http://avalonadvancedmaterials.com/_resources/sustainability/AVL-http://avalonadvancedmaterials.com/about/governance/ 30 2019 SUSTAINABILITY REPORT Mechanisms for advice and concerns about ethics 102-17 The Whistleblower Protection Policy establishes procedures for managing complaints received regarding accounting, internal accounting controls, auditing matters or violations of the Company’s Code of Business Conduct and Ethics.