Prohibition of Trafficking in Persons California Transparency in Supply Chains
Act of 2010 UK Modern Slavery Act of 2015 Policy
As a business we have a responsibility to be alert to the risks of modern slavery and human trafficking andto prevent Prevention of Slavery and Human Trafficking within the Workplace. however small, in ourbusiness and in the wider supply chain. Staff is expected to report concerns and management is expectedto act upon them.
We expect all who have or wish to have a business relationship with Park Place Technologies (PPT) and/or
any member of our organization, to familiarize themselves with our anti-slavery values and to always act ina way which is consistent with our anti-slavery values.
As a corporation we have a zero-tolerance approach to modern slavery. We are committed to acting
ethically and with integrity in all our business dealings and relationships. We fully expect our employees
and business associates to act in this way and to assist in the implementing and enforcement of effective
systems and controls to ensure modern slavery is not taking place in our own businesses or those of oursuppliers.
As part of our culture of good governance for good business, we operate to a set of core values that arereflected in our relationships with our customers, suppliers and team members. Our business values andrelationships reflect our attitude to the exploitation of individuals in any form, and more particularly theoffences under the Modern Slavery Act 2015.
We are committed to opposing modern slavery in all its forms and preventing it by whatever means wecan within our own business dealings. We expect and demand the same attitude of all those who work for
us and expect it of all with whom we work with.
The California Transparency in Supply Chains
Act of 2010 and the United Kingdom Modern
Slavery Act of 2015 require certain businesses
to provide disclosure concerning their efforts, ifany, to address the issues of slavery and humantrafficking in their supply chains. The
disclosures are intended to provide consumers
the ability to make better, more informed
choices about the products and services they
buy and the companies they support. In
addition, the United States Federal Government
has adopted a zero-tolerance policy regarding
trafficking in persons. As a federal contractor,
Park Place Technologies and its employees areprohibited from:••••

ETHICAL TREATMENT
Supply chain ethics are integral toPark Place Technologies. If
something does not feel right ordoes not pass the “smell test,” youshould proceed with caution. Seek
guidance from the LegalDepartment. Askquestions before you act.

Engaging in any forms of trafficking inpersons.
Procuring commercial sex acts; or using forced labor in the performance of any
contract.
Using child labor (child: anyone under the age of sixteen unless local law statesotherwise) in the performance of any contract.
Destroying, concealing, confiscating, or otherwise denying access by an1
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Prohibition of Trafficking in Persons California Transparency in Supply Chains
Act of 2010 UK Modern Slavery Act of 2015 Policy
employee to the employee's identity or immigration documents, such as
passports or drivers' licenses, regardless of issuing authority.
•Using misleading or fraudulent practices during the recruitment of employees oroffering of employment, such as failing to disclose, in a format and language
accessible to the worker, basic information or making material misrepresentations
during the recruitment of employees regarding the key terms and conditions ofemployment.

•If required by law or contract, failing to provide an employment contract, recruitment
agreement, or other required work document in writing. Such written work document
shall be in a language the employee understands.

All employees and suppliers who work or may work on service or other contracts on behalfof Park Place Technologies must comply with this policy.
Violation of this policy may subject an employee or supplierto actions that include, but are not limited to, removal from
DOES THIS IMPACT YOU?
a particular role, reduction in benefits, termination, and/or
disciplinary action in accordance with the Park PlaceTechnologies Employee Handbook or contract, asThis policy applies to Park Placeapplicable.
supply chain. From time to time,

What Are My Responsibilities?
All officers, employees, and agents of Park Place whopurchase items on behalf of Park Place, are responsible forunderstanding and complying with this Policy as it relates totheir jobs. It is the individual responsibility of each director,
officer, employee, agent, and supplier to:

•••••
•
•

Park Place uses independent
contractors or agents to conduct
specific business transactions.
This policy also applies to them.

Comply with this Policy and anti-slavery laws
and the Code of Business Ethics
Be familiar with applicable aspects of the Policy and communicate them to subordinates
Ask questions if the Policy or action required in a particular situation is unclear
Properly manage and monitor business activities conducted through third parties
Be alert to indications or evidence of possible wrongdoing
Participate in training as directed
Promptly report violations or suspected violations through appropriate channels

Training and Awareness Program•

To ensure a high level of understanding of the risks of modern slavery and humantrafficking in our supply chains and our business, we provide training to relevant membersof staff, particularly in our procurement teams.
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Document Classification: PUBLICProhibition of Trafficking in Persons California Transparency in Supply Chains
Act of 2010 UK Modern Slavery Act of 2015 Policy•All Directors and Senior Managers have been briefed on the subject and the Company's
Prohibition of Trafficking in Persons Policy has been made available to all employees on
the company’s intranet.

•Additionally, sections within our Employee Handbook have been added to cover where tofind these policies, and procedures for reporting any suspected•••In addition, the Company’s managers have a particular responsibility to:Ensure that subordinates, including agents and suppliers, receive the training needed
to understand laws and regulations governing international transactions particularly
as they relate to their assigned work
Monitor compliance with this Policy
Raise concerns regarding this Policy, the FCPA and other Anti-Corruption and AntiBribery Laws or the Company’s Code of Business Ethics, including any suspected•••

violations, to management, the Legal Department or by contacting the Park Place“Hotline”, which permits anonymous reporting.
Maintain full and accurate records with respect to transactions subject to this Policy•Terminology•Trafficking in persons includes the following:

Coercion•

Threats of serious harm to or physical restraint against any person.

•Any scheme, plan, or pattern intended to cause a person to believe that failure to perform
an act would result in serious harm to or physical restraint against any person; or•The abuse or threatened abuse of the legal process.

Commercial Sex Act•

Any sex act on account of which anything of value is given to or received by anyperson.

Debt Bondage•

The status or condition of a debtor arising from a pledge by the debtor of his or herpersonal services or of those of a person under his or her control as a security for
debt, if the value of those services as reasonably assessed is not applied toward theliquidation of the debt or the length and nature of those services are not respectively
limited and defined.

Forced Labor/Labor Trafficking•

Knowingly providing or obtaining the labor or services of a person:▪

By threats of serious harm to, or physical restraint against, that person or anotherperson.

▪

By means of any scheme, plan, or pattern intended to cause the person to believe
that, if the person did not perform such labor or services, that person or anotherperson would suffer serious harm or physical restraint.
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Prohibition of Trafficking in Persons California Transparency in Supply Chains
Act of 2010 UK Modern Slavery Act of 2015 Policy
By means of the abuse or threatened abuse of law or the legal process.

▪

Involuntary Servitude – Includes a condition of servitude induced by means of:•Any scheme, plan, or pattern intended to cause a person to believe that, if theperson did not enter into or continue in such conditions, that person or anotherperson would suffer serious harm or physical restraint.

•The abuse or threatened abuse of the legal system.

Severe forms of trafficking in persons•

Sex trafficking in which a commercial sex act is induced by force, fraud, orcoercion, or in which the person induced to perform such act has not attained 18
years of age.

•The recruitment, harboring, transportation, provision, or obtaining of a person forlabor or services, through the use of force, fraud, or coercion for the purpose ofsubjection to involuntary servitude, peonage, debt bondage, or slavery.

Sex trafficking
The recruitment, harboring, transportation, provision, or obtaining of a person for thepurpose of a commercial sex act in order to receive money, goods, or services inreturn.

What Due Diligence Is Required?
Park Place Technologies will verify the qualifications, background and references of
all the business partners, agents, representatives, suppliers, or consultants withwhich Park Place intends to engage or establish a binding business relationship. The
Legal Department and senior management shall provide guidance on the level ofdue diligence required for a particular business arrangement. All required due
diligence must be conducted prior to entering into any contractual or binding
agreement.

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Prohibition of Trafficking in Persons California Transparency in Supply Chains
Act of 2010 UK Modern Slavery Act of 2015 Policy

Pay Attention to Red Flags
Employees therefore must be alert to potential “red flags” in transactions with supply chain.
This means that you should pay particular attention to unusual or suspicious circumstancesthat may indicate possible legal or ethics concerns. These are commonly referred to as“red flags.” “Red flags” are circumstances that may
suggest refurbished parts have been procured
NO DEFENSE
unethically and the prices are low because theworkers have not been paid a minimum wage for their“Willful ignorance” is not a defense.
work. The presence of red flags in a relationship or“Willful ignorance” includes nottransaction
requiresgreaterscrutinyand
making reasonable inquiry when there
implementation of safeguards to prevent and detectare suspicious circumstances. It also
improper conduct. Ignoring these circumstances is notdoes not matter whether the agent orappropriate. If something does not seem right, youintermediary is itself subject to theshould seek further guidance from the Legal
FCPA, the UK Bribery Act or other AntiDepartment.
Corruption or Anti-Bribery Laws.
“Willful ignorance” is not a defense. “Willfulignorance” includes not making reasonableinquiry
whentherearesuspicious
circumstances. It also does not matter whether
the agent or intermediary is itself subject to theCalifornia Transparency in Supply Chains Act of2010, UK Modern Slavery Act of 2015, or otheranti-slavery laws.

What Are My Reporting Obligations?
Any employee who has reason to believe that aGeneral Counsel
violation of this Policy has occurred, or may(001)
440-947-0213
occur, must promptly report this information tohis or her supervisor, any member ofbdellinger@parkplacetech.com
management
or the Legal Department, or by
Hotlinecontacting the Park Place Technologies Hotline.
833-350-0044
Specifically, information may be reported inwww.lighthouse-services.com/parkplacetech
confidence by calling the Park Place GeneralCounsel at (001) 440-947- 0213. Retaliation in any
form against an employee who has, in good faith, reported a violation or possible violation of this Policy isstrictly prohibited. Additionally, the Park Place “Hotline” may be used for anonymous reporting. The Hotline may
be reached at 833-350-0044 or worldwide at www.lighthouse-services.com/parkplacetech
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Prohibition of Trafficking in Persons California Transparency in Supply Chains Actof 2010 UK Modern Slavery Act of 2015 Policy
Additional Relevant Policies
The organization operates the following policies that describe its approach to the identification of modern
slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:••

Hotline and Whistleblowing Policy - The organization encourages all its workers, customers andother business partners to report any concerns related to the direct activities, or the supply chainsof, the organization. This includes any circumstances that may give rise to an enhanced risk ofslavery or human trafficking. The organization has a hotline, available to all employees and posted
in all offices and on the company internal intranet, designed to make it easy for workers to makedisclosures, without fear of retaliation. Employees, customers or others who have concerns can also
contact our Legal or HR Department who will advise complainant of the relevant Company
Director/investigating Officer in line with this policy.
Employee Handbook & Code of Conduct - The Organization’s Employee Handbook and Code ofConduct makes clear to employees the actions and behavior expected of them when representing
the organization.

CORRECTIVE ACTIONS
Violations of this Policy will result incorrective action that may include, but is
not limited to, verbal or written warnings,
suspension from work, or other disciplinary
action up to and including employment
termination. Verbal or written corrective
actionisintendedto
eliminate
inappropriate workplace conduct of amore minor nature. Immediate termination
without use of progressive discipline may
be appropriate for serious incidents.

What Are the Consequences of Violations?
Violations of this Policy will result in corrective actionthat may include, but is not limited to, verbal orwritten warnings, suspension from work, or otherdisciplinary action up to and including employment
termination. Verbal or written corrective action isintended
to eliminate inappropriate workplace
conduct of a more minor nature. Immediate
termination without use of progressive discipline may
be appropriate for serious incidents.

Applicability
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes ourorganization’s Slavery and Human Trafficking Statement for the current financial year
This Policy statement is communicated to all employees. Documents are classified as Public or Private.
Public Policies are available on the Company Intranet. Private Policies can be made available to interested
parties, on request. This Policy will be reviewed for continuing suitability by Executive Leadership at least
annually.
Betsy Dellinger
Senior Vice President & General Counsel

Date: 28 Sept 2021

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