Modern Slavery and Human Trafficking Statement

This Statement describes the actions taken by Upwork Inc. and its subsidiaries (“Upwork,” “we” or “our”) to prevent modern slavery and human trafficking in our operations and our supply chains pursuant to the UK Modern Slavery Act 2015.

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.

Upwork provides an online platform that enables businesses to connect with independent professionals and agencies for all their hiring and remote work needs and that enables independent professionals and agencies to market their services to prospective clients. Users of Upwork's platform, located at, may only use Upwork for remote, knowledge-based work, and payments must be made through the platform.

Because Upwork is only a platform and does not supply the services that are purchased on its platform, Upwork’s supply chain consists of the supplies and services that enable the operation of the platform itself and the provision of related services to the users that transact on its platform. Upwork engages employees, leased employees, and independent contractors to perform services for Upwork. 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.

In 2021, Upwork published a Global Human Rights Policy (the “Human Rights Policy”) to strengthen our commitment to human rights principles. The Human Rights Policy honors the International Bill of Human Rights and aligns with the Guiding Principles on Business and Human Rights, as well as the ILO Declaration on Fundamental Principles and Rights at Work. The Human Rights Policy directly applies to Upwork employees, members of our contingent workforce program, other consultants and independent contractors, officers, and members of the Board of Directors of Upwork.

The Human Rights Policy reiterates our commitment to the following principles:

  • We Do Not Tolerate Human Trafficking, Forced Labor, or Child Labor
  • We Support the Health and Safety of Our Workforce
  • We Do Not Tolerate Harassment
  • We Support Equal Opportunity and Do Not Tolerate Discrimination
  • We Recognize the Right to Freedom of Association and Collective Bargaining
  • We Enable Stakeholders to Raise Concerns and Do Not Tolerate Retaliation

In addition, Upwork’s Code of Business Conduct and Ethics (the “Code”) requires that its 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 also 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. In 2021, Upwork’s Board of Directors approved an updated version of the Code that included our expanded “Speak Up” program. 

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 the Code, and provides reporting procedures for employees 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, Upwork will reasonably investigate the matter and take appropriate action. Furthermore, if Upwork becomes aware that laws, rules or regulations have been violated, Upwork will cooperate fully with the appropriate authorities.

In 2021, Upwork created a Supplier Code of Conduct that outlines our expectations of suppliers with regard to human rights and fair labor practices. As the Supplier Code of Conduct states, Upwork expect 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: 

  • Enable employees to discontinue their employment freely upon reasonable notice;
  • Compensate their employees fairly and follow local wage regulations; 
  • Ensure that working hours, including overtime, do not exceed applicable legal limits;
  • 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.

In addition, Upwork’s standard vendor agreements require that vendors adhere to applicable laws, rules and regulations. Upwork conducts employment-related business due diligence regarding the operations of vendors that provide staffing services prior to engagement to ensure that such vendors have appropriate employment practices in place and comply with all employment laws and regulations.

Upwork reports on its efforts to assess and respond to human rights risks across our operations and supply chain in our annual impact reports, which can be found at Upwork’s ESG Reports Hub

The Upwork Inc. Board of Directors has approved this transparency statement for the fiscal year ended December 31, 2021 and delegated authority to sign it on their behalf to the Corporate Secretary.

Date: February 4, 2022


Brian Levey
Corporate Secretary