Pythian Anti-Slavery and Anti-Human Trafficking Statement

Pythian is committed to upholding human rights. We recognize that human trafficking, forced labour and child labour in all its forms are violations of fundamental human rights and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in our supply chains.

This statement has been prepared in accordance with the principles of the Modern Slavery Act 2015 (UK), the Australian Modern Slavery Act 2018, and the Fighting Against Forced Labour and Child Labour in Supply Chains Act (Canada).

About Pythian

Our group of companies include Pythian Services Inc. and its subsidiaries Pythian UK Limited, Pythian India Private Limited, and Pythian Australia Pty Ltd. and Pythian Services USA Inc. and its subsidiary, Agosto, LLC. (collectively, “Pythian”).

Pythian is a global IT professional services company, who offers data, analytics and AI solutions to customers in North America, Europe and Australia. We are also an authorized reseller of Google products in North America and the UK.

We have employees in all jurisdictions where we are incorporated and also retain top talent in other jurisdictions via a contract for services. These individuals (“In-house Contractors”) are fully integrated into Pythian’s processes and procedures and are subject to the same policies, oversight and supervision as are the employees of Pythian. Pythian Personnel are approximately 420 individuals. Through our work, we also retain subcontractors, following a strict process of qualification to ensure they meet Pythian standards.

We are an equal opportunity employer, fully committed to providing a safe work environment, free from any type of abuse and exploitation, and offering mechanisms for our personnel to report concerns without any risk of retaliation.

Our Human Resources Department manages processes designed to ensure that all prospective employees are authorized to work where they reside and to protect them from any form of abuse.

Our Commitment to Human Rights

We believe that every human being has an intrinsic, universal and inviolable worth and we recognize that human dignity is foundational for human rights and ethical treatment. We are committed to respecting and protecting human rights, and we do not tolerate any form of modern slavery in our business and supply chains.

We follow the UN Guiding Principles on Business and Human Rights, and we comply with all applicable human rights legislation and standards in the jurisdictions in which we operate including legislation addressing human trafficking, forced and child labour, discrimination and harassment, pay equity, employment equity, and health and safety. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

Our Supply Chains

Our supply chain is fundamentally made of subcontractors that may assist Pythian in the provision of services to its customers. We also engage cloud providers in support of our operations.

We do not engage in any business with any organization that knowingly supports or is involved in modern slavery practices.

Pythian has a procurement process for the qualification of vendors, which includes a due diligence step to assess vendor’s status or position with respect to different standards, including modern slavery. With respect to subcontractors, once qualified, we require them to adhere to Pythian’s Supplier Code of Conduct, which includes a commitment to uphold the principles of modern slavery legislation.

Our Policies on Slavery and Human Trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery and Anti-Human Trafficking Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

In addition to the Anti-Slavery and Anti-Human Trafficking Policy, Pythian has in place other policies (collectively, “Pythian Policies”) that set out standards required of our personnel and provide for mechanisms to report issues or concerns, including about modern slavery legislation:

Code of Business Conduct and Ethics
Human Rights Policy
Whistleblowing Policy
Compliance Reporting Policy
Procurement Policy
Anti-Bribery and Anti-Corruption Policy
Diversity, Equity and Inclusion Policy
Supplier Code of Conduct

Due Diligence Processes for Slavery and Human Trafficking

As part of our initiative to identify and mitigate the risk of inadvertently engaging someone who supports modern slavery, we have in place recruitment and procurement processes that allow us to identify and assess potential risks:

We ensure that every individual we engage, whether as an employee or a contractor, is entitled to work in the jurisdiction where they are located.
We comply with applicable employment legislation in the jurisdictions where we operate, ensuring that we meet or exceed the requirements of the law, including with respect to wages, overtime, vacation, termination rights and any other entitlements employees may have under applicable law.
We require all Pythian Personnel to acknowledge annually all of Pythian Policies, including those relating to modern slavery and human trafficking.
With respect to individuals who Pythian requires to be in a specific location, Pythian assumes all costs associated with obtaining applicable work permit or visa.
We assess subcontractors through our procurement process and require them to adhere to our Supplier Code of Conduct, which addresses, among other issues, modern slavery.
We have in place mechanisms for personnel to report concerns or violations anonymously.
We continuously assess areas of improvement and work to modify our due diligence steps if we identify any higher risk to our personnel, subcontractors or applicants.

Risk Assessment and Management

Recruitment of Pythian personnel and retention of subcontractors are the two main areas of risk in relation to modern slavery for Pythian. We manage this risk through:

A strong Human Resources department, which leads the recruitment process and ensures that all the required criteria are met, including eligibility to work in the jurisdiction where the individual is located and that applicable employment legislation is complied with. Human Resources is also responsible to ensure that all personnel review Pythian Policies are and acknowledge them in writing, at the time of hire and annually thereafter; and
A well-defined Procurement Process, which starts with a due diligence questionnaire for the vendor to complete, followed by a process of internal approvals to qualify the vendor. Where the vendor is a subcontractor, once qualified, there is a requirement to contractually adhere to the Supplier Code of Conduct.

We review modern slavery legislation annually to identify any material changes and work towards updating our policies and practices accordingly.

Training

Pythian has a risk-approach to training. The nature of Pythian services is such that services are delivered remotely and personnel are allowed to work from their home office. Similarly, our supply chain consists only of potential subcontractors we need to engage to support us in our provision of services to our customers. Recruitment of personnel and engagement of subcontractors are subject to very controlled processes. Based on the foregoing, we have assessed that our activities are low risk for the occurrence of forced or child labour and, consequently, we have determined that company-wide training would not be commensurate with that level of risk. Our Human Resources department and our Legal department (within which Procurement is managed) are always aware of compliance with modern slavery legislation. In addition, all of our personnel are required to read and acknowledge in writing our Anti-Slavery and Anti-Human Trafficking Policy on an annual basis. We are also designing educational emails that will be sent to all of our personnel quarterly, as a reminder of the importance of complying with Pythian policies.

Key Performance Indicators

100% of Pythian personnel have reviewed and acknowledged Pythian policies in writing.

Since the implantation of the Code of Conduct for Vendors of Pythian in January 2024, 80% of subcontractors who at one point between 2024 to date provided services to Pythian have signed the Code of Conduct.

Awareness emails will start quarterly in 2026.

Administration

The General Compliance Office at Pythian, integrated by Legal, Finance, Human Resources and Security, is responsible for ensuring compliance with our Anti-Slavery and Anti-Human Trafficking Policy. Any communications relating to this Statement are received by this General Compliance Office at compliance@pythian.com.