This statement is published in accordance with Section 54 of the UK Modern Slavery Act 2015 and the Modern Slavery Act 2015 (Transparency in Supply Chains) Regulation. It sets out the steps that Instructure Inc. and its subsidiaries, including Instructure Global Ltd., in the United Kingdom (collectively “Instructure”), have taken and will continue to take, to prevent slavery, child labor, and human trafficking in its business and supply chain for the financial year ending 31 December 2021.
Instructure is committed to conducting its business in accordance with all legal and regulatory requirements and with the highest standards of ethical behavior. For that reason, Instructure maintains rigorous internal processes to follow laws, regulations, and industry codes of conduct that support good business practices.
Modern Slavery
Instructure is committed to ensuring its supply chain and operations remain free from any form of human slavery, human trafficking, and forced labor. To this end, Instructure continues to raise awareness among its employees, suppliers, partners, and other stakeholders on this critical topic.
Policies and Controls
Instructure believes that its Code of Conduct and Ethics (“Code of Conduct”) establishes the principles and expectations of its employees and contractors. Instructure enforces compliance with those expectations through internal audits, training, and, when necessary, disciplinary action. The scope of these principles includes adherence to applicable laws and fair and ethical business practices.
All employees at Instructure are trained on the Code of Conduct upon hire and subsequently refreshed on an annual basis. Instructure also requires its employees to report any policy or legal violations to their supervisor, Human Resources Department, Compliance Officer, or the Legal Department. Employees may also report violations of law or the Code of Conduct anonymously in accordance with Instructure’s Whistleblower Policy.
Instructure’s Executive Leadership Team is responsible for monitoring, investigating, and enforcing the Code of Conduct, as well as regularly reviewing Instructure’s policies, including the Code of Conduct, and revising those policies to reflect Instructure’s position on ongoing issues.
Instructure also requires its business partners to comply with all applicable laws, regulations, industry codes, and contractual terms.
Due Diligence
Instructure understands that there is potential exposure to slavery, human trafficking, and forced labor when purchasing goods and services from third parties. To address this, Instructure conducts regular compliance audits of its direct service providers as part of its overall commitment to the quality service Instructure provides to its customers. The scope of these supplier evaluations includes review of labor practices and document instances of deviations from legal or ethical standards established by the country of origin or by Instructure.
Instructure has not employed a third party to evaluate and address risks of human trafficking and slavery in its supply chain. Instructure contracts with its direct service providers and specifies within those contracts that compliance with all applicable laws is integral to performance under those contracts.
Assessing and Managing Risk
Instructure is committed to conducting its business in accordance with all legal and regulatory requirements and with the highest standards of ethical behavior. Instructure believes there is an extremely low risk that its supply chain contains any element of slavery, child labor, or human trafficking.
Due to the nature of Instructure’s business, Instructure generally does not source materials associated with forced labor or child labor. Instructure does not pursue a strategy of low-cost country sourcing and is foremost focused on vendor quality and risk avoidance. Any questions or comments regarding Instructure’s business practices should be directed to Instructure’s compliance office at privacy@instructure.com.
Instructure and Modern Slavery
Instructure will continue to review and update its policies, procedures, and guidelines, and raise awareness of human trafficking, forced labor, and slavery. Instructure is dedicated to maintaining appropriate safeguards to protect human rights in its supply chain and business.
This statement was approved by the Board of Directors of Instructure Global Limited on 31 December 2021.