GLOBAL PRIVACY STATEMENT

Effective January 1, 2023

This Privacy Statement applies to West Technology Group and its affiliates (“West” “we” “us” “our”) unless the affiliate has a separately posted privacy statement. West values the privacy of our customers, users, and any individual who accesses or uses the West websites, products, and services (collectively, the “Services”). Your privacy is an important factor West considers in the development of each of our products and services. This Privacy Statement explains generally how we receive Personal Information about you, and what we do with that Personal Information once we have it.

As West is a global provider, the provision of the Services to users may require Personal Information to be shared with other West companies around the world. All West companies are bound by privacy statements, confidentiality and data transfer agreements as appropriate.

• What do we mean by “Personal Information”?
• What type of Personal Information is collected?
• How do we receive Personal Information about you?
• What do we do with your Personal Information once we have it?
• How long will we retain Personal Information?
• When do we share your Personal Information with others?
• How do we protect your Personal Information?
• How can you protect your Personal Information?
• How do you handle Information subject to the California Consumer Privacy Act?
• How do you keep my healthcare information private?
• What about cookies and other tracking technology?
• How do you handle my “Do Not Track” browser settings?
• Does West use any other tracking technology?
• How does West ensure compliance with legal obligations?
• Data Analytics
• China Users
• What choices do you have regarding your Personal Information?
• What if we change this Privacy Statement?
• How to Contact Us?

What do we mean by “Personal Information”?

For us, “Personal Information” means information or data that relates to an identified or identifiable individual. “Sensitive Personal Information” is a subset of Personal Information and is data about children, financial information, health information (including PHI as defined by the Health Insurance Portability and Accountability Act), Social Security or other national identification number, racial or ethnic origin, political opinions, religious beliefs, trade union membership, sex life, criminal convictions, and precise geolocation data.

We also want you to be aware certain information related to your account may be Customer Proprietary Network Information (“CPNI”). CPNI is information we obtain solely by providing telecommunications services or interconnected Voice over Internet Protocol (VoIP) services to you. It includes the type, technical arrangement, quantity, destination, location, and amount of services you purchased and related billing information. CPNI does not include your telephone number, name and address, or aggregate customer information or data not specific to you. The protection of your information is important to us, and you have a right, and we have a duty, under U.S federal law, to protect the confidentiality of your CPNI. We may use or disclose CPNI without your consent to (a) initiate, render, repair, maintain, bill, troubleshoot, and collect for our services; (b) protect our rights and property or to protect our subscribers or other carriers from the unlawful or fraudulent use of our services; (c) provide call location information required in connection with emergency services; (d) market services formerly known as adjunct-to-basic services; (e) market our services within the categories of services to which you already subscribe; and, (f) respond to a valid request from law enforcement, a court order, or other appropriate authority. Absent your consent, we will not access, use or disclose your CPNI to market categories of telecommunications or VoIP products and services that you do not already subscribe to or share your CPNI with unrelated third parties for their own use.

What type of Personal Information is collected?

We may collect data, including Personal Information, about you as you use our websites, services and interact with us. This information may include name, address, email address, IP address, phone number, login information (user name, password), marketing preferences, or payment card number. If we link other data with your Personal Information, we will treat that linked data as Personal Information. We also collect Personal Information from trusted third-party sources and engage third parties to collect Personal Information to assist us.

Please understand, in addition to collecting Personal Information, West may also gather information that does not personally identify you regarding your use of the West website (“Anonymous Information”). We may use the Anonymous Information we collect regarding your use of this website to measure the effectiveness of our marketing efforts, for improving the Services we offer to you, or to improve the West website. Generally, you will not be aware when we collect such Anonymous Information. It may be collected in various ways, such as through traffic data or direct surveys of our customers and may entail the use of, among other things, cookies, IP addresses, or other numeric codes used to identify the computer or other device used to access the West website.

How do we receive Personal Information about you?

We learn Personal Information about you when:

• you give it to us directly (e.g., when you choose to contact us, or register on the West website);
• we collect it automatically through our products and services (e.g., your use of West services);
• someone else tells us Personal Information about you (e.g., our client provides us your Personal Information in order for us to perform services for them); or
• when we try to understand more about you based on Personal Information you’ve given to us (e.g., when we use your IP address to customize language for some of our services).

If you are under 18, we don’t collect your Personal Information, and you should not provide it to us. By providing your Personal Information, you opt-in and consent to its collection, use, disclosure, sharing, and transfer as described in this Privacy Statement.

What do we do with your Personal Information once we have it?

West does NOT sell your personal information.

When you give us Personal Information, we will use it in the ways for which you’ve given us permission, or ways in which our clients who provided us the Personal Information instruct. Generally, we use your Personal Information to help us provide and improve our products and services for you and our clients with which you have a business relationship. We may also use the Personal Information you provide to contact you regarding additional or new services and features offered by West, or important information regarding West.

We may use the Personal Information to enforce our agreements with you, prevent fraud and other prohibited or illegal activities, for other legally permissible purposes and generally to ensure that we comply with applicable laws and prevent or detect use or abuse of our services.

Important Notice Regarding Unified Communications Services, Webcasting, and Virtual Event Services

West processes Personal Information as part of delivering the above noted services on behalf of its customers. The customer is the data controller of the information. For these services, West only collects Personal Information necessary to fulfill our contractual obligations with the customer. We may collect contact data such as name, e-mail address and company details you provide us during the registration process and during your use of the services. We may also collect product usage data, such as the date on which you viewed a webcast, the duration of your viewing and the part of the webcast you viewed.

West may also use your Personal Information to create anonymous data records or aggregations of data, to perform statistical analyses and for other purposes, by omitting or removing information that makes the data personally identifiable to you.

If you have provided Personal Information to our customer, their respective privacy statement will also apply to the processing of your data. You should familiarize yourself with their statement.

How long will we retain Personal Information?

We will retain your Personal Information only as long as needed to fulfill the purposes for which it was collected or as required by law. Your information will be deleted, anonymized or pseudonymized once it is no longer needed to comply with our business requirements, legal obligations, resolve disputes, protect our assets, or enforce our agreements.

When do we share your Personal Information with others?

We will/may share your Personal Information with others:

• When we have asked and received your permission to share it.
• When we’re required to provide it to our client from whom we received your Personal Information, or with whom you have a business relationship.
• For processing or providing products and services to you, but only if those entities receiving your Personal Information are contractually obligated to handle the data in ways approved by West. We may use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development).
• To provide aggregate Personal Information to our business partners to make our products and services better, but when we do so, we will de-identify your Personal Information and try to disclose it in a way that minimizes the risk of you being re-identified.
• To provide your Personal Information to business partners in case you purchase services of third parties from West (“Third Party Services”). Third Party Services are not directly controlled operated or maintained by West and West’s Privacy Statement does not apply to such Third Party Services. For any Third Party Services you purchase from West, we recommend you consult the respective privacy statements of the Third Party Services providers to determine how they will handle your Personal Information.
• To follow the law whenever we receive requests about you from a government entity, or related to a lawsuit. We’ll notify you or our client from whom we received your Personal Information when we’re asked to hand over your Personal Information in this way unless we’re legally prohibited from doing so. When we receive requests like this, we’ll only release your Personal Information if we have a good faith belief the law requires us to do so. Nothing in this Statement is intended to limit any legal defenses or objections you may have to a third party’s request to disclose your Personal Information.
• If we have a good faith belief it is reasonably necessary to protect the rights, property or safety of you, our other users, West or the public.
• If our organizational structure or status changes (e.g., if we undergo a restructuring, are acquired, or go bankrupt), we may pass your Personal Information to a successor or affiliate.

How do we protect your Personal Information?

We are committed to protecting your Personal Information once we have it. We implement industry standard physical, administrative and technical security measures. If, despite these efforts, we learn of a security breach involving your Personal Information, when required by law or contractual obligations, we’ll notify you or our client so appropriate protective steps can be taken. West is not responsible for unauthorized access to such Personal Information by hackers or others that obtain access through illegal measures in the absence of negligence on the part of West.

You may have access to other sites through the West websites. These sites may have different security practices and you should familiarize yourself with those practices.

How can you protect your Personal Information?

Electronic communication (e.g., email, online chat or instant messaging, etc.) you send to us may not be secure unless we advise you in advance security measures will be in place prior to you transmitting the information. For this reason, we ask you do not send Personal Information such as financial information, social security numbers or passwords to us through unsecured electronic communication. Users should also take care with how they handle and disclose their Personal Information. Please refer to the Federal Trade Commission’s Web site at http://www.ftc.gov/bcp/menus/consumer/data.shtm for information about how to protect yourself against identity theft.

The West website may contain hyperlinks that can take you to websites run by third parties (“Third-Party Websites”). Any hypertext or other links to Third-Party Websites from the West website are provided solely as a convenience to you. If you use these links, you will leave the West website. West has not reviewed all of these Third-Party Websites and does not control and is not responsible for any of these websites or their content or practices. Thus, West does not endorse or make any representations about them, or any information, software, or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the Third-Party Websites linked to the West website, you do this entirely at your own risk. Remember, this Privacy Statement only applies to West. When you are no longer on an West website, you may encounter different privacy and security practices and you should familiarize yourself with those practices each time you visit a new website.

Please be aware any information you choose to share on any publicly available portion of the Services or with third parties, including without limitation your personal page, chat messages, forum posts, blogs, resumes, job applications, business cards, or any other information you provide may be collected and used by third parties or other attendees without restriction.

How do you handle information subject to the California Consumer Privacy Act?

West complies with all applicable privacy laws including the California Consumer Privacy Act (CCPA). We may collect data, including Personal Information, about you as you use our websites, services and interact with us. This information may include name, address, email address, IP address, phone number, login information (user name, password), marketing preferences, or payment card number. If we link other data with your Personal Information, we will treat that linked data as Personal Information. We also collect Personal Information from trusted third-party sources and engage third parties to collect Personal Information to assist us. This information will only be used to provide services or information which you have requested. West does not sell your Personal Information.

We will retain your Personal Information only as long as needed to fulfill the purposes for which it was collected or as required by law. Your information will be deleted, anonymized or pseudonymized once it is no longer needed to comply with our business requirements, legal obligations, resolve disputes, protect our assets, or enforce our agreements.

Please see Cookies section below to understand how we use cookies.

West will not discriminate in any way against you for exercising any of your rights under the CCPA or any other applicable privacy law. This includes, but is not limited to denying goods or services, change in pricing, or lower quality goods or services. Please see “What choices do you have regarding your personal information?” and “How to Contact Us” sections below for how to exercise your rights under the CCPA and other applicable privacy laws.

How do you keep my healthcare information private?

West is required by law to maintain the privacy of “protected health information.” Please follow this link to West’s HIPAA Privacy Notice.

What about cookies and other tracking technology?

A cookie is a small file, typically of letters and numbers, downloaded onto a device when the user accesses certain websites. Cookies can make the web more useful by storing information about your preferences for a particular website or a service. Cookies in and of themselves do not personally identify users, although they do identify a user’s computer.

Cookies are typically classified as either session Cookies or persistent Cookies depending on whether they expire at the end of a browser session (from when a user opens the browser window to when they exit the browser) or they can be stored for longer.

• Session Cookies – allow websites to link the actions of a user during a browser session. They may be used for a variety of purposes such as remembering what a user has put in their shopping basket as they browse around a site. They could also be used for security when a user is accessing internet banking or to facilitate use of webmail. These session Cookies expire after a browser session, so would not be stored longer term. For this reason, session Cookies may sometimes be considered less privacy intrusive than persistent Cookies.
• Persistent Cookies – are stored on a user’s device in between browser sessions which allows the preferences or actions of the user across a site (or in some cases across different websites) to be remembered. Persistent Cookies may be used for a variety of purposes including remembering users’ preferences and choices when using a site or to target advertising.

West uses cookies or other similar tracking technologies to provide you with better Services.

Most browsers are initially set to accept Cookies. You may configure your browser to accept all Cookies, reject all Cookies, or notify you when a Cookie is set. You can manage your own Cookies preferences by using your browser settings: each browser is different, so check the “Help” menu of your browser to learn how to change your Cookie preferences or delete them. If you prefer, you can set your browser to refuse Cookies. You block Cookies by activating the setting on your browser which allows you to refuse the setting of all or some Cookies.

Please note you may browse some West websites without accepting Cookies from West; however, you may not be able to take full advantage of the functionality of the website or the Services if you do so. Other Services, particularly those which require a login and password, require Cookies and cannot be used when you have disabled Cookies in your browser. For more general information, you can visit www.allaboutcookies.org.

How do you handle my “Do Not Track” browser settings?

West does not track the non-West website activity of any internet user with Do Not Track browser settings engaged.

Does West use any other tracking technology?

West employs a software technology called transparent images to help us better manage content on our site by informing us what content is effective. We use extremely small, transparent images with a unique identifier, similar in function to cookies, used to track the online movements of Web users. The main difference between the two is transparent images are invisible on the page and are very small, about the size of the period at the end of this sentence. In some instances, transparent images are tied to users’ personally identifiable information. In particular, we use transparent images in our HTML-based e-mails to let us know which e-mails have been opened by the recipients. This allows us to gauge the effectiveness of certain communications. Users may opt out of these e-mails by replying to the unsubscribe link at the end of the e-mail message.

How does West ensure compliance with legal obligations?

In connection with the Services, and if applicable, you and West shall at all times ensure compliance with any privacy and data protection laws including those in the United States (including but not limited to the Gramm-Leach-Bliley Financial Services Modernization Act, the Health Insurance Portability and Accountability Act, California Consumer Privacy Act and the Fair Credit Reporting Act), in the United Kingdom (including but not limited to the Data Protection Act), in the European Union (including but not limited to relevant EU member state legislation and the General Data Protection Regulation), in the Asia-Pacific Economic Cooperation (including but not limited to Australia’s Privacy Act along with the Australian Privacy Principles, Singapore’s Personal Data Protection Act, Japan’s Act on the Protection of Personal Information and Hong Kong’s Personal Data (Privacy) Ordinance) and anywhere around the world.

We’re a global organization and our information systems are in several countries around the world. We also use service providers whose information systems may also be in various countries. This means your Personal Information might end up in one of those information systems in another country, and that country may have a different level of data protection regulation than yours. The whole or any part of your Personal Information in connection to the Services may be processed by West, its affiliates and subcontractors in the United States, United Kingdom, the European Union, Philippines, India, Canada, Mexico and the rest of the world, and may be transferred outside the country in which you provided the Personal Information. By giving us Personal Information, West may conduct such transfers of your Personal Information. West uses Standard Contractual Clauses approved by the European Commission as an international data transfer mechanism. No matter what country your Personal Information is in, we comply with applicable law and will also abide by the commitments we make in this Privacy Statement.

Data Analytics

We provide business to business communication technology services and may use your Personal Information in order to enhance and deliver data analytics, which include transforming, examining, cleansing and modelling data in order to support decision making, determining useful information and informing conclusions. Specifically, data analytics are intended to include the following data sharing and recommendations across our various lines of business:

• Expand contact information;
• Aggregation of data to identify trends and benchmarks;
• Connect attendees and enhance profiles;
• Provide people and content recommendations;
• Drive recruitment to virtual and hybrid events;
• Help to understand usage, adoption and engagement;
• Increase and demonstrate return on investment of customer investments;
• Assess the physical component of hybrid events; and
• Give insight to customer analytics to develop new customers and expand existing customer relationships.

We make no representations or warranties on the accuracy and serviceability of your data in connection with data analytics. Data created or existing from data analytics is intended for your use only. Data may not be resold, reused or shared with third parties without prior written consent by West. For the avoidance of doubt, by signing up to use our Services, you have freely and voluntarily given informed, explicit and unambiguous permission for West to process your Personal Information, including your users’ Personal Information, for data analytics. You also acknowledge that providing this permission is not a condition of receiving West’s Services. You further understand that you have the right to withdraw this permission at any time by providing written notice to West.

China Users

If you use our services in the People’s Republic of China, your personal data is collected, processed and/or stored by West, its affiliates and their third party suppliers in the People’s Republic of China, the United States of America and other locations in the rest of the world. By using the services in the People’s Republic of China, you hereby consent that (a) your personal data may be transferred outside of the People’s Republic of China to the locations noted herein and (b) West and its affiliates and their third party suppliers may collect, process and or/store your personal data in order to provision the services.

What choices do you have regarding your Personal Information?

We are aware you have several rights in respect to how we process your Personal Information, which include but are not limited to, a right to access your Personal Information, be forgotten, restrict and/or object to processing in some circumstances and request your Personal Information be transferred to you or your nominated third party.

You may choose not to have your information disclosed to a third party (unless West is legally required to share it). You may also choose to not have your information used for a purpose materially different than the purpose for which it was originally collected or subsequently authorized by you.

We will take reasonable steps to give you the opportunity to correct inaccuracies in the Personal Information we retain concerning you and delete Personal Information concerning you upon your request, unless the burden or expense of providing access would be disproportionate to the risks to your privacy or where the rights of persons other than you would be violated. We may deny a request to delete your data if we have legal obligations to retain it. Any such data will be subject to our standard retention guidelines.

You are entitled to know whether we hold personal data about you and, if we do, to have access to that personal data and require it to be corrected if it is inaccurate. In some circumstances, you may have the right to oppose the use or disclosure of your data or have your data deleted. You can do this by contacting us as directed in the “Contact Us” section below.

To correct inaccuracies in your Personal Information, limit purpose of use and disclosure, delete your Personal Information, or for any other requests or questions, please contact us as directed in the “Contact Us” section below. Once we have verified your identity, we will complete the request from you or an authorized agent you have designated. We will make all efforts to verify your identity using information we already have but may need to request additional data if we are unable to make the verification on this data alone. If you designate an agent to make requests for you, we reserve the right to ask for proof of the agency.

West will not discriminate against any individual for exercising their privacy rights outlined above. This includes, but is not limited to; denying goods or services, change in pricing or lower quality goods or services.

What if we change this Privacy Statement?

We may need to change this Statement and our notices. Unless otherwise required, the updates will be posted online. If the changes are substantive, unless otherwise required, we will announce the update through West’s websites. Unless further steps are necessary related to the changes, your continued use of the product or service after the effective date of such changes constitutes your acceptance of such changes. To make your review more convenient, we will post an effective date at the top of the page.

How to Contact Us?

If you want to make a correction to your Personal Information, or you have any questions about our privacy statement, please contact the privacy team by emailing privacy@west.com or by mail at:

US
West
Privacy and Legal Department
PO Box 541178
Omaha, NE 68154

EUROPEAN UNION – GDPR
West
Legal Department
4 Rue Charras
Paris 75009
France

AMENDED AND RESTATED CODE OF ETHICAL BUSINESS CONDUCT

Effective January 1, 2023

This Code of Ethical Business Conduct ("Code") is intended as an overview of West's guiding principles and not as a restatement of West's policies and procedures. West's reputation as an ethical company is essential to our success. Our reputation needs to be managed and developed with the same care we extend to our clients. In carrying out the business of West, we deal with investors, clients, vendors, government officials, community leaders, the press and the general public. It is essential all of our dealings be legal and above reproach, and must not, in any way, compromise West's interests, its policies or its reputation for the highest standards of business ethics. We believe West directors, officers and employees should disclose any activity that may have the appearance of being unethical. In so doing, not only can we take appropriate disciplinary or legal action, but we may be able to take steps to prevent the situation that gives rise to the questioned activity. Merely operating within the law is just the beginning of the ethical conduct we expect and insist upon. This Code is a broad statement of West's expectations regarding legal and ethical conduct. This statement is intended to be interpreted in the spirit of its intent and not literally, as it is virtually impossible to address every situation or condition that may arise. In the event of any conflict between the Code and the certificate of incorporation or bylaws of the Company, including, without limitation, provisions related to business opportunities presented to members of the Board of Directors, the provisions set forth in the certificate of incorporation or bylaws, as applicable, shall control.

Business Conduct:

Each director and officer should be aware of the ethical practices of each of the people he or she manages. We must maintain an attitude within West unethical actions or the appearance of unethical actions are not acceptable, even though they may seem to be standard business practices in other companies. This Code cannot and is not intended to cover every applicable law or provide answers to all questions that might arise; for that we must rely on each person's good sense of what is right, including a sense of when it is proper to seek guidance from others on the appropriate course of conduct.

Conflict of Interest:

All directors, officers and employees of West are expected to avoid any activity, investment, interest or association which interferes with or is reasonably likely to interfere with the independent exercise of his or her judgment when it is related to West's interests. Directors, officers and employees of West have a duty of loyalty to West and must, therefore, avoid any actual or apparent conflict of interest with West.

It is impossible to cover every possible conflict of interest. At times it will not be easy to distinguish between proper and improper activity. The most common conflicts are:

• Having a financial interest, directly or indirectly, in any supplier, client or competitor of West. All interests of 1% or greater in a supplier, client or competitor should be fully disclosed to West’s General Counsel.
• Engaging in a business transaction on behalf of West with a relative by blood or marriage, or with a firm where such relative is an officer or representative, without prior full disclosure and written clearance.
• Accepting any money, gifts of other than nominal value, unusual hospitality, loans or any other preferential treatment from any supplier, client or competitor of West.

In short, we cannot be influenced by improper personal considerations which might consciously or unconsciously affect our judgment regarding the best interests of West. If a director, officer or employee becomes aware of an actual or apparent conflict of interest, he or she should discuss it with the appropriate manager and disclose it to West's General Counsel.

Corporate Opportunities:

No director, officer or employee of West may:

• Take for himself or herself personally any business opportunity discovered through the use of West's property, information or position;
• Use West's property, information or position for personal gain;
• Use confidential or non-public information of any of West’s clients for personal gain; or
• Compete with West.

Employees, officers and directors owe a duty to West to advance its legitimate interests when the opportunity to do so arises.

Information About Competitors:

As a business that competes in the marketplace, we seek economic knowledge about our competitors. However, West officers, directors and/or employees shall not engage in illegal or improper acts to acquire a competitor's trade secrets or customer lists. In addition, we will not hire a competitor's employees for the purpose of obtaining confidential information about the competitor.

Confidentiality:

All directors, officers and employees should maintain the confidentiality of information entrusted to them by West, its business partners, suppliers, clients or others related to West's business. Such information must not be disclosed to others, except when disclosure is authorized by West or legally mandated. Confidential information includes all nonpublic information that might be of use to competitors, or harmful to West or its clients if disclosed. Employees should not disclose confidential information of third parties. For example, you should not disclose a former employer’s confidential information to anyone, including other West employees.

Dealing with Suppliers and Clients:

West's overall view regarding its relations with suppliers and clients is simple. They must be treated as West expects to be treated - with fairness.

West strives to ensure it does not have or contribute to adverse human rights impacts (including modern slavery or human trafficking) within its business or through its supply chains. There is an ongoing commitment to engage only those suppliers that uphold the same principles as West. In the event suppliers fail to take steps to cease or prevent adverse human rights impacts, West will reconsider its business relationships with those suppliers.

Contributions to Political Parties, Candidates or Government Officials:

West's policy is precise and specific. Contributions by a corporation to political parties or candidates involving federal offices in the United States are expressly forbidden by Federal law. West obeys the law. In addition, while political contributions to parties or candidates may be legal in some states and in some foreign countries, no West corporate funds may be used for such purposes without the express prior approval of West’s General Counsel. West is an active participant in the democratic process at the national, state and local levels within the parameters of the law. West also encourages all employees to participate in our political system by voting, speaking out on public issues, and becoming active in civic and political activities. It is important, however, directors, officers and employees clearly distinguish their personal views from those of West, unless specifically authorized by West to speak on West's behalf.

Payments to Government Personnel:

The U.S. Foreign Corrupt Practices Act prohibits giving anything of value, directly or indirectly, to officials of foreign governments or foreign political candidates in order to obtain or retain business. It is strictly prohibited to make illegal payments to government officials of any country.

In addition, the U.S. government has a number of laws and regulations regarding business gratuities which may be accepted by U.S. government personnel. The promise, offer or delivery to an official or employee of the U.S. government of a gift, favor or other gratuity in violation of these rules would not only violate Company policy but could also be a criminal offense. State and local governments, as well as foreign governments, may have similar rules.

Accuracy of West's Records: All official records showing the conduct of West's business must be accurate and complete in all material respects. All those involved in the preparation of such materials should consider the accuracy of the records of critical importance and should understand West does not maintain any off-the-books funds for any purposes. It is West’s policy to fully and fairly disclose its financial condition in compliance with applicable accounting principles, laws, rules and regulations.

West keeps all books and records to fully and fairly reflect all West transactions in accordance with generally accepted accounting principles. There must be full, fair, accurate, timely and understandable disclosure in reports and documents filed with the Securities and Exchange Commission and in other public communications made by West.

Retention of Records: Disposal or destruction of West records and files should comply with company policy. In addition, when litigation or a government investigation is pending or imminent, relevant records must not knowingly be destroyed until the matter is closed. Insider Information:

Federal law and the Securities and Exchange Commission's regulations prohibit the use of "inside" (i.e., material nonpublic) information when trading in West's securities. The Insider Trading and Securities Fraud Enforcement Act of 1988 imposes significant criminal and civil penalties for insider trading.

Examples of such information include possible acquisitions, mergers, stock splits, dividends, earnings, new contracts, new products or discoveries, major management changes, expansion plans, data which may be proprietary, or data which has not yet been disclosed to the investment public and other important corporate developments. As a result of these regulations, West personnel should follow the West Insider Trading Policy located on West's intranet.

Dealings with Clients:

West's business is built upon the principle of effective, courteous management of client contacts. West treats all clients and their consumers with dignity and respect.

Equal Opportunity:

West's people have been, and will continue to be, the key to our success. West strongly supports and recognizes its responsibility to provide equal employment opportunities to all qualified individuals. West places a high value on diversity. West strongly believes that all people are unique, valuable, and should be respected for their individual abilities. In support of this goal, West has established a company policy regarding discrimination or harassment on the basis of race, gender, age, color, religion, disability status, veteran status, sexual orientation, marital status or ethnic, national or any other characteristic protected by law. This policy applies to all personnel relationships, including but not limited to: promotions, transfers, training, job assignments, job stations, hours of work, rates of pay, working conditions, terminations, and all terms and conditions of employment.

Legal Conduct and Compliance with this Code: West's policy is that all of its directors, officers and employees shall conduct business on behalf of West in full compliance with the laws of the many jurisdictions in which West may conduct business. Accordingly, the provisions of the present Code are not intended as a substitute for applicable national laws and regulations and the scope of the Code’s application shall be limited to the extent incompatible with such laws and regulations. Under the laws of certain countries in which the Company has a presence, legal conduct and compliance with this Code may require further adaptations and directors, officers and employees should refer to the appropriate country annex that addresses such matters.

Any director, officer or employee who acquires knowledge of a violation of a law or this Code, or has cause to believe that a law or this Code has been violated, must immediately report this situation to the General Counsel, the Chief Executive Officer, the Chief Financial Officer or outside legal counsel for West. If you wish to remain anonymous, you may report a violation of this Code by calling the Telephone Hotline at 855-900-0042. The Telephone Hotline is answered by an independent company and is available 24 hours a day every day. You may also report a violation by email to west@getintouch.com or online at www.lighthouse-services.com/west. No director, officer or employee who reports such a situation, in good faith, shall be penalized for his or her reporting of any violation or suspected violation of a law or this Code. To the fullest extent possible, the identity of a person making a report will be kept confidential. If an West person believes that he or she is being treated unfairly because of reporting a violation or potential violation, this should be brought to the immediate attention of the General Counsel or a Vice President of Employee Relations of West.

Any employee who ignores or violates any of West's ethical standards, and any manager who penalizes a subordinate for trying to follow these ethical standards, will be subject to corrective action. However, it is not the threat of discipline that should govern your actions. West expects you to share its belief that a dedicated commitment to ethical behavior is the right thing to do and is good business.

Violations of this Code will result in disciplinary action that may include termination, referral for criminal prosecution and reimbursement to West for any losses or damages resulting from the violation. As with all matters involving investigations of violations and discipline, principles of fairness and dignity will be applied pursuant to the procedures developed and used by West's Employee Relations Department.

Waivers:

Any waivers of this Code for directors or executive officers must be approved by the Board of Directors of West and must be promptly disclosed in a Form 8-K within five business days with reasons for the waiver.

Foreign Hotline Numbers:

English-speaking USA and Canada: 855-900-0042
Spanish-speaking USA and Canada: 800-216-1288
Spanish-speaking Mexico: 01-800-681-5340
French-speaking Canada: 855-725-0002
Australia: 1-800-983-589
China: 400-120-3529
France: +33-975182340
Germany: +49-32211001267
India: 000-800-100-4371
Lithuania: +370-52141268
Mexico: 01-800-681-8161
Philippines: 1-800-1-322-0224
Singapore: +65-31581730
United Kingdom: 0-808-189-3366

MODERN SLAVERY STATEMENT

Effective January 1, 2023

The purpose of this Modern Slavery Statement (the “Statement”) is to ensure that West Technology Group, LLC and its affiliates (“West”) are compliant with the principles of the Modern Slavery Act 2015 (the “Act”), including laws against human trafficking in the UK and other jurisdictions where West operates. This Statement sets out West’s commitment to eradicating any form of modern slavery and human trafficking from its business operations and from any form of its business conduct.

It is West’s policy to comply fully with the Act. West does not tolerate modern slavery and/or human trafficking in any form and any such act is strictly prohibited within its business and its supply chain. To that end, West collaborates with partners and suppliers who are committed to similar principles.

West Employees

West recognises the importance of the duty to respect human rights for its employees. It strives to be in compliance with and adheres to the internationally recognised principles of human rights and the applicable national labour and employment laws. The Company has a zero-tolerance approach to modern slavery and human trafficking. The Company is committed to acting lawfully and in compliance with the principles of International Labour Organization (ILO), rights of individuals as recognised by the International Bill of Human Rights (IBHR), and other recognised international principles prohibiting human trafficking and slavery.

West is highly committed to treating all its employees with dignity and respect and explicitly prohibits human trafficking and the use of involuntary labour. In order to meet this commitment, amongst other things, West ensures all work is voluntary, never withholds workers’ original government-issued ID or travel documentation and ensures that forced labour conditions are not entertained or supported within its business.

Supply Chain

West is committed to ensuring that there is no modern slavery or human trafficking in its supply chain. Its Code of Ethical Business Conduct reflects this commitment to act ethically, lawfully and with integrity in all of its business relationships. West is committed to the implementation and enforcement of stringent contractual controls to ensure modern slavery and human trafficking is not taking place anywhere within West’s supply chain.

In addition, West expects the same high standards from all its contractors, suppliers and other business partners. West includes specific provisions in its contracts that require compliance with all applicable laws and regulations by its contractors, suppliers and business partners. Additionally, West expects that its contractors, suppliers and business partners will hold their own contractors, suppliers and business partners to the same high standards as followed by West itself to ensure that no form of modern slavery or human trafficking exists within the respective supply chains. West believes that with such a progressive and firm approach towards modern slavery and human trafficking, it will increase its positive impact in this sphere.

Training

West appreciates and acknowledges the importance of enabling employees across the organisation to understand and respect the principles, objectives and implications of non-compliance with West’s Code of Ethical Business Conduct, which specifically addresses human trafficking. This commitment is reflected in the internal training programme that every West employee is required to complete on an annual basis which includes a presentation on the principles of the Act to ensure all employees are fully aware of the compliance requirement with the principles set out therein.

The Modern Slavery statement published above has been approved by the Executive Management team of West and signed in accordance with the guidelines set out in the Act. West recognises that modern slavery and human trafficking are significant global issues and, as such, its Board of Directors will review and, as necessary, update it annually.

ARTIFICIAL INTELLIGENCE (AI) POLICY

West is committed to advancing Artificial Intelligence (AI) technologies responsibly, ethically, transparently and in compliance with applicable laws. Our AI policy outlines the principles and guidelines that govern the development and use of AI in our organization and our client facing products. We are committed to upholding the highest privacy and security standards and promoting the responsible use of AI technologies in accordance with our Privacy Policy (www.west.com/legal-privacy).

Principles

Human-Centered Approach: We prioritize the security and privacy of individuals affected by our AI systems. We strive to enhance human capabilities, augment human decision-making and protect the fundamental rights of all individuals.

Transparency: We are committed to being transparent about how AI systems are developed, used and the data the AI systems rely on. We provide clear explanations of AI-driven decisions whenever possible.

Fairness and Bias Mitigation: We actively work to identify and mitigate biases in AI systems to ensure fairness and equal treatment for all individuals, regardless of race, gender, ethnicity or other protected characteristics.

Accountability: We hold ourselves accountable for the ethical implications of our AI technologies. We establish clear lines of responsibility for the development, deployment and outcomes of AI systems.

Privacy: We respect individuals' privacy rights and ensure the protection of sensitive information. Data collection, storage and processing is done in compliance with relevant laws and regulations. More information on our privacy processes can be found on the Privacy page of our website (www.west.com/legal-privacy).

Security: West is committed to protecting its customers, partners and employees from unauthorized access to, alteration, disclosure, or destruction of data and information systems whether intentional or unintentional. West's commitment to security is further exemplified by our third-party assessment of our security controls and SOC2 compliance.

Collaboration: We actively engage with the wider AI community, experts, policymakers and stakeholders to address ethical challenges collectively and share best practices. We support open and constructive dialogues that promote responsible AI development.

Auditability: We maintain detailed records on system development and performance to enable internal and external auditing as appropriate.

Lawful and Ethical: West's AI systems and data practices are compliant with applicable laws and in line with ethical norms for research and innovation.

Responsible AI Development

Data Quality: We use high-quality, diverse and representative data to train AI models, minimizing the risk of biased outcomes.

Explainability: We strive to make our AI systems interpretable and understandable to users, enabling them to comprehend how AI-derived decisions are made, whenever possible.

Human Oversight: We maintain human oversight in the development and deployment of AI systems, ensuring that decisions with significant consequences are not made solely by machines.

Continuous Monitoring: We continuously monitor AI systems to identify and address any unintended consequences or biases that may arise during their use.

Continuous Education: We invest in the continuous education and training of our teams on AI ethics and responsible AI practices.

Compliance and Review

Compliance: We comply with all relevant laws and regulations related to AI development and usage and actively engage with relevant organizations contributing to emerging AI industry standards.

Reporting and Whistleblower Protection: We encourage employees to report any ethical concerns related to AI development or deployment. We provide mechanisms for reporting, protect whistleblowers and take appropriate action in response to these concerns (via email at west@getintouch.com).

Regular Review: This AI policy may be reviewed and updated regularly to ensure its relevance and effectiveness. This policy may evolve as AI technology and ethical considerations advance. We are committed to remaining at the forefront of responsible AI practices.

Conclusion

By adhering to these principles and guidelines, West is committed to ensuring that AI technologies are developed and used ethically, fostering trust among our customers, employees and the industry as a whole.