Policy Statement

This document sets forth the policy of code9technologand is designed to provide reasonable assurance that (I) a consistent process is followed with respect to the dissemination of commercial electronic messages code9technologand prospective clients in Canada, and (ii)code9technolog sending commercial electronic messages from and/or to a computer system(s) in Canada comply with the requirements of CASL.

The code9technolog Anti-Spam Policy (“Anti-Spam Policy”) and related procedures (the “CASL Procedures”) require that all code9technolog sending CEMs from and/or to a computer system(s) in Canada or to an electronic address that will be accessed from a computer system in Canada comply with CASL, and seeks to ensure that all CEMs sent by or on behalf of  code9technolog,or using a code9technolog email address or using a device owned or provided by code9technolog, comply with CASL.

Policy Details

The Anti-Spam Policy describes code9technolog commitments relating to the provisions of CASL and electronic messages of a commercial nature sent code9technolog, prospective clients, and others, as applicable. From time to time, code9technolog may implement additional policies, procedures and/or practices as it relates to anti-spam measures. 

Application

This Policy applies code9technologwho may be sending CEMs from and/or to a computer system(s) in Canada or to an electronic address that will be accessed from a computer system in Canada.

With respect to code9technolog operations, the Anti-Spam Policy has been adopted in compliance with the requirements of CASL, and code9technologis committed to complying with CASL. All other code9technolog and procedures will be interpreted in a manner that is consistent with the Anti-Spam Policy and that promotes compliance with CASL to seek to deter damaging and deceptive forms of spam from occurring in Canada.

Consent

code9technolog obtains express, opt-in consent, unless a verifiable basis for implied consent or an exception to consent exists, before sending a CEM to anyone who has not had an existing business relationship with code9technolog within two years before the date on which the CEM is sent. Unless a valid documented basis for implied consent or an exception to consent exists, code9technolog also obtains express, opt-in consent for the sending of CEMs to code9technolog prospects.

The request for consent cannot be in an electronic message unless there exists a basis for implied consent to send the message. The request for consent must be sought separately within a communication (e.g. through a separate action such as affirmatively checking a checkbox) and cannot be bundled as a term of acceptance of an agreement. A verbal consent is acceptable where a record of the details of the consent is maintained in a database.

Form and Content of CEMs

All CEMs are required to comply with the form and content requirements of CASL, generally described as follows:

• identifies the sender;
• the sender’s mailing address;
• the sender’s telephone number or email address or link to a webpage; and
• an unsubscribe mechanism or withdrawal of consent from receiving CEMs from code9technologand its subsidiaries

code9technolog takes steps to require that any third-party service provider who sends CEMs on behalf of code9technologcomplies with CASL.

Storage of Relationship Details

A key component of complying with CASL involves maintaining records of code9technolog relationships with clients and prospective clients.

Each business unit of code9technologrequired to create and maintain in the business unit’s Client Relationship Management (CRM) system (including, but not limited to, Benchmark, Salesforce), verifiable records documenting the relationships giving rise to implied consent, and verifiable records of express, opt-in consents obtained from code9technologand prospective clients. “Clients” are defined as those organizations or individuals who have at least one open account or a contractual relationship with code9technolog Sat the relevant time. Organizations or individuals who have closed their last remaining account or terminated their contract with code9technolog are not considered code9technolog for purposes of this Policy.

Implied consent or express, opt-in consent is obtained in accordance with the CASL Procedures and recorded in the applicable CRM system in order to track the client and prospect relationships.

Records of express, opt-in consent and records documenting the relationships giving rise to implied consent are retained for a minimum of three years after ceases sending CEMs to the code9technolog client or prospect.

Commercial Electronic Messages

All code9technologsending CEMs from and/or to a computer system(s) in Canada are required to comply with this Policy and related CASL procedures and processes.

A “CEM” is defined as an electronic message that includes content (for instance, text, hyperlinks, images or attachments) that:

1. promotes, offers or advertises code9technologor code9technologproducts or services, or employees, or contacts;
2. solicits business for code9technolog employees or contacts; and
3. any other similar message that encourages participation in commercial

Examples include promotional event invitations (e.g., webcasts or code9technolog events), marketing newsletters, etc.

The following messages do not have to comply with the requirements applicable to CEMs:

• messages sent code9technologabout their business;
• internal communications aboutcode9technolog business (including communications with code9technolog offices outside Canada);
• legally required notices, such as messages that are sent to comply with a regulatory requirement (e.g., material changes, required account activity information, etc.); and
• responses to requests, inquiries or

Messages that code9technologemail each other internally using a device that code9technolog owns or provides, or using ancode9technologemail address, should be related to. code9technolog may not internally email each other offers, promotions, advertisements, or referrals unrelated to code9technolog business without the internal recipient’s verbal consent.

Compliance by Third Parties

All third-party contracts with service providers who may send CEMs on behalf of code9technologmust contain contractual clauses obligating the service provider to comply with CASL including the form and content requirements of CEMs.

Unsubscribe Mechanism

CEMs that are not exempt from requirements applicable to CEMs noted above are required to include a form of unsubscribe mechanism to facilitate the withdrawal of consent or do-not-contact requests within a period of time and in a manner that would allow code9technologto process that request within 10 days of the date on which the unsubscribe, withdrawal of consent or do-not-contact request was made. This information should be maintained in the applicable database that tracks the client and prospect relationships.

All emails sent by code9technolog. employees will be compliant with CASL and will include the option to ‘unsubscribe.’

You can ‘unsubscribe’ from our Commercial Electronic Messages at any time by visiting https://code9technolog.com/unsubscribe or by emailing do www.code9technolog.com with ‘Unsubscribe’ in the subject line.

Policy Administration

The Anti-Spam Policy is maintained by the Compliance department of each Expertly legal entity and will be reviewed and updated, where necessary, and approved on an annual basis. Any changes to, or exceptions from this Policy require the approval of the respective Expertly Board or equivalent.

Review and Approvals

Expertly Compliance is responsible for review and revision of this Policy, subject to approval of the respective Expertly Board or equivalent. This Policy is subject to review on an annual basis, or otherwise as needed.

Enforcement and Audit

Compliance with this Policy, and any related procedure, may be reviewed by Expertly at any time. Failure to comply with this Policy, as well as any associated procedures, may result in disciplinary action in accordance with the applicable Global Human Resources Disciplinary policy or procedure.