PER CASO D’USO
Citrix Systems, Inc. (NASDAQ: CTXS) (“Citrix”) 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.
This Statement has been prepared pursuant to the U.K. Modern Slavery Act and the Australian Commonwealth Modern Slavery Act and relates to the fiscal period from January 1, 2020 through December 31, 2020. Citrix operates in the United Kingdom through its subsidiary Citrix Systems UK Limited and in Australia through its subsidiary Citrix Systems Asia Pacific Pty Ltd, to whom this statement relates. This Statement describes Citrix’s group-wide modern slavery policies and compliance procedures since we have common policies and compliance procedures and the same modern slavery risks across our business.
As used in this Statement, “modern slavery” encompasses forced labor, prison labor, indentured labor, bonded labor, debt servitude, state imposed forced labor, human trafficking, child labor and other similar conduct commonly thought of as modern slavery.
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.
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 the risk of modern slavery in their performance for Citrix is low. 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 policies and compliance and other procedures discussed herein that are applicable to Citrix and/or its third party manufacturers to mitigate the risks of modern slavery 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.
We believe our principal risk of modern slavery is that forced labor could occur without our knowledge in violation of our policies in upper tiers of the supply chain.
Citrix has a risk based vendor due diligence program which, among other things, screens for certain labor violations.
Citrix’s standard contract and purchase agreement language requires our suppliers to act in a manner consistent with the standards set out in the Supplier / Partner Code of Business Conduct (the “Supplier Code”), which was rolled out in 2020. As indicated in the Supplier 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. Our Supplier Code is made publicly available on the Citrix website for all of our partners, vendors and customers to access. The Supplier 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 Supplier 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.
In addition to the Supplier 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. The standard purchase order terms and conditions, reiterates that all suppliers are required to act in a manner set forth in the RBA Code of Conduct. Citrix also includes a statement on all purchase orders to vendors requiring vendors to comply with our Supplier Code, which reminds vendors to comply with all applicable anti-human trafficking regulations.
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.
Other vendors may be required to comply with our terms and conditions and other contractual provisions, as described above.
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.
We assess the effectiveness of the actions being taken to assess and address modern slavery risks through ongoing engagement with our principal third party manufacturer, the findings of our vendor due diligence program and the number and type of complaints received through our grievance mechanism.
Citrix has mechanisms for its employees and third parties 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 modern slavery. 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.
Solely for purposes of compliance with the U.K. Modern Slavery Act, this Statement was approved by the board of directors of Citrix Systems UK Limited and signed by a director of that entity, in each case on June 15, 2021. A signed copy of this Statement is available upon request.
The Board of Directors,
Citrix Systems UK Limited
Citrix Systems Asia Pacific Pty Ltd (“Citrix Systems Asia”), an indirect wholly-owned subsidiary of Citrix with approximately 135 employees located in Australia and one employee in Thailand (where Citrix Systems Asia has a representative office), provides our products and services in the Asia Pacific (excluding Japan) market. Citrix Systems Asia does not own or control other entities. As earlier noted, we do not have our own manufacturing facilities and source physical products from third-party manufacturers. Citrix Systems Asia provides the same products and services in Australia as are provided by Citrix in other parts of the world and has the same supply chains and modern slavery risks as other Citrix companies. Citrix’s supply chain is discussed earlier in this Statement.
Solely for purposes of compliance with the Australian Commonwealth Modern Slavery Act, this Statement was approved by the board of directors of Citrix Systems Asia and signed by a director of that entity, in each case on June 1, 2021. A signed copy of this Statement is available upon request.
The Board of Directors,
Citrix Systems Asia Pacific Pty Ltd