Introduction

Flashpoint is committed to upholding human rights and preventing modern slavery in all its forms. This statement outlines our commitment to ensuring that modern slavery and human trafficking do not occur within our organization and sets out the steps we take to assess and mitigate the risk of modern slavery within our business and supply chains.

Our Business and Structure

EJ2 Communications, Inc. d/b/a Flashpoint (“Flashpoint”) is a Delaware Corporation with subsidiaries in Canada and the UK.

Flashpoint is the pioneering leader in threat data and intelligence. We empower commercial enterprises and government agencies to decisively confront complex security challenges, reduce risk, and improve operational resilience amid fast-evolving threats.

Among other territories, we operate in the UK, United States, and Canada, primarily offering software-as-a-service (SaaS) solutions.

As a SaaS company, Flashpoint employees and contractors are usually highly skilled professionals who have signed written employment agreements subject to local legislation and protected rights. Additionally, such engagements are overseen by experienced human resources professionals. Therefore, given the above, as well as Flashpoint’s structured and centralized hiring processes and human resources and procurement aspects, the risk of modern slavery in this regard is low.

Our Supply Chains

As a technology company with a predominantly digital business model, our supply chain is primarily focused on technology development and professional services. While our direct reliance on physical goods is limited, we recognize the potential for modern slavery risks to exist within our extended supply chain. We rely on our suppliers to self-audit or monitor their supply chains. We may terminate our relationship with individuals or organizations who work on our behalf if we suspect breaches of the Act or other relevant anti-slavery and human trafficking legislation or of this policy.

Our Policies

We are committed to ethical business practices and have implemented policies to mitigate the risk of modern slavery and human trafficking, including:

• Code of Conduct: Our Code of Conduct outlines the company’s expectation that employees operate ethically, fairly, and with integrity. This Code of Conduct also requires employees to report any misconduct, policy violation, or area of concern and provides a process for doing so. Flashpoint has a zero-tolerance approach to modern slavery and is committed to acting ethically and in accordance with our values.
• Human Resources Policies: Our HR policies ensure fair recruitment practices, competitive wages, and a safe and inclusive working environment for all employees.

Flashpoint encourages reporting of any concerns related to modern slavery; all concerns are thoroughly investigated.

Our Commitment

Flashpoint is dedicated to continuous improvement in our efforts to combat modern slavery. Flashpoint has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity. We will continue to review and enhance our policies and procedures to ensure they remain effective in identifying and mitigating risks.

This statement is made in accordance with Section 54 of the Modern Slavery Act 2015, the Fighting Against Forced Labour and Child Labour in Supply Chains Act, and constitutes Flashpoint’s modern slavery and human trafficking statement for the current financial year.

November, 2024