Boldest Inc. Human Rights Policy

I. Purpose/objective

A. Boldest Commitment to Human Rights

At Boldest, Inc. (“Boldest”), we are committed to respecting the human rights and fundamental dignity of all persons.

Boldest creates powerful connected experiences for businesses and clientele. We pursue meaningful, long-term relationships with individuals and businesses that benefit from our unique investigation solutions and security offerings.

Our differentiated techniques empowers clients and businesses to experience smarter investigative / security services. Our knowledge of the job powers all aspects of our business, not only providing the safety & security business, but also enabling a number of other valuable investigative methods.

Boldest Investigation & Security Services, Executive Officer, Olu Ajayi, states: “We believe that more Investigations to “Uncover the truth” is better and that people have a right to safety and security in their homes and businesses. We further believe that our company supports human rights by enabling personal safety and security. However, we recognize that there are many “bad actors” out there who aims to infringe human rights, and that global supply chains can present human rights risks. For that reason, we are committed to respecting human rights in all aspects of our business. That is why we created this Human Rights Policy. This policy serves as a foundation to help us ensure that Boldest employees, management and executives, suppliers, business partners, customers, and other stakeholders respect human rights.”

B. Scope

Boldest Human Rights Policy applies to all employees, management and executives, suppliers, and business partners, and strives to protect the human rights of all Boldest stakeholders. There are no exceptions to this policy and no one is exempt from it.

II. International human rights framework

Boldest is committed to respecting and supporting international law as it pertains to the human rights of our workers and surrounding communities. In particular, Ooma abides by the United Nations Guiding Principles on Business and Human Rights (UNGPs), which were unanimously endorsed by the UN Human Rights Council in 2011 and are now the authoritative global reference point on business and human rights. They are based on the three pillars of the UN “Protect, Respect and Remedy” Framework, which recognizes the complementary yet distinct roles of states and business in protecting and respecting human rights:

• State Duty to Protect: States have the duty to safeguard human rights through appropriate policies, regulation, and adjudication;

• Corporate Responsibility to Respect: Companies must “Know and Show,” meaning they must assess human rights impacts and take steps to manage them;

• Provide Access to Remedy: States and companies must remedy abuses through judicial and nonjudicial means.

Boldest fully endorses the UNGPs and has integrated respecting human rights into its fundamental policies, including this Policy, the Injury and Illness Prevention Program, Vendor Code of Conduct, and Environmental Policy.

The following international laws and principles form the foundation and guide the implementation of Ooma’s Human Rights Policy and its compliance with the UNGPs:

• International Bill of Human Rights

• Universal Declaration of Human Rights

• International Covenant on Civil and Political Rights

• International Covenant on Economic, Social and Cultural Rights

• International Labour Organization (ILO) Declaration on Fundamental Principles and Right to Work

• United Nations Convention on the Rights of the Child

• United Nations 2030 Agenda for Sustainable Development (and its 17 Sustainable Development Goals)

III. Boldest human rights policy

A. Our Principles

Boldest is committed to upholding the human rights of its employees, management and executives, suppliers, business partners, customers, and other stakeholders, and expects these stakeholders to uphold human rights as well. We express our commitment in part through the various policies that govern our workplace, such as Boldest’s Injury and Illness Prevention Program, Vendor Code of Conduct, and Environmental Policy.

1. Diversity and Non-Discrimination

Boldest values cultural and individual diversity in our workforce, management and board of directors, as well as in our customers, suppliers, and communities. We treat everyone equally and fairly and provide equal employment opportunities, including in hiring, placement, promotion, development, training, and compensation. We do not discriminate on the basis of race, color, gender, gender expression, gender identity, sexual orientation, religion, religious creed, sex, national or social origin, ancestry, age, mental or physical disability, medical condition, genetic information, military or veteran status, marital status, pregnancy, or any other characteristic protected by local law, regulation, or ordinance.

2. No Harassment or Violence

Boldest is committed to providing a workplace free of violence and sexual harassment, as well as harassment based on factors such as race, color, gender, gender expression, gender identity, sexual orientation, religion, religious creed, sex, national or social origin, ancestry, age, mental or physical disability, medical condition, genetic information, military or veteran status, marital status, pregnancy, or any other characteristic protected by local law, regulation, or ordinance. We will not tolerate physical, verbal, sexual or psychological harassment, bullying, abuse, or threats by managers or co-workers.

3. Freedom of Association

Boldest recognizes that employees have the right to freely associate with labor organizations and the right to bargain collectively. Boldest respects those rights and acknowledges that everyone is entitled to freedom of opinion, expression, and speech. We value an open and fair culture and are committed to cultivating an environment of open communication where everyone feels comfortable about expressing opinions and contributing ideas. We encourage employees to speak with their supervisors about their ideas, concerns, or problems. Furthermore, Boldest expects and prioritizes compliance with all applicable local laws.

4. No Child Labor

Boldest respects the rights of the child as stated in the United Nations Convention on the Rights of the Child. Boldest will not use or tolerate child labor within our facilities or in those of our suppliers. We adopt the International Labour Standards on Child Labour’s Minimum Age Convention, which sets the minimum age for admission to employment or work at 15, and we comply with local laws that may set a higher minimum age.

6. No Involuntary Labor, Human Trafficking, and Slavery

Boldest will not use or tolerate the use of forced, compulsory, bonded, or indentured labor in our operations or those of our suppliers. Our suppliers must not traffic workers or in any other way exploit workers by means of threat, force, coercion, abduction, or fraud. Working must be voluntary, and workers must be free to leave work and terminate their employment or other work status with reasonable notice. Workers will not be required to pay recruitment, hiring, or other similar fees related to their employment; our suppliers must bear or reimburse to their workers the cost of any such fees. Our suppliers must not require workers to surrender government issued identification, passports, or work permits as a condition of working, and our suppliers may only temporarily hold onto such documents to the extent reasonably necessary to complete legitimate administrative and immigration processing. Workers must be given clear, understandable contracts regarding the terms and conditions of their engagement in a language understood by the worker. Suppliers must ensure that each of their staffing or recruiting agencies complies with this commitment and with the more stringent of the applicable laws of the locality where work is performed.

7. Fair Wages

Boldest will compensate employees and contractors in compliance with applicable wage laws, including those related to minimum wages, overtime hours, and legally mandated benefits. Working hours are not to exceed the maximum set by local law, regulations, and customs.

8. Privacy and Freedom of Expression

Boldest is committed to the rights to privacy and freedom of expression and we seek to protect against unauthorized access, use, destruction, modification, or disclosure of personal information and data. Boldest takes seriously its role in ensuring the protection of data and minimizing potential threats, and is committed to the proper processing of personal data to ensure its protection. Additionally, Boldest promotes the right of its employees, management and executives, suppliers, business partners, customers, and other stakeholders to hold and freely share opinions without interference, and to access the full range of ideas and information. We at Boldest believe restrictions on freedom of expression will dampen the exchange of ideas and reduce innovation and commercial opportunities. Through our commitment to upholding the rights to privacy and freedom of expression, we are also committed to respecting any applicable local laws.

9. Anti-Corruption

Boldest is committed to acting with honesty and integrity. We use ethical business practices in our dealings with public officials, other companies, and private citizens. We do not seek to influence them through the payment of bribes, kickbacks, or any other unethical payment or practice. Boldest expects and prioritizes compliance with all applicable local laws.

10. Product Responsibility

As the range of products and services that Boldest offers broadens and changes, we evaluate potential concerns about how technology products may be used to infringe upon human rights. We continually review our policies and assessment processes to analyze these potential risks.

11. Supplier Responsibility

Boldest expects all suppliers to maintain employment, environmental, health and safety, and ethics practices that meet or exceed our Human Rights Policy while conducting business with and/or on behalf of Boldest.

12. Workplace Security

We are committed to maintaining a workplace that is free from violence, harassment, intimidation and other unsafe or disruptive conditions due to internal and external threats. Security safeguards for employees are provided as needed, and are maintained with respect for employee privacy and dignity.

13. External Engagement; Community and Stakeholders

We are conscious of the impact we have on the communities in which we operate. We are committed to engaging in dialogue with stakeholders on human rights or labor rights issues related to our business where appropriate.

B. Reporting

Boldest will not tolerate human rights violations within any part of our business or supply chain. Anyone subject to this Policy who observes or suspects misconduct is required to report their concerns to their manager. All reports will be kept confidential to the extent possible. Additionally, anyone who reports potential misconduct, provides information, or otherwise assists in an investigation of potential misconduct will be protected against any retaliatory action.