Modern Slavery Policy

Modern slavery is a crime and a violation of fundamental human rights. It encompasses slavery, servitude, human trafficking, and forced labor. Cardlytics has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

SCOPE OF THIS POLICY

The following policy applies to all persons working for Cardlytics or on our behalf in any capacity, including partners, employees, agency workers, volunteers, interns, contractors, external consultants, third-party representatives, and business partners.

This policy does not form part of any employee’s contract of employment and we may amend it at any time.

OUR POLICY

Cardlytics will take the following steps with respect to modern slavery:

• Conducting due diligence on all suppliers to ensure that a particular organization has never been convicted of offenses relating to modern slavery;

• Providing information to staff on the warning signs that might indicate that modern slavery is taking place;

• Promoting to staff the importance of raising immediately any concerns they may have; and

• Protecting staff who are ‘whistle blowers’ in respect of concerns they have about modern slavery.

RESPONSIBILITY FOR THIS POLICY

Our Legal and Compliance department have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

BREACHES OF THIS POLICY

Anyone who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

We may terminate our relationship with other individuals and organizations working on our behalf if they breach this policy.