Anti-Slavery and Human Trafficking Statement
Last updated: November 2023
This Anti-Slavery and Human Trafficking Statement is made on behalf of Upland Software, Inc., (“Upland”) and its wholly owned subsidiaries, pursuant to section 54(1) of the Modern Slavery Act 2015 and the California Transparency in Supply Chain Act 2010 and constitutes Upland’s position with regards to modern instances of slavery, forced labor, and human trafficking (“Modern Slavery”).
Organizational Structure and Supply Chain
Upland, a United States based organization, is the parent company of various subsidiaries doing business internationally, including, but not limited to, Australia, Canada, Ireland, Israel, and the United Kingdom. Upland generates revenue by delivering cloud-based software solutions to its customers.
At Upland, we encourage only the highest of standards, not only from our staff and business, but also from our suppliers and partners. We do not tolerate any type of Modern Slavery within our supply chain or operations. The organization is committed to preventing Modern Slavery in its corporate activities throughout the entirety of our services provided to customers. Although we engage with suppliers for a range of services, with most of our suppliers providing Upland with hosting, network, and software services, Upland is still very conscious and considerate that Modern Slavery can occur in all industries and supply chains.
Upland’s Code of Business Conduct and Ethics (“Code”) is consistent with the Company’s commitment to human rights and fair labor and its policy against Modern Slavery. A program of work is currently underway to assess any areas in our supply chain where there may be a risk of Modern Slavery.
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 staff has any concerns or suspicions that Modern Slavery 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.
Each of Upland’s partners and suppliers are assessed by Upland prior to engagement to make sure they can meet and comply with Upland’s policies as described above and includes a risk assessment to determine whether a particular partner or supplier is a particular “high risk” for Modern Slavery.
Upland’s partners and suppliers are assessed on a continuous basis by Upland to verify they are continuing to abide by their obligations. If a partner or supplier fails to provide adequate assurance prior to engagement or reassurance during an audit of their commitment against Modern Slavery, Upland will seek further information to assess whether they can continue the relationship with the partner or supplier. In certain cases, Upland may terminate or no longer pursue a relationship with that partner or supplier.
Additionally, when recruiting new staff, Upland conducts due diligence, including, but not limited to pre-employment screening and as allowed under the law of the applicable jurisdiction, to identify any instances of Modern Slavery that may be occurring with new staff. For staff that is a contractor or consultant, Upland also conducts due diligence to assess the potential for Modern Slavery based on the relationship between Upland and the contractor or consultant.
Evaluating Risk and Management
Risks occur for Upland based on its contractual relationships, as a global company, and from the recruitment of staff. To address these risks, we conduct due diligence as a set forth above, and continuously review relevant policies to account for the global nature of Upland’s business and its continuous engagement of staff, partners, and suppliers across the globe.
Upland is developing a program to evaluate supplier risk and measure performance pursuant 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 in their own supply chain. Any supplier considered to be “at risk” will be notified and given an opportunity to respond to the risks.
Upland provides training and guidance on Modern Slavery, including on how to identify both, and further provides guidance on what actions to take if staff suspects a case of Modern Slavery.
Upland will ensure that staff involved in procuring partners and suppliers, and including in the recruitment of staff, receive training on Modern Slavery.
This Statement is approved for Upland Software, Inc., and its wholly owned subsidiaries.
Last updated: November 2023