Anti-Slavery and Human Trafficking Policy

Last Reviewed: Oct. 1, 2019

Summary: This policy sets out Optimizely’s positions on opposing modern slavery and human trafficking as part of Optimizely’s business and supply chain.

Questions? Please contact the Compliance Manager at compliance@optimizely.com

1. ANTI-SLAVERY POLICY STATEMENT

1.1 Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour, and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We are committed to acting ethically and with integrity in our business dealings and relationships and to implementing and enforcing systems and controls to ensure modern slavery is not taking place in our own business or in our supply chains.

1.2 We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with disclosure obligations we may have under applicable law. We expect the same standards from our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children.

2. WHO MUST COMPLY WITH THIS POLICY?

2.1 This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

3. WHO IS RESPONSIBLE FOR THIS POLICY?

3.1 Optimizely’s legal team has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. A member of the Optimizely Legal has been nominated as the Compliance Manager, and can be reached at compliance@optimizely.com.

3.2 The Compliance Manager has primary responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and reviewing internal control systems and procedures to ensure they are effective in countering modern slavery.

3.3 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy.

4. YOUR COMPLIANCE WITH THIS POLICY

4.1 You must ensure that you read, understand and comply with this policy.

4.2 The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

5. HOW AND WHEN TO NOTIFY IN CASE OF NON-COMPLIANCE

5.1 You must notify the Compliance Manager as soon as possible if you believe or suspect that a breach of this policy, has occurred, or may occur in the future.

5.2 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains at the earliest possible stage.

5.3 If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with the Compliance Manager.

6. BREACHES OF THIS POLICY

6.1 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.