This Statement describes the actions taken by Upwork Inc. and its subsidiaries (“Upwork,” “we” or “our”) during the fiscal year ended December 31, 2024 (the “Reporting Period”) to prevent modern slavery and human trafficking in our operations and our supply chains pursuant to the UK Modern Slavery Act 2015 and the Australian Modern Slavery Act 2018. In order to prepare this statement, Upwork Inc. consulted with the entities that it owns or controls.
Upwork provides an online marketplace that enables businesses to connect with independent professionals and agencies for all their hiring and remote work needs. On Upwork, talent markets their services directly to prospective clients. Businesses and professionals use Upwork for remote, knowledge-based work, and payments must be made through the platform.
Upwork operates primarily in the United States, with an office in California. As of December 31, 2024, Upwork had approximately 600 employees, nearly all of which are based in the United States, and throughout the Reporting Period, Upwork engaged approximately 2,200 contingent workforce team members through its work marketplace to provide services on a variety of internal projects. These remote freelancers were highly skilled knowledge workers based in 90 countries. Independent professionals who use Upwork’s work marketplace to engage our clients are neither employees nor suppliers of Upwork.
The majority of our direct suppliers are based in the United States and provide goods and services (e.g., software products, legal services, advertising support) with a low modern slavery risk. Upwork does not outsource significant operations to agencies or other entities that engage workers on behalf of Upwork without Upwork having visibility into such arrangements.
Upwork is opposed to all forms of human trafficking, slavery, servitude, child labor, forced or compulsory labor and all other trafficking-related activities. We are committed to (i) fully complying with all applicable labor and employment laws, rules and regulations, and (ii) working to mitigate the risk of human trafficking in our business and supply chains.
Based on the nature of our business, our geographical footprint, and the limited goods and services we procure, we believe that our operations are low risk with respect to modern slavery and human trafficking practices. Our workforce is primarily made up of skilled employees and freelancers, which further supports our low-risk profile. However, we recognize that most organizations have a risk of modern slavery, if not in their direct operations, then further down their supply chain. Areas that could represent a higher risk of modern slavery for Upwork include our procurement of electronic products, such as laptops, computers, and mobile phones, which may be manufactured from resources extracted in countries where forced labor and human trafficking is common.
Our Human Rights Commitment (our “Commitment”) clarifies our commitment to human rights and describes our efforts to address possible human rights risks across our operations, supply chain, and work marketplace. Our Commitment honors internationally recognized human rights principles and outlines our expectations of our team members and suppliers. Our Commitment outlines our expectations of our customers, both the clients and independent talent that use Upwork, and the steps we are taking to build a work marketplace that reduces human rights risks and actively supports trust and safety. We also clarify our commitment to use and develop technology responsibly and to effectively govern and implement the commitments included in the statement in everything we do.
In addition, Upwork’s Code of Business Conduct and Ethics (the “Code”) requires that our employees, independent contractors, officers and directors obey the law while performing work for Upwork and comply with U.S. laws, rules and regulations governing the conduct of business by U.S. citizens and corporations outside the United States. The Code contains a specific requirement that Upwork and its employees comply with all applicable environmental, health and safety laws and regulations. Upwork trains all employees and officers and certain independent contractors in Code policies as part of the onboarding process. Upwork’s Whistleblower Policy and Speak Up program indicate that Upwork expects its employees to internally report concerns about activity that is unlawful or otherwise violates Upwork’s policies, including our Commitment and the Code, and provides reporting procedures for team members who wish to anonymously submit a concern or complaint regarding such matters. The Code includes reporting procedures and provides for protection against retaliation for those making a report. If Upwork becomes aware of a violation of its policies, including our Commitment and the Code, Upwork will reasonably investigate the matter and take appropriate action, which can include required training, warnings, and/or employment termination. Furthermore, if Upwork becomes aware that laws, rules or regulations have been violated, including human rights laws, Upwork will cooperate fully with the appropriate authorities.
Upwork’s Supplier Code of Conduct further clarifies our expectations of suppliers with regard to human rights and fair labor practices and shares the specific steps we’re taking to assess human rights risks across our supply chain.
As the Supplier Code of Conduct states, Upwork expects that suppliers will prohibit and take steps to avoid all forms of human trafficking, slavery, servitude, child labor, forced or compulsory labor, and all other trafficking-related activities within their value chains. Among other practices, the Supplier Code of Conduct states that suppliers will:
- Ensure that they do not employ any persons under the legal age of employment as per ILO Convention 138;
- Enable employees to discontinue their employment freely upon reasonable notice;
- Compensate their employees fairly and follow local wage regulations;
- Follow all applicable laws and regulations with respect to working hours and days of rest, at a minimum, and ensure that overtime is voluntary and that workers paid on an hourly basis do not exceed 60 hours per week, except in emergency or unusual situations;
- Respect employees’ right to freely associate and collectively bargain;
- Practice fair and proper hiring, firing, and evaluation practices and provide employees’ access to their identity or immigration documents, such as government-issued identification, passports, or work permits; and
- Engage their suppliers to minimize and respond to human rights risks and/or violations.
Upwork’s standard vendor agreements require that vendors adhere to applicable laws, rules and regulations.
During the Reporting Period, Upwork joined the UN Global Compact as a “Signatory member,” committing to responsible business practices and annual reporting related to human rights, labor, environment, and anti-corruption. We also conducted employment-related business due diligence regarding the operations of suppliers that provide staffing services prior to engagement to ensure that such vendors had appropriate employment practices in place and complied with all employment laws and regulations. To assess and manage human rights risks across our supply chain, Upwork evaluates the human rights commitments and employment practices of our suppliers. We do this through our Request for Proposal (RFP) exercises and through an annual supply chain risk assessment, led by our Sustainability and Impact team. Suppliers are expected to provide reasonable assistance to any investigation or audit by Upwork, including of an alleged or suspected violation of our Supplier Code of Conduct. Where human rights risks or evidence of human trafficking is found in our supply chain, Upwork will engage relevant suppliers to manage said risks and/or terminate the business relationship.
Upwork reports on its efforts to assess and respond to human rights risks across its operations and supply chain in its annual impact reports, which can be found at Upwork’s ESG Reports Hub.
This statement was approved by the Board of Directors of Upwork Inc. in their capacity as the principal governing body of Upwork Inc. on February 5, 2025.
Date: February 6, 2025
UPWORK INC.
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Brian Levey
Corporate Secretary