{"id":922,"date":"2025-12-03T11:00:03","date_gmt":"2025-12-03T09:00:03","guid":{"rendered":"https:\/\/upcloud.com\/global\/us\/modern-slavery-policy\/"},"modified":"2025-12-03T11:00:03","modified_gmt":"2025-12-03T09:00:03","slug":"modern-slavery-policy","status":"publish","type":"page","link":"https:\/\/upcloud.com\/global\/modern-slavery-policy\/","title":{"rendered":"Modern Slavery Policy"},"content":{"rendered":"\n
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Last Updated <\/b>1.7.2025<\/span><\/p>\n

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. (\u201c<\/span>Modern Slavery<\/b>\u201d)<\/span><\/p>\n

1. Purpose<\/b><\/h3>\n

Addressing Modern Slavery is a central part of our environmental, sustainable and governance program (ESG) and our commitment to a safe and responsible business. <\/span>The purpose of this Modern Slavery Policy (\u201c<\/span>Policy<\/b>\u201d) is to <\/span>set out UpCloud\u2019s 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.<\/span><\/p>\n

2. Scope<\/b><\/h3>\n

This Policy applies to all persons working for UpCloud or on our behalf in any capacity, including all employees, directors, and officers (\u201c<\/span>Employees<\/b>\u201d). 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 (\u201c<\/span>Business Partners<\/b>\u201d) We expect all Business Partners to hold their own supply chains to the same standards.<\/span><\/p>\n

3. Our Business and Supply Chains<\/b><\/h3>\n

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.\u00a0<\/span><\/p>\n

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.\u00a0<\/span><\/p>\n

Although UpCloud\u2019s 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.<\/span><\/p>\n

5. Our Commitment<\/b><\/h3>\n

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\u00a0 in the pursuance of the provision of\u00a0 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.\u00a0<\/span><\/p>\n

6. Due Diligence<\/b><\/h3>\n

UpCloud\u2019s 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.<\/span><\/p>\n

7. Relevant Policies & Processes<\/b><\/h3>\n

We have implemented\u00a0 the following policies that drive our approach to the identification of Modern Slavery risks and steps to be taken to prevent it:<\/span><\/b><\/p>\n