DocuSign Envelope ID: 2C153026-15EE-4AA0-A158-4CFC85778A38

Modern and Statement For the Fiscal Year January 1 to December 31, 2018

Background and Introduction

Section 54 of the Modern Slavery Act of 2015 (UK) requires certain companies to provide disclosure regarding their efforts to address issues around slavery and human trafficking within their business and their supply chains.

This statement sets out the actions used to assess the risks of modern slavery and human trafficking, related to, and within, the business and the supply chain of Solium Capital Inc. (“Solium” or the “Corporation”).

Solium specializes in technology and services for the administration of equity-based incentive and savings programs. Solium’s main product, Shareworks, is an end-to-end web-based application utilized by both public and private clients and their participants.

The headquarters of Solium Capital Inc. are located in Calgary, Alberta, Canada. The Corporation is publicly-traded and its shares are listed on the Toronto Stock Exchange (TSX: SUM). Solium Capital Inc. owns various subsidiaries which operate globally in such countries as Canada, USA, UK, Spain, Germany, Australia, and Hong Kong. As of December 31, 2018, the Corporation has approximately 800 global employees, with annual revenue for 2018 fiscal year of USD $108.3M.

Solium is committed to preventing slavery and human trafficking within its corporate activities and within its supply chain. The Corporation has zero tolerance for slavery and human trafficking. Supply Chain

Solium’s main supply chain is comprised of outsourced specialized services (e.g. background check providers), legal and professional advisory consultancy services, banks, brokers, and vendors involved in supporting our technology, such as our outsourced data centre. Our significant vendors consist of both publicly traded and private organizations which primarily reside in Canada, USA, Australia, and European countries.

We are of the opinion that vendors used by Solium are low risk for committing infractions around slavery or human trafficking. As part of Solium’s vendor selection and annual vendor review processes, we monitor that vendors either meet Modern Slavery compliance, or, in the cases where vendors are not required to produce a Modern Slavery statement, we monitor that these vendors have codes of conduct or similar principles which align with Solium’s.

Code of Business Conduct and Other Policies

Solium's Code of Business Conduct is clear that all of its employees and consultants are expected and required to adhere to the highest ethical standards in all of their conduct of business for and on behalf of Solium. A concern for what is right underlies all business decisions. Solium believes that all employees and consultants should respect the work and responsibilities of their co-workers. It is Solium’s policy to deal fairly and lawfully with all customers, suppliers and independent consultants purchasing or furnishing goods or services. Solium maintains a Policy, which provides procedures for reporting wrongdoings to an independent party without the fear of retaliation. Our Code of Conduct and Whistleblower Policy are both internally accessible for all staff on our intranet, as well as being publicly deployed on our external website.

Solium’s practices ensure that only specified, reputable search agencies are used, in the event that such services are required. All employees are subject to a detailed background check. Solium adheres to all relevant employment labour and employment laws in each jurisdiction where staff reside.

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DocuSign Envelope ID: 2C153026-15EE-4AA0-A158-4CFC85778A38

All new staff are required to read and confirm compliance with Solium’s key policies, including Solium’s Code of Business Conduct and Whistleblower Policy. Annually, all staff are required to re-review the policies and confirm compliance thereto. Mandatory accompanies the sign-off exercise.

Approval

This statement was approved on 12-March-2019 by the Risk and Compliance Committee of the Board of Directors and Board of Directors of Solium Capital, Inc, and this statement is hereby signed by Director Brian Craig.

Brian Craig

Director

Solium Capital, Inc.

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