Anti-Slavery, Human Trafficking, & Child Labor Policy

1. Purpose

Exxact Corporation ("Exxact" or the "Company") is committed to conducting business in a manner that respects human rights and upholds the dignity of all workers. This Policy establishes Exxact's zero-tolerance position on forced labor, human trafficking, and child labor, and sets forth the protections, controls, and accountability mechanisms the Company maintains to prevent, identify, and remediate these risks in its own operations and, where applicable, its supply chain.

This Policy supports Exxact's compliance obligations under applicable laws and regulations, including but not limited to the U.S. Federal Acquisition Regulation clause on Combating Trafficking in Persons (FAR 52.222-50), Section 307 of the U.S. Tariff Act of 1930, the California Transparency in Supply Chains Act, and other supply chain due diligence regulations referenced in customer-requested disclosures.

2. Scope

This Policy applies to all Exxact employees, officers, and agents, at all locations, without exception. Where Exxact engages recruiters, staffing agencies, or similar third parties to source labor on its behalf, this Policy extends to those relationships as well. Provisions of this Policy that address foreign or domestic migrant worker housing, transportation, and recruiter oversight reflect Exxact's standing commitments should its workforce composition or recruiting practices change in the future; they do not imply that such arrangements are currently in use.

3. Policy Statement

Exxact prohibits, and will not knowingly benefit from, any form of forced labor, bonded or indentured labor, involuntary prison labor, slavery, or human trafficking in its own operations or those of its suppliers. Exxact prohibits child labor in all its forms, consistent with the definitions below. Compliance with this Policy is a condition of employment and of doing business with Exxact.

4. Prohibited Conduct

4.1 Forced Labor and Human Trafficking (Modern Slavery)

Exxact strictly prohibits all forms of forced labor and human trafficking, including work or service extracted through force, fraud, coercion, debt bondage, or threat of penalty, and any recruitment, transportation, harboring, or receipt of persons by improper means for the purpose of exploitation.

4.2 Child Labor

Exxact prohibits the employment of any worker below the minimum age for completing compulsory schooling, and in no case below 15 years of age (or the applicable local legal minimum, if higher). Exxact further prohibits the "worst forms of child labor," defined as hazardous work performed by any person under the age of 18 that jeopardizes their physical, mental, or moral well-being, including work performed for long hours, during the night, or under otherwise hazardous conditions.

4.3 Identity and Immigration Documents

Exxact prohibits the withholding, destruction, concealment, or confiscation of any worker's identity documents, immigration documents, or other personal legal documents, whether by the Company or by any recruiter engaged on the Company's behalf.

4.4 Recruiter Compliance

In the event Exxact engages recruiters, those recruiters will be required to comply with all applicable local labor laws in the jurisdiction where recruiting takes place, and to refrain from engaging subcontractors to recruit workers without Exxact's prior written approval and equivalent contractual compliance obligations.

4.5 Discrimination

Exxact prohibits discrimination in hiring, employment, or termination on the basis of race or color, sex, religion, political opinion, national extraction, age, HIV/AIDS status, disability, nationality, sexual orientation, family responsibilities, or trade union membership or activity.

4.6 Recruitment Fees

Exxact prohibits charging workers or prospective workers any recruitment fees or related costs, consistent with the "employer pays" principle. This prohibition applies to the Company directly and to any recruiter engaged on the Company's behalf.

4.7 Commercial Sexual Exploitation

Exxact prohibits its workers and agents from procuring commercial sex acts at any time in connection with their employment or engagement with the Company, including during business travel, consistent with applicable law and contractual obligations.

5. Worker Rights and Protections

5.1 Foreign Migrant Worker Transportation

Exxact does not currently employ or arrange for the employment of foreign migrant workers. Should this change, Exxact will provide or pay for return transportation for any foreign migrant worker brought into the country for the purpose of working for the Company (directly or through a recruiter) at the end of their period of work, except where an exception recognized under applicable guidance (e.g., voluntary early termination for cause, or the worker's independently arranged subsequent employment) applies.

5.2 Worker Housing

Exxact does not currently provide or arrange housing for its workers. Should this change, any housing provided or arranged by Exxact will meet applicable host-country housing and safety standards.

5.3 Freedom to Terminate Employment

All workers, including any migrant workers, may cancel their work agreements at any time without financial penalty, subject to providing reasonable notice in accordance with applicable law or any applicable collective agreement.

5.4 Wages and Compensation

Exxact pays wages that meet or exceed all applicable host-country legal minimum wage requirements. Where no legal minimum wage applies, Exxact aligns compensation with the prevailing wage for the relevant sector and location.

5.5 Freedom of Association

Workers have the right to form and join trade unions of their own choosing, to bargain collectively, and to engage in peaceful assembly, consistent with applicable law.

5.6 Work Agreements

Workers, including any hired through recruiters, are provided detailed and accurate work agreements or equivalent work papers, in a language they understand, prior to relocation where relocation is required, and in all cases where required by applicable law or contract.

5.7 Pre-Employment Document Verification

Exxact verifies applicable documentation for all workers prior to the start of employment, including proof-of-age documentation, to confirm eligibility to work in accordance with legal requirements and Company policy.

6. Migrant Worker Provisions

Exxact does not currently hire foreign or domestic migrant workers. Exxact will review and, if necessary, extend this Policy to address the specific regulation of migrant worker recruitment, placement, and working conditions prior to engaging in such hiring practices.

7. Supply Chain Communication and Flow-Down

Exxact incorporates a flow-down clause into its standard Purchase Order Terms and Conditions requiring suppliers to comply with, and to further flow down to their own subcontractors and sub-tier suppliers, obligations substantially consistent with this Policy, including prohibitions on forced labor, human trafficking, and child labor; sourcing restrictions related to the Xinjiang Uyghur Autonomous Region; and supplier disclosure, audit, reporting, and remedy obligations. This clause is set out in Exxact's Purchase Order Terms and Conditions under the section titled "Combating Human Trafficking, Forced Labor, and Child Labor."

8. Remedy

Where Exxact identifies that an adverse impact related to forced labor, human trafficking, or child labor has occurred in connection with its operations, Exxact will take appropriate steps to provide for, or participate in, remedy for affected individuals, proportionate to the Company's involvement in the impact.

9. Policy Administration

POL-004 | Policy Owner: Quality & Compliance Manager | Approval Authority: Vice President

Review Cycle: Annually, or upon material change in operations, workforce composition, or applicable regulation.

This Policy is maintained under Exxact's Quality Management System document control process and is available to employees, customers, and other stakeholders upon request.