Whistleblower Policy

Anera is committed to integrity and ethical behavior in all its activities and fosters an environment where employees can raise issues relating to potential waste, fraud and abuse without fear of retaliation.

Anera encourages all employees and other interested persons to report waste, fraud and abuse, as well as other wrongdoing that may adversely impact Anera, its employees, those Anera seeks to assist, or the general public. If concerned about reporting to your supervisor, complaints can be made anonymously, and the confidentiality of any whistleblower will be maintained insofar as possible while Anera investigates any such complaint. (The source of a complaint will be disclosed only as necessary to conduct a thorough investigation.) All reports of suspected waste, fraud and abuse will be forwarded to the chair of the audit committee, which is responsible for investigating any complaints.

If unsure who to contact, you may report a complaint to Anera’s outside counsel:

George Doumar of Doumar Martin, PLLC

+1-703-243-3737

gdoumar@doumarmartin.com.