Anti-Modern Slavery Policy

Anti-Modern Slavery Policy

Introduction

This policy outlines SmartyAds' expectations and commitments regarding modern slavery and human trafficking. We have adopted this policy as the best practice to demonstrate our ethical commitment.

SmartyAds is a global digital advertising software developer that creates cutting-edge programmatic solutions for digital advertisers, publishers, ad agencies, and enterprises worldwide. By leveraging Machine Learning, AI, and other smart technologies, we are reshaping the future of programmatic advertising, making it surprisingly simple and profitable for everyone.

The Company provides a full-stack package of complex AdTech solutions, including demand side platform (DSP) services, supply side platform (SSP) services, and ad marketplace services, for digital advertisers, publishers, and ad agencies worldwide.

1. Our Commitment

SmartyAds:

• Has zero tolerance for modern slavery in any form;
• Is committed to ensuring transparency in our own business and in our approach to tackling modern slavery throughout our supply chains;
• Expects the same high standards from all contractors, suppliers, and business partners;

• Promotes ethical business practices that respect human rights and dignity.

   

2. Policy Statement

2.1 Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labor and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. SmartyAds is committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

2.2 We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we incorporate provisions requiring business partners to acknowledge and adhere to this policy and we expect that our suppliers will hold their own suppliers to the same high standards.

2.3 This policy applies to all persons providing services to us or on our behalf in any capacity, including directors, officers, agency workers, contractors, consultants, interns, agents, and business partners.
 

3. Responsibility for the Policy

3.1 The company has established clear oversight for this policy, ensuring it complies with our legal and ethical obligations. Regular monitoring of the policy's effectiveness takes place, with appropriate review of internal control systems and procedures to ensure they remain effective in countering modern slavery.

3.2 Management throughout the organization ensures that team members understand and comply with this policy and receive adequate and regular information on modern slavery issues, particularly as they might affect our supply chains.
 

4. Compliance with the Policy

4.1 Everyone providing services to us or on our behalf in any capacity SmartyAds must ensure that they read, understand, and comply with this policy.

4.2 The prevention, detection, and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

4.3 You must notify SmartyAds as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.

4.4 If you are unsure about whether a particular act, the treatment of service providers, or their operating conditions within any tier of our supply chains constitutes any form of modern slavery, raise it with the management of SmartyAds.

4.5 We encourage transparency and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our business or supply chains.
 

5. Due Diligence Processes

5.1 As part of our initiative to identify and mitigate risk, we:

• Conduct risk assessments to determine which parts of our business and which of our suppliers are most at risk of modern slavery;
• Review our supply chains regularly to evaluate modern slavery and human trafficking risks;
• Take steps to improve substandard supplier practices, including providing advice and guidance;
• Where possible, build long-term relationships with suppliers and clearly communicate our expectations of business behavior.
   

6. Training and Awareness

6.1 Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the onboarding process for all individuals who provide services for us, and regular training will be provided as necessary.
 

7. Monitoring and Review

7.1 SmartyAds will review this policy annually to ensure its effectiveness and relevance.
7.2 This policy is not part of any contract and we reserve the right to amend it at any time


This policy was approved by the SmartyAds Inc. 03/04/2025