Legal Posture

Axya Inc. will not engage in legal action against individuals who submit vulnerability reports through our Vulnerability Reporting inbox. We openly accept reports for the currently listed Axya Inc. products.

We agree not to pursue legal action against individuals who:

• Engage in testing of systems/research without harming Axya Inc. or its customers.

• Engage in vulnerability testing within the scope of our vulnerability disclosure program.

• Test on products without affecting customers, or receive permission/consent from customers before engaging in vulnerability testing against their devices/software, etc.

• Adhere to the laws of their location and the location of Axya Inc. For example, violating laws that would only result in a claim by Axya Inc. (and not a criminal claim) may be acceptable as Axya Inc. is authorizing the activity (reverse engineering or circumventing protective measures) to improve its system.

• Refrain from disclosing vulnerability details to the public before a mutually agreed-upon timeframe expires.

Policy

Vulnerability Report/Disclosure

How to Submit a Vulnerability

To submit a vulnerability report to Axya Inc.’s Product Security Team, please utilize the following email security@axya.co.

Preference, Prioritization, and Acceptance Criteria

We will use the following criteria to prioritize and triage submissions.

What we would like to see from you:

• Well-written reports in English will have a higher probability of resolution.

• Reports that include proof-of-concept code equip us to better triage.

• Reports that include only crash dumps or other automated tool output may receive lower priority.

• Reports that include products not on the initial scope list may receive lower priority.

• Please include how you found the bug, the impact, and any potential remediation.

• Please include any plans or intentions for public disclosure.

What you can expect from Axya Inc.:

• A timely response to your email (within 2 business days).

• After triage, we will send an expected timeline, and commit to being as transparent as possible about the remediation timeline as well as on issues or challenges that may extend it.

• An open dialog to discuss issues.

• Notification when the vulnerability analysis has completed each stage of our review.

• Credit after the vulnerability has been validated and fixed.

If we are unable to resolve communication issues or other problems, Axya Inc. may bring in a neutral third party to assist in determining how best to handle the vulnerability.

Whistle Blowing

How to Submit a Report

To anonymously report an information security program violation or a violation of related laws and regulations, please email over question@axya.co

Preference, Prioritization, and Acceptance Criteria

We will use the following criteria to prioritize and review submissions.

What we expect from you:

• Detailed report made in good faith or based on a reasonable belief.

◦ Good Faith means the truthful reporting of a company-related violation of information security policies, procedures, or regulations, as opposed to a report made with reckless disregard or willful ignorance of facts.

◦ Reasonable Belief refers to the subjective belief in the truth of the disclosure AND that any reasonable person in a similar situation would objectively believe based on the facts.

• Details of the violation (i.e., what, how, why).

• Details of the reported event, with facts (i.e., who, where, when).

• You are NOT responsible for investigating the alleged violation, or for determining fault or

corrective measures.

What you can expect from Axya Inc.:

• Your report will be submitted to the Security team for review.

• Protection of your identity and confidentiality.

◦ CAVEAT: It may be necessary for your identity to be disclosed when a thorough investigation, compliance with the law, or due process of accused members is required.

• Protection against any form of retaliation and harassment, such as termination, compensation decreases, or poor work assignments, and threats of physical harm.

◦ If you believe that you are being retaliated against, immediately contact HR.

◦ Any retaliation or harassment against you will result in disciplinary action.

◦ CAVEAT: Your right for protection against retaliation does not include immunity for any personal wrongdoing alleged in the report and investigated

• Due process for you and for the accused member(s).

• Corrective actions taken to resolve a verified violation and a review and enhancement of applicable policies and procedures, if necessary or appropriate.

• Continuous information security awareness training and understanding your rights as a whistleblower.