Modern Slavery and Human Trafficking Statement

Global Shares is committed to fair, ethical, and responsible business practices. This statement is made pursuant to Article’s 5 and 6 of the EU Charter of Fundamental Rights and sets out the steps that Global Shares and its subsidiaries has taken to prevent slavery and human trafficking taking place in our own operations or, to the maximum extent possible, in any of our supply chains.

Introduction

Global Shares is the world’s leading global equity incentive service provider. We are 100% focused on making the complex world of equity compensation as streamlined, straightforward and efficient as possible. We’ve been perfecting our award-winning software for more than 15 years and our 550-strong international team of skilled equity professionals will become an extension of your business. We provide a customised platform where your plan participants see and manage their equity and we help companies manage insiders and stay compliant. We provide a convenient share dealing solution, tax withholding admin services, tools to generate reports in real time, and much more.

Our supply chains:
Our supply chains include indirect services relating to facilities, human resources, and technology. As well as having the requisite contractual controls in place, there are rigorous on-boarding/background screens carried out on all individuals working at Global Shares locations.

Training and Awareness:
We have a dedicated compliance team, which consists of involvement where applicable from legal, internal audit, compliance, human resources, procurement and sales. We maintain awareness on MSHT through supplier engagement, raising awareness of issues and requirements, and by delivering training to our key staff, who manage the relationships with our suppliers on a risk-based approach.
As we operate in a highly regulated space Global Shares conducts regular business-wide Financial Crime Risk Assessments, which review our level of risk and control in all areas of financial crime, including Modern Slavery and Human Trafficking (MSHT), and continue to enhance the control framework on an ongoing basis.

Handbook:
All employees must read and acknowledge the Global Shares Handbook, which underscores our values and our commitment to ensuring a workplace that includes equal opportunity, dignity and respect, including with respect to our suppliers, affiliates and partners.
Global Shares is fully committed to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our business.

Ongoing Plans
In addition to the steps set out above, we intend to continue to work on reducing the risk of there being modern slavery and human trafficking in our operations or supply chain by taking the following steps:

• We will continue to provide training to internal groups; and
• We will conduct further due diligence on all suppliers with regards to human rights.
• We will incorporate ethical practices into our Business-to-Business transactions as part of our due diligence process