Confluence Technologies’ Modern Slavery and Human Trafficking Statement 2020

Introduction

Confluence Technologies, Inc. (together with its subsidiaries, including the recently acquired StatPro Group of companies, “Confluence”) is a global technology solutions provider delivering innovative products to the investment management industry. We are committed to achieving and maintaining the highest standards of ethical conduct in its business practices. We also believe it to be our responsibility to encourage appropriate ethical behaviour within Confluence and its supply chains.

Confluence does not support and is not aware of any dealings with any business which is involved in modern slavery and we will not knowingly work with any party who we suspect is connected with any such conduct or behaviour. Nonetheless, we recognise the heightened risk of becoming involved with modern slavery in some of the countries where Confluence has a presence, primarily where we engage with contractors or third-party service providers.

If we become aware of a heightened risk of modern slavery with respect to our own operations, we will develop a clearly articulated action plan as to how that risk is addressed and eliminated. In all such scenarios our objective would be to have a zero tolerance of any form of modern slavery.

Organisation Structure and Supply Chains

Confluence is a global technology solutions provider delivering innovative products to the worldwide money management industry, to meet asset managers and service providers performance, reporting, analytics, risk and data needs. With the recent acquisitions of StatPro Group, Compliance Solutions Strategies, and Investment Metrics, we now service over 1000 clients in more than 40 countries, with locations across Europe, North America, South Africa, Australia and Asia.

The countries we currently operate in:

Our supply chain is predominantly with information technology (hardware and software), telecommunications and data and we undertake a rigorous approach to procurement to ensure that all suppliers are subject to robust contractual constraints which are vetted by legal counsel to ensure compliance with applicable local laws.

Training and Policies

We impose the highest professional standards on all our employees and comply with all local laws and regulations applicable to our business. Confluence’s commitment to deliver a high standard of corporate governance in a socially responsible manner is documented in our policies and procedures.

Confluence is committed to developing further robust training and policies that ensure the continual development of our working practices. These policies will be regularly reviewed and communicated to ensure that all personnel are fully aware of their obligations.

Confluence promotes an open culture. All employees and workers are encouraged to report any concerns related to the business’ activities through our organization’s whistleblowing procedure which is designed to make it easy to make disclosures, without fear of retaliation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.

Measures of success

Confluence will use the following key performance indicators to measure the effectiveness of its approach to modern slavery:

1. Annual Risk Assessment.
2. Effective deployment of training to key stakeholders.
3. We are continuing to develop due diligence procedures and on-going monitoring of key suppliers.

BOARD APPROVAL

Mark Evans, Founder and Chief Executive Officer

This Policy Statement will be reviewed and published annually.