Efforts to Combat

Human Trafficking and Modern Slavery

Background

Virgin Pulse ¹ is a software company that designs technology aimed at cultivating positive employee lifestyle habits. Our goal is to promote positive change in individuals’ lives, and through that, in work environments across the world. Configured to complement the organization’s culture, our technology, and the overall wellbeing experience we deliver, drives superior outcomes for an organization’s contributors and its business.

Virgin Pulse is committed to ensuring everyone working with and for our organization and supply chain, whether directly or indirectly, is treated with the respect and dignity they inherently deserve. Virgin Pulse works hard to safeguard the wellbeing of the people who support our operations and services, and makes every effort to ensure our work and our employees promote positive changes in the world.

Virgin Pulse and all its employees wholeheartedly believe that Human Trafficking and Modern Slavery have no place in our society. We invest time and resources to ensure we raise the bar every year, not because the law requires it, but because we know it is the right thing to do. As a global company, we are committed to compliance with all applicable laws, and through our work bring about positive changes in the world.

The U.K. Modern Slavery Act 2015 instructs certain commercial organizations to prepare and publish a Modern Slavery and Human Trafficking statement for the financial year describing the steps, if any, the organization has taken during the financial year to ensure that Modern Slavery and Human Trafficking is not taking place in any of its supply chains and in any part of its own business.

This Statement summarizes our efforts to combat Human Trafficking and Modern Slavery in all its forms, including servitude and forced, compulsory, non-retributed and involuntary labor in our supply chain, our partners and our operations.

The Virgin Pulse Anti-Human Trafficking and Anti-Modern Slavery Code of Conduct

Virgin Pulse expressly prohibits the use of involuntary labor in its supply chain and among its employees within our business. We enforce this approach through a multifaceted process. The prohibition is explicitly stated in our Code of Conduct and enforced through contractual provisions and regular audits.

Our selection criteria for suppliers follows a vendor review process, instituted to recognize any potential abuses and violations. As a global company, we purchase services and products all over the world. We take a risk-based approach to performing due diligence on our suppliers, which includes reviewing suppliers doing business in high-risk countries or offering high-risk products or services.

Where we employ the services of contractors locally and offshore, our process is to assess their operations, assess their employees’ conditions under normal circumstances and validate the status of internationally recognized ethical standard certifications.

We set standards for our suppliers in the following areas:

• Labor and Employment – We require that ethical employment practices be strictly enforced, including, but not limited to, policies with respect to ethnicity and culture. We further require strict compliance with applicable international and local laws as a basic requirement to enter into a business relationship.
• Environment – We require that the conditions within which employees are working in align with applicable international standards and that the care of the local environment through waste management and similar initiatives sufficiently conform with internationally recognized standards and applicable local regulations.
• Financial – We require that suppliers offer sufficient proof of their solvency and ability for a long term commitment for goods or services to be maintained.
• Third party relationships – We require that suppliers providing us with goods or services purchased exclusively to support our manufacturers and suppliers to provide appropriate evidence of their compliance with internationally recognized standards and applicable local regulations.
• Risk mitigation – We require appropriate assurances that the goods and services we’re buying are ethically sought and plans are in place to continue to provide them should the need arise to change supply.
• Anti-corruption – We require appropriate assurances that the supplier is not relying on unethical behavior in the supply chain to enable delivery of the goods or service.

Within our own environments, including our office spaces and home-offices, as well as any instance where our employees act on behalf of the company, we make all possible efforts to maintain a high standard for our employees, including but not limited to:

• offering flexible working hours,
• safe and appropriate workplaces,
• the opportunity to access training and development programs, and
• regular employee performance and remuneration reviews.

We communicate our company values regularly and clearly, to instill in our employees, vendors, suppliers, partners and clients an understanding of our commitment to work towards the eradication of Human Trafficking and Modern Slavery in our society. We make our expectations clear through our Code of Conduct and employee policies, and we promote Human Trafficking and Modern Slavery awareness to assist in all decision making by our employees worldwide.

Our organizational structure is designed to allow free access to the most senior levels, to ensure any breaches are swiftly reported and acted upon. We have processes in place, including the ability to communicate with Human Resources easily, fairly and without fear of repercussions, to deal with all aspects of employee conduct and decision making.

The maintenance of this policy is with the Virgin Pulse Compliance Department which is responsible for the management of the organization’s Corporate Social Responsibility Program.

Signed by:
Chris Michalak
Chief Executive Officer
Virgin Pulse, Inc.

Date:
November 18, 2021

_{1 The term “Virgin Pulse” as used in this document refers collectively to Virgin Pulse, Inc., and its domestic and foreign subsidiaries, including Gettheworldmoving, Ltd. and its subsidiaries.}