April 25, 2022

To our stakeholders:

I am pleased to confirm that CarltonOne Engagement reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to share this information with our stakeholders using our primary channels of communication.

Sincerely,

Robert Purdy
Chief Executive Officer

CarltonOne Engagement is committed to diversity, inclusion and accessibility for persons with disabilities and ensuring equal access, service, and participation for people with disabilities. We are committed to treating people with disabilities in a way that allows them to maintain their dignity and independence, in accordance with Accessibility for Ontarians with Disabilities Act, 2005.

CarltonOne has adopted the following policies in accordance with the Accessibility for Ontarians with Disabilities Act, 2005.

General Principles and Practices:

1. Communication - CarltonOne Engagement is committed to communicating with persons with disabilities in ways that consider their disability.
2. Training of employees - CarltonOne Engagement will provide training to all its workers regarding the provisions and ways to ensure accessible programs, goods, services, and workplace. Training will occur on an ongoing basis and whenever changes are made to relevant policies, practices and procedures.
3. Assistive devices - CarltonOne Engagement permits persons with disabilities to use their personal assistive devices while on its premises.
4. Service animals and support persons - CarltonOne Engagement welcomes onto its premises people with disabilities and their service animals and support persons upon whom persons with disabilities rely.
5. Notice of temporary disruption - CarltonOne Engagement will give notice of temporary disruptions to services or facilities used by persons with disabilities including the reason for the disruption, the anticipation of the disruption and any alternative facilities or services that may be available. The notice shall be posted in a conspicuous place on the premises.

Assistive Devices

CarltonOne Engagement will ensure that its staff is trained and familiar with various assistive devices that may be used by customers with disabilities while accessing our goods or services. Persons with disabilities may use their own assistive devices as required when accessing goods and services at any CarltonOne Engagement location. In cases where the assistive device presents a safety concern or where accessibility might be an issue, other reasonable measures will be used to ensure the access of goods and services.

Communication

CarltonOne Engagement will communicate with people with disabilities in ways that consider their disability.
- Train employees to be aware of signs of communications problems;
- Asking the person how they would like to be communicated with;
- Communicate with person with a disability in a manner that considers his/her disability.

Training for Staff

Training will be provided to all CarltonOne Engagement employees in Ontario, those that assist in developing policies and procedures that govern the provision of goods and services to the public, and others who deal with the public or other third parties on their behalf. This training will be given to all new employees as part of their orientation. All training records will be kept in employee files.
Training will include:
- an overview of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the customer service standard;
- how to interact and communicate with people with various types of disabilities;
- how to interact with people with disabilities who use an assistive device or require the assistance of a service animal or a support person;
- what to do if a person with a disability is having difficulty in accessing CarltonOne Engagement goods and services;
Staff will also be trained when changes are made to this plan.

Recruitment and Selection

CarltonOne Engagement will notify its employees and the public, including internal and external job applicants about the availability of accommodation for applicants with disabilities in its recruitment processes. Where needed, accommodations for disabilities will be provided, on request, to support their participation in all aspects of the recruitment process.
CarltonOne Engagement will notify candidates that accommodations are available upon request in

Employment

CarltonOne Engagement will inform its employees of the policies used to support employees with disabilities. We will provide this information to new employees as a part of their orientation. All existing employees will be provided with updated information on changes in accessibility policies whenever there is a change to existing policy.

Performance Management

CarltonOne Engagement will take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when using its performance management process in respect of employees with disabilities. If employee responsibilities change as a result of performance management process, and the employee has a disability, CarltonOne Engagement will revisit the employee’s individual accommodation plan to ensure that all necessary adjustments are made.

Career Development and Advancement

CarltonOne Engagement will take into account the accessibility needs of the employees with disabilities as well as any individual accommodation plans, when providing career development and advancement to the employees who have disabilities. CarltonOne Engagement will take into account what accommodations employees with disabilities may need to succeed elsewhere in their organizations or to take on new responsibilities in their current position.

CarltonOne Engagement is committed to ensuring that its policies, practices and procedures are consistent with and promote the core principles of dignity, independence, integration and equal opportunity. Any policy that does not respect and promote the dignity and independence of persons with disabilities will be modified or removed. CarltonOne Engagement will maintain the Accessibility Plan & Policy outlining the Company’s strategy to prevent and remove barriers from its workplace and to meet its requirements under the Accessibility for Ontarians with Disabilities Act, 2005.

CarltonOne Engagement is committed to providing a collegial working environment in which all people are treated with respect and dignity. Each person has the right to work in a professional atmosphere that promotes equal opportunities and prohibits discriminatory practices. CarltonOne Engagement has a zero tolerance policy with respect to harassment, discrimination, violence and bullying as defined by the Ontario Human Rights Code.

Workplace harassment, discrimination, bullying and violence is offensive, degrading and threatening. CarltonOne Engagement will not tolerate workplace harassment, discrimination or violence. CarltonOne Engagement encourages the reporting of all incidents of workplace harassment, discrimination or violence regardless of who the offender may be. A person, regardless of seniority or position, found to have engaged in conduct constituting workplace harassment, discrimination, bullying or violence may be disciplined up to and including dismissal. Management who know or should have known of workplace discrimination or harassment and fail to report such behavior, or fail to take immediate and appropriate corrective action, will be subject to corrective action up to and including dismissal.

CarltonOne Engagement will do its best to preserve and protect the anonymity and confidentiality of those involved in alleged breaches of this policy. However, it may not be possible to preserve confidentiality or anonymity of those involved as it may be necessary for CarltonOne Engagement to take action, including consultation with others. In such cases, information will be shared on a strict need to know basis only.

CarltonOne has implemented the following complaint policy for any individual who believes they are being discriminated against, bullied, or harassed:

Allegations of harassment, violence, bullying or discrimination will be promptly and thoroughly investigated and corrective action, up to and including termination, will be taken, as appropriate. The investigation will be conducted in a confidential manner to the extent possible given the facts of each case.

No employee will be penalized, reprimanded or otherwise retaliated against for reporting harassment or discrimination, for filing a complaint under this policy or for providing information or otherwise participating in a complaint investigation. Any employee that feels that they have been retaliated against under this policy should contact their manager/Director/Vice-President if appropriate, Human Resources Consultant or Chief Executive Officer immediately.
In all cases where a manager is notified or becomes aware of a matter that may constitute discrimination or harassment, the Human Resources Consultant or Chief Executive Officer must be notified immediately.

A. Informal Complaint Procedure

Any individual who believes he or she is being discriminated against, bullied or harassed is expected to:

1. Approach the individual personally or in writing, (if the person who is feeling discriminated against or harassed feels comfortable), informing him or her that the behaviour is unwelcome and must stop. In many cases, the person may be unaware that the behaviour is unwelcome and an informal discussion will resolve the problem. AND/OR,

2. Seek consultation from his or her direct manager if approaching the person seems either inappropriate or embarrassing. If the manager is the alleged harasser or for some reason the person (complainant) does not wish to discuss the problem with his or her manager, he or she should seek consultation from any other management staff or the Human Resources Consultant. The manager or HR Consultant will provide coaching as to options available to resolve the concern and will provide assistance to the employee to take appropriate action, as required.

Written documentation of the incident(s) and the attempted resolution process should be dated and signed and kept by both the person alleging the harassment and the management staff involved. This information will be maintained in confidence, except where disclosure is necessary for further investigation of the complaint or for taking appropriate corrective action.

B. Formal Complaint Procedure

1. In serious cases of alleged harassment/discrimination, or if the attempted resolution is not satisfactory through the informal complaint stage, or in the event the behaviour continues despite the informal resolution process, a formal complaint may be lodged by the person being subjected to the harassment or discrimination. A formal complaint will be made in writing and given to the complainant’s direct manager, Human Resources Consultant or Chief Executive Officer.

2. After any formal complaint is received, it will be shared with the Human Resources Consultant who is responsible to lead the investigation of the complaint. Should the Human Resources Consultant be the alleged harasser, the Chief Executive Officer is responsible to ensure a thorough investigation is conducted. Should the Chief Executive Officer be the alleged harasser, the Board Chair will be responsible for the investigation. Investigations will be thorough and prompt. Information gathered will include the date, time and location of the incident(s) and a description of the incident(s). The investigation will include an interview with the complainant, the alleged harasser and any other persons who may provide pertinent information.

Information will be documented and will be maintained in confidence, except where disclosure is necessary for investigating the complaint or taking appropriate corrective action. Information will only be shared on a clear need to know basis.

3. In some cases, the services of an independent outside investigator will be used. The decision to do so will rest with the Chief Executive Officer, in consultation with the Human Resources Consultant.

Where harassment or discrimination occurs, appropriate corrective measures will be taken, up to and including dismissal.

Nothing in this policy prevents or discourages an individual from filing an application with the Human Rights Tribunal of Ontario on a matter related to Ontario’s Human Rights Code or to exercise any other legal avenues that may be available.

CarltonOne has launched a diversity committee to both represent and educate all employees about diversity and inclusion within CarltonOne. In addition, all employees are required to read and acknowledge the company's policies in relation to anti-discriminatory behaviour.

At CarltonOne we've adopted an overarching initiative company-wide to fund climate change eco-action. With every transaction on our network, we plant a tree in return. Our products can fund the planting of hundreds of millions of trees, removing billions of pounds of CO2 from the atmosphere. We can support ecosystem conservation and species protection. We weigh the ecological responsibility of our international scope, and have intentionally structured our solutions to minimize the carbon footprint of our operations. This is both climate-positive and our competitive advantage. We procure and fulfill locally in every possible market, reducing shipping costs, delivery times and CO2 emissions.

However, reducing carbon emissions is not enough. Increasing carbon sequestration, or removing greenhouse gas from the atmosphere, is critical to stabilizing rising temperatures. And while the science of climate change is complex, the solution is remarkably simple. One effective way to reduce greenhouse gas is to plant more trees. Trees and mangroves naturally absorb and store dangerous carbon. While one mature tree can remove up to 48 lbs. of carbon every year, mangroves can remove up to 4 times more.

We have designed a unique business model that converts member actions on our platforms directly into climate change funding. It’s being applied now across all our products, across all our markets. Our goal is to plant 100 million trees every year by the end of 2023

We have engaged with Eden Reforestation Projects as our first tree planting partner. Founded in 2004, Eden Reforestation Projects is recognized as one of the most cost-effective reforestation partners on the planet. When we plant trees, we’re also growing communities. Eden Reforestation Projects targets high-priority sites suffering from deforestation and severe poverty.

Our direct funding is being used to plant in Madagascar, Nepal, Kenya, Mozambique and Indonesia. Our results in these regions so far is:

Madagascar - 3,660,051 trees planted, 106 planters employed
Mozambique - 879,441 trees planted, 84 working days/month funded
Nepal - 350,000 trees planted
Indonesia - 366,000 mangrove trees planted, 32 planters employed
Kenya - 367,000 trees planted, 84 planters employed

In total, to date we've funded the planting of 11,454,245 trees.

In addition to our tree funding commitment, we’ve also implemented our other sustainability initiatives:

- We have made a major 5-year commitment to The Sierra Club, to protect the summer whale calving waters in the Gulf of St. Lawrence
- Our corporate offices have a zero-waste, zero-paper, zero-plastic policy, and we have reduced paper-based incoming mail by 75% by switching to email invoicing and direct deposits
- Even pre-pandemic, we restricted corporate travel and encouraged commute-free remote work

With our partnership with Eden Reforestation, we are in constant contact and provided with updates on the impacts of our funding in both the actual number of trees planted, along with the socio-economic impact in localized communities of our contributions. Bi-annually audits of the results of our funding are provided to senior management, and we engage in constant reviews to increase the effectiveness of our funding, and how we can maximize that funding to allow for the planting of even more trees on a yearly basis. Our target in 2022 was planting 50 million trees a year, and we've increased that target to 100 million trees a year in 2023.

To combat a rise in global money laundering and terrorism financing, banks require every business owner creating a prepaid rewards program to verify their identity. This enhanced mandatory policy, backed by counter-terrorism financing laws in North America and Europe, requires Know Your Business (“KYB”) and Universal Beneficial Ownership (“UBO”) documentation to be completed by the Program Sponsor, before any bank will issue prepaid cards. Since part of CarltonOne's solutions offering is prepaid rewards cards, we have adopted these measures as part of our anti-corruption efforts.

As part of CarltonOne' anti-corruption initiatives we have implemented KYB and UBO standards with our business partners. This includes providing the following information that our clients must provide in order to be approved by our banking partners and for CarltonOne to issue prepaid reward cards as part of our solution offering:

• Business Information (name, address, contact information)
• Company Registration # or Tax ID (e.g. TIN, VAT, EIN)
• Stock Ticker (if company is publicly traded)
• Names and titles of all business executives: All officers/Signers of Corporation, CEO, CFO, COO, VP, MD and/or equivalent
• Company Ownership Details – name, address and birth date for any person or entity who owns 25% or more of a privately held company. This is required for all businesses listed as “Private”. If a company is publicly traded, a Controlling Officer may be designated for whom personal identifying details may be required to authenticate the request
• Direct contact details for a Controlling Officer/Program Administrator/Project Stakeholder of the reward program operated by the company
• Sales forecasts for the prepaid products being issued
• Program/recipient information (e.g. first order date, location of recipients, etc.)
• Program marketing information

Failure to provide this information will result in applications being rejected by our financial institution partners.

All suspected incidents of corruption are investigated by CarltonOne's procurement team, as well as periodical audits of any suspicious activities that may indicate corruptive practices. As we have adopted KYB and UBO standards and policies, we make any and all attempts to prevent corruption before we engage in any business practises with our clients and partners.