Effective Date: August 17, 2021

Modern Slavery Act 2015: Modern Slavery and Human Trafficking Statement

This statement is made by Blueshift Labs, Inc. (“Blueshift” or “we”) under section 54(1) of the Modern Slavery Act 2015 (the “Act”). This constitutes our Modern Slavery and Human Trafficking Statement for financial year ended January 31, 2021 and was approved and signed on behalf of the Board of Blueshift Labs, Inc. on August 17, 2021.

Organization and structure

Blueshift Labs is a private corporation registered in the State of Delaware, USA. Blueshift is an international corporation comprising of Blueshift Labs, Inc. and its affiliates operating in the jurisdictions as detailed on our website here.

We are committed to legal compliance and ethical business practices in all of our operations worldwide, this includes improving our practices to combat slavery and human trafficking. We choose suppliers and contractors who we believe share that commitment.

Risk Assessment

As the leader in customer data activation platforms, we consider that we are at low risk of modern slavery occurring within our own business. However we remain alert to the possibility, and contractual requirements with our suppliers and vendors cover our approach to this.

Our key suppliers are those required to support our global business, which is office based. The key areas of spend with suppliers are IT Management and Facilities. Global spend on suppliers is concentrated in the United States, with other spend distributed across other international offices. Our aim is to foster long term relationships with our critical business suppliers, as this is key to establishing an open relationship where price is not the only driver.

Blueshift conducts the following actions to help prevent forced labour, modern slavery and human trafficking:

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We commit to use only legal and ethical business practices and to implement and enforce effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. All suppliers are subject to legal terms and conditions with Blueshift and they are contractually obligated to abide by all applicable laws.

Next steps

We will review the steps taken so far to identify any gaps and consider the effectiveness of our approach.

We will continue with supplier screening and a risk based approach to such suppliers following the due diligence process described above.

We will seek to expand and embed knowledge of the issues and risks around modern slavery and human trafficking to all appropriate staff across the network of offices via regular communication and targeted training.

We will include modern slavery in our ongoing operational risk review process which is conducted across our network of offices.

Signed

Vijay Chittoor

Chief Executive Officer
On behalf of the Board