HUMAN Modern Slavery Act Transparency Statement

Updated: August 23, 2024

INTRODUCTION

This statement for fiscal year ending December 31, 2023 is submitted on behalf of Human Security, Inc.’s wholly owned subsidiary in the United Kingdom, Human Security UK, Ltd., and its wholly owned subsidiary in Canada, Human Security Canada, Inc. Human Security, Inc. is a Delaware, USA corporation. Human Security, Inc. and its subsidiaries are collectively referred to herein as “HUMAN”.

ZERO TOLERANCE

HUMAN has a zero-tolerance approach to any form of modern slavery in its business and supply chains. Modern slavery encompasses slavery, servitude, human trafficking and forced labor. We are committed to acting ethically and with integrity and transparency in all our business dealings. HUMAN fully supports the elimination of human trafficking, modern slavery, or any other forced or child labor from the global supply chain. HUMAN makes this statement to support and comply with Section 54 of the United Kingdom’s Modern Slavery Act of 2015, Section 6(2) of Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act of 2023, and the California Transparency in Supply Chains Act of 2010.

OUR STRUCTURE & BUSINESS

HUMAN is a wholly owned indirect subsidiary of Singularity TopCo LLC, a Delaware, USA limited liability company. HUMAN has wholly owned subsidiaries in the US, UK, Canada, and Israel.

HUMAN is a cybersecurity company that offers a platform to protect organizations, including media platforms and enterprises, by disrupting bot attacks, digital fraud and abuse. Whether it's stealing sensitive data, breaking into online accounts, purchasing limited-availability goods and resources, engaging in fraudulent financial transactions, manipulating popularity and sentiment, or conducting malvertising and programmatic ad fraud — cybercriminals can take many different paths to commit fraud online. The Human Defense Platform detects, disrupts, and eliminates fraud with unmatched scale, speed, and decision precision–ensuring a secure and trustworthy environment for our customers and their customers. HUMAN develops and sells cybersecurity software and related professional services to companies worldwide.

OUR SUPPLY CHAIN

HUMAN employs a technically skilled, professional, global labor force. Our workers are voluntary, at-will employees or independent contractors, who receive competitive compensation and benefits.

HUMAN’s global supply chain consists of engaging professional services, computing services, retail and promotional items, office supplies, marketing services and event planning, and the leasing of physical facilities such as office space or temporary coworking spaces. The majority of HUMAN’s vendors, suppliers and partners are based in the United States, Europe and Israel.

HUMAN is committed to respecting universal human rights to ensure that our business plays a proactive and positive role in the global community. HUMAN expects all employees, consultants, contractors, agents, representatives, and officers (collectively, “Personnel”) and each of our partners, resellers, vendors, and other suppliers (collectively, “Partners”) to share this commitment to putting humans first. We expect that our Personnel and Partners comply with all applicable laws, and to the fullest extent possible, require that Partners make such a representation in our contractual agreements.

HUMAN VALUES

HUMAN’s company culture is defined by our core values, including:

  • Put Humans First;
  • Be A Hacker;
  • Win As A Team;
  • Create Tau;
  • Own It; and
  • Be Good.

HUMAN’s core values were in place and promoted with our organization throughout the financial year ending December 31, 2023. In accordance with these values, HUMAN aims to ensure that it hires, works and collaborates with Personnel and Partners who hold the highest standards of ethics and integrity and promote a culture of compliance.

POLICIES

HUMAN has a comprehensive Purchasing Policy in place to regulate how we deal with our global suppliers in a well-managed, fair and ethical manner. HUMAN also has a Third Party Risk Management Policy to mitigate risk when procuring new products and services. Our procurement process also provides for an organized tracking system of vendors and periodic audits of vendor and procurement procedures to ensure compliance.

As a practice, notwithstanding any local laws permitting employment at a lower age, HUMAN does not hire employees below the age of 18.

Looking forward, HUMAN will codify its opposition to modern slavery and human trafficking in our global employee handbook and will develop a supplier code of conduct. These will provide for incident reporting and reflect our commitment to acting ethically and with integrity in all our business relationships. We will continue to implement and enforce effective systems and controls to eliminate, as far as possible, the risk of modern slavery and human trafficking taking place anywhere in our business or supply chains.

RISK ASSESSMENT AND GOVERNANCE

In light of our business and supply chain in the cybersecurity industry, HUMAN poses a low risk of facilitating modern slavery in its present operations. HUMAN is aware of no actual or alleged Docusign Envelope ID: E494F8A7-C650-454F-9907-73E67D4BBE53 modern slavery, human trafficking, or other forced or child labor in its business or supply chain and has received no reports of potential modern slavery or human trafficking occurring.

To ensure that HUMAN is successful in implementing its ethical approach, HUMAN’s General Counsel and Legal Team presently oversee relevant compliance responsibilities, which include:

  • Conducting risk assessments
  • Investigating possible violations of policy and ethical practices
  • Coordinating with internal departments to update policies as needed; and
  • Otherwise promoting an atmosphere of integrity and a culture of compliance.

HUMAN will continue cross-functional collaboration within its business to diligence, assess and monitor supply chain risk and identify opportunities to iterate on and improve its efforts to mitigate unethical practices, including modern slavery, human trafficking, and other forced or child labor.

LOOKING AHEAD

HUMAN remains committed to improving our efforts to address modern slavery risks. HUMAN will consider what actions it can take in the following year to mitigate such risks in our global business and supply chains.

APPROVAL OF THIS STATEMENT

This statement was reviewed by relevant internal teams and reviewed and approved by the Board of Directors for Singularity TopCo LLC, a Delaware limited liability company and the ultimate parent of HUMAN.

Modern-Slavery-Act-Transparency-Statement_Stu-Signature

Name: Stuart Solomon

Title: Director