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GoTo Statement on the Prevention of Slavery and Human Trafficking

A downloadable signed copy of this statement is available in English here.

Reviewed & Approved: May 23, 2024

This joint statement, made pursuant to the Fighting Against Forced Labour and Child Labour in Supply Chains Act, the U.K. Modern Slavery Act 2015 and The Australian Federal Modern Slavery Act 2018, (collectively, the “Acts”) sets out the approach taken by GoTo and its affiliated companies to understand all potential modern slavery risks related to its business, and the actions undertaken to mitigate any such risks during the financial year ending 2023.

Business Overview

GoTo’s mission is to unlock the potential of the modern workforce. We set out each day to give the world the products, solutions and services that help people do their best work – whenever, wherever and however. GoTo operates in Canada, the United Kingdom and Australia through its subsidiaries GoTo Technologies Canada Ltd., a Canadian limited company, GoTo Technologies UK Ltd, a United Kingdom private limited company, and GoTo Technologies AUS Pty Ltd, an Australian private company limited by shares, respectively, to which this joint statement relates. This joint statement has been developed in consultation with those entities and was approved by the boards of all reporting entities covered by this statement.

Our Workforce

A substantial portion of our workforce consists of skilled labor. All employees hired by GoTo are subject to background checks. GoTo also utilizes independent contractors. Because of the nature of the types of jobs performed by our independent contractors, we believe that there is no meaningful risk of modern slavery. GoTo generally uses placement agencies to source independent contractors. These agencies are selected following a standard sourcing process with defined business criteria.

Our Structure, Operations and Supplier Relationships

We are committed to ensuring that there is no slavery or human trafficking in our supply chains or in any part of our business. As a software company, our main operations consist of the delivery of information technology products, solutions and services, and we have undertaken an assessment of risks by completing a detailed review of our business operations and supply chain. As a result of this process, and due to the nature of our business and our approach to governance, we assess that there is very low risk of slavery and human trafficking in our business and supply chains.

GoTo does not use an extensive range of local or international suppliers where modern slavery or human trafficking would generally be a material risk. Our supply chain is relatively simple, including acquiring products and services needed for the businesses’ day-to-day operations such as office supplies, leasing premises, employment and professional advice. Our actions to address slavery and human trafficking have included developing this statement, the Supplier Code of Conduct, Employee Handbook, Code of Ethics described below, and the Social & Environmental Responsibility Principles. We require all of our suppliers to adhere to GoTo’s Supplier Code of Conduct (“Code of Conduct”), containing detailed human rights and labor standards, as published on our website. Our Code of Conduct and Modern Slavery Statement reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. Our Environmental Responsibility Principles reflects our social responsibility, environmental sustainability, our commitment to employee safety and engagement, and our compliance with all applicable forced labor and child labor laws, wage and hour laws, and non-discrimination laws. We do not believe any of these controls have caused or are likely to cause vulnerable families to experience any loss of income as a result of the steps GoTo has taken to eliminate forced labor or child labor risks. However, we aim to periodically review the effectiveness of and ongoing compliance with the relevant policies and procedures that we have in place. We do not have key performance indicators in relation to slavery or human trafficking as any instance would be expected to be a breach of law, our supplier standards or our company policies.

GoTo’s Policies and Trainings

GoTo’s Employee Handbook (“Handbook”) sets the standards of conduct for those working for or on behalf of GoTo which includes GoTo’s Code of Ethics (“Code of Ethics”). The Handbook is subject to regular review and is updated accordingly to ensure a high level of understanding of the risks of modern slavery and human trafficking in the supply chains and to the business.

GoTo is committed to providing a safe and violence-free work environment. Therefore, the Company has implemented a zero-tolerance policy of violence, threats of violence or any other illegal activity in the workplace. GoTo has mechanisms for its employees to ask questions or report concerns about possible violations of the Code of Ethics, GoTo policies and laws. This would include any questions or concerns relating to slavery or human trafficking. Our Code of Ethics has procedures and contact information for raising such matters, and we provide therein that retaliation will not be tolerated.