Corbus Corporate Social Responsibility Plan

PREFACE

Human trafficking is a global phenomenon that individuals and companies, whether public or privately held, should be committed to combatting. Today, an estimated 21 million victims are trapped in some form of modern day slavery and the “business” of controlling and exploiting people for profit has quickly becoming a $150 billion a year industry for traffickers.[1][2] Corbus, LLC and its Affiliates are opposed to human trafficking and forced labor in any form. We are committed to working to mitigate the risk of human trafficking and forced labor in all aspects of our business.

The U.S. Government has a zero-tolerance policy regarding any companies and their agents performing work for or on behalf of the Government from engaging in any severe form of trafficking in persons, defined to mean the recruitment, harboring, transportation, provision or obtaining of a person for labor or services, through the use of force, fraud, or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage or slavery and sex trafficking2. Nevertheless, companies within the private sector are equally encouraged to adopt policies of this nature and aid in the efforts against the perpetuation of human trafficking. Moreover, the U.S. federal government is not alone in its heightened scrutiny and enforcement of this atrocity against human rights[3]; international organizations, like the United Nations, and the European Union have adopted strict laws against human trafficking.[4]

As a company with a global presence, Corbus believes that it has a heightened responsibility to actively enable its employees and contractors to be made aware of this problem and become educated in how to spot and combat human trafficking.

APPLICABILITY

The purpose of this Corporate Social Responsibility Plan (the “Plan”) is to set out Corbus’ policies and procedures for: (1) making all Corbus employees aware of the conduct prohibited under this plan, as derived from U.S. and international anti-trafficking provisions, and the actions that may be taken against employees for violations; (2) employing fair recruitment and wage practices; and (3) preventing prohibited trafficking activity by suppliers, subcontractors and subrecipients, and monitoring, detecting and terminating those who engage in such activities.

We expect all of our employees, executives, and Board members to know and follow this Plan. Failure to do so will result in disciplinary action, including, without limitation, termination of employment. Moreover, while the Plan is specifically written for Corbus employees, executives, and Board members, we expect Corbus contractors, consultants and others who may be temporarily assigned to perform work or services for Corbus to follow the Code in connection with their work for us, and these individuals will be held to the same standards and consequences as those applicable to Corbus employees, executives, and Board members.

EMPLOYEE AWARENESS PROGRAM

Corbus strictly prohibits its employees and all subcontractors and agents from:

1. engaging in severe forms of trafficking in persons;

2. procuring commercial sex acts;

3. using trafficked labor;

4. destroying, concealing, confiscating, or otherwise denying an employee access to the employee’s identity or immigration documents, such as passports or drivers’ licenses, regardless of issuing authority;

5. using misleading or fraudulent practices during the recruitment of employees or offering of employment, such as failing to disclose, in a format and language accessible to the employee, basic information or making material misrepresentations during the recruitment of employees regarding the key terms and conditions of employment, including wages and fringe benefits, the location of work, the living conditions, housing and associated costs (if employer or agent provided or arranged), any significant costs to be charged to the employee, and, if applicable, the hazardous nature of the work;

6. using recruiters that do not comply with local labor laws of the country in which the recruiting takes place;

7. charging employees recruitment fees (as defined by the FAR);

8. failing to pay return transportation costs upon the end of employment, for certain employees who are not nationals of the country in which the work is taking place (with some exceptions as specified under FAR 52.222.50(b)(7));

9. providing or arranging housing that fails to meet the host country housing and safety standards, if employer or agent provided or arranged housing; and

10. if required by law or contract, failing to provide an employment contract, recruitment agreement, or other legally required work document in writing in a language the employee understands, containing a detailed description of the terms and conditions of employment at least five (5) days before an employee relocates from their country of origin to perform work.

On an annual basis, Corbus requires all employees to review and compete Ethics Training and certify that they have read and understand this Plan and the Corbus Code of Conduct and agree to comply with the policies, procedures and principles contained therein and report any violations of which they are aware. Corbus may also conduct additional compliance training as needed throughout the year. Such compliance training is targeted and customized for various business units and appropriate to the nature and scope of the activities to be performed.

SUPPLIER COMPLIANCE

In the event that Corbus may engage in work for or on behalf of the U.S. Government, whether as a Government contractor or subcontractor, all Corbus contractors, consultants, vendors, suppliers, sub-contractors and subrecipients (“Suppliers”) would be required to agree to comply with the Plan and all applicable Anti-Trafficking Provisions. Should Corbus engage in such work, Corbus would include language prohibiting the trafficking of person in all Supplier contracts, sub-contracts and sub-agreements (“Supplier Contracts”), including inserting FAR 52.222-50, FAR 52.222-56 and USAID Standard Provisions, where applicable.

In accordance with the foregoing, should any Supplier fails to comply with the Plan or applicable Anti-Trafficking Provisions, Corbus would take appropriate action to remediate the violation and prevent future violations, including, but not limited to:

1. Requiring the Supplier to remove an employee or agent from a project;

2. Requiring the Supplier to terminate its relationship with any Supplier contractor, consultant, supplier, subcontractor or sub-recipient;

3. Suspending payments to Supplier until violation is remedied; or

4. Immediately terminating the Supplier Contract.

In all non-governmental agreements or private sector transactions, the FAR regulations and USAID provisions are not required. Any requirements for Corbus contractors, consultants, vendors, suppliers, sub-contractors and subrecipients shall be made at the discretion of Corbus and in accordance with best practices, as outlined in this Plan.

REPORTING REQUIREMENTS AND PROCEDURES

All employees of Corbus or its suppliers, subcontractors and agents must report any actual or suspected activity or condition that may violate this Plan or federal, state, or international law confidentially and without retaliation. Reports may be made via Corbus’ anonymous ethics hotline (1-844-438-4427 (1-844-4ETHICS) – OR 937-6104008) or anonymous reporting to ethics@corbus.com. Employees may also report their concerns directly to the Global Human Trafficking Hotline at 1-844-888-FREE or its email address at help@befree.org. In addition, reports may be made to any Corbus supervisor, senior management, or HR. Any Corbus supervisor, member of senior management, or HR representative who receives such a report is required to immediately forward the report to Corbus’ General Counsel. Failure of an employee to report an actual or suspected occurrence of the unlawful trafficking of persons, as set forth in this Plan or federal, state, or international law, shall result in the employee’s immediate termination, in addition to any other remedies available at law or equity. Failure of a supplier, subcontractor, or agent to report an actual or suspected occurrence of the unlawful trafficking of persons, as set forth in this Plan or federal, state, or international law, shall result in immediate termination of the business relationship, in addition to any other remedies available at law or equity.

Human Resources and/or General Counsel will investigate all reports of prohibited trafficking-related activity or violations of this Plan and take appropriate action. Corbus will make all required notifications to any government agencies.

Corbus strictly prohibits retaliation against any employee who report prohibited trafficking-related activity or other violations of this Plan, or who cooperates with any internal or government investigations of such reports. Employees may do so without fear of reprisal. Corbus personnel who engage in any form of retaliation against those who report prohibited trafficking-related activities or other violations of this Plan are subject to disciplinary action, up to and including termination of employment. However, Corbus personnel should also be aware that Corbus strictly prohibits acts of knowing or intentional false reporting. Good faith reports of actual or suspected abuse of this Plan or the laws surrounding it are not only encouraged, but required, and all claims of abuse shall be investigated to the highest extent. In the event the any Corbus personnel, supplier, subcontractor, or agent is found to have intentionally, knowingly, or in bad faith reported a false violation of trafficking-related activity, such individual(s) shall be liable for and subject to appropriate disciplinary actions, including termination and all other remedies available at law or equity.

INVESTIGATIONS

If Corbus receives credible information from an employee report or any other source alleging prohibited trafficking related activity, the Corbus General Counsel will conduct an investigation and report its findings and determine, in conjunction with HR and senior management, what, if any, remedial action is appropriate. Corbus will also monitor senior management’s implementation of such remedial action.

General Counsel will be responsible for immediately notifying the appropriate parties of the information received and any resulting remedial action taken. Corbus will cooperate fully with any US Government agencies responsible for any investigations, audits or corrective actions relating to trafficking in persons, including, but not limited to, providing timely and complete responses to document requests, and providing reasonable access to Corbus facilities and staff.

Corbus will protect all employees suspected of being victims of or witnesses to prohibited activities, prior to returning to the country from which the employee was recruited, and will not prevent or hinder these employees from cooperating fully with US government authorities.

POSTING

Corbus will post this Plan on its external website, www.corbus.com. Corbus will also post this Plan at all workplaces, except where the work is being performed in the field, customer site, or not otherwise at a fixed location. Corbus employees or personnel can also request a copy of this Plan at any time. If you have any questions or concerns, do not hesitate to reach out to any Corbus supervisor, senior management, HR, or General Counsel.

[1] “Human Trafficking By The Numbers”. Human Rights First. N.p., 2017. Web. 23 Mar. 2017.

[2] CFR Parts 1, 2, 9, 12, 22, 42, and 52; 48 CFR Parts 203, 204, 212, 222, and 252; and Executive Order 13627

[3] Ohio SB 235 (2010) creates offenses for trafficking in persons and unlawful conduct with respect to documents. Revises the involuntary servitude-related elements of kidnapping, increases the penalty for the offense of abduction based on involuntary servitude and clarifies an element of compelling prostitution that relates to the compelling of another to engage in specified conduct. The bill also includes abduction and trafficking in persons within the offense of conspiracy

[4] The EU Strategy Towards The Eradication Of Trafficking In Human Beings 2012-2016. 1st ed. European Commission, 2017. Web. 23 Mar. 2017.