1. Purpose

Sirva, Inc. (“Sirva”) and its family of affiliated companies are committed to ensuring the highest standards of integrity by creating a culture of honest and ethical behavior, corporate compliance, and good corporate governance. Ethics & Compliance Reporting supplements Sirva’s Code of Business Conduct & Ethics and applies to all officers, directors, employees, and contractors acting on behalf of Sirva or its affiliated companies. This portal facilitates the receipt, retention, investigation, and treatment of reports of actual or suspected unethical, illegal, fraudulent, or undesirable conduct by Sirva or its directors, officers, employees, or agents. It is also the mechanism for requesting information or assistance with privacy and security questionnaires, learning and development training issues, and supplier/vendor questionnaires and compliance.

Policy Statement on Compliance Reporting

Sirva encourages prompt reporting of any suspected or known violation of law or Sirva policies, including but not limited to the following:

• Suspected or actual violations of Sirva’s Code of Business Conduct & Ethics
• Suspected or actual violations of any Sirva policy or procedure
• Questionable accounting, violations of internal accounting controls, or any other auditing or financial matter, or the reporting of fraudulent or misleading financial information
• Suspected or actual violations of the law or fraudulent activities

Anyone may report a suspected violation of compliance concern, including employees, third-party agents, contractors, suppliers, and customers. Sirva takes all reported claims seriously and will timely, and confidentially investigate each claim.

No Retaliation

Neither Sirva nor its affiliate companies will retaliate against an employee for reporting to a supervisor or manager, officer, auditor, or other authority figure as recognized by applicable law what the reporting employee believes in good faith to be a violation of the law.  Sirva and its affiliated companies will also not retaliate against a person for participating in good faith in any resulting investigation or proceeding, or for exercising his or her rights under any applicable law(s) or regulation(s) to pursue a claim or take legal action to protect the reporter’s rights.

Sirva and its affiliated companies may take disciplinary action (up to and including termination) against any employee who, in management’s assessment, has engaged in retaliatory conduct in violation of its policies.

Reporting Procedure

Associates suspecting a violation of law or Sirva policy may raise their concerns to several individuals within the Sirva family of companies, including, but not limited to:

• The associate’s supervisor or manager;
• The next level of management;
• Human Resources;
• The Sirva Compliance Manager;
• Sirva’s Legal Department;
• Sirva’s officers and directors; or
• Any other authority figure recognized by applicable law.

The Compliance Office, consisting of Sirva’s Chief Compliance Officer, the Sirva Legal Department, and the Sirva Compliance Helpline Manager, manages Sirva’s program for compliance with the law. Associates may contact the Compliance Office via Sirva’s Safecall Reporting Hotline (see below).

Personal Data

Personal data is any information or data identifying or associated with a living person.  This includes a name plus any of the following types of data.  If the below combination of data is exposed to an Unauthorized Person, then a report should be filed with Safecall.  An Unauthorized Person is someone who is not an Authorized Person.  Authorized Persons should include the data subject and Sirva personnel (Only HR for Sirva employee Personally Identifiable Information (PII) and Government and Other Restricted Client employee PII can only be shared with Sirva employees authorized for those accounts).

Acting in Good Faith

Anyone filing a written complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation.  Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.

SAFECALL – SIRVA’S ETHICS AND COMPLIANCE HOTLINE

The Reporting Hotline is available toll-free 24 hours a day, 7 days a week.

You may report violations online at www.safecall.co.uk/report or toll-free:

For a list of additional freephone numbers, visit: www.safecall.co.uk/freephone