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Anti-Slavery & Human Trafficking Policy

Effective as of May 31, 2022

Introduction

Firmex is a global provider of virtual data room and secure document sharing solutions. As one of the world’s most widely used virtual data rooms, Firmex supports complex processes for organizations of all sizes, including diligence, compliance, and litigation. Whenever professionals need to share sensitive documents beyond the firewall, Firmex is their trusted partner. A Firmex subscription provides simple, safe, and stress-free document sharing without hidden costs or complexity. Since 2006, Firmex has helped over 120,000 companies worldwide take control of their confidential documents. Firmex is serious about our products and serious about our commitment to corporate social responsibility wherever and whenever we engage in business. Firmex recognizes that this commitment must also include actions intended to lead to the eradication of slavery and human trafficking worldwide.

Structure, Business and Supply Chain

The Firmex Anti-Slavery and Human Trafficking policy statement applies to all employees of Firmex. In performance of its core business, Firmex engages with suppliers, vendors, contractors, partners and other entities or individuals who perform services or provide resources for Firmex. Firmex intends that the policy herein be applied to any entity that works with Firmex.

Policies on Slavery and Human Trafficking

Firmex has a responsibility to be alert to slavery and human trafficking in our business and in our work with third party vendors and suppliers. Our Anti-Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Due Diligence Processes for Slavery and Human Trafficking

As part of our initiative to identify and mitigate risk, Firmex is committed to building and maintaining long-standing relationships with qualified customers, third party vendors and suppliers and to make clear our expectations of business behavior.

Firmex has established a framework for business accountability to allow for raising issues, and reporting slavery and human trafficking.

In furtherance of these goals, Firmex has in place systems to identify and assess potential risk areas in our supply chains, monitor potential risk areas in our supply chains, and a hotline program to both encourage reporting and protect whistleblowers.

Supplier Adherence to Our Values and Ethics

With regards to our national or international vendors or suppliers, we expect these entities to have suitable anti-slavery and human trafficking policies and processes. Firmex has zero tolerance to slavery and human trafficking. We expect all those that we engage in business with to comply with our values and the law.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business and our supply chain. .We include training and this Policy to all relevant staff. All employees have been informed of Firmex’s expectations regarding slavery and human trafficking via Annual Security & Compliance Training.

Our Effectiveness in Combatting Slavery and Human Trafficking

In order to assess the effectiveness of our modern slavery measures we review annually the following key performance indicators:

  • Whistleblowing
  • Employees understanding and awareness of this policy
  • Number of incidents reported
  • Employee Code of Conduct

Further Steps

In addition, we use the following systems to ensure that slavery and human trafficking is not taking place in any part of our business or with our vendors or suppliers:

  • Completion of contract screening and review by the HR team
  • Use of payroll systems

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our group’s slavery and human trafficking statement for the current financial year. It was approved by the General Manager on May 31, 2022.