Modern Slavery Act Statement

Made pursuant to Section 54, Part 6 of the UK Modern Slavery Act (2015) and the Australian Modern Slavery Act 2018 (Cth).

Zimperium, Inc. and its subsidiaries (collectively, “Zimperium”) are committed to maximizing the positive effect we have on society and to minimizing negative impacts. As part of this commitment, we strive to continually improve our practices to combat slavery and human trafficking. We are committed to respecting human rights and recognize that human rights are essential to achieving sustainable development globally.

The organizational structure of Zimperium comprises Zimperium, Inc. and its subsidiaries located in various jurisdictions. This joint statement and the measures described herein are applicable to Zimperium and its affiliated entities because all entities operate in the same sector, use the same policies and processes, and have many shared suppliers. Refer to the Appendix herein for a list Zimperium’s subsidiaries.

Zimperium is controlled by a Board of Directors. Zimperium’s Main Offices are located in Dallas (US) and Riga (LV). Zimperium operates in these jurisdictions and conducts business in other countries around the world via subsidiaries, re-sellers, managed service providers, and other partners.

Zimperium is a leading provider of mobile security platforms for enterprise environments providing on-device, machine learning-powered mobile threat defenses.

Definitions

Zimperium defines modern slavery as encompassing:

Human trafficking.
Forced work, through mental or physical threat.
Being owned or controlled by an employer through mental or physical abuse or the threat of abuse.
Being dehumanized, treated as a commodity, or being bought or sold as property.
Being physically constrained having restrictions placed on freedom of movement.

Commitment

Zimperium acknowledges its responsibilities under the Modern Slavery legislation referenced herein and is committed to preventing slavery and human trafficking within its own businesses and in its supply chains. Zimperium understands that this requires an ongoing review of both its internal practices in relation to its labor force and its supply chains.

Zimperium has a zero-tolerance policy towards modern slavery and is committed to acting ethically and with integrity in all our business dealings and relationships. We will refrain from doing business, and/or will discontinue any current business with any other organization which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labor.

The labor supplied to Zimperium in pursuance of the services it provides is carried out in the countries where those services are provided as appropriate. No labor provided to Zimperium in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. Zimperium strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation, and in many cases exceeds applicable minimums in relation to its employees.

Zimperium employees are offered industry/market-based compensation packages. Zimperium maintains an anonymous Compliance Hotline to provide employees with the ability to raise concerns relating to their employment, the company, and its practices as appropriate. Zimperium encourages employees to expressing themselves both directly and anonymously via the Compliance Hotline relative to their employment and working conditions.

Zimperium has implemented and enforces systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our distribution channels. The Board of Directors and senior leadership are accountable for the governance and oversight of modern slavery risks. Zimperium’s Chief Compliance Officer and their associated team is responsible for day-to-day activities and due diligence.

Measures

Zimperium regularly assesses risks in relation to modern slavery and human trafficking within our business and supply chain. We consider these risks to be low, particularly because of the sector (SaaS security software) in which we operate, the limited nature of our supply chains (mainly distribution channels), and the values and policies that guide the actions of our directors, officers, employees, and contractors.

Zimperium’s workforce is primarily made up of full-time employees and contingent employees/contractors. All employees and contractors are subjected to background checks and must complete regular training. Zimperium sources services and goods from reputable suppliers. The nature of our business results in our typically not requiring the types of goods and services likely to require labor subject to the risks of slavery and human trafficking. Zimperium understands that growth entails risks and management teams analyze these risks before expanding into new markets or undertaking to employ additional individuals or vendors.

1. Code of Business Ethics

To help avoid the risks in relation to modern slavery, Zimperium enforces a Code of Business Ethics. This code is applicable to all employees and defines and promotes the principles by which we run our business. Among other requirements, the code sets forth our commitments to respect, fairness, integrity, compliance, ensuring our business is conducted free from any human trafficking, confidentiality, anticorruption, honest accounting, responsibility, and clear reporting requirements.

2. Vendor Relationships

Zimperium requires that all vendors to the company enter arrangements with the company subject to executed legal terms and conditions. Prior to becoming a vendor, potential vendors are assessed by our procurement team and screened against relevant sanctions and denied parties lists which includes screens against human trafficking. Zimperium does not enter contracts with organizations under sanctions imposed by the United States, United Kingdom, UN, or the European Union, etc.

3. Training and Employee Resources

Zimperium conducts Code of Conduct and other training promulgated by our Human Resources team for all employees upon hiring and requires ongoing training. We track compliance with our training regimen using third-party software tools. Employees who fail to comply with training requirements are subject to employee discipline. Zimperium encourages the use of its Compliance Hotline (displayed prominently on the Zimperium webpage) by employees, vendors, suppliers, and third parties to report any concerns regarding modern slavery. Zimperium’s management takes all reports seriously and we investigate complaints thoroughly.

4. Compliance and Review

Zimperium’s Chief Compliance Officer regularly reviews vendors deemed to present higher risks to the company to assess their compliance with this Modern Slavery Statement. Our compliance team reviews internal policies and procedures annually to ensure their alignment with this statement.

Assessment of Effectiveness

To ensure effectiveness in combatting modern slavery, Zimperium maintains an up-to-date compilation of vendor and supplier contracts. We ensure action is taken to respond rapidly and thoroughly to reports of modern slavery in our company and/or supply chain. Complaints or reports made to our Compliance Hotline are responded to in accordance with this policy.

In the previous fiscal year Zimperium has not received any reports or complaints regarding being involved in activities covered by the Modern Slavery Act.

Reports of potential violations of the Modern Slavery Acts of the UK and Australia are reviewed by our HR and Legal Departments to ensure that appropriate measures are taken, including termination of business relationships and appropriate reporting in accordance with legal requirements.

This statement was reviewed and approved by legal and compliance personnel at Zimperium and has been signed by our CEO who is also a member of our Board of Directors.