NETWORK INNOVATIONS: Anti-Trafficking Policy

Introduction:

Network Innovations Inc. and its affiliates (“Company” or “Network Innovations”) are defined by the character and integrity of our operations. We are committed to conducting business with honesty and integrity wherever we operate around the world, treating all people with dignity and respect and complying with all applicable laws, regulations and treaties.

We are also committed to protecting and promoting human rights globally and are committed to a work environment that is free from human trafficking and slavery. We do not tolerate illegal child labor, forced labor or any use of force or other form of coercion, fraud, deception, abuse of power or other means to exploit people or to subject a person to involuntary servitude.

We respect international principles of human rights – including, but not limited to, those in the UN Declaration of Human Rights, the US Trafficking Victims Protection Act of 2000 as amended, the US Federal Acquisition Regulation’s (FAR) final rule on Combating Trafficking in Persons (52.222-50),  the UK Modern Slavery Act of 2015, the California Supply Chain Transparency Act of 2010, the French Corporate Duty of Vigilance Law (2017-399), the Countering America’s Adversaries Through Sanctions Act (Title III), the Australia Modern Slavery Act,  Section 307 of the US Tariff Act and the Canada Customs Tariff Act (No. 9897.00.00) – and embody these principles and commitments in our corporate policies.

We comply with the employment laws of every country in which we operate and expect those with whom we do business to do the same.

This Policy is consistent with our core values to protect and advance human dignity and human rights in our global business practices. We have included this Policy on our website. This Policy makes our commitments more public and ensure our stakeholders know the standards we apply to ourselves and expect from all of our business partners. Our employees, contractors, subcontractors, vendors, partners and others through whom we conduct business must avoid complicity in any practice that constitutes trafficking in persons or slavery.

Scope:

This Policy applies to all personnel employed by or engaged to provide services to Network Innovations, including, but not limited to, Network Innovations’ employees, officers, temporary employees, contingent workers (including agency workers), casual staff, and independent contractors (for ease of reference throughout this Policy, “employees”).

Every Network Innovations employee is responsible for reading, understanding and complying with this Policy.

Network Innovations’ managers are responsible for ensuring that employees who report to them, directly or indirectly, comply with this Policy and complete any certification or training required of them.

If you have any questions or concerns relating to this Policy, consult Network Innovations’ Legal Department or a member of the Executive Team. If you learn of any conduct that you believe may violate this Policy, report it immediately by any of the means listed under the heading “Policy Compliance” below.

Policy Statement:

Network Innovations prohibits trafficking in persons and slavery. Network Innovations employees, contractors, subcontractors, vendors, suppliers, partners and others (collectively, “Suppliers”) through whom Network Innovations conducts business must not engage in any practice that constitutes trafficking in persons or slavery. This includes, but is not limited to, the following activities:

• Engaging in any form of human trafficking;
• Procuring commercial sex acts;
• Using forced labor in the performance of any work;
• Destroying, concealing, confiscating, or otherwise denying access by an individual to the individual’s identity or immigration documents, such as passports or drivers’ licenses, regardless of issuing authority;
• Using misleading or fraudulent practices during the recruitment of candidates or offering of employment/contract positions; such as failing to disclose, in a format and language accessible to the potential candidate, basic information or making material misrepresentations during the recruitment of candidates regarding the key terms and conditions, including wages and fringe benefits, the location of work, the living conditions, housing and associated costs (if provided by Network Innovations), 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 labor laws of the country in which the recruiting takes place;
• Charging applicants/candidates recruitment fees;
• Restricting freedom of movement or right to terminate employment;
• Making loans to workers or job seekers under circumstances where repayment terms could be construed as debt bondage or forced labor;
• Taking disciplinary action for refusing overtime in excess of what is contemplated, required or permitted pursuant to a binding and enforceable collective bargaining agreement;
• Setting production quotas at such a level that employees need to work beyond regular working hours (excluding overtime) to earn the legal minimum wage or prevailing industry wage;
• Having direct control of, or access to, employees’ bank accounts other than to make direct deposits of compensation;
• If required by law or contract, failing to provide return transportation or failing to pay for the cost of return transportation upon the end of employment;
• If required by law or contract, failing to provide or arrange housing that meets the host country housing and safety standards; or
• If required by law or contract, failing to provide an employment contract, recruitment agreement, or other required work document in writing.

Network Innovations has undertaken actions and is committed to maintaining and improving its systems and processes, to eradicate human trafficking and slavery in its direct hardware supply chain. Network Innovations requires its direct hardware supply chain suppliers to observe all applicable laws and conduct business in an ethical and responsible manner.

Network Innovations continues to verify, evaluate, promote awareness about, and address risks associated with forced labor and human trafficking in its direct hardware supply chain.

Additionally, commencing 2023, we will begin developing a Supplier Code of Conduct which will be applicable to all Suppliers of Network Innovations.

Investigation and Audits:

Network Innovations Group companies must cooperate fully with the U.S. Government and/or other appropriate governmental authorities in audits or investigations relating to such violations.

Network Innovations reserves the right to perform investigations and audits to verify that business is being conducted in compliance with this Policy. All Network Innovations employees and third parties  through whom Network Innovations conducts business are required to fully and promptly cooperate with Network Innovations’ internal and external auditors and investigators, and must respond fully and truthfully to their questions, requests for information, and documents. Any failure by an employee to completely cooperate, or any action to hinder an investigation or audit, including for example, hiding or destroying any information or documentation, providing false answers or false information, or deleting email or other documents, may be grounds for disciplinary action, up to and including termination, subject to applicable law.

Policy Compliance:

Report any conduct that you believe to be a violation of this Policy, either directly to Network Innovations’ Legal Department or to Network Innovations’ Executive Team.

Employees having knowledge of credible information concerning actual or potential violations of this Policy must report them immediately in accordance with the Network Innovations’ escalation procedure. Timeliness of reporting any suspected violation is critical as the U.S. Government has imposed an especially stringent reporting obligation when there is credible information of violations. Failure to report actual or potential illegal behavior or actual or potential violations of this Policy may also subject employees to disciplinary action, up to and including termination of employment.

Network Innovations will not tolerate retaliation against an employee for reporting a concern in good faith or for cooperating with an internal compliance investigation or governmental audit or investigation, even when no evidence is found to substantiate the report.

Any violation of this Policy or any employee who engages in retaliation or threats of retaliation may be grounds for disciplinary action, up to and including termination, subject to applicable law. Violation of applicable laws may also result in criminal prosecution of responsible individuals.