Corporate Social Responsibility

Anti-Slavery and Human Trafficking Policy

1. BACKGROUND

1. Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
2. We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
3. This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
4. This policy does not form part of any employee’s contract of employment, and we may amend it at any time.

2. RESPONSIBILITY FOR THE POLICY

1. The Class A member, TRI Ventures Inc, has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
2. The Ethics Committee, which comprises of representatives from our Senior Management, HR and Legal departments, has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
3. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
4. You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Ethics Committee or your local HR.

3. COMPLIANCE WITH THE POLICY

1. You must ensure that you read, understand and comply with this policy.
2. The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
3. You must notify your manager, or the Ethics Committee, as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.
4. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
5. If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify your manager or the Ethics Committee or report it in accordance with our Code of Business Ethics as soon as possible.
6. If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager or the Ethics Committee.
7. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform HR immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.

4. COMMUNICATION AND AWARENESS OF THIS POLICY

1. Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the on-boarding process for all individuals who work for us, and regular training will be provided as necessary.
2. Our zero-tolerance approach to modern slavery in our business and supply chains must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

5. BREACHES OF THIS POLICY

1. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
2. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy

Code of Business Ethics and Code of Conduct

To ensure orderly operations and provide the best possible work environment, Aquent expects you to follow rules of conduct that protect the interests and safety of the organization and its employees.

The reputation of Aquent has been built on providing excellent service and collaboration. Maintaining this reputation requires the active participation of every employee; everyone must be sensitive to the importance of providing courteous treatment in all working relationships.

It is not possible to list all the forms of behavior that are considered unacceptable in the workplace. Aquent will take necessary and appropriate action to ensure a meaningful and healthy work environment, bearing in mind the Company’s at-will employment policy.

CODE OF BUSINESS ETHICS

It is Aquent’s policy to conduct its affairs in accordance with the highest ethical business practices and to comply with all applicable laws and regulations worldwide. This Employee Code of Conduct and Business Ethics (the Code) sets forth legal and ethical standards of conduct for all officers and employees of Aquent. Although it is the purpose of the Code to present a clear statement of what is expected of all Aquent employees, the Code cannot address all possible situations of concern that may arise. Accordingly, Aquent also has a number of other policies and procedures in place that provide guidance and that all Aquent employees are expected to follow.

Aquent has the duty to communicate to all employees the standards of ethics and conduct set forth in this Code and the responsibility to enforce these standards at all levels. Every employee of the Company has the duty to read, understand, and comply with this Code. Any employee who has questions about, or suspects violations of, the Code has the duty to contact his or her manager or Human Resources.

Aquent employees are expected to use good judgment and common sense in seeking to comply with this policy and to ask for advice when they are uncertain. This Code applies to Aquent and all of its subsidiaries and other business entities controlled by Aquent worldwide.

Aquent requires that all employees, directors, contractors, and agents comply with all laws, rules, and regulations applicable to Aquent wherever it does business and that all such individuals conduct themselves in a manner consistent with the highest standards of business ethics and practices. If you become aware of the violation of any law, rule, or regulation by the Company, whether by its officers, employees, or directors or any third party doing business on behalf of the Company, it is your responsibility to promptly report the matter to your manager, who shall promptly report it to Human Resources. If, for whatever reason, you do not wish to report any violations to your manager or to Human Resources, you can make a written report to the Board of Directors. Any such report should be addressed to Aquent Board of Directors, 711 Boylston Street, Boston, MA 02116, U.S.A. It is important to remember that Aquent must be made aware of potential corporate misconduct before it can take corrective action.

Upon receipt of any employee complaint or concern regarding possible corporate misconduct, Aquent will conduct a prompt investigation. The investigation will be kept confidential to the extent possible and will normally involve interviews with those involved and a review of relevant materials, documents, procedures, etc. If warranted, Aquent will take prompt remedial action to correct any misconduct and prevent future misconduct.

No retaliation will be tolerated against any employee who makes a good-faith report of corporate misconduct or potential misconduct. Any attempt at retaliation will be subject to appropriate disciplinary action, up to and including termination.

While it is the Company’s desire to address matters internally, nothing in this Code should discourage you from reporting any illegal activity, including any violation of securities laws; antitrust laws; environmental laws; or any other federal, state, or foreign law, rule, or regulation, to the appropriate regulatory authority. Employees and directors shall not discharge, demote, suspend, threaten, harass, or in any other manner discriminate or retaliate against an employee because he or she in good faith reports any such violation. This Code should not be construed to prohibit you from testifying, participating, or otherwise assisting in any state or federal administrative, judicial, or legislative proceeding or investigation.

Managers and supervisors of Aquent have a duty to make certain that all employees under their supervision are advised of the current provisions of the Code and are periodically reminded of the importance of adhering to the principles set forth in it. Managers and supervisors of Aquent also have the duty to create and maintain an environment where each employee feels responsible for and comfortable with complying with this Code and reporting actual or suspected violations of it, without fear of retribution or retaliation.

CODE OF CONDUCT

Aquent expects all employees to act in a positive manner and contribute to a productive work environment. To provide some guidance concerning unacceptable behavior, the following are examples of the types of conduct that are impermissible and are considered sufficient reasons for disciplinary action, including termination of employment. However, reasons for discipline and termination are not limited to those specifically listed below, and such reasons do not change the fact that all employees are at-will employees and that either the employee or Aquent may terminate the employment relationship at any time, with or without cause or notice. Aquent may exercise its discretion to utilize forms of discipline that are less severe than termination in certain cases. Examples of such less severe forms of discipline include verbal warnings, written warnings, and suspensions. Although one or more of these steps may be taken in connection with a particular employee, no formal order or system is necessary. Aquent may, of course, terminate an employee without following these steps whenever it determines that such action is warranted.

• Insubordination, including improper conduct toward a supervisor or refusal to perform tasks assigned by a supervisor
• Release of Aquent’s confidential information or that of any of its clients
• Unauthorized removal of property from or possession of property belonging to Aquent, coworkers, clients, or anyone on Company or client property
• Altering or falsifying any timekeeping record, filling out another employee’s time sheet without proper authorization, allowing someone else to fill in your time sheet, or destroying your own or another employee’s time sheet
• Absence for three (3) or more consecutive workdays without notice to your immediate manager, unless a reasonable excuse is offered by you and accepted by Aquent
• ƒƒFalsifying or making a material omission on an employment application or any other Company record
• ƒƒExcessive, nonbusiness, unauthorized, and/or inappropriate use of the Internet
• ƒƒMisusing, destroying, or damaging the property of Aquent, a client, a coworker, or a visitorƒ
• Fighting on Company or client property
• Bringing onto Company or client property any dangerous or unauthorized materials, such as explosives, firearms, weapons, or other similar items
• ƒƒMisconduct
• Unsatisfactory performance
• Absenteeism and tardiness (excluding absences covered by applicable state and federal laws)
• Violation of any Company policies