FWI | Poppulo Ethics and Compliance

FWI conducts business ethically, honestly, and in full compliance with the law. We believe that how we conduct ourselves is as critical to FWI’s success as making the best products in the world. Our Ethics and Compliance policies are foundational to how we do business and how we put our values into practice every day.

UK Modern Slavery Act Statement

Four Winds Interactive LLC (“FWI”, “we” or “us”) is committed to improving our practices to combat slavery and human trafficking. We are pleased to issue this modern slavery and human trafficking statement in compliance with Section 54 of the United Kingdom’s Modern Slavery Act 2015 (“Act”) and to reflect our support of human rights worldwide.

FWI is a computer software company providing Cloud-based digital signage management, workplace management solutions, omnichannel employee communications, and pre-built digital signage solutions. FWI is headquartered in Denver, Colorado, United States and has affiliates in Boston, Massachusetts, Cork, Ireland, and Luton, England. All references to FWI shall be deemed to include its respective affiliates and subsidiaries, including SmartSpace Global Ltd., Poppulo, Inc., and E-SEARCH DAC.


FWI’s Supply Chains

In compliance with the Act, we believe there is no modern slavery in our own organization or in our supply chain. FWI employees are required to comply with ethics and integrity policies made applicable to all employees and that are set forth in our Employee Handbook which is designed to ensure employees support our values and abide by applicable laws and regulations. All employees are required to read, understand and agree to our Employee Handbook as part of their employment obligations. FWI’s policies and procedures are continuously reviewed and updated to address applicable legislation in the countries where we do business. As with any company policy, disciplinary procedures are included and are aligned to discourage any violation of FWI’s policies and applicable laws.

FWI’s supply chain is wide and varied, with a strong technology focus. We abide by labor and employment laws in the jurisdictions where we employ people and operate a robust recruitment program including conducting eligibility to work checks for all employees. As a software provider, FWI uses very little unskilled labor. We therefore believe that the risks of modern slavery or human trafficking in our supply chain are minimal as compared to many other industries. FWI nevertheless takes such obligations seriously and has a zero-tolerance stance in relation to use of slavery or human trafficking in our supply chain and will terminate relationships with any FWI vendor that we learn engages victims of slavery or human trafficking.


Summary of Steps Undertaken and Planned Next Steps

We intend to take the following steps to combat slavery and human trafficking:

  1. Promulgate a new Code of Conduct referencing the U.K. Modern Slavery Act of 2015;
  2. Implement a Supplier Code of Conduct that, in part, prohibits the use of slavery and human trafficking;
  3. Notify and present to existing vendors the Supplier Code of Conduct and remind them of their obligation in relation to the prohibition of modern slavery;
  4. Incorporate anti-slavery and human trafficking obligations in our procurement and service agreements; and
  5. Provide training to relevant employees to ensure understanding of the risks associated with modern slavery and human trafficking.

Further, we will endeavor to continue to monitor potential risk areas with our supply chains and address issues if they arise.

This statement has been approved by the FWI Board of Directors. This statement is issued for the financial year 2022 on behalf of FWI and its subsidiaries, including SmartSpace Global Limited, Poppulo, Inc., and E-SEARCH DAC.


Global Anti-Bribery & Anti-Corruption Statement

FWI is committed to conducting business free from extortion, bribery and all unlawful, unethical or fraudulent activity. FWI partners must not offer, give, promise or authorize any bribe, gift, loan, fee, reward or other advantage to any government official or employee, any customer, any FWI employee or any other person to obtain any business advantage or improperly influence any action or decision. FWI business partners, suppliers and vendors must comply with all applicable international anti- corruption laws and regulations, including the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act.


Whistleblower Policy

A whistleblower as defined by this policy is an employee of FWI who reports an activity that he/she considers to be illegal or dishonest to one or more of the parties specified in this Policy. The whistleblower is not responsible for investigating the activity or for determining fault or corrective measures; appropriate management officials are charged with these responsibilities.

Examples of illegal or dishonest activities are violations of federal, state or local laws; billing for services not performed or for goods not delivered; and other fraudulent financial reporting.

If an employee has knowledge of or a concern of illegal or dishonest fraudulent activity, the employee is to contact his/her immediate supervisor or the Human Resources Director. The employee must exercise sound judgment to avoid baseless allegations. An employee who intentionally files a false report of wrongdoing will be subject to discipline up to and including termination.

Whistleblower protections are provided in two important areas — confidentiality and against retaliation. Insofar as possible, the confidentiality of the whistleblower will be maintained. However, identity may have to be disclosed to conduct a thorough investigation, to comply with the law and to provide accused individuals their legal rights of defense. The Company will not retaliate against a whistleblower. This includes, but is not limited to, protection from retaliation in the form of an adverse employment action such as termination, compensation decreases, or poor work assignments and threats of physical harm. Any whistleblower who believes he/she is being retaliated against must contact the Human Resources Director immediately. The right of a whistleblower for protection against retaliation does not include immunity for any personal wrongdoing that is alleged and investigated.

Defend Trade Secrets Act (DTSA) Compliance: “Immunity from Liability for Confidential Disclosure of a Trade Secret to the Government or in a Court Filing:

  1. Immunity—An individual shall not be held criminally or civilly liable under any federal or state trade secret law for the disclosure of a trade secret that—(A) is made—(i) in confidence to a federal, state or local government official, either directly or indirectly, or to an attorney; and (ii) solely for the purpose of reporting or investigating a suspected violation of law; or (B) is made in a complaint or other document filed in a lawsuit or other proceeding, if such filing is made under seal
  2. Use of Trade Secret Information in Anti-Retaliation Lawsuit—An individual who files a lawsuit for retaliation by an employer for reporting a suspected violation of law may disclose the trade secret to the attorney of the individual and use the trade secret information in the court proceeding, if the individual—(A) files any document containing the trade secret under seal; and (B) does not disclose the trade secret, except pursuant to court order.”

All reports of illegal and dishonest activities will be promptly submitted to Human Resources who is responsible for investigating and coordinating corrective action.

Employees with any questions regarding this policy should contact Human Resources.


Anti-Facilitation of Tax Evasion Policy

Our vision is “to be the most highly respected company in the industry”, and our success in this endeavor is dependent upon how all employees behave. It is also our policy to comply with the law wherever we operate.

In many countries (including the UK), it is a criminal offence to dishonestly evade tax or to assist others to do so. This can deprive governments of the revenues needed to fund vital public services. We expect the businesses and people we engage with to comply with their tax obligations. Tax evasion or its facilitation has no place at FWI and we do not tolerate any of our Directors, Officers or employees (together “Colleagues”), agents or business partners knowingly assisting or encouraging tax fraud by any of our customers, suppliers or others that we do business with.

  • We are committed to the following principles:
  • We will carry out business fairly, honestly and openly.
  • We will not provide services or sell to parties where we know or suspect that the services or the items sold will be misused or abused by a customer for the purposes of fraudulent tax evasion.
  • We will not buy services or goods from any supplier where we know or reasonably suspect them not to be properly declaring their income and any relevant tax and duties in connection with those activities.
  • Any colleague found to be in breach of these principles will face disciplinary action up to and including dismissal.
  • No colleague will suffer demotion, penalty, or other adverse consequence for refusing to engage in the sale or purchase of services and goods where they reasonably suspect or know tax evasion to be taking place. Our clear policy is not to engage in transactions where tax evasion is present or suspected to be present, even if it may result in us losing business.
  • We expect our agents and others who represent us also to commit to these principles.