Flex B2B Pvt. Ltd. here referred as Flex B2B and/or its related corporations (collectively “Flex B2B”)

Policy Statement 

This document sets forth the policy of Flex B2B and is designed to provide reasonable assurance that (i) a consistent process is followed with respect to the dissemination of commercial electronic messages to QMPL clients and prospective clients in Canada, and (ii) Flex B2B employees sending commercial electronic messages from and/or to a computer system(s) in Canada comply with the requirements of CASL.

The Flex B2B Anti-Spam Policy (“Anti-Spam Policy”) and related procedures (the “CASL Procedures”) require that all QMPL employees sending CEMs from and/or to a computer system(s) in Canada or to an electronic address that will be accessed from a computer system in Canada comply with CASL, and seeks to ensure that all CEMs sent by or on behalf of QMPL, or using a QMPL email address or using a device owned or provided by Flex B2B, comply with CASL.

Policy Details

The Anti-Spam Policy describes Flex B2B’s commitments relating to the provisions of CASL and electronic messages of a commercial nature sent to Flex B2B clients, prospective clients, and others, as applicable. From time to time, Flex B2B may implement additional policies, procedures and/or practices as it relates to anti-spam measures.

Application

This Policy applies to Flex B2B’s employees who may be sending CEMs from and/or to a computer system(s) in Canada or to an electronic address that will be accessed from a computer system in Canada.

With respect to Flex B2B’s operations, the Anti-Spam Policy has been adopted in compliance with the requirements of CASL, and QMPL is committed to complying with CASL. All other Flex B2B policies and procedures will be interpreted in a manner that is consistent with the Anti-Spam Policy and that promotes compliance with CASL to seek to deter damaging and deceptive forms of spam from occurring in Canada.

Consent

Flex B2B obtains express, opt-in consent, unless a verifiable basis for implied consent or an exception to consent exists, before sending a CEM to anyone who has not had an existing business relationship with Flex B2B within two years before the date on which the CEM is sent. Unless a valid documented basis for implied consent or an exception to consent exists, Flex B2B also obtains express, opt-in consent for the sending of CEMs to Flex B2B prospects.

The request for consent cannot be in an electronic message unless there exists a basis for implied consent to send the message. The request for consent must be sought separately within a communication (e.g. through a separate action such as affirmatively checking a checkbox) and cannot be bundled as a term of acceptance of an agreement. A verbal consent is acceptable where a record of the details of the consent is maintained in a database.

Form and Content of CEMs

All CEMs are required to comply with the form and content requirements of CASL, generally described as follows:

• identifies the sender;
• the sender’s mailing address;
• the sender’s telephone number or email address or link to a webpage; and
• an unsubscribe mechanism or withdrawal of consent from receiving CEMs from Flex B2B and its subsidiaries and

Flex B2B takes steps to require that any third-party service provider who sends CEMs on behalf of Flex B2B complies with CASL.

Storage of Relationship Details

A key component of complying with CASL involves maintaining records of Flex B2B’s relationships with clients and prospective clients.

Each business unit of Flex B2B is required to create and maintain in the business unit’s Client Relationship Management (CRM) system (including, but not limited to, Benchmark, Salesforce), verifiable records documenting the relationships giving rise to implied consent, and verifiable records of express, opt-in consents obtained from Flex B2B clients and prospective clients. “Clients” are defined as those organizations or individuals who have at least one open account or a contractual relationship with Flex B2B at the relevant time. Organizations or individuals who have closed their last remaining account or terminated their contract with Flex B2B are not considered Flex B2B clients for purposes of this Policy.

Implied consent or express, opt-in consent is obtained in accordance with the CASL Procedures and recorded in the applicable CRM system in order to track the client and prospect relationships.

Records of express, opt-in consent and records documenting the relationships giving rise to implied consent are retained for a minimum of three years after Flex B2B ceases sending CEMs to the Flex B2B client or prospect.

Commercial Electronic Messages

All QMPL employees sending CEMs from and/or to a computer system(s) in Canada are required to comply with this Policy and related CASL procedures and processes.

A “CEM” is defined as an electronic message that includes content (for instance, text, hyperlinks, images or attachments) that:

1. promotes, offers or advertises Flex B2B or Flex B2B’s products or services, or employees, or contacts;
2. solicits business for Flex B2B or Flex B2B employees or contacts; and
3. any other similar message that encourages participation in commercial

Examples include promotional event invitations (e.g., webcasts or Flex B2B events), marketing newsletters, etc.

The following messages do not have to comply with the requirements applicable to CEMs:

• messages sent to Flex B2B clients about their business;
• internal communications about Flex B2B’s business (including communications with Flex B2B offices outside Canada);
• legally required notices, such as messages that are sent to comply with a regulatory requirement (e.g., material changes, required account activity information, etc.); and
• responses to requests, inquiries or

Messages that Flex B2B employees email each other internally using a device that Flex B2B owns or provides, or using a Flex B2B email address, should be related to Flex B2B. Flex B2B employees may not internally email each other offers, promotions, advertisements, or referrals unrelated to FBPL business without the internal recipient’s verbal consent.

Compliance by Third Parties

All third-party contracts with service providers who may send CEMs on behalf of Flex B2B must contain contractual clauses obligating the service provider to comply with CASL including the form and content requirements of CEMs.

Unsubscribe Mechanism

CEMs that are not exempt from requirements applicable to CEMs noted above are required to include a form of unsubscribe mechanism to facilitate the withdrawal of consent or do-not-contact requests within a period of time and in a manner that would allow Flex B2B to process that request within 10 days of the date on which the unsubscribe, withdrawal of consent or do-not-contact request was made. This information should be maintained in the applicable database that tracks the client and prospect relationships.

All emails sent by Flex B2B Pvt. Ltd. employees will be compliant with CASL and will include the option to ‘unsubscribe.’

You can ‘unsubscribe’ from our Commercial Electronic Messages at any time by visiting https://starleadhub.com/unsubscribe or by emailing dpo@flexb2b.com with ‘Unsubscribe’ in the subject line.

Policy Administration

The Anti-Spam Policy is maintained by the Compliance department of each XpertLync legal entity and will be reviewed and updated, where necessary, and approved on an annual basis. Any changes to, or exceptions from this Policy require the approval of the respective XpertLync Board or equivalent.

Review and Approvals

XpertLync Compliance is responsible for review and revision of this Policy, subject to approval of the respective XpertLync Board or equivalent. This Policy is subject to review on an annual basis, or otherwise as needed.

Enforcement and Audit

Compliance with this Policy, and any related procedure, may be reviewed by XpertLync at any time. Failure to comply with this Policy, as well as any associated procedures, may result in disciplinary action in accordance with the applicable Global Human Resources Disciplinary policy or procedure.