California Transparency in Supply Chains Acts

Vantive seeks to foster and maintain a culture of compliance with applicable laws, rules and regulations, and the highest standards of ethics and business conduct with respect to forced labor and human trafficking and slavery. Our commitment to fostering this culture of compliance extends to our relationships with suppliers. Specifically, Vantive does not support, encourage or endorse any form of forced labor or human trafficking and slavery in our operations or in our supplier networks. We take a number of steps with respect to verification of our supply chain and certification of materials to ensure suppliers are operating in an ethical manner with respect to forced labor, including the following: This disclosure is made pursuant to the California Transparency in Supply Chains Act of 2010 (SB 657), Cal. Civ. Code § 1714.43.

• On an annual basis, Vantive conducts a sustainability survey of its select suppliers to assess whether these suppliers have programs to address potential human rights risks, including human trafficking and slavery, and whether they have been alleged to have violated any human rights standards. This survey is conducted by a third party. The third party platform is used to conduct corporate responsibility surveys of participating suppliers’ corporate responsibility programs and performance in areas of labour and human rights, ethics, environment, and sustainable procurement. Vantive prioritizes suppliers for assessment based on factors including geographic risk, industry sector, and spend volume. This verification process is designed to evaluate and address risks of human trafficking and slavery in Vantive’s product supply chains.

• Supplier contracts include language that permit Vantive, upon advance notice, to access facilities at which any products and services provided to Vantive are manufactured and delivered to assess suppliers’ compliance with Vantive’s Ethics & Compliance Standards for Suppliers. Vantive conducts periodic audits of suppliers to evaluate compliance with company standards for trafficking and slavery in supply chains. Where circumstances warrant, such audits may be conducted on an unannounced basis by independent third-party auditors. Audit findings are reviewed by Vantive’s procurement and compliance teams, and corrective action plans are required for identified deficiencies.

• We have incorporated rules against forced labor into our Ethics & Compliance Standards for Suppliers and commercial agreements with suppliers. Suppliers who conduct business with Vantive are required to acknowledge receipt of Vantive’s Ethics & Compliance Standards for Suppliers. Specifically, the standards forbid the production or manufacture by suppliers of products or services (or incorporation of any materials therein) in violation of laws governing workers’ human rights, including human trafficking and slavery. Additionally, Vantive requires direct suppliers to certify that the materials incorporated into Vantive’s products comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.

• The Vantive Supplier Code of Conduct defines minimum ethical, legal, and human rights standards for suppliers and supports Vantive’s efforts to identify, prevent, and mitigate risks of forced labor and child labor in its supply chain.

• Employees and contractors of Vantive are expected to know, understand and live up to Vantive’s Code of Conduct. Employees have a duty to report any known or suspected violation of the code, or any laws, rules or regulations applicable to Vantive. Reporting such violations helps to safeguard the reputation and integrity of Vantive and its employees. See Vantive’s Code of Conduct for Vantive’s internal accountability standards and procedures for employees and contractors. Failure by employees or contractors to meet Vantive’s standards regarding slavery and trafficking may result in disciplinary action, up to and including termination of employment or contract. Vantive maintains procedures for investigating reported violations and tracks remediation efforts to completion.

• Vantive provides training sessions on Vantive’s Code of Conduct for new and existing employees. Additionally, Vantive has a procurement ethics course for those who have direct responsibility for supply chain management. Since 2012, this module has included material to educate procurement professionals about human rights risks, including human trafficking and slavery. Training content is reviewed and updated periodically to reflect evolving legal requirements and emerging risks. Completion of training is tracked and documented for employees with direct supply chain management responsibilities.

   

• Vantive's Ethics & Compliance Helpline, a telephone and web resource, is available to employees, their families, suppliers and customers as another channel to report or seek guidance on issues. The Ethics & Compliance Helpline has the ability to connect callers to counselors, 24 hours a day, seven days a week, in 150 languages.

This statement covers Vantive’s fiscal year 2025 and was approved by Vantive’s senior management.

Please also see Vantive's Global Human Rights Policy.