DocuSign Modern Slavery and Human Trafficking Statement
Adopted August 28, 2020
This Modern Slavery and Human Trafficking Statement (“Statement”) of DocuSign (entities outlined below) addresses the reporting requirements set out in section 54(1) of the UK’s Modern Slavery Act 2015, the Australian Modern Slavery Act 2018 (Cth) (the “Australian Act”) and all other applicable laws and regulations as the case may be for the financial year ending 31 January 2020.
DocuSign is committed to operating ethically and responsibly and strives to ensure that there is no slavery or human trafficking in any part of our business or our supply chains. We encourage and expect our employees and suppliers to take this same approach and uphold these values.
We welcome the transparency and diligence that the legislation mentioned above encourages and this Statement sets out the steps DocuSign has taken to comply with its obligations under that legislation.
Modern Slavery and Human Trafficking
The term “modern slavery” describes a range of situations in which coercion, threats or deception are used to exploit individuals and undermine their freedom. These situations include slavery, servitude, forced marriage, forced labor, debt bondage, deceptive recruiting for labor and the worst forms of child labor.
“Human trafficking” occurs when a person arranges or facilitates the travel of another person with a view to the other person being exploited.
This Statement covers the following DocuSign group entities:
DocuSign UK Limited;
Seal Software Ltd.;
DocuSign France SAS;
DocuSign Canada Ltd.; and
DocuSign International, Inc.,
together referred to in this Statement as “DocuSign”.
Where it is the case that any of the aforementioned legislation does not apply to one of these group entities or does not require that group entity to provide this statement, that group entity has chosen to provide this statement anyway as part of its responsible approach to business conduct.
Reporting entity for the purposes of the Australian Act
For the purposes of the Australian Act, DocuSign International, Inc. is the relevant reporting entity and the relevant reporting period is 1 February to 31 January.
DocuSign International, Inc. has limited its initial reporting in this Statement to its Australian operations. DocuSign will review this approach to reporting in subsequent reporting periods.
Our business, structure and operations
Since its inception in 2003, DocuSign’s mission has been to accelerate business and simplify life for companies and people around the world through pioneering agreement process technology. The DocuSign Agreement Cloud is our cloud software suite for automating and connecting the entire agreement process and it has more than 585,000 customers and hundreds of millions of users worldwide. The DocuSign Agreement Cloud includes DocuSign eSignature, the world’s number one electronic signature solution. Our services help organizations do business faster, with less risk, lower costs, and better experiences for customers and employees. Further details of our company can be found in our annual report and accounts available at investor.docusign.com.
DocuSign’s group’s parent company is DocuSign, Inc., a Delaware corporation. DocuSign, Inc. has subsidiary companies operating in over 10 countries with around 3,909 employees as of January 31, 2020.
In Australia, DocuSign operates through the following branch offices:
Sydney branch office: Level 8, 126 Phillip Street, Sydney, NSW 2000, Australia; and
Melbourne branch office: 401 Collins Street, Melbourne, VIC 3000, Australia.
DocuSign operates sales and customer success/support activities through its Australian branch offices and employs over 150 employees in its Australian branch offices as of the date of this statement. The Australian branch offices do not own, operate or control any subsidiary entities in Australia.
Our suppliers and supply chains
Our key suppliers are concentrated in the supply of open source software, software as a service, hardware products, and standard physical items for internal business operational use such as computer hardware.
Risks of modern slavery practices in DocuSign’s supply chains
DocuSign does not have long or complex supply chains. DocuSign does not manufacture any products. We do source “off the shelf” physical products for a handful of customers, but this is not a large revenue stream or significant part of our business. Our major vendors and suppliers (other than those that meet our physical operating requirements, such as office space, physical office supplies, etc.) are mostly “software as a service” and service-based. We have determined that, in light of these characteristics, there is minimal risk of modern slavery occurring in our supply chains.
Actions taken by DocuSign to assess and address those risks
We expect our suppliers to act with the utmost integrity and treat their employees fairly. Our supplier relationships are governed by written contracts which set out how we expect our suppliers to act and conduct themselves. We expect our suppliers to act with the upmost integrity and ensure that their employees and staff do the same. When we contract with a new supplier, we carry out due diligence on the supplier and make a comprehensive risk assessment in accordance with our Third Party Risk Policy. Our supplier relationships remain subject to ongoing review and we will not knowingly work with any business involved in (or suspected to be involved in) modern slavery or human trafficking.
Our policies and training
We have the following policies in place which reflect the robust governance of our business and the importance we place on adopting an ethical and legally compliant approach to business conduct as well as a diverse and safe workplace:
Third Party Risk Policy;
Anti-Harassment and Discrimination Policy;
Legal Compliance Policy;
Global Anti-Corruption Compliance Policy;
Employee handbooks (which are country-specific);
DocuSign’s Code of Business Conduct and Ethics (the “Code”); and
Whistleblower and Complaint Policy.
These policies are made available to our employees globally. Our Code and our Whistleblower and Complaint Policy exemplify our commitment to preventing human rights violations and actively encourage our employees to take issues of illegal and unethical conduct seriously and report in good faith all known and suspected improper activities. Our Code clearly states that we do not tolerate an abusive or harmful work environment and that this standard applies to our relations with our customers, partners, co-workers, and fellow community members around the world. We are committed to ensuring that the letter and spirit of our Code is upheld across our business and will continue to monitor and remedy violations if they should occur. We have prepared updates to our Code to specifically address issues in relation to modern slavery and to underline the importance of having a work environment that is free of slavery and human trafficking where our employees take these issues seriously and raise any concerns without fear of retribution or victimization, which we expect to become effective in the second half of 2020.
Our Whistleblower and Complaint Policy provides our employees with a confidential or anonymous avenue of communication for reporting any violations of the law or the company policies, including violations by third parties who provide services to our business. If employees become aware of any potential issues regarding modern slavery and/or human trafficking in either our own business or in that of our suppliers, the whistleblowing policy and procedures give employees the opportunity to safely raise these issues without fear of retribution or victimization.
Our employee handbooks also encourage our employees to uphold the highest standards of integrity and act in compliance with the law and our policies.
We provide all of our employees with training on our Code to ensure a unified approach to upholding DocuSign’s values. We also make training available to our employees on our other company policies and provide additional role-specific training.
Assessment of policies and practices and further steps
We recognise the need to continually review the effectiveness of our policies and practices in preventing slavery and human trafficking within the business and our supply chains. We do not currently have in place any key performance indicators to measure the effectiveness of the steps being taken but continue to monitor risks and continually develop and progress our approach.
As outlined above, we plan to further develop our anti-slavery and human trafficking framework by amending our Code in the second half of 2020 to include a statement expressly requiring our employees to take issues of modern slavery seriously and raise any issues or concerns they have in relation to issues of modern slavery within the business.
This Statement was approved on the date set forth below by the boards of directors of DocuSign UK Limited, DocuSign France SAS, DocuSign Canada Ltd., and (for the purposes of the Australian Act) by the board of directors of DocuSign International, Inc. The foregoing boards of directors have authorized Vivian Chow to sign this Statement on behalf of DocuSign in her capacity as a director of the DocuSign group entities making this Statement.
By: Vivian Chow, Director
Date: September 25, 2020