Modern Slavery Statement

UKG Modern Slavery Statement 2022

Scope

UKG Inc. (and its subsidiaries and affiliates, hereinafter referred to as “UKG” or the “Company”) is committed to ensuring that slavery and human trafficking are not taking place in our business or within our supply chain.

UKG adheres to the principles found in the United Nations Universal Declaration of Human Rights, which prohibits:

  • the use of any form of forced labor, including indentured labor, bonded labor, and physical confinement in the work location;
  • exploitative practices, such as forced overtime and limited access to documentation including passports, identity papers, and travel documents; and
  • support for or engagement in any form of human trafficking or involuntary labor through threat, force, fraudulent claims, or other coercion.

UKG complies with all applicable modern slavery laws, including the U.K. Modern Slavery Act of 2015 (“UK Modern Slavery Act”) and the Modern Slavery Act 2018 of Australia (“Australia Modern Slavery Act”).

Our Operations and Values

UKG is a leading provider of human capital management (“HCM”) and workforce management (“WFM”) software as a service (“SaaS”) solutions for businesses. As strong believers in the power of culture and belonging as the secret to success, we champion great workplaces and build lifelong partnerships with our customers. Our Life-work Technology™ approach to HCM and WFM SaaS solutions helps more than 70,000 organizations around the globe and across every industry anticipate and adapt to their employees’ needs beyond just work. UKG has co-headquarters in Lowell, MA, and Weston, FL. With more than 15,000 employees in more than 15 countries, UKG continues to grow and evolve to create new opportunities for all stakeholders.

To learn more about our vision, values, and commitments, visit ukg.com/about-us.

Our Products and Services

We’ve created an unmatched suite of HCM and WFM SaaS solutions, backed by our people who care about our customers. Our solutions deliver global workforce experiences that truly reflect the connection between life and work today.

To learn more about our products and services, visit ukg.com/solutions.

Our Commitment

UKG recognizes the important role we can play in helping to protect the rights of people throughout the world where we do business. Our purpose is people™ and we are committed to achieving this purpose by living our core values—United, Kind, and Growing—every day and in everything that we do. We invite and value diverse perspectives, actively sacrifice individual preferences in order to benefit the greater good, value transparency and kindness, are adaptive and agile, offer support and unlimited opportunities for growth, and relentlessly pursue great outcomes.

Embedded in our culture is a profound commitment to doing the right thing for our employees, customers, and other stakeholders. This includes actively working to earn and maintain trust by showing consistency between our words and actions, by being transparent, and by taking personal and collective responsibility for the decisions we make and the outcomes that follow. It also includes the work we are doing in support of our ESG Program as well as our significant investments in and focus on diversity, ethics, compliance, and philanthropic initiatives. Our ESG Report — together with our ESG Policy, Global Environmental Policy, Human Rights Policy, Code of Conduct, Third-Party Code, and other policies —reflect our commitment to enhancing our already-strong background in governance and corporate social responsibility.

Our Policies

UKG has a variety of tools to help our employees understand and live our values. This includes our Employee Handbook and Code of Conduct, which apply to employees worldwide and describe how they are expected to act when conducting business on behalf of UKG. In 2021, the Company updated its modern slavery statement in its Code of Conduct as follows:

The Company complies with modern slavery prevention laws, including the Modern Slavery Act 2015 (UK), and the Modern Slavery Act 2018 (Australia). This includes not using underage labor, as defined under applicable law, and not employing workers below the age of 18 in jobs that are likely to jeopardize their health and safety. The Company only uses voluntary labor and employees who have the proper work-related documentation and is otherwise committed to taking steps to ensure compliance with those laws. This commitment applies to UKG and its suppliers.

  • Human Rights Policy
  • Anti-Money Laundering Policy
  • Harassment and Discrimination Policy (part of our employee handbook)
  • Conflict of Interest Policy
  • Anti-Corruption Policy
  • Privacy Policy, Privacy Notice
  • Information security policies

UKG’s Human Rights Policy, which was introduced in 2022, affirms the Company’s commitment to adhering to the United Nations Guiding Principles on Business and Human Rights, and to respecting the internationally recognized human rights of our employees, supply chain, and others. In the Policy, UKG commits to working to address adverse impacts that the Company or third-parties may cause or to, and acknowledges the important role UKG can serve in influencing others.

UKG’s Human Rights Policy is aligned with several internationally recognized human rights frameworks, including The International Bill of Human Rights (including the Universal Declaration of Human Rights, the International Covenant on Economic, Social and Cultural Rights, and the International Covenant on Civil and Political Rights), The International Labour Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work and core International Labour Standards, The Organisation for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprises, The UN Convention on the Rights of the Child, The UN Declaration on Human Rights Defenders, and Framework Principles on Human Rights and the Environment. For more information about our commitment to human rights, click here.

UKG also complies with applicable U.S. sanctions and embargo laws and regulations. Neither UKG nor its directors, officers, employees, or suppliers are listed on the U.S. Department of the Treasury Office of Foreign Assets Control or Specially Designated Nationals List. UKG does not conduct business in any U.S. sanctioned country, including without limitation, Cuba, Iran, Iraq, Libya, North Korea, Syria, and Sudan.

Third-Party Risk Assessment and Management

UKG actively seeks to work with third-parties that share our values and commitments. In addition to the requirements set forth in our contracts, our Third-Party Code describes the standards we expect third-parties to meet or exceed in important areas, including anti-discrimination, modern slavery prevention, union membership, fair treatment, compensation and working hours, anti-corruption and gifting, confidentiality, intellectual property rights, privacy, grievance channels and nonretaliation, workplace safety, environmental responsibility, health and safety training and communication, and responsibly sourced materials.

As part of deepening our commitment to working with responsible third-parties, in 2022 we:

  • Mapped our supply chain to better understand diversity while introducing practices that embrace our ESG initiatives.
  • Expanded and enhanced our international reseller due diligence process.
  • Enhanced our monitoring of third-parties in higher-risk countries. This includes implementing enhanced audit and evaluation processes, conducting on-site visits, and otherwise taking additional steps to ensure that the third-party understands and adheres to our Third-Party Code.

UKG uses a risk-based approach when evaluating third-parties. Modern slavery, human trafficking, and other topics consistent with our core values are included as part of our standard third-party due diligence processes. New third-parties are required to attest to UKG’s Third-Party Code—including as it concerns employment and labor practices, compliance with regulatory requirements, and health and safety protections—prior to UKG doing business with them. Consistent with our commitment to expand the use of our Third-Party Code, UKG has also made considerable progress incorporating it into relationships with our existing third-parties when those contracts come up for renewal. UKG remains committed to having all third-parties with whom we do business comply with the principles set forth in our Third-Party Code.

UKG’s Strategic Sourcing Team is responsible for leading the Company’s third-party due diligence process and other key supply chain initiatives, including ensuring that:

  • Third-parties comply with our Third-Party Code, have ethical business practices, safe and healthy working conditions, and strive for continuous improvement with respect to human rights-related issues;
  • UKG engages in responsible sourcing and seeks out third-parties that support our business innovation goals;
  • UKG achieves greater supplier diversity; and
  • UKG conducts enhanced due diligence and takes additional precautions where and as appropriate, including when working with third-parties in higher risk geographies. This includes implementing enhanced audit/evaluation processes, conducting on-site visits, and other steps.

Responsible Sourcing and Human Rights initiatives are managed cross-functionally within UKG by UKG’s Governance, Risk and Compliance, Legal, and Security teams. These teams are responsible for developing comprehensive strategies, sharing best practices, and building awareness to facilitate continuous improvement of UKG’s human rights initiatives.

UKG’s Internal Audit and Third-Party Risk Management teams routinely audit various aspects of UKG operations, including third-parties. We also regularly engage independent auditors to support this work.

Employment and Working Practices

UKG has robust recruiting processes that meet or exceed local laws, including right to work document checks, employment contracts for all employees, and checks to ensure that all employees are above the minimum working age. Our pay and benefits packages are reviewed annually, and they are linked to appropriate benchmarks. UKG has consistently received awards for how it treats its most important asset—its people.

COVID-19

Throughout the pandemic, we have prioritized the health and safety of our workforce. We established a COVID-19 Advisory Committee that consists of senior leadership within the Company, and a COVID-19 Operating Committee comprised of key cross-functional employees, to engage on and drive our response to key pandemic-related issues. This includes taking steps to ensure employees are equipped to work productively from home, imposing business travel restrictions (and an approval process), implementing a thoughtful and voluntary approach to returning to the office for fully vaccinated employees in certain locations, providing training and other tools for all levels within the Company, and implementing a COVID-19 dedicated reporting line and intranet site. We worked to address new labor and modern slavery risks posed by the pandemic and made a commitment that we would continue to pay members of our extended workforce who were affected by reduced office schedules.

Recruitment

UKG’s Human Resources team manages the company’s recruitment process and only uses specified, reputable employment agencies to source labor. UKG expects these agencies to follow the “employer pays principle,” which states that no worker should pay for a job, and the costs of recruitment should be borne not by the worker, but by the employer.

Training

UKG has robust training and other programs for employees on our values, and various resources dedicated to ensuring we maintain a culture that supports those values. This includes comprehensive compliance training program for employees on various topics, including our Code of Conduct and modern slavery, anti-bribery and corruption, anti-money laundering, business continuity management, data privacy and security, workplace harassment and discrimination—among other courses. New employees are also required to review and acknowledge our Code of Conduct and other key policies as part of their onboarding. All employees receive annual training on preventing discrimination and harassment. Employees in certain roles also received specialized training on other topics, such as the ethical use of artificial intelligence and other relevant topics.

Regular Assessment

UKG recognizes the importance of continually assessing the effectiveness of our actions to address modern slavery risks. This includes continuing to evaluate the third-parties we work with and maintaining active feedback channels. The UKG ReportingLINE is available for anyone to ask questions or report concerns about various matters, including the topics described in this Statement.

UKG’s commitment to identifying and addressing potential modern slavery risks is an ongoing and evolving one. We will continue to monitor the effectiveness of our policies, education, processes, and procedures, and we will continually assess the effectiveness of our efforts by tracking outcomes, partnering with suppliers, and through internal governance and external assurance processes. UKG is committed to driving continuous improvement. This includes conducting of an annual audit of our largest and most populated global office locations. This audit considers health and safety, environmental factors, human rights, labor management, and site management.


This joint Modern Slavery Statement has been duly approved and adopted by the Board of Directors of UKG for the calendar year ending 31 December 2022 in accordance with the UK Modern Slavery Act and section 14(2)(d)(ii) of the Australian Modern Slavery Act.

For purpose of complying with the UK Modern Slavery Act, this Statement applies to Kronos Worldwide Limited.

For purpose of complying with the Australia Modern Slavery Act, this Statement applies to the following entities:

  • Kronos Australia Pty Limited (ACN # 074-408-067)
  • Digital Instinct Pty Ltd. (ACN # 091-694-745)

Christopher Todd

Christopher Todd | CEO
Ultimate Kronos Group
Date: 12/20/2022
Updated December 2022