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UKG Modern Slavery Statement 2021

This Modern Slavery Statement describes UKG’s commitment to ensuring that slavery and human trafficking is not taking place in our business or within our supply chain. This Statement is made with reference to the calendar year ending 31 December 2021.

UKG adheres to the principles found in the United Nations Universal Declaration of Human Rights, which prohibits:

  • the use of any form of forced labor, including indentured labor, bonded labor, physical confinement in the work location;
  • exploitative practices, such as forced overtime and limited access to documentation including passports, identity papers and travel documents; and
  • support for or engagement in any form of human trafficking or involuntary labor through threat, force, fraudulent claims, or other coercion.

UKG complies with the UK Modern Slavery Act 2015, the Modern Slavery Act 2018 (Australia), and other applicable anti-slavery laws.

Our Commitment

UKG is a leader in workforce management and human capital management software. We recognize the important role we can play in helping protect the rights of people throughout the world where we do business. At UKG, our purpose is people. We are committed to achieving this purpose by living our core values—United, Kind, and Giving—every day and in everything that we do. Our culture is an intentional one—one that invites and values diverse perspectives, actively sacrifices individual preferences in order to benefit the greater, values transparency and kindness, is adaptive and agile, offers support and unlimited opportunities for growth, and relentlessly pursues great outcomes.

Embedded in our culture is a profound commitment to doing the right thing for our employees, customers, and other stakeholders. This includes actively working to earn and maintain trust by showing consistency between our words and actions, by being transparent, and by taking personal and collective responsibility for the decisions we make and the outcomes that follow.

As is reflected in our Human Rights Policy, we are committed to respecting internationally recognized human rights in our operations, which includes our employees and those in our supply chain, in our products, and in our communities. This commitment is informed by our adherence to the United Nations Guiding Principles on Business and Human Rights (UNGPs). This means we aim to respect the rights of all individuals affected by our business and will work to address any adverse impacts that we may cause or to which we may contribute. It also means that we seek to mitigate adverse human rights impacts that are directly linked to our operations, products, or services by our business relationships with third parties, including those in our supply chain (collectively, “partners”). We also believe that we can serve as a catalyst for action by our partners.

Policies

To reinforce our Company values, UKG has a variety and tools to help our employees understand and live those values. This includes our Code of Business Conduct and Ethics (the “Code”), which describes how UKG employees are expected to act when conducting business on behalf of the Company. It also includes specific training on living our values, and various programs, teams, and resources designed to help us ensure that we foster a culture that supports those values. UKG also has policies that support our commitment to human rights and compliance with modern slavery laws, including:

  • Human Rights Policy
  • Anti-Money Laundering Policy
  • Employee Handbook (which addresses numerous human rights and labor practices related policies)
  • Conflict of Interest Policy
  • Anti-Corruption Policy
  • Privacy Policy
  • Information Security Polices

Note that, in 2021, the Company updated its modern slavery statement in its Code as follows:

The Company complies with modern slavery prevention laws, including the Modern Slavery Act 2015 (UK), and the Modern Slavery Act 2018 (Australia). This includes not using underage labor, as defined under applicable law, and not employing workers below the age of 18 in jobs that are likely to jeopardize their health and safety. The Company only uses voluntary labor and employees who have the proper work-related documentation and is otherwise committed to taking steps to ensure compliance with those laws. This commitment applies to UKG and its suppliers.

Supply Chain

UKG uses a risk-based approach when evaluating suppliers. Modern slavery, human trafficking, and other topics consistent with our core values are included as part of our standard supplier due diligence processes. New suppliers are required to attest to UKG’s Supplier Code—including as it concerns employment and labor practices, compliance with regulatory requirements, and health and safety protections—prior to UKG doing business with them. Consistent with our commitment to have all suppliers bound by our Supplier Code, UKG has also made considerable progress incorporating our Supplier Code into relationships with our existing suppliers when those contracts come up for renewal.

UKG’s Strategic Sourcing Team is responsible for leading our supplier due diligence process and other key supply chain initiatives worldwide, including ensuring that:

  • Our suppliers comply with our Supplier Code (or alternatively demonstrate that their own Code requirements are representative of the provisions outlined in the UKG Supplier Code), have ethical business practices, safe and healthy working conditions, and strive for continuous improvement with respect to human rights-related issues;
  • UKG engages in responsible sourcing and seeks out suppliers that support our business innovation goals; and
  • UKG achieves greater supplier diversity.

In instances where UKG determines it must use a supplier from a country that is considered a higher risk, UKG’s Strategic Sourcing Team will conduct enhanced due diligence and take additional precautions where and as appropriate. This includes implementing enhanced audit/evaluation processes, conducting on-site visits, and otherwise taking additional steps to ensure that the supplier understands and adheres to UKG’s Supplier Code.

UKG complies with applicable U.S. sanctions and embargo laws and regulations. Neither UKG nor its directors, officers, employees, or suppliers are listed on the U.S. Department of the Treasury Office of Foreign Assets Control or Specially Designated Nationals List. UKG does not conduct business in any U.S. sanctioned country, including Cuba, Iran, Iraq, Libya, North Korea, Syria, and Sudan.

Employment and Working Practices

UKG has robust recruiting processes that meet or exceed local laws, including right to work document checks, employment contracts for all employees, and checks to ensure that all employees are above the minimum working age. Our pay and benefits packages are reviewed annually, and they are linked to appropriate benchmarks. UKG has consistently received awards for how it treats its most important asset—it’s people.

Throughout the pandemic, we have prioritized the health and safety of our workforce. This includes establishing a Covid Advisory Committee that consists of senior leadership within the Company, and a Covid Operating Committee comprised of key cross-functional employees, to engage on and drive our response to key pandemic-related issues. This includes taking steps to ensure employees are equipped to work productively from home, imposing business travel restrictions (and an approval process), implementing a thoughtful and voluntary approach to returning to the office for fully vaccinated employees in certain locations, providing training and other tools for all levels within the Company, and implementing a Covid dedicated reporting line and intranet site.

Training

UKG has a robust compliance training program for all employees. This program provides employees with training on various topics, including our Code and modern slavery, data privacy and security, and harassment and discrimination—among other required courses. New employees are also required to review and acknowledge our Code and other key policies as part of their onboarding.

Reporting

The UKG ReportingLINE is available for employees or third-parties to ask questions or report concerns about various matters, including the topics described in this Statement.

Liz McCarron, EVP, Chief Legal Officer | UKG
Date: January 25, 2022