Modern Slavery Act

Introduction

This is the statement covering modern slavery, forced labor, and child labor (“Statement”) for RFPIO, Inc. d/b/a Responsive and its subsidiaries (collectively, “Responsive”). This statement has been prepared in compliance with global modern slavery and forced labor-related legislation including the UK Modern Slavery Act of 2015, the California Transparency in Supply Chains Act 2010, the Australian Modern Slavery Act 2018, and Canada Bill S- 211, which require that businesses disclose information concerning their efforts to address the risks of modern slavery and forced labor within their organization and in their supply chains. This Statement constitutes Responsive’s forced labor and human trafficking statement for Responsive’s fiscal year ending December 31, 2024.

Responsive  is dedicated to ensuring that the way we conduct our business reflects our values and our belief that everyone should be treated with dignity and mutual respect in an environment that is free from harassment and discrimination. We are committed to practices that combat modern slavery and human trafficking, and to working with and encouraging any suppliers to uphold the principles in this statement.

Our Business and Supply Chain

Responsive’s vision is to transform how organizations share and exchange information. This vision guides every solution we design, develop, and deliver.

Responsive is the global leader in Strategic Response Management (SRM). Our SaaS platform enables organizations to respond efficiently and accurately to RFPs, DDQs, security questionnaires, and vendor assessments. Our operations include Direct commercial relationships with enterprise customers worldwide, Strategic technology and service partners, and Procurement of third-party services and infrastructure from global vendors.

Responsive is a U.S. private corporation incorporated in Delaware, headquartered in Beaverton, Oregon. Responsive is governed by a board of directors. Responsive provides this joint statement for itself and on behalf of certain of its foreign subsidiaries, including RFPIO India Private Ltd (India), and Bidhive Pty Ltd (Australia). Responsive has one or more offices in each country where it has a subsidiary, and each local office has employees in that location. Responsive and its consolidated subsidiaries share the same core business operations and supply chains as well as modern slavery policies, processes, and risks further described in this statement.

Based on our business model, Responsive believes that the risk of modern slavery and forced labor in our business and supply chain is limited. Responsive does not manufacture a tangible product—rather, we sell subscription licenses to our cloud based software platform globally through both direct sales and via our partners. We recognize that the provision of services and goods within our offices is also part of our global supply chain, and all vendors who provide goods or services to Responsive go through our global vendor procurement processes, which are described in more detail below.

Assessing and Addressing Risks of Modern Slavery     

While Responsive is not at high risk for modern slavery in our business, we recognize that there is some risk present in every operation. Responsive is committed to ensuring that there is no modern slavery or human trafficking in any part of our business. As part of our initiative and to ensure compliance with the UK Modern Slavery Act 2015 (as amended) all directors, officers, and employees of Responsive shall act ethically and with integrity in all our business relationships and shall seek to to implement and enforce effective systems and controls to ensure slavery and human trafficking is not taking place. The Company has a zero-tolerance policy relating to slavery and human trafficking. All employees have been informed of the Company’s expectations regarding slavery and human trafficking and all those engaged in business with the Company are required comply with our values and the law. The Company has a responsibility to be alert to the risks of slavery and human trafficking in our business and in our work with third party vendors and suppliers. Thus, directors, officers, and employees are expected to report such concerns including, but not limited to, employment of human slaves, trafficked persons, forced or indentured labor, or workers subject to any form of coercion and management are expected to act upon any such concerns or reports. Further, all directors, officers and employees are expected to comply with the UK Modern Slavery Act 2015 as amended.

Code of Ethics and Business Conduct

Responsive is committed to recognizing and supporting human rights. Responsive strives to comply with all applicable laws and regulations governing our business. Our commitment to act with integrity in our business practices is memorialized in our Code of Ethics and Business Conduct (the “Code”), which provides guidance to our employees, officers, and board members (collectively, the “Responsive”) on the policies, laws, rules, and regulations they are expected to follow.

Under the Code, Responsive members who become aware of a potential violation of the Code have a responsibility to report it. Responsive offers reporting channels for Responsive team members who may have ethics concerns, and promotes them through internal policies, communications, and training. Those reporting channels include a web portal that allow users to report anonymously. Any allegations of forced labor will be investigated by our Legal Operations team in collaboration with Responsive’s Internal Governance, Risk, and Compliance (GRC) team, as needed, and under the direction and oversight of Responsive’s Senior Legal Director. Retaliation against any individual that reports a modern slavery concern in good faith is strictly prohibited.

We have created a Vendor Supplier Code of Conduct to hold our vendors to the minimum standards of behavior that we expect in relation to matters such as integrity and ethics, trade sanctions and export controls, human rights, labor standards, environmental standards, and a commitment to ensure compliance with global modern slavery-related legislation. Our Vendor Supplier Code of Conduct is included as a requirement in high-risk vendor contracts.

Training

Recognizing that it is important to educate Responsive members about the potential for forced labor in our supply chain, Responsive has provided guidance and training to all      employees, directors, and officers on the risk and the steps to be taken in the event an issue arises. 

Combating Modern Slavery 

Responsive is committed to continuously improving our efforts to combat modern slavery and forced labor in our operations and supply chain. In fiscal year 2025, we will focus on the following goals:

1. Continuing our modern slavery and human trafficking awareness creation for all employees: 
2. Continuing and strengthening our supply chain risk assessment, Responsive will initiate a supply chain risk assessment of our supply chain to identify potential modern slavery risks and develop a strategy to monitor and manage those risks.
3. Enhancing vendor accountability: Responsive will add our Vendor Supplier Code of Conduct into our standard vendor template agreement and it will be included in the onboarding process for new vendors.

Responsive will monitor and report on our progress in achieving these goals in our next Modern Slavery Act statement.

Conclusion

We believe that these goals will help us further mitigate the risk of modern slavery and forced labor in our business and supply chain, and we remain committed to upholding the highest standards of ethical conduct and human rights.

Approval and Signature

In accordance with the Act, this Statement is made by RFPIO, Inc. d/b/a Responsive by and on behalf of itself and its consolidated subsidiaries. This Statement was approved by the Board of Directors, and signed by Sankar Lagudu, Chief Operating Officer.

In accordance with the requirements of the Acts, I attest that I have reviewed the information contained in the report for the entity or entities listed above. Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above.