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SITECORE TRUST CENTER

Slavery and Human Trafficking Statement

FY 2020

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Slavery and Human Trafficking Statement

Pursuant to section 54 of the Modern Slavery Act 2015, this is Sitecore UK Ltd.’s Slavery and Human Trafficking Statement (“Statement”) for the financial year ended 30 June 2020.

Business Overview

Sitecore UK Limited (Company No. 05505160) is a subsidiary of Sitecore Holding II A/S, a Danish limited liability company (CVR. No. 37624071) (collectively referred to as “Sitecore”). All Sitecore entities are subject to the same internal governance standards as detailed in this Statement.

Sitecore is a global leader in experience management software tools that combine content management, commerce, and customer insights. Sitecore products are used to empower marketers to deliver personalized content in real time and at scale across every channel in the consumer lifecycle. Our primary business activities involve software development, sales and customer support.

As a global software company, with offices in North America, Europe, Australia, the Middle East and Asia, and over 1300 employees, Sitecore is committed to acting ethically as a good corporate citizen, with integrity in all of our business relationships. We have implemented and enforce systems and controls to ensure slavery and human trafficking is not, to the best of our knowledge, taking place anywhere in our supply chains. To achieve this, we have established monitoring and risk management processes outlined in this Statement to ensure continuous oversight of our suppliers and ongoing compliance obligations.

Our Supply Chains

Suppliers are a critical part of Sitecore’s operations and help us to drive our business, fulfil contractual obligations and meet our strategic goals. Our suppliers include the following:

  • HR and payroll service providers which help us administer employee salary and benefits;
  • Technology partners which support Sitecore with the development and delivery of product solutions and services to our customers;
  • Departmental service providers such as companies which automate our services or drive efficiencies (for example database management or lead generation);
  • Cloud service providers which provide underlying cloud solutions which enable us to offer our cloud products; and
  • Facilities vendors such as caterers and repair services.

Services are performed by suppliers who have relevant experience and, for specialist advisors or those in a regulated profession, are qualified and/or accredited personnel for the services that they have been engaged for.

Internal Policies and controls

Sitecore works with suppliers that share our core values and help us promote a respectful workplace environment that values ethics, complies with the law, and believes in social responsibility. They are required to take steps to prevent modern slavery in their own businesses and supply chains. To achieve this, Sitecore has implemented the following policy and control functions to help prevent forced labor, slavery and human trafficking:

Internal Policies

  • Supplier Code of Conduct - At Sitecore, we engage with reputable suppliers and set clear expectations which are outlined in our Supplier Code of Conduct (“Supplier Code”). This Supplier Code requires suppliers to – among other things – abide by labor standards in regions of Sitecore business operations, not engage in bribery, and provide a safe and healthy work environment. The Supplier Code is shared with and acknowledged by all our global suppliers as part of our vendor contract negotiation and onboarding process. We expect our suppliers to establish policies and procedures to ensure compliance with the Supplier Code and all applicable laws. Our Supplier Code of Conduct is available here.
  • Sitecore’s Code of Business Conduct – Sitecore has an internal Code of Business Conduct (“Code of Conduct”) for its personnel, which sets forth our expectations of lawful and ethical behaviour. This Code of Conduct describes Sitecore’s fundamental organizational values, indicates how all personnel will conduct business activities and provides guidance on how to follow company policies in accordance with applicable laws.

Controls

  • Supplier Agreements – Prior to engagement, all suppliers are onboarded in accordance with Sitecore’s procurement processes, which requires legal terms and conditions in supplier agreements to be reviewed by Sitecore’s Legal team.
  • Employees – All new employees are subject to background checks (to the extent permitted by law).
  • Diversity and inclusion – Sitecore has increased its focus on diversity and inclusion within the company, ensuring further that modern slavery, in any form, does not go undetected in our recruitment process.

Due Diligence and Audits

Due Diligence

  • Sitecore undertakes risk assessments of potential suppliers as part of our supplier onboarding process. These risk assessments review the performance of suppliers based on their relative risk to the company and are completed by cross-functional stakeholders, including the Legal and Security teams.
  • Risk assessments will factor in the type of service that the supplier is providing, industry risks, and geographical risks.
  • Sitecore does not select suppliers based purely on quality of service or pricing but also considers location, reputation of suppliers, and supplier business practices

Non-compliance

  • Any instances of non-compliance detected are reported to the Legal team which will take appropriate action, including disciplinary action with respect to any employee, reporting to a regulator or law enforcement agency, conducting an audit of a supplier, or making recommendations to terminate any supplier relationship.

Whistleblowing

  • Sitecore maintains a communication channel, outlined in the Code of Business Conduct, to enable staff to confidentially submit concerns or file a report relating to any unethical business practice.
  • Our employees are expected to report code violations or any ethical concerns, including modern slavery, using the appropriate channels. At the same time, our commitment to conducting business with integrity requires that we take all reports seriously, investigate them fairly and confidentially, and take action where needed.

Training and Awareness

Sitecore requires all internal employees to take an annual Code of Business Conduct training, including as part of the mandatory onboarding process for new hires. This training includes slavery and human trafficking awareness. Employees receive a certification of completion at the end of the training that confirms they understand the policy.

In turn, all suppliers are expected to communicate the principles in the Supplier Code to their employees.

Further steps

Next year, Sitecore will continue to assess the effectiveness of its policies and programs to measure performance and identify areas for continued improvement. We will continue to review our compliance, including considering our due diligence processes around slavery and human trafficking, ensuring that our suppliers adhere to the same values and ethics, implementing staff training where necessary, and monitoring our effectiveness in ensuring that slavery and human trafficking is not taking place in any part of our business.

This Statement was approved by the Board of Directors of Sitecore UK Ltd. on 19 March 2021.

Signed on behalf of the Board.

Sitecore UK Ltd.

Rich Foehr
Director

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