Citrix Systems, Inc (NASDAQ: CTXS) aims to power a world where people, organizations and things are securely connected and accessible to make the extraordinary possible. We help customers reimagine the future of work by providing the most comprehensive secure digital workspace that unifies the apps, data and services people need to be productive and simplifies IT’s ability to adopt and manage complex cloud environments. Citrix solutions are used by more than 400,000 organizations globally including 99 percent of the Fortune 100 and 98 percent of the Fortune 500.
Citrix operates in the United Kingdom through its subsidiary Citrix Systems UK Limited to whom this statement relates.
A substantial portion of our workforce consists of skilled labor. In addition, all employees hired by Citrix are subject to a background check.
Citrix also uses independent contractors. Because of the nature of the types of jobs performed by our independent contractors, we believe that there is no meaningful risk of modern slavery. Citrix generally uses placement agencies to source independent contractors. These agencies are selected following a standard sourcing process with defined business criteria.
Certain physical products are manufactured for us by a limited number of third parties. We do not have our own manufacturing facilities and, therefore, do not manufacture products directly. Generally, our third party manufacturers control the supply chain relationships for our physical products.
We have established compliance and other procedures discussed herein that are applicable to Citrix and/or its third party manufacturers to mitigate the risks of slavery and human trafficking in the supply chains for our products. Our approach is to focus on our direct suppliers since this is the level of the supply chain where we believe that we have the most influence and can therefore be the most effective.
Recently Citrix has recently undertaken a risk based vendor due diligence program which, among other things, focuses on certain labor violations.
Citrix includes a statement on all payment notifications to vendors, which provides a link to the UK Modern Slavery Act and reminds vendors to comply with all applicable anti-human trafficking regulations. Further, in our standard contract, Citrix requires its vendors to ensure that they have implemented appropriate and effective policies including monitoring, reviewing, training and auditing activities thereby ensuring both their and their subcontractors compliance with Modern Slavery legislation.
Citrix Code of Business Conduct
Our Code of Business Conduct (the “Code”) sets the standards of conduct for those working for or on behalf of Citrix. The Code is subject to regular review by the board of directors of Citrix Systems, Inc and is updated accordingly.
The Code provides that all employees should be treated with respect, and, more specifically, it states that Citrix is committed to adhering to applicable employment laws, including those relating to child labor, wages, hours and working conditions.
Our Business Partners
Our Code is made publicly available on the Citrix website for all of our partners, vendors and customers to access. As indicated in the Code, we are committed to working with socially responsible business partners that embrace high standards of ethical behavior and treat their employees fairly and with respect. The Code states that we will not do business with partners that do not comply with laws relating to child labor, wages, hours and working conditions. Furthermore, the Code provides that, if we learn that our vendors, contractors or consultants have acted in a manner inconsistent with our ethical standards, we will take appropriate action.
Additionally, Citrix’s standard contract and purchase agreement language requires its suppliers to act in a manner that is consistent with the standards set out in the Code.
In addition to the Code, Citrix is also a member of the Responsible Business Alliance (“RBA”) which has its own compliance code of conduct http://www.responsiblebusiness.org/standards/code-of-conduct (“RBA Code of Conduct”), which in turn provides that forced, bonded (including debt bondage) or indentured labor, involuntary prison labor, slavery or trafficking of persons shall not be used.
Citrix has mechanisms for its employees to ask questions or report concerns about possible violations of the Code, Citrix policies and laws. This would include any questions or concerns relating to slavery or human trafficking. Our Code has procedures and contact information for raising such matters, and we provide in our Code that retaliation will not be tolerated. Our website publishes this grievance mechanism to other stakeholders. Citrix also makes this information available to our channel partners through our Partner Central portal.
Supply Chain Engagement
As noted above, we use third party manufacturers to manufacture our physical products. Our principal third party manufacturer is both required and has indicated to us that it adheres to the RBA Code of Conduct and that it notifies its suppliers of their obligation to comply with the RBA Code of Conduct.
This third party manufacturer has indicated in writing that it takes steps to verify, evaluate and address risks of slavery and human trafficking in its supply chain. According to the manufacturer, the vast majority of its supplier contracts and purchase order terms contain language requiring suppliers to comply with the RBA Code of Conduct. The manufacturer also has indicated that it monitors compliance through self-assessment questionnaires completed by its suppliers. In addition, it has indicated that it performs audits that, among other things, cover slavery and human trafficking and, if deficiencies are found during an audit, it requires the supplier to develop and submit a corrective action plan.
We provide mandatory internal training intended to ensure that all our employees observe and understand the Code, the underlying policies, law and regulations and their applicability to our business.
In addition, our principal third party manufacturer has indicated that it provides training on forced labor and human trafficking to its employees.
This Statement is made pursuant to section 54 (1) of the Modern Slavery Act and constitutes our slavery and human trafficking statement for the financial year ending 31st December 2017. It has been approved by the applicable board of directors and signed by a director. A signed copy of this Statement is available upon request.
The Board of Directors,
Citrix Systems UK Limited