Anti-slavery & Human Trafficking Policy Statement

Anti-Slavery and Human Trafficking Policy Statement

Introduction and Organisation Structure Satuit Technologies, Inc. (STI) is a Florida registered S Corporation founded in 1994. STI develops and markets internet-accessible CRM (Client Relationship Management), client reporting, and investor portal software for institutional managers, wealth managers, and alternative asset managers (private equity, hedge fund, and real estate). The SatuitCRM® application suite (the System) provides support for sales, lead management, client services, and retention, compliance, and reporting. Satuit has its headquarters in Braintree MA. And serves clients in over 35 countries. STI manages information for a globally diverse client base comprising a broad range of regulated financial entities and as such the risk of encountering modern slavery is reduced. Nevertheless, STI is committed to ensuring it is not connected to modern slavery in any way.

To this end, STI ensures that the business continues to operate in an open and transparent way and the overall approach to tackling modern slavery throughout STI’s supply chain is consistent with the legal obligations under the Modern Slavery Act 2015. Furthermore, our values guide our business: to have courage and integrity, to show ownership, to connect with our stakeholders, and, above all, to be human. At the heart of our business is a restless spirit to challenge convention in our industry, and in ourselves, to always do better. These values underpin a reputation we have earned for decent behaviour in everything we do, which we firmly believe is good for the morale of our staff and for the results of the business.

Our policies on slavery and human trafficking

STI aims to work in partnership with all service providers to ensure that they share and work towards the same values STI holds against slavery and human trafficking. STI prohibits, and expects all service providers to prohibit, the use of forced, compulsory, or trafficked labour, or anyone held in slavery or servitude, whether adults or children. This prohibition extends to any sub-contractor as STI expects our service providers to hold their own suppliers to the same high standards.

STI has the following policy elements in place that reduce the risk of slavery or forced labour and ensure staff are treated with the dignity and respect they deserve and expects its key service providers to have similar requirements in place:

• Freedom for staff to terminate employment.
• Freedom of movement.
• Freedom of association.
• Prohibition of child labour and other unacceptable labour practices.
• Prohibition of violence, harassment, and intimidation, or the threat thereof.
• Prohibition of discrimination.

These policy elements are easily accessible to all staff in a public area of STI’s intranet. Furthermore, this anti-slavery policy is available to all staff and STI informs suppliers of the commitment to preventing modern slavery as part of the close and continuous oversight of any third-party supplier contracted to the business. Our ongoing commitment to maintaining a culture that encourages employees to raise any concerns relating to malpractice or wrongdoing, including issues related to slavery and human trafficking, without threat of unfair treatment as a result. If an employee has a serious concern relating to the operation of the business, we have a grievance procedure that enables that person to confidentially raise their concern with senior management.

In addition, all staff worldwide can access free, confidential advice from Public Concern at Work in relation to any concerns about possible malpractice or wrongdoing in the workplace.

Due diligence process for preventing slavery and human trafficking

The following systems are in place as part of STI’s commitment to tackling modern slavery and human trafficking:

• Monitoring of potential risk areas in STI’s supply chain via a risk assessment having due regard to the indicators of forced labour outlined in all applicable US laws and regulations and guidance as contained in the principles of the UN’s Universal Declaration of Human Rights
• Long-standing relationships with well-respected, regulated service suppliers.
• Close and continuous oversight of all material STI service providers.

Personnel are required to avoid any activity that might lead to, or suggest, a breach of this statement. Staff are encouraged to raise concerns, making use of STI’s grievance procedures which are contained in STI’s Employee Handbook.

Supplier adherence to our values

To ensure those in STI’s supply chain comply with STI’s zero tolerance to slavery and
human trafficking, an addition to our vendor management policy and procedures has been introduced which consists of:

• Standard clause in service provider contracts to comply with all applicable laws; and
• Self-certification of compliance where applicable as part of due diligence reviews.

STI is committed as an organisation to tackling modern slavery and human trafficking and strives to work with suppliers who share these same values. As part of regular oversight and monitoring, STI would raise any slavery concerns that had been identified with the relevant service provider.

Risk assessment

STI undertakes a risk assessment to identify the nature and extent of its exposure to modern slavery, which is updated on a regular basis. It has due regard to the countries in which STI and its supply chain operates, the sector it works in, transaction risks, and business partnership/service provider risks.

As part of this risk assessment, STI monitors various performance indicators that could indicate a heightened risk of supporting modern slavery, for example, staff training or service provider responsiveness to questions regarding enforced labour.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our organisation and our supply chain, STI has provided details to all relevant staff and made this policy available on our website for all stakeholders to observe. Ongoing training is provided to all staff upon joining and regularly thereafter about our expectations with regards to modern slavery.

Further steps

STI’s Executive Committee has endorsed this policy and has confirmed STI’s commitment to improving practices to combat slavery and human trafficking following a review of the effectiveness of the steps STI has taken to ensure that there is no slavery or human trafficking in STI’s supply chains.