Vertical Screen, Inc. Anti-Slavery Policy

1. Overview

Vertical Screen, Inc. (“Vertical Screen”) values human rights and is committed to ensuring that all business is conducted according to ethical, professional, and legal standards in a fair, honest, and open manner. Modern Slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced labor, trafficking, child labor, or debt bondage. Vertical Screen has a zero-tolerance policy for Modern Slavery within all business operations and client relationships. We are committed to acting with the utmost ethics and integrity in all business operations, and we strive to ensure Modern Slavery does not take place within our workplace.

2. Purpose

This Anti-Slavery Policy (“Policy”) sets out our expectations and commitments in accordance with the United Kingdom (UK) Modern Slavery Act of 2015 and the Australian Modern Slavery Act of 2018. This Policy promotes Vertical Screen’s compliance with applicable obligations under these Modern Slavery Acts. This Policy expands on Vertical Screen policies and implements further standards to adhere to anti-slavery principles.

3. Scope

This Policy applies to all Vertical Screen directors, officers, and employees. This Policy is meant to supplement our Code of Conduct and our Business Ethics policy set forth in our Employee Handbook.

4. Confidentiality

Any employee who believes that a violation of this Policy has occurred or is likely to occur must notify their supervisor and the Legal department, or submit a report at Vertical Screen Incident Reporting. All reports will be kept confidential to the extent possible and will be appropriately managed. Employees will not experience any retribution or retaliation for reporting a suspected violation in good faith.

5. Policy Statement

Vertical Screen employees, contractors, subcontractors, representatives, and agents must not engage in any practice that constitutes any form of Modern Slavery. This includes, but is not limited to, the following activities:

• Engaging in any form of trafficking in persons;
• Using forced labor in the performance of any work;
• Destroying, concealing, confiscating, or otherwise denying access by an individual to their identity or immigration documents, such as passports or driver’s licenses, regardless of issuing authority;
• Using misleading or fraudulent practices during the recruitment or offering of employment/contract positions to candidates. This may include failing to disclose, in a format and language accessible to the potential candidate, basic information or making material misrepresentations during recruitment regarding key terms and conditions, including wages and fringe benefits, the location of work, the living conditions, housing and associated costs, any significant cost to be charged to the candidate, and, if applicable, the hazardous nature of the work;
• Using recruiters that do not comply with local laws or charging applicants/candidates recruitment fees;
• If required by law or contract, failing to provide an employment offer, recruitment agreement, or other required work document in writing.

6. Compliance with this Policy

Some measures to promote compliance with this Policy include:

• All Vertical Screen employees acknowledge receipt of our Code of Conduct that provides similar expectations to ensure ethics in the workplace.
• Conducting due diligence on business partners, agents, contractors, consultants, subcontractors, and suppliers.
• Training all relevant individuals throughout Vertical Screen to recognize and enforce compliance with this Policy. Such training may include: history of the problem, risk to our organization, how to identify signs of Modern Slavery, and how to respond to Modern Slavery.
• Performing routine monitoring activities, both internal and external, to verify that business is conducted in compliance with Modern Slavery laws.
• Providing transparency in our business operations and implementation of this Policy.
• Reviewing insight and guidance from various labor and human rights groups.
• Sanctioning clients and vendors who fail to comply with Modern Slavery laws.

7. Violations of this Policy

Any employee who violates this Policy by engaging in or conspiring to engage in any Modern Slavery conduct will face disciplinary action. This could, in the most severe circumstances, include immediate dismissal for misconduct or gross misconduct and, if warranted, legal proceedings may be brought against the employee.