PRIVACY POLICY

Privacy Policy for CommerceWorks Technology Ltd

At CommerceWorks Technology Ltd, we are committed to protecting your privacy. This Privacy Policy explains how we collect, use, and safeguard your personal information.

Information We Collect:

• Personal identification information (Name, email address, phone number, etc.)

• Usage data (IP address, browser type, etc.)

How We Use Your Information:

• To improve our website and services

• To send periodic emails regarding updates or other information

Data Protection: We implement a variety of security measures to maintain the safety of your personal information.

For more details, please contact us at info@commerceworks.net.

TERMS AND CONDITIONS

Terms and Conditions for CommerceWorks Technology Ltd

Welcome to CommerceWorks Technology Ltd. By accessing our website, you agree to comply with and be bound by the following terms and conditions.

Use of the Site:

• You agree to use the site for lawful purposes only.

• You must not misuse our site by knowingly introducing viruses or other harmful material.

Intellectual Property: All content on this site is the property of CommerceWorks Technology Ltd.

Governing Law: These terms are governed by the laws of the United Kingdom.

For more details, please contact us at info@commerceworks.net.

DISCLAIMER

Disclaimer for CommerceWorks Technology Ltd

The information provided by CommerceWorks Technology Ltd is for general informational purposes only. All information on the site is provided in good faith, however, we make no representation or warranty of any kind regarding the accuracy or completeness of any information on the site.

COOKIE POLICY

Cookie Policy for CommerceWorks Technology Ltd

CommerceWorks Technology Ltd uses cookies to enhance your experience on our website. By using our site, you consent to our use of cookies.

What Are Cookies: Cookies are small files that a site or its service provider transfers to your computer's hard drive through your web browser.

How We Use Cookies:

• To understand and save your preferences for future visits

• To compile aggregate data about site traffic and site interactions

For more details, please contact us at info@commerceworks.net.

ACCESSIBILITY STATEMENT

Accessibility Statement for CommerceWorks Technology Ltd

CommerceWorks Technology Ltd is committed to ensuring digital accessibility for people with disabilities. We are continually improving the user experience for everyone and applying the relevant accessibility standards.

Feedback: We welcome your feedback on the accessibility of our website. Please let us know if you encounter accessibility barriers by contacting us at info@commerceworks.net.

COPYRIGHT NOTICE

Copyright Notice for CommerceWorks Technology Ltd

All content included on this site, such as text, graphics, logos, images, and software, is the property of CommerceWorks Technology Ltd and protected by international copyright laws.

GLOBAL MODERN SLAVERY AND HUMAN TRAFFICKING POLICY

OUR POLICY COMMITMENT

At Commerceworks Technology Ltd, we are strongly committed to human rights and employees’ rights. We believe it is our responsibility to do our part to eradicate modern slavery and human trafficking, and we expect the same ethical conduct from all our employees and our business partners, including suppliers and contractors. This Policy establishes our baseline principles and the steps we take to help ensure modern slavery and human trafficking do not occur in our supply chain or business. It provides a framework for compliance and effective risk management under our Code of Conduct, Partner Code of Conduct, and the United Nations Declaration of Human Rights. Where an applicable law, rule, regulation, or contractual obligation requires a higher standard, we will follow the requirements of that law, rule, regulation, or contract.

WHO MUST COMPLY

This Policy applies to all Commerceworks Technology Ltd team members who work for wholly and majority-owned subsidiaries, including employees, contractors, or contingent workers of each of these entities. Subsidiaries outside of the U.K. are expected to adopt and implement this Policy or a local version of this Policy in accordance with applicable laws to bring this Policy into effect locally. The Policy Commitment, Principles, and Operating Standards also apply to our vendors and suppliers who process or otherwise handle data for or on behalf of Commerceworks Technology Ltd, and any other third parties, whom we may obligate by contract or other agreement to comply.

WHAT DO I NEED TO KNOW AND DO

The following five Principles guide the way we work to meet our Policy Commitment:

1. Modern Slavery and Human Trafficking: We do not tolerate the use of modern slavery, child labour, forced labour, or human trafficking in any form in our organization or supply chain. We support the principles established under the United Nations Declaration of Human Rights and are committed to conducting business in a way that respects the rights and the dignity of people and prevents adverse human rights impacts. We prohibit the employment of underage children or forced labour, including slave labour, prison labour, indentured servitude, or bonded labour, as well as any form of physical punishment or abuse including use of force, coercion, or other means for the purpose of exploiting them.

2. Global Supply Chain: We expect third parties throughout our supply chain to support human rights and encourage third parties to adopt standards consistent with the principles established under the United Nations Declaration of Human Rights. We clearly outline in our Partner Code of Conduct that we expect our third parties to compensate their employees in accordance with all applicable laws, not to employ underage children or forced labour or allow any form of physical punishment or abuse. Third parties must take steps to ensure that slavery and human trafficking are not taking place within their organization or organisations with which they work.

3. Third Party Screening and Monitoring: We conduct screening and due diligence on third parties, both at the time of onboarding and contract renewal, for human trafficking and modern slavery alerts and red flags. Across all levels of due diligence, the Global Third Party Engagement process will check the third party for any recorded involvement in people trafficking, human rights violations, trafficking or distribution of drugs, illegal prostitution or promotion of illegal prostitution, kidnapping, abduction, sex offenses, or abuse. The Third Party Engagement process is risk-based, and with exceptions to low risk, all third parties are obligated to commit to our Partner Code of Conduct before onboarding. High-risk third parties may be subject to additional scrutiny by our Third Party Engagement teams including but not limited to providing training and advice, onsite audits, and if necessary termination of contract.

4. Recruitment and Hiring: We have recruitment and hiring processes to safeguard against modern slavery, human trafficking, or forced labour. We have comprehensive team member recruitment and onboarding processes and procedures in place, including conducting checks on eligibility to work in a jurisdiction for all employees which safeguard against human trafficking and forced labour. Most of our colleagues are full-time, and all colleagues have employment contracts and/or other agreements in place which are regularly reviewed in line with employment law and best practices. In addition, all our employment agencies are thoroughly vetted.

YOUR RESPONSIBILITIES – ACCOUNTABILITY AND ASSURANCE

Governance: The principles set forth in this Policy are overseen by Global Compliance & Ethics and implemented through processes managed in partnership with other Legal Teams, People Team, and Global Sourcing & Procurement.

Demonstration of Accountability: At least once annually, we will review our compliance with this Policy, and we will update this Policy to reflect any changes in Commerceworks Technology Ltd practices or the obligations under applicable laws.

Workforce Competence and Accountability: Commerceworks Technology Ltd team members must ensure that they have read, understand, and comply with this Policy. Team members are accountable for avoiding unethical practices or activities that may lead to or suggest a violation of this Policy.

Speaking Up and Seeking Guidance: Prevention, detection, and reporting any violation of this Policy is the responsibility of all team members and those working for or with us. If you are unsure of what to do, take the time to seek guidance. You can ask questions, seek guidance, or raise concerns in the strictest confidence by reaching out to the following resources:

• Global Compliance Helpline: hello@commerceworks.net

• Compliance Officer Inbox: hello@commerceworks.net

Monitoring: Depending on the issues, Global Compliance & Ethics, and Internal Audit will conduct, or engage a third party to conduct, reviews of the relevant practices, systems, and records to ensure that Commerceworks Technology Ltd can demonstrate its compliance with this Policy.

Enforcement: Any employee who is found to have violated this Policy may face disciplinary action, up to and including termination of employment, in accordance with and as permitted by applicable laws. Contractors and organisations with whom Commerceworks Technology Ltd has a contractual relationship will face termination of our contractual relationship and other remedies available under the applicable contract for violations of this Policy.