UK Modern Slavery Statement

INTRODUCTION

This Modern Slavery Statement (the “Statement”) is designed to meet Harness Inc.’s reporting obligations under the United Kingdom’s (UK) Modern Slavery Act 2015 (the “Act”).  The Act was introduced to help eradicate slavery, servitude, and forced or compulsory labor (herein “slavery”) and human trafficking in company operations and supply chains. Harness is committed to principles of the Act and recognizes that slavery and human trafficking are global issues that require concerted attention and action. 

The Statement is provided on behalf of Harness Inc. and its subsidiaries (collectively, “Harness,” “we,” or the “Company”) located in the Americas, Europe, and APAC. This Statement describes the actions taken by Harness during the period from February 1, 2023, to January 31, 2024. 

OUR BUSINESS 

Operations

Harness is a leading end-to-end platform for complete software delivery. We provide a simple, safe, and secure way for engineering and DevOps teams to release applications into production. We use machine learning to detect the quality of deployments and automatically roll back failed ones, saving time and reducing the need for custom scripting and manual oversight.

Harness is a privately held Delaware corporation headquartered in San Francisco, California, United States, with subsidiaries in Australia, Israel, UK, Germany, Serbia, India, France, Canada, and Brazil. As of January 31, 2024, we have over 700 direct employees that include all full and part time roles employed directly by Harness or through professional employer organizations (PEOs) in the areas of: People & Workplace, Sales, Revenue, Research and Development (R&D), Administration, Customer Success, Finance, IT, Legal, Marketing, and Security & Compliance. The majority of our direct employees are in the United States and India. In addition to our direct employees, we also employ contract workers from time to time.

Supply Chain

As a Software-as-a-Service (SaaS) company our supply chain is largely comprised of indirect vendors as our business does not produce or distribute any hardware goods. We rely on indirect services to support our Company’s functioning, facilities maintenance, third-party labor agencies, food and beverage, and other related items. Our vendors are primarily located in the United States, though we also have vendors from the UK, Israel, Brazil, France, India, Ireland, Germany, Australia, Serbia, Canada, Mexico and some suppliers in South Africa and Switzerland who support our UK operations.

‍POLICIES‍

Harness’s policies establish our baseline expectations and aim to communicate our values, foster trust and collaboration, and establish our conduct expectations to our employees, vendors, partners, and communities in which we operate. While we do not have specific policies pertaining to slavery and human trafficking (e.g., a Human Rights Policy) in our operations and supply chain, our policies reflect different elements of ethical expectations. Our relevant policies include: 

Code of Conduct

Our Code of Conduct summarizes the ethical standards that all Harness employees must acknowledge and adhere to in order to protect the interests and safety of all employees and the Company. The Code of Conduct requires employees to comply with all laws and governmental regulations that are applicable to Harness’s activities, including those applicable to slavery and human trafficking.

The Code of Conduct also outlines our grievance mechanism, including the complaints reporting procedure, links to our third-party whistleblower hotline, our investigation procedures, possible corrective actions, and our zero tolerance for retaliation policy. Please refer to “Risk Management and Due Diligence” for more details about our grievance mechanism. 

Employees are required to complete an annual Ethics and Code of Conduct training.

Policy Against Harassment, Discrimination, and Retaliation 

The Policy Against Harassment, Discrimination, and Retaliation outlines our commitment to providing a safe and respectful working environment that is free from harassment and discrimination from other employees or non-employee clients, vendors, contingent workers, and guests. 

Employees in United States and India are required to complete sexual harassment training, which includes a comprehensive review of our policy and the law.

Similar to the Code of Conduct, we outline our grievance mechanism in this policy. 

Vendor Code of Conduct

Our Vendor Code of Conduct outlines our expectations for our vendors, distributors, partners, business associates, and third-party representatives (collectively, “vendors”). In addition to requiring compliance with all applicable laws and regulations, we explicitly prohibit the use of any form of forced labor, human trafficking, and child labor at any point in our value chain. We also provide our suppliers and business partners with access to our grievance mechanism in the Vendor Code of Conduct. 

Grievance Mechanism

Harness’s grievance mechanism is a third-party whistleblower hotline, EthicsPoint, that is available for all employees, vendors, and partners (collectively, “stakeholders”) to utilize in accordance with applicable law. Our stakeholders may report any actual or potential concerns about violations of applicable laws or any concerns relating to unfair labor practices and other indicators of slavery and human trafficking. Reports can be made 24/7 via phone or online and are multilingual and non-retaliatory. In addition, reports maintain anonymity for reporters where permitted by local law. 

We are strongly committed to preventing retaliation against anyone who, in good faith, reports any actual or potential violations of law, or any illegal or unethical behavior. All issues raised via the whistleblower hotline are reviewed and assessed for remediation, where circumstances warrant. We promote awareness of this reporting channel through internal policies, communications, and training such as through our Code of Conduct policy and training and the Vendor Code of Conduct.

To ensure Harness is successful in implementing its ethical compliance approach, including communication and monitoring of grievance reporting, Harness’s Legal and People teams oversee relevant responsibilities, which include:

• Notifying relevant business channels to begin investigating procedure for possible violations;

• Updating policies as needed and alerting employees, vendors, and business partners to any updates; and

• Promoting an atmosphere of responsible and ethical conduct.

In the reporting period February 1, 2023, to January 31, 2024, there were no slavery or human trafficking related reports through this hotline.

In addition to our whistleblower hotline, Harness’s employees are also encouraged to utilize internal channels when experiencing something unethical, inappropriate, or in violation of any of the codes of conduct. Where comfortable, employees may notify their manager of violations but are not required to and may reach out to any other manager, their People Business Partner, the Legal team, our Chief People Officer, or our Chief Executive Officer.

RISK MANAGEMENT & DUE DILIGENCE

Although we are considered lower risk for slavery and human trafficking in our operations and supply chains due to being a SaaS company, we acknowledge that all companies have a risk of adverse impacts on human rights. As such, we have explored our risks to understand where we may be more vulnerable to instances of slavery and human trafficking, though we have never had such instances occur in our operations and supply chain.

Operational Risks

Our global direct workforce is largely comprised of highly technical roles such as engineers, product managers, account executives, and professional services which are considered low risk for slavery and human trafficking. High skill roles such as these are at lower risk for adverse human rights impacts because they typically possess greater bargaining power, strong educational backgrounds, legal protections, and employment in formal economic sectors. 

We also employ contract workers through third party agreements to fill gaps typically in the areas of People & Workplace, Sales, Research & Development, and Marketing. All elements of our contract workers’ employment conditions are managed by our business units. Due to the decentralized management and oversight of our contract workers and the third-party recruitment agencies, we lack visibility on contract workers roles, geographical locations, and contract details with third party providers throughout our business. This poses a potential risk of slavery and human trafficking, as contract workers can be vulnerable to labor exploitation due to job insecurity, limited legal protections, precarious work arrangements, and limited representation or access to rights.  

Associated Due Diligence

We aim to mitigate the risks of labor exploitation to our direct employees by conducting background checks on every employee we hire in all of our geographies. We also leverage our internal policies like the Code of Conduct to ensure employees are aware of our grievance mechanism, which is our primary outlet for ensuring our employees’ and other members of our value chain’s workplace rights are represented and respected.

Supply Chain Risks

The majority of services in Harness’s supply chain come from application software, which is a type of computer program that performs specific business functions designed to assist end-users in accomplishing a variety of tasks (e.g., human resources). Directly, application software is low risk for slavery and trafficking. 

Our indirect services (e.g., office maintenance, cleaning services, catering) that are not included in the application software classification is where we have a higher risk of slavery and human trafficking in our supply chain. Industries providing these services are associated with slavery and human trafficking risks even in lower-risk countries, due to frequent use of migrant workers and the use of labor-for-hire organizations. Labor-for-hire organizations often employ casual, temporary, or sub-contracted workers, which can contribute to job insecurity and exacerbate financial instability, creating conditions where a worker may become more vulnerable to slavery and human trafficking. Migrant workers can face higher risks of labor exploitation due to tenuous immigration status that can put them at risk of deportation, limited representation or access to rights, job insecurity, precarious work arrangements, and low socio-economic status (which can exacerbate vulnerabilities).

We acknowledge that there may also be unidentified risks in our supply chain beyond those discussed above, particularly past our Tier 1 suppliers. Such risks could include the raw material inputs into the electronics we utilize for business (e.g., computers), or textile production of company-branded clothing. 

Associated Due Diligence

Our Vendor Code of Conduct sets the expectation for our vendors to uphold human rights and anti-slavery and anti-human trafficking principles in their operations, though it does not contain expectations for our vendors to conduct due diligence on their supply chains. To address this gap, we are actively engaging with external experts and applications to enhance our visibility into our supply chain. We also aim to enhance our screening of our vendors and incorporate slavery and human trafficking due diligence requests into our current procurement process, to further increase our visibility of slavery and human trafficking risk into our supply chain.

Our supply chain risk management procedure currently focuses on security, privacy, and service delivery elements and subject our vendors and business partners to due diligence checks based on their risk profile. We categorize vendors on a scale from low, medium, high, or critical, based on how business critical they are and whether they have access to restricted / confidential data elements. 

¹ _{Per the UK Modern Slavery Act, slavery, servitude and forced or compulsory labour is if “(a)the person holds another person in slavery or servitude and the circumstances are such that the person knows or ought to know that the other person is held in slavery or servitude, or (b)the person requires another person to perform forced or compulsory labour and the circumstances are such that the person knows or ought to know that the other person is being required to perform forced or compulsory labour.}
² _{Per the UK Modern Slavery Act, human trafficking is defined as, “a person commits an offence if the person arranges or facilitates the travel of another person (“V”) with a view to V being exploited”.}

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TRAINING

All Harness’s employees are required to complete an annual ethics and code of conduct training and acknowledge all aspects of our code of conduct. 

KEY PERFORMANCE INDICATORS

Currently, we track the incidences reported through our whistleblower hotline. In the February 1, 2023 to January 31, 2024 reporting period there were no slavery and human trafficking related reports through this hotline.

As we develop out our responsible sourcing strategy, we plan to integrate more slavery and human trafficking indicators.

LOOKING FORWARD

Harness aims to promote ethical practices in all aspects of our business. In line with our Company value of continuous improvement, we plan to focus on the following actions throughout the next fiscal year:

• Add a slavery and human trafficking training module in our annual ethics and code of conduct training for all employees. This module will be rolled out through our compliance training website, NAVEX, and will teach employees how to spot the signs of slavery and human trafficking, and how and when to make a report and best practices for working with third parties, including vendors.

• Update our Vendor Code of Conduct to be in alignment with globally recognized frameworks such as OECD Guidelines for Multinational Enterprises, International Labour Organization (ILO) Fundamental Principles, and the Universal Declaration of Human Rights (UDHR).

• Enhance procurement processes to integrate slavery and human trafficking-based screening of new and existing vendors and increase vendor awareness of Harness’s Vendor Code of Conduct expectations. 

APPROVAL OF THIS STATEMENT

This UK Modern Slavery Act Statement dated July 2024 (the “Statement”) has been reviewed and approved by the Board of Directors of Harness Group UK Limited as the UK trading entity.

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 January 31, 2024.

For and on behalf of Harness Inc.
Hanna Steinbach
General Counsel
July 30, 2024

Link to Signed Statement