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ZERO-TOLERANCE FOR ANY FORM OF MODERN SLAVERY POLICY AND STATEMENT

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

Alation, its subsidiaries and affiliates (“Alation”) has a zero-tolerance approach to modern slavery. We are committed to ensuring transparency and 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 expect the same high standards from all our contractors, suppliers and other business partners and we expect that our suppliers will hold their own suppliers to such 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 Zero-Tolerance Modern Slavery Policy and Statement is intended for all Alation’s businesses in all countries, especially the United Kingdom and Australia; and was brought to you by Alation.

Responsibility for the policy

Alation has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing any 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.

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 Head of Legal.

Compliance with the policy

You must ensure that you read, understand and comply with 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 with and for us. 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 in any parts of our business or supply chains of any supplier, raise it with your direct manager or a member of Alation’s executive staff as soon as possible.

You should note that where appropriate, and with the welfare and safety of local workers as a priority, we will give support and guidance to our suppliers to help them address coercive, abusive and exploitative work practices in their own business and supply chains.

We aim to encourage openness and will support anyone who raises genuine concerns under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any retaliation as a result of reporting their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains.

Communication & awareness of this policy

Our Employee Handbook, which includes our code of conduct and is supplemented by other policies, such as this, sets the standard for our employees’ behaviour. The employees receive mandatory training on the Handbook, both as new hires and at regular intervals during their tenure.

Our zero-tolerance approach to modern slavery will be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

Breach of this policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. A supplier’s failure to comply with this policy may result in cancellation of all orders and termination of the business relationship between Alation and such supplier.