Vanta Modern Slavery Act Statement

Last Updated: May 08, 2024

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Introduction from the Chief People and Legal Officer

We, Vanta Inc. (with its direct and indirect subsidiaries, “Vanta”, “we”, “us”, “our”), are committed to improving our practices to combat slavery and human trafficking in our business and supply chain.  We do not tolerate or condone human trafficking or slavery in any part of our global organization or our supply chain.  This statement sets out how Vanta seeks to ensure that its operations and its supply chains are kept free of slavery and human trafficking (“Modern Slavery”). This statement is consistent with our internal Code of Conduct and our Handbook of Policies, and expresses our firm commitment to protect and advance human dignity and human rights in our global business practices.
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Our structure

Vanta is a software-as-a-service (“SaaS”) security and compliance platform designed to automate compliance, risk, and vendor reviews with one platform. We were founded to protect consumer data by making it easy to implement and prove industry-standard processes and protections. Vanta was founded in 2018, in the wake of several high-profile data breaches. Online security was only becoming more important, but we knew firsthand how hard it could be for fast-growing companies to invest the time and manpower it takes to build a solid security foundation. Vanta was inspired by a vision to restore trust in internet businesses by enabling companies to improve and prove their security.

Vanta Inc. has its head office in the United States and has over 450 employees worldwide and operates in five countries.
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Our supply chains

Typically, our major suppliers fall into one of the broad categories outlined below:

• hosting services providers and other SaaS providers who host and process our data and our customers’ data processed in our SaaS offerings;
• third-party consultants (including subcontractors) that we engage for services from time to time related to various work, including accounting work, legal counsel, IT applications, security, professional services; and
• service providers providing a range of services including relating to IT, travel, employee payroll, and maintenance.

Modern Slavery risks

We continually monitor our supply chain to identify partners or vendors that may pose a risk with respect to engaging in illegal activities and Modern Slavery. Generally, our assessment follows a specific number of principles:

• The type of services we engage in. As noted above, our business focuses on the provision of a SaaS platform. We do not manufacture our products and solutions in factories, nor do we engage third parties to perform any such manufacturing on our behalf.
• Rigor in our human resource processes. Our human resources processes ensure that those recruited have appropriate authorizations to work. We also verify legal age for employment prior to hiring.
• The nature of our usage of our outside contractors. Our usage of outside contractors for professional services or non-SaaS services is generally very limited. We do not consider the Modern Slavery risk in the provision of our professional or other non-SaaS services to be high.
• The nature of our largest vendors. As a SaaS company, our largest vendors typically consist of hosting and related cloud service providers. Our vendors also include providers of online advertising services and various professional services.
• The geographic locations in which we engage. As of the date of this statement, the majority of the number of jurisdictions in which our customers and suppliers are located are geographical locations in which we do not consider the risk of illegal activities such as Modern Slavery to be high.

In consideration of the nature of our operations and our supply chains, we consider the Modern Slavery risk presented to be low.
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Our policies on Modern Slavery

Despite our assessment that the Modern Slavery risk presented by our operations and supply chains is low, we have appropriate policies in place that underpin our commitment to ensure that there is no Modern Slavery in our supply chains or in any part of our business. We continuously review and update all our policies.

Our Code of Conduct reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. We also have the following policies in place relevant to modern slavery, which we continuously review and update:

• Whistleblower policy
• Workplace safety and security policies

Our business operations and policies uphold the principles of internationally recognized human rights. We respect human rights in the workforce, in our business operations, and in our supply chain. Our management, with the oversight of our Board of Directors, will take reasonable steps from time to time to monitor compliance with our Code of Conduct and impose and enforce appropriate disciplinary measures for violations of our Code of Conduct or other company policies.
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Due diligence processes for Modern Slavery

As part of our initiative to identify and mitigate risk we provide regular training on the employee handbook and Code of Conduct to our personnel. In support of efforts to eradicate Modern Slavery, we will provide training to key members of our sales and procurement teams on the importance of our partners reflecting our commitment against Modern Slavery.  We also have in place systems to protect whistle blowers.
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Supplier adherence to our values

We have zero tolerance to Modern Slavery. To ensure all those in our supply chain and contractors comply with our values and ethics we have in place a rigorous procurement process. This consists of review and approval of each procured vendor by authorized personnel from each of the teams below:

• Legal
• Finance
• Privacy and security
• Procurement

Our effectiveness in combating Modern Slavery

We use the following key performance indicators to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:

• Number of whistleblower complaints
• Number of high-risk countries in which we have employees
• Number of high-risk countries in which we have suppliers

Further steps

During the coming financial year, we will:

• continue to update our personnel training programs in line with best practices;
• continue to take steps where possible to ensure our operations and supply chains are and remain Modern Slavery-free; and
• monitor and review our assessment of the Modern Slavery risks our operations and supply chains present on a regular cadence.

This statement is made in accordance with the Australian Modern Slavery Act 2018 and the United Kingdom’s Modern Slavery Act 2015 and constitutes Vanta’s slavery and human trafficking statement for the financial year ending January 31, 2024.
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/s/ Ari Shahdadi

Ari Shahdadi, Chief People and Legal Officer

Vanta Inc.

Date: May 8, 2024

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