UK Modern Slavery Statement

Last updated on November 14, 2022

This modern slavery and human trafficking statement (the “Statement”) is made by Appspace Holdings, Inc. on behalf of itself and its affiliates, (“Appspace”) pursuant to the U.K. Modern Slavery Act 2015 and the Modern Slavery Act 2018(Cth) of Australia (the “Acts”). It sets out the steps Appspace has undertaken, and is continuing to take, to manage the risk, which we believe to be negligible, of slavery and human trafficking (referred to collectively as “modern slavery” below) violations in our direct supply chain. This statement has been approved by Appspace’s leadership team. 

Introduction from the Appspace Family

As a global family of companies, Appspace fully supports the objectives of the Act.  Appspace understands that modern slavery and human trafficking are among the fastest-growing activities of trans-national criminal organizations and have the potential to affect every country across the world.  Appspace believes that respect for human rights is integral to our culture and to being a legally and socially responsible company.  It is why the prevention of forced, bonded and trafficked labour, are key elements of our own internal policies and of our expectations of our suppliers.

Organization’s structure

We are a global software company delivering Software-as-a-Service to support employee communications, intranet solutions, and workplace experiences headquartered in Dallas, Texas.  While Appspace’s headquarters are located in the United States, it has grown worldwide with offices locations in the United Kingdom, the European Union, Australia, the United Arab Emirates, Malaysia, and Canada. 

Our business 

Our business is organized into two business units: i) a Software-as-a-Service provider delivering software services via the internet, and ii) enhanced services such as implementation, training, third-party software integration, and creative content for customers using Appspace’s software services. 

Appspace Holdings, Inc. is a USA headquartered group with trading subsidiaries in the UK, Australia, Spain, Australia, Malaysia, and the United Arab Emirates. Central functions are provided from the USA with each trading entity having its own sales and customer support team. Software development is carried out from the Appspace trading entities in Malaysia, Spain, and the USA. 

Appspace has a 31 December year end.

Our supply chains

Our supply chain includes third party services, software-as-a-service, hosting services, and various consulting and advising services. 

We contract with many large and small organizations, based in the USA and throughout the world.  We set out below our compliance approach regarding these suppliers. 

Due diligence processes for slavery and human trafficking

Appspace is committed to conducting business to a high ethical standard in all our business dealings.  Our business ethos includes a zero-tolerance approach to any form of modern slavery, and we expect the same high standards and commitment from those with whom we do business.  

None of our staff should ever be subjected to servitude, forced and/or compulsory labor or human trafficking.  Employees should have the freedom to work for their employer and to leave the company after they’ve given reasonable notice.  

As part of our initiative to identify and mitigate risk we require all third party spend to be made using written contracts and we do not pay cash for services. 

We have in place systems to:

• Identify and assess potential risk areas in our supply chains.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains.
• Monitor potential risk areas in our supply chains.
• Protect whistleblowers. 

Our policies on slavery and human trafficking

Our Anti-Slavery Policy and internal code of conduct reflects 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. 

We expect and require violations of any of the above policies to be reportable to our  Legal team.  Such reporting may be anonymous if necessary, and whistleblowers will be protected.  Our legal team will investigate all alleged violations and recommend appropriate actions to management.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we may provide training to our staff.  We also require our business partners to provide training to their staff and suppliers and providers.  

Supplier adherence to our values and ethics

To ensure all those in our supply chain and contractors comply with our values and ethics we have in place a rigorous supply chain compliance program.  This consists of: 

• Those employees directly involved with suppliers where Appspace considers there is a heightened risk of modern slavery and human trafficking are fully aware of their responsibilities and receive coaching and mentoring as appropriate.
• Each year Appspace reviews its supplier base to identify any heightened risk of modern slavery.
• Condeco also monitors the websites of and news regarding its main suppliers to satisfy itself that they remain committed to eradicating modern slavery and human trafficking.

We have a dedicated compliance team, which consists of the involvement from the following departments:

• Legal
• Informational Security
• Human resources
• Sales

Given the nature of Appspace’s business and the vendors engaged to assist in our operating needs, Appspace considers the risk of modern slavery to be low within the organization and its supply chains. We remain confident through the collaboration between our teams that we can help reduce any possible negligible risk of modern slavery in our personnel supply chain.

Further steps

Going forward, we anticipate a recurring review of our use of suppliers and to adapt our processes if we determine that our risk has increased.

This Statement has been approved by the Appspace senior leadership team and is our statement under both Acts for the year ended 31 December 2022. 

Jeff Cate

For and on behalf of Appspace