Anti-Slavery and Human Trafficking Statement

Last updated: November 2022

 This statement is made on behalf of Upland Software, Inc., (“Upland” or “Company”) 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.

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 customers.

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. Although we engage with suppliers for a range of services, the majority of our suppliers provide us with hosting, network, and software services.

Our Policies

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 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.

Due Diligence

Each of Upland’s vendors and partners are assessed 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 human trafficking.  Additionally, Upland’s partners and suppliers are assessed on a continuous basis to verify they are continuing to abide by their obligations.

If a vendor or supplier fails to provide adequate assurance prior to engagement or reassurance during an audit of their commitment to anti-slavery and human trafficking, Upland will seek further information to assess whether they can continue the relationship with the supplier or vendor. In certain cases, Upland may terminate or no longer pursue a relationship with that particular supplier or vendor.

Evaluating Risk

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 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.