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UK Modern Slavery Act Statement

The United Kingdom Modern Slavery Act of 2015 requires businesses with an annual turnover of £36 million or greater to publish an annual statement providing information on the steps taken to prevent slavery and human trafficking from their supply chain as well as within their own organization.

Pursuant to Section 54 of the Modern Slavery Act 2015 the following is Enjoy’s slavery and human trafficking statement for the fiscal year ended December 31, 2020.

The Enjoy group of companies are, Enjoy TechnologyInc (holding company), Enjoy Technology LLC (parent company), Enjoy Technology Canada Ltd (subsidiary) and Enjoy (UK) Ltd(subsidiary). Enjoy is reinventing the way people buy the world’s best technology products through its mobile, on-demand retail store. We partner with the world’s premier technology companies such as BT, EE, AT&T and Rogers Telecom to deliver The Last Smart MileTM. Enjoy is a privately held corporation headquartered in PaloAlto, CA. Enjoy is committed to its core values of Kindness, Winning Together, Growth Mindset and Experience Obsessed.

Enjoy is committed to good corporate citizenship and the highest ethical standards. We deliver and sell our partners’ products and provide a service to their customers. We do not manufacture these products. The supply chain for these products is managed by our partners. Our partners maintain ownership over these products until we deliver or sell them to their customers. We review our partners’ controls over their supply chain with respect to modern slavery.

Our suppliers are a critical part of the Enjoy community. Integrity, transparency, trust, respect, communication, and ethical conduct are critical to all successful business endeavours. These values provide a strong foundation for Enjoy and for its relationships with suppliers. We have safeguards in place to guard against slavery in the supply chain of the products from our suppliers.

Enjoy is also committed to not only abide by the laws and regulations that apply to our organization as we conduct business around the world, but to be a leader in the areas of compliance and ethics.

Enjoy’sCode of Conduct outlines how Enjoy conducts business and describes the company’s core values. It provides Enjoy employees with guidance on how to follow company policies, applicable laws, rules and regulations. Enjoy’s Anti-Corruption Policy outlines our zero-tolerance approach to prevent and detect bribery and corruption activities. It is imperative that all employees act with integrity and in accordance with local laws and regulations.

We partner with our suppliers and set clear expectations, which is acknowledged by our suppliers as part of our supplier due diligence process prior to the execution of agreements. We expect our suppliers to establish policies and procedures to ensure compliance with all applicable laws and regulations. Should we become aware of any policy violations or issues related to slavery or human trafficking, we will consult with our Legal Department to ensure that appropriate measures are taken, which may include reporting this information to authorities and terminating our relationship with the supplier.

Enjoy conducts the following actions to help prevent forced labour, modern slavery and human trafficking:

  • 1 ) Anti-Slavery and Human Trafficking Due Diligence Process

    • a ) Our supplier due diligence process will require all potential suppliers to confirm they and their supply chain do not engage in forced labour, slavery and human trafficking. This process applies to all third-party suppliers of products or services that are paid directly by Enjoy, including consulting firms, independent contractors, staffing agencies, and agency temps, regardless of their title or the product or service they provide (“suppliers”).

  • 2 ) Supplier Agreements

    • a ) All suppliers are subject to Enjoy’s legal terms and conditions.

    • b ) Assessments of potential suppliers are completed as part of our supplier due diligence and on-boarding process.

    • c ) Enjoy reviews the performance of suppliers based on their relative risk to the company, basedon the assessment of cross-functional stakeholders, including the Information Security, Legal and Compliance Departments. Suppliers deemed highest risk are audited or reviewed on a periodic basis. Enjoy works closely with suppliers to develop corrective action plans and carry out all audit findings. Suppliers that do not or are unable to meet our requirements are subject to termination.

  • 3 ) Compliance & Training

    • a ) Enjoy employees are encouraged to raise concerns including potential violations of (1) the code of conduct, (2) company policies, and (3) the laws and regulations in which they operate. Enjoy has reporting mechanisms in place to collect and relay information regarding potential violations to appropriate company resources for review and follow-up.

    • b ) Enjoy is in process of rolling out Code of Conduct training for 2021and currently requires all Enjoy employees agree to abide by and act in accordance with the Code of Conduct.

    • c ) We expect our suppliers to communicate our requirements for an ethical and compliant supply chain to their employees and third-party partners through training, policy and other messaging.

This statement applies to Enjoy Technology Inc., Enjoy Technology LLC, Enjoy Technology Canada Ltdand Enjoy (UK) Ltd.

  • Nick Hale
  • Director
  • July 1, 2021