[company name] Statement Against Modern Slavery and Child Labor

[year] statement

According to the International Labour Organization (ILO), 40 million people were victims of modern slavery and 152 million children were subject to child labor globally in [year]. As the ILO reports:

1 in 4 victims of modern slavery are children.

Out of the 24.9 million people trapped in forced labour, 16 million people are exploited in the private sector such as domestic work, construction or agriculture; 4.8 million persons in forced sexual exploitation, and 4 million persons in forced labour imposed by state authorities.

Women and girls are disproportionately affected by forced labour, accounting for 99% of victims in the commercial sex industry, and 58% in other sectors.

[company name] deplores the presence and persistence of modern slavery and child labor, and takes seriously its responsibility to ensure that neither modern slavery nor child labor takes place in its supply chain or in any part of its business. ("Modern slavery" in this statement refers to slavery, forced or compulsory labor, trafficking, servitude, and workers who are imprisoned, indentured, or bonded. "Child labor" refers to work performed by someone under 16 years of age, or under 14 for light work, provided it is not confined to periods that interfere with the child's schooling and not in conditions that interfere with the child's health or well-being.)

In accordance with the UK Modern Slavery Act, and in alignment with the ILO 2014 Protocol to its Forced Labour Convention, ILO Declaration on Fundamental Principles and Rights at Work, and United Nations Sustainable Development Goals target 8.7, this 2018 Statement Against Modern Slavery and Child Labor ("the Statement") describes the steps [company name] has taken to prevent modern slavery and child labor from occurring in its business or supply chain.

[company name]'s structure, business, and supply chains

[company name] is a software development platform with its headquarters in San Francisco, and employees and contractors working in numerous countries.

All [company name] employees and individual independent contractors are voluntary and at-will. [company name] has a largely distributed workforce, and strives to provide competitive compensation and benefits to its employees and contractors regardless of location. This is true whether we hire independent contractors directly or through an intermediary.

[company name] does not conduct manufacturing or produce hardware, nor does [company name] use recruitment agencies for the kinds of services often performed by migrant workers. The nature of [company name]'s business does not subject it to sudden changes in workload or pricing pressures, which often drive demand for practices that increase the risk of forced labor in supply chains, such as forced overtime.

[company name] offers free and paid software and web-based software as a service to customers all over the world. [company name]'s products include:

[company name].com: web-based collaboration and code-hosting platform

[company name] Enterprise: on-premises collaboration and code hosting software

Electron: framework for writing cross-platform desktop apps

[company name] Desktop: desktop app for accessing [company name].com and [company name] Enterprise

[company name]'s supply chain consists of goods and services for our products and operations including computing services, event planning, purchase of retail and promotional items, office supplies, and leasing of facilities such as office space and data centers.

Policies in relation to modern slavery and child labor

Modern slavery and child labor

[company name]'s Code of Ethics prohibits knowingly using, participating in, supporting, or tolerating modern slavery (slavery, forced or compulsory labor, trafficking, servitude, or workers who are imprisoned, indentured, or bonded) or child labor in its business operations. Any [company name] employee or contractor who violates this prohibition will be subject to termination of employment or business relationship.

[company name]'s Standards of Conduct prohibit unsafe and illegal conduct, including knowingly using, participating in, supporting, or tolerating modern slavery (slavery, forced or compulsory labor, trafficking, servitude, or workers who are imprisoned, indentured, or bonded) or child labor.

[company name] complies with laws prohibiting trafficking and child labor in the jurisdictions in which it operates, including U.S. Federal Acquisition Regulation 22.17 on combatting human trafficking.

Going forward, [company name] will communicate this Statement to all employees, contractors, and suppliers, including recruiters and employment agencies. In addition, [company name] is developing training for all [company name] employees on modern slavery and child labor. [company name] posts its Statement Against Modern Slavery and Child Labor publicly.

[company name] has a non-retaliation policy for reporting workplace-related concerns. Consistent with this Statement, [company name] allows employees and contractors to report issues regarding modern slavery and child labor without fear of retaliation.

Labor laws and practices

[company name]'s labor practices are

fair:

[company name] pays its employees and contractors a fair wage, in accordance with applicable legal wages

[company name] maintains humane working conditions

[company name] does not require workers to exceed the maximum hours of daily labor set by local and national laws or regulations

[company name] pays its employees and contractors in a timely manner, with documentation (such as a pay stub) stating the basis on which they are paid, and keeps employee records in accordance with local and national laws

humane and ethical:

[company name] uses only voluntary labor

[company name] prohibits child labor

[company name] does not engage in physical discipline or abuse

[company name] does not tolerate harassment or unlawful discrimination in the workforce or workplace

respectful:

[company name] protects its employees' rights to freedom of association and collective bargaining in accordance with legal requirements, including to post legal notices of employees' rights under the National Labor Relations Act

[company name] provides benefits to employees at or in excess of levels expected in the industry

[company name] encourages employees to report any workplace complaint and does not tolerate retaliation for reporting

Due diligence processes in relation to modern slavery and child labor in its business and supply chains

[company name] assesses its business and supply chain for risks related to modern slavery and child labor. Drawing on internal and external human rights expertise, [company name] engaged in a cross-functional analysis (including Policy, Legal, Procurement, Finance, and Operations, especially Human Resources) to determine where labor services exist in its business and supply chain and to identify potential risks related to modern slavery and child labor. [company name] prioritizes areas where those risks might be more significant in terms of severity, scale, or probability for greater due diligence, monitoring, and verification. [company name] continues to consider where risks may occur and how to address them. In addition, [company name] now obtains its suppliers' assurance that they have practices consistent with this Statement, including by complying with laws related to modern slavery or child labor.

Places in [company name]'s business and supply chains where there is a risk of modern slavery and child labor, and steps [company name] has taken to assess and manage that risk

[company name] has not identified any high-risk suppliers; however, modern slavery or child labor would be more likely to occur with suppliers for services involving manual labor, such as event support, construction, facilities services, and food services. [company name] will audit its existing suppliers and require those in such higher risk areas to confirm that they provide services consistent with this Statement.

Although [company name] knows of no actual or alleged modern slavery or child labor in its business or supply chain, and has no credible basis to believe it is occurring, [company name] is committed to providing remedies if [company name] itself were to directly cause modern slavery or child labor and to remediation of broader patterns of non-conformance with this Statement caused by deficiencies in [company name]'s systems or processes. [company name]'s remediation to individual victims would include protocols for appropriate immediate action to eliminate the modern slavery and child labor practices, along with resources for reasonable and appropriate victim services designed to offset the harm experienced.

Effectiveness in ensuring neither modern slavery nor child labor is occurring in [company name]'s business or supply chains

[company name] complies and will continue to comply with laws related to modern slavery and child labor.

Going forward, [company name] now requires its suppliers to comply with this Statement, as well as laws related to modern slavery and child labor. [company name] now also requires its suppliers to:

Not use, participate in, support, or tolerate modern slavery or child labor

Not use misleading or fraudulent recruitment or engagement practices for employees or contract workers

Not charge employees or contract workers recruitment or engagement fees

Not destroy, conceal, confiscate, or otherwise deny access by an employee or any contract worker to passport, driver's license, or other identity documents;

Allow us to terminate our agreements with them for any violation of its obligations related to modern slavery or child labor; and

Remediate any harms caused to any worker found to be subjected to any form of modern slavery or child labor, if required by law.

In addition, [company name] strongly encourages its suppliers to:

Conduct anti-modern slavery and child labor due diligence processes, including risk assessments, for their suppliers;

Take steps to address risks identified; and

Use similar anti-modern slavery and child labor language with their suppliers.

[company name]'s procurement instructions to employees making company purchases now includes a reference to the requirement for suppliers to comply with Microsoft's Supplier Code of Conduct or this Statement.

Training for [company name] staff about modern slavery and human trafficking

[company name] is developing modern slavery and child labor training that will be mandatory for all employees, with a view to [company name]'s business and supply chain. [company name] will emphasize suppliers providing services involving manual labor, such as event support, construction, facilities services, and food services, as areas of greater potential risk.

[company name]'s Board of Directors approved this Statement.