INTRODUCTION

Welcome to HAPPYDOER, your premier global creative platform offering full-service solutions, high-quality content, and applications for brands, corporations, and media organizations. Our extensive library features top-tier licensed pictures, vectors, drawings, movies, 3D models, and music, accessible directly or through our group companies.

In compliance with Section 54 of the Modern Slavery Act 2015, this declaration outlines HAPPYDOER’s proactive measures to prevent modern slavery and human trafficking within our supply chain. We uphold the highest ethical standards and conduct our business with utmost integrity.

STRUCTURE, BUSINESS AND SUPPLY CHAINS

Based in Dubai, HAPPYDOER operates a global marketplace for licensed content, connecting users with content providers. Our platform offers easily searchable content for consumers to license while rewarding contributors for their work. HAPPYDOER’s ultimate parent company is HAPPYDOER, Inc., based in the United States, with subsidiaries in the United Kingdom, continental Europe, and Asia. In this statement, “HAPPYDOER” refers to the entire group, including all subsidiaries and affiliates worldwide.

HAPPYDOER employs around 1,000 people globally, including staff photographers, videographers, contributors, producers, and creatives. Our content offering includes:

• Wholly owned content by staff photographers
• Crowdsourced content from our global contributor network
• Bespoke content produced by our in-house Studios team
• Content distributed through partnerships with agencies, production, and media companies

We also have vendor agreements for employee perks, facilities, and services in financial, legal, and technology sectors.

POLICIES, TRAINING AND WHISTLEBLOWING PROTECTION

We are committed to eradicating modern slavery and human trafficking from our supply chains and business operations. Our Code of Conduct and Business Ethics emphasizes ethical behavior and integrity in all business relationships. We implement and enforce effective systems and controls to prevent slavery and human trafficking. HAPPYDOER fosters a workplace culture that values diversity, equality, inclusion, and respect, providing accessible and protected channels for voicing concerns, including a whistleblowing hotline. Annual compliance training ensures all workers read and approve the Code of Conduct and Business Ethics.

RISK ASSESSMENT AND DUE DILIGENCE PROCEDURES

HAPPYDOER considers our sector and most suppliers low-risk but strives to minimize the risk of modern slavery by:

• Ensuring all employees have the right to work in their respective territories and comply with local legal requirements.
• Including contractual provisions in all agreements with external suppliers, contributors, contractors, and agencies to ensure compliance with modern slavery and anti-trafficking laws.
• Collaborating with vendors and customers for thorough due diligence processes.
• Protecting whistleblowers and those who raise concerns through a dedicated hotline and HR support.
• Reviewing our supplier audit program to include modern slavery considerations.
• Enforcing content creation rules and third-party agreements to comply with anti-slavery laws.
• Guaranteeing all necessary permits and authorizations, including for minors, when creating and distributing content.

MEASURING EFFECTIVENESS

We will conduct an annual evaluation of our global processes to mitigate the risk of noncompliance with the Modern Slavery Act. We will foster ongoing conversations across our supply chains to identify and address risk areas or noncompliance effectively. Our Board of Directors will review and approve this policy annually.