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Modern Slavery Policy

Policy Statement

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. Altair Global has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all our business dealings and relationships and to implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or our supply chain.

Altair Global is also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chain. Altair Global demands the same high standards from all of our contractors, suppliers and other business partners. As part of our contracting processes, Altair Global includes specific prohibitions against the use of forced, compulsory or trafficked labor, or anyone held in slavery or servitude and Altair Global expects that our suppliers will hold their own suppliers to the same 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, agents, contractors, external consultants, third-party representatives and business partners.

This policy does not form part of any employee’s contract of employment and Altair Global may amend it at any time.

Responsibility for the Policy

Supplier Partnerships has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

The Senior Vice President of Supplier Partnerships has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing 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 and receive any required training.

Compliance with the Policy

Every Team Member must ensure that he/she has read, understands and complies with this policy.

The prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all those working for us or under our control. Team Members are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Team Members must notify a manager OR Supplier Partnerships as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.

Team Members are encouraged to raise concerns about any issue of suspicion of modern slavery in any parts of our business or the supply chains of any supplier tier at the earliest possible stage.

If a Team Member believes or suspects a breach of this policy has occurred or that it may occur, he/she must notify his/her manager or report it in accordance with our Whistleblowing Policy as soon as possible.

If a Team Member is unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chain constitutes any of the various forms of modern slavery, he/she must raise it with his/her manager or a member of the Supplier Partnerships team.

Altair Global encourages openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. Altair Global is committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any part of our supply chain. If any individual believes he or she has suffered any such treatment, he or she should inform a member of the management team immediately.

Communication and Awareness of Policy

Training on this policy, and on the risk our business faces from modern slavery in its supply chain will be given where needed.

Altair Global’s zero-tolerance approach to modern slavery must 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 Team Member who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

Altair Global may terminate our relationship with other individuals and organizations working on our behalf if they breach this policy.