Modern Slavery Statement

2023 Statement Pursuant to the United Kingdom (UK) Modern Slavery Act 2015, Chapter 30, Part 6, Provision 54.

This statement is made by Firstup, Inc. and Dynamic Signal, Inc., each doing business in the UK under the name, Firstup UK Limited and Dynamic Signal UK Limited (Firstup UK Limited and Dynamic Signal UK Limited, together “Firstup UK”). Firstup UK is taking steps to identify and minimize the risk of slavery and human trafficking taking place in any of our supply chains and in any part of our business. For the purposes of this statement, any reference to “Firstup” is a reference to Firstup, Inc. and each of Firstup, Inc.’s subsidiaries (including the Firstup UK entities), as we uphold the values set out in this statement, regardless of geographic location.

About Firstup

Firstup, Inc. is a global internal communications SaaS company that helps connect every worker within an organization and ensures employees stay up to date with company news, alerts, and communications. Firstup is headquartered in California, with offices throughout the United States and the UK. As a responsible, ethical and leading member of the global software industry, we are committed to social and environmental responsibility.

Firstup Policy in Relation to Slavery and Human Trafficking

Firstup adheres to its “Code of Conduct”, which requires, among other things, that our directors, officers and employees work with our customers, suppliers, competitors and other employees lawfully and ethically in all business matters on Firstup’s behalf. This includes acting in compliance with the Modern Slavery Act. All directors, officers and employees of Firstup are supplied with a copy of the Code of Conduct, and if an employee becomes aware of an actual or imminent breach of the Code of Conduct, such employee is obliged to escalate the issue. This Code of Conduct has been in force since at least the last financial year and applies to all companies within Firstup. Firstup’s partner terms include contractual provisions, such as compliance with the company practices and the right to audit.

Risk Analysis

Each Firstup UK entity considers its modern slavery risk to be low, particularly because of the sector in which it operates, the nature of its supply chains, and the values, policies and the Code of Conduct to which its employees, directors and officers are required to adhere. Of higher potential risk are suppliers that sit outside of our core line of business, supporting and supplying other Firstup entities across our global business that form our wider supply chain.

Supplier Due Diligence

With respect to the conduct of our suppliers, we expect and require our suppliers to comply with applicable laws, including the Modern Slavery Act. Should Firstup become aware of any policy violations or issues related to slavery or human trafficking, we will consult with our legal team to ensure that appropriate measures are taken, which may include reporting such information to authorities, and terminating our relationship with any supplier conducting its business in such a manner.

Moving forward, Firstup will formulate an updated supplier due diligence process for on-boarding suppliers.  Firstup explicitly seeks to do business with suppliers that mirror our values. Our onboarding approach will include questions related to human trafficking or slavery activities to ensure our suppliers do not engage with or are a party to this behavior.

Policy Enforcement

To date, Firstup has not been made aware of any human trafficking or slavery activities within the supply chain. However, if any were highlighted to us, we would act immediately in accordance with our legal and moral obligations. To the extent that a risk of modern slavery, or a potential modern slavery incident, was identified within our business or supply chain, we would investigate and address such incident in accordance with our Code of Conduct.

These efforts, as well as this disclosure, will be reviewed by Firstup’s executive leadership team at least annually and updated as needed. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015, and constitutes our slavery and human trafficking statement for the financial year ending 2023.