Global Anti-trafficking And Modern Human Slavery Policy

Entrust Corporation (the “Company”) has a zero-tolerance approach to human trafficking, slavery, servitude, forced or compulsory labor, child labor, and other forms of modern slavery and is committed to acting ethically and with integrity in all business dealings and relationships and implementing and enforcing effective governance, systems controls, and risk-based processes to help prevent, identify, assess, address, remediate, monitor, and report on these risks in our own business or supply chains.

Human trafficking, slavery, servitude, forced or compulsory labor, child labor, and other forms of modern slavery are serious human rights challenges that afflict vulnerable groups on a global scale. This policy is designed to communicate and ensure Entrust’s zero-tolerance approach to human trafficking and modern slavery.

Entrust is a supplier of secure physical and digital identity solutions. Entrust Corporation has its headquarters in Minnesota, USA. Together with its global subsidiaries and affiliates (referred to herein as “Entrust” or the “Company”), the organization has over 3,000 colleagues worldwide and operates in four key regions: EMEA, APAC, LATAM, and North America.

This policy applies to all colleagues of Entrust colleagues globally. Entrust also expects relevant contractors, temporary workers, business partners, and suppliers to comply with Entrust’s applicable anti-slavery, forced labor, child labor, and human rights expectations through contracts, supplier standards, codes and related procedures, as appropriate.

This policy shall be implemented in a manner consistent with applicable local legal requirements. If there is any conflict between this policy and any local policy, the local policy shall prevail.

Entrust will maintain processes to periodically assess the risk of human trafficking, forced labor, child labor, and modern slavery in its operations and supply chains.

Entrust will apply risk-based due diligence to relevant suppliers, third parties, and other business relationships, including, where appropriate, onboarding, renewal, contractual review, and escalation measures.

Risk assessments and due diligence activities may consider factors such as supplier category, geographic exposure, industry sector, sourcing model, operating context, and other relevant risk indicators.

Entrust will reassess risks and controls where there are material changes in business activities, supply-chain profile, legal requirements, or identified risk indicators.

SUPPLIER STANDARDS AND CONTRACTUAL CONTROLS

Entrust will maintain supplier ethics expectations and may require relevant suppliers and third parties to comply with Entrust’s applicable supplier standards, codes, questionnaires, certifications, and contractual provisions relating to human trafficking, forced labor, child labor, modern slavery, and related compliance obligations.

Where appropriate and consistent with applicable procurement, legal, and commercial requirements, Entrust may require cooperation with due diligence requests, investigations, corrective action plans, audits, or other reasonable compliance measures.

It is Entrust’s policy to prohibit human trafficking, slavery, servitude, forced or compulsory labor, child labor, and other forms of modern slavery in any part of its operations and supply chains. Accordingly, the Company is undertaking steps including the following:

• The Company does not and will never tolerate human trafficking, slavery, servitude, forced or compulsory labor, child labor, and other forms of modern slavery in any aspect of its own work.
• The Company may collaborate with internal and external stakeholders, including suppliers and other relevant parties, where appropriate, to strengthen prevention and response efforts.
• The Company will support colleagues, as needed, to be aware of the risks of human trafficking and modern slavery, and to act appropriately when any such risk is detected, including by providing appropriate training on this policy and its requirements, pursuant to applicable legal requirements and local practices.
• The Company will maintain standards, procedures, and controls governing supplier and third-party due diligence, supplier ethics expectations, contractual compliance requirements, issue escalation, investigation, corrective action, and program oversight.
• The Company may suspend, restrict, terminate or decline business relationships, and may require corrective action or other remedial measures, where concerns under this policy are substantiated or where a party fails to cooperate with reasonable compliance expectations, subject to applicable law and contractual terms.

DEFINITIONS

Child labor: Labor or services provided by persons under the age permitted by applicable law, or under circumstances that are unlawful, mentally, physically, socially, or morally dangerous, interfere with schooling, or otherwise constitute prohibited child labor under applicable law or international standards recognized by Entrust.

Due diligence: Risk-based measures used to identify, assess, prevent, mitigate, monitor, and address risks related to human trafficking, forced labor, child labor, and modern slavery in operations and supply chains.

Human trafficking: Arranging or facilitating the travel of another person so that person may be exploited. It is irrelevant whether that person has consented to travel. The exploitation need not actually have taken place.

Exploitation: Slavery, servitude or forced or compulsory labor; sexual exploitation, in particular but not limited to prostitution and sexual offences involving children; the removal of organs, otherwise than as properly approved by relevant authorities; securing services or other benefits/advantage by force, threats or deception; and securing services from children or anyone who is mentally or physically ill or disabled, where it is reasonable to expect that someone without the relevant vulnerability would have refused.

Forced or compulsory labor: Work or service extracted from any person under threat, coercion, penalty, deception, abuse of power, or other circumstances in which the person has not offered themselves voluntarily.

Modern slavery legislation: All applicable laws related to the prevention of slavery, including but not limited to the United Kingdom’s Modern Slavery Act of 2015, Australia’s Modern Slavery Act of 2018, and Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act of 2023.

Remediation: Appropriate corrective, preventive, or restorative measures taken in response to substantiated concerns, which may include corrective action plans, enhanced monitoring, suspension, termination, escalation, or other actions as appropriate under the circumstances and applicable law.

RESPONSIBILITY

The prevention, detection, escalation, and reporting of human trafficking, forced labor, child labor, and modern slavery in any part of Entrust’s business or supply chain is a shared responsibility.

Compliance / Legal is responsible for policy oversight, interpretation, program governance, investigation support or oversight as appropriate, and coordination of annual anti-slavery reporting obligations.

Procurement / Supply Chain is responsible for implementing relevant supplier and third-party due diligence, contractual controls, and supply-chain risk escalation processes.

Human Resources is responsible for supporting colleague awareness, speak-up processes, and escalation of relevant labor-related concerns.

Managers and business leaders are responsible for promoting compliance with this policy, escalating concerns, and supporting implementation within their respective areas.

Colleagues are required to complete applicable training, comply with this policy and related requirements, and promptly report concerns or suspected violations. Relevant internal stakeholders, including covered reporting entities where applicable, will cooperate in support of annual reporting, internal consultation, risk assessment, and program review activities.

REPORTING AN INCIDENT

Incidents involving possible violations of this policy must be reported immediately. Reports may be made through management, Human Resources, Legal, Compliance, or the Ethics Hotline (which is available at entrust.ethicspoint.com), as appropriate. Entrust also expects relevant suppliers and third parties to report credible concerns through available channels, where applicable.

Any report of a possible violation of this policy will be investigated in a manner consistent with applicable local law and policy and appropriate to the nature of the reported violation. Confidentiality will be maintained throughout the investigation to the extent consistent with conducting an adequate investigation and taking appropriate corrective action, and to the extent consistent with applicable local law and policy. The Company encourages openness and will support anyone who raises a genuine concern in good faith under this policy, even if it turns out to be mistaken.

Retaliation against an individual for reporting possible violations is strictly prohibited and will be subject to disciplinary action, up to and including termination.

REMEDIATION AND CORRECTIVE ACTION

Where concerns under this policy are substantiated, Entrust may take appropriate corrective, preventive, or remedial measures based on the facts and circumstances, applicable law, and contractual rights. Such measures may include corrective action plans, enhanced monitoring, escalation to leadership, suspension or termination of relationships, disciplinary action, or other appropriate actions.

Where relevant and appropriate, Entrust will consider the potential impact of its response on affected persons and on vulnerable populations, consistent with applicable law, available information, and the circumstances of the matter.

MONITORING, METRICS, AND RECORDS

Entrust will maintain appropriate records relating to policy implementation, risk assessment, due diligence, investigations, approvals, corrective actions, training, and other relevant compliance activities, in accordance with applicable law and record-retention requirements.

Entrust will periodically review the effectiveness of its anti-slavery program using appropriate management review processes and effectiveness indicators. Such indicators may include, where applicable, due diligence completion, training completion, issue escalation and investigation timeliness, corrective action implementation, and other governance measures.

Entrust may use the results of such reviews to improve controls, processes, training, and annual reporting.

There are no exceptions to this policy.

This policy is owned by the Director of Corporate Responsibility, who is responsible for overseeing the policy and coordinating periodic review in consultation with relevant functions, including Legal, Procurement / Supply Chain, Human Resources, and other stakeholders as appropriate.

This policy will be reviewed at least annually, and more frequently if required by changes in law, business operations, supply-chain profile, reporting obligations, or identified program needs.

The review process should be timed, where practicable, to support Entrust’s annual anti-slavery / forced-labor / child-labor reporting obligations and related governance activities.

• Anti-Slavery Policy (English)
• Anti-Slavery Policy (Spanish)
• Anti-Slavery Policy (French)
• Anti-Slavery Policy (German)
• Anti-Slavery Policy (Chinese)
• Anti-Slavery Policy (Japanese)
• Anti-Slavery Policy (Portuguese)
• Modern Slavery Statement