Policies

Modern Slavery Statement
SparkGrid Software, Inc.
Financial Year: 2025
Published: December 2024

1. Introduction
   This statement is made pursuant to Section 54(1) of the UK Modern Slavery Act 2015 and constitutes
   SparkGrid Software, Inc.'s ("SparkGrid" or "the Company") slavery and human trafficking statement for the
   financial year ending December 31, 2025.
   SparkGrid is committed to preventing modern slavery and human trafficking in all its forms within our business
   operations and supply chains. We recognize our responsibility to ensure that our business practices uphold
   fundamental human rights and labor standards.

2. Organization Structure and Business
   SparkGrid Software, Inc. is a software-as-a-service (SaaS) company headquartered in the United States. We
   develop and maintain Box Connector, a HubSpot integration platform that enables seamless file management,
   workflow automation, and e-signature capabilities for businesses worldwide.
   Our Business Model:
   Cloud-based software development and delivery
   Subscription-based SaaS licensing
   Professional services and customer support
   Integration development for enterprise platforms (HubSpot and Box)
   Geographic Operations:
   Primary operations based in the United States
   Customer base spanning multiple countries and regions
   Remote workforce operating across various locations

3. Our Supply Chains
   As a software company, SparkGrid's supply chain is relatively limited compared to manufacturing or retail
   organizations. Our primary supply chain components include:
   Technology Infrastructure:
   Cloud computing services (AWS, Azure, Google Cloud)
   Software development tools and platforms
   Third-party API services and integrations
   Communications and collaboration platforms
   Professional Services:
   Software development contractors and consultants
   Marketing and creative services
   Legal and accounting services
   Customer support services
   Corporate Operations:
   Office equipment and supplies
   IT hardware and devices
   Professional services (legal, accounting, insurance)

4. Policies and Commitments
   SparkGrid maintains the following policies and commitments related to modern slavery and human trafficking:
   4.1 Ethical Business Practices
   We are committed to conducting business ethically and with integrity. We expect all employees, contractors, and
   business partners to:
   Comply with all applicable labor laws and regulations
   Respect fundamental human rights
   Maintain fair employment practices
   Prohibit forced labor, child labor, and human trafficking in any form
   4.2 Employment Standards
   SparkGrid ensures that all employment relationships are:
   Voluntary and based on mutual consent
   Compliant with applicable wage and hour laws
   Free from unreasonable restrictions on workers' freedom of movement
   Properly documented with clear terms and conditions
   4.3 Supplier Code of Conduct
   We expect our suppliers and service providers to:
   Maintain ethical labor practices
   Prohibit forced labor, child labor, and human trafficking
   Comply with all applicable employment and labor laws
   Provide safe working conditions
   Respect workers' rights to freedom of association

5. Due Diligence and Risk Assessment
   SparkGrid conducts due diligence to identify and mitigate modern slavery risks:
   5.1 Risk Assessment
   We have assessed that our modern slavery risk exposure is relatively low due to:
   Our business model as a software company with no physical manufacturing
   Primary operations in jurisdictions with strong labor protections
   Limited supply chain complexity
   Use of established, reputable service providers
   However, we recognize potential risks in:
   Extended supply chains of our cloud infrastructure providers
   Contractor and consultant relationships
   IT hardware procurement
   5.2 Supplier Evaluation
   When engaging new suppliers or service providers, we:
   Conduct appropriate due diligence based on risk level
   Review suppliers' labor practices and compliance commitments
   Include contractual provisions requiring compliance with anti-slavery laws
   Prioritize established providers with documented ethical practices
   5.3 Contractor and Employee Practices
   For our workforce, we:
   Ensure all employment relationships are properly documented
   Maintain compliant employment contracts and consultant agreements
   Verify right to work documentation
   Prohibit retention of identity documents or charging of recruitment fees
   Provide clear terms regarding compensation, working conditions, and termination

6. Training and Awareness
   SparkGrid is committed to ensuring relevant staff members understand modern slavery risks:
   Management Team: Receives training on modern slavery risks and due diligence requirements
   Procurement Personnel: Trained on supplier evaluation and risk indicators
   Human Resources: Educated on ethical recruitment practices and employee rights
   General Workforce: Provided with awareness of company policies and reporting mechanisms

7. Effectiveness and Key Performance Indicators
   SparkGrid measures the effectiveness of our anti-slavery efforts through:
   Supplier Compliance: Percentage of key suppliers with documented anti-slavery commitments
   Contract Coverage: Percentage of supplier contracts containing modern slavery provisions
   Training Completion: Percentage of relevant staff completing modern slavery awareness training
   Incident Reporting: Number of modern slavery concerns reported and investigated
   Policy Review: Annual review and update of policies and procedures
   Current Status (2025):
   Zero incidents of modern slavery identified in our operations or supply chain
   Key supplier contracts updated to include anti-slavery provisions
   Management team trained on modern slavery risks and requirements
   Annual policy review completed

8. Reporting Mechanisms
   SparkGrid encourages employees, contractors, and stakeholders to report concerns about modern slavery or
   human trafficking:
   Reporting Channels:
   Direct report to management or Human Resources
   Email: compliance@sparkgridsoftware.com
   Anonymous reporting through company channels
   Commitment to Non-Retaliation: We prohibit retaliation against anyone who reports concerns in good faith
   regarding modern slavery or human trafficking.

9. Continuous Improvement
   SparkGrid is committed to continuous improvement in our efforts to prevent modern slavery:
   Annual review and update of this statement
   Regular assessment of emerging risks in our supply chain
   Enhancement of due diligence procedures as our business evolves
   Collaboration with industry partners on best practices
   Response to stakeholder feedback and regulatory developments

10. Looking Forward
    For the coming financial year, SparkGrid commits to:
    Expanding modern slavery training to all employees and contractors
    Conducting targeted assessments of higher-risk supplier relationships
    Enhancing our supplier onboarding questionnaire to include modern slavery screening
    Reviewing and updating supplier contracts to strengthen anti-slavery provisions
    Monitoring regulatory developments and adapting our practices accordingly

11. Approval and Signature
    This statement has been approved by the Board of Directors of SparkGrid Software, Inc. and constitutes our
    modern slavery statement for the financial year ending December 31, 2025.
    Signed:
    Chris Eustace
    Chief Executive Officer
    SparkGrid Software, Inc.
    Date: December 10, 2024
    Contact Information
    For questions regarding this statement or to report concerns:
    SparkGrid Software, Inc.
    Email: compliance@sparkgridsoftware.com
    Website: www.sparkgridsoftware.com