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Spaulding Ridge Anti-Modern Slavery Statement

We strive to make the world a better place.

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Spaulding Ridge has a zero-tolerance approach to slavery and will comply with all applicable local and international anti-slavery regulations (such as, the UK Modern Slavery Act 2015), treaties, conventions, and principles relating to the protection, welfare, and health & safety of all human beings, especially children. We are firmly committed to ensuring a work environment that is free from human trafficking and slavery and acting ethically and with integrity in all our business dealings and relationships.

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Most of our suppliers are next generation Software-as-a-Service (SaaS) applications and cloud hosting services vendors based in the United States of America, Canada, and the European Union. Considering where our vendors and suppliers are based, their nature, and the industry in which we operate, we believe there is a very low risk that modern slavery and human trafficking may affect our business. Nonetheless, we adopt policies and procedures which are designed to:

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  • Ensure all relevant staff are alert to the risk of slavery and human trafficking occurring in our business.
  • Monitor potential risk areas in our business and supply chains.
  • Reduce the risk of slavery and human trafficking in our business and supply chain.
  • Provide protection to whistleblowers.

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For purposes of this Statement, “Modern Slavery” includes forced labor and unlawful child labor. “Human trafficking” includes all form of trafficking in persons, including using them as forced labor or to procure commercial sex acts and/or confiscating or withholding an individual’s immigration documents or passports.

Enforcement Measures

Our Third-Party Risk Assessment Procedure includes reasonable checks and due diligence to ensure that our vendors and suppliers comply with the standards that apply to them. This due diligence may include raising enquiries asking about relevant policies and working conditions.

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Our bandmates are instructed to avoid complicity in any practice that constitutes trafficking in persons or slavery. This applies to all Spaulding Ridge entities and Bandmates, including our international subsidiaries.

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Bandmates are asked to report any conduct they believe to be constitutive of the above to the Legal or Human Resources departments. Failure to report actual or suspected misconduct is considered policy violation subject disciplinary action.

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Our Code of Conduct and Business Ethics makes clear to our bandmates the actions and behavior expected from them when representing the organization (including that we will not tolerate modern slavery and human trafficking affecting any part of our business or supply chain). We strive to maintain the highest standards of employee conduct and ethical behavior.

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We include appropriate contractual compliance commitments and protections in our agreements with our suppliers where necessary.

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Our HR Team continues to ensure that we comply with all applicable laws in the territories in which we are based. We are proud of the work environment we provide for our staff and the vibrant culture that permeates our business.

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For more information on the structure and business of the Spaulding Ridge, please see www.spauldingridge.com

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This statement is made pursuant to section54(1) of the UK Modern Slavery Act 201

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