For the Financial Year Ending 2024

This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015, and other related laws and regulations pertaining to anti-slavery and anti-human trafficking, and outlines the steps our organization, including its affiliates have taken and continues to take to ensure that slavery and human trafficking are not taking place in our business or supply chains.

Introduction

Aprimo US LLC and its affiliates, including without limitation, Aprimo Marketing Operations UK Ltd. (the “Aprimo Group”), is committed to conducting business ethically, with integrity, and in compliance with applicable laws and regulations, including those aimed at preventing modern slavery and human trafficking. We recognize our responsibility to take a robust approach to addressing these issues within our operations and supply chains.

Our Structure and Business

The Aprimo Group has staff and operates primarily in the following jurisdictions:

• United States
• United Kingdom
• European Union
• Australia
• Philippines

The Aprimo Group is a leading provider of digital asset management and marketing operations software. Our platform helps organizations manage content, streamline marketing workflows, and optimize resources across the entire content lifecycle, enabling teams to deliver consistent and personalized customer experiences at scale.

Our Supply Chains

Our supply chains consist primarily of cloud and software vendors, IT service providers, marketing and support vendors, and professional services firms. While we assess our overall risk of exposure to modern slavery and human trafficking as low due to the nature of our business, we remain vigilant, particularly where third-party labor is involved.

Policies and Governance

We maintain a zero-tolerance policy toward slavery and human trafficking. Our efforts to prevent such practices include:

• A Code of Conduct requiring employees and contractors to adhere to ethical business standards;
• Employment policies that uphold workers’ rights and ensure compliance with all applicable labor and human rights laws;
• Internal reporting mechanisms, including whistleblower protections, for raising concerns without retaliation;
• Ongoing awareness and training initiatives on responsible sourcing and human rights.

Due Diligence and Risk Assessment

We conduct risk-based due diligence on suppliers during onboarding processes. This includes evaluating whether vendors operate in high-risk regions or industries and, where necessary, requesting additional assurances regarding labor practices.

We also monitor and reassess our third-party relationships on a periodic basis and are enhancing our supplier risk framework to improve visibility into labor practices throughout our supply chain.

Training and Awareness

We provide targeted training to managerial functions to ensure awareness of modern slavery risks and encourage appropriate escalation of concerns. We are committed to expanding this training to other key business areas.

Effectiveness and Continuous Improvement

We are committed to continually reviewing and improving our practices. In the next financial year, our objectives include, without limitation, further integrating human rights due diligence into supplier risk assessments.

Approved By:

Michael W Nelson
Chief Financial Officer

On behalf of the Aprimo Group