## Q26 key (Hotline Clock)

1. Preserve first: suspend seven-day chat deletion, 21-day finance-log rollover, weekend purge, and deletion on company and work-used personal devices; issue a focused hold to Cole, finance, compliance, East Reach managers, customs staff, and IT. Missed: the most probative communications disappear before credibility is tested.
2. Pause the four-installment payment stream if any remains, block new East Reach facilitation payments, preserve the relationship rather than destroy evidence, and prohibit witness coordination or retaliation. Missed: suspected conduct continues or the investigation is tainted.
3. Form an independent board committee excluding Cole's close allies and retain outside counsel to direct legal investigation. Separate legal advice from ordinary remediation and give company-representation, privilege-control, separate-counsel, and nonretaliation warnings. Missed: implicated management controls scope or employees receive false personal assurances.
4. The attachments likely reach credible evidence already: a disguised $240,000 invoice, reimbursement trail, and instruction to hide government names support a reasonable belief beyond a bare hotline claim, even though the ultimate recipient remains unknown. Treat August 2 as the conservative clock date while documenting the unresolved threshold. Missed: Solstice waits for proof beyond the program's reasonable-belief standard and loses credit.
5. Within seven days collect bank beneficiary data, East Reach's subledger and contracts, consultant identity and ownership, customs-entry files, invoices, approvals, device messages, and interviews beginning with nonimplicated record custodians before Cole. Missed: the disclosure decision rests on labels rather than the money path.
6. Set a committee decision no later than day 10 to 14, not day 30. If evidence supports payment to an official or an intermediary for that purpose, disclose before regulator contact and within 30 days; identify known facts, participants, amounts, and uncertainties and commit to supplement. Missed: a perishable leniency option is treated as a last-day filing.
7. Do not disclose privileged advice, interview impressions, or legal theories, but disclose underlying facts truthfully. If records establish only legitimate brokerage, document the basis and continue remediation without a false self-accusation. Missed: privilege is unnecessarily waived or uncertainty is presented as exoneration.