Tilli Consolidated Anti-Slavery and Anti-Trafficking Policy

1. Purpose

This policy establishes Tilli's consolidated anti-slavery and anti-trafficking framework for global business operations and supports customer, partner, procurement, and government-contracting diligence.

2. Covered Entities

For United States operations, the relevant entity is Utilli LLC (doing business as Tilli). For India operations, the relevant entity is Tilli Software India Private Limited. Those entities are referred to in this policy individually or collectively, as applicable, as Tilli or Tilli Software.

3. Scope

This policy applies to Tilli's directors, officers, employees, temporary workers, contractors, subcontractors, consultants, recruiters, suppliers, vendors, referral partners, other business partners, and other persons or entities acting for or on behalf of Tilli. It applies across Tilli's operations globally, including corporate, engineering, sales, implementation, support, operations, partner, vendor, and procurement functions.

4. Prohibited Conduct

Tilli prohibits conduct that constitutes or supports modern slavery, trafficking in persons, forced labor, coercive labor practices, unlawful child labor, or related exploitation.

• Trafficking in persons.
• Use of forced, bonded, indentured, or involuntary labor.
• Unlawful child labor.
• Procurement of commercial sex acts in connection with business activity.
• Confiscation, destruction, concealment, or denial of access to identity or immigration documents.
• Misleading or fraudulent recruiting practices.
• Charging prohibited recruitment fees to workers.
• Threats, coercion, intimidation, abuse, retaliation, or other exploitative practices.
• Knowingly engaging suppliers, recruiters, contractors, or partners that participate in such conduct without appropriate remediation or disengagement.

5. Core Commitments

Tilli is committed to maintaining ethical employment and sourcing practices, assessing and managing slavery and trafficking risks in relevant business relationships, using due diligence and contractual controls with relevant suppliers and partners, investigating credible concerns, protecting good-faith reporters from retaliation, and reviewing and updating this policy periodically.

6. Due Diligence and Supply Chain Controls

Tilli may implement risk-based procedures such as supplier, contractor, recruiter, and partner due diligence; contract clauses requiring compliance with anti-slavery and anti-trafficking laws and this policy; review of labor and subcontracting practices; targeted assessments for higher-risk roles, geographies, or third-party relationships; and remediation plans, suspension, or termination where material concerns are identified.

7. Reporting and Non-Retaliation

Anyone covered by this policy must promptly report suspected violations, red flags, or concerns involving modern slavery, trafficking, forced labor, unlawful child labor, coercive recruiting, document confiscation, or related misconduct.

8. Investigations and Remediation

Tilli may investigate reported or observed concerns and may request information, suspend onboarding or procurement, require corrective action plans or remediation, restrict or terminate supplier or partner relationships, or escalate matters to senior management, legal counsel, customers, prime contractors, or authorities where required or appropriate.

9. Training and Awareness

Tilli may provide role-based training or awareness activities to relevant personnel, especially those involved in procurement, vendor management, recruiting, human resources, partner management, operations, and government-contracting support.

10. Compliance with Government and Legal Requirements

Tilli intends to align this policy with applicable anti-slavery, anti-trafficking, labor, procurement, and government-contracting requirements relevant to its business relationships and operating regions. Where specific customer, partner, or government requirements apply, Tilli may maintain supplemental procedures or contractual obligations.

11. Policy Review and Updates

This policy should be reviewed at least annually and may be updated more frequently to reflect changes in law, risk, operations, sourcing, or customer and government expectations.

12. Enforcement

Failure to comply with this policy may result in disciplinary action, removal from an engagement, termination of employment or contract, suspension of business activity, or termination of supplier, recruiter, or partner relationships.

13. Contact