The Board of Directors and management of TaxModel International, located at Stationsplein 12, 5211 AP, ‘s-Hertogenbosch, which is in the business of developing off-the-shelf tax technology, are committed to preserving the confidentiality, integrity and availability of all the physical and electronic information assets throughout their organization in order to preserve its competitive edge, cash-flow, profitability, legal, regulatory and contractual compliance and commercial image. Information and information security requirements will continue to be aligned with TaxModel International‘sgoals and the ISMS is intended to be an enabling mechanism for information sharing, for electronic operations, and for reducing information-related risks to acceptable levels.

TaxModel International‘s current strategic business plan and risk management framework provide the context for identifying, assessing, evaluating and controlling information-related risks through the establishment and maintenance of an ISMS. The Risk Assessment, Statement of Applicability and Risk Treatment Plan identify how information-related risks are controlled. TaxModel International‘s security officer is responsible for the management and maintenance of the risk treatment plan. Additional risk assessments may, where necessary, be carried out to determine appropriate controls for specific risks.

In particular, business continuity and contingency plans, data backup procedures, avoidance of viruses and hackers, access control to systems, and information security incident reporting are fundamental to this policy.

All employees of TaxModel International and certain external parties identified in the ISMS are expected to comply with this policy and with the ISMS that implements this policy. All employees and certain external parties will receive appropriate training. The consequences of breaching the information security policy are set out in TaxModel International‘s disciplinary policy and in contracts and agreements with third parties.

The ISMS is subject to continuous, systematic review and improvement.

TaxModel International has established an ISMS steering group, chaired by the Chief Executive Officer (CEO), Information Security Officer, and the Head of IT to support the ISMS framework and to periodically review the security policy.

TaxModel International is committed to keeping certification of its ISMS to ISO27001:2013.

This policy will be reviewed to respond to any changes in the risk assessment or risk treatment plan and at least annually.

In this policy, ‘information security‘ is defined as:

Preserving

This means that management, all full time or part time employees,sub-contractors, project consultants and any external parties have, and will be made aware of, their responsibilities (which are defined in their job descriptions or contracts) to preserve information security, to report security breaches (in line with the policy and procedures identified in Section 16 of the Manual) and to act in accordance with the requirements of the ISMS. All employees will receive information security awareness training and more specialized employees will receive appropriately specialized information security training.

the availability,

This means that information and associated assets should be accessible to authorized users when required and therefore physically secure. The computer network must be resilient and TaxModel International must be able to detect and respond rapidly to incidents (such as viruses and other malware) that threaten the continued availability of assets, systems and information. There must be appropriate business continuity plans.

confidentiality

This involves ensuring that information is only accessible to those authorized to access it and therefore to preventing both deliberate and accidental unauthorized access to TaxModel International‘s information and proprietary knowledge and its systems including its network(s), website(s), extranet(s), and e-commerce systems.

and integrity

This involves safeguarding the accuracy and completeness of information and processing methods, and therefore requires preventing deliberate or accidental, partial or complete, destruction or unauthorized modification, of either physical assets or electronic data. There must be appropriate contingency including for network(s), e-commerce system(s), website(s), extranet(s) and data backup plans and security incident reporting. TaxModel International must comply with all relevant data-related legislation in those jurisdictions within which it operates.

of the physical (assets)

The physical assets of TaxModel International including, but not limited to, computer hardware, data cabling, telephone systems, filing systems and physical data files.

and information assets

The information assets include information printed or written on paper, transmitted by post or shown in films, or spoken in conversation, as well as information stored electronically on servers, website(s), extranet(s), intranet(s), PCs, laptops, mobile phones and PDAs,as well as on CD ROMs, floppy disks, USB sticks, backup tapes and any other digital or magnetic media, and information transmitted electronically by any means. In this context, ‘data‘ also includes the sets of instructions that tell the system(s) how to manipulate information (i.e. the software: operating systems, applications, utilities, etc.).

Of TaxModel International.

The ISMS is the Information Security Management System, of which this policy and other supporting and related documentation is a part, and which has been designed in accordance with the specification contained in ISO27001:2013.

A SECURITY BREACH is any incident or activity that causes, or may cause,a break down in the availability, confidentiality or integrity of the physical or electronic information assets of TaxModel International.