Sellexio's fees on genuine recoveries already collected and indemnifies Sellexio against any claim brought by a carrier, terminal, insurer, or authority arising from the non-genuine material. Sellexio does not indemnify any party against the consequences of documents that party fabricated or altered. 10. PAYMENT-FRAUD CONTROLS. Sellexio will never request a change of banking details by email alone. Any change to payment details — in either direction — is verified by a live voice or video call with a known contact before funds move. Invoices to clients are issued only from sellexio.co addresses and reference an engagement identifier. Participants must report any suspicious payment request to legal@sellexio.co immediately. Neither party is liable for payments made in reliance on details the other party supplied and confirmed through this verification process. 11. SANCTIONS, AML AND EXPORT CONTROL. Sellexio screens clients, counterparties, vessels, and beneficial owners against OFAC, EU, UK, UN, and Canadian sanctions lists and will decline or terminate any engagement involving a sanctioned party, a vessel engaged in AIS-dark behaviour indicative of sanctions evasion, or proceeds Sellexio reasonably believes to be criminal in origin. 12. CONFLICTS OF INTEREST. Advisors and partners must disclose in writing any ownership, employment, family, or commission relationship with a client, prospect, carrier, terminal, or forwarder involved in a matter, before working on it. Undisclosed conflicts are treated as a breach of this Policy. 13. DATA PROTECTION. Investigation material is handled under the Data Processing Agreement at /legal/dpa, retained in the tamper-evident audit ledger, and disclosed only to personnel, professional advisors, insurers, or authorities with a legitimate need. 14. WHISTLEBLOWING AND NON-RETALIATION. Any person may report a suspected breach in confidence to legal@sellexio.co. Reports may be made anonymously. Sellexio will not retaliate against, terminate, or withhold payment from any Participant for a good-faith report, and will treat the reporter's identity as confidential to the extent permitted by law. 15. GOOD-FAITH ERRORS. This Policy targets deliberate misconduct. A genuine error — a wrong container number, a duplicate upload, a stale tariff page — is not fraud. Participants who identify and disclose an error promptly will not be penalised; the affected finding is simply corrected or withdrawn and the record is annotated. 16. RECORD RETENTION AND AUDIT TRAIL. Every upload, extraction, human edit, AI output, review decision, claim assertion, and payment event is written to an append-only ledger with actor, timestamp, and hash. Records are retained for seven (7) years and are available to a Participant in respect of its own matters on written request. 17. UPDATES. Sellexio may update this Policy. Material changes take effect thirty (30) days after posting or notice, except changes required by law, which take effect immediately. The version and date at the head of this document control. Questions or reports: legal@sellexio.co