2024 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
Firstup seeks to do business with suppliers that mirror our values. With respect to the conduct of our suppliers, we endeavor to require our suppliers to contractually represent and warrant that they comply with all applicable laws. 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.
As part of Firstup’s supplier vetting process that occurs prior to onboarding a new supplier, Firstup requires all suppliers, when applicable, to confirm that they have policies and procedures in place to mitigate the risk of modern slavery in their supply chain. Our onboarding intake system asks all suppliers whether they have in place policies to minimize the risk of modern slavery in its supply chain. In addition, all such suppliers must provide their Modern Slavery Act Statement or an explanation of why it is not applicable to them.
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 are, and 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 2024.
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