Quinn-Curtis, Inc.

Modern Slavery and Human Trafficking Policy

Modern slavery has been legally abolished in most countries around the world but remains a real issue today. It affects businesses and supply chains across economies and sectors and generally relates to holding a person in servitude for the purpose of forced labor, sexual exploitation or arranging or facilitating human trafficking.

Statements in this policy relates to section 54 of the Modern Slavery Act 2015 (“the Act”). We oppose slavery and human trafficking in all its forms and make this statement to set out the steps we have taken to ensure that slavery or human trafficking is not taking place in our business or in our supply chains. The intention of this policy is to set out how Quinn-Curtis, Inc. address modern slavery and human trafficking across its business and supply chain.

(a) Structure and supply chains

Quinn-Curtis, Inc. is a Massachusetts, United States based provider of computer software. All of our staff and suppliers are within the United States, and we make it a company policy to not use third party contractors or suppliers from outside the US.

(b) Policies and governance

Quinn-Curtis, Inc. has committed to respect and promote human rights and social principles in all our operations, including work with business partners and supply chains. 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.

We strive to uphold human rights in accordance with the 1948 Universal Declaration of Human Rights and aim to implement responsible action according to the Guiding Principles for Business introduced by the UN Human Rights Council in 2011. We also support and follow the UK Government’s guidance for business to integrate human rights. We are 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 our contractors, suppliers and other business partners. We expect that our suppliers will hold their own suppliers to the same high standards.

(c) Ownership and responsibility

This policy is owned by the Executive Board of Quinn-Curtis, Inc. and applies to all Quinn-Curtis, Inc. employees, partners and suppliers. The Board of Quinn-Curtis, Inc. is responsible for implementing this policy, monitoring its use and effectiveness, and dealing with any queries about it.

(d) Risk Assessment and due diligence

Quinn-Curtis, Inc. aims to tackle modern slavery and human trafficking across its business activities by identifying any existing issues or risks related to it as well as managing and mitigating those. All of those working for us or under our control are responsible for preventing, detecting and reporting any existing or potential issues of modern slavery and human trafficking at Quinn-Curtis, Inc. and across its supply chains. Employees and suppliers are encouraged to raise any concerns about any issues or suspicion of modern slavery within the Quinn-Curtis, Inc. business operations or any tier of our supply chain as soon as they become aware of it.

Whilst we have not identified any occurrences of modern slavery, we have done risk assessments and have identified the following key processes to influence and manage any potential risk of modern slavery and human trafficking within our business and supply chains:

• Ensure other relevant policies are updated and aligned.
• Continuous risk assessment: Our procurement function will continue to monitor our procurement spend on identified higher risk areas and suppliers, following an initial category and supplier risk evaluation.
• Scrutinize and monitor suppliers: Our procurement function, and other business functions dealing with suppliers, will carry out due diligence on specified higher risk suppliers to identify and manage potential risks related to modern slavery and human trafficking.
• Effective contract management: Our procurement function, and other business functions dealing with suppliers, will engage with specified higher risk suppliers and their supply chains to make them aware of this policy, and to jointly identify risks of modern slavery and human trafficking and mitigating actions.

We encourage everyone within the business to raise genuine concerns in good faith under this policy regardless of whether these may turn out to be mistaken. No members of staff may be punished, dismissed or be subject to any form of detriment for having taken an initiative that falls within the scope for the whistle-blowing procedures. We will terminate our relationship with individuals, suppliers, and organizations working on our behalf who breach this policy.

(e) Communication and Training

All new employees and temporary workers are made aware of this policy as part of the Quinn-Curtis, Inc. induction process, and specific awareness training concerning modern slavery and human trafficking risks is provided. Equally, this policy is communicated to all Quinn-Curtis, Inc. suppliers, contractors and business partners at the start of a business relationship or renewal of a contract.

This policy is reviewed and, if required, updated on an annual basis.

Date: 22 February 2022

Richard Quinn, President – Quinn-Curtis, Inc.

February 2022