Modern Slavery Statement

TitanFile Inc. has zero tolerance for modern slavery, forced labour, child labour and human trafficking in its operations and supply chain. This statement sets out the steps TitanFile takes to prevent them.

About TitanFile

TitanFile is a privately held software company headquartered in Toronto, Canada. It provides a secure file sharing and client collaboration platform, delivered as a cloud service, to law firms, financial institutions, government and other regulated organizations. TitanFile does not manufacture or distribute physical goods, and its platform is hosted by established cloud infrastructure providers.

Supply chain

TitanFile’s supply chain consists mainly of cloud infrastructure, software, professional services, office facilities and IT equipment suppliers. Most are established firms with skilled workforces in regulated markets. TitanFile considers the inherent risk in its supply chain to be low. The higher risks sit further down the chain, in hardware manufacturing and facilities services.

Policies

TitanFile’s commitment is set out in its Corporate Responsibility and Compliance Policy, which applies to all employees, contractors and officers and to third parties acting on TitanFile’s behalf. It is supported by policies on whistleblowing, personnel screening and supplier risk management. TitanFile expects its suppliers to comply with applicable laws on modern slavery.

Risk assessment and due diligence

TitanFile assesses modern slavery risk in its own operations and supply chain at least once a year. New employees are screened as part of hiring. Suppliers are risk assessed before engagement and reviewed annually. TitanFile considers the risk in its own operations to be low.

Training

All staff are trained on the Corporate Responsibility and Compliance Policy during onboarding and every year after, including awareness of modern slavery risks and how to report a concern.

Reporting concerns

Employees, contractors, suppliers and other stakeholders can report a concern to the Compliance Officer, a manager or ethics@titanfile.com, and may do so anonymously. Retaliation against anyone who reports in good faith is prohibited. Reports are investigated promptly and confidentially. Proven misconduct may lead to disciplinary action, up to termination of employment or of the supplier relationship.

Review

The Compliance Officer reviews this statement and the supporting policies at least once a year.

Last reviewed: November 2026

Approval

Approved by Tony Abou-Assaleh, President and CEO, TitanFile Inc., on November 4, 2026.