Modern Slavery Policy

The United Kingdom Modern Slavery Act of 2015 requires businesses to publish an annual statement specifying the efforts taken to prevent slavery and human trafficking anywhere in their own business or their supply chain.

oboloo, a global leader in Software as a Service (SaaS) empowers companies to connect with their customers in a whole new way. oboloo is committed to a set of core values —

• Trust
• Customer success
• Innovation
• Equality of every human being

Our suppliers are a critical part of the oboloo community. Transparency, trust, respect, communication and ethical conduct are critical to all successful business endeavours. These values provide a strong foundation for oboloo and for its relationships with suppliers.

oboloo is also committed to not only abide by the laws and regulations that apply to us as we conduct business around the world, but to be a leader in the areas of compliance and ethics.

The oboloo Code of Conduct outlines how oboloo and its subsidiaries conduct business and describes the company’s most fundamental shared values. It provides oboloo employees guidance on how to follow company policies, applicable laws, rules and regulations, as it is vital that all employees act with integrity and in accordance with local laws.

We partner with our suppliers and set clear expectations outlined in our oboloo Global Supplier Code of Conduct (“Supplier Code”), which is acknowledged by our suppliers as part of our supplier on-boarding process. We expect our suppliers to establish policies and procedures to ensure compliance with the Supplier Code and all applicable laws and regulations. Should we become aware of any policy violations or issues related to slavery or human trafficking, we will consult with our legal representatives to ensure that appropriate measures are taken, which may include reporting this information to authorities and terminating our relationship with the supplier.

oboloo conducts the following actions to help prevent forced labour, modern slavery and human trafficking:

1. Global Supplier Code of Conduct Acknowledgement

– Our Supplier Code serves as a guide to ethical supplier conduct. The Supplier Code applies to all third party suppliers of products or services that are paid directly by Oboloo, including consulting firms, independent contractors, staffing agencies, agency temps, and licensors, regardless of their title or the product or service they provide (“suppliers”). Suppliers must acknowledge receipt of the Supplier Code and agree to provide a copy of it to all supplier personnel assigned to perform services to oboloo.

2. Supplier Agreements

– All suppliers are subject to legal terms and conditions with oboloo.
– Assessments of potential suppliers are completed as part of our supplier on-boarding process.
– oboloo reviews the performance of suppliers based on their relative risk to the company, based on the assessment of cross-functional stakeholders, including the Legal Department. Suppliers deemed highest risk are audited or reviewed on a periodic basis. We work closely with
suppliers to develop corrective action plans and carry out all audit findings.
– We perform continuous monitoring of suppliers for changes in policies, environments, contracts and processes.

3  Training

– oboloo conducts oboloo Code of Conduct training and certification annually for all oboloo employees.
– We expect our suppliers to communicate the principles in the Supplier Code to their employees and third party partners through training, policy and other messaging.

This statement applies to oboloo.com and oboloo Limited