Anti-Slavery & Human Trafficking Policy

Updated & Effective as of July 2020

This Anti-Slavery & Human Trafficking Policy is made by and on behalf of Sovos Compliance, LLC and its subsidiaries (“Sovos”) pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our group’s slavery and human trafficking statement.

Introduction

Sovos is a leading global provider of software that safeguards businesses from the burden and risk of modern transactional taxes. The company has offices throughout North America, Latin America and Europe.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our group’s slavery and human trafficking statement for the current financial year.  We have zero tolerance for slavery and human trafficking in any part of our business, including our supply chains. We have a number of policies in place to ensure all our employees have the right to work and are paid fairly, that we act with integrity and ethically, and that we have effective measures in place to ensure slavery is not present anywhere in our business or supply chain.  This includes our Equal Opportunities policy, which encompasses recruitment, promotion, training, performance management and reward. Our principles of fair treatment and respect are also applied to our relationships with customers, suppliers, contractors, shareholders and other stakeholders.

Policy

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labor 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 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.

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 labor, 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.

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.

This policy does not form part of any employee’s contract of employment and we may amend it at any time.

Responsibility for the Policy

The Sovos General Counsel 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.

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.

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 Sovos General Counsel.

Compliance with the Policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

We may terminate our relationship with other individuals and organizations working on our behalf if they breach this policy.

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.  If you believe or suspect that a conflict with this policy has occurred, or may occur in the future, you must notify the Sovos General Counsel.  If you have concerns with the working conditions within any tier of our supply chains, you must notify the Sovos General Counsel.

Supplier Auditing; Certification of Compliance

In general, our suppliers are contractually required to comply with applicable laws and regulations in the U.S. and globally in providing us products and services. In light of our perceived minimal risk, we do not anticipate auditing our suppliers to evaluate their compliance with this Policy.  Suppliers shall agree to implement due diligence procedures for their own suppliers, subcontractors, and other participants, and they shall acknowledge that neither the Supplier nor any of its officers, employees, or other associates have been convicted of any offence involving slavery and human trafficking and have never been the subject of any investigation by a regulatory body regarding any offence in connection with slavery and human trafficking.

Amendments

This Policy will be reviewed by the Company’s Board of Directors and Executive Management Team on a regular basis and may be revised and re-distributed as necessary.