Modern Slavery Statement for the 2023 Financial Year
This statement sets out the steps that SailPoint Technologies, Inc. and our subsidiaries (“SailPoint”) have taken and are continuing to take to ensure that modern slavery and human trafficking are not taking place within our business or supply chain. This statement relates to the 2023 financial year.
SailPoint’s fundamental policy is to conduct its business with honesty and integrity in accordance with the highest legal and ethical standards. We are committed to protecting and respecting human rights and have a zero-tolerance approach to modern slavery in our business dealings and supply chain in all forms including human trafficking, servitude and forced labor.
SailPoint is headquartered in the United States, and has office locations in Australia, Canada, France, India, Israel, Japan, Mexico, the Netherlands, Singapore, and the United Kingdom. While the majority of our business is conducted in these jurisdictions, we also conduct business in a number of other countries around the world.
Our Operations and Supply Chain
Our products, services and software development are generally provided in-house by SailPoint, rather than by third parties. Our global procurement team is based in our headquarters in the United States. We offer both software and software-as-a-service solutions, which provide organizations visibility and the intelligence required to both seamlessly empower users and securely manage their access to systems, applications and data across hybrid IT environments, spanning on-premises and cloud applications and file storage platforms. Given the nature of our business, our supply chain consists of the hiring of independent consultants and other service providers, along with the procurement of goods and services which support the day-to-day function and growth of SailPoint. Accordingly, we consider ourselves to be low risk with respect to slavery and human trafficking issues in our supply chain.
Key Controls and Actions Taken
We continue to implement our modern slavery framework, which includes a number of policies and practices to ensure we conduct business in an ethical manner. This framework establishes SailPoint’s processes in respect to modern slavery and also provides our staff with guidance in circumstances where modern slavery is identified. This framework includes:
Training. We require employees within our legal, compliance, procurement and talent acquisition teams to complete a training course on human trafficking, which includes human trafficking warning signs, how to prevent human trafficking in the organization and its supply chain, and how to support anti-trafficking efforts through awareness, advocacy and action.
Contracting practice. To help mitigate any risk, to the extent possible when we enter into negotiated agreements, we require that our contractors, partners, resellers, vendors and other suppliers comply with all applicable laws, which may include the Modern Slavery Act, depending on the type of the particular transaction and the nature of the counterparty.
Supplier procurement. We maintain a supplier code of conduct, which we expect our suppliers to review and comply with when doing business with us. The supplier code of conduct contains a requirement that suppliers fully comply with the applicable legal requirements of slavery, forced labor and human trafficking laws and to enact practices to ensure compliance with such laws. Additionally, our procurement team requires potential vendors to complete a due diligence questionnaire, to ensure we contract with reputable third parties.
Recruitment policy. We conduct eligibility to work checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
Corporate code of business conduct and ethics. We maintain a corporate code of business conduct and ethics which covers a wide range of business practices and procedures and outlines our fundamental policy to conduct business with honesty and integrity in accordance with the highest legal and ethical standards. The policy requires that all SailPoint stakeholders comply with applicable legal requirements of the State of Delaware, the United States and each country in which the company conducts business.
Next Steps in 2024 and Beyond
We will revisit and update our Modern Slavery Statement in the 2024 financial year and in doing so, will take steps including the following:
- Review our current internal controls,
- Review the effectiveness of our human trafficking training course to understand the effect to which participants are more able to identify human trafficking warning signs and take action to prevent human trafficking within the organization and its supply chains; and
- Continue to monitor any potential or arising risks of modern slavery within our supply chain.
This statement has been approved by the Board of Directors of SailPoint Technologies, Inc.
Director, SailPoint Technologies, Inc.
Date: June 29, 2023