Modern Slavery Act Transparency Statement
Effective Date:February 2, 2024
For the financial year ending 31 December 2023
OPENING STATEMENT FROM SENIOR MANAGEMENT
At Pluralsight, we are committed to ensuring that our business and supply chain reflects our values, including respect for human rights. This commitment runs through our affiliates and subsidiaries (collectively, the “Pluralsight Group” or “Pluralsight”).
OUR ORGANIZATIONAL STRUCTURE, BUSINESS, OPERATIONS, AND SUPPLY CHAINS
The Pluralsight Group is a multinational technology workforce development organization that provides its customers with technology skills and engineering insights to help businesses and individuals deliver and quickly adopt new tools by building tech skills, benchmarking expertise across roles, and improving workflow efficiency using actionable data.
Pluralsight Europe Limited, A Cloud Guru, Ltd, Cloud Guru Group Ltd, and The Cloud Guru Ltd (collectively, the “UK Subsidiaries”) are the Pluralsight Group's UK subsidiaries. Pluralsight PTY Limited and Ephemeral PTY Limited (collectively, the “AU Subsidiaries”) are the Pluralsight Group’s Australian subsidiaries. All of these entities are wholly owned by Pluralsight, LLC, the primary operating entity for the Pluralsight Group. At year end, the Pluralsight Group employed 1,500 people throughout the world and at its regional offices in the United States, Ireland, Australia, and India. The Pluralsight Group sources goods and services from around the world including from the countries where Pluralsight has offices and utilizes services from expert technologists around the world.
Our key supply chains are made up largely of professional technology companies located primarily in the United States and the European Union that offer services via the cloud to support Pluralsight Group’s operations. The Pluralsight Group also engages a global network of technology experts to provide content and services to our customers. Lastly, the Pluralsight Group procures goods for use in its offices and among its employees, including furniture, computer equipment and accessories, branded gear, and food/beverage.
RISKS OF MODERN SLAVERY IN OUR OPERATIONS AND SUPPLY CHAINS
We are committed to identifying possible modern slavery risks in our operations and supply chains. We have considered four key factors that generally have been found to elevate the risk of modern slavery in operations and supply chains:
Sector and Industry Risks: As a technology workforce development organization, we understand that we are not in an identified high-risk sector or industry.
Product and Services Risks: While our cloud-based services are not considered high risk for modern slavery, we understand that the electronics that underpin our services including laptops, computers, and mobile phones are high risk for modern slavery.
Geographic Risks: While the United States, Australia, and Ireland are lower risk from a geographical perspective, we understand that India is higher risk due to socio-economic factors and less robust labor laws. Additionally, we hire employees and retain independent contractors in numerous other countries that may have less robust human rights or labor standards protections.
Entity Risks: The majority of our suppliers are professional technology companies and are leading specialist suppliers. We are not aware of any of our suppliers’ non-compliance with any human rights or labor standards.
We are committed to continuously improving our approach in identifying modern slavery risks in our supply chains and operations, including by undertaking risk assessments beyond our tier one suppliers in the future.
OUR ACTIONS TO ASSESS AND ADDRESS MODERN SLAVERY RISKS
Our policies in relation to slavery and human trafficking
As part of Pluralsight's commitment to combatting modern slavery and human trafficking, we have implemented the following policies:
A. Internal Policy
Pluralsight is committed to upholding fundamental human rights and we believe that all human beings around the world should be treated with dignity, fairness, and respect. We will only engage suppliers and direct contractors who demonstrate a serious commitment to the health and safety of their workers and operate in compliance with human rights laws. Pluralsight does not use or condone the use of slave labor or human trafficking; denounces any degrading treatment of individuals or unsafe working condition; and supports purchasing products that are free of conflict minerals.
This statement is included in Pluralsight’s Code of Business Conduct and Ethics.
B. Procurement Policy
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Pluralsight’s relationships with suppliers are based on lawful, socially responsible, and fair practices. We expect our suppliers to obey the laws and regulations that require them to treat workers fairly and provide a safe and healthy work environment.
Pluralsight requires vendors contractually to commit to ongoing compliance with the Modern Slavery Acts of 2015 (UK) and 2018 (AU) throughout our engagement (collectively, the “Acts”).
Pluralsight continues to evaluate and monitor our procurement practices, including the countries in which we transact, in alignment with our commitment to combat modern slavery and human trafficking.
C. Whistleblower Policy
Pluralsight has in place a whistleblowing policy that sets out the process for our employees to anonymously raise any concerns they may have in relation to compliance with our legal obligations and to ensure that there is adequate protection for employees who make protected disclosures or "blow the whistle."
D. Diversity and Belonging Report
Creating equal access to opportunity is fundamental to Pluralsight’s mission to advance the world’s technology workforce. Our commitment to growing a more diverse workforce and creating a place of belonging is reflected in our Diversity and Belonging Report, which is available here.
E. Our Due Diligence Process
We have taken steps to identify, assess, and monitor potential areas of risk in relation to our supply chains. Pluralsight requires that all vendors commit contractually to adherence to the Acts themselves and that they continue to do so throughout our engagement.
Pluralsight expects all contractors and suppliers, at a minimum, to comply with all applicable local laws and regulations in relation to working conditions and the treatment of workers. We also expect contractors and suppliers to operate their businesses ethically, ensuring that suppliers do not utilize forced, prison, or endangered labor, or subject workers to any form of compulsion or coercion.
F. Training
To ensure our employees are aware of the Acts and Pluralsight's obligations under those Acts, we share this statement with employees and a copy of this statement is available on our website. We train our team members to comply with our Code of Business Conduct and Ethics, which captures our expectation with respect to human rights and that our team members act with honesty and integrity, comply with applicable laws, rules and regulations, and report concerns of improper actions, wrongdoing, illegal or unethical activity. We also ensure that employees whose roles directly involve procurement of vendors or services are provided with additional training and reference materials, which further outline the signs and risks of modern slavery.
OUR APPROACH TO ASSESSING EFFECTIVENESS
We continue to develop our monitoring and reporting program to evaluate the effectiveness of our actions and to assess and address modern slavery risks in our operations and supply chains. This includes establishing processes to regularly review our actions and solicit regular feedback and engagement among key areas in Pluralsight.
LOOKING FORWARD
Following a review of the effectiveness of the steps we have taken this year to ensure that there is no modern slavery or human trafficking in our supply chains, we intend to take the following steps to combat slavery or human trafficking:
enhance our policies and procedures to mitigate the risk of modern slavery and human trafficking; and
enhance our due diligence process in relation to our supply chains.
OUR CONSULTATION PROCESS
The Pluralsight Group has communicated its commitment to and actions in combatting modern slavery to the relevant entities in our operations, including entities we own and control.
We have ensured that all relevant areas of the Pluralsight Group are aware of the actions needed to identify, assess, and address modern slavery risks in our operations and supply chains.
OTHER INFORMATION
Pluralsight One
Pluralsight One is our commitment to drive significant, lasting social impact by improving equal access to technology skills and investing in catalytic solutions. In addition to offering our products to qualified nonprofit organizations, we work with the Norwegian Refugee Council, Year Up, and the Malala Fund, among other organizations, to invest in the future of underserved, displaced, and vulnerable populations around the globe.
APPROVAL
This statement is made for the financial year ending 31 December 2023 and pursuant to:
section 54(1) of the UK Modern Slavery Act 2015 and constitutes Pluralsight, LLC’s and its UK Subsidiaries anti-slavery and human trafficking statement; and
the requirements of the Australian Modern Slavery Act 2018 (Cth) (the “AU Act”). However, as Pluralsight is not a ‘reporting entity’ for the purposes of the AU Act, it has not been formally submitted to the modern slavery register under the AU Act.
This statement has been approved by and signed on behalf of the Pluralsight, LLC Chief Compliance Officer and will be reviewed and updated on an annual basis.
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Matthew Forkner
Chief Compliance Officer
For and on behalf of Pluralsight, LLC