Introduction

    Entrust Corporation (the “Company”) has a zero-tolerance approach to human trafficking and modern slavery and is committed to acting ethically and with integrity in all business dealings and relationships and implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or supply chain.

    Purpose

    Human trafficking and 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.

    Scope

    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, the organization has over 3,000 employees worldwide and operates in four key regions: EMEA, APAC, LATAM, and North America.

    This policy applies to all colleagues of Entrust entities worldwide to the extent consistent with applicable local legal requirements, policy, business need, and practice. To the extent there is any conflict between this policy and any local policy, the local policy shall prevail.

    Policy

    It is Entrust’s policy to oppose human trafficking and modern slavery vigorously. Accordingly, the Company is undertaking steps including the following:

    • The Company does not and will never tolerate human trafficking or modern slavery in any aspect of its own work.
    • The Company will collaborate with other organizations as needed to present a united front against human trafficking and modern slavery in its broader working environment.
    • The Company will support staff 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 include provisions in supplier contracts to similarly prohibit the use of forced, compulsory, or trafficked labor, and expects that its suppliers will hold their own suppliers to the same high standards.
    • The Company may terminate its relationship with individuals

    DEFINITIONS

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

    Exploitation means: slavery, servitude or forced or compulsory labor; sexual exploitation, in particular but not limited to prostitution and sexual offenses 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.

    RESPONSIBILITY

    The prevention, detection, and reporting of modern slavery in any part of the Company’s business or supply chain is the responsibility of all colleagues.

    • It is the responsibility of Entrust to ensure implementation of this policy and any related local policies in all applicable locations.
    • It is the responsibility of managers at all levels to ensure that those reporting to them understand and comply with this policy and any related local policy within his or her department.
    • Colleagues are expected to help Entrust provide a workplace that is free from any violations of this policy. It is therefore the responsibility of each colleague to promptly raise any concerns about a violation or possible violation of this policy and/or any related local policy.

    REPORTING AN INCIDENT

    Incidents involving possible violations of this policy must be reported immediately. The employee may choose first to report the incident to the employee's immediate supervisor or next level manager. Supervisors and managers are required to report all such incidents to Human Resources.

    If for any reason the employee is unable or reluctant to report the incident to supervisory personnel, the employee should report the incident to the Business Unit Human Resources Business Partner. In addition, employees have the option to report concerns anonymously through the Ethics Hotline, which is available at entrust.ethicspoint.com. Additional information on the Ethics Hotline can be found in the Code of Ethics and on the Entrust Compliance webpage.

    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.

    Compliance

    This policy will be reviewed and updated annually and constitutes the Company’s statement pursuant to section 54(1) of the Modern Slavery Act of 2015 for the United Kingdom.

    Exceptions

    There are no exceptions to this policy.

    Ownership and Review

    This policy is owned by the Chief Human Resources Officer, who is responsible for ensuring Company-wide compliance with this policy. It will be reviewed on an annual basis in accordance with the Global Policy on Creation and Administration of Global Policies.

    Beth Klehr
    Chief Human Resources Officer
    1-952-988-1236
    [email protected]