Modern Slavery & Human Trafficking Statement

Financial Year: 2025
Published: August 27, 2025
Approved By: Executive Leadership

ARTICLE I. EXECUTIVE STATEMENT AND FOUNDATIONAL COMMITMENTS

Section 1.01 Leadership Commitment to Human Rights Protection

Assivo, Inc., an Illinois corporation ("Assivo," "Company," "we," "us," or "our"), maintains an unwavering commitment to combating modern slavery and human trafficking in all their manifestations across our global operations and extended supply chain ecosystem. We recognize that modern slavery represents a fundamental violation of human dignity and rights that demands vigilant, systematic action from responsible businesses worldwide.

Section 1.02 Statement Purpose and Regulatory Compliance

This Modern Slavery and Human Trafficking Statement (this "Statement") outlines the comprehensive steps Assivo has implemented and continues to enhance to identify, prevent, mitigate, and address modern slavery and human trafficking risks within our direct operations, business relationships, and global supply chains. This Statement reflects our institutional commitment to conducting business ethically while upholding fundamental human rights and dignity.

Section 1.03 Legal and Regulatory Framework

This Statement is published in accordance with the UK Modern Slavery Act 2015, the Australian Modern Slavery Act 2018, California Transparency in Supply Chains Act, and similar international legislation governing corporate transparency and accountability regarding modern slavery prevention. This Statement covers the financial year ending December 31, 2025, and has been reviewed and approved by executive leadership with appropriate oversight and governance validation.

ARTICLE II. ORGANIZATIONAL STRUCTURE AND BUSINESS OPERATIONS

Section 2.01 Corporate Structure and Global Operations

Assivo operates as a leading business process outsourcing firm providing sophisticated technology-enabled services to Fortune 500 companies and private equity portfolio companies across multiple industry sectors. Founded in 2017, we have established a global delivery model with distributed operational capabilities spanning Chicago, Mexico City, Mumbai, and Chennai, enabling us to provide comprehensive service delivery while maintaining rigorous operational standards and ethical business practices.

Section 2.02 Business Model and Service Framework

Our comprehensive service portfolio encompasses:

(a) Business Process Outsourcing Services: Finance and accounting operations, human resources management, customer service delivery, and specialized operational support services designed to optimize client operational efficiency and effectiveness.

(b) Technology Services and Solutions: Application development and maintenance, data analytics and business intelligence, automation and digital transformation initiatives, and technical infrastructure support services.

(c) Strategic Consulting and Advisory Services: Process optimization consulting, regulatory compliance support, strategic advisory services, and specialized consulting engagements designed to enhance client capabilities and competitive positioning.

Section 2.03 Operational Structure and Geographic Presence

(a) Corporate Headquarters: Chicago, Illinois, United States, serving as the primary center for strategic management, client relationship oversight, and corporate governance activities.

(b) Global Delivery Network: Distributed service delivery capabilities across Chicago, Mexico City, Mumbai, and Chennai with scalable workforce deployment and technology infrastructure supporting comprehensive client service requirements.

(c) Client Engagement Model: North America-focused client base with expanding global presence and service delivery capabilities designed to meet diverse client requirements and regulatory compliance obligations.

(d) Workforce Architecture: Remote-first operational model with distributed workforce capabilities enabling flexible service delivery while maintaining consistent quality standards, ethical practices, and compliance requirements across all operational locations.

Section 2.04 Supply Chain Ecosystem and Business Relationships

Our supply chain infrastructure encompasses diverse business relationships including:

(a) Technology and Infrastructure Providers: Software licensing partners, cloud services providers, telecommunications suppliers, and hardware vendors supporting our technology infrastructure and service delivery capabilities.

(b) Professional Services Partners: Legal service providers, accounting and audit firms, consulting organizations, and specialized professional service providers supporting business operations and regulatory compliance.

(c) Facilities and Operations Support: Real estate services, utilities providers, facility management companies, and operational support services enabling business operations across multiple geographic locations.

(d) Human Resources and Talent Partners: Recruitment agencies, staffing organizations, training providers, and employee benefit service providers supporting workforce development and employee welfare across global operations.

ARTICLE III. GOVERNANCE FRAMEWORK AND ACCOUNTABILITY STRUCTURE

Section 3.01 Executive Leadership Oversight and Strategic Direction

Executive leadership maintains comprehensive oversight responsibility for modern slavery prevention through:

(a) Strategic Policy Development: Annual review and approval of this Statement, comprehensive oversight of risk management and prevention programs, strategic resource allocation for prevention and remediation efforts, and integration of human rights considerations into strategic business planning and decision-making processes.

(b) Performance Monitoring and Accountability: Systematic monitoring of prevention program effectiveness, performance measurement against established objectives, accountability frameworks for implementation success, and strategic guidance on human rights protection and ethical business practice evolution.

(c) Stakeholder Engagement and Transparency: Regular communication with stakeholders regarding our commitments and progress, transparent reporting on prevention activities and outcomes, and proactive engagement with industry initiatives and regulatory authorities on modern slavery prevention and human rights protection.

Section 3.02 Executive Leadership Responsibility Matrix

(a) Principal: Ultimate strategic direction and organizational culture development with responsibility for ensuring modern slavery prevention is integrated into corporate strategy, values, and operational decision-making frameworks across all business functions and geographic locations.

(b) Operations Officer: Operational implementation and supply chain oversight including development and implementation of supply chain due diligence procedures, vendor management protocols, and operational risk assessment and mitigation strategies for modern slavery prevention.

(c) General Counsel: Employment practices oversight and regulatory compliance including development of employment policies and procedures, legal compliance monitoring, regulatory relationship management, and legal risk assessment and mitigation for human rights protection obligations.

Section 3.03 Operational Management and Implementation Structure

Day-to-day modern slavery prevention management encompasses:

(a) Regional Directors and Management: Local implementation of prevention policies and procedures, cultural adaptation and sensitivity considerations, regional compliance monitoring and reporting, and local stakeholder engagement and community relationship development supporting prevention objectives.

(b) Operations and Procurement Teams: Supplier oversight and relationship management including vendor due diligence procedures, contract management and compliance monitoring, and supplier development and improvement initiatives supporting ethical business practices throughout the supply chain.

(c) Human Resources and People Management: Employment practices development and implementation including ethical recruitment procedures, employee welfare and protection programs, workplace culture development, and training and awareness initiatives supporting modern slavery prevention and human rights protection.

(d) Compliance and Risk Management Teams: Risk assessment and monitoring activities including systematic risk identification and evaluation procedures, compliance validation and verification programs, and incident response and corrective action implementation supporting comprehensive prevention and remediation capabilities.

ARTICLE IV. RISK ASSESSMENT AND MANAGEMENT FRAMEWORK

Section 4.01 Comprehensive Risk Assessment Methodology

We conduct systematic and comprehensive risk assessments incorporating multiple dimensions of modern slavery and human trafficking vulnerability:

(a) Geographic Risk Factor Analysis: Country-level governance assessments, rule of law evaluations, human rights performance indicators, and regional risk factors including political stability, economic conditions, and social development indicators affecting modern slavery prevalence and prevention effectiveness.

(b) Industry and Sector Risk Evaluation: Sector-specific vulnerability assessments, industry risk patterns and trends analysis, supply chain complexity evaluations, and business model risk factors that may inadvertently increase vulnerability to modern slavery and human trafficking risks.

(c) Operational Risk Assessment: Business process risk evaluation, employment practice assessments, supplier relationship risk analysis, and operational control effectiveness reviews identifying potential vulnerabilities in our direct operations and business relationships.

(d) Supply Chain Complexity and Transparency Analysis: Multi-tier supplier relationship mapping, supply chain visibility assessments, subcontracting arrangement evaluations, and third-party relationship risk categorization supporting comprehensive understanding of extended supply chain risks and prevention requirements.

Section 4.02 Identified Risk Areas and Mitigation Strategies

4.02.1 Direct Operations Risk Management

(a) Ethical Recruitment and Employment Practices: Implementation of comprehensive ethical recruitment policies eliminating recruitment fees and deceptive practices, transparent employment terms and conditions, voluntary employment frameworks ensuring freedom of movement and employment termination rights, and systematic monitoring of employment practices across all operational locations.

(b) Migrant Worker Protection and Support: Enhanced protection programs for foreign national employees including documentation security, cultural integration support, grievance mechanisms, and specialized assistance programs preventing exploitation and ensuring equal treatment and opportunity regardless of nationality or immigration status.

(c) Subcontracting and Third-Party Service Oversight: Comprehensive monitoring of third-party staffing providers, service contractors, and outsourced function providers including due diligence procedures, contract compliance monitoring, and ongoing relationship management ensuring ethical practices throughout extended operational relationships.

(d) Working Conditions and Employee Welfare: Maintenance of fair wages meeting or exceeding living wage standards, reasonable working hours respecting work-life balance, safe and healthy working environments, and comprehensive employee welfare programs supporting physical and mental health, professional development, and career advancement opportunities.

4.02.2 Supply Chain Risk Mitigation and Management

(a) Technology Manufacturing and Hardware Supply Chains: Enhanced due diligence for hardware suppliers and technology manufacturers operating in regions with known labor rights challenges, supplier diversity initiatives promoting ethical suppliers, and contract requirements for labor standards compliance and worker protection throughout technology supply chains.

(b) Facilities and Support Services Management: Systematic oversight of cleaning services, security providers, maintenance contractors, and other facilities support services with particular attention to vulnerable worker populations, subcontracting practices, and employment condition verification through direct engagement and monitoring procedures.

(c) Logistics and Transportation Service Providers: Due diligence and monitoring of shipping companies, delivery services, and transportation providers including assessment of driver employment practices, subcontractor management, and adherence to labor standards throughout logistics and distribution networks.

(d) Complex Multi-Tier Supplier Relationship Management: Supply chain mapping initiatives enhancing visibility into upstream supplier relationships, tier-two and tier-three supplier due diligence procedures, and collaborative industry initiatives improving transparency and accountability throughout extended supply chains and business networks.

Section 4.03 Risk Prioritization and Resource Allocation

Higher-risk areas receive enhanced attention and resources including:

(a) Enhanced Due Diligence and Assessment Procedures: More comprehensive supplier assessment processes, increased frequency of monitoring and evaluation activities, specialized expertise engagement for complex risk situations, and enhanced documentation and verification requirements for high-risk relationships and geographic locations.

(b) Intensive Monitoring and Oversight Programs: Increased frequency of audits and site visits, real-time monitoring systems and reporting mechanisms, enhanced stakeholder feedback and grievance procedures, and proactive engagement with local communities and civil society organizations in high-risk operational areas.

(c) Capacity Building and Supplier Development: Technical assistance and training programs for suppliers in high-risk categories, collaborative improvement initiatives and best practice sharing, financial and operational support for supplier capability enhancement, and long-term partnership development focused on sustainable improvement and ethical practice institutionalization.

(d) Strengthened Contractual Protections and Requirements: Enhanced contract terms and compliance requirements, specific modern slavery prevention clauses and obligations, strengthened audit rights and transparency provisions, and clear consequences and remediation requirements for non-compliance or violation of prevention standards and expectations.

ARTICLE V. POLICY FRAMEWORK AND INSTITUTIONAL STANDARDS

Section 5.01 Comprehensive Policy Architecture

Our commitment to modern slavery prevention is institutionalized through comprehensive policy frameworks:

(a) Code of Business Ethics Integration: Fundamental ethical principles and behavioral expectations embedded throughout organizational culture, specific prohibitions and requirements related to human rights protection, and clear accountability structures and consequences for violations of ethical standards and human rights protection obligations.

(b) Supplier Code of Conduct Requirements: Comprehensive requirements for all business partners and suppliers including specific modern slavery prevention obligations, human rights protection standards and expectations, and ongoing compliance monitoring and verification requirements ensuring consistent application of prevention standards throughout our business network.

(c) Employment Policies and Procedures: Detailed employment practice standards ensuring ethical recruitment, fair compensation, voluntary employment, and worker welfare protection across all operational locations with regular review and updating to reflect best practices and regulatory requirements.

(d) Anti-Slavery and Human Trafficking Policy Framework: Specific policy framework dedicated to modern slavery prevention including detailed prohibitions, prevention procedures, detection mechanisms, and response and remediation protocols providing comprehensive guidance and requirements for all personnel and business partners.

Section 5.02 Core Policy Prohibitions and Standards

We maintain absolute prohibitions regarding:

(a) Forced Labor and Involuntary Servitude: Comprehensive prohibition of any work or service performed involuntarily under threat of punishment, physical coercion, or other forms of compulsion with specific protections ensuring voluntary employment, freedom of movement, and right to termination without penalty or restriction.

(b) Debt Bondage and Financial Coercion: Absolute prohibition of employment conditions predicated on debt repayment, financial obligations to employers, or other forms of economic coercion with specific requirements ensuring transparent financial relationships and prohibition of recruitment fees, deposits, or other financial barriers to employment freedom.

(c) Human Trafficking and Exploitation: Comprehensive prohibition of transportation, harboring, recruitment, or exploitation of persons for labor purposes through force, fraud, or coercion with specific detection and reporting procedures and victim protection and support mechanisms.

(d) Child Labor and Minor Protection: Strict prohibition of employment of individuals below minimum legal working age with enhanced protections for young workers including education requirements, restricted working conditions, and comprehensive welfare monitoring ensuring protection of minors and compliance with international child protection standards.

(e) Deceptive Recruitment and Fraudulent Employment Practices: Prohibition of misleading promises about employment terms, working conditions, compensation, or other employment-related matters with requirements for transparent recruitment procedures, accurate job descriptions, and clear employment terms and conditions.

Section 5.03 Employment Standards and Worker Protection Framework

Our employment practices ensure comprehensive worker protection through:

(a) Freedom of Movement and Document Security: Employees retain possession and control of personal identity documents, passports, and work authorization with explicit prohibition of document confiscation or restriction and clear procedures ensuring employee freedom of movement and travel as legally permitted.

(b) Fair Compensation and Living Wage Standards: Wages that meet or exceed local minimum wage requirements and living wage standards with transparent pay structures, regular payment schedules, comprehensive benefits packages, and prohibition of illegal deductions or wage withholding practices.

(c) Voluntary Employment and Termination Rights: Clear employment termination procedures respecting employee rights to end employment relationships, prohibition of employment restrictions or penalties for termination, and comprehensive grievance and dispute resolution mechanisms protecting employee rights and interests.

(d) Safe and Healthy Working Environments: Maintenance of healthy and safe working conditions meeting or exceeding regulatory standards, comprehensive occupational health and safety programs, regular workplace assessments and improvement initiatives, and employee participation in workplace safety and wellness programs.

(e) Equal Treatment and Non-Discrimination: Commitment to equal treatment and non-discrimination based on nationality, immigration status, race, gender, religion, or other protected characteristics with comprehensive equal opportunity programs and anti-discrimination policies and procedures.

ARTICLE VI. DUE DILIGENCE AND SUPPLIER MANAGEMENT

Section 6.01 Comprehensive Supplier Due Diligence Framework

Our supplier onboarding and management process incorporates systematic due diligence procedures:

6.01.1 Initial Assessment and Evaluation

(a) Comprehensive Risk Questionnaires and Assessments: Detailed evaluation of labor practices, human rights policies, employment procedures, and modern slavery prevention measures with specific focus on recruitment practices, working conditions, compensation structures, and worker welfare programs implemented by potential suppliers and business partners.

(b) Background Verification and Reputation Assessment: Systematic investigation of company registration status, business history, financial stability, legal compliance record, and reputation within industry and local communities with particular attention to labor relations, human rights performance, and ethical business practice demonstrated over time.

(c) Regulatory Compliance and Legal Standing Verification: Validation of business licenses, permits, regulatory compliance status, and legal standing including review of any violations, penalties, or legal proceedings related to labor practices, human rights issues, or modern slavery concerns that could affect business relationships.

(d) References and Client Validation: Independent verification of ethical business practices through client references, industry associations, certification bodies, and other credible sources providing objective assessment of supplier performance, reputation, and commitment to ethical business practices and human rights protection.

6.01.2 Enhanced Due Diligence for High-Risk Suppliers

For suppliers operating in higher-risk categories or geographic locations:

(a) On-Site Assessments and Facility Inspections: Physical inspections of operational facilities, working conditions, accommodation facilities (where applicable), and operational practices with direct observation of employment practices, worker treatment, facility conditions, and management systems implementation and effectiveness.

(b) Document Review and Employment Record Analysis: Comprehensive review of employment contracts, payroll records, working time documentation, worker identification and documentation practices, and other employment-related records verifying compliance with legal requirements and prevention of exploitative practices.

(c) Confidential Worker Interviews and Feedback: Private discussions with employees regarding working conditions, treatment, compensation, grievance mechanisms, and other employment-related matters ensuring worker voices are heard and concerns are identified and addressed appropriately and effectively.

(d) Management System Assessment and Capability Evaluation: Evaluation of management policies, procedures, training programs, monitoring systems, and commitment levels demonstrated through resource allocation, performance measurement, and continuous improvement initiatives supporting modern slavery prevention and human rights protection.

Section 6.02 Ongoing Monitoring and Relationship Management

Continuous oversight and management include:

(a) Annual Certification and Compliance Confirmation: Regular supplier confirmation of continued compliance with modern slavery prevention requirements, human rights protection standards, and contractual obligations with formal certification processes and accountability mechanisms ensuring sustained attention and commitment.

(b) Performance Reviews and Relationship Assessment: Systematic evaluation of supplier performance against ethical standards, compliance requirements, and service quality expectations with regular relationship management discussions addressing performance, concerns, and improvement opportunities.

(c) Audit Programs and Independent Verification: Periodic independent audits of key suppliers and high-risk relationships including third-party assessment organizations, specialized human rights auditors, and industry experts providing objective evaluation of compliance status and improvement requirements.

(d) Incident Reporting and Issue Resolution: Systematic mechanisms for reporting concerns, violations, or issues related to modern slavery risks or human rights violations with comprehensive investigation procedures, corrective action requirements, and follow-up validation ensuring effective resolution and prevention of recurrence.

Section 6.03 Internal Due Diligence and Operational Monitoring

Within our own operations:

(a) Recruitment Process Audits and Verification: Regular review of hiring practices, recruiter relationships, employment terms, and onboarding procedures ensuring ethical recruitment, transparent employment conditions, and prevention of deceptive or exploitative practices throughout talent acquisition and employment processes.

(b) Employment Verification and Documentation Review: Systematic checks of employee documentation, employment status, working conditions, compensation structures, and employment terms ensuring compliance with legal requirements and prevention of forced labor or other exploitative employment practices.

(c) Workplace Condition Assessments and Monitoring: Periodic evaluation of working conditions, employee welfare, workplace culture, and management practices including facility conditions, health and safety programs, employee satisfaction, and workplace environment assessment across all operational locations.

(d) Employee Feedback and Grievance Mechanisms: Confidential and accessible systems for employee feedback, concerns, complaints, and suggestions regarding working conditions, treatment, or other employment-related matters with comprehensive investigation, resolution, and follow-up procedures protecting employee rights and welfare.

ARTICLE VII. TRAINING, AWARENESS, AND CAPACITY BUILDING

Section 7.01 Comprehensive Employee Training and Development Program

7.01.1 Universal Awareness and Education Initiative

All personnel receive foundational training encompassing:

(a) Modern Slavery Fundamentals and Recognition: Comprehensive education regarding definitions, forms, manifestations, and warning signs of modern slavery and human trafficking with practical examples, case studies, and recognition techniques enabling effective identification and response to potential situations and risks.

(b) Company Policies and Procedures: Detailed understanding of organizational prohibitions, requirements, reporting procedures, and accountability expectations with specific guidance on individual responsibilities, escalation procedures, and available resources for addressing concerns or suspected violations.

(c) Individual Responsibility and Empowerment: Clear articulation of individual roles and responsibilities in modern slavery prevention including specific actions, decision-making criteria, reporting obligations, and support mechanisms enabling effective contribution to prevention efforts and risk mitigation.

(d) Reporting Mechanisms and Support Systems: Comprehensive information about available channels for reporting concerns, seeking guidance, accessing support, and escalating issues with emphasis on confidentiality protection, non-retaliation policies, and available assistance for individuals affected by modern slavery or human trafficking.

7.01.2 Specialized Training for Key Personnel

Targeted training programs address specific roles and responsibilities:

(a) Procurement and Supplier Management Teams: Advanced training on supplier assessment techniques, contract negotiation and management, monitoring and audit procedures, and relationship management strategies specific to modern slavery prevention and human rights protection throughout supply chain relationships.

(b) Human Resources and People Management: Specialized training on ethical recruitment practices, employment law compliance, worker welfare programs, grievance handling, and employment verification procedures ensuring comprehensive protection of worker rights and prevention of exploitative employment practices.

(c) Management and Leadership Development: Strategic training on governance responsibilities, risk oversight, incident management, stakeholder communication, and leadership accountability for modern slavery prevention including decision-making frameworks and performance management for prevention program effectiveness.

(d) Compliance and Risk Management Personnel: Technical training on risk assessment methodologies, audit techniques, investigation procedures, corrective action development, and regulatory compliance ensuring specialized expertise in modern slavery prevention and human rights protection program development and implementation.

Section 7.02 Supplier Training and Capacity Building Initiative

We support supplier development through:

(a) Educational Workshops and Best Practice Sharing: Regular workshops, seminars, and training sessions for suppliers covering modern slavery prevention, ethical business practices, worker welfare programs, and industry best practices with collaborative learning and knowledge sharing opportunities.

(b) Resource Provision and Technical Assistance: Provision of training materials, policy templates, assessment tools, and technical guidance supporting supplier capability development and implementation of effective modern slavery prevention measures and human rights protection programs.

(c) Collaboration Platforms and Industry Engagement: Forums for discussing challenges, sharing solutions, collaborative problem-solving, and industry collaboration on modern slavery prevention with participation in industry initiatives and multi-stakeholder partnerships advancing prevention objectives.

(d) Ongoing Support and Partnership Development: Technical assistance for implementing enhanced due diligence systems, developing internal capabilities, addressing identified deficiencies, and building sustainable prevention programs with long-term partnership and continuous improvement focus.

Section 7.03 Training Effectiveness and Continuous Improvement

We systematically assess and enhance training impact through:

(a) Knowledge Assessment and Competency Validation: Testing comprehension of key concepts, principles, and requirements with practical scenario evaluation, decision-making assessments, and ongoing competency validation ensuring training effectiveness and knowledge retention.

(b) Behavioral Observation and Implementation Monitoring: Monitoring implementation of learned practices, behavioral changes, decision-making improvements, and practical application of prevention knowledge in day-to-day operations and business relationships.

(c) Feedback Collection and Program Enhancement: Participant evaluation of training quality, relevance, effectiveness, and improvement suggestions with regular program updates, content refinements, and delivery method improvements based on feedback and emerging best practices.

(d) Performance Measurement and Impact Assessment: Tracking improvements in risk identification capabilities, prevention effectiveness, incident reduction, and overall program performance with systematic evaluation of training contribution to prevention objectives and continuous improvement initiatives.

ARTICLE VIII. PERFORMANCE MEASUREMENT AND MONITORING

Section 8.01 Key Performance Indicators and Metrics Framework

8.01.1 Operational Performance and Implementation Metrics

(a) Training Completion and Awareness Development: Measurement of personnel training completion rates across different employee categories, knowledge retention assessment results, competency development indicators, and awareness program participation with tracking of training effectiveness and continuous improvement in prevention knowledge and capabilities.

(b) Supplier Assessment Coverage and Compliance: Evaluation of supplier assessment completion rates, due diligence procedure implementation, compliance verification activities, and risk assessment coverage with measurement of supplier compliance levels and improvement in prevention capabilities throughout the supply chain network.

(c) Audit Completion and Monitoring Effectiveness: Tracking of planned audit completion rates, monitoring activity implementation, assessment quality and comprehensiveness, and follow-up action completion with evaluation of monitoring program effectiveness and continuous improvement in oversight capabilities.

(d) Incident Response and Resolution Performance: Measurement of incident response times, investigation quality and thoroughness, resolution effectiveness, and corrective action implementation with assessment of response capability and continuous improvement in incident management and prevention effectiveness.

8.01.2 Strategic Performance and Impact Assessment

(a) Risk Reduction and Prevention Effectiveness: Assessment of improvements in risk assessment scores, reduction in identified vulnerabilities, prevention program effectiveness, and overall risk profile improvement with measurement of strategic prevention objective achievement and long-term impact.

(b) Supplier Compliance and Capability Development: Evaluation of supplier meeting prevention requirements, compliance improvement over time, capability development success, and long-term partnership sustainability with assessment of supply chain prevention effectiveness and collaborative improvement impact.

(c) Corrective Action Implementation and Effectiveness: Measurement of corrective action plan development, implementation success rates, effectiveness in addressing identified issues, and prevention of recurrence with assessment of remediation capabilities and continuous improvement in response effectiveness.

(d) Stakeholder Engagement and Satisfaction: Collection and analysis of feedback from employees, suppliers, clients, community partners, and other stakeholders regarding prevention program effectiveness, support adequacy, and satisfaction with prevention efforts and outcomes.

Section 8.02 Regular Monitoring and Reporting Framework

8.02.1 Internal Reporting and Management Information

(a) Monthly Dashboard and Performance Monitoring: Key metrics and trend analysis for management review including performance against targets, emerging issues identification, and decision support information with regular management attention and strategic guidance for program enhancement and improvement.

(b) Quarterly Comprehensive Assessment and Review: Complete evaluation of prevention program effectiveness, compliance status, emerging challenges, and improvement opportunities with systematic assessment of strategic objectives and performance against prevention goals and expectations.

(c) Annual Strategic Review and Planning: Comprehensive evaluation of prevention program performance, strategic objective achievement, industry benchmarking, and future planning with integration of lessons learned, stakeholder feedback, and emerging best practices into strategic planning and program development.

(d) Ad-Hoc Investigation and Incident Reporting: Special investigations, incident response documentation, corrective action tracking, and lessons learned integration with comprehensive documentation supporting continuous improvement and prevention program enhancement.

8.02.2 External Communication and Transparency

(a) Annual Modern Slavery Statement Publication: Public disclosure of prevention efforts, performance results, challenges encountered, and future commitments with transparent communication about program effectiveness and organizational commitment to continuous improvement and stakeholder accountability.

(b) Client Communication and Relationship Management: Regular updates to clients regarding supply chain risk management, prevention program performance, compliance status, and capability development with appropriate balance of transparency and confidentiality protection.

(c) Regulatory Reporting and Authority Engagement: Compliance with disclosure requirements, regulatory reporting obligations, and proactive communication with regulatory authorities regarding prevention efforts, compliance status, and emerging issues requiring attention or collaboration.

(d) Industry Engagement and Thought Leadership: Participation in industry forums, knowledge sharing initiatives, best practice development, and collaborative improvement efforts with contribution to industry prevention capabilities while maintaining competitive advantage and proprietary information protection.

ARTICLE IX. REMEDIATION AND CORRECTIVE ACTION

Section 9.01 Incident Response and Immediate Action Framework

Upon identification of potential modern slavery or human trafficking situations:

9.01.1 Immediate Response and Protection Measures

(a) Worker Protection and Safety Assurance: Ensuring immediate safety, protection, and support for affected individuals with emergency assistance, temporary accommodation, medical care, and other immediate needs with priority focus on individual welfare and protection from further harm or retaliation.

(b) Investigation Launch and Evidence Preservation: Prompt initiation of thorough investigation procedures with appropriate expertise, independence, and authority with systematic preservation of evidence, documentation, and information supporting investigation activities and potential legal or regulatory proceedings.

(c) Stakeholder Notification and Communication: Appropriate and timely disclosure to relevant authorities, regulatory bodies, law enforcement agencies, and other stakeholders with balanced communication protecting affected individual privacy and rights while fulfilling legal and ethical disclosure obligations.

(d) Containment and Risk Mitigation: Immediate action to prevent further violations, protect additional potential victims, contain operational risks, and implement emergency measures preventing expansion or continuation of harmful practices while investigation and remediation activities are conducted.

9.01.2 Investigation Process and Due Process

(a) Independent and Qualified Investigation: Comprehensive investigation by qualified personnel with appropriate expertise, independence, and authority including external experts, legal counsel, and specialized investigators as necessary to ensure thorough, objective, and effective investigation processes.

(b) Victim-Centered Approach and Rights Protection: Prioritization of affected individual welfare, rights, and interests throughout investigation and remediation processes with appropriate support services, legal representation, and advocacy ensuring individual needs and rights are protected and promoted.

(c) Stakeholder Cooperation and Collaboration: Proactive cooperation with law enforcement agencies, regulatory authorities, social services, non-governmental organizations, and other stakeholders with appropriate information sharing and collaborative response ensuring effective investigation and remediation.

(d) Due Process and Fair Treatment: Fair and thorough evaluation of evidence, circumstances, and contributing factors with appropriate consideration of all relevant information and perspectives ensuring accurate findings and appropriate response measures based on comprehensive investigation and analysis.

Section 9.02 Remediation Measures and Victim Support

9.02.1 Victim Support and Assistance Programs

(a) Immediate Emergency Assistance: Emergency support for health, safety, and basic needs including medical care, temporary housing, food, clothing, and other essential services with immediate availability and appropriate cultural sensitivity and individual needs assessment.

(b) Legal Support and Advocacy: Access to qualified legal representation, advocacy services, and legal assistance including immigration support, labor rights enforcement, and other legal protections and remedies available to affected individuals with appropriate expertise and resources.

(c) Financial Remediation and Compensation: Appropriate financial compensation for lost wages, damages, suffering, and other financial impacts with fair and reasonable compensation determination based on individual circumstances and applicable legal standards and remedies.

(d) Long-Term Support and Recovery Services: Access to counseling services, mental health support, training and education programs, job placement assistance, and other long-term support services supporting recovery, reintegration, and future stability and success for affected individuals.

9.02.2 Systemic Remediation and Prevention Enhancement

(a) Root Cause Analysis and System Assessment: Comprehensive investigation of underlying factors, contributing causes, and systemic issues that enabled violations to occur with identification of prevention failures, control weaknesses, and system improvements required to prevent recurrence.

(b) Process Improvements and Control Enhancement: Implementation of enhanced controls, monitoring systems, prevention measures, and operational improvements addressing identified vulnerabilities and strengthening prevention capabilities throughout operations and supply chain relationships.

(c) Policy Updates and Requirement Strengthening: Revision and enhancement of policies, procedures, contractual requirements, and enforcement mechanisms based on lessons learned with strengthened prevention requirements and improved implementation and monitoring capabilities.

(d) Training Enhancement and Awareness Improvement: Enhanced training programs, awareness initiatives, and education improvements incorporating incident lessons learned with improved recognition capabilities, response procedures, and prevention effectiveness throughout the organization and supply chain.

Section 9.03 Supplier Remediation and Relationship Management

For supplier-related violations and non-compliance:

(a) Corrective Action Plans and Performance Improvement: Time-bound requirements and improvement plans for addressing deficiencies, implementing enhanced controls, and achieving compliance with prevention requirements with clear milestones, performance targets, and accountability mechanisms.

(b) Enhanced Monitoring and Oversight During Remediation: Increased oversight frequency, comprehensive monitoring procedures, performance tracking, and progress validation during remediation periods with enhanced reporting and validation requirements ensuring effective improvement and sustained compliance.

(c) Capacity Building and Technical Assistance: Additional training, technical assistance, resource provision, and partnership support helping suppliers implement required improvements, develop prevention capabilities, and achieve sustained compliance with prevention requirements and expectations.

(d) Relationship Review and Continuation Assessment: Systematic evaluation of supplier commitment, improvement progress, compliance achievement, and long-term capability for maintaining prevention standards with decisions regarding relationship continuation, modification, or termination based on performance and commitment demonstration.

Section 9.04 Non-Compliance Consequences and Accountability

Failure to achieve adequate remediation or sustained compliance may result in:

(a) Contract Suspension and Business Limitation: Temporary suspension of business activities, limitation of service assignments, and restriction of commercial transactions pending successful completion of required improvements and demonstration of sustained compliance capabilities.

(b) Financial Penalties and Cost Recovery: Monetary sanctions for contractual violations, cost recovery for investigation and remediation expenses, and financial accountability for harm caused with appropriate penalty determination based on violation severity and impact.

(c) Relationship Termination and Permanent Exclusion: Permanent cessation of business partnerships, contract termination, and exclusion from future business opportunities for serious violations, inadequate remediation response, or repeated non-compliance with prevention requirements and expectations.

(d) Legal Action and Regulatory Cooperation: Pursuit of available legal remedies, cooperation with regulatory authorities and law enforcement, and support for legal proceedings addressing violations with appropriate legal action and accountability measures for serious violations and non-compliance.

ARTICLE X. COLLABORATION AND INDUSTRY ENGAGEMENT

Section 10.01 Industry Collaboration and Collective Action

10.01.1 Industry Initiative Participation

We actively participate in collaborative industry efforts including:

(a) Industry Association Engagement: Active membership and leadership in relevant industry associations, professional organizations, and trade groups with focus on modern slavery prevention, ethical business practices, and collaborative improvement initiatives addressing industry-wide challenges and opportunities.

(b) Best Practice Development and Sharing: Contribution to industry best practice development, knowledge sharing initiatives, and collaborative research with appropriate sharing of experiences, methodologies, and lessons learned while protecting competitive information and proprietary practices.

(c) Standards Development and Certification Programs: Participation in development of industry standards, certification programs, and voluntary initiatives establishing higher prevention standards and accountability mechanisms with contribution to industry-wide prevention capability development and improvement.

(d) Research and Development Collaboration: Support for collaborative research initiatives, academic partnerships, and development programs advancing prevention knowledge, methodologies, and capabilities with contribution to evidence-based prevention approaches and innovation in prevention techniques and practices.

10.01.2 Multi-Stakeholder Partnership Development

(a) Cross-Sector Collaboration and Partnership: Engagement with organizations across different sectors, industries, and functional areas with shared interest in modern slavery prevention and human rights protection with collaborative initiatives addressing common challenges and opportunities.

(b) Supply Chain Collaboration and Improvement: Collaboration with suppliers, clients, and other business partners on prevention initiatives, capability development, and shared responsibility approaches creating collective impact and shared accountability for prevention throughout extended business networks.

(c) Technology and Innovation Partnerships: Partnership with technology companies, research institutions, and innovation organizations developing new tools, methodologies, and approaches for prevention, detection, and response with focus on scalable and effective prevention solutions.

Section 10.02 Civil Society and Non-Governmental Organization Partnerships

10.02.1 Expert Organization Collaboration

We maintain collaborative relationships with:

(a) Human Rights and Anti-Trafficking Organizations: Partnership with specialized non-governmental organizations focused on human rights protection, anti-trafficking efforts, and victim support with collaborative initiatives, knowledge sharing, and mutual support for prevention and response objectives.

(b) Academic and Research Institutions: Collaboration with universities, research centers, and academic experts on prevention research, policy development, and evidence-based approaches with support for academic research and application of research findings to practical prevention initiatives.

(c) International Development Organizations: Partnership with multilateral organizations, development agencies, and international institutions working on human rights protection and development with alignment of prevention efforts with broader development objectives and international cooperation initiatives.

(d) Local Community Organizations: Engagement with grassroots organizations, community groups, and local institutions in our operational areas with support for community-based prevention initiatives and local capacity building supporting prevention objectives and community development.

10.02.2 Knowledge Sharing and Capacity Building

(a) Expertise Sharing and Consultation: Provision of expertise, experience, and resources to support broader prevention efforts and capability development with appropriate sharing of knowledge and lessons learned while maintaining competitive position and intellectual property protection.

(b) Training and Education Support: Support for training programs, educational initiatives, and awareness campaigns conducted by partner organizations with contribution of resources, expertise, and participation supporting broader prevention education and capability development objectives.

(c) Research and Policy Support: Contribution to policy research, advocacy initiatives, and regulatory development supporting evidence-based policy making and regulatory frameworks addressing modern slavery prevention with appropriate engagement and thought leadership contributions.

Section 10.03 Government and Regulatory Authority Cooperation

10.03.1 Regulatory Engagement and Compliance Support

(a) Proactive Regulatory Engagement: Constructive and proactive engagement with regulatory authorities, government agencies, and policy makers on modern slavery prevention with appropriate transparency, cooperation, and support for regulatory objectives and policy development.

(b) Law Enforcement Cooperation and Support: Full cooperation with law enforcement investigations, regulatory inquiries, and legal proceedings related to modern slavery prevention with appropriate information sharing, evidence provision, and support for law enforcement objectives and legal processes.

(c) Policy Development and Regulatory Input: Contribution of expertise and perspective to policy development processes, regulatory consultations, and legislative initiatives with appropriate input and recommendations based on operational experience and industry knowledge.

(d) International Cooperation and Diplomatic Support: Support for international cooperation initiatives, diplomatic efforts, and multilateral programs addressing modern slavery prevention with appropriate participation in international forums and support for global prevention objectives and cooperation.

10.03.2 Transparency and Accountability Support

(a) Reporting and Disclosure Excellence: Comprehensive and transparent reporting exceeding minimum regulatory requirements with additional voluntary disclosure and information sharing supporting accountability and transparency objectives while maintaining appropriate confidentiality and competitive protection.

(b) Audit and Assessment Cooperation: Full cooperation with regulatory audits, assessments, and investigations with provision of access, information, and support facilitating effective regulatory oversight and validation of prevention efforts and compliance status.

(c) Best Practice Demonstration and Leadership: Demonstration of prevention best practices and leadership in prevention efforts with appropriate example setting and industry leadership supporting regulatory objectives and policy effectiveness.

ARTICLE XI. CONTINUOUS IMPROVEMENT AND STRATEGIC ENHANCEMENT

Section 11.01 Program Evolution and Development Framework

11.01.1 Systematic Program Review and Enhancement

Our modern slavery prevention program undergoes continuous evolution through:

(a) Comprehensive Annual Program Assessment: Systematic evaluation of prevention program effectiveness, performance against objectives, industry benchmark comparison, and identification of improvement opportunities with comprehensive review of policies, procedures, implementation effectiveness, and strategic alignment.

(b) Stakeholder Feedback Integration and Response: Regular collection and systematic integration of feedback from employees, suppliers, clients, partners, community organizations, and other stakeholders with evaluation of program effectiveness and satisfaction with prevention efforts and outcomes.

(c) Industry Benchmarking and Best Practice Integration: Comparison with industry best practices, leading organization approaches, and emerging standards with identification and integration of proven practices and innovative approaches improving prevention effectiveness and capability.

(d) Regulatory Development and Compliance Enhancement: Adaptation to evolving legal requirements, regulatory guidance, and compliance expectations with proactive adjustment of prevention programs ensuring continued compliance and alignment with regulatory objectives and stakeholder expectations.

11.01.2 Innovation and Technology Integration

(a) Technology Enhanced Prevention and Detection: Evaluation and implementation of emerging technologies supporting prevention objectives including data analytics for risk assessment, artificial intelligence for pattern recognition, blockchain for supply chain transparency, and other technological solutions enhancing prevention capabilities and effectiveness.

(b) Digital Monitoring and Transparency Solutions: Implementation of digital solutions improving supply chain visibility, real-time monitoring capabilities, stakeholder communication, and transparency enhancement with technology-enabled prevention and accountability improvement supporting strategic prevention objectives.

(c) Automation and Efficiency Enhancement: Application of technology and automation improving efficiency of prevention activities, monitoring procedures, assessment processes, and reporting capabilities while maintaining effectiveness and human oversight ensuring appropriate balance of efficiency and prevention effectiveness.

Section 11.02 Strategic Performance Measurement and Impact Assessment

11.02.1 Long-Term Impact Evaluation and Measurement

(a) Prevention Impact Assessment and Validation: Systematic evaluation of actual reduction in modern slavery risks, prevention of incidents, improvement in worker welfare, and overall impact on human rights protection with measurement of strategic prevention objective achievement and long-term program effectiveness.

(b) Supply Chain Improvement and Capability Assessment: Assessment of supplier capability development, compliance improvement, prevention program implementation, and sustainable change achievement throughout supply chain relationships with measurement of collaborative improvement impact and partnership effectiveness.

(c) Organizational Culture and Capability Development: Evaluation of organizational culture development, employee awareness and capability improvement, management system effectiveness, and institutional prevention capability enhancement with measurement of cultural change and capability development supporting prevention objectives.

(d) Industry Leadership and Influence Assessment: Assessment of industry influence, leadership demonstration, best practice contribution, and broader impact on industry prevention capabilities and standards with measurement of thought leadership and collaborative improvement contributions.

11.02.2 Strategic Enhancement and Future Development

(a) Strategic Objective Evolution and Enhancement: Regular review and enhancement of strategic prevention objectives based on performance assessment, stakeholder feedback, emerging challenges, and industry development with continuous alignment of objectives with organizational capabilities and stakeholder expectations.

(b) Capability Development and Investment Planning: Strategic investment in prevention capabilities, technology enhancement, training and development programs, and partnership development supporting long-term prevention effectiveness and organizational prevention leadership and excellence.

(c) Partnership Development and Collaboration Enhancement: Expansion and enhancement of collaborative relationships, partnership opportunities, and collective impact initiatives with focus on strategic partnerships supporting prevention objectives and broader industry improvement and capability development.

Section 11.03 Future Commitments and Strategic Direction

11.03.1 Strategic Priorities and Focus Areas

Our future strategic focus encompasses:

(a) Supply Chain Transparency and Visibility Enhancement: Implementation of advanced supply chain mapping technologies, multi-tier supplier visibility systems, and transparency enhancement initiatives providing comprehensive understanding of supply chain relationships and enabling more effective prevention and risk management throughout extended business networks.

(b) Technology Innovation and Prevention Enhancement: Leveraging emerging technologies including artificial intelligence, blockchain, data analytics, and other technological innovations for enhanced detection capabilities, prevention effectiveness, and monitoring system improvement with focus on scalable and sustainable technology solutions.

(c) Capacity Building and Supplier Development Expansion: Expansion of training programs, technical assistance initiatives, and supplier development support with enhanced collaboration and partnership approaches creating sustainable prevention capabilities and long-term improvement throughout supply chain relationships.

(d) Collaborative Impact and Industry Leadership: Increased participation in industry-wide initiatives, multi-stakeholder partnerships, and collective action programs with enhanced contribution to industry prevention capabilities and leadership in prevention innovation and best practice development.

11.03.2 Specific Strategic Goals and Commitments

We commit to achieving the following strategic objectives:

(a) Risk Assessment Enhancement and Sophistication: Implementation of more sophisticated risk modeling, analysis methodologies, and assessment techniques incorporating advanced data analytics, stakeholder feedback, and comprehensive risk evaluation supporting more effective risk identification and mitigation.

(b) Supplier Engagement Expansion and Improvement: Extension of comprehensive due diligence procedures to additional supplier tiers, enhancement of supplier development programs, and expansion of collaborative improvement initiatives creating broader supply chain prevention capabilities and accountability.

(c) Training Program Enhancement and Effectiveness: Development of specialized training programs for high-risk regions and sectors, enhancement of training methodologies and effectiveness, and expansion of training reach and impact supporting improved prevention awareness and capability throughout organization and supply chain.

(d) Performance Measurement and Monitoring Improvement: Implementation of enhanced metrics, monitoring systems, and performance measurement approaches providing better visibility into prevention effectiveness and enabling more effective management and continuous improvement of prevention programs and outcomes.

11.03.3 Long-Term Vision and Commitment

Our long-term vision encompasses:

(a) Zero Tolerance Achievement and Prevention Excellence: Elimination of modern slavery risks from our operations and supply chain through comprehensive prevention systems, continuous improvement, and sustained commitment to human rights protection and ethical business practices achieving prevention excellence and industry leadership.

(b) Industry Leadership and Recognition: Recognition as a leader in ethical business practices, human rights protection, and modern slavery prevention with demonstration of best practices, thought leadership contribution, and positive influence on industry standards and capabilities.

(c) Collaborative Impact and Societal Contribution: Significant contribution to broader societal efforts to combat human trafficking and modern slavery through collaborative initiatives, resource sharing, knowledge contribution, and partnership development supporting collective impact and social progress.

(d) Sustainable Practice Integration and ESG Leadership: Full integration of modern slavery prevention efforts with broader sustainability initiatives, environmental responsibility, and ESG leadership creating comprehensive stakeholder value and contributing to sustainable development and social responsibility objectives.

ARTICLE XII. TRANSPARENCY AND ACCOUNTABILITY

Section 12.01 Public Disclosure and Stakeholder Communication

12.01.1 Comprehensive Transparency Framework

We maintain organizational transparency through:

(a) Annual Statement Publication and Accessibility: Public availability of modern slavery statements, prevention program information, and performance reporting through accessible website disclosure, stakeholder communication, and appropriate media channels ensuring broad stakeholder access to prevention information and accountability.

(b) Stakeholder Engagement and Communication Programs: Regular updates and communication with key stakeholders including clients, employees, suppliers, investors, community partners, and regulatory authorities regarding prevention efforts, performance results, and strategic commitments with appropriate balance of transparency and confidentiality protection.

(c) Media Engagement and Public Communication: Proactive and responsive communication about prevention efforts, industry leadership, and collaborative initiatives through appropriate media engagement, thought leadership contribution, and public speaking supporting transparency objectives and accountability demonstration.

(d) Industry Forum Participation and Knowledge Sharing: Active participation in industry conferences, professional forums, and knowledge sharing initiatives with contribution of expertise and experience supporting industry capability development while maintaining competitive advantage and proprietary information protection.

12.01.2 Stakeholder Engagement and Feedback Integration

(a) Advisory Group Consultation and Input: Regular consultation with external experts, advocacy organizations, industry peers, and other stakeholders providing independent perspective, expertise, and guidance supporting prevention program effectiveness and continuous improvement based on diverse stakeholder input and feedback.

(b) Client Communication and Service Integration: Integration of prevention information and accountability into client relationships through regular reporting, service discussions, and partnership development with appropriate transparency about prevention efforts and capabilities while maintaining confidentiality and competitive position.

(c) Employee Engagement and Culture Development: Comprehensive employee engagement on prevention topics through internal communication, training programs, feedback mechanisms, and culture development initiatives ensuring organizational alignment and commitment to prevention objectives and human rights protection.

(d) Community Outreach and Local Engagement: Appropriate engagement with local communities, civic organizations, and community leaders in operational locations supporting community-based prevention efforts and local stakeholder relationship development consistent with prevention objectives and community development.

Section 12.02 Accountability Mechanisms and Oversight

12.02.1 Organizational Accountability Framework

Accountability is ensured through comprehensive oversight structures:

(a) Executive Leadership Oversight and Accountability: Regular reporting to and oversight by executive leadership including performance assessment, resource allocation decisions, strategic guidance, and accountability for prevention program effectiveness and organizational commitment to human rights protection and ethical business practices.

(b) Management Accountability and Performance Integration: Clear management responsibility assignment, performance measurement and evaluation, accountability consequences, and integration of prevention objectives into management performance evaluation and organizational success metrics ensuring sustained management commitment and effectiveness.

(c) Independent Assessment and External Validation: Engagement of independent auditors, assessment professionals, and external experts for objective evaluation of prevention program effectiveness, compliance validation, and continuous improvement recommendation with external perspective and validation supporting accountability and effectiveness enhancement.

(d) Regulatory Compliance and Authority Engagement: Proactive compliance with regulatory requirements, cooperation with regulatory authorities, and transparent reporting supporting regulatory objectives and legal compliance while demonstrating organizational commitment to prevention excellence and stakeholder accountability.

12.02.2 Performance Accountability and Continuous Improvement

(a) Objective Performance Measurement and Reporting: Systematic measurement and reporting of prevention program performance against established objectives, industry benchmarks, and stakeholder expectations with transparent communication about achievements, challenges, and improvement initiatives supporting accountability and continuous enhancement.

(b) Stakeholder Feedback Integration and Response: Regular collection, analysis, and response to stakeholder feedback regarding prevention program effectiveness, service quality, and organizational performance with systematic integration of feedback into improvement initiatives and strategic planning supporting stakeholder satisfaction and program enhancement.

(c) Corrective Action Implementation and Validation: Systematic implementation of corrective actions, improvement initiatives, and enhancement programs with validation of effectiveness and sustained improvement supporting continuous improvement and prevention program excellence.

(d) Industry Benchmark Comparison and Excellence Pursuit: Regular comparison with industry best practices, leading organizations, and prevention excellence standards with pursuit of industry leadership and best practice demonstration supporting accountability and prevention program excellence.

ARTICLE XIII. STATEMENT APPROVAL AND GOVERNANCE

Section 13.01 Executive Leadership Approval and Validation

This Statement has been comprehensively reviewed and formally approved by executive leadership of Assivo, Inc., demonstrating:

(a) Strategic Commitment and Resource Allocation: Executive commitment to modern slavery prevention as a strategic organizational priority with appropriate resource allocation, capability development, and sustained attention ensuring effective prevention program implementation and continuous improvement.

(b) Accountability and Oversight Responsibility: Executive accountability for ensuring effectiveness of prevention efforts, performance monitoring and management, corrective action implementation, and sustained organizational commitment to human rights protection and ethical business practices.

(c) Stakeholder Protection and Value Creation: Commitment to protecting interests and welfare of employees, suppliers, clients, and broader society while maintaining competitive advantage and business success through ethical business practices and responsible organizational leadership.

(d) Continuous Improvement and Excellence Pursuit: Ongoing commitment to prevention program enhancement, capability development, industry leadership, and contribution to broader prevention efforts and human rights protection objectives through sustained organizational commitment and resource investment.

Section 13.02 Annual Review and Enhancement Commitment

This Statement will undergo systematic annual review and enhancement including:

(a) Comprehensive Program Assessment and Review: Thorough evaluation of prevention program effectiveness, performance against objectives, stakeholder feedback integration, and identification of improvement opportunities with comprehensive assessment of strategic alignment and capability development.

(b) Regulatory Development and Compliance Enhancement: Updates reflecting evolving regulatory requirements, industry standards, best practice development, and legal obligation changes ensuring continued compliance and alignment with regulatory expectations and stakeholder requirements.

(c) Stakeholder Feedback Integration and Response: Systematic incorporation of feedback from employees, suppliers, clients, regulatory authorities, and other stakeholders with evaluation of satisfaction and effectiveness and integration of improvement suggestions and recommendations.

(d) Strategic Enhancement and Future Planning: Integration of lessons learned, performance results, and strategic objectives into future planning and program development with continuous enhancement of prevention capabilities and effectiveness supporting long-term prevention excellence and industry leadership.

ARTICLE XIV. CONTACT INFORMATION AND REPORTING

Section 14.01 General Inquiries and Information

Ethics and Compliance Office
Assivo, Inc.
444 West Lake Street, Suite 1700
Chicago, Illinois 60606
Telephone: (312) 416-8649
Email: ethics@assivo.com

Section 14.02 Regional Coordination and Support

Regional Prevention Coordination:

Americas Operations: americas@assivo.com
Mexico Operations: mexico@assivo.com
India Operations: india@assivo.com

Section 14.03 External Resources and Emergency Support

For additional support, assistance, and information:

National Human Trafficking Hotline: 1-888-373-7888
Modern Slavery Helpline (UK): 08000 121 700
Local Law Enforcement: Emergency services in respective operational locations

Section 14.04 Stakeholder Engagement and Partnership Opportunities

For collaboration opportunities, partnership development, and stakeholder engagement regarding modern slavery prevention initiatives, please contact our Ethics and Compliance Office through the primary contact information provided above.

EXECUTIVE CERTIFICATION AND APPROVAL

Signed:

Karan R. Vaswani
Principal
Assivo, Inc.

Date: August 27, 2025

This Modern Slavery and Human Trafficking Statement represents our comprehensive and unwavering commitment to combating human trafficking and modern slavery through systematic prevention efforts, continuous improvement, and collaborative stakeholder engagement. It reflects our institutional dedication to human rights protection and ethical business practices as fundamental organizational values and strategic priorities.