Introduction

The information in this statement details policies, processes, and actions we have taken to ensure that slavery and human trafficking are not taking place within our business or supply chains. It covers the Lightspeed Systems group of companies and is our Modern Slavery statement for the financial year ended 31 December 2022 required under the provisions of the Modern Slavery Act 2015.

Organizational Structure

Lightspeed develops the most up-to-date enterprise-class software for primary and secondary schools (K-12) supporting online education. Our headquarters is in Austin, Texas with an additional office near London, UK. The core of our business is the product development, data analysis and customer engineering teams. The NOC and IT teams keep the technology running. The sales and marketing teams bring in revenue and the finance, facilities and administration teams support the smooth running of the business. About 90% of our workers are based in the USA with the remainder in the UK.

Our customers are schools based mostly in North America or Europe, with less than 5% in other regions. We sell through a distribution channel mostly based in North America and Europe, with Australia/New Zealand being another market for us. Our supply chains are almost exclusively in the above markets and so generally the risk of our suppliers engaging in slavery or trafficking is relatively low.

However, we are not complacent in our due diligence, on the contrary we try to uphold higher standards than the minimum required to ensure our supply chain uses high quality people and treats them fairly. A risk area we have identified is our sales into the Middle East and we are working on a mitigation strategy.

Supply Chains

Lightspeed is a people company, our success is based on finding the best talent and retaining them for the long term. We do not outsource or subcontract any critical workers and our services supply chains are simple. As a software author, we create our products in-house using our own workers in the USA. We may also partner with other US companies to provide specific software development services. Our customer support and services teams are also our own workers in the USA or UK. Our non-engineering teams such as sales, marketing, IT, HR, facilities, accounting, and finance are also our own workers in the USA or UK. This focus on hiring directly rather than agency workers or contractors/subcontractors allows us to have high confidence we are not inadvertently using victims of modern slavery or human trafficking.

Our most crucial suppliers are other American software and services companies such as Amazon Web Services, Microsoft, Apple, Adobe, Oracle, Salesforce and Twilio – all of whom comply with the Modern Safety Act 2015. We have one large supplier who does not yet have a modern slavery statement but is a member of an anti- trafficking initiative. Out of an abundance of caution we have accessed them as medium risk, but we are urging them to deepen their commitment to stop modern slavery.

Our second-tier suppliers are all US or UK companies who operate wholly or mostly in North America or Europe. As smaller companies, they do not all yet have modern slavery statements. Our due diligence has accessed all of them low risk, but we are challenging them to publicly commit to anti-slavery/trafficking.

We are currently assessing our lowest tier suppliers, and this is where we are most likely to find some higher risk companies. The hospitality industry is known to have extensive problems with modern slavery and human trafficking. As we use hotels often, we have assessed the major hotel groups and are giving high priority to hotels that comply with the Modern Slavery Act.

Modern Slavery Policy

Lightspeed Systems and its subsidiaries (“Lightspeed”) is opposed to modern slavery in all its forms of slavery or servitude, forced or compulsory labour, child labour and human trafficking. We are committed to eradicating these practices in all its forms from our business and supply chains. For our part we comply with the following statement:

In our business we prohibit use of child labour, forced labour, prison labour, or trafficked labour. We make conditions of employment clear when hiring, provide fair compensation, comply with local working hour and rest day requirements, provide accessible and effective grievance procedures, allow workers to resign without imposing penalties, and treat workers with dignity and respect in accordance with local laws and customs. We will not require “deposits” or other forms of debt bondage, we will not harass or bully workers, or unlawfully discriminate or restrict freedom of association.

We will provide internal training on our Modern Slavery Statement to ensure our workers understand the requirements of the Modern Safety Act 2015. We will provide workers guidance on how they can report concerns within our business or with our resellers or suppliers. We will use appropriately trained recruiters to support compliance of the above.

We will ensure to the best of our ability that our suppliers do not engage in modern slavery or human trafficking. We will check if new and existing suppliers have a modern slavery or similar statement and will prefer to use suppliers that have such a statement. If a supplier does not have a statement, we will provide a questionnaire based on our statement above. Based on the questionnaire, a risk assessment will be done. Suppliers that refuse to provide their status on modern slavery and human trafficking will be removed from our supply chain as soon as we can make alternative arrangements.

We will require that all new resellers either have a published Modern Slavery Statement or similar policy on worker rights or commit to our above statement or similar. We will check if existing resellers have a published Modern Slavery or Worker Rights Statement. If a reseller does not have a statement, we will provide a questionnaire based on our statement above. Based on the questionnaire, a risk assessment will be done. Resellers that refuse to provide their status on modern slavery and human trafficking will be removed as a reseller as soon as we make alternative arrangements.

Due Diligence

Part of the Lightspeed mission is helping to protect children, and that includes ensuring we are not doing business with companies that benefit from forced labour or human trafficking of children or their families.

We perform due diligence on suppliers and partners looking for potential issues and urge them to strengthen their commitment to stopping modern slavery and human trafficking. Our due diligence includes inspecting public statements and requesting further information if needed. We also check official sanctions lists and databases for high-risk companies and countries. Companies that have operations in high-risk countries are given further scrutiny.

We are not afraid to ask tough questions and act accordingly if answers are not forthcoming or indicate a company may be benefitting from modern slavery or human trafficking. We are proud of the care we take to ensure we use only the highest quality suppliers.

Risk Assessment

Our risk assessment process gives each supplier into a low, medium or high-risk profile based on our due diligence. Currently all our crucial suppliers have a low risk profile. Most of our important suppliers are also low risk, though some are medium risk through an abundance of caution while we work with them to resolve questions or concerns. We have identified at least one commodity supplier as high risk until we receive further information. As we work through all our many commodity suppliers, it is expected we will uncover other high- risk companies. We will engage with these to improve but will disengage if they do not.

Key Performance Indicators

We have made a good start on ensuring our supply chain is free from slavery/trafficking. This is a multi-year effort as we improve over time and work with others to ensure they also improve. Our goals for 2023 are:

• Ensure all our crucial vendors have a low risk profile
• Ensure we know the risk profile of every important vendor and are working with medium risk vendors to make them low risk. Have a plan for each high-risk vendor to move away from them as soon as possible if they continue to be high risk.
• Ensure we know the risk profile of every commodity vendor and disengage from high-risk vendors if they continue to be high risk.

Training

We are training all employees on Modern Slavery and Human Trafficking. This includes understanding our policies and processes and what to do if they suspect a supplier or partner has a problem. We are also educating our suppliers and resellers in this important area, so more companies strengthen their commitment to the cause of stopping modern slavery and human trafficking.

Ongoing Commitment

Looking ahead Lightspeed Systems will further develop its existing efforts to combat modern slavery and human trafficking across its own operations and those of its suppliers and partners. Lightspeed’s commitment to addressing human rights issues including modern slavery and human trafficking is a central part of its social responsibility ethos. As an industry leader, Lightspeed believes in inspiring and encouraging as many as possible to follow its lead – employees, customers, suppliers, partners, and local communities.

Lightspeed Systems Board of Directors approved this statement on 26 May 2023.

Signed

/s/ Brian Thomas
President & CEO