Modern Slavery Act 2015

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, including slavery, servitude, forced or compulsory labour, and human trafficking, all of which have in common the deprivation of a person's liberty by another to exploit them for personal or commercial gain.

We are committed to combatting slavery and human trafficking. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our company's slavery and human trafficking statement.

Who we are: We are a SaaS company providing cloud-based grant management platforms to foundations, corporations, and public sector organizations. Following the merger of SmartSimple Software Inc., Foundant Technologies, and GivingData, we operate as a combined entity serving clients globally.

Where we operate: Our organization operates internationally, with remote team members across Canada, the United States, and the EMEA region, including the United Kingdom.
Our business model: As a software company, we do not manufacture, produce, or distribute physical products. Our software solutions are delivered digitally via cloud infrastructure.
Our supply chains: Given our digital business model, our supply chains consist primarily of:
•    Cloud infrastructure and hosting services 
•    Software and technology vendors
•    Professional services and consultants
•    Corporate services (legal, accounting, insurance)
Our suppliers similarly provide digital or professional services rather than physical goods, resulting in inherently lower modern slavery risk profiles compared to manufacturing or goods-based supply chains.
Entities covered by this statement: This statement covers Foundant Technologies, Inc., SmartSimple Software Ltd., SmartSimple Software UK Limited, SmartSimple Software Ireland Limited, SmartSimple Software Inc. and GivingData, LLC
Our Policies on Modern Slavery and Human Trafficking
We are committed to ensuring that modern slavery and human trafficking are not present in our supply chains or any part of our business. Our workplace policies demonstrate our commitment to ethical business practices and include:
•    Code of Conduct and Ethics Policies: Establishing standards for ethical behavior and compliance with all applicable laws
•    Vendor Management Policy: Requiring supplier compliance with applicable employment and anti-slavery laws
•    Employment Practices: Ensuring direct employment relationships, fair compensation, freedom to terminate employment, and prohibition of any form of forced labor
•    Whistleblower Policy: Providing confidential channels for reporting concerns without fear of retaliation

Risk assessment approach: Our GRC team is responsible for assessing modern slavery risks across our operations and supply chains as part of our compliance framework.
Risk profile: As a digital software company with cloud-based service delivery, our assessed risk of modern slavery in our operations and supply chains is low. We:
•    Do not manufacture physical products or operate facilities with on-site labor forces
•    Primarily engage vendors providing digital, cloud, or professional services
•    Maintain direct employment relationships with our workforce
•    Partner with established, tier-1 technology providers such as Amazon Web Services and Microsoft Azure who maintain their own robust compliance programs
Risk management measures: While our risk profile is low, we take the following steps to ensure continued compliance:
•    Vendor due diligence and assessment procedures
•    Contractual requirements for supplier compliance with anti-slavery laws
•    Regular review of our vendor base and employment practices
•    Monitoring of industry developments and emerging risks

Vendor management: Our vendor management processes include due diligence to assess supplier compliance with applicable laws, including modern slavery legislation. Suppliers are required to confirm their compliance with all employment, labor, and human trafficking laws.
Contractual protections: Our vendor selection prioritizes established suppliers with robust compliance frameworks. We conduct due diligence on vendors' policies and practices, including their approach to employment law and modern slavery compliance. Our key infrastructure partners, Amazon Web Services and Microsoft Azure, maintain comprehensive modern slavery and ethical sourcing programs.
Employment practices: We maintain direct employment relationships with our workforce, ensuring:
•    Fair compensation and benefits
•    Freedom to terminate employment
•    Clear employment terms and conditions
•    No use of forced labor, child labor, or exploitative practices
Grievance mechanism: We maintain confidential reporting channels through which employees and suppliers can raise concerns. All reports are investigated promptly and appropriately.
Remediation commitment: In the unlikely event that modern slavery is identified, we will take immediate action to investigate, remediate, and if necessary, terminate supplier relationships. To date, we have not identified any instances of modern slavery in our operations or supply chains.

We provide training to our employees on ethical business practices and compliance with applicable laws, including modern slavery and human trafficking legislation. Training covers the identification of potential risk indicators and procedures for reporting concerns. Training is tailored to employee roles and responsibilities across the organization and  is provided as part of our onboarding process and through ongoing compliance programs.

We assess the effectiveness of our approach through:
Key measures:
•    Review of vendor compliance programs and policies
•    Employee training on ethical business practices
•    Monitoring of our vendor base
•    Investigation and resolution of any reported concern
Continuous improvement: We will continue to review and enhance our policies, due diligence procedures, and training programs to ensure ongoing effectiveness in preventing modern slavery in our business and supply chains.

This statement was approved by the Board of Directors of L Squared Capital Management LP on December 16, 2025.

Signed on behalf of the Board:

Jake Robert Meyer, Associate
L Squared Capital Partners