Labor and Human Rights Policy

Last Updated and Effective Date: October 2023

This Labor and Human Rights Policy (“Policy”) is incorporated as part of the Employee Handbook. All employees (including officers and managers), agents, contractors, and vendors must follow the procedures and comply with the requirements of this Policy. This Policy formalizes DerbySoft’s commitment to preserving and promoting the fundamental rights of others as reflected in our commitment to labor and human rights. We believe that DerbySoft can promote human rights through the example of our actions and values. Our commitment to international human rights standards and local laws is rooted in our core values and reinforced through our Code of Conduct and other company policies. We support the aim of the International Labor Organization (ILO), the Universal Declaration of Human Rights (UDHR), the International Bill of Human Rights and the UN Guiding Principles on Business and Human Rights and our goal is to conform with the OECD Guidelines for Multinational Enterprises to arrive at universally accepted labor standards and endeavor to adopt associated internal policies, standards, procedures, and guidelines that are aligned with these policies.

Freely Chosen Employment

We shall, under no circumstances, make use of any form of slave, forced, bonded, indentured, or prison labor. All employees who work with DerbySoft and its suppliers and vendors must be voluntary and prohibit the use of forced labor of any kind, including restrictions on the movement of workers and their access to basic liberties. Depending on local law requirements, everybody is free to terminate their employment upon reasonable notice without penalty. We will only employ, directly or through others, such as labor agents, people who are working of their own free will.

Under no circumstances will workers be required to participate in any form of forced savings or loan program where repayment terms are indicative of debt bondage or forced labor. We regularly conduct training for our teams so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our industry.

Child Labor and Young Workers

DerbySoft will and expects our suppliers and vendors to always adhere to the legal minimum age requirements and prohibits the use of child labor in all countries in which we operate, with commitments to the principles of the United Nations Convention on the Rights of the Child and the UNICEF Children’s Rights and Business Principles. We will never employ children under the age of 16, under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is stricter. DerbySoft has a strong age-verification process during the recruitment and selection process to make sure all our employees are age-qualified. This includes, at a minimum, inspection and verification of at least two forms of identification and visual identification.

If workers between the ages of 16 and 18 are employed, we will ensure that this work does not affect or preclude their educational opportunities or obligations, nor jeopardize their health and safety, including restrictions on overtime and night work.

If an underage worker were found, DerbySoft would immediately implement a remediation program, which includes protecting the young worker from reprisal and providing the completion of the young worker’s compulsory education.

Nondiscrimination and Diversity

DerbySoft is committed to diversity in its workforce and encourages equality of opportunity and fairness. We promote diversity and inclusion within our company and business partners. We work to understand the nature of diversity, assuring the same rights are granted to all employees, that fairness follows—including pay equity, and that we pursue greater diversity and inclusion where possible. We do not tolerate any kind of harassment or discrimination based on, among other things, race, color, age, gender, sexual orientation, gender identity or gender expression, ethnicity, disability, pregnancy, religion, political affiliation, veteran status, union membership, or marital status in hiring or employment practices such as promotions, rewards, or access to training. We are committed to protecting the rights of women and minority groups and expect our suppliers and vendors to also uphold these basic human rights and beliefs. We will, and expect our suppliers and vendors will recruit, hire, and promote employees solely based on suitability for the job.

Humane Treatment

Harsh or inhumane treatment of workers, including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, or verbal abuse, is prohibited by DerbySoft employees as well as for the suppliers and vendors that we work with. Employees must be able to communicate openly with management regarding working conditions without fear of reprisal, intimidation, or harassment. Disciplinary policies and procedures in support of these requirements must be clearly defined and communicated to workers. There will be no restriction on workers’ access to basic physical comforts such as toilets, bathrooms, or medical facilities.

Wages and Benefits

DerbySoft is committed to providing a fair and living wage to all employees and expects our suppliers and vendors to also adhere to this policy. Our remuneration shall be consistent with the provisions of all applicable wage laws, including those relating to minimum wage, overtime hours, and legally mandated benefits. In compliance with local laws, workers must be compensated for overtime at pay rates greater than their regular hourly rates. Workers must be paid regularly, in full and on time, and must receive equal pay for equal work. Deductions from wages as a disciplinary measure or unauthorized deductions are not permitted. Vacation time, leave periods, and holidays are consistent with applicable laws and regulations. Workers must always be aware of the composition of pay and benefits, explaining any legitimate deductions in a detailed and clear manner prior to employment. Workers must receive clear statements in detail, in a language understood by workers.

Freedom of Association and Collective Bargaining

DerbySoft recognizes and respects the right of workers to be represented by trade unions or other employee organizations and the freedom of employees to establish or join an organization of their choice and respects. We will not make employment subject to the condition that a person must not join a union or must terminate membership in a trade union. DerbySoft will not tolerate threats, intimidation, or physical or legal attacks against human rights defenders, for both our operations and our supply chain.

Workers must be able to openly communicate and share grievances with management regarding working conditions and management practices without fear of reprisal, intimidation, harassment, or violence. More information about grievance and whistleblower policies can be found in DerbySoft’s whistleblower policy.