SUPPORTFINITY MODERN SLAVERY & HUMAN TRAFFICKING POLICY

Effective Date: July 17th, 2026

1. POLICY STATEMENT

SupportFinity Inc. (“SupportFinity” or the “Company”) has zero tolerance for modern slavery, forced labor, child labor and human trafficking, in our own business and in our supply chain.

As a hiring company, we believe every person has the right to choose their work freely, be paid fairly and be treated with dignity. This Policy explains how we protect that right and how we meet the law in every country where we operate. Where local law or a customer contract sets a stricter rule, the stricter rule applies.

2. SCOPE

This Policy applies to everyone who works for or on behalf of SupportFinity, in every country:

Directors, officers and employees, full-time, part-time or temporary
Co-founders, advisors, consultants and contractors
Recruiters and recruitment desk staff working on client hiring
Suppliers, subcontractors, referral partners, resellers and other business partners (together, “Third Parties”)

It covers our own operations, the services we deliver to customers, including recruitment process outsourcing (RPO), and the goods and services we buy.

3. APPLICABLE LAWS

SupportFinity is a Delaware corporation based in San Francisco, California. We comply with all laws against modern slavery and human trafficking that apply to our business, including:

Law	What it requires or prohibits
U.S. Trafficking Victims Protection Act (TVPA), 22 U.S.C. §§ 7101 et seq.	Prohibits human trafficking and forced labor, with civil liability for knowingly benefiting from them
U.S. criminal code, 18 U.S.C. §§ 1581–1597	Prohibits peonage, forced labor, trafficking and destroying or withholding identity documents
U.S. Tariff Act of 1930, Section 307 (19 U.S.C. § 1307)	Bans importing goods made with forced labor
Uyghur Forced Labor Prevention Act (2021)	Presumes goods from the Xinjiang region are made with forced labor
California Transparency in Supply Chains Act (Civil Code § 1714.43)	Disclosure duties for large retailers and manufacturers; we follow its standards voluntarily
UK Modern Slavery Act 2015 and Australian Modern Slavery Act 2018 (Cth)	Reporting duties for large organizations; we apply equivalent standards when serving UK and Australian customers
Local laws where we operate or recruit	For example, laws in Saudi Arabia, Egypt, India and Kuwait on labor, recruitment fees and worker documents

SupportFinity is currently below the revenue thresholds that trigger mandatory reporting under the UK and Australian Acts and the California Act. We apply their standards voluntarily.

4. WHAT MODERN SLAVERY MEANS

“Modern slavery” covers any situation where a person is exploited and cannot refuse or leave because of threats, violence, coercion, deception or abuse of power. It includes:

Forced or compulsory labor: work done under threat of a penalty, which the person did not freely agree to.
Debt bondage: forcing someone to work to pay off a debt, often a recruitment fee, that they can never realistically repay.
Human trafficking: recruiting, moving or holding people by force, fraud or deception in order to exploit them.
Servitude and slavery: treating a person as property or controlling them so they cannot leave.
Child labor: work by children below the legal minimum age, or hazardous work by anyone under 18.
Deceptive recruitment: misleading people about the nature, pay or conditions of a job to trap them into it.

5. OUR LABOR STANDARDS

SupportFinity commits to the following for everyone who works for us:

Freely chosen work: all work is voluntary, and people may leave with reasonable notice and without penalty.
No fees for work: workers never pay any fee, deposit or cost to be hired.
Own documents: we never take, hold or destroy passports, ID cards or work permits.
Fair pay: wages meet at least the legal minimum, are paid on time and in full, and are never withheld as a penalty.
Legal hours: working hours and overtime follow the law, and overtime is voluntary and paid.
Minimum age: we never employ anyone below the legal working age, and never under 16.
Written terms: every worker gets clear written terms in a language they understand, before they start.
Respect and safety: no violence, threats, harassment or degrading treatment, and a safe place to work.
Freedom of association: people may join or form worker organizations where the law allows.

6. ETHICAL RECRUITMENT IN OUR SERVICES

Recruitment is a known route to forced labor, so we hold our hiring services to a higher standard. We follow the Employer Pays Principle: the employer, never the candidate, bears the cost of recruitment.

When SupportFinity sources, screens, interviews or places candidates for customers, including through our RPO services:

We never charge candidates any fee, at any stage.
Job descriptions, pay and conditions we share with candidates must be accurate and complete.
We never ask candidates to hand over identity documents beyond lawful, temporary checks.
We do not knowingly recruit for a role, customer or location where we suspect forced labor, unpaid wages or document retention.
Candidates can withdraw at any time, with no penalty.
Our platform’s fraud and fake-profile checks are used to protect candidates as well as customers, and any sign of exploitation is reported.

We may decline or end work with any customer who refuses to meet these standards.

7. SUPPLIERS, CONTRACTORS AND PARTNERS

We expect every Third Party to meet the standards in this Policy, and we check that they do.

Screen before engaging: basic checks on identity, reputation and labor practices, scaled to the risk of the country and the service.
Put it in writing: every agreement includes terms requiring compliance with anti-slavery laws and this Policy, no recruitment fees charged to workers, cooperation with reasonable audits, prompt reporting of any concern, and the right for SupportFinity to suspend or end the agreement for breach.
Pass it down: Third Parties must apply the same standards to their own subcontractors.
Review: we re-check higher-risk Third Parties at least once a year, and when a concern is raised.

Red flags to report at once: workers paying recruitment fees or carrying debt to an agent, employers holding passports, pay withheld or far below the legal minimum, workers unable to leave their housing or job, refusal to sign anti-slavery terms, or unusually low prices that suggest labor exploitation.

8. RISK ASSESSMENT

SupportFinity is a software and recruitment services company. Our team is made up of salaried professionals and contractors on written agreements, and our main suppliers are established technology and cloud providers. Our overall risk is low, but we watch the areas where it is higher:

Area	Risk	How we manage it
Recruitment and RPO services	Medium	Employer Pays Principle, accurate job information, no candidate fees, customer standards checked (section 6)
Cross-border hiring, including India and the Middle East	Medium	Extra checks on local agents and partners, attention to fees and document retention
Contractors and freelancers	Low	Written agreements, fair pay, freedom to end the engagement
Technology, cloud and office suppliers	Low	Established providers with their own published anti-slavery commitments
Hardware and office goods	Low	Buy from reputable vendors, avoid goods from high-risk regions

We review this assessment at least once a year, and when we enter a new country or service line.

9. REPORTING CONCERNS AND NON-RETALIATION

Anyone, including employees, candidates, contractors and Third Parties’ workers, can raise a concern.

How to report: to your manager, or by email to info@supportfinity.com. Reports may be made anonymously where local law allows.
Confidentiality: reports are shared only with those who need to know to investigate.
No retaliation: no one will be penalized for reporting a concern in good faith. Retaliation is itself a serious breach of this Policy.
Emergencies: if someone is in immediate danger, contact local police first. In the U.S., the National Human Trafficking Hotline is 1-888-373-7888.
Your legal rights: nothing in this Policy stops anyone from reporting directly to a government agency.

10. REMEDIATION

If we find modern slavery or a breach of this Policy, our first priority is the safety and wellbeing of the people affected.

Act promptly to protect anyone at risk, and involve the authorities where needed.
Investigate the facts, with outside help where appropriate.
Work with the Third Party on a corrective plan with clear deadlines, including repayment of any fees workers were charged.
Suspend or end the relationship if the Third Party will not or cannot fix the problem.
Record what happened and what we changed, so it does not happen again.

Employees or contractors who breach this Policy may face disciplinary action, up to termination of employment or contract, and referral to law enforcement.

11. TRAINING

Everyone covered by this Policy receives modern slavery awareness training within 30 days of joining, and again every year.
Recruiters, recruitment desk staff and anyone managing suppliers receive extra training on ethical recruitment and the red flags in section 7.
Each person confirms in writing that they have read this Policy when they join.

12. MONITORING, GOVERNANCE AND REVIEW

Owner: the Chief Executive Officer is responsible for this Policy and its compliance.
Monitoring: we track how many Third Parties have signed anti-slavery terms, training completion, the concerns reported and how each was resolved.
Review: the Policy and the risk assessment are reviewed at least once a year, and whenever the law or our business changes in a material way.
Effective date: this Policy takes effect on 17 July 2026.

Approved by: Chief Executive Officer, SupportFinity Inc.