OpenX Modern Slavery Act Statement

for the Financial Year ending December 31, 2021


OpenX is committed to understanding potential modern slavery risks related to our business and ensuring that there is no modern slavery in our own business and supply chains. We endorse the principles of the Modern Slavery Act 2015 (the “Act“) and we do not condone modern slavery in any form. This updated statement covers the financial year, January 1, 2021 to December 31, 2021 and is made pursuant to s.54 of the Act by OpenX Software Limited and on behalf of its subsidiary OpenX Limited (together, “OpenX“).

Structure and Supply Chains

OpenX and its worldwide subsidiaries and affiliates operate a digital advertising exchange connecting top brands with consumers across the most trafficked websites and mobile apps globally. We currently have offices in the United Kingdom, Australia, Singapore, the United States, Poland and Japan. We have contracts in place with publishers and application developers who provide digital advertising inventory, and demand partners who purchase digital advertising inventory via our digital advertising exchange. We also purchase professional services, IT equipment and office materials, among other things, from third party suppliers and strive to conduct business with third party suppliers who share our commitment to high ethical standards and who operate in a responsible and ethical manner towards their workers and suppliers.

We choose our suppliers with care and their integrity and ethical business practices form part of the selection criteria. Acknowledging the importance of the Act in the context of our supply chain, we will enhance our due diligence processes as far as is relevant to modern slavery and human trafficking. Whilst OpenX takes a proportionate approach commensurate to the prevailing risks to preventing modern slavery in the supply chain, we acknowledge the elevated risk of modern slavery in certain countries of the world and our due diligence and evaluation processes will develop to address those elevated risks appropriately.

Policies on Modern Slavery

OpenX is dedicated to ensuring that human rights are respected at all times. Our code of conduct requires employees to maintain the highest ethical standards and comply with all applicable laws and company policies. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.

OpenX encourages its team members to report any suspected wrongdoing or dangers in relation to any activity that falls short of our code of conduct and modern slavery policy.

This includes any circumstances that may give rise to an enhanced risk of slavery. By encouraging a culture of openness and accountability within OpenX, OpenX believes that it can help prevent illegal or unethical practices from occurring. OpenX’s procedure is designed to make it easy for its team members to make disclosures without fear of reprisal.

Due diligence processes

OpenX undertakes due diligence when considering taking on new partners and suppliers. We expect all our contractors, suppliers and other business partners to adopt the same high standard as we do to prevent modern slavery, by ensuring their operations are conducted with dignity and respect in a fair and ethical environment.

Risk Assessment

Considering our digital advertising business consists of predominantly professionally qualified and highly skilled people and the lengths of our supply chains are relatively short, we assess the risk of modern slavery within our business and supply chain to be low.

However, we are committed to preventing slavery in all of our corporate activities, and to ensuring that our supply chains are free from slavery including servitude and forced or compulsory labour.

Training for staff

We recognize the importance of training in combating modern slavery. We plan to to develop a modern anti-slavery training workshop for senior internal stakeholders to socialize our efforts in addressing modern slavery and raise awareness of key areas of potential risk.

Performance Indicators and Measuring Effectiveness

We accept that effective action to prevent modern slavery and human trafficking in our business and supply chain requires constant monitoring and an effective response should issues be identified. OpenX measures its effectiveness in the following ways: (a) periodically reviewing relevant policies and updating them as necessary; (b) confirming that employees have acknowledged its code of conduct; and (c) conducting anti-slavery training for relevant staff.

Our management will continue to take a zero tolerance approach to modern slavery and human trafficking and will react accordingly to any transgression whether by our staff or by our suppliers.

A Progressive Approach to Compliance

OpenX recognises that the risks from modern slavery and human trafficking are constantly evolving. We also recognise that efficient methods to identify and address modern slavery and human trafficking will be developed and enhanced. Open X will continue to monitor and evaluate such developments and our approach to preventing modern slavery will be reviewed annually so we can constantly adapt and improve our approach.

Board Approval

This statement has been approved by the board of OpenX Software Limited on its own behalf and for the benefit of OpenX Limited on December 1, 2022.

Signed by John Gentry, a director of OpenX Limited and of OpenX Software Limited