Modern Slavery and Human Trafficking Policy

Last Updated: November 30, 2021

This policy (the “Policy”) has been published and is made on behalf of Ltd. (the  “Company,” “we” or “our”).  

As a global organization, the Company is committed to high standards of ethical conduct and  compliance with applicable laws and, as such, has a zero-tolerance approach to modern slavery and  human trafficking. We are further committed to implementing effective systems of controls to ensure  modern slavery and human trafficking are not taking place within our own business or in any of our  supply chains. It is our expectation that our suppliers and business partners also conduct themselves in  this manner.  

This Policy applies to all persons working for us or on our behalf in any capacity, including employees  at all levels, directors, agency workers, seconded workers, volunteers, interns, agents, contractors,  external consultants, third-party representatives and business partners. 

Business structure and description of supply chain 

The Company globally sells a leading a project management tool that enables organizations to manage  tasks, projects, and team work. As of 2020, the Company serves over 100,000 organizations, including  many non-technical organizations. 

In the course of our day to day operations we engage with many suppliers of varying sizes and sectors  throughout the world. These suppliers play an integral piece in supporting our growth and sustainability.  

Relevant policies 

We are dedicated to ensuring that our supply chains do not rely on or benefit from slavery or human  trafficking. To this end, we have formulated, and seek to enforce, a code of conduct for our vendors (the “Vendor Code of Conduct”). The Vendor Code of Conduct requires our suppliers to: 

• comply with all applicable human rights laws prohibiting child, forced, indentured, or  involuntary labor. 

• not tolerate harassment by our suppliers in any form, including verbal, physical, or sexual  harassment. 

• to provide equal opportunities in employment, development, and advancement for all qualified  persons.  

By requiring our business partners adherence to the Vendor Code of Conduct, we seek to implement  and maintain a robust framework of controls to prevent slavery and human trafficking in our supply  chains.  

Due diligence in the supply chain 

The Company has overall responsibility for ensuring this Policy complies with its legal and ethical  obligations. Management of the Company are given the necessary training in order to understand and  comply with this Policy (as discussed further below). 

The Company carries out risk assessments in relation to its suppliers and to monitors its suppliers’  compliance with the Code of Conduct as well as any other applicable national regulations. Where the  Company identifies potential risks, we seek to increase our internal and external diligence protocols to 

ensure that all our suppliers are compliant with the Code of Conduct and all applicable national  regulations. 

Where we suspect that any of our suppliers are relying on or benefitting from modern slavery or human  trafficking, we would terminate our relationship with that supplier and make any necessary reports to  the relevant authorities. 

To date, we have received no reports of any incidents relating to modern slavery or human trafficking  in our supply chains.  

Training, reporting, and communication of this Policy 

Each of the Company’s employees and directors are required to adhere to the “Code of Business  Conduct and Ethics” (the “Code”). Pursuant to the Code, employees and directors have a duty to report  any known or suspected violation of the Code, including violations of the laws, rules, regulations or  policies that apply to the Company. Employees are made aware of this through onboarding and through  regular training. 

Further to the Code, we also ensure that our key employees are aware of any potential risk of modern  slavery or human trafficking in our supply chains. 

Compliance with this Policy 

All parties subject to this Policy are expected to adhere to the requirements set out herein. 

We expect all such parties to assist in the prevention, detection and reporting of instances of modern  slavery and/or human trafficking and should any party have knowledge or suspicion of instances of  modern slavery and/or human trafficking relating to or connected to the Company, then they should  inform us as soon as possible. 

In the event of any breach of this Policy, we will carefully consider the circumstances. In relation to  our employees, any breaches of this Policy will be addressed through our disciplinary process and could  ultimately result in dismissal. In relation respect of any other individuals or organisations with whom  we have a business relationship, we will engage with such individuals or organisations and consider the  appropriate steps to take. Such steps could involve a review of the risk mitigation measures in place, a  requirement for the individual/organisation to remedy any identified breach, ongoing monitoring  obligations, and/or the potential termination of the business relationship where appropriate.  

This Policy has been approved by the Board of Directors of the Company. 

Date Approved: May 25, 2021

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