CallTower Inc. –

Modern Slavery Policy

Background

This Modern Slavery Code of Conduct (the “Code”) applies to CallTower Inc.’s (“CallTower”) employees, contractors and suppliers. It sets out the minimum standards that CallTower expects from these individuals and organizations with respect to the protection of human rights and fair and ethical work practices. CallTower understands that it has a responsibility to conduct its business ethically, and this extends to its employees, contractors and suppliers.

CallTower expects its employees, contractors and suppliers to share its commitment to respecting the rights of all workers and to act lawfully and ethically in all areas of business.

It is a condition of all supply and vendor contracts entered into with CallTower that the principles set out in this Code are adhered to.

All CallTower employees and independent contractors are required to read and acknowledge this Code, and to undertake training relating to it as made available by CallTower from time to time.

Minimum Standards

This Code establishes minimum standards that CallTower expect its contractors and suppliers (“Vendors”) to meet or exceed. These standards do not intend to deviate from national or local laws or standards. Failure to meet these standards may be cause for termination of any agreement entered into with CallTower.

All Vendors must maintain awareness of, and comply with, applicable laws and regulations in the jurisdictions in which they do business.

Child Labor

CallTower is opposed to the use of any form of child labor or practices. No person under the age of 15 (or under 14 where permitted by local law) may be employed, and workers under the age of 18 may not perform work that is likely to jeopardize their health and safety. Vendors are required to comply with applicable child labor laws and employ only workers who meet the applicable minimum legal age requirement in their countries of operation.

Forced or Involuntary Labor & Trafficking

CallTower’s Vendors must not participate, engage or promote forced, bonded, indentured or involuntary prison labor of people in any part of their business.

CallTower’s Vendors must not participate, engage or promote the trafficking of any person.

All slavery and human trafficking laws must be complied with. Vendors must ensure they have taken steps to ensure their business operations are free from slavery and human trafficking practices, both internally and within their supply chains and other external business relationships.

Vendors must ensure that all workers employed by them choose their employment freely and are not mentally or physically coerced to provide their labor.

Vendors must not contract with subcontractors or suppliers using or engaging in modern slavery or trafficking.

Compliance and Reporting

Vendors must take all reasonable steps to ensure that slavery and human trafficking is not taking place within their supply chain or within any part of their business. Vendors must adhere to this Code along with all applicable national and local laws.

Where applicable, Vendors must be able to certify that materials included in their products comply with all requisite slavery and human trafficking laws. CallTower may at any time request a Vendor to supply a report setting out the steps they have taken to ensure compliance with the requirements of this Code.

Employees and Vendors have a duty to immediately report to CallTower any breach of, or deviation from, this Code. Reports should be made to legal@calltower.comcreate new email. Vendors must provide reasonable assistance to any investigation by CallTower of a violation of this Code.

CallTower does not tolerate acts of retaliation against any individual who makes a good faith report of known or suspected violations of this Code.

If a Vendor breaches this Code, CallTower reserves the right to request from such Vendor a corrective action plan, setting out the steps that the Vendor will undertake to rectify the breach. Should the corrective action plan not rectify the breach, or should CallTower determine that the breach is not capable of being rectified, CallTower reserves the right to terminate any contractual relationship that exists.