Information security policy at Sponge.

Sponge Germany GmbH

Hardenbergstr. 32
10623 Berlin
Phone: +49 30 841914-0

Email: berlin@spongelearning.com

Limited liability company based in Berlin
Managing Director: Adam Poulter
District Court: Charlottenburg, HR B 90 643
VAT Identification Number: DE 173211552

The Policy of Sponge is, on a continuing basis, to exercise due care and due diligence to protect Information systems from unauthorized access, use, disclosure, destruction, modification, disruption or distribution. This will ensure that our reputation with our clients, and all related interested parties is maintained through confidentiality, integrity and availability.

Management will commit to adhering to business, legal, regulatory, applicable requirements and contractual security obligations. Risk Assessment against agreed criteria is routinely undertaken through monthly Information Security risk reviews and management reporting.

Management has responsibility for establishing and maintaining the system and undertakes to ensure its integrity is maintained through instruction, policies and training of its staff and that each employee has a proper understanding of what is required of them.

Equally every employee has a personal responsibility to maintain this integrity.

Furthermore, Management will ensure any contractor employed for a particular function will meet the requirements specified and accept responsibility for their actions.

The company has a Policy of Continual Improvement and Objective setting in line with the ISO 27001:2022 Standard requirements.

Objectives and Targets are set to meet the requirements of this policy and are reviewed regularly at management reviews to enable continual improvement. The policy will be made available to interested parties as appropriate.

The Information Security Management System will be monitored regularly.