Join Digital, Inc. is committed to ensuring that modern slavery and human trafficking, in any form, does not occur in our business or supply chain. This “2025 Slavery and Human Trafficking Policy Statement” (the “Statement”) is made pursuant to the requirements of the statutes and regulations noted below and reflect our continuing efforts to eradicate slavery and human trafficking in our business and supply chains.
Our Global Human Rights Principles demonstrate our commitment to respecting the fundamental dignity of people throughout our entire value chain. 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.
In accordance with internationally recognized human rights standards, this Statement defines modern slavery as child labor, involuntary or forced labor, and human trafficking in any form—including slave labor, invol¬untary or exploitative prison labor, indentured servitude, or bonded labor. Join does not tolerate any form of modern slavery.
Combating modern slavery requires commitment, resources, expertise, and innovative solutions from gov¬ernments, international organizations, the private sector, civil society, and people with lived experiences. At Join, we recognize the private sector’s unique responsibility to respect human rights and are committed to addressing modern slavery risks that may arise during the course of our business.
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 expect these individuals to abide by the same high standards mentioned in this policy statement, and we expect that they will hold their own suppliers to the same high standards.
Join’s respect for human rights is practiced throughout our business activities, including into our policy and governance framework.
Join’s Board of Directors is responsible for the control and direction of Join. Our Board of Directors regularly reviews reports from management on various aspects of our business, including related risks and strategies for addressing them. In addition, they oversee and monitor our corporate social responsibility policies and initiatives, including risks related to human rights and ethical business practices, and risks related to Join’s operations and engagement with customers, suppliers, and communities.
Our efforts to address modern slavery risks across our business and supply chains are included in our policies and practices, which convey our values and expectations, setting a high standard for ourselves and our supply chain. We regularly review and work to improve these policies. We do not tolerate the use of child labor, involuntary or forced labor, human trafficking, or modern slavery in any form—including slave labor, involuntary or exploitative prison labor, indentured servitude, or bonded labor—in our operations.
Our Business Conduct Policy and associated policies, procedures, training, and communications outline our expectations of our employees. All Join employees receive our Business Conduct policy at their onboarding. Join provides its employees various secure and accessible channels with guidelines for reporting concerns and violations. Employees can also voice concerns, anonymously report potential violations of Join’s Code of Business Conduct and Ethics, and ask questions about potentially unethical conduct through their manager or any senior manager at Join. We prohibit retaliation for making such complaints and take all allegations seriously.
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.
Suppliers are required to conform to our Supply Chain Standards, even when our Standards exceed the requirements of applicable law. Suppliers must follow all applicable laws and regulations. When applicable law conflicts with our Standards, suppliers must follow the law while finding a way to respect the principles of internationally recognized human rights and the expectations contained in our Standards.
We encourage our business partners, suppliers, contractors, to perform human rights and environmental due diligence to help ensure their products and services are produced and supplied in a way that respects human rights and the envi¬ronment and protect the fundamental dignity of workers.
Join does not tolerate the use of child labor. Suppliers are required to engage work¬ers who are: (i) minimum age requirement for the state or country they reside in, (ii) the age of completion of compulsory education, or (iii) the minimum age to work in the coun¬try where work is performed, whichever is greater. Workers under the age of 18 (“young workers”) must not perform hazardous work, including that which is likely to jeopardize their health or safety, or work that compro¬mises their education (e.g., night shifts, over¬time). If cases of child labor are identified, our Supply Chain Standards mandate reme¬diation, including corrective measures that facilitate the child’s safety and wellbeing.
Suppliers must respect the rights of workers to form, join, or refrain from joining, a labor union or other lawful organization of their own selection. Suppliers must respect workers’ rights to freedom of association and collective bargaining. Workers must not be penalized or subjected to reprisal, harassment, or intimida¬tion for the non-violent exercise of these rights.
Suppliers are required to provide workers with a safe and healthy work environment that avoids harm to workers’ physical and mental health. Suppliers must comply with applicable laws regarding occupational safe¬ty, working conditions, and health standards.
Our risk assessment process focuses on identifying and prioritizing risks of modern slavery within our operations and supply chains, helping us identify vulnerabilities, mitigate risks, and make informed decisions. Join takes steps to identify and prioritize risks, takes action to address and mitigate identified risks, measures progress, and remediates harm when issues occur.
Audits are an important due diligence tool that help us direct our efforts and resources. Audits help us detect issues before we engage with suppliers and during our relationship with suppliers, allowing us to work together on remediation, when appropriate. We accept audits completed by qualified indepen¬dent audit firms based on our own audit standards and those of industry associations.
When Join identifies gaps between a supplier’s practices and our Standards, we track remedia¬tion and conduct follow-up assessments as needed. We maintain ongoing engagement with suppliers to ensure respect for human rights in their operations and supply chains. While proud of our progress to further respect and advance human rights and address modern slavery risks throughout our business, we remain focused on scaling our initiatives and engaging company-wide to address these challenges.
Join Digital, Inc.’s global policies, practices, and procedures to assess and address modern slavery risks are implemented with attention to the local contexts and specific regional needs, in consultation with all reporting entities and their subsidiaries. Consultation on Join’s approach to modern slavery is led by Join’s Executive Team, which has visibility over and responsibility for assessing and providing Join’s businesses with the tools to address modern slavery risks in our global operations and supply chains. The team works closely and on an ongoing basis with all our operations, implement preventive measures, and monitor our approach to combating modern slavery. This annual policy statement and commitment was approved by Join’s Executive Team, and Board of Directors and covers all activities undertaken by Join Digital, Inc.
Signed by:
Karl May
CEO