Canada’s Anti-Spam Legislation (CASL)

Policy Statement

This document sets forth the policy of ReadersCube and is designed to provide reasonable assurance that
(i) a consistent process is followed with respect to the dissemination of commercial electronic
messages to ReadersCube clients and prospective clients in Canada, and (ii) ReadersCube employees sending
commercial electronic messages from and/or to a computer system(s) in Canada comply with the
requirements of CASL.
The ReadersCube Anti-Spam Policy (“Anti-Spam Policy”) and related procedures (the “CASL Procedures”)
require that all ReadersCube 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 ReadersCube, or using a ReadersCube email address or
using a device owned or provided by ReadersCube, comply with CASL.

Policy Details

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

Application

This Policy applies to ReadersCube 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 ReadersCube’s operations, the Anti-Spam Policy has been adopted in compliance with the
requirements of CASL, and ReadersCube is committed to complying with CASL. All other ReadersCube 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

ReadersCube 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 ReadersCube 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, ReadersCube also obtains
express, opt-in consent for the sending of CEMs to ReadersCube 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 ReadersCube and its
subsidiaries and affiliates.

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

Storage of Relationship Details

A key component of complying with CASL involves maintaining records of ReadersCube’s relationships with
clients and prospective clients.
Each business unit of ReadersCube 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 ReadersCube clients and prospective clients. “Clients”
are defined as those organizations or individuals who have at least one open account or a
contractual relationship with ReadersCube at the relevant time. Organizations or individuals who have
closed their last remaining account or terminated their contract with ReadersCube are not considered
ReadersCube 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 ReadersCube ceases sending CEMs to the ReadersCube
client or prospect.
Commercial Electronic Messages
All ReadersCube 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:

a. promotes, offers or advertises ReadersCube or ReadersCube’s products or services, or employees, or
contacts;

b. solicits business for ReadersCube or ReadersCube’s employees or contacts; and

c. any other similar message that encourages participation in commercial activity.

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

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

⬤ messages sent to ReadersCube clients about their business;

⬤ internal communications about ReadersCube’s
business (including communications with ReadersCube 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 complaints.

Messages that ReadersCube employees email each other internally using a device that ReadersCube owns or
provides, or using a ReadersCube email address, should be related to ReadersCube. ReadersCube employees may not
internally email each other offers, promotions, advertisements, or referrals unrelated to ReadersCube
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 ReadersCube 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 ReadersCube 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 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://www.domain.com/unsubscribe
or by emailing dpo@ReadersCube.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.