1. Introduction

This policy serves as a guideline for Virtual Trader to employ its best endeavors to ensure that environmental, social, and governance factors are considered in all aspects of its business operations.

2. Guiding Principles

Before considering any new undertaking (e.g., change in operating practices or new supplier/customer relationship), Virtual Trader will analyze the extent to which the following principles are met by all parties:

• Acting responsibly in respect of the environment.
• Fostering business practices centered on integrity, transparency, accountability, and propriety.
• Complying with the laws in each jurisdiction in respect of environmental issues, social legislation, and sound international industry practices.
• Engaging with companies that maintain a positive position on nature preservation, resource efficiency, and/or health.
• Maintaining accessibility to and engagement with relevant stakeholders — either directly or through representatives.
• Ensuring consideration is given to environmental, public health, safety, social, and governance issues in respect of vendor/customer relationships.
• Adopting ethical business practices at all times.
• Avoiding discrimination in all its forms (e.g., gender, race, age, and disability) in the recruitment process at all levels of the organization.
• Respecting human rights, thereby ensuring the prohibition of slavery and child labor.

3. Environmental Considerations

Virtual Trader considers the environmental impact associated with all new engagements (e.g., products, customers, suppliers) in respect of the following areas:

• Preservation of nature and avoidance of climate change.
• Resource efficiency, sustainability, and consumption.
• Responsible waste disposal.
• Health and safety.

When impact is to some degree unavoidable, Virtual Trader always seeks to responsibly minimize adverse effects on the environment.

4. Social Considerations

Virtual Trader supports equity, diversity, and inclusion in its relationships with staff, customers, and suppliers. It accepts no violations of human rights, exploitation of child labor, or slavery. Principles for safeguarding staff health and safety are laid out in employment policies that are subject to regular review.

5. Governance Considerations

The Company:

• Evaluates its performance to check for good management practices.
• Protects and secures data, infrastructure, and identity.
• Has appointed independent companies for information security controls.
• Maintains a member of the board of directors who is separate from management.
• Ensures the organization is structured appropriately to meet its goals and mission statement.

Updated: November 8, 2022