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99 Degrees Declaration on Modern Slavery and Human Trafficking

  1. Introduction

At 99 Degrees, based in Mexico City, a company dedicated to digital and traditional marketing, creative campaigns and software development, we reaffirm our commitment to operate with integrity, respect for human rights and freedom from any form of labor exploitation, servitude, human trafficking or forced labor. This document presents the actions we have taken to prevent modern slavery in our activities, in our value chain and in our business processes.

  1. Risk assessment

We recognize that the risks of labor exploitation, forced labor, debt bondage or human trafficking may occur, including in service sectors or in the supply chain of suppliers. In accordance with the provisions of the General Law to Prevent, Punish and Eradicate Crimes of Human Trafficking and for the Protection and Assistance to the Victims of these Crimes, and based on the labor risk guide for Mexico, we have identified and evaluated the following risks relevant to our business:

  • Hiring of subcontracted suppliers without full visibility of their working conditions.
  • Use of informal contracting, service providers or outsourcing without the guarantees of the labor law (Federal Labor Law).
  • Work situations that may involve debt bondage, wage withholding or restriction of movement.
  • Reputational risks in our end customers or partners who do not apply human rights policies in their supply chain.
  1. Policies and procedures

To mitigate these risks, 99 Degrees has adopted the following internal policies and procedures:

  • Code of conduct for employees and suppliers that expressly prohibits human trafficking, forced labor, debt bondage, withholding of wages or restriction of workers' freedom.
  • Contractual clause with suppliers and subcontractors requiring them to comply with Mexican labor regulations, relevant ILO conventions, and the company's internal human rights policy.
  • Due diligence procedure for new suppliers that includes verification of labor compliance, documentary audit and commitment to correct in case of findings.
  • Annual training for key personnel (management, purchasing, operations) on labor exploitation risks, warning messages and internal reporting channels.
  1. Due diligence

We implement systematic controls to assess and manage identified risks:

  • Review of supplier contracts: human rights clauses and compliance with Mexican labor law.
  • Evaluation of external personnel hiring processes to ensure that there are no conditions of coercion, salary withholding or debt bondage.
  • Periodic monitoring and auditing of critical suppliers, with compliance indicators, and establishment of corrective action plans when deviations are detected.
  • Internal whistleblower channel (confidential) to report any suspicion of exploitation or non-compliance.
  1. Effectiveness

To measure the effectiveness of our actions, we have defined indicators such as:

  • Percentage of new suppliers accepting and signing our Human Rights clause.
  • Number of supplier audits conducted per year.
  • Number of incidents of labor exploitation, forced or bonded labor, or debt bondage identified.
  • Number of corrective action plans implemented and their closure.

We will report these indicators annually in our sustainability report or in the section on compliance with human rights policies.

  1. Training and awareness

All 99 Degrees employees receive initial and annual training (depending on function) on human rights, forced and bonded labor policies, including awareness of obligations under the LGPSDTP and the Federal Labor Law. In addition, the purchasing and legal teams receive specific training on supply chain risks.

  1. Approval and publication

This document has been approved by 99 Degrees' general management and is signed by a member of the board of directors/legal representative. It will be published annually on our website (https://99degrees.tech) and will be available to all our stakeholders.

  1. Continuous commitment

We recognize that eradicating modern slavery requires ongoing vigilance and continuous improvement. We are therefore committed to reviewing and updating this Statement every year, to adapting our policies to changes in legislation, regulations or best practices, and to responding proactively to any incidents that arise in our operations or supply chain.

99 Degrees Tech & Co.