p.6

"As described in the 2022 ESG Report, IBM judiciously follows the RBA audit process, requiring root cause and corrective actions to be implemented for all Code nonconformance. Corrective Action Plan (CAP) implementation is reviewed by the internal IBM team prior to RBA re-audits performed on all nonconformant findings, including those associated with the Freely Chosen Labour provision of the Code. IBM treats all nonconformance as a serious issue and invests considerable time working with its suppliers to advise on best practices to attain and maintain code conformance."

pg. 6

"The 26 nonconformant findings are summarised as follows:

(5) In prohibited recruitment situations and where workers were charged transportation and hiring fees, workers were reimbursed within three months"