Modern Slavery Policy
Last Updated 1.7.2025
Modern Slavery is a crime and a fundamental violation of human rights. It can take various forms, such as slavery, servitude, forced labour, and human trafficking, all of which involve depriving a person of their liberty to exploit them for personal or commercial gain. (“Modern Slavery”)
1. Purpose
Addressing Modern Slavery is a central part of our environmental, sustainable and governance program (ESG) and our commitment to a safe and responsible business. The purpose of this Modern Slavery Policy (“Policy”) is to set out UpCloud’s commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place to ensure Modern Slavery is not present in our operations, business relationships or in our supply chains.
2. Scope
This Policy applies to all persons working for UpCloud or on our behalf in any capacity, including all employees, directors, and officers (“Employees”). The Policy extends equally to all our external business partners, which includes our suppliers, contractors, external consultants, agents, third-party representatives, and any other partners (“Business Partners”) We expect all Business Partners to hold their own supply chains to the same standards.
3. Our Business and Supply Chains
UpCloud is a European cloud service provider operating from third-party data centers globally. Our supply chain, therefore, consists mainly of data center facility operators and the manufacturers of our computer hardware, such as servers and networking equipment.
We acknowledge several key vulnerabilities that generally increase the potential for Modern Slavery in electronics supply chains. The risk is particularly increased when suppliers are located in geographies with prevalent Modern Slavery, engage in subcontracting, rely on a migrant workforce, or are connected to raw material sourcing, hardware production, and indirect service providers.
Although UpCloud’s supply chain is global, we partner with hardware suppliers who have documented programs to combat these issues. Our key suppliers conduct ongoing due diligence and have committed to prevention of Modern Slavery.
5. Our Commitment
UpCloud has a zero-tolerance approach to Modern Slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure Modern Slavery is not taking place anywhere in our own business or our supply chain. No labour provided to UpCloud in the pursuance of the provision of services is obtained by means of Modern Slavery and UpCloud strictly adheres to all standards required in relation to its responsibilities under relevant employment legislation. We do not enter into business with any organisation which knowingly supports or is found to be involved in Modern Slavery.
6. Due Diligence
UpCloud’s due diligence process aims to identify, evaluate, and reduce the risk of Modern Slavery within our supply chains. Our key suppliers respond to our due diligence questionnaire about their environmental, social and governmental efforts, including prevention of Modern Slavery. Should our initial questionnaire or other information reveal potential red flags related to Modern Slavery, we will engage directly with the supplier to address these concerns and take appropriate steps to ensure Modern Slavery is not present in our operations.
7. Relevant Policies & Processes
We have implemented the following policies that drive our approach to the identification of Modern Slavery risks and steps to be taken to prevent it:
- Code of Conduct reflects our values and establishes the ethical standards that all our employees, partners, and suppliers are expected to uphold. The Code of Conduct guides our actions, decisions, and interactions ensuring that we build trust and operate with integrity and accountability at every level.
- Anti Corruption Policy sets out UpCloud’s commitment to preventing bribery and corruption in its operations.
- Whisteblowing Channel is open for anyone who wants to report their suspicions of crime, violations, or other types of misconduct in UpCloud’s operations. The reports can be made anonymously.
8. Reporting
You are encouraged to raise concerns about any issue or suspicion of Modern Slavery in any parts of our business or supply chain at the earliest possible stage.
We encourage you to use our Whisteblowing Channel for reporting your concerns.
9. Violations of the Policy
Employees breaching this Policy may face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with any Business Partners breaching this Policy.
10. Responsibility of the Policy
UpCloud Legal department is responsible for this Policy and monitors that all stakeholders comply with it.