Anti-Slavery and Human Trafficking Statement

Last updated: June 2021

This statement is made on behalf of Upland Software, Inc. and its wholly owned subsidiaries pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”) and constitutes Upland’s anti-slavery and human trafficking statement.

Who We Are and How We Do Business

Upland Software is a leader in cloud-based tools for digital transformation. At Upland, we encourage only the highest of standards, not only from our employees and business but also, from our suppliers and partners. We do not tolerate any type of forced labor, human trafficking, or slavery within our supply chain or operations. The organization is committed to preventing slavery and human trafficking in its corporate activities.

Our Supply Chain

We are a Saas company with a relatively small supply chain because our people, their expertise, and our intellectual property are our business. Although we engage with suppliers for a range of services, the majority of our suppliers provide us with network services and software.

Our Policies

Upland’s Code of Business Conduct and Ethics is consistent with the Company’s commitment to human rights and fair labor and its policy against slavery and human trafficking. A program of work is currently underway to assess any areas in our supply chain where there may be a risk of modern slavery and/or human trafficking.

All Company business is to be conducted with the highest standard of integrity and in compliance with all applicable laws and regulations. This Code applies to the Company and all its subsidiaries worldwide.

Upland’s Ethics Helpline Policy encourages reporting any improprieties, whether actual or suspected, including those related to the direct activities or the supply chains of the organization. The prevention, detection, and reporting of modern slavery in any part of our business or supply chain is the responsibility of all of those working for us. If employees have any concern or suspicion that modern slavery or human trafficking is taking place in any part of our business or supply chain, they are urged to report such concerns pursuant to our Ethics Helpline Policy.

Evaluating Risk

Upland is developing a program to evaluate supplier risk, depending on the type of product or service being supplied and the country where the service is performed. Where a supplier is deemed to be “high risk”, Upland will require evidence from the supplier that they have written policies and effective procedures in place to control the risk of modern slavery and human trafficking in their own supply chain. Any supplier considered to be “at risk” will be notified and given an opportunity to respond to the risks.